January 25, 2019 Secretary Matthew A. Beaton, Executive Office Of

Charles D. Baker Matthew A. Beaton Governor Secretary

Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner

January 25, 2019

Secretary Matthew A. Beaton, RE:FEIR Review #15787 Executive Office of Energy & BARNSTABLE. Final Environmental Environmental Affairs Impact Report Vineyard Wind Connector 100 Cambridge Street, Suite 900 Barnstable and Yarmouth Attention: MEPA Unit – Purvi Patel Boston, MA 02114

Dear Secretary Beaton,

The Massachusetts Department of Environmental Protection (MassDEP) has reviewed the Final Environmental Impact Report (FEIR) for the proposed Vineyard Wind Connector, located approximately 14 miles southeast of Martha’s Vineyard, with export cables running from the Federal/Massachusetts water boundary, northerly to make landfall at Covell’s Beach in Barnstable and onto the Barnstable Switching Station, Barnstable or, alternatively, from the Federal/ Massachusetts water boundary to make landfall at New Hampshire Avenue in Yarmouth, Massachusetts. The comments below address impacts to State-regulated waters and anticipated permitting requirements. Some of these comments also apply to project components located in Federal waters, including, but not limited to, comments regarding invasive species, cable installation best management practices, and long-term monitoring methodologies.

Project Description

Vineyard Wind LLC, the Proponent, is in the process of permitting an up to approximately 800- megawatt (MW) offshore wind project in an offshore lease area in federal waters under the jurisdiction of the Bureau of Ocean Energy Management (BOEM). Major elements will include a wind turbine array, offshore electrical service platforms, offshore transmission to shore, onshore underground transmission, and an onshore substation that will step down transmission voltage for interconnection with the electrical grid. All proposed elements will be subject to review under federal permitting and the BOEM process. Massachusetts reviews, including those by the Energy Facilities Siting Board (EFSB) and other state, regional, and local entities, will focus on the elements proposed within state boundaries, including most of the offshore export cables, all the onshore underground cables, and the proposed onshore substation.

This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 MassDEP Website: www.mass.gov/dep Printed on Recycled Paper

Bureau of Water Resources Comments

Wetlands and Waterways: The MassDEP Wetlands and Waterways Program has reviewed the FEIR and has the following comments:

The Program supports the proposal of Vineyard Wind LLC to use proven installation techniques to deepen the export cable and avoid hard and complex seafloor to the maximum extent possible in order to avoid or minimize impacts to natural resources and marine habitats. MassDEP discourages cable protection using rock placement, concrete mattresses, or other protective methods due to their detrimental impacts to biological resources and marine habitat.

Dredging Pursuant to 314 CMR 9.07(2)(b)(5), proponents for projects involving the dredging of over 10,000 cubic yards are required to develop a project-specific sampling and analysis plan (SAP). The plan is required to be submitted in draft form to MassDEP for review and comment as part of the pre- application process. The FEIR states that the submarine cable will be installed using either jetting by jet-plow or mechanical trenching to minimize the area of dredging and direct seafloor impact. For the installation of the two cables, total dredging could impact up to 69 acres (279,400 m 2) and could include up to 214,500 cubic yards (164,000 cubic meters) of dredged material. For the cable installation within state waters, volumes of sand wave dredging and appurtenant volumes of sediment fluidized in–trench will vary, depending on which route and dredging methods are selected. The final proposed dredging method and total dredge volume should be provided as part of the MassDEP 401 WQC/Chapter 91 License/Permit application.

Due to the scale of the dredging operation, sediment plumes are expected. It is essential that the Proponent monitor the turbidity (and total suspended solids, if appropriate) within both the construction/dredging corridor and the immediate area beyond the work corridor. There will be impacts from turbidity and sedimentation to biological resources and their habitats. Dredging of sand waves will directly impact organisms within and adjacent to the dredge footprint. Although sediment dispersion and turbidity impacts to water quality during installation and cable-laying might be minor due to limited duration and small work area, it is recommended that the Proponent adopt Best Management Practices to reduce turbidity as much as possible during construction. After the final installation route is identified the following actions should be taken by the Proponent: (1) collection of pre-installation data such as grain size composition; (2) substrate type, and bathymetric data along the installation route; (3) monitoring of the sediment plume and water turbidity during cable installation; and (4) documentation of changes in sediment composition and bathymetry mapping. A long-term monitoring plan will be required to document any changes to the sediment profile in order to assess habitat recovery.

Dredging of the top portion of sand waves may be necessary to allow the cable installation tool to reach the stable sediment layer under the base of the mobile sand unit/habitat. The impact to the habitat is assumed to be minimal and short in duration because the disturbed bedform will evolve back to its original morphology as a result of prevailing tidal forces and associated sand migration. The Proponent should provide an estimated time period expected for the natural restoration of the ocean bottom morphology based on the best available information or experience. 3

Horizontal Directional Drilling (HDD) The Project plans to install two approximately 1,000-foot-long conduits via horizontal directional drilling (HDD) to bring the two offshore export cables onshore. The preferred transition site from offshore to onshore is the paved parking lot at Covell’s Beach in the Town of Barnstable. The use of HDD to transition the submarine cables from offshore to onshore can minimize impacts to marine habitats and natural resources within intertidal areas. The HDD design at Covell’s Beach is proposed to angle eastward from the beach to avoid impacts on eel grass, hard bottom, and complex habitats. The Covell’s Beach route in Barnstable appears to be the preferable landfall option for cable routing because it will allow the Project to avoid impacts to rare species habitat, eelgrass, coastal dunes, the beach, near shore area, and tidal zone.

Cable Installation The offshore cables will be buried using a jet plow, mechanical plow, and/or mechanical trenching, as suited for the bottom type in the immediate area. Dredging may be necessary in some areas, especially where large sand waves occur. The 401 WQC/Chapter 91 License/Permit application should provide more detailed information on why and how cable installation tools can further minimize dredging and the impact to benthic organisms.

Long-Term Natural Resource Monitoring Vineyard Wind LLC has committed to performing post-construction monitoring to examine the disturbance and recovery of coastal and benthic habitats in the Proposed Action area. As stated in the FEIR, impacts and recovery times will vary dependent upon habitat types. These habitat types can generally be separated into the high-energy oceanic environment versus the low-energy estuarine environment. However, more detailed information such as monitoring frequency on recolonization and succession of benthic communities among different habitats is not clearly described in the long-term monitoring plan. A more detailed sampling and analysis plan (SAP) must be developed and included in the 401 WQC application. A monitoring plan should also be provided to assess the impacts following the removal or decommission of all installations.

Long-Term Invasive Species Monitoring The FEIR states that the Project may have possible long-term beneficial effects on biological communities. Although possible, these newly created habitats may also facilitate the establishment and spread of invasive species. Invasive species are considered to be one of the greatest threats to biodiversity resulting in severe ecological and economic damage. In coastal New England, invasive tunicates have become an emerging issue (Colarusso 2018) 1 . Alterations to near-shore ocean-bottom morphology and off-shore new artificial structures will create hard substrate for invasive species colonization with the potential for impacts to commercial and recreational fishing operations. Warming ocean and coastal waters and species range expansions influenced by climate change will further compound these issues (Eberhardt et al. 2015) 2.

Therefore, a systematic monitoring plan for potential marine invasive species colonization should

1 Colarusso, P. 2018. Impacts of Invasive Tunicates on Eelgrass. Northeast Panel on Aquatic Nuisance Species Fall Meeting. Portsmouth NH. December 3 to 4, 2018 2 Eberhardt, A., J. Pederson and B. Bisson. 2015. Rapid Response Plan for Management and Control of the Chinese Mitten Crab - Northeast United States and Atlantic Canada. New Hampshire, MIT and Maine Sea Grant Programs. 4 be developed prior to commencement of the Project. Corresponding appropriate management actions should also be adopted to control colonization of invasive species in these artificial habitats

Baseline Data Because a SAP requires approval from MassDEP per 314 CMR 9.07(2)(5), it is recommended that all pre-construction data (baseline data) be submitted, or collected as needed and submitted, to MassDEP as part of the 401 WQC application. This information is required in the 401 WQC permitting process to ensure the Project meets the state water quality standards to avoid, minimize, and mitigate impacts to biological communities and their habitats. Both raw data and secondary data are welcome. These data include but are not limited to the 2018 Marine Habitat Survey, Eelgrass, Benthic Community, Fisheries. Electronic data format such as Access or Excel is preferred and will be helpful in facilitating the 401 WQC review process. We encourage the Proponent to discuss appropriate data collection and analysis methodologies with MassDEP during the development of any data collection plan.

Bureau of Waste Site Cleanup Comments The Proponent has adequately addressed the comments raised by the Bureau of Waste Site Cleanup.

Other Comments/Guidance MassDEP staff is available to provide additional guidance to the Proponent upon request. Questions pertaining to the 401 WQC/c.91 permit review process can be directed to Michael Stroman at [email protected] or 617-292-5526 or David Wong at [email protected] or 617-292-5893. If you have any other questions regarding this comment letter, please do not hesitate to contact George Zoto at either [email protected] or 508-946-2820.

Very truly yours,

Regional Engineer, Bureau of Water Resources

JH/GZ

Cc: DEP/SERO

ATTN: Millie Garcia-Serrano, Regional Director and Acting BAW Deputy Regional Director David Johnston, Deputy Regional Director, BWR Gerard Martin, Deputy Regional Director, BWSC Jennifer Viveiros, Deputy Regional Director, ADMIN Lealdon Langley, Director, Wetlands and Wastewater Program Jim Mahala, Chief, Wetlands and Waterways, BWR David Hill, Wetlands and Waterways, BWR 5

David Wong, Wetlands and Waterways, BWR/Boston Michael Stroman, Chief, Wetland and Waterways, BWR/Boston Allen Hemberger, Site Management, BWSC

Commonwealth of Massachusetts Division of Marine Fisheries 251 Causeway Street, Suite 400 Boston, Massachusetts 02114 (617) 626-1520 David E. Pierce, Ph.D. Director fax (617) 626-1509 Charles D. Baker Governor Karyn E. Polito Lieutenant Governor January 25, 2019 Matthew A. Beaton Secretary Secretary Matthew A. Beaton Ronald Amidon Executive Office of Energy and Environmental Affairs (EEA) Commissioner Mary-Lee King Attn: MEPA Office Deputy Commissioner Purvi Patel, EEA No. 15787 100 Cambridge Street, Suite 900 Boston, MA 02114

Dear Secretary Beaton: The Division of Marine Fisheries (DMF) has reviewed the Final Environmental Impact Report (FEIR) by Vineyard Wind LLC for the Vineyard Wind Connector project. The proposed cable routes would link the Vineyard Wind offshore wind array and associated cables in federal waters to the onshore Barnstable Switching Station. The FEIR identifies Covell’s Beach in the Town of Barnstable as the preferred Landfall Site with the New Hampshire Avenue landfall now listed as an alternative. The FEIR identifies that two cables will be emplaced. The FEIR includes two potential cable routes through Muskeget Channel (eastern and western routes), and proposed cable length, dredging, and benthic impacts would vary between both offshore cable routes and landfall alternatives. DMF previously provided comments on the Supplemental Draft Environmental Impact Report (SDEIR) in a comment letter dated October 3, 2018. Our current letter, which is also informed by BOEM’s Draft Environmental Impact Statement (DEIS) and the Construction and Operations Plan (COP) from October 2018, follows up on these previous comments and further describes information needed to assess impact.

Landfall Alternatives  DMF supports the Covell’s Beach cable landfall route as the preferred alternative to the New Hampshire Avenue landfall given the variety of sensitive resources within Lewis Bay that would potentially be impacted by cable installation (e.g., winter flounder, horseshoe crabs, shellfish). The Covell’s Beach alternative avoids sensitive estuarine habitat entirely and can avoid impacts to any nearshore resources through horizontal directional drilling (HDD) installation.

Eelgrass  The FEIR adequately documents the distribution of eelgrass along the proposed cable routes and provides an appropriate avoidance strategy for eelgrass identified off of Covell’s Beach.  Our primary concern is that contractors do not damage vulnerable seafloor areas that are being avoided by cable routing. Damage to these areas could occur via anchoring, grounding, prop wash, etc.

Fish and shellfish  Cable burial can result in direct impact to shellfish, conch, and squid eggs. April, May, and June is a time period of very high activity for most fisheries resources in Nantucket Sound. We continue to

recommend avoiding cable laying during this time period. Vineyard Wind states, “the period of April-June [is] the preferred offshore export cable installation timeframe” (FEIR p. 6-40). We understand Vineyard Wind’s preference because good weather maximizes opportunities for cable laying with fewer weather interruptions. Nevertheless, DMF always prefers and stresses environmental alteration projects to avoid times when fisheries are most active, i.e., spring and summer. We recommend cable laying occur from March into April with May and June being avoided. However, if our preferred option cannot be selected, we recommend Vineyard Wind factor its preference into its mitigation package being developed for the Commonwealth’s affected fisheries and the resources themselves.  The FEIR still fails to provide an adequate electromagnetic field (EMF) impact assessment report. The response to our SDEIR comments included relevant information regarding EMF. However, since the issue of EMF impacts is a high priority for many stakeholders, these specific responses to comments in the SDEIR should not act as a substitute for an impact assessment. It is imperative that a cohesive report is provided that describes how the proposed burial depth adequately minimizes risk to EMF-sensitive species. This report should include appropriate modeling and references; it should identify the particular EMF sensitive species of greater concern in Nantucket Sound (e.g., skates and flounder); it should describe what is known from 220 kV AC cables that “are used routinely for offshore wind projects in Europe,” (FEIR p. 6-33); and it should identify key areas of uncertainty in the assessment.  Cable shielding and burial are the primary means of minimizing electromagnetic field impacts (COP Vol 3 Ch. 6). The COP states that Cable Inspection/Repair is planned for eight surveys over the Project's lifespan (Years 1,2,3,6,9,12,15, and 20) (COP Vol 1, page 4-47). We recommend including in the cable conduits continuous monitoring mechanisms that can verify cable burial (such as temperature monitoring). If continuous monitoring cannot be done, then geophysical surveys should occur more frequently and always after major storm events such as hurricanes and nor’easters.  A study to confirm assumptions made in the EMF impact assessment is recommended as part of the pre- and post- fisheries resource monitoring plan that Vineyard Wind has committed to but has not yet defined.  We have not identified concerns with the sediment dispersion modeling or impact thresholds used; and the description of the burial thresholds used is adequate in the FEIR. If the New Hampshire Avenue landfall ends up being used, we will revisit this impact assessment and the resource characterizations since the risk for sedimentation impacts in Lewis Bay is high.

Fisheries  Closures around the cable laying vessel will be required per USCG regulations. The FEIR does not commit to simultaneous lay and burial with a jet plow, so it is conceivable that a cable laid on the seafloor is protected via a closure until it is buried. This could have adverse impacts on fishing access and depending on the specific time of year and the length of the closure these impacts could be severe.  Communication methods should include ensuring that all vessels have up-to-date information regarding construction activities and the location of the cable. We are generally satisfied with Vineyard Wind’s fisheries communication plan and outreach efforts, and as further details regarding scheduling and impacts emerge, we will continue to provide assistance in developing effective communication protocols.  Vineyard Wind has reached out to many stakeholder groups to solicit feedback. We appreciate the applicant’s interest in keeping the results of these meetings and their attendees confidential, yet continue to press for more information regarding how project decisions have been influenced by fishermen’s feedback. For example, Vineyard Wind states, “The period of time when the Offshore Export Cable Corridor may experience localized impacts on fish resources and fishing activity will be a matter of only a few months and will be located within limited geographic areas relative to the much larger fishing grounds utilized by commercial fishing vessels in the region” (FEIR p. 3-8).

 However, some fisheries are very territorial, and in fact have more limited fishing area than may be apparent. All are dependent on resources that can be unevenly distributed spatially. Support for this statement from fishermen in Nantucket Sound would be a beneficial outcome of their outreach efforts. More generally, we recommend a much more comprehensive and transparent documentation of how outreach has informed various project development decisions including siting, construction, and operations. It is our objective to maximize compatibility of the offshore wind industry with the recreational and commercial fishing industries (DMF 2018).  Vineyard Wind recently has described how the orientation of the turbines in the WDA responded to fishermen’s input and/or data analysis of VMS, fishermen-provided data, and assessments of the federal trawl survey tow patterns. While we understand the timeline of the project prevents reconfiguration at this time, there is potential that this alignment may require alteration of trawl survey tows, changed fishing practices and exacerbate loss of fishing in these grounds. For this reason we recommend impacts on fishing be factored into the Vineyard Wind mitigation package.  Vineyard Wind states that “proposed mitigation measures and careful siting of the cable will further minimize fishing impacts” (FEIR p. 3-7) but it is unclear what mitigation measures they are referring to. Also, we are uncertain how the cable siting process has addressed fishing impacts.  It has not been reported if construction methods have been discussed with fishermen. Such outreach can identify how scheduling can adapt to periods of high/low fishing activity, aid in the identification of unique areas along the cable corridor, and determine optimal communication strategies during construction and post-construction.  A comprehensive mitigation strategy to address snags, lost revenue, and other potential impacts to the fishing industries operating in this area and in the wind development area still has not been established. We understand it is being developed, and DMF will contribute to its development and review that suggested mitigation when finally presented for consideration.

Monitoring  We received a hard drive with the benthic data generated by Vineyard Wind from 2016 to 2018. We are in the process of reviewing it to ensure compatibility of all data files.  The FEIR references a fisheries monitoring plan in development with SMAST and stakeholders, but does not provide any details of the draft plan for review. In order to ensure the adequacy of the proposed plan, particularly with regards to a limited window for pre-construction monitoring, DMF feels that a draft monitoring plan should have been included with the FEIR.  The proposed benthic monitoring plan is inadequate both in terms of sample sizes and collection methods to assess any potential changes following cable installation. The plan needs to be fully revised with guidance from the agencies. More detailed comments are attached.  Environmental Management System – this is referred to in the COP (Vol 1, page 4-1) but the EMS is not provided, and it is not stated if it will be used to evaluate contractors. Our primary concern is that contractors do not damage vulnerable seafloor areas that are being avoided by cable routing. Damage to these areas could occur via anchoring, grounding, prop wash, etc. The identification of these areas and ensuring contractors are avoiding these areas is important. We also want to ensure that the maximum efforts are taken to reduce the risk of at sea disposal of contaminants including grouts, HDD fluids, plastics, and oils.

Questions regarding this review may be directed to Dr. Kathryn Ford or Dr. John Logan in our New Bedford office at (508) 742-9749 or (508) 742-9722.

Sincerely yours,

David E. Pierce, Ph.D. Director

cc: Yarmouth Conservation Commission Barnstable Conservation Commission Conrad Caia, Yarmouth Shellfish Constable Karl Van Hone, Yarmouth Director of Natural Resources Dan Horn, Barnstable Shellfish Constable Rachel Pachter, Vineyard Wind Michael Pentony, Sue Tuxbury, NOAA Julia Livermore, RIDEM Lisa Engler, Robert Boeri, Todd Callaghan, CZM Brian Hooker, BOEM Tim Timmerman, EPA Ronald Amidon, Richard Lehan, DFG Bruce Carlisle, CEC Terry O’Neil, Tom Shields, Mike Hickey, Kathryn Ford, Mike Pol, Kelly Whitmore, Erin Burke, Catherine O’Keefe, John Logan, Ryan Nuttall, MA DMF DP/KF/JL/KW/sd

References MA DMF (2018) Recommended regional scale studies related to fisheries in the Massachusetts and Rhode Island-Massachusetts offshore Wind Energy Areas. Report to the Massachusetts Fisheries Working Group. 57 pp.

Attachment  As proposed, monitoring would only be conducted at two sites for any given habitat type along the cable route and within the WDA. The monitoring plan notes that two sites will be monitored per habitat type “to ensure reliability in conclusions and increase statistical power of the data” (FEIR D-2), but does not provide any further support for the proposed sampling. The Franco et al. (2015) study1 cited as support for the two site per station sample size concludes, based on analyses of monitoring efforts in European wind farms, that five (benthic species abundance) to ten (biomass) stations may be required to detect a 50%

1 Franco A, Quintino V, Elliot M (2015) Benthic monitoring and sampling design and effort to detect spatial changes: a case study using data from offshore wind farm sites. Ecol Indic 57:298–304

change. The Vineyard Wind benthic monitoring plan should be designed to have greater statistical power as changes less than 50% would certainly still represent biologically- relevant changes to the benthic community. The study further notes that “a much higher sampling effort would be required with 10 to 15 stations per area required to assess 10% changes in species richness, 15 to 20 stations for abundance and 20 to 50 stations for biomass, depending on data transformation.” The revised benthic monitoring plan should provide a power analysis to justify the proposed number of sampling stations and sub- samples (i.e., individual benthic grabs) per station following a BACI design.  We have concern regarding the exclusive use of towed video monitoring and benthic grabs for epibenthic species (specifically when including larger invertebrates such as whelk and horseshoe crab), as indicated in the response to DMF comment “DMF-34.” Video monitoring is a qualitative approach. It also does not adequately assess species that bury diurnally, such as whelk, or move in response to bow wakes of towed or dropped camera sleds. Difficulty estimating areal coverage, identification of species from inherently low-resolution images, and the inability for replication preclude its use as quantitative assessment tool. Methods (Attachment F) indicate presence and general characterization of epibenthic invertebrates, but offer no methods for how species’ densities would be quantified. Quantitative approaches should be added to the assessment regime in addition to the presence/absence information that may be acquired through video work, as presence/absence of species in a region is not an adequate measure of change following cable installation.

From the MA DMF letter to the BOEM Draft Environmental Impact Statement:  Benthic Habitat Monitoring Plan (COP Vol 3 App 3). The BACI approach seems appropriate but needs additional detail and samples taken along a gradient of distance from the impact site would be very useful to answer the question “What is the distance of detectable habitat changes?” (MA DMF 2018).  The benthic stations where infauna are being sampled should also be sampled for grain size. SPI images should be taken pre- and post-construction.  The entire cable pathway should be re-imaged with multibeam post-construction; that data should be incorporated in a post-construction impact analysis.  Similarly, studies focused on scour can be combined with benthic habitat assessments.  Video surveys should use high resolution video and be georeferenced.  The timeline of sampling, including the season, should be clarified.  The specific impact/recovery assessment metrics included are abundance and community composition of infauna, presence/absence of lobster and crabs, shellfish, evidence of burrowing activity, and changes in surface features.  The benthic monitoring plan needs additional detail with respect to how change will actually be measured and may need additional sampling stations for a quantitative assessment. The plan should state the hypotheses being tested. The plan identifies reports as the primary product; we recommend all data be made available in regional database management systems.

January 28, 2019

Matthew A. Beaton, Secretary Executive Office of Energy and Environmental Affairs Attention: MEPA Office Purvi Patel, EEA No. 15787 100 Cambridge St. Boston, Massachusetts 02114

Project Name: Vineyard Wind Connector Proponent: Vineyard Wind LLC Location: Cable connection (from offshore wind project within federal waters) through Massachusetts waters northerly through Nantucket Sound to Covell’s Beach, Barnstable or New Hampshire Ave, Yarmouth with onshore underground cables to Barnstable Switching Station. Project Description: Utility – Transmission Cables from offshore Wind Energy Generation Document Reviewed: Final Environmental Impact Report EEA File Number: 15787 NHESP Tracking No.: 17-37398

Dear Secretary Beaton:

The Natural Heritage & Endangered Species Program of the Massachusetts Division of Fisheries & Wildlife (the Division) has reviewed the Final Environmental Impact Report (FEIR) for the proposed cable connection through Massachusetts waters northerly through Nantucket Sound to Covell’s Beach (Barnstable) or New Hampshire Avenue (Yarmouth) as well as onshore underground cables to a new Barnstable Substation. The proposed cable connection will facilitate a proposed 800 MW offshore wind project within federal waters. The Division would like to offer the following comments regarding state- listed species and their habitats.

Renewable energy sources such as wind power are a necessary component of a future, sustainable energy portfolio. Although an important emission-free energy source, wind power generation can have unintended impacts, particularly upon avian species. Thus, wind generation must thoroughly assess potential impacts, have comprehensive planning and review during the permitting process, and detail an adaptive management strategy to avoid, minimize and mitigate these potential impacts.

Components of Vineyard Wind Connector will occur within areas mapped as Priority Habitat and Estimated Habitat for state-listed species, including Piping Plover (Threatened), Roseate Tern (Endangered), Common Tern (Special Concern), and Least Tern (Special Concern) according to the 14th Edition of the Massachusetts Natural Heritage Atlas. The Piping Plover and Roseate Tern are also listed as Threatened and Endangered, respectively, pursuant to the U.S. Endangered Species Act (ESA, 50 CFR 17.11). These species and their habitats are protected pursuant to the Massachusetts Endangered

Species Act (M.G.L c. 131A) and its implementing regulations (MESA, 321 CMR 10.00) as well as the rare wildlife provisions of the Massachusetts Wetlands Protection Act and its implementing regulations (WPA, 310 CMR 10.37, 10.58(4)(b) and 10.59).

Cable Installation: Vineyard Wind Connector, which includes those components of the project that occur within Priority Habitat and Estimated Habitat, requires review by the Division for compliance with the MESA and rare species provisions of the WPA.

The preferred Landfall Site utilizing Covell’s Beach (Barnstable) occurs within mapped habitat for Piping Plover. As detailed in the FEIR (Section 4.3), the Proponent has continued to proactively consult with the Division regarding this Landfall Site and has committed to beginning the Horizontal Direction Drilling process (HDD) in advance of April 1, or will otherwise not begin HDD until after Labor Day, in order to minimize impacts to Piping Plovers during the breeding season. In December 2018, the Proponent submitted a MESA Project Review Checklist for the Vineyard Wind Connector. On January 17, 2019, the Division determined (attached) that a Piping Plover protection and contingency plan must be developed to ensure that state-listed species and their habitats are protected in the event that either delays or HDD issues arise during the cable installation process.

The FEIR retains the New Hampshire Avenue (Yarmouth) landing site and variants thereof as alternative routes. All onshore alternate routes associated with the Yarmouth landing site appear to avoid mapped Priority Habitat and Estimated Habitat for state-listed species. However, and as noted in the Division’s comments on the SDEIR, Variant 3 (Bike Path) may traverse the Division’s Hyannis Ponds Wildlife Management Area. The Proponent has acknowledged (pg. 6-45) that should Variant 3 be pursued, additional and early coordination with the Division’s Chief of Wildlife Lands is required.

The Proponent has detailed some of the potential impacts to state-listed species associated with the proposed cable installation process, including vessel traffic and suspended sediment. Secondary impacts (e.g. electromagnetic fields (EMF) and heat from the cables) and their anticipated impacts on benthic organisms, particularly Sand Lance – a critical prey resource for state-listed terns – were not specifically addressed. However, the Proponent has incorporated Sand Lance into the Benthic Habitat Monitoring Plan. The Division will continue to evaluate these impacts as they relate to state-listed tern species and looks forward to providing comments on the Benthic Habitat Monitoring Plan. The Division requests that the Proponent continue to incorporate recommendations from the Division of Marine Fisheries (DMF) regarding the Benthic Habitat Monitoring Plan to ensure valuable data collection relative to Sand Lance.

The Division will not render a final decision until the MEPA review process and associated public and agency comment period is completed, and until all required MESA filing materials are submitted to the Division. As the MESA review is not complete, no work associated with the proposed project shall occur until the Division has made a final MESA determination.

Wind Energy Generation: A large proportion of the North American Roseate Tern population is reliant upon Massachusetts for nesting. In addition, the largest Roseate Tern breeding colony in New York annually (spring and fall) travels through federal waters to Massachusetts for staging in advance of migrating south for the winter. Because a large proportion of the North American population is likely to travel within and

through the Vineyard Wind Lease Area, and given the regional importance of Massachusetts to nesting, feeding and staging Roseate Terns, wind turbines have the potential to increase risks to Roseate Terns and other state-listed avian species (e.g., Common Tern, Least Tern and Piping Plover).

On January 22, 2019, the Division provided detailed comments through EEA to the Bureau of Ocean Energy Management (BOEM) regarding its Draft Environmental Impact Statement (DEIS) and associated documents prepared for the proposed Vineyard Wind Project pursuant to the National Environmental Policy Act (NEPA). In summary, the DEIS concluded that effects of Vineyard Wind Project are insignificant and discountable and thus, “not likely to adversely affect” ESA-listed bird species. The Division’s comments confirm that the DEIS does not provide sufficient evidence to support these conclusions, does not reference several previous studies that run counter to its conclusions, and does not fully or accurately characterize existing and recently collected avian data. As a result, the DEIS does not fully account for increased mortality risk and other negative impacts to ESA- and MESA-listed bird species associated with the Vineyard Wind Project.

The Division anticipates that the operation of Wind Turbine Generators (WTGs), primarily, will result in increased risk of direct mortality of individual ESA- and MESA-listed birds. This mortality is of greatest concern for the Endangered Roseate Tern given their small population size, recent population volatility, and the large proportion of the North American population expected to travel within and through the Wind Development Area.

The FEIR presents a comprehensive strategy for avoiding, minimizing and mitigating potential impacts to marine mammals associated with the Vineyard Wind Connector as well as the WTG installations. Given the likelihood of impacts to avian species associated with WTG installation and operation, the Division believes a similar approach is warranted for MESA-listed avian species, particularly the Roseate Tern. However, the FEIR does not provide a comparable comprehensive strategy for MESA-listed avian species and the Division is concerned that impacts have not been adequately addressed. Therefore, we recommend that the Proponent submit a comprehensive plan to minimize impacts to MESA-listed avian species and develop a comprehensive post-construction monitoring and adaptive management plan. We also recommend that the Proponent mitigate any unavoidable Project impacts by providing support for conservation measures that provide meaningful and measurable benefit to these species.

The Division requested that the Proponent submit a comprehensive plan to minimize and mitigate impacts to ESA- and MESA-listed avian species in its June 8, 2018 comments on the DEIR and its October 5, 2018 comments on the SDEIR. The Secretary’s October 12, 2018 Certificate reflected the Division’s request, stating that “[t]he FEIR should include a comprehensive, adaptive strategy for avoiding, minimizing and mitigating potential impact to listed avian species.” Therefore, the Division again requests that the Proponent submit a comprehensive, adaptive plan to minimize impacts to MESA-listed avian species, and consult with the Division to develop an appropriate mitigation plan to address unavoidable impacts associated with the Vineyard Wind Project.

If you have any questions about this letter, please contact Amy Hoenig, Endangered Species Review Biologist, at (508) 389-6364 or [email protected]. We appreciate the opportunity to comment on this project.

Sincerely,

Thomas W. French, Ph.D. Assistant Director

cc: Rachel Pachter, Vineyard Wind Matthew Robertson, Vineyard Wind Holly Carlson Johnston, Epsilon Associates, Inc. Jack Vaccaro, Epsilon Associates, Inc. Yarmouth Board of Selectmen Yarmouth Conservation Commission Yarmouth Planning Department Barnstable Board of Selectmen Barnstable Conservation Commission Barnstable Planning Department DEP Southeast Regional Office, MEPA

January 17, 2019

Rachel Pachter Vineyard Wind LLC 700 Pleasant Street, Suite 510 New Bedford MA 02740

Project Location: offshore Edgartown, Nantucket & Barnstable; onshore landing at Covell’s Beach, Barnstable Town: Edgartown, Nantucket & Barnstable, MA Project Description: Vineyard Wind Connector – a subsea cable installation in state waters with onshore landing at Covell’s Beach (to service an offshore wind facility in federal waters) NHESP File No.: 17-37398

RE: Notice that additional information is required for review of this project pursuant to MESA (321 CMR 10.18).

Dear Applicant:

On December 18, 2018, the Natural Heritage & Endangered Species Program in the Massachusetts Division of Fisheries & Wildlife (the “Division”) received an application for review of the above reference proposed project in Priority Habitat for review pursuant to 321 CMR 10.18 of the MA Endangered Species Act (MESA) Regulations.

The proposed project is located within the mapped Priority and Estimated Habitat for the state-listed species listed below. Fact sheets for state-listed species can be found at www.mass.gov/nhesp. Scientific name Common Name Taxonomic Group State Status Charadrius melodus Piping Plover Bird Threatened* Sternula antillarum Least Tern Bird Special Concern Sterna dougallii Roseate Tern Bird Endangered* Sterna hirundo Common Tern Bird Special Concern Sterna paradisaea Artic Tern Bird Special Concern * Species also protected pursuant to the U.S. Endangered Species Act (ESA, 50 CFR 17.11).

The purpose of the Division’s review under the MESA regulations is to determine whether a Take of state-listed species will result from the proposed project. Under 321 CMR 10.18(1), the Division is required to notify the Record Owner of the property where the project is proposed within 30 days whether the submitted application contains the information required to be submitted to the Division pursuant to 321 CMR 10.20.

As detailed within the MESA application, Vineyard Wind has committed to measures to reduce impacts to state-listed species and their habitats associated with the proposed Vineyard Wind Cable Connector.

NHESP No. 17-37398, 1/17/2019, Page 2

This includes a prohibition on commencing work associated with the Horizontal Directional Drill (HDD) cable installation at Covell’s Beach during the Piping Plover nesting season April 1 – August 31. Typically, HDD can be conducted with minimal impacts; however, problems may arise during the drilling process or due to other unforeseen circumstances, which could result in delaying the start of work or habitat alterations during the nesting season. While The Division anticipates that the proposed Vineyard Wind Cable installation can be conditioned to avoid a prohibited Take of state-listed species a Piping Plover protection plan and contingency plan must be developed to ensure that state-listed species and their habitats are protected in the event problems arise during the cable installation process.

Therefore, the Division has reviewed the materials submitted with your application under the MESA (321 CMR 10.18) regulations and has determined that additional information is required in order for the Division to complete its review pursuant thereto, as specified below: 1) Please provide Piping Plover protection plan that addresses measures to protect state-listed species and their habitats during the nesting season (April 1 – August 31) and a contingency plan in the event problems arise during the HDD cable installation, including: a. Work begins prior to April 1 and lapses for 3 or more days. b. Weather or other unforeseen problems arise which delay the start of work to April 1 – August 31. c. Problems with the HDD drill arise which require physical access to the coastal beach or result in physical disturbance to the coastal beach (e.g. obstructions, blow-outs). d. Details regarding how the work area will be delineated to prevent encroachment onto the coastal beach. The Division is available for consultation regarding protection and contingency plan(s) and appropriate measures to protect state-listed species and their habitats. After receiving the above information, the Division will continue its review of the proposed project for compliance with the state-listed species provisions of the WPA and MESA regulations. The Division reserves the right to request additional information to understand the potential impacts of the proposed project on state-listed species and their habitats.

No work or other activities related to your filing may be conducted anywhere on the project site until the Division completes its review. If you have any questions regarding this letter please contact Amy Hoenig, Endangered Species Review Biologist, at (508) 389-6364.

Sincerely,

Thomas W. French, Ph.D. Assistant Director cc: Jack Vaccaro, Epsilon Associates Matthew Robertson, Vineyard Wind LLC Mark Ellis, Town of Barnstable

MEMORANDUM

TO: Matthew A. Beaton, Secretary, EEA ATTN: Purvi Patel, MEPA Unit FROM: Lisa Engler, Acting Director, CZM DATE: January 25, 2019 RE: EEA-15787, Vineyard Wind Connector

The Massachusetts Office of Coastal Zone Management (CZM) has completed its review of the above-referenced Final Environmental Impact Report (FEIR) for the Vineyard Wind Connector, noticed in the Environmental Monitor dated December 26, 2018. CZM continues to support the responsible development of marine renewable energy to help meet state and regional greenhouse gas emission reduction goals. The comments below address the responsiveness of the FEIR regarding CZM’s comments on the Supplemental Draft Environmental Impact Report (SDEIR) and the Secretary’s Certificate on the proposed project. In general, the FEIR has responded to CZM’s comments and questions raised in previous letters and at meetings with Vineyard Wind. CZM commends Vineyard Wind for their efforts to address agency concerns throughout the MEPA review and looks forward to working with Vineyard Wind, the Massachusetts Department of Environmental Protection (MassDEP), and the Division of Marine Fisheries (DMF) during permitting to finalize construction, mitigation, and monitoring plans.

Project Description The Vineyard Wind Connector is a proposal to install two 10-inch diameter 220 kV AC offshore export cables from the federally-designated Wind Energy Area off Massachusetts to the existing electrical grid on Cape Cod. The Vineyard Wind Connector is part of a larger project that seeks to permit an 800-megawatt (MW) offshore wind farm under the jurisdiction of the Bureau of Ocean Energy Management (BOEM). Major elements of the total project include a wind turbine array, offshore electrical service platforms, offshore electrical transmission to shore, onshore underground transmission, and an onshore substation. The FEIR maintains two alternative offshore export cable corridors (a Western route and an Eastern route) which can make landfall at one of two potential sites: the preferred location at Covell’s Beach in Barnstable and the alternative at New Hampshire Avenue in Yarmouth. Each proposed cable construction corridor may be up to 810 meters wide. The Western corridor to Covell’s Beach would pass through 20.9 miles of state waters and the Eastern corridor would pass through 22.6 miles of state waters, while the New Hampshire Avenue alternative would pass through 21.4 and 23.3 miles, respectively. Both proposed cable routes through Nantucket Sound include sections within federal waters in the center of the sound. The cables will be buried approximately 1.5 to 2.4 meters below the seafloor and laid with a combination of hydroplowing (through flat, soft sediments), jetting (through small sand waves), suction dredging (through large sand waves), and mechanical dredging (through compacted sand/gravel/cobble). Dense aggregations of boulders will be avoided while solitary boulders may be removed from the cable pathway and placed in another location within the construction corridor.

Project Comments In comments on the SDEIR, CZM requested that Vineyard Wind use its 2018 field data and revised modeling to demonstrate how the proposed project avoids sensitive resources identified in the Massachusetts Ocean Management Plan. The FEIR addresses many of CZM’s comments by presenting: preliminary cable alignments, a revised sediment dispersion analysis, revised dredging calculations, greater definition on dredge spoils disposal areas, an outline of a monitoring plan, and more information on an ocean use mitigation fee. However, because Vineyard Wind has not yet selected a construction contractor and cable vendor, the exact methods for dredging sand waves, the tool for installing the cables, and the timing of cable installation are still unknown. In addition, Vineyard Wind delivered the field data too late in the comment period for it to be used to verify mapped seafloor resources. The comments below identify areas where CZM looks forward to working with Vineyard Wind, as well as our state and federal partners, in the permitting process to ensure the project’s avoidance and minimization of impacts to sensitive resource areas.

Massachusetts Ocean Management Plan In previous comments, CZM requested that Vineyard Wind provide clearer depictions of the proposed project relative to existing ocean resources and uses addressed in the Massachusetts Ocean Management Plan (OMP). The maps in Attachment A and the map books provided to CZM are responsive to this request. Figure 1-4 depicts areas of eelgrass, hard bottom, and complex seafloor as well as preliminary cable alignments that seek to minimize disturbance to these areas. Figure 2-1 depicts the areas within the cable corridor where dredge spoils associated with cable laying are not allowed to be deposited (coarse sediment areas) and areas where dredge spoils may be deposited (sand bedform areas).

CZM also recommended quantification of the amount of hard and complex seafloor that cannot be avoided and that may be impacted during the cable laying process. Table 2-1 presents the predicted lengths of preliminary cable alignment that would occur in both hard bottom (up to 4.7 miles) and complex seafloor (up to 19.3 miles) and Table 2-2 provides the predicted areal impacts to hard and complex seafloor (up 1.9 and 8.0 acres, respectively). As suggested in CZM’s SDEIR comments, Vineyard Wind has used its 2018 survey data to avoid or minimize large sand waves, and through careful preliminary siting, via preliminary cable alignments depicted in Figure 1-4, has decreased the amount of dredging proposed in sand waves by 25-40%.

With the application of additional survey data and mapping, it appears that the preliminary cable alignments avoid hard and complex seafloor to the maximum extent practicable and where it cannot be avoided, no less damaging environmentally practicable alternative exists. In this way, Vineyard Wind has adequately met the siting standards in the OMP. In addition, the public benefits of the proposed total project are sufficiently detailed in Section 1.2 of the FEIR. With this information and analysis, CZM finds that Vineyard Wind has demonstrated that the public benefits of the proposed project outweigh the public detriments to OMP resources.

As previously stated, the exact methods and equipment for dredging sand waves and installing the submarine cable will not be known until Vineyard Wind selects a marine construction contractor. Furthermore, field data (sediment grabs and cores, seafloor videos and photos, biological samples) were not provided in time for CZM to review in conjunction with the maps and assessments associated with the FEIR. This information will be necessary in the permitting process to meet state standards for avoiding, minimizing, and mitigating impacts to biogenic and hard and complex habitats.

Species of Concern Vineyard Wind has proposed to avoid wind turbine pile driving in offshore waters between January 1 and April 30 in order to protect marine mammals, to orient horizontal directional drilling (HDD) activities to avoid eelgrass, and to time HDD at Covell’s Beach to occur between August 31 and April 1 in order to avoid horseshoe crab spawning and Piping Plover nesting.

Vineyard Wind has identified that approximately 13.8 nautical miles (25,558 m) of cable installation would occur in the avian foraging hotspot in Muskeget Channel (Fig 4-1). Using a cable installation rate of 200 m/hr, Vineyard Wind estimates that installation activities might last for five days within the avian hotspot. Additional modeling of the suspended sediment (TSS) associated with dredging and cable installation suggests that the maximum area with excess (i.e., above ambient) TSS > 10 mg/l would be 1.75 km2 (< 1% of the hotpot area) and would last for a maximum of six hours, confining any disruption of avian foraging to a narrow corridor and presumably allowing foraging to continue throughout the majority of the avian hotspot. Vineyard Wind should develop a TSS monitoring protocol for use during construction to verify these estimates.

Discussions are ongoing with DMF to find an appropriate marine construction window to avoid impacts to various resources and water dependent uses (including the squid fishery). DMF has proposed July/August as a preferred time of marine cable installation while Vineyard Wind prefers April through June. Vineyard Wind has stated that it may be possible to begin laying the energy export cables in the nearshore in one year, bury the partial cable segments, and then splice and continue laying the remaining cable lengths in the offshore portion of the project in the following year. To this end, Vineyard Wind states that it has been working with cable vendors for earlier delivery than originally proposed and is re-evaluating its weather modeling to see if it can accept more weather-related risk to begin dredging and cable installation earlier in the spring. Vineyard Wind should provide information relating to how construction activities will be timed, staged, and sequenced to minimize impacts as the details become available.

Cable Installation As stated above, Vineyard Wind has not yet selected a marine construction contractor or the tools to perform the dredging and cable laying activities. Absent this information, Vineyard Wind has been able to revise its estimates of impact based upon an expectation of access to a cable installation tool with a “deeper achievable burial depth” than previously assumed in impact assessments in the SDEIR. Through new preliminary cable alignments, optimized to minimize impacts to sand waves, the amount of expected sand wave dredging ranges from 54,000-85,000 cubic yards, a significant reduction from the 71,000-136,000 cubic yards presented in the SDEIR. In addition, a decrease in the length of cable expected to need permanent hard cover and a new proposal to reduce hard cover width to 10 feet has reduced the projected cable protection impact from 27 acres to nine acres (across 7.4 miles). The expected impact due to anchoring is 2.1-2.3 acres. Projected sediment plume and settlement characteristics have not changed appreciably between the SDEIR and the FEIR. CZM appreciates the efforts that Vineyard Wind has made to minimize temporary and permanent impacts. CZM suggests that these refined impact estimates be used to help define performance standards in the 401 Water Quality Certification.

Monitoring Plan(s) As noted several times above, because there are aspects of this project that have yet to be defined, the scope of impacts remains in flux. The comprehensive monitoring plan for Vineyard Wind, developed with CZM and other state agencies, should: 1) establish a robust pre-construction baseline; 2) evaluate TSS dispersion during construction; 3) measure changes in seafloor topography and any disturbance of the seafloor habitats; 4) evaluate the adequate burial of the cables in the near and long term; and 5) outline adequate means and metrics to detect differences in biological or geological parameters within the construction corridor and recovery times of resources. While Vineyard Wind has outlined a monitoring effort, details regarding specific methods, times of year, frequency, and locations are still to be determined.

Specifically regarding cable burial, it is important that all efforts be made to lay the cable at adequate depth to minimize the amount of cable protection required and to ensure that the cable does not become exposed in the long term. CZM discourages the use of armoring due to the detrimental impacts that can include increased scouring of the seafloor adjacent to the hard cover, increased substrate providing a vector for invasive species colonization, and impacts to commercial and recreational fishing operations. Instead of hard cover, CZM recommends additional efforts to bury any exposed cable to the appropriate depth or covering the cable with sand bags and gravel/cobble cover, as appropriate, to mimic adjacent seafloor conditions.

CZM looks forward to working with Vineyard Wind and the other resource agencies on the details of these monitoring plans and establishing a process for determining if established performance standards have been met.

Ocean Development Mitigation Fee As stated in previous comments and in meetings with Vineyard Wind, mitigation for the Vineyard Wind project should be based upon the full extent of the impact of the project including: direct cable laying and dredging area, dredged disposal area, sediment deposition area, and impacts to biota and habitat, as well as permanent hard cover. Based upon estimates in the SDEIR, the Vineyard Wind Connector project was classified as Ocean Development Mitigation Fee Class III: a project large and/or complex in scale; with a footprint greater than 20 acres; and moderate, re-occurring, or continuous effects on natural resources or water-dependent uses. Through new data developed in 2018 and additional work by Vineyard Wind on preliminary cable alignments, the projected impacts have decreased. The projected cable protection impact has decreased from 27 acres to nine acres. In addition, refinements, including an expectation for access to a cable installation tool with a “deeper achievable burial depth”, have reduced the area of sand waves expected to be dredged from a maximum of 136,000 cubic yards to 75,000 cubic yards. Impacts associated with sediment dispersion and resettlement have remained the same. With these updated impact values, the Vineyard Wind Connector project is classified as Ocean Development Mitigation Fee Class II: a project moderate in scale; with a footprint general between 6 – 20 acres; and generally minor but more than temporary effects on natural resources or water-dependent uses.

Vineyard Wind’s mitigation fee proposal in the FEIR includes a base fee of $240,000 with an adjustment of the fee based upon final impacts. Vineyard Wind has proposed an additional $10,000 per acre for every additional acre of hard cover beyond the projected nine acres and $500 for every 1,000 cubic yards of dredging required above the projected 75,000 cubic yards, with a maximum fee of $500,000. Vineyard Wind further suggests that payments would occur over two years. CZM looks forward to further discussion with Vineyard Wind and the Secretary’s office on finalizing the Ocean Development Mitigation Fee.

Fisheries Mitigation Vineyard Wind is actively engaged in discussions with EEA, CZM and DMF regarding mitigation for commercial and recreational fisheries that may be impacted by the proposed project. Vineyard Wind should continue to coordinate with these state agencies and fishermen to establish appropriate mitigation for Massachusetts fisheries interests. The discussions should clearly describe the status of compensation discussions with Massachusetts fishermen for losses incurred during construction. Additionally, the discussions should discuss mitigation to Massachusetts fishermen for the potential loss of fishing opportunity over the lifespan of the project.

Federal Consistency The proposed project is subject to CZM federal consistency review. For further information on this process, please contact, Robert Boeri, Project Review Coordinator, at 617-626-1050 or visit the CZM web site at www.state.ma.us/czm/fcr.htm.

LE/rlb/tc/sm cc: Yarmouth Conservation Commission Barnstable Conservation Commission Holly Carlson Johnston, Epsilon Associates, Inc. Rachel Pachter, Vineyard Wind Conrad Caia, Yarmouth Shellfish Constable Dan Horn, Barnstable Shellfish Constable Christopher Boelke, Sue Tuxbury & Alison Verkade, NMFS Ed Reiner, EPA Derek Standish, David Wong, DEP Kathryn Ford, John Logan, Eileen Feeney, DMF

Andrew Gottlieb Executive January 17, 2019 Director Mr. Matthew Beaton

BOARD OF DIRECTORS Secretary of Energy and Environmental Affairs Massachusetts Executive Office of Energy and Environmental Affairs (EEA) Margo Fenn President Attn: MEPA Office Purvi Patel, EEA No. 15787 (Vineyard Wind Connector) 100 Cambridge Street, Suite 900 Charles Sumner Boston, MA 02114 Vice President

Bob Ciolek RE: Vineyard Wind Final Environmental Impact Report, EEA No. 15787 Treasurer

Maureen O’Shea Dear Secretary Beaton: Clerk

Founded in 1968, the Association to Preserve Cape Cod (APCC) is the leading nonprofit Michael Corrigan environmental advocacy and education organization for the Cape Cod, Massachusetts DeeDee Holt region. APCC works for the adoption of laws, policies and programs that preserve, protect and enhance Cape Cod’s natural resources and quality of life. Thomas Huettner

Pat Hughes On December 19, 2018, APCC issued a public statement endorsing the Vineyard Wind

Cheryl Lubin project. The decision to support the project followed comprehensive review by APCC of the project’s multiple state regulatory filings through the Massachusetts Elysse Magnotto-Cleary Environmental Policy Act (MEPA) process, including the project’s Final Environmental Blue Magruder Impact Report (FEIR), as well as the release of the Bureau of Ocean Energy Management’s Draft Environmental Impact Statement (DEIS). Eliza McClennen

Maureen O’Shea APCC believes Vineyard Wind has largely addressed the major issue areas associated Kris Ramsay with the project through proposed actions that would avoid, minimize or mitigate most of the potential environmental impacts in the offshore and onshore aspects of Robert Summersgill the project. In the analysis provided in the DEIS and the FEIR, it was determined that Taryn Wilson where environmental impacts may be unavoidable, those impacts are likely to be minimal.

APCC recognizes that any project of such a large scale will inevitably have some impacts, and Vineyard Wind is no exception. However, APCC is also keenly aware that impacts to the environment and to humans will be catastrophically more significant if nothing is done to address climate change, and if projects such as Vineyard Wind do not more forward. As the first major offshore wind project in the United States,

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Vineyard Wind will be a significant step forward in the effort to shift our reliance from greenhouse gas- causing fossil fuels to clean renewable energy sources.

While APCC has expressed support for the project, we recognize that some aspects of project planning are yet to be finalized. Therefore, further project scrutiny in those areas is called for. We also believe there are opportunities to improve proposed mitigation to further protect environmental resources. We encourage Vineyard Wind to continue to work with BOEM, state regulatory agencies and others in addressing the key environmental issues associated with the project. Three areas on which APCC urges particular focus are:

• Protection of marine mammals, especially the critically endangered North Atlantic right whale (Eubalaena glacialis). • Protection of offshore avian species, including federal and state listed species. • Protection of groundwater at the proposed substation site in Barnstable.

Marine Mammals: APCC supports the package of mitigation proposed by Vineyard Wind to protect marine mammals, including the proposed $3 million contribution for creation of a Wind and Whales Fund to develop innovative methods and technologies that will maximize protections for marine mammals as the U.S. offshore wind industry becomes established. But, in addition to Vineyard Wind’s mitigation proposals, APCC recommends that BOEM require the implementation of other mitigation measures described in Appendix D of the DEIS, including long-term passive acoustic monitoring, daily pre-construction passive acoustic monitoring and visual surveys, and the prohibition of pile driving from sunset to sunrise during construction. Protection of marine mammals must be a fundamental component of this project, and APCC calls on BOEM, the National Marine Fisheries Service, state permitting agencies and Vineyard Wind to continue to seek additional mitigation strategies to further reduce the potential for adverse impacts, especially potential impacts to North Atlantic right whales.

Avian Species: The analysis of potential avian impacts conducted for the DEIS concluded that any offshore impacts would likely be negligible to minor. APCC recommended that BOEM require additional mitigation measures it has considered in its analysis that would further reduce potential for impacts to avian species during construction as well as during ongoing operation phases of the project, particularly mitigation that could help reduce the potential for fatalities of federally listed bird species. According to the FEIR, Vineyard Wind is also continuing its consultations with the Massachusetts Division of Fisheries and Wildlife’s Natural Heritage and Endangered Species Program (NHESP) regarding potential impacts to federal and state listed avian species, including roseate tern (Sterna dougallii), least tern (Sternula Antillarum) and piping plover (Charadrius melodus). In its written comments on the project’s Supplemental Draft Environmental Impact Report (SDEIR), NHESP noted Vineyard Wind’s comprehensive mitigation strategy to protect marine mammals and recommended that a similar approach be implemented for listed avian species. APCC supports NHESP's recommendation and looks to further coordination between Vineyard Wind and NHESP, along with BOEM's input, to develop a strategy to maximize protection of listed avian species.

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Substation: APCC applauds the efforts of Vineyard Wind and the town of Barnstable to develop a Host Community Agreement that facilitates the use of Covell’s Beach as the cable landing site, enables onshore underground cable routing to be located entirely within existing roadway layouts, and establishes coordination between Vineyard Wind and the town on protecting groundwater at the substation site through a spill containment system, stormwater management plan and other mitigation. APCC strongly encourages the project applicant to continue to pursue the possibility of using biodegradable dielectric fluids for the substation’s main transformers, as described in the FEIR. Vineyard Wind stated in the FEIR that a Spill Prevention Control and Countermeasures Plan will be developed but will likely not be ready for the upcoming Cape Cod Commission Development of Regional Impact (DRI) review process. Ensuring that water supplies are protected from hazardous material spills is of paramount importance, and APCC therefore recommends that DRI approval be conditioned on the Commission’s and the town of Barnstable’s review and approval of a completed plan.

APCC is confident that appropriate, comprehensive strategies and mitigation can be devised through continued consultation between Vineyard Wind, BOEM, state permitting agencies and other sources that will help protect rare species and vital natural resources, both offshore and onshore.

Sincerely,

Andrew Gottlieb Don Keeran Executive Director Assistant Director

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P.O. Box 2189, Vineyard Haven, MA 02568 Phone (508) 693-9588 | Fax (508) 693-0683 www.vineyardconservation.org

[email protected]

January 25, 2019

RE: Public comment on EEA No. 15787 (Vineyard Wind Connector)

Dear Ms. Patel,

The Vineyard Conservation Society (VCS) is a 54-year old non-profit environmental organization dedicated to conserving the natural resources of Martha’s Vineyard – including conservation of energy resources.

VCS strongly believes that, (1) reducing the worst impacts of global climate change requires deployment of an arsenal of renewable energy technologies including wind, and (2) that if we are to succeed, we must simultaneously address conservation and efficiency. Global energy demand is rising rapidly and will continue to do so; for renewable energy to significantly supplant fossil fuels it is essential that we slow the growth in demand. In addition, conservation and efficiency measures are highly cost effective, reduce the impact of peak demand on the grid, and provide carbon reduction benefits immediately.

For the last 15 years, VCS has taken the position that development of renewable energy sources is fundamental to protection of the environment and the public interest, provided it is part of a coherent regulatory framework addressing all offshore wind facilities, which the MEPA unit ensures.

VCS promotes the broadest possible definition of conservation, including habitat, biodiversity, open space, and community character. Therefore, we believe that for offshore wind to succeed, the process must promote the protection of marine resources and provide a net benefit to host communities’ local environments. To this end, we were very pleased to learn this week of the agreement with conservation groups to take measures to protect the endangered North Atlantic right whale. We also applaud the plans to allow our emergency management services to use Vineyard Wind’s storage batteries, reducing local carbon emissions and air pollution.

Stabilization of atmospheric greenhouse gas emissions is a global environmental priority; yet, renewable energy projects are not without environmental costs. To the greatest extent possible, MEPA regulatory oversight of this project should seek to protect biodiversity and habitat, and to facilitate local benefit for host communities in the form of dollars for energy conservation and efficiency programs.

While we support this project in concept, we would like to see it take the lead, and vigorously initiate and underwrite additional community benefits that promote energy conservation and improved efficiency in its many forms: from earmarking dollars for non-polluting transportation and improving efficiency of machines, to improving energy efficiency of homes and businesses. Development of new energy without an equally forceful effort at energy conservation will undercut the magnitude of change required, and we will lose a pivotal opportunity. With emissions and temperatures rising nearly every year, time is of the essence.

Thank you for the opportunity to comment.

Brendan O’Neill, Executive Director

January 22, 2019

Dr. Walter Cruickshank, Acting Director Bureau of Ocean Energy Management Attention: Program Manager, Office of Renewable Energy 45600 Woodland Road Sterling, VA 20166

RE: Vineyard Wind COP Draft EIS (Docket No. BOEM-2018-0069)

Dear Dr. Cruickshank:

On behalf of the board of trustees of the Cape Cod Climate Change Collaborative (5Cs), I am writing to strongly endorse the proposed Vineyard Wind project, the nation’s first large-scale offshore wind energy project. Proposed for siting 14 miles off the coast of Martha’s Vineyard, the project intends to bring 800 megawatts of electricity to the Cape and Islands and generate clean, renewable, cost- competitive energy for 400,000+ residents of the Commonwealth of Massachusetts.

Established in 2015, the 5Cs is a consortium of Cape Cod-based organizations whose mission is to unite available resources, organizations and intelligence to mitigate climate change impacts on Cape Cod, reduce greenhouse gas emissions, and work toward achieving “net zero”-based goals for the region. Board members include community leaders from across the region representing organizations such as the Association to Preserve Cape Cod, Cape Air, Cape Light Compact, Center for Coastal Studies, Friends of Pleasant Bay, Outer Cape Energize, Woods Hole Research Center, and numerous faith-based, educational, non-profit and business entities.

On January 15, 2019, the 5Cs issued a public statement endorsing the Vineyard Wind project. We did so in recognition that climate change poses the biggest global threat of our time. Recent federal reports describing acceleration and increased severity of climate change underscore the need for immediate action to generate clean renewable energy for the Cape Cod region, Massachusetts, and beyond. We believe the Vineyard Wind project will make major strides in advancing this goal.

The waters off New England are warming at an alarming rate, much faster than scientists thought just four years ago. Climate change has also created more extreme weather events and unpredictable storms. Climate change poses existential threats to our environment, human health, and the economy—indeed, our entire way of life on Cape Cod. The Cape’s fishing industry will be especially

Cape Cod Climate Change Collaborative PO Box 1092, South Orleans, MA 02662 www.capecodclimate.org Phone 607.351.8681 [email protected] 1 | Page

impacted by warming water, which means cold water fish species will leave the area in search of cooler water or become extinct. It’s imperative that we change our energy sources to a low-carbon mix containing a significant amount of renewable energy, starting yesterday.

The 5Cs board has carefully followed and been impressed by Vineyard Wind’s efforts to mitigate project impacts and address community concerns. The project, for example, has developed community agreements with municipal partners on the Vineyard and town of Barnstable, committing $15 million for numerous initiatives which benefit Cape and Islands residents including programs to recruit, mentor and train Massachusetts workers, particularly those in southeastern Massachusetts, for careers in the new offshore wind industry.

The 5Cs also supports comments submitted by the Association to Preserve Cape Cod (APCC) on January 17, 2019. Specifically, we endorse its recommendation that the Bureau of Ocean Energy Management work closely with Vineyard Wind and state agencies to ensure that proposed project mitigation protect the following important environmental resources:

• Marine mammals, especially the critically endangered North Atlantic right whale • Offshore avian species, including federal and state listed species • Groundwater at the proposed substation site in Barnstable

We are confident that appropriate regulatory conditions and mitigation will be developed through continued consultation among Vineyard Wind, BOEM, state agencies and other entities charged with protecting rare species and natural resources, both off- and onshore.

Sincerely,

Moncrieff M. Cochran

Moncrieff M. Cochran, Executive Director Cape Cod Climate Change Collaborative

2 | Page

January 25, 2019

Mr. Matthew Beaton, Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) MEPA Office/ Purvi Patel, EEA No. 15787 (Vineyard Wind Connector) 100 Cambridge Street, Suite 900 Boston, MA 02114

RE: Vineyard Wind Connector Final Environmental Impact Report

Dear Secretary Beaton and Ms. Patel,

Clean Water Action (CWA) submits the following letter in support of the Vineyard Wind Connector project. CWA has been working since 1972 to protect the environment, public health, economic well-being and community quality of life. CWA’s clean energy campaigns in Massachusetts support efforts to fight climate change and work to bridge racial and economic gaps that sometimes limit the ability of low-income residents and communities of color to benefit directly from the transition to a clean energy future.

CWA supports the Vineyard Wind Connector project for several reasons. First, the project will deliver 800 MW of emission-free electricity to Massachusetts from the nation’s first large-scale offshore wind farm. The greenhouse gas emission reductions benefits of the offshore wind farm are estimated to be avoided emissions of 1.6 million tons of carbon dioxide per year.

Second, Vineyard Wind Connector will reduce Massachusetts’ reliance on natural gas and lower electricity bills. The Massachusetts Department of Energy Resources projects that Vineyard Wind’s 800 MW project will save electricity customers $1.4 billion over 20 years.

Third, Vineyard Wind has worked closely with local communities in developing Vineyard Wind Connector and has made improvements to the project based on community and other stakeholder

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input. The Host Community Agreement that Vineyard Wind has signed with the Town of Barnstable ensures the town will directly benefit from the project, and the project more than addresses the limited community concerns about noise and light pollution.

In addition to the above, Vineyard Wind is committed to responsible renewable energy project development as evidenced by the recently announced agreement with environmental organizations to protect the critically-endangered North Atlantic right whale (NARW). This historic agreement sets a strong standard of protection for this species and will help Massachusetts achieve its climate change and renewable energy goals without further endangering the NARW.

For all of these reasons, CWA supports the Vineyard Wind Connector and respectfully requests that you approve it.

Thank you, and please do not hesitate to reach me with any further questions.

Sincerely,

Alex Papali Energy and Zero Waste Programs Clean Water Action- Massachusetts 617 338 8131 x212 [email protected]

Submitted electronically to: [email protected]

January 25, 2018

Mr. Matthew Beaton Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office, Purvi Patel, EEA No. 15787 (Vineyard Wind Connector) 100 Cambridge Street, Suite 900 Boston, MA 02114 Re: Massachusetts Final Environmental Impact Report for Vineyard Wind, LLC’s Proposed Vineyard Wind Connector (EEA #15787)

Dear Secretary Beaton: On behalf of Conservation Law Foundation (CLF), Natural Resources Defense Council (NRDC), National Wildlife Federation (NWF), Mass Audubon, and the Environmental League of Massachusetts, and our millions of members, we submit the following comments on the Massachusetts Final Environmental Impact Report for the Vineyard Wind Connector (EEA #15787) (Project) submitted by Vineyard Wind LLC. Our organizations applaud the Commonwealth’s leadership to advance offshore wind. The Vineyard Wind Project will, if responsibly developed with care to avoid, minimize, and mitigate potential environmental and economic impacts, have substantial benefits to the Commonwealth and society as a whole as it makes an urgent transition away from dirty, climate-altering fossil fuels to a clean energy economy. When built, this 800 MW project is expected to provide enough electricity to power approximately 400,000 homes.1

It is a pivotal moment in America’s nascent offshore wind story, with states along the coast currently mobilizing to tap into this booming global industry and harness the abundant, clean energy available off their shores. As Massachusetts sets bold goals to transition from polluting fossil fuels to a clean energy economy, offshore wind provides a tremendous opportunity to fight climate change, reduce local and regional air pollution, and grow a new industry that supports thousands of well-paying jobs in both coastal and inland communities. States from Massachusetts to Virginia have collectively committed to developing approximately 15 gigawatts of offshore wind power over the next 10-15 years, and this number is expected to increase.2

1 See www.vineyardwind.com. 2 Gilman, P., Maurer, B., Feinberg, L., Duerr, A., Peterson, L., Musial, W., Beiter, P., Golladay, J., Stromberg, J., Johnson, I., Boren, D., and Moore, A. T. “National Offshore Wind Strategy: Facilitating the Development of the Offshore Wind Industry in the United States.” U.S. Department of Energy and U.S. Department of the Interior. doi:10.2172/1325403. https://www.osti.gov/servlets/purl/1325403.; McClellan, S. “Building America's Regional Offshore Wind Powerhouses – 10 GWs & Counting.” Renewable Energy World. September 2018. Accessed January 21, 2018, available at https://www.renewableenergyworld.com/articles/2018/09/building-americas-regional- offshore-wind-powerhouses-10-gws-counting.html.

Against this backdrop of unprecedented momentum, it is critical that all offshore wind development activities move forward with strong protections for coastal and marine habitat and wildlife in place every step of the way. We can and must develop this resource thoughtfully and responsibly, using science-based measures to avoid, minimize, and mitigate impacts on valuable and vulnerable wildlife. This must include a specific focus on ensuring sufficient measures are in place to protect our most threatened and endangered species.

As described in these comments, Vineyard Wind has made a landmark set of commitments to ensure the Project is built and operated in a way that is consistent with protection of the highly endangered North Atlantic right whale. We congratulate Vineyard Wind for these commitments, which set an important precedent for the other commercial-scale offshore wind projects that are also moving forward and for U.S. offshore wind development as a whole. While our final view of the Project will await our assessment of the final environmental reviews by state and federal agencies, we commend Vineyard Wind for its leadership in protecting right whales and enthusiastically look forward to seeing the Project advance through the final stages of the review process.

I. Vineyard Wind’s Historic Commitment to Right Whale Protection

On January 22, 2019, Vineyard Wind signed a landmark agreement with NRDC, NWF, and CLF to deploy additional mitigation measures to protect the North Atlantic right whale during activities pertaining to the Project’s construction and operations. The Vineyard Wind - NGO agreement dated January 22, 2019, attached as Attachment A (Agreement), is the result of an extensive, collaborative effort informed by input from leading North Atlantic right whale scientific experts. The parties came together voluntarily to address these issues in order to advance their mutual interest in the sustainable development of offshore wind energy.

The measures set forth in the Agreement reflect the commitment of Vineyard Wind to undertake steps, beyond the state and federal government’s current requirements, that provide additional protections for the North Atlantic right whale. The intent of the Agreement is to minimize the disruption of normal feeding, breeding, and migratory behaviors and prevent injury or mortality to right whales. Vineyard Wind has committed to mitigation measures that aim to lower risk from injury to a level approaching zero and to reduce other effects caused by marine noise. It is our expectation that the mitigation measures included in the agreement will meet these goals.

The mitigation measures agreed to by the parties include:

1. A seasonal prohibition on pile driving activities from January 1st through April 30th, the period when North Atlantic right whales are most likely to be present in the Project Area;

2. Enhanced mitigation protocols for pile driving from November 1st through December 30th and from May 1st through May 14th, and for geophysical survey activities from January 1st through May 14th, to reflect times of likely presence of North Atlantic right whales. Enhanced mitigation protocols include, but are not limited to, restrictions on initiating pile driving at night or during periods of poor visibility and the establishment of a 10,000

meter clearance zone during pile driving that will be monitored by real-time passive acoustics, visual observers, and, in early May, aerial surveys;

3. Comprehensive monitoring protocols during the construction window (i.e., May 15th through October 31st), including, but not limited to, a restriction on initiating pile driving at night or during periods of poor visibility and the establishment of a minimum 1,000 meter clearance zone that will be monitored by real-time passive acoustics and visual observers;

4. A vessel speed restriction of ten knots for all Project-associated vessels, with the exception of crew transfer vessels, from November 1st through May 14th and within Dynamic Management Areas designated by the National Marine Fisheries Service (NMFS). Additional monitoring measures are required of crew transfer vessels during the same time periods, including real-time passive acoustics, visual observers, and aerial surveys within Dynamic Management Areas;

5. Timely reporting of North Atlantic right whale sightings to the National Marine Fisheries Service or the Coast Guard within two hours of occurrence when feasible;

6. Underwater noise reduction measures to reduce sound levels by a target of 12 dB; and

7. A commitment to consider other mitigation approaches aimed at overall species protection.

In addition, Vineyard Wind has made a $3 million commitment to develop and deploy technologies to help ensure heightened protections for North Atlantic right whales and other marine mammals as the U.S. offshore wind industry continues to grow.3

As described below, we urge the Commonwealth to incorporate the mitigation measures detailed in Attachment A into the Certificate of the Secretary of Energy and Environmental Affairs on the Final Environmental Impact Report (Secretary’s Certificate) and factor these measures into the agency’s environmental assessment of potential impacts and evaluations of mitigation measures for other protected and endangered species.

II. Comments on the Project FEIR

The Commonwealth must meet its obligations under the Massachusetts Environmental Protection Act (MEPA) to prepare a final Environmental Impact Report (FEIR) that ensures that the Project will minimize damage to the Commonwealth’s natural resources.4 The FEIR is designed to provide state agencies with adequate information for making permitting and funding decisions and to ensure that environmental damages are minimized and mitigated.

3 See https://www.vineyardwind.com/winwithwind/. 4 See G.L. c. 30, § 61 (“All agencies, departments, boards, commissions and authorities of the commonwealth shall review, evaluate, and determine the impact on the natural environment of all works, projects or activities conducted by them and shall use all practicable means and measures to minimize damage to the environment.”).

As stated in the FEIR, the Project will require a Section 401 Water Quality Certification (WQC), a Chapter 91 (c. 91) License, and Approval of Easement pursuant to 310 CMR 22.00 from the Massachusetts Department of Environmental Protection (MassDEP); review under the Massachusetts Endangered Species Act (MESA) by NHESP; review under the OMP and Ocean Sanctuaries Act; a Non-Vehicular Access Permit, Road Crossing Permits, and a Rail Division Use and Occupancy License from the Massachusetts Department of Transportation (Mass DOT); and Approval under MGL Chapter 164 Sections 69J and 72, and Chapter 40A Section 3 Zoning Exemption from the Energy Facility Siting Board (EFSB) and DPU. The Project also requires a Federal Consistency review by the Massachusetts Office of Coastal Zone Management (CZM). We note that in the FEIR, the Massachusetts CZM Federal Consistency approval was not listed in the list of permits in Table 1-2 (pp. 1-20 to 1-23).

Our specific comments on the FEIR are as follows:

1. The Secretary’s Certificate should update the marine mammal mitigation provisions in Sections 4.1 and 5.2 (specifically Table 5.1: Summary of Impacts and Mitigation Measures) to reflect Vineyard Wind’s new commitments to North Atlantic right whale mitigation contained in Attachment A.

As the Secretary is aware, the conservation status of the North Atlantic right whale is dire. Recent scientific analysis confirms that the species has been declining since 2010 and only approximately 411 individuals were estimated to remain at the end of 2017.5 Three more animals were found dead in 2018. Overall, at least 20 North Atlantic right whales are known to have been killed in the last two years, leading the National Marine Fisheries Service (NMFS) to declare the species is experiencing an Unusual Mortality Event (UME).6 Only approximately 100 breeding females remain and, concerningly, females are more negatively impacted by stressors than males, now surviving to only 30-40 years of age with an extended inter-calf interval of approximately ten years.7 To our knowledge, no calves were born in the 2017-2018 calving season8 and only three calves have been sighted so far in the 2018-2019 season.9 While these three calves offer an emblem of hope, they will not offset the number of right whales currently being lost. It is imperative that all potential stressors acting on this species be minimized and mitigated to the full extent practicable in order to ensure its survival.

The North Atlantic right whale is listed as “endangered” under the federal Endangered Species Act of 1973 (ESA), 16 U.S.C. § 1531 et seq., as well as the Massachusetts Endangered Species Act (MESA), M.G.L. c. 131A. The Commonwealth must meet its obligations under the Massachusetts Environmental Protection Act (MEPA) to prepare an Environmental Impact

5 See Anderson Cabot Center for Marine Life, “Right whale consortium releases 2018 Report Card update.” Accessed January 18, 2019, available at: https://www.andersoncabotcenterforoceanlife.org/blog/2018-right-whale- report-card/. 6 NOAA-NMFS, “North Atlantic right whale Unusual Mortality Event.” Accessed January 18, 2019, https://www.fisheries.noaa.gov/national/marine-life-distress/2017-2018-north-atlantic-right-whale-unusual- mortality-event. 7 Moore, M. J. (2019). How can we all stop killing whales: a proposal to avoid whale entanglement in fishing gear. ICES Journal of Marine Science, 1-6, doi:10.1093/icejms/fsy194. 8 Id. 9 See https://www.cbc.ca/news/canada/new-brunswick/third-right-whale-calf-spotted-1.4984202.

Report (EIR) that ensures that the Project will minimize damage to the Commonwealth’s natural resources.10 The Commonwealth must also meet its obligations under the Massachusetts Ocean Act of 2008 to ensure that “all certificates, licenses, permits and approvals for any proposed structures, uses or activities” are “consistent, to the maximum extent practicable, with the plan.” See Chapter 114 of the Acts of 2008 – An Act Relative to Oceans. The Commonwealth must also meet its obligations under the Coastal Zone Management Act of 1972, 16 U.S.C. § 1451 et seq., when it completes its federal consistency review. Id. at § 1456.

There are a number of potential impacts to North Atlantic right whales associated with offshore wind energy development and operation, most notably potential injury and disruption of normal feeding, breeding, and migratory behaviors due to pre-construction and construction noise and heightened collision risk from construction and service vessels. The potential impacts to right whales of offshore wind development led five of the leading scientific experts on North Atlantic right whales to send a letter to the Bureau of Ocean Energy Management (BOEM) and the National Oceanic and Atmospheric Administration (NOAA) on September 19, 2018 with their recommendations for “adequate and effective mitigation of impacts to the North Atlantic right whale during offshore wind development and operations.” In this letter, included as Attachment B, the scientists recommend a detailed package of mitigation measures including a seasonal prohibition on pile driving, vessel speed restrictions, monitoring, and the employment of noise attenuation technologies.

As described above in Section I, on January 22, 2019, Vineyard Wind signed an historic agreement with NRDC, NWF, and CLF to deploy additional mitigation measures to protect the North Atlantic right whale during activities pertaining to the Project’s construction and operations. We strongly recommend that the Secretary incorporate all planned mitigation measures described above in Section I and included in Attachment A into the Final EIR to provide a more accurate description of Vineyard Wind’s commitment to implementing extensive mitigation to protect North Atlantic right whales. These mitigation measures may also lead to enhanced protection for other marine mammals in the project area.

2. The Secretary’s Certificate should support the Preferred Route of Covell’s Beach as the preferred landfall for the offshore export cable.

Our organizations have a strong preference for the offshore export cable landfall at the Covell’s Beach location, now identified in the FEIR as the Preferred Route. This location and the use of horizontal directional drilling (HDD) technology will result in fewer impacts and risks to winter flounder spawning areas, horseshoe crabs, and other benthic resources as compared to the New Hampshire Avenue Route, listed as the Notice Alternative Route, that runs through Lewis Bay. HDD will help to avoid disturbance of the nearshore area, tidal zone, beach, and coastal dunes.11

10 See G.L. c. 30, § 61 (“All agencies, departments, boards, commissions and authorities of the commonwealth shall review, evaluate, and determine the impact on the natural environment of all works, projects or activities conducted by them and shall use all practicable means and measures to minimize damage to the environment.”). 11 It is our understanding that the Covell’s Beach landfall (Preferred Route) is the preferred cable landing site for the Project and that the company signed a Host Community Agreement with the Town of Barnstable in October 2018 indicating its intention to land the cable at Covell’s Beach and detailing various measures to minimize impacts to the Town of Barnstable. See https://www.southcoasttoday.com/news/20181004/vineyard-wind-barnstable-officials-sign- agreement-on-cable-project.

Horseshoe crabs are of particular concern because of their declining abundance in New England.12 Because horseshoe crabs use Covell’s Beach as a spawning site, we believe that additional protective measures are warranted, including the use of HDD,13 to avoid disruption of horseshoe crab spawning activities.

We also note that the surveys by Vineyard Wind recently identified patches of eelgrass near Spindle Rock. Eelgrass, an important nursery habitat for a variety of marine species, is a declining species in Massachusetts. Eelgrass near Spindle Rock should be avoided by realigning the cable at an angle as it approaches Covell’s Beach.

We also note that the Project will take place in Essential Fish Habitat designated for many fish and shellfish species including a number of depleted and overfished populations such as Atlantic cod, winter flounder, Atlantic wolffish, and yellowtail flounder. There are also four species listed under the U.S. Endangered Species Act (ESA) present in the Project Area, including Atlantic salmon, Atlantic sturgeon, shortnose sturgeon, and giant manta ray.14 As a general matter and to ensure minimal impact on Essential Fish Habitat species and those listed under the ESA, we recommend that Vineyard Wind work closely with the Massachusetts Division of Marine Fisheries (DMF) and NMFS to consider and implement appropriate mitigation measures to avoid, minimize, and mitigate potential adverse impacts to Essential Fish Habitat, fish and invertebrate populations which may be affected by construction activities particularly during vulnerable times of spawning, larval settlement, and juvenile development. We note that DMF has indicated that cable-laying in July and August instead of April and May avoids a more sensitive time of year for a wide array of natural resources that are actively reproducing and settling in the springtime in Nantucket Sound. We encourage Vineyard Wind to continue their ongoing discussions about appropriate time of year considerations, noting Vineyard Wind’s need for safe operational conditions for cable-laying vessels and the need to complete the project by May-June of 2021 so that power can be delivered by January 2022.

3. The Secretary’s Certificate should recognize the benefits of Vineyard Wind’s Agreement on Right Whale Core Habitat.

The FEIR states that the project will not impact Core Habitat of the North Atlantic right whale, defined as a Special, Sensitive and Unique area (SSU) in the Massachusetts Ocean Plan15 (see, for example, pages 1-81, 1-84, 2-1, 5-2). We appreciate that the Vineyard Wind Project avoids construction directly in the right whale Core Habitat SSU. We note, however, that activities that occur outside of the Core Habitat can impact North Atlantic right whales that may be in the Core Habitat SSU. Implementation of the mitigation measures contained in Attachment A, will help

12 2018 Review of the Atlantic States Marine Fisheries Commission Fishery Management Plan for Horseshoe Crab (Limulus polyphemus), 2017 Fishing Year. Available at: http://www.asmfc.org/uploads/file/5c06e2c9HSC_FMPReview_2018.pdf. 13 It is our understanding that the Massachusetts Division of Marine Fisheries (MA DMF) has determined that the use of HDD for landfall at Covell’s Beach “should avoid any disturbance to horseshoe crab spawning habitat.” See the letter from MA DMF in the Massachusetts Final Environmental Impact Review, p. 199, available at https://vineyardwind.app.box.com/s/9mg2zp4nuy80cf8pdljd1dw08ku8deh6. 14 DEIS, Appendix B, Table B.5-2, pp. B-15 – B-16. 15 Available at https://www.mass.gov/service-details/massachusetts-ocean-management-plan.

protect right whales that may be in the Core Habitat through speed restrictions and enhanced monitoring and thus provide increased protection of the Core Habitat SSU.

4. The Secretary’s Certificate should recognize Vineyard Wind’s ongoing need to work with state agencies to refine the offshore cable alignment to avoid Hard/Complex Seafloor.

Extensive benthic surveying has been undertaken by Vineyard Wind to map benthic habitat within the proposed cable corridors, and in particular, to update the information on hard/complex seafloor habitat which is identified in the Massachusetts Ocean Plan as an SSU. Hard/complex seafloor habitat supports a diversity of marine life including sea anemones, sponges, and bryozoans that are important habitat for a number of fish species. The rocks, boulders and cobble seafloor found in this type of habitat provide places to hide from predation and structure for successful reproduction for many species including Atlantic cod, Atlantic wolffish and lobster, among others.16 We encourage Vineyard Wind to continue to work with state agencies to further refine as feasible the cable alignment within the identified export cable corridors to avoid and minimize impact to this particularly important habitat.

5. The Secretary’s Certificate should include provisions for long-term monitoring before, during, and after construction to document changes to the marine environment and its ecological communities in and around the Project Area.

Given that the offshore wind energy industry is in its infancy in the Atlantic and much will be learned during the construction and operation of the Vineyard Wind wind energy facility including the wind turbines and offshore export cable, a comprehensive monitoring effort is needed. As a general matter long-term monitoring before, during, and after construction to document changes to the marine environment and its ecological communities in and around the full project Area, including the wind turbine area as well as the offshore export cable route, is critically important. If significant impacts are detected, Vineyard Wind should work with federal and state agencies as necessary, to design appropriate adaptive mitigation strategies to address impacts identified. The FEIR contains a Benthic Habitat Plan (FEIR Attachment D) which Vineyard Wind will implement to document disturbance and recovery of marine and benthic communities related to the construction and installation of the Project. Pre- and post-construction monitoring surveys will be conducted. We understand that Vineyard Wind will work with state and federal agencies to conduct pre- and post-monitoring surveys of fisheries resources, and we encourage this action. As part of its recent Agreement with NGOs, Vineyard Wind has also committed funding to advancing understanding of the effects of offshore wind development on marine and coastal resources, the effectiveness of mitigation measures, and strategies to reduce other stressors facing affected species, such as the North Atlantic right whale (see Attachment A). Data gathered from these monitoring studies should be made publicly available and, as appropriate, incorporated into the Massachusetts Ocean Resource Information System17 and the Northeast Ocean Data Portal.18

16 Massachusetts Ocean Plan Baseline Assessment. December 2009. Massachusetts Office of Coastal Zone Management. Available at https://eeaonline.eea.state.ma.us/EEA/eeawebsite/mop/final-v2/v2-complete.pdf. 17 Available at https://www.mass.gov/service-details/massachusetts-ocean-resource-information-system-moris. 18 Available at https://www.northeastoceandata.org/.

6. The Secretary’s Certificate must include consideration of the full scope of impacts to state and federally protected birds.

The Secretary’s Certificate must address the full range of potential impacts on all bird species known to forage and rest in state and/or federal waters in or near the Project Area, or to migrate through the area, including those species protected under the MESA, federal Migratory Bird Treaty Act (MBTA) and the ESA.

We are aware that the Department of the Interior (DOI) and the U.S. Fish and Wildlife Service (FWS) are now relying on a new interpretation of the MBTA that limits the scope of the Act to the purposeful take of birds. Our organizations strongly oppose this interpretation as contrary to the plain MBTA responsibilities as all previous administrations have done in the past, with explicit recognition that incidental take is prohibited. This would also be consistent with the memorandum of understanding that BOEM signed with FWS in 2009 to protect migratory bird populations.19 We note that NRDC and several other organizations and states, have challenged DOI’s unlawful reinterpretation of the Migratory Bird Treaty Act in court.

The Secretary’s Certificate should take care to ensure that all bird species covered by MESA and the MBTA are accounted for in the impact assessment. All Massachusetts bird species are protected and the statement that jaegers and gulls are not species of conservation concern is incorrect.

7. The Executive Office of Energy and Environmental Affairs should coordinate with BOEM to advance further monitoring measures to account for avian survey flaws.

Given that existing survey efforts do not appear to have adequately captured avian use of the Project Area, the Executive Office of Energy and Environmental Affairs (EEA) should coordinate with BOEM to adopt a conservative approach in any Project avian impact analyses. Modeling issues stemming from recent survey efforts must be addressed. For example, BOEM’s recent aerial surveys off the Massachusetts coastline aggregated many medium-sized tern sightings into a shared “tern species” category, which cannot be parsed out to provide detail on the number of endangered roseate terns.20 Further, the Marine-Life Data and Analysis Team predictive models, while excellent for estimating broad-scale, relative patterns of avian abundance along the Atlantic, are not suitable for estimating range and abundance for a rare and narrowly distributed species like the state and federally listed roseate tern.21 As a result, when

19 Memorandum of Understanding Between the Department of the Interior U.S. Minerals Management Service and the Department of the Interior U.S. Fish and Wildlife Service Regarding Implementation of Executive Order 13186, “Responsibilities of Federal Agencies to Protect Migratory Birds” (Jun. 4, 2009). https://www.boem.gov/Renewable-Energy- Program/MMS-FWS_MBTA_MOU_6-4-09-pdf.aspx. 20 Veit, R., White, T., Perkins, S., Curley, S. 2016. Abundance and Distribution of Seabirds off Southeastern Massachusetts, 2011-2015: Final Report. OCS Study BOEM 2016-067. Sterling, Virginia: U.S. Department of the Interior, Bureau of Ocean Energy Management. 21 Curtice C., Cleary J., Shumchenia E., Halpin P.N. 2018. Marine-life Data and Analysis Team (MDAT) technical report on the methods and development of marine-life data to support regional ocean planning and management. Prepared on behalf of the Marine-life Data and Analysis Team (MDAT). Accessed at: http://seamap.env.duke.edu/models/MDAT/MDAT-Technical-Report.pdf.

these and other data deficiencies22 are factored into BOEM’s impact model, roseate tern presence is likely to be underestimated. The core of the roseate tern’s breeding range, which overlaps the Project Area, is small23 and so a conservative approach for this species and others that may be impacted by these surveys should be taken.

In addition to better accounting for potential avian impacts, EEA and BOEM, in partnership with Vineyard Wind and in consultation with the State of Rhode Island, should require long-term project monitoring before, during, and after construction for state and federally listed endangered species like roseate terns, red knots; along with others with a suspected high collision risk, such as shearwaters and jaegers, and incorporate adaptive management measures to address impacts, as needed. * * *

In conclusion, we reiterate our support for responsibly developed offshore wind power and applaud the Commonwealth’s actions to date to advance this important climate and clean energy solution. We look forward to working together to ensure that all projects built to meet the Commonwealth’s goals are developed responsibly with strong protections in place for our most vulnerable coastal and marine wildlife.

Sincerely,

Priscilla M. Brooks, Ph.D. Vice President and Director of Ocean Conservation Conservation Law Foundation

Francine Kershaw, Ph.D. Project Scientist, Marine Mammal Protection and Oceans, Nature Program Natural Resources Defense Council

Catherine Bowes Program Director, Offshore Wind Energy National Wildlife Federation

Jack Clark Director of Public Policy and Public Relations Mass Audubon

Eric Wilkinson General Counsel and Director of Energy Policy Environmental League of Massachusetts

22 The BRI spring tern surveys failed to identify any roseate terns, through of the total of 23 terns found 22% were unidentified and a high proportion of unidentified terms (86%) were noted in transit surveys to and from the lease area. The unpublished nanotag study did not include MOTUS receivers within the area, potentially skewing data results. 23 Nisbet. I.C.T., M. Gochfeld, and J. Burger. “Roseate Tern (Sterna dougallii).” In The Birds of North America, version 2.0. A. F. Poole, Ed. Ithaca: Cornell Lab of Ornithology, 2014.

ATTACHMENT A

Vineyard Wind – NGO Agreement January 22, 2019

This Agreement dated as of January 22, 2019, is made by and between VINEYARD WIND, LLC (“Vineyard Wind”), which has its principal place of business at Suite 510, Bank Plaza, 700 Pleasant Street, New Bedford, MA 02740, the NATIONAL WILDLIFE FEDERATION, the NATURAL RESOURCES DEFENSE COUNCIL, and the CONSERVATION LAW FOUNDATION (the “NGOs”) (collectively the “Parties”).

WHEREAS, the Parties are united in the belief that responsibly developed offshore wind power has a major role to play in America’s energy future;

WHEREAS, the Parties recognize that wind energy does not have the negative climate effects of carbon emissions from other generation sources, and wind power thus helps to ameliorate impacts like ocean acidification, loss of sea ice, sea level rise, more extreme weather, and many other climate effects;

WHEREAS, the Parties are committed to working together to ensure that the development of much-needed wind electricity generation capacity off the nation’s coasts will occur in a manner that avoids, minimizes, and mitigates adverse impacts on the health of our coastal and marine wildlife;

WHEREAS, the development of offshore wind energy provides a unique opportunity for offshore wind developers to collaborate with academic research institutions, government, environmental organizations, ocean user groups and other stakeholders to advance scientific research that enhances protections for the critically endangered North Atlantic right whale, including research on the effects, if any, of wind farm operations on right whale distribution and habitat use;

WHEREAS, Vineyard Wind is committed to developing offshore wind power projects in the U.S. with robust standards of environmental protection during pre-development, construction, and operations and maintenance activities, while making a meaningful contribution to science that can support the responsible development of America’s vast offshore wind resources;

WHEREAS, the protection of the North Atlantic right whale is a top priority, the Parties recognize and agree that protective actions set forth herein must be done in a manner that ensures human health and safety when working in the offshore environment; Vineyard Wind – NGO Agreement January 22, 2019

WHEREAS, while this Agreement pertains to protections for the North Atlantic right whale specifically, the Parties agree that the measures set forth herein may also provide additional protections to other marine mammals and protected species;

WHEREAS, this agreement is intended to serve as a model for similar agreements pertaining to offshore wind projects along the East Coast;

WHEREAS, the Parties agree that the commitments made herein apply specifically and solely to Vineyard Wind’s first 800 MW project located in the northern portion of the lease area OCS-A-501 (the “Project Area”), and as more fully described in the Construction and Operations Plan submitted to the Bureau of Ocean Energy Management (“BOEM”) dated December 19, 2017, as supplemented thereafter (the “Project”).

NOW THEREFORE, in consideration of the foregoing the Parties agree as follows:

I. Protective Measures for North Atlantic Right Whales

Vineyard Wind agrees to implement the following measures for responsible offshore wind development in constructing and operating the Project.

A. Construction Activities

Table 1. Seasonal Restrictions on Pile Driving Activities Timeframe Mitigation Protocol

Red Period: January 1 – April 30 No pile driving

Yellow Period: November 1 – December 31; May 1 – 14 Enhanced mitigation protocol required

Green Period: May 15 – October 31 Comprehensive monitoring / clearance zone protocol required

1. Red Period: No Pile Driving

During this period of most likely presence of North Atlantic right whales, as specified in Table 1, no pile driving shall occur.

2. Yellow Period: Enhanced Mitigation Protocol for Pile Driving

During the times of likely presence of North Atlantic right whales, as specified in Table 1, an Enhanced Mitigation Protocol will be implemented during each day that pile driving is scheduled to take place. This will include:

2 Vineyard Wind – NGO Agreement January 22, 2019

a) Pile driving shall not be initiated at night or when the clearance zone cannot be visually monitored, as determined by the lead Protected Species Observer (hereafter, “PSO”)1 on duty. Pile driving may continue after dark only if the action began during the day and must proceed for human safety or installation feasibility2 reasons;

b) A clearance zone for North Atlantic right whales shall extend 10,000 meters in all directions from the center of the pile. Pile driving activities shall not be initiated when there is either a visual observation or acoustic detection of one or more North Atlantic right whales within the clearance zone through (i.), (ii.), or (iii.) of this section, and shall be shut-down under either of these circumstances unless it must proceed for human safety or installation feasibility reasons.

i. Real-time passive acoustic monitoring (“PAM”)3, assuming a detection range of 10,000 meters, shall be undertaken from a vessel other than a pile driving vessel, or from a stationary unit, to avoid the hydrophone being masked by the pile driving vessel or development-related noise and to ensure that the clearance zone is clear of North Atlantic right whales. PAM shall begin at least 60 minutes prior to commencement of pile driving and shall be conducted throughout the time of pile driving activity; and

ii. There shall be vessel-based PSOs stationed at the pile driving site. There shall be a minimum of four PSOs following a two-on, two-off rotation, each responsible for scanning no more than 180° per pile driving event. Observation shall begin at least 60 minutes prior to the commencement of pile driving and shall be conducted throughout the time of pile driving activity; and

iii. Between May 1 – 14, a track-line survey fully covering the clearance zone to detect the presence of North Atlantic right whales must be completed prior to commencement of pile driving using at least one of the following methods:

1 PSO refers to an individual with current National Marine Fisheries Service (“NMFS”) certification as a Protected Species Observer. 2 Installation feasibility refers to ensuring that the pile installation event results in a usable foundation for the wind turbine (e.g., installed to the target penetration depth without refusal and with a horizontal foundation/tower interface flange). In the instance where pile driving is already started and a PSO recommends pile driving be halted, the lead engineer on duty will evaluate the following: 1) Use the site-specific soil data and the real-time hammer log information to judge whether a stoppage would risk causing piling refusal at re-start of piling; and 2) Check that the pile penetration is deep enough to secure pile stability in the interim situation, taking into account weather statistics for the relevant season and the current weather forecast. Determinations by the lead engineer on duty will be made for each pile as the installation progresses and not for the site as a whole. This information will be included in the reporting for the Project. 3 Throughout this agreement “PAM” refers to a real-time passive acoustic monitoring system, with equipment bandwidth sufficient to detect the presence of vocalizing North Atlantic right whales.

3 Vineyard Wind – NGO Agreement January 22, 2019

• An aerial survey, weather permitting (based on safe flying conditions), conducted once the lead aerial observer4 determines adequate visibility based on standardized environmental parameters (e.g., glare, sea state, wind speed, etc.); or • A vessel-based survey carried out by PSOs conducted during daylight hours.

c) Pile driving may resume upon confirmation that all North Atlantic right whales have departed the clearance zone:

i. May 1 – 14: after one day of monitoring using methods described in (b.i.), (b.ii.), and (b.iii.) of this section.

ii. November 1 – December 31: methods listed under (b.i.) and (b.ii.) of this section may be used by the lead PSO on duty to confirm that the whales have departed the 10,000 meter zone; if so, piling may commence following observance of the clearance zone monitoring protocol described in (b.i.) and (b.ii.).

3. Green Period: Comprehensive Monitoring / Clearance Zone Protocol for Pile Driving

During this period of less likely presence of North Atlantic right whales, as specified in Table 1, a Comprehensive Monitoring / Clearance Zone Protocol will be implemented during each day that pile driving is scheduled to take place. This will include:

a) Pile driving shall not be initiated at night or when the clearance zone cannot be visually monitored, as determined by the lead PSO on duty. Pile driving may continue after dark only if the action began during the day and must proceed for human safety or installation feasibility reasons; and

b) A clearance zone for North Atlantic right whales shall extend a minimum of 1,000 meters in all directions from the center of the pile. Pile driving activities shall not be initiated when there is either the visual observation or acoustic detection of one or more North Atlantic right whales within the clearance zone through (i.) and (ii.) of this section and shall be shut down under either of these circumstances unless it must proceed for human safety or installation feasibility reasons. If a shut-down is implemented, pile driving may resume upon confirmation that all North Atlantic right whales have departed the clearance zone after 60 minutes of monitoring through (i.) and (ii.) of this section.

4 The lead aerial observer shall be selected from a roster of qualified lead aerial observers who are available for duty with 12 hours’ notice. This roster to be provided by either the New England Aquarium, the Center for Coastal Studies, National Oceanic and Atmospheric Administration (“NOAA”), or other organizations recommended by the organizations listed in this sentence. The Project will use only observers from this roster to the extent they are available at the time needed to perform the monitoring.

4 Vineyard Wind – NGO Agreement January 22, 2019

i. Real-time PAM will be implemented at least 60 minutes prior to pile driving. PAM will be undertaken from a vessel other than the pile driving vessel, or from a stationary unit, to avoid the hydrophone being masked by the pile driving or other development-related noise; and

ii. There shall be a minimum of four PSOs stationed at the pile driving site, following a two- on, two-off rotation, each responsible for scanning no more than 180° per pile driving event. Observation will begin at least 60 minutes prior to the commencement of pile driving and shall be conducted throughout the period of pile driving activity.

4. Installation of Jacket Foundations

No more than two jacket foundations will be installed.

B. Geophysical Surveys During Construction and Post-Construction

This section does not refer to any geophysical surveys carried out as part of site assessment and characterization (“SAC”) stage of offshore wind development. The Parties believe further discussion is necessary to agree upon feasible protocols for SAC surveys that would allow Vineyard Wind to meet BOEM geophysical survey requirements.

Table 2. Seasonal Restrictions on Geophysical Surveys During Construction and Post-Construction Timeframe Mitigation Protocol

Red Period: January 1 – May 14 No geophysical surveys with RMS sound pressure levels > 180 dB re 1 uPa at 1 meter for equipment that operates between 7 Hz and 35 kHz unless with Enhanced Mitigation Protocol

Green Period: May 15 – December 31 Comprehensive monitoring / clearance zone protocol required

1. Red Period: No Surveys or Surveys with Enhanced Mitigation Protocol

During this period, as specified in Table 2, no surveys with RMS sound pressure levels > 180 dB re 1 uPa at 1 meter for equipment that operates between 7 Hz and 35 kHz shall occur. An exception can be made for infrequent geophysical surveys that are essential during the construction and micro-siting of the Project to ensure proper installation or maintenance of the Project post-construction. In these instances, the following enhanced mitigation protocol shall be implemented:

a) A clearance zone for North Atlantic right whales shall extend 1,000 meters in all directions from the survey vessel;

5 Vineyard Wind – NGO Agreement January 22, 2019

b) Surveys shall not be initiated at night or when there is either a visual observation or an acoustic detection (confirmed by visual observation) of one or more North Atlantic right whales within the clearance zone and shall be shut down under either of these circumstances. After daylight hours, surveys shall be shut down following an acoustic detection only. Observation and PAM shall begin at least 60 minutes prior to commencement of the survey and shall be conducted throughout the period of the survey activity. Surveying may resume upon confirmation that all North Atlantic right whales have departed the clearance zone after 60 minutes of both visual and acoustic monitoring; and

i. Real-time PAM shall be undertaken in a manner that avoids masking of the North Atlantic right whale vocalizations by vessel noise, including use of a system that is independent from the survey vessel if necessary; and

ii. There shall be a minimum of four PSOs following a two-on, two-off rotation, each responsible for scanning no more than 180°.

c) Survey equipment will commence following a ramp-up procedure and will be operated at the lowest source level feasible to meet survey requirements.

2. Green Period: Comprehensive Monitoring / Clearance Zone Protocol for Surveys

During this period, as specified in Table 2, a Comprehensive Monitoring/ Clearance Zone Protocol will be implemented during all surveys with RMS sound pressure levels > 180 dB re 1 uPa at 1 meter for equipment that operates between 7 Hz and 35 kHz. This will include:

a) A clearance zone for North Atlantic right whales shall extend 500 meters in all directions from the survey vessel and, to the extent feasible, shall be extended to 1,000 meters;

b) Surveys shall not be initiated when there is either a visual observation or an acoustic detection of one or more North Atlantic right whales within the clearance zone and shall be shut down under either of these circumstances. After daylight hours, surveys shall be shut down following an acoustic detection only. Visual and acoustic surveys shall begin at least 30 minutes prior to commencement of survey activity and shall be conducted throughout the period of the activity. Surveying may resume upon confirmation that all North Atlantic right whales have departed the clearance zone after 30 minutes of visual or acoustic monitoring; and

6 Vineyard Wind – NGO Agreement January 22, 2019

ii. The clearance zone shall be monitored by at least one PSO and at least two PSOs if feasible.

c) Survey equipment will commence following a ramp-up procedure and will be operated at the lowest source level feasible to meet survey requirements.

C. Vessel Speed Restrictions

All Project-associated vessels shall adhere to the following speed restrictions:

1. A mandatory speed restriction of 10 knots shall be observed within Dynamic Management Areas (“DMAs”) established by National Oceanic and Atmospheric Administration (“NOAA”) Fisheries, with the exception of crew transfer vessels.5

2. A mandatory speed restriction of 10 knots shall be observed within DMAs established by NOAA Fisheries by crew transfer vessels, unless the following procedures result in confirmation that the North Atlantic right whales are clear of the transit route and Project Area for two consecutive days:

(a) Vessel based surveys carried out by PSOs conducted during daylight hours and real- time PAM shall be undertaken, in a manner that avoids masking of the North Atlantic right whale vocalizations by vessel noise; or

(b) An aerial survey, weather permitting (based on safe flying conditions), conducted once the lead aerial observer6 determines adequate visibility based on standardized environmental parameters (e.g., glare, sea state, wind speed, etc.) and real-time PAM shall be undertaken, when feasible, in a manner that avoids masking of the North Atlantic right whale vocalizations by vessel noise.

5 A crew transfer vessel is a vessel whose principle purpose is to transfer technicians who work offshore, and the supplies and small-scale components used by these technicians, to and from a port facility and their offshore work location. 6 The lead aerial observer shall be selected from a roster of qualified lead aerial observers who are available for duty with 12 hours’ notice. This roster to be provided by either the New England Aquarium, the Center for Coastal Studies, NOAA, or other organizations recommended by the organizations listed in this sentence. The Project will use only observers from this roster to the extent they are available at the time needed to perform the monitoring.

7 Vineyard Wind – NGO Agreement January 22, 2019

(c) Following clearance from C. 2. (a.) and (b.), vessel transits conducted within a DMA will employ at least two observers7 aboard the vessel to visually monitor for North Atlantic right whales. If a North Atlantic right whale is spotted within or approaching the transit route, vessels shall operate at less than 10 knots until the procedures in C. 2. (a.) and (b.) result in clearance of the transit route for two consecutive days.

3. From November 1 through May 14:

(a) A 10-knot speed restriction shall be observed by all vessels, with the exception of crew transfer vessels operating within and transiting to/from the lease area and vessels operating in Nantucket Sound (which has not been demonstrated by best available science to provide consistent habitat for North Atlantic right whales).

(b) A 10-knot speed restriction shall be observed by crew transfer vessels operating within and transiting to/from the Project Area (except while in Nantucket Sound, which has not been demonstrated by best available science to provide consistent habitat for North Atlantic right whales) unless the following measures are in place:

i. At least one observer,8 and two when personnel are available, aboard the vessel to visually monitor for North Atlantic right whales; and

ii. Real-time PAM shall be undertaken in a manner that avoids masking of the North Atlantic right whale vocalizations by vessel noise.

iii. If a North Atlantic right whale is detected as a result of the monitoring measures identified in (i.) and/or (ii.) of this section, a 10-knot speed restriction shall be in effect for the remainder of the day.

D. Reporting

Vineyard Wind commits to report all visual observations and acoustic detections of vocalizing North Atlantic right whales to the National Marine Fisheries Service (“NMFS”) or the Coast Guard within two hours of occurrence when feasible and no later than the end of their shift.

7 During construction the observers shall be NMFS certified PSOs. During Project operations and maintenance, the observers shall have North Atlantic right whale observer training provided by a company utilized by NMFS for PSO training or recommended by the organizations listed in in footnote 6. Two individuals shall be designated during each vessel trip to conduct monitoring. 8 See footnote 7.

8 Vineyard Wind – NGO Agreement January 22, 2019

E. Underwater Noise Reduction

Vineyard Wind is committed to employing technically and commercially feasible noise reduction and attenuation measures that minimizes impacts to North Atlantic right whales and other high- priority species. Vineyard Wind will implement attenuation mitigation to reduce sound levels by a target of 12 dB. A noise attenuation technology will be implemented (e.g., Noise Mitigation System [NMS], Hydro-sound Damper [HSD], Noise Abatement System [AdBm], bubble curtain, or similar), and a second back-up attenuation technology (e.g., bubble curtain or similar) will be on- hand, to be used if needed given results of field verification. For the Project, Vineyard Wind will not request Level A takes of a North Atlantic Right Whale. Vineyard Wind will inform and receive input from the other Parties as it identifies noise attenuation measures and technologies to be used for the Project.

F. Additional Mitigation Strategies

In addition to the above measures designed to avoid and minimize impacts to North Atlantic right whales, Vineyard Wind commits to considering other mitigation approaches aimed at overall species protection.

II. Commitment to Collaborative Science

Vineyard Wind has made a $3 million commitment to develop and deploy technologies that ensure heightened protections for North Atlantic right whales and other marine mammals as the U.S. offshore wind industry continues to grow. Vineyard Wind commits to implement the following principles when undertaking marine science and science-based conservation efforts:

A. Plan and conduct science and science-based conservation efforts in a collaborative and transparent manner, utilizing recognized marine experts, engaging relevant stakeholders, and making results publicly available;

B. Contribute to the field of marine science and make efforts to address the priorities defined by regional and state ocean planning efforts; and

C. Advance understanding of the effects of offshore wind development on marine and coastal resources, the effectiveness of mitigation measures (e.g., noise attenuation, thermal detection), and strategies to reduce other stressors facing affected species (e.g., incidental fishing gear entanglement reduction), such as the North Atlantic right whale.

III. Inclusion of Protective Measures in Agency Submittals

Where Vineyard Wind seeks state and federal authorizations to conduct Project activities that may potentially affect the North Atlantic right whale, Vineyard Wind agrees to propose mitigation strategies

9 Vineyard Wind – NGO Agreement January 22, 2019 consistent with the protective measures set forth herein as they relate to the activity for which authorization is sought. Vineyard Wind will also inform the relevant state and federal agencies of Vineyard Wind’s voluntary commitments under this Agreement. To the extent that a state or federal agency declines to adopt, for regulatory purposes, a protective measure specified herein, Vineyard Wind will nevertheless implement the measure provided it does not conflict with regulatory requirements.

IV. Modeling and Adaptive Management

The intent of this agreement is to minimize disruption of normal feeding, breeding and migratory behaviors and prevent injury to right whales. The mitigation measures of this Agreement aim to lower risk from injury to a level approaching zero and to reduce other effects caused by marine noise significantly below that estimated in BOEM’s December 2018 Draft Environmental Impact Statement (“DEIS”) for Vineyard Wind. The Parties’ expectation is that the mitigation measures included in this agreement will meet these goals. To confirm this before construction, Vineyard Wind agrees to re-run and share with the Parties its piling noise exposure model to incorporate the execution of mitigation measures in this Agreement and the Project parameters (e.g., number of monopiles, number of jackets) planned to actually be built (as opposed to the permitting envelope analyzed in the DEIS). Should the revised modeling not demonstrate that impacts from construction are reduced to the levels described in this paragraph, the Parties will consider additional mitigation measures.

While this Agreement applies only to Vineyard Wind’s 800 MW project located in the northern portion of the lease area OCS-A-501, the Parties recognize that Vineyard Wind intends to propose future projects. In a good faith effort to continue to work collaboratively and evaluate lessons learned from the Project subject to this Agreement, every two years, or if one of the Parties so requests, the Parties agree to review the scientific data on the occurrence, abundance, habitat use, and conservation status of North Atlantic right whales, particularly in the vicinity of the Project Area, along with any other relevant data, including information on new noise attenuation and monitoring technologies or practices that have become available. This review will inform future projects and agreements between the Parties. To the extent that new protective measures are identified relevant to this Project, Vineyard Wind agrees to evaluate their technical and commercial feasibility and implement them if appropriate.

V. Dispute Resolution

In the event of a dispute among the Parties concerning implementation of or compliance with any aspect of this Agreement, the initiating Party or Parties shall provide the other Party or Parties with a written notice outlining the nature of the dispute and the remedy that is sought. The Parties shall meet and confer, either in person or over the telephone, to work in good faith to attempt to resolve the dispute, including by modification of the agreement if all Parties agree. If agreement on the appropriate resolution of the dispute cannot be reached, the Parties reserve their right to withdraw from the agreement as a last resort.

10 Vineyard Wind – NGO Agreement January 22, 2019

VI. Term of Agreement

The Parties agree that the protective measures set forth herein will remain in place for five years unless extended or modified by mutual agreement of the Parties.

[SIGNATURE PAGE TO FOLLOW]

11 Vineyard Wind – NGO Agreement January 22, 2019

Vineyard Wind, LLC Natural Resources Defense Council

By: By:

Name: Erich Stephens Name: Katherine Kennedy Chief Development Officer Senior Director, Climate & Clean Energy Program

Date: January 22, 2019 Date: January 22, 2019

National Wildlife Federation Conservation Law Foundation

By: By:

Name: Collin O’Mara Name: Priscilla Brooks, Ph.D. President & Chief Executive Officer Vice President and Director of Ocean Conservation

Date: January 22, 2019 Date: January 22, 2019 NWF ID: 1901-041

12 ATTACHMENT B September, 19th, 2018

Mr. James F. Bennett Ms. Donna Wieting Chief of the Office of Renewable Director, Office of Protected Resources Energy Programs National Marine Fisheries Service Bureau of Ocean Energy Management National Oceanic and Atmospheric United States Department of the Interior Administration 1849 C Street, NW 1315 East-West Hwy. Washington D.C., 20240 Silver Spring, Maryland 20910 [email protected] [email protected]

Dear Mr. Bennett and Ms. Wieting,

We respectfully submit this letter presenting recommendations for adequate and effective mitigation of impacts to the North Atlantic right whale during offshore wind development and operations. These recommendations are based on our expertise as marine scientists working on North Atlantic right whales and marine mammal acoustics.

The most effective means of protecting North Atlantic right whales from injury and harassment from noise generated during the offshore wind construction phase is to implement a temporary prohibition on pile driving during periods of heightened vulnerability. Periods of heightened vulnerability are defined by the following criteria: (i) phases when a higher relative density of animals is present, or expected to be present, within the project site; and (ii) phases when mother-calf pairs, pregnant females, aggregations of three or more whales (including surface active groups; indicative of feeding or social behavior), or entangled animals, are, or are expected to be, present.

In line with the best available science on North Atlantic right whale distribution and abundance in the waters off Rhode Island and Massachusetts, we recommend the following seasonal prohibition on pile driving and, if development activities absolutely cannot be avoided, the implementation of an enhanced mitigation protocol during the following times for leases within the Rhode Island/Massachusetts and Massachusetts Wind Energy Areas:

 January 1st – April 30th: Prohibition on pile driving.  May 1st – 14th and November 1st – December 31st: Enhanced mitigation protocol in place during pile-driving.

Temporary prohibitions should also be defined for all lease areas along the Atlantic coast based on the best data available for those regions. The enhanced mitigation protocol should be developed for individual offshore wind projects via a participatory process that includes scientists, offshore wind developers, and environmental groups. As North Atlantic right whale distribution is known to be shifting, we recommend the dates of these restrictions and the enhanced mitigation protocol be reassessed every two years by an independent advisory group based on the best scientific and commercial data available. Noise reduction and attenuation technologies should also be required throughout the entire construction period to the maximum extent practicable, thereby directly addressing one of the primary impacts to marine mammals from offshore wind development.

The probability of serious injury or mortality of North Atlantic right whales significantly increases when vessels of any length are traveling at speeds greater than ten knots. Vessel-based right whale monitoring measures must be employed by the offshore wind industry, including the staffing of at least one PSO aboard industry vessels and the real-time acoustic monitoring of major vessel routes (e.g., using fixed location hydrophones with real-time reporting to transiting vessels). In addition, all vessels operating within or transiting to/from lease areas are strongly urged to observe a speed restriction of ten knots during periods of time involving the confirmed presence of North Atlantic right whales or the expected presence of mother-calf pairs, pregnant females, and aggregations of three or more whales, based on best available science. A compulsory vessel speed restriction of ten knots must be required of industry vessels within any Dynamic Management Areas established by NOAA Fisheries.

We also encourage your agencies to incentivize the use of alternative vessel types by the offshore wind industry that would significantly reduce the risk to North Atlantic right whales (e.g., hovercraft); the use of these vessels would significantly reduce the number of vessel speed mitigation measures presently required of the industry. Similarly, significant resources should be directed towards the research, development, and implementation of improved noise reduction and attenuation technologies for deployment during construction.

Thank you in advance for your consideration of our comments. We would be happy to meet with you or your staff to discuss our recommendations in more detail.

Sincerely,

Scott Kraus, Ph.D. Vice President and Senior Science Advisor Chief Scientist, Marine Mammals Anderson-Cabot Center for Ocean Life New England Aquarium

Ester Quintana, Ph.D. Chief Scientist, Marine Mammal Surveys Anderson-Cabot Center for Ocean Life New England Aquarium

Aaron Rice, Ph.D. Science Director, Bioacoustics Research Program The Cornell Lab of Ornithology Cornell University

Caroline Good, Ph.D. Adjunct Research Professor Nicolas School of the Environment Duke University

Mark Baumgartner, Ph.D. Associate Scientist Biology Department Woods Hole Oceanographic Institution MS #33, Redfield 256 Woods Hole, MA 02543

January 22, 2019

Mr. Matthew Beaton, Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) MEPA Office Purvi Patel, EEA No. 15787 (Vineyard Wind Connector) 100 Cambridge Street, Suite 900 Boston, MA 02114

Dear Secretary Beaton and Ms. Patel,

Please accept this letter on Massachusetts Climate Action Project (MCAN) in support of the Vineyard Wind Connector project. MCAN is a 501(c)(3) non-profit that works on the state and municipal level with 51 local chapters representing more than 70 communities in Massachusetts to fight climate change by promoting clean energy and educating the public on the dangers of dirty energy.

MCAN supports the Commonwealth’s nation leading efforts to harness offshore wind, an abundant renewable energy resource. Offshore wind has the potential to dramatically lower power sector pollution, replace retiring coal and nuclear power plants, and grow our green economy. In light of the urgency of the climate crisis, Massachusetts should do everything in its power to rapidly reduce pollution and facilitate the development of responsibly-sited renewable energy projects.

The Vineyard Wind Connector project will bring pollution free electricity from the country’s first large-scale wind farm to shore on Cape Cod. The Final Environmental Impact Report (FEIR) submitted by Vineyard Wind shows the project’s overall impact on the environmental and local communities will be minimal. The FEIR also shows that Vineyard Wind has worked closely with local community leaders and elected officials to mitigate impacts and build support for the project. The Host Community Agreement that Vineyard Wind has signed with Barnstable, which establishes a cooperative relationship between the town and the company and will provide significant economic benefits to local residents.

Finally, Vineyard Wind is a local company with significant ties to the community. Massachusetts has more to gain economically and otherwise when it supports renewable energy projects developed by local companies with staff that live and work in the state.

For all of these reasons, MCAN supports the Vineyard Wind Connector and respectfully requests that it be allowed to move forward.

Thank you for your consideration.

Sincerely,

Carol Oldham Executive Director

36 Bromfield St, Suite 36, Boston MA 02108 (781) 691-5519 www.massclimateaction.net

Patel, Purvi (EEA)

From: [email protected] Sent: Saturday, January 26, 2019 2:50 PM To: Patel, Purvi (EEA) Cc: Sedor, Kathryn (DPU); [email protected]; [email protected]; [email protected]; Pierce, David (FWE); Ford, Kathryn (FWE); [email protected] Subject: Spelling Correction

* statutes --- Paragraph 8.

Our apologies.

-----Original Message----- From: Arthur Warren To: Patel, Purvi (ENV) Cc: [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] Sent: Fri, Jan 25, 2019 4:53 pm Subject: Written Comment regarding Vineyard Wind FEIR

January 25, 2019

Secretary Matthew A. Beaton Attn: MEPA Office, Purvi Patel Executive Office of Energy and Environmental Affairs 100 Cambridge Street Boston, MA 02114

Re: Vineyard Wind, Petitioner Written Comments regarding FEIR EFSB 17-05; D.P.U.18-18; D.P.U. 18-19

Dear Secretary Beaton:

Please accept this email as our Written Comments regarding the Final Environmental Impact Report (FEIR) filed by Vineyard Wind in the above- referenced matter. 1

We are most concerned that Lewis Bay, a recognized estuary, and the Town of Yarmouth remain in a certain limbo given its status as the identified alternate route for the burial and on-shoring of 800-megawatt transmission cables.

We have observed the review process used by your office and the Energy Facilities Siting Board in regard to the appropriateness of both Covell’s Beach, Barnstable, as the preferred site, and Lewis Bay and New Hampshire Avenue as the alternate site. This review included: Siting Board hearings, filings by the Massachusetts Division of Marine Fisheries, letters and emails of so many Town of Yarmouth residents and Neighborhood Associations, public meetings, the Petition in Opposition to the Burial of Transmission Cables in Lewis Bay signed by more than 2,000 residents and tourists, petitions and letters from the aquafarmers, and the meeting in your office with concerned residents. All of this activity demonstrates the extremely high level of concern regarding the inevitable destruction of Lewis Bay to be caused by the trenching and burial of cables.

We also noted the inability of the Town of Yarmouth to participate meaningfully in the highly technical review of this project, due to lack of environmentally trained personnel and funds for scientific and legal expertise, and its silence in the face of possible exemption for Vineyard Wind of its zoning bylaws.

In particular, we noted that during the public hearings, the Siting Board members raised dozens of questions about the appropriateness of Lewis Bay as a burial and landing site. The testimony of the Vineyard Wind witnesses clearly showed that Nantucket Sound and Covell’s Beach are locations that are clearly superior in their ability to withstand the interruptions caused by any windfarm cabling project. On the other hand, all answers in regard to the industrialization of Lewis Bay by Vineyard Wind described the extreme challenges to boaters and sailors, mooring fields, the aquafarms, the marine life, the plant life, the Town of Yarmouth recreational quahog program, the commercial quahog and scallop programs, and the Town Sailing program which would arise in the event the cables are brought into Lewis Bay.

2 All of these concerns for the health of Lewis Bay raised in the hearings remain unanswered by Vineyard Wind in its FEIR.

All of these concerns bring us to these questions:

1. What is the role of the alternate site?

2. Is it intended to be a site which is equally acceptable as the preferred site, or perhaps has some more challenges but yet is still acceptable if not preferable? We believe this is not the case with Lewis Bay, New Hampshire Avenue and the Town of Yarmouth. From a risk- management analysis, this alternate site is not at all acceptable.

3. By accepting Lewis Bay and New Hampshire Avenue as the alternate site, is the Siting Board stating that this location meets the standards set by the Siting Board for the cabling portion of a wind farm project? We hope not. And if not, will you state that fact in your findings and decision?

4. What recourse do the Town of Yarmouth, the residents, the aquafarmers, the sailors and boaters on Lewis Bay, the commercial shell fishermen, and the tourists have in the event the alternate route becomes the preferred route?

We believe the Massachusetts statues which prescribe the process of identifying preferred and alternate sites is flawed, leaving small towns like Yarmouth without sufficient funds and resources to evaluate, negotiate and defend itself from an unplanned and unsolicited wind farm development. Lewis Bay is an estuary recognized by the U.S. EPA and the Massachusetts EPA and should be accorded protection as such. The Lewis Bay Embayment is part of one of Cape Cod’s watershed receiving

3 precious little fresh water through creeks and streams all of which support Cape Cod’s single source aquifer for drinking water.

It is now the duty of the Siting Board to overcome the deficiencies in the law and set the standards for this project and all future wind farm projects in Massachusetts.

Thank you for your review of our concerns.

Sincerely,

Arthur and Judy Warren 2 Shore Road West Yarmouth, MA 02673 508-380-0355

4 48 Glenwood Street, West Yarmouth, MA 02673

January 25, 2019

purvi.patel@ state.ma.us [email protected] Re: EEA#15787

We submit this in response to the FEIR (12/17/18) and as a summary of the concerns and issues that we have raised with the initial project submission and subsequent filings by Vineyard Wind LLC. As we have expressed before, we do not believe that any approval should be given for the placement of cables in Lewis Bay to either Vineyard Wind or any future entity.

The use of the terms “mitigation, “we will meet with” and “TBF” are of significant concern when you understand this is a “first time” project for this country. There is little evidence in the world of the use of a shallow environmentally fragile bay/estuary being used in this manner. Lewis Bay should not be the site of an experiment when there are other reasonable, economically feasible alternatives available that will not cause the project any delay or compromise.

1. We continue to be surprised by Vineyard Wind’s statements that “certain Yarmouth residents” (pg. 1-4) are concerned about the cable placement, as opposed to the facts that the 1000+ members of the neighborhood associations abutting the Bay continue their active opposition, along with a 2000+ signature petition from Barnstable and Yarmouth of strong opposition that was submitted to Governor Baker last summer. Work schedules and other commitments made attendance at hearings and open houses more difficult for some of the members of the group, but their research and review involved thousands of hours of work here in Yarmouth. This is significant as the “company views community acceptance and support as a significant factor” in their cable placement (12/17/19 Cover letter Pg. 1-4). There is none in Yarmouth.

2. One of the more serious issues for landing in Lewis Bay is the requirement to place their cables over the existing Nantucket Cable. The depth and clearance as proposed at the October hearings is of great concern. There is no need to cross it if landing is made at Covell’s Beach.

3. The entrance to Lewis Bay through the Hyannis Harbor is both difficult and ever changing. Historical maps clearly document this fact, especially in the areas of Egg Island and Smith’s Point. The need for dredging to maintain the essential commercial channel, along with periodic Coast Guard ice breakers is in the area needed for the cable placement. In addition, issues of Roseate tern habitat exist in this area.

4. The Bay is shallow and a designated estuary. It is so shallow that the survey boat employed by Vineyard Wind was not able to survey any of the shoreline of the Bay in 2018! Nitrogen loading and other important environmental issues are of significant concern to town officials and our residents. We are currently working on long-term plans to address the issues and having to “work around” cables may compromise these plans. In addition, the Bay is the site of a variety of commercial shell fishing and recreational use- including mooring, sailing schools and swimming in Yarmouth. Having seen the “floating” of displaced cables at Block Island recently is a reminder that what is considered a safe cable burial depth is still an unknown.

There is constant use of the Bay by both Barnstable and Yarmouth- scheduled year-round ferry boat traffic, commercial fishing boats, tour boats, recreational boating, firework barges, and both commercial and personal aircraft traffic overhead (Runway 15-33).

5. The Division of Marine Fisheries in their October letter cited questions about the use of “mitigation” and the research on electromagnetic fields and sedimentation in such shallow waters. The Association to Preserve Cape Cod also notes in their October letter their concerns about the “resuspension and remobilization of nitrogen” in the Bay.

6. The commercial shell fishermen and the Town have raised serious questions about the sedimentation modeling that was done as it appears to be more of an experiment and never done in shallow waters such as this Bay.

7. The maps developed by Vineyard Wind (Attachment A Figure 2-2) all show that the cables will be placed directly through established mooring fields and shell fishing beds in Lewis Bay, especially as they approach the New Hampshire Avenue landing. In addition, the issue of the manner of cable placement (open trench versus HDD) is still in discussion as the Town prefers the later, which will help to protect/preserve the mooring field.

8. The boat ramp layout for New Hampshire Avenue (Attachment A Figure 2-3) visually demonstrates the havoc of the landing and construction requirements. In previous filings the need to bring barges into the area to support construction has been mentioned, but this drawing clearly shows the closure of the street, denial of access to abutting homes and the inadequacies of the landing and staging area. This is in stark contrast to the Covell’s Beach landing and use of their significant parking lot and surrounding roadways. We have previously submitted photographs of the area, the roadway flooding that occurs weekly and the proximity of power poles/lines, fences and trees in the immediate area and route. The blockage of access for parking of the commercial fisherman/shell fishermen is a major issue. The Board of Selectmen and Yarmouth Police Department have actually held public discussions this past year of how to address the significant parking needs in the area- none of which will be helped by this construction plan! No such issues are present at the Covell’s Beach landing.

9. As the cables progress on the proposed route up Berry Avenue and Higgins Crowell Road, there are additional issues of concern. There will be a need for a Zone 1 area easement from the EPA, the cables will pass through the Thornton Brook area and past Yarmouth’s only police center and 2 public schools. The DOT will require street opening permits, and grants of location need to be obtained. None of these issues exist on the Covell’s Beach landing route. Vineyard Wind even states that the “duct bank has a more straightforward approach to the substation” (12/17/18 Cover letter Pg. 1-5) there.

10. We have discussed in prior submissions our concerns about construction/road disruption in any area of Willow Street as it is the primary ambulance corridor to Cape Cod Hospital. In addition, there are still significant unresolved issues of where cable placement would be made through Yarmouth land- on a yet to be designed bicycle trail and through private property requiring easements. No such issues exist with the recently enacted agreements signed with Barnstable and the easy current roadway access to their existing substation.

11. The Host Agreement signed by Vineyard Wind and the Town of Barnstable allows for the construction of cable ducts from the Covell’s Beach landing into their roadways that are designed to handle not just the current planned project but also a Phase 2/future project. No such opportunity exists with a landing through Lewis Bay and New Hampshire Avenue.

12. When you read the various letters of support it is significant to note that they generally praise the ideas of renewable energy and the excitement of having the first in the nation project here. They talk about our future energy needs. What they do not cite, quite possibly since we have not yet identified a writer who lives on or near Lewis Bay, are the environmental costs to this shallow, fragile Bay. We have stated, and restate now, that we are not opposed to a wind farm and its environmental benefits. We are adamantly opposed to any placement of cables in Lewis Bay!

The opportunity to read and review the multiple filings and massive binders, attend hearings and to participate in the review process of this project has given us the opportunity to better understand the project and have our concerns received and considered. For that we are deeply appreciative.

We believe that although Vineyard Wind has continued to advance their plans with New Hampshire Ave as an alternative landing site, there are too many issues to ever allow the placement of industrial cables in Lewis Bay. There are a number of alternative locations in this State that have less environmental impact and cost, while having community and citizen support. We ask that you do not approve the New Hampshire Avenue landing as their alternative site- and that it never be approved for use by a future entity.

Sincerely, Christine K. Greeley Paul M. Greeley

From: DAVE MAGEE To: Patel, Purvi (EEA) Subject: vineyard wind Date: Thursday, January 24, 2019 5:53:49 PM offshore wind is no good will put the fishermen out of business and just pad the pockets of the politicians. From: David Bernstein To: Patel, Purvi (EEA); Sedor, Kathryn (DPU) Subject: Vineyard Wind Date: Friday, January 25, 2019 1:01:53 PM

Jan. 25, 2019

Dear Presiding Officer Sedor:

The neighborhood associations listed below want to go on record as opposing any approval of the placement of cables in Lewis Bay with a landing at New Hampshire Avenue as an alternative landing for Vineyard Wind, and in the future by any other entity. The environmental impact of the placing of cables through a shallow estuary such as Lewis Bay will have a devastating effect on fishing, shellfish aquaculture, recreation and water quality. Vineyard Wind has wisely moved away from choosing a cable route through Lewis Bay and we support the placing of the cable at Covell’s Beach.

We have submitted many written letters to the EFSB which support our objections. Among those, we wish to highlight the following:

Our 9 Associations represent over 1,000 properties that abut the Bay. The Associations are unanimous in their opposition. We have spent thousands of hours reading all of the Vineyard Wind filings and other research materials from both national and international projects. We have presented our research to Mathew Beaton, Secretary of Energy and Environment. We have also attended all the public hearings where we voiced our objections.

We submitted a petition strongly opposing the placement of cables in the Bay with over 2,000 signatures gathered from both Yarmouth and Barnstable neighborhoods. This petition was submitted to Governor Baker last summer.

The Yarmouth Board of Selectmen unanimously opposed the siting of the cables in the Bay and in the streets of the Town of Yarmouth. They needed to request financial assistance for the legal costs incurred by them to challenge a project they had no interest in but that was being forced on them by a foreign corporation.

There have been many filings with you made by shell fishermen and other individuals familiar with the environmental issues of this Bay. This Bay is environmentally challenged and there is significant work currently being undertaken that is not compatible with the placement of cables that will be there for the next 25 years.

We remain committed to the restoration and preservation of Lewis Bay. Industrial cables are inappropriate in a shallow environmentally fragile Bay. Please approve only the use of the Covell’s Beach landing and do not approve New Hampshire Avenue as an alternative. Lewis Bay should not be in consideration now, or in the future by any entity.

Sincerely, David Bernstein, for

Crowell Beach Associates, Inc

Englewood Shores Beach Association

Great Island Associates, Inc.

Grist Mill Village Civic Association, Inc

Harborside Estates Beach Association

Hyannis Park Civic Association, Inc

Lewis Bay Neighborhood Association, Inc

Ocean Harbor Estate Association, Inc

Wimbledon Shores, Inc From: JARRETT DRAKE To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Thursday, January 24, 2019 6:24:01 PM

I am writing to let you all know about two unfilled MA commercial fishermen seats on the RI Coastal Resources Management Council http://www.crmc.ri.gov Fishermens Advisory Board that need to be filled. These seats seem to be intentionally left vacant and Congress is dragging it's feet to fill them. Without these seats filled, Massachusetts commercial fishermen have no legal voice with respect to the guidance and impact of these windmills. Maybe this is what Charlie Baker wants since any holdup of the offshore wind projects will result in $1.4 billion of lost tax incentives and "affordable" clean energy will be unobtainable as he promised.

The lack of MA representation is damaging to the MA commercial fishing industry and is such an important step in the offshore wind development.

Massachusetts needs to fill these seats asap! Dire consequences are inevitable to the lease area fishermen and neighboring fishermen that will feel distribution pressures caused by the windmills. The commercial fishing shore support communities will also feel this impact. Don't rush through this important process damaging fishermen's livelihood just to catch a tax break.

Thank you,

Jarrett Drake 6 County Road, Marion, MA 02738 508-789-9809 From: John Haran To: Patel, Purvi (EEA) Subject: comment Date: Tuesday, January 22, 2019 11:13:46 AM

This process is proceeding with little protection of the environment for future generations.

There is no effective decommissioning plan.

Sector 13, Sector 10

John Haran, manager From: John Haran To: Patel, Purvi (EEA) Subject: comment Date: Friday, January 25, 2019 7:59:51 AM

The environmental groups and our politicians are silent about the future environmental damage these turbines will have on the environment in the future.

There has not been any studies to show what damage may occur.

There is no clear decommissioning plan; look at the abandoned oil rigs in the gulf. 2

Mr. Michael H. Dunbar Edmund J. Janiunas, SOC Signatory unavailable as the preferred landing site. During the EFSB hearings, members of dba Dunbar Aquafarm Sweetheart Creek Oyster Co., LLC the Siting Board inquired of the Vineyard Wind witnesses if any outreach and 28 Cocheset Path 481 Buck Island Road, Suite 11A communications with the aquafarmers had taken place, noting the importance of West Yarmouth, MA 02673 West Yarmouth, MA 02673 such outreach. In our Final Written Comment, dated November 26, 2018, we Email: [email protected] Email: [email protected] described the minimal level of outreach and communications by one Cell: 508-367-7821 Cell: 917-797-7594 representative of Vineyard Wind from January through October 2018. Following Division of Marine Fisheries ID 116862 Division of Marine Fisheries ID 176908 the hearings and during the months Vineyard Wind has been preparing its FEIR,

there have been no attempts by Vineyard Wind to communicate with us.

January 25, 2019 Furthermore, in the event the alternate Lewis Bay site becomes the site preferred

by your Board or becomes the only available site, will we as oyster farmers, with Secretary Matthew A. Beaton both Massachusetts and Town of Yarmouth licenses and permits, be afforded the Attn: MEPA Office, Purvi Patel opportunity to again raise our concerns and to have the Siting Board again review Executive Office of Energy and Environmental Affairs Lewis Bay for appropriateness as a site for burying cables transmitting 800 100 Cambridge Street, Suite 900 megawatts of electrical power? Boston, MA 02114

We believe that in order for your Siting Board to accept Lewis Bay and New via email: [email protected] Hampshire Avenue as the alternate site, our concerns should be addressed. It is

unacceptable to us to have Lewis Bay identified as the alternate site without Re: Vineyard Wind, Petitioner resolution of all the issues raised at the hearings and in our letters to your Board. Written Comments regarding FEIR

EFSB 17-05; D.P.U. 18-18; D.P.U. 18-19 As you are aware, we operate two oyster aquafarms in Lewis Bay, within 1,000

feet of the proposed cabling route. We have submitted three previous letters to Dear Ms. Patel: your Board describing all our concerns for the health and well-being of our oyster

farms in the event the cables are buried in Lewis Bay. All those concerns remain Please accept this letter as our comments regarding the Final Environmental relevant in light of the FEIR. Our previous letters still represent our position about Impact Report (FEIR) filed by Vineyard Wind in the above-referenced matter. As the cabling in the Bay. We attach our previous letters to the transmittal email for aquafarmers with productive oyster farms now operating in Lewis Bay, we have your reference. grave concerns about the status of Lewis Bay as the alternate site for the burial and landing of the 800-megawatt transmission cables. We believe the abutting aquafarmers are entitled to certain future protections in the event the alternate site becomes the preferred site. The FEIR fails to provide any level of protection Continued on next page. to our oyster farms, our livelihoods.

We wish to make you aware that Vineyard Wind, while preparing its FEIR, has not contacted us nor made any attempts to reach any agreement or plan for mitigation of our certain losses in the event the alternate site is chosen or in the event some unforeseen factor arises which makes Covell’s Beach inappropriate or 3

We respectfully request that the Energy Facilities Siting Board not allow Vineyard Mr. Michael H. Dunbar Edmund J. Janiunas, SOC Signatory Wind or any entity to dig trenches in Lewis Bay and to bring the cables onshore at dba Dunbar Aquafarm Sweetheart Creek Oyster Co., LLC New Hampshire Avenue for the purpose of burying high voltage electric cables. 28 Cocheset Path 481 Buck Island Road, Suite 11A West Yarmouth, MA 02673 West Yarmouth, MA 02673 Email: [email protected] Email: [email protected] Sincerely, Cell: 508-367-7821 Cell: 917-797-7594 Division of Marine Fisheries ID 116862 Division of Marine Fisheries ID 176908

Michael H. Dunbar Edmund J. Janiunas dba Dunbar Aquafarm SOC Signatory November 26, 2018 Sweetheart Creek Oyster Co., LLC

cc: M. Kathryn Sedor, Esq., Presiding Officer M. Kathryn Sedor, Esq., Presiding Officer Senior Officer/Hearing Officer Senior Officer/Hearing Officer email: [email protected] MA Energy Facilities Siting Board Adam P. Kahn, Esq., FOLEY HOAG LLP One South Station, 5th Floor email: [email protected] Boston, MA 02110 Thaddeus Heuer, Esq., FOLEY HOAG LLP

Email: [email protected] via email: [email protected] Zachary Gerson, Esq. FOLEY HOAG LLP

Email: [email protected]

David E. Pierce, Ph.D., Director, Massachusetts Division of Marine Fisheries Re: Vineyard Wind Connector Project email: [email protected] Written Comments to Testimony Dr. Kathryn Ford, Program Manager, Habitat Program, MA DMF EFSB 17-05; D.P.U. 18-18; D.P.U. 18-19 email: [email protected]

Town of Yarmouth Board of Selectmen Dear Attorney Sedor: email: [email protected]

Daniel Knapik. Town of Yarmouth Administrator Please accept this letter as our Written Comments in the above-referenced email: [email protected] matter. We are submitting this letter in response to the Energy Facilities Siting Karl von Hone, Director, Town of Yarmouth Division of Natural Resources Board hearings regarding the topic of “Shellfish Impacts” presented October 10 email: [email protected] and October 11, 2018. Conrad Caia, Yarmouth Shellfish Constable

email: [email protected] We thank the EFSB for granting us the opportunity to be Limited Participants in

this proceeding. We believe in the importance of the proceeding and the

hearings and chose to each take one day away from our aqaufarms to attend the “Shellfish Impact” hearings in Boston.

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We thank the members of the EFSB. The questions asked demonstrated both about other wind farm companies, which are right now seeking to secure their preparation for the hearings and their concerns for the environmental contracts with the Commonwealth of Massachusetts, submitting proposals to impact on Lewis Bay and on all the shell fishing activities which take place in the bring cables through Lewis Bay as part of any future wind farm projects. Bay. Harmful Sedimentation As aquafarmers, we are proponents of alternative energy sources. We are, The Vineyard Wind Connector Project requires several steps, each causing equally, proponents of the preservation of the ecological health of Lewis Bay. We disturbance: original trenching up to eight feet deep to create a bed for the believe it will be possible to bring wind energy to the Commonwealth of cables, placing the cables in the trench, and the refilling of the trench. Massachusetts without compromising this important natural resource. We object to the comments by the Vineyard Wind witnesses stating that the We respectfully request the Energy Facilities Siting Board not accept Lewis Bay as trenching of Lewis Bay and burial of the cables will cause sedimentation to be an appropriate first choice site or alternative site for burying 800-megawatt disturbed for a distance of one meter wide. The testimony described two electrical transmission cables as part of the Vineyard Wind Connector Project now trenches from Smith’s Point to New Hampshire Avenue. Our daily experience under review nor for any other wind farm project in the future. tending to our oyster farms informs us that, when the seabed is disturbed, sand will settle and silt will suspend in the water column. When the seabed is In this letter, we present our concerns regarding the testimony presented at the repeatedly disturbed, the result will be a layer of sand covered by a layer of silt hearings to assist the EFSB with its final review and decision. covered by a layer of sand covered by a layer of silt, etc. This layering creates a weakened seabed and silt will be easily disturbed repeatedly. Sediment Lewis Bay is an Estuary consisting of silt will flow with the current and the normal prevailing winds. There was no discussion by the Vineyard Wind witnesses regarding Lewis Bay status as an estuary. The digging and the refilling of the trench through the entirety of Lewis Bay will result in the layering of sand and silt. The silt will be suspended and re-suspended In 2001, the Massachusetts Estuaries Project (MEP) identified Lewis Bay as an in the water column, and move with the current and winds, for many months and estuary. MEP is a collaborative organized in 2001 to support healthy ecosystems perhaps up to one year before settling. and includes the Massachusetts Department of Environmental Protection, the US Environmental Protection Agency, and the Massachusetts Executive Office of The risk of sand and silt smothering the oysters is great. The risk of mortality is Energy and Environmental Affairs. Lewis Bay should not ever have been great. considered as a part of a proposed route for the purpose of burying high voltage electrical transmission cables. The Vineyard Wind witnesses made clear that this process would occur twice in Lewis Bay as part of the Connector Project under review. As aquafarmers with contractual relationships with both the Massachusetts Division of Marine Fisheries and the Town of Yarmouth, we should not be in the The Vineyard Wind witnesses stated that the sedimentation modeling studies position to have to defend our aquafarms located in Lewis Bay from the threats were conducted throughout the entire cable route. Yet the witnesses reported which would be created by the burying of high voltage cables and the presence of the same sedimentation figures of 5 mm of sediment and stated that the active cables in the same estuary as our aquafarms. We remain deeply concerned sediment settles quickly. We suggest that the settling of sedimentation in the about the proposed Vineyard Wind Connector Project bringing high voltage open waters of Atlantic Ocean, Muskeag Pass and Nantucket Sound is decidedly electrical transmission cables through Lewis Bay. We are equally concerned 4 5 different than the settling rate in the enclosed Lewis Bay where there is an unavailable. There was mention of financial reimbursement for a broken rake. absence of wave pressure at the seabed level. There was mentioned of the use of a silt screen. There was mention of the Consequently, we disagree with and object to the statement by the Vineyard process of temporarily removing the oysters from their current location. Wind witnesses that the sediment impact would affect a small area and for a short duration. We disagree with and object to the statement by the Vineyard Please be advised that we each have invested upwards of $100,000 in equipment Wind witnesses that the sediment impact would be confined to the width of the in our aquafarms. A lost day on the water is not only a loss of one day, but a risk trench and skids. to oysters which need daily attention. There is no proof of a silt screen having been successfully used to prevent sedimentation from reaching aquafarms. The Vineyard Wind witnesses did not address the question of what effect the Removing the oysters to a different location is not appropriate for subtidal oyster disturbance of mud in Lewis Bay will have on the aquafarms. farms; our oysters are not accustomed to air and sun the same way intertidal oysters are. The removal process could result in high mortality rate. We agree with the statement of the Vineyard Wind witnesses that the issue of sediment impact pertains to Lewis Bay to a much great degree than to the Covells Although the Vineyard Wind representative spoke to us about moving the Beach landfall site. Covells Beach, Barnstable, faces Nantucket Sound which is oysters, the witnesses at the hearing stated that they believed there would be no 750 square miles of open sea. Lewis Bay is 1.6 square miles and has one egress need to move the oysters because the sediment impact would be below the and ingress channel. Sediment will remain in Lewis Bay and will not be disbursed threshold for tolerance. There was no recognition by the witnesses of the over many miles of sea, as would happen at a landfall site like Covells Beach. inability of oysters, unlike other shellfish, to dig themselves up out of a layer of sediment, no matter how small in measurement of millimeters the layer of Lack of Offer of Mitigation sediment may be. The Vineyard Wind witnesses stated that there is a full-time staff person assigned to discuss mitigation procedures with the shell fishermen and aquafarmers and During the past year, there has been a complete lack of discussion or proposals that discussions were held on a regular basis. between us and the Vineyard Wind representative regarding the reimbursement for any financial loss, including identification of who determines the extent of any In fact, a Vineyard Wind staff person contacted us irregularly during the past 12 losses, who determines cause of any loss, who determines fault, who determines months. The out-reach consisted of text messages and a few meetings while the outcome of any disagreement between the parties, and what the time line for standing in the Englewood Beach Parking Lot. We each have received no written any reimbursement would be. These talks simply never took place. communications from any staff person from Vineyard Wind. We have received no written proposals of any offer of mitigation in any format. All mitigation Oyster seeds must be ordered months in advance of planting. Seed is only proposals were made verbally, while standing in the Englewood Beach Parking Lot available at a specific time of year. There is no process which would recompense and at one local donut shop and once at a meeting in the Town of Yarmouth us and bring us back to our current level of production of fully-grown oysters Office of Natural Resources held for purpose of discussing the Town shellfish ready for harvest within one year’s time. If a loss occurs, there is no guarantee program and not the aquafarms. that Vineyard Wind would be able to replace the existing product; it is foreseeable that we would lose an entire year of income. The mitigation procedures which were verbally mentioned by the Vineyard Wind staff person were woefully inadequate and lacked understanding of the breadth We were never informed by any Vineyard Wind staff person or by timely written of the risk to our aquafarms. There was mention of financial reimbursement for a notice from Vineyard Wind that we were entitled to participate in the EFSB lost day on the water in the event the Englewood Beach Parking Lot was process as Intervenors or as Limited Participants. 6 7

In short, we report to the EFSB that the communications between us and of the oysters from the subtidal farm site. These limitations are required to Vineyard Wind was negligible and insubstantial. ensure that the oysters do not spoil and to avoid vibrio.

Lack of Mention of Aquafarms in SDEIR Vineyard Wind witnesses testified about the possible closing of the Englewood The SDEIR explains impact on bay scallops, quahogs, and the Town of Yarmouth Beach Parking Lot and New Hampshire Avenue. In the event the Englewood recreational shellfish program. Both the DEIR and the SDEIR fail to address the Beach Parking Lot is closed, and if our oysters cannot be picked-up at an approved issues facing the four aquafarms located in Lewis Bay in the event of trenching landing site, we will be in violation of our DMF permits. and cable laying in the Bay. Each autumn, our floating cages must be removed from the water which requires Aquafarms as a Nitrogen Abatement Program more than 20 days. It is a labor-intensive process. In the event we are unable to During the Shellfish Impact hearings, the Vineyard Wind witnesses did not access the Englewood Beach landing and parking lot because it is closed, it would address the issue of the need for nitrogen abatement in Lewis Bay. The presence be very difficult to bring the cages ashore at a different location. This would add of the aquafarms in Lewis Bay, with millions of growing oysters, serves as a non- substantial time to the cage removal process. Failure to remove all the cages technical nitrogen abatement process. Currently, the nitrogen abatement that is prior to Lewis Bay being frozen could result in substantial damage to our cages. If a natural part of oyster growth process is the only nitrogen abatement program the cages are crushed and damaged by ice, they are no longer useable. utilized by the Town of Yarmouth. Any loss of oysters due to the trenching in Lewis Bay or due to the presence of high voltage cables buried in the Bay will First in the Nation Not Always a Good Thing result in increased presence of harmful nitrogen. The Vineyard Wind witnesses were asked if they know of any other cables buried near aquafarms. The witnesses answered that they had no knowledge of any Lack of Understanding of Aquafarming Process cables buried near aquafarms. The Vineyard Wind witnesses explained that the trenching and cable laying in Lewis Bay would occur during the months between November and April. The Use of HDD to Avoid Impact oyster aquafarm process involves sinking oysters in their bags starting in The Vineyard Wind witnesses stated that Vineyard Wind would use the HDD November and ending in January. The bags of oysters are re-surfaced during late method of laying cables near the New Hampshire Avenue landfall site in order to April and May. If seabed disturbance is caused during the months when the bags avoid impact to the Town of Yarmouth shellfish program. The limited distance of lay on the seabed floor, sedimentation will exceed the threshold for the oysters the HDD method, however, does not protect our aquafarms. Please note that the and result in high mortality. Farmed oysters in bags are not similar to other distance of our aquafarms to the proposed Lewis Bay route is, at its closest point, benthic shellfish to the extent that benthic shellfish have the ability to dig less than 1,000 feet in distance. themselves under the surface of the seabed and then up to the surface of a seabed as needed to survive. Time of Harvest The Vineyard Wind witnesses testified that the primary harvest time for Permit and Contractual Limitations aquafarmers is October through December. This is not true. We harvest our Both of us are obligated, by the terms of our Division of Marine Fisheries permits oysters each month of the year as long as Lewis Bay is not frozen. No matter and our Town of Yarmouth leases, to bring our oyster harvest ashore at a Town of which month Vineyard Wind would conduct trenching and cable burial activity, Yarmouth landing site. We are required to arrange for pick-up of the oysters and our harvest activity would be interrupted. refrigeration of the oysters within a specific time limit from the point of removal

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Electro Magnetic Field; Electrolysis; Impact of Freezing Temperatures on Cables We respectfully request that the Energy Facilities Siting Board not allow Vineyard The issue surrounding the effects of the electro-magnetic field have also not been Wind or any entity to dig trenches in Lewis Bay for the purpose of burying high sufficiently reviewed by Vineyard Wind and there has been no proof nor studies voltage electric cables. to suggest that our oyster farms will not be harmed by the electro-magnetic field. This issue was quickly raised and dismissed by the Vineyard Wind witnesses. We respectfully request the Energy Facilities Siting Board find that Lewis Bay is not an appropriate cabling site as a first choice nor as an alternative choice for the The possibility of electrolysis causing harm to our metal equipment has not been Vineyard Wind Connector Project now under review nor for any other wind farm reviewed by Vineyard Wind and no remediation plan has been presented to us. project which may come under its review in the future. We are very concerned about the possibility of electrolysis in the event even the tiniest leak in the cables occurs. As an analogy, if a boat owner installs a 120V light fixture on a dock and if a leak of the electrical wire occurs, this leak will cause Sincerely, damage to anything metallic in the water to rust and totally deteriorate. In the event of a leak in the 800-megawatt cable, this leak will destroy all the metal Michael H. Dunbar Edmund J. Janiunas cages used in our aquafarms. dba Dunbar Aquafarm SOC Signatory Sweetheart Creek Oyster Co., LLC The Vineyard Wind witnesses testified that the cable coatings become brittle when the cables are exposed to freezing temperatures. The witnesses also cc: Adam P. Kahn, Esq., FOLEY HOAG LLP discussed the fact that the cable route through Lewis Bay includes two points email: [email protected] where the path of the cable takes a bend. We are very concerned that the Thaddeus Heuer, Esq., FOLEY HOAG LLP combination of a cable coating becoming brittle at certain temperatures plus two Email: [email protected] bends in the cable path will increase the likelihood of cracks in the coating, leaks Zachary Gerson, Esq. FOLEY HOAG LLP of electricity and damage to our equipment due to electrolysis. Email: [email protected] David E. Pierce, Ph.D., Director, Massachusetts Division of Marine Fisheries Applicability of Ocean Management Plan email: [email protected] The Vineyard Wind witnesses were questioned about the applicability of the Dr. Kathryn Ford, Program Manager, Habitat Program, MA DMF Massachusetts Ocean Management Plan dated 2009 and its supplement dated email: [email protected] 2015 which cautioned that future cabling for wind farms should stay clear of Secretary Matthew A. Beaton, Executive Office of Energy and Lewis Bay. We believe the witness’ response that the language was not Thou Environmental Affairs Shalt Not Do Anything in Lewis Bay was dismissive of the importance of the OMB email: [email protected] and the goal of the various state agencies to protect this estuary. Town of Yarmouth Board of Selectmen email: [email protected] Conclusion Daniel Knapik. Town of Yarmouth Administrator We respectfully request the Energy Facilities Siting Board note that all the email: [email protected] problems presented in this letter would reoccur in the event any repairs are Karl von Hone, Director, Town of Yarmouth Division of Natural Resources necessary to the high voltage cables in Lewis Bay. email: [email protected] Conrad Caia, Yarmouth Shellfish Constable email: [email protected] Written Comments_Aquafarmers_EFSB_11.08.01(v1) 2

Mr. Michael H. Dunbar Edmund J. Janiunas, SOC Signatory Bay which will smother and choke our oysters. This sediment will be dba Dunbar Aquafarm Sweetheart Creek Oyster Co., LLC raised with each successive storm for an extended period of months. 28 Cocheset Path 481 Buck Island Road, Suite 11A West Yarmouth, MA 02673 West Yarmouth, MA 02673 2. The impact of the electromagnetism, heat, sound and vibration Email: [email protected] Email: [email protected] Cell: 508-367-7821 Cell: 917-797-7594 emanating from the industrial cables into the Lewis Bay estuary will Division of Marine Fisheries Division of Marine Fisheries have a detrimental impact on the growth pattern of our oysters. Vibrio ID 116862 ID 176908 is a concern; even a one-degree temperature increase could be problematic.

October 3, 2018 3. In the event of a tiniest leak of electricity into Lewis Bay electrolysis will

occur and will cause damage to our aquafarm equipment. Hon. Matthew A. Beaton Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 4. Any need for future repairs will again present all of the above issues. Boston, MA 02114 Both Dunbar Aquafarm and Sweetheart Creek Oyster Company, LLC (Sweetheart Also via email: [email protected] Creek) operate pursuant to a permit issued by the Massachusetts Division of [email protected] Marine Fisheries and both submit annual reports and annual fees to DMF.

We each possess leases with the Town of Yarmouth for the purpose of operating Subject: Vineyard Wind Connector (EEA #15787) Supplemental Draft Environmental Impact Report our oyster aquaculture farms in Lewis Bay and we each pay an annual amount for Vineyard Wind LLC EFSB 17-05/D.P.U. 18-18/18-19 our leases to the Town of Yarmouth.

Dear Secretary Beaton: Dunbar Aquafarm has conducted an aquaculture farm in Lewis Bay for the past 17 years. Sweetheart Creek has conducted an aquaculture farm for the past two We operate two separate commercial oyster farms in Lewis Bay, Dunbar years in Lewis Bay. Both these farms are located at the eastern end of Lewis Bay Aquafarm and Sweetheart Creek Oyster Company, Inc. We submit this Comment very near the proposed track of the Vineyard Wind cable trenches. to inform you that we strenuously object to the disruption to the seabed of Lewis Bay as proposed by Vineyard Wind, LLC, as part of the Connector Project, and to Dunbar Aquafarm now consists of approximately three million growing oysters. the burial in Lewis Bay at any depth of transmission cables for the purpose of During 2018, Dunbar planted one million oyster seeds. The 2018 yield is expected bringing 800 megawatts of electrical energy to shore. to be 500,000 oysters ready to be sold commercially.

Our concerns are as follows: Sweetheart Creek is a newer aquafarm and currently has approximately 250,000 1. Plowing, trenching and burial of the industrial cables will cause sand, silt oyster seeds planted in Lewis Bay. It is expected that Sweetheart Creek will go to and sediment to be raised throughout the entire eastern end of Lewis market with fully grown oysters during 2018. 3 4

A. Damage Due to Burial of Cables As recently as August 2018, news reports showed two-year-old cables were If the Project includes the plowing and burial of 800 megawatt cables under the exposed off the coast of Block Island. Please see: seabed of the Lewis Bay estuary, the damage to the four aquafarmers could well https://turnto10.com/news/local/electric-transmission-line-at-ri-beach-designed- exceed millions of dollars. The plowing as proposed by Vineyard Wind will result to-be-buried-below-sea-bottom-exposed in sand, sediment or silt smothering and choking the oysters. We lose our entire and investment of money and time. If even a small amount of sediment is found https://www.blockislandtimes.com/article/deepwater-wind%E2%80%99s-cable- inside the oysters, this will cause harm to the brand quality of our oysters. We exposed/53036 are at risk of losing our wholesale customers if the quality of the oysters is diminished by even the slightest presence of sand or silt inside the oyster. In the event repair to the cable in Lewis bay is necessary, there will be no time to consider the protection of the 5 million oysters growing in Lewis Bay. Repair will Each winter, our oyster farms suffer from the natural storms which cause sand have to be immediate, and that repair will take precedence over the health and and silt to be disturbed and to float naturally in the Bay. We actually can lose a growth of oysters. We understand that. The only way to protect the aquafarmers portion of our oyster seed after a major storm. We anticipate that any additional from this event is to not permit cabling in Lewis Bay from the inception of the disturbance will cause long-lasting and even permanent damage to our Project. aquafarms. C. Electro Magnetic Field and Electrolysis have not been reviewed in relation B. Risk from Future Interruption of Lewis Bay Seabed in Event Repairs Have to the aquafarms by Vineyard Wind, LLC in the SDEIR. to be Made The possibility of electrolysis causing harm to our metal equipment has not been There are known failures of cables now in place in Nantucket Sound and there is a reviewed by Vineyard Wind and no remediation plan has been presented to us. recent exposure of a cable off Block Island, R.I., requiring repairs. We refer you to The issue surrounding the effects of the electro-magnetic field have also not been the Presentation entitled Martha’s Vineyard Hybrid Submarine Cable Project reviewed by Vineyard Wind and there has been no proof or studies to suggest Comcast & NSTAR and which is described that our oyster farms will not be harmed by the electro-magnetic field. at: https://web.whoi.edu/seagrant/wp- content/uploads/sites/24/2018/06/09_NCC2017_smith.pdf. This project was D. Suggestions of Remediation by Vineyard Wind Are Inadequate. proposed in 2012 and started in 2014. The Presentation describes the status of Vineyard Wind has met informally with us to discuss the Connector Project. Vineyard Wind representatives talked about possible preventive measures. the existing four cables between Martha’s Vineyard and Falmouth, MA and states:

Cable # 75 has failed and is not operational. a. Installing silt curtains while cabling work is being conducted. However, Cable # 91 failed six times. there is no evidence or guarantee that harm to our oysters will still not Cable #99 failed four times over a span of 15 years. occur. The flow of the unsettled silt and sand is unpredictable and there Cable # 97 is the only cable in that project which has not failed. are no assurances that Vineyard Wind’s concepts will work.

5 6

b. Moving oysters physically off the Lewis Bay grants. This method is in use The Town of Yarmouth has encouraged aquafarms in the Lewis Bay to help bring successfully where oyster farms are located in intertidal sea beds which go nitrogen levels to safe standards as established by Massachusetts regulations. dry at low tides. The oysters are accustomed to being exposed to air and Many towns on Cape Cod rely on oyster aquafarms as nontechnical nitrogen sun. The oyster farms in Lewis Bay are in subtidal locations, and the oysters abatement strategies. This is well documented in the Cape Cod Commission may be damaged by being removed from water. This is not a viable option. study of estuaries and nitrogen abatement. Therefore, our aquafarms are more In fact, Southeastern Massachusetts Aquaculture Center (SEMAC) has than simply our livelihood. They are part of the nitrogen abatement strategies to advised us to never remove the oysters for an extended period of time due protect residents, tourists and tourist related businesses which rely on estuaries to high mortality rates associated with taking the oysters out of the water. like Lewis Bay. Lewis Bay is precious and is a natural resource for recreational shell-fishing, boating, swimming and beautiful views. Our aquafarms profit not c. Vineyard Wind has suggested that it will conduct its work in Lewis Bay only us; they profit all the Town of Yarmouth. during the month of November. At that time of year, our oysters are still growing and are very susceptible to harm. Our oysters are dormant during The Cape Cod Commission study can be accessed the months of January and February. However, Vineyard Wind cannot at: http://www.capecodcommission.org/resources/208/watershedreports/2017 conduct its work at that time because Lewis Bay is the breeding ground for _Watershed_Report_MC_Lewis_Bay.pdf. This study was a collaboration flounder during that time. between the MA Department of Environmental Protection, the US Environmental Protection Agency, the MA Executive Office of Energy and Environmental Affairs, Furthermore, there is a suggestion by Mr. Mayo that laying the cables in the Cape Cod Commission, and other state and federal offices. the coldest of months is not practicable because the cables are not pliable in freezing temperatures. The SDEIR is unclear whether freezing Finally, please note that there are two additional aquaculture farmers in Lewis temperatures affect the protective coating covering the cables or if any Bay estuary and they are equally at risk of damage and loss due to the proposed further problems exist due to freezing weather. This issue needs to be plowing and burial of 800 megawatt transmission cables in Lewis Bay estuary. examined and understood by the Energy Facilities Siting Board. Thank you for your review and understanding of our serious concerns.

E. AQUAFARMS IN THE LEWIS BAY ESTUARY ARE AN INTEGRAL PART OF THE TOWN OF YARMOUTH NITROGEN ABATEMENT PROGRAM. Sincerely, Our aquafarms provide a major benefit to the health of Lewis Bay. Each oyster filters 35 to 50 gallons of water daily. During the filtering process, the oyster absorbs the nitrogen from the water to build its shell. The oyster itself does not Michael H. Dunbar Edmund J. Janiunas absorb the nitrogen. This absorption greatly assists with the elimination of the dba Dunbar Aquafarm SOC Signatory Sweetheart Creek Oyster Co., LLC harmful impact of nitrogen in Lewis Bay. In fact, the nitrate content of Lewis Bay is reduced each year in large part because of the presence of the oyster aquafarms. 2

Mr. Michael H. Dunbar Edmund J. Janiunas, SOC Signatory cables into the estuary known as Lewis Bay and in turn into our oyster farms. We dba Dunbar Aquafarm Sweetheart Creek Oyster Co., LLC are also very concerned about electrolysis occurring and we address that later in 28 Cocheset Path 481 Buck Island Road, Suite 11A this letter. West Yarmouth, MA 02673 West Yarmouth, MA 02673 Email: [email protected] Email: [email protected] We rely heavily on the permitting process provided by both the Commonwealth Cell: 508-367-7821 Cell: 917-797-7594 of Massachusetts through its Division of Marine Fisheries and by the Town of Yarmouth which has resulted in the lease to us of the right to use Lewis Bay for our aquafarms. This is our livelihood. September 6, 2018 Dunbar Aquafarm, along with numerous others, holds a commercial shellfish license for the fertile bay scallop area in Lewis Bay. M. Kathryn Sedor, Esq., Presiding Officer Senior Officer/Hearing Officer Do we, as leaseholders with permission to conduct aquafarms in Lewis Bay, have MA Energy Facilities Siting Board the right to participate in the upcoming Hearings to be held by EFSB in Boston One South Station, 5th Floor during the month of October? We wish to participate. Boston, MA 02110 Do we have the right to receive notice of all proceedings and decisions which will via email: [email protected] affect our leases, our permits, our commercial licenses and our livelihoods? We wish to receive all notices of proceedings decisions. Re: Request for Notice of and Participation in Siting Board Hearings Vineyard Wind Project Please be advised of the following in support of our requests: Dear Attorney Sedor: Both Dunbar Aquafarm and Sweetheart Creek Oyster Company, LLC (Sweetheart We are writing to you to inquire about our hopeful participation in the Energy Creek) operate pursuant to a permit issued by the Massachusetts Division of Facilities Siting Board Hearings regarding the proposed trenching of and burial of Marine Fisheries and both submit annual reports to DMF. Both Dunbar Aquafarm high voltage, industrial cables in Lewis Bay as proposed by Vineyard Wind, LLC. and Sweetheart Creek pay an annual fee to the DMF. Each of our businesses has We first learned of these Hearings yesterday. We have not received any notice of a lease from the Town of Yarmouth and each pays an annual amount per acre to any administrative hearings or proceedings in regard to the various Vineyard the Town of Yarmouth for the lease of the oyster farm acreage in Lewis Bay. Wind petitions or in regard to the siting of the cables. Dunbar Aquafarm has conducted an aquaculture farm in Lewis Bay for the past 17 We each possess leases, permits and licenses from the Massachusetts Division of years. Sweetheart Creek has conducted an aquaculture farm for the past two Marine Fisheries and the Town of Yarmouth for the purpose of operating oyster years in Lewis Bay. Both these farms are located at the eastern end of Lewis Bay aquaculture farms in Lewis Bay. We are very concerned about the detrimental very near the proposed track of the Vineyard Wind cable trenches. impact of the trenching and burial of the industrial cables which will cause smothering and choking of our oysters and the detrimental impact of the electromagnetism, heat, sound and vibration emanating from the industrial 3 4

Dunbar Aquafarm now consists of approximately three million growing oysters. additional disturbance will cause long-lasting and even permanent damage to our During 2018, Dunbar planted one million oyster seeds. The 2018 yield is expected aquafarms. to be 500,000 oysters to be sold commercially. We are also very concerned about the possibility of electrolysis in the event even Sweetheart Creek is a newer aquafarm and currently has approximately 250,000 the tiniest leak in the cables occurs. As an analogy, if a boat owner installs a 120V oyster seeds planted in Lewis Bay. It is expected that Sweetheart Creek will go to light fixture on a dock and if a leak of the electrical wire occurs, this leak will cause market with fully grown oysters during 2018. damage to anything metallic in the water to rust and totally deteriorate. In the event of a leak in the 800 megawatt cable, this leak will destroy all the metal You should also know that Lewis Bay provides ideal growing conditions for our cages used in our aquafarms. oysters. Oysters thrive in estuaries like Lewis Bay where salt water mixes with fresh water. Our oysters grow at the highest growth rate of any oyster farm on Vineyard Wind has suggested that it will conduct its work in Lewis Bay during the Cape Cod. month of November 2019. At that time of year, our oysters are still growing and are very susceptible to harm. Our oysters are dormant during the months of Each of our aquafarms requires a very sizeable investment in equipment and February and March. However, Vineyard Wind cannot conduct its work at that labor. To give you an idea of the investments made, Dunbar Aquafarm has time because Lewis Bay is the breeding ground for flounder during that time. The expended in excess of $100,000 in the past three years alone for such costs as flounder do not live in Lewis Bay, but do come into the Bay to spawn. boats, metal cages, and staging equipment. This represents an intended expansion of Dunbar Aquafarm. Dunbar Aquafarm has more than 300 cages and We wish to further inform you that our aquafarms have provided a major benefit each cage and its associated gear costs $200, for a total expenditure of $60,000. to the health of Lewis Bay. Each oyster filters 50 gallons of water through its shell This business supports numerous wholesale shellfish buyers which support housing daily. During the filtering process, the oyster shell absorbs the nitrogen restaurants and retail businesses on Cape Cod, nationally and internationally. in the water. The oyster itself does not absorb the nitrogen. This absorption greatly assists with the elimination of the harmful impact of nitrogen in Lewis Bay. Sweetheart Creek has invested more than $50,000 in its operation. In fact, the nitrate content of Lewis Bay is reduced each year in large part because of the presence of the oyster aquafarms. Vineyard Wind has met with us to discuss its Project. During our meetings, we repeatedly expressed our serious concern that the plowing, trenching and burial There are two additional oyster farms in Lewis Bay and we do not know if the of industrial cables in Lewis Bay will cause serious harm to our oysters. The aquafarmers of those leases have received any notice of proceedings or have process of laying cables will cause sand and silt to rise in Lewis Bay and will contacted you. Also, there are at least two more identified areas for aquafarm smother the oysters. Vineyard Wind representatives did talk about possible leases in Lewis Bay even closer to the cable layout. preventive measures by installing silt curtains while their work is being conducted. However, there is no evidence or guarantee that harm to our oysters We are unsure as to which government body, if any, represents us in the Vineyard will still not occur. The flow of the unsettled silt and sand is unpredictable and Wind Project proceedings. We are requesting a seat at the Hearing table. there are no assurances that Vineyard Wind’s concepts will work. We will be happy to talk with you about our concerns. Our contact information is Each winter, our oyster farms suffer from the natural storms which cause sand given above. Thank you for your consideration of our requests. and silt to be disturbed and to float naturally in the Bay. We actually can lose a portion of our oyster seed after each major storm. We anticipate that any 5

Sincerely,

Michael H. Dunbar Edmund J. Janiunas dba Dunbar Aquafarm SOC Signatory Sweetheart Creek Oyster Co., LLC

cc: David E. Pierce, Ph.D., Director, Massachusetts Division of Marine Fisheries email: [email protected] Dr. Kathryn Ford, Program Manager, Habitat Program, MA DMF email: [email protected] Secretary Matthew A. Beaton, Executive Office of Energy and Environmental Affairs email: [email protected] Town of Yarmouth Board of Selectmen email: [email protected] Daniel Knapik. Town of Yarmouth Administrator email: [email protected] Karl von Hone, Director, Town of Yarmouth Division of Natural Resources email: [email protected] Conrad Caia, Yarmouth Shellfish Constable email: [email protected]

Request to EFSB_Lewis Bay Aquaculturist_Vineyard Wind_09.06.18 Patel, Purvi (EEA)

From: Mastrocola, Reno Sent: Tuesday, January 22, 2019 12:45 PM To: Patel, Purvi (EEA) Subject: comments: State Final Environmental Impact Report (FEIR) for Vineyard Wind

Dear Purvi,

Here are my comments regarding the Vineyard Wind project.

The Vineyard Wind Lease Area OCS-A 0501 should be outfitted with environmentally responsible equipment as best possible. This includes transport vehicles and lifting machines with reduced fossil fuel consumption drive trains, or all-electric drive trains if possible.

The Lease Area should include facilities to mitigate potential spills of hydrocarbon based fuels or lubricants and should include recycling capability for any used lubricants. Environmentally Acceptable Lubricants (EALs) should be considered for use in all machinery operating in the Lease Area, as long as those EALs do not negatively impact operation and longevity of the machines.

I believe this Offshore Wind Project, when managed in an environmentally responsible way, will be a good economic stimulator for the local communities, especially where the wind mill components are imported by ship, staged for offshore delivery, and where the production and test facilities are located. The project could offer local contractors the opportunity to gain business in support of installation and maintenance tasks, and could result in increased employment with local contractors and suppliers.

Best regards,

Reno

Reno Mastrocola Regional Sales Manager, East Coast Mobile: +1 908-770-6523 [email protected]

Kalmar-USA 21 Englehard Drive Monroe Township, NJ 08831 www.kalmarglobal.com

2 From: susan brita To: Patel, Purvi (EEA) Subject: FEIR Vineyard Wind Date: Wednesday, January 23, 2019 6:59:39 AM

Ms. Patel:

Please include the following statement in the public record regarding the Final Environmental Impact Report (FEIR) filed by Vineyard Wind.

The 10 neighborhood and beach associations along Lewis Bay, West Yarmouth, MA continue to be opposed to Vineyard Wind’s proposal to lay electric cables through Lewis Bay, with the connector project making landfall at New Hampshire Ave, West Yarmouth. During several hearing sessions before the Energy Facilities Siting Board (EFSB) in October 2018 Vineyard Wind offered to the Board changes to their original plans. These changes included making landfall at Covell’s Beach, Barnstable MA. We support that site change as it is more environmentally sound and includes more opportunities for effective remediation. While the FEIR contains more and updated environmental data it does not provide any significant relevant data or plans to protect Lewis Bay. Thus, the neighborhood and beach associations in West Yarmouth, along Lewis Bay remain united in opposition to electric cables in Lewis Bay and continue to support the alternative site at Covell’s Beach.

Susan Brita Lewis Bay Neighborhood Association

From: vida morris To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Wednesday, January 23, 2019 4:25:55 PM

I am one of those "certain Yarmouth people" as Vineyard Wind likes to call us who for the umpteenth time ask you to tell them to, please, leave us alone and go where they are wanted. I understand that the company still lists New Hampshire Avenue, Yarmouth as possible landing site for their cables. It would be greatly appreciated if you could persuade them to cease and desist.Thank you.

Vida Morris From: Strahler, Alan To: Patel, Purvi (EEA) Subject: EEA No. 15787 Vineyard Wind Connector Date: Sunday, January 20, 2019 2:53:24 PM

To:

January 20, 2019

Dear Mr. Beaton:

We write today in support of the Vineyard Wind Project, which will provide 84 powerful wind turbines to generate more than 800 MW of carbon-free, renewable energy -- enough to power over 400,000 homes in Massachusetts. This power will reduce emissions of CO2 by 1.6 million tons per year, as well as significantly ease regional air pollution by NOx and SO2. Since our global climate is rapidly changing in the face of increasing atmospheric concentrations of CO2 and other greenhouse gases, the project will make a very significant contribution to moderating climate change.

In review of the Draft Environmental Impact Statement, the BOEM has found mostly negligible or minor negative impacts to Massachusetts' environment and communities, based on extensive research, data collection, and stakeholder input. Their process has been comprehensive and inclusive, and has included reducing the number of turbines and re-routing the cable landing at Barnstable to provide less impact.

As a coastal island community, Martha’s Vineyard is particularly vulnerable to climate disruption and ocean acidification. Our home community, Edgartown, has already experienced impacts of sea level rise and more severe storms. As a result, climate change is very important to us and our community. The Vineyard Wind project will pioneer our local and regional action to reduce our own contribution to greenhouse gas emissions, and help us sustain our community in the face of this change.

Economic impacts of the project for our state will be overwhelmingly positive. Southeastern Massachusetts will reap the equivalent of over 3,600 full-time jobs; our island alone will reap 50 additional jobs in hosting and administering project maintenance and planning. Massachusetts ratepayers will save $1.4 billion over the 20 year life of the project. Multiplier effects will support small businesses on our Island, and supply chains will provide opportunities for existing Massachusetts companies to feed into offshore wind industry.

Our island cooperative, Vineyard Power, is the local partner for the Vineyard Wind project, and has provided liaison services to Vineyard Wind to mitigate possible environmental and economic impacts as viewed by Island towns. Vineyard Wind has been very responsive and arranged to utilize our Island expertise and capabilities during all phases of the project.

In summary, we strongly support the Vineyard Wind project and find no fault with the MEPA Final Environmental Impact Report.

Sincerely yours,

Alan H. Strahler Kristi S. Strahler 21 Brushy Lane PO Box 9000 Edgartown, MA 02539

From: Alexander Boyle To: Patel, Purvi (EEA) Cc: [email protected] Date: Tuesday, January 22, 2019 3:09:53 PM

Dear Sirs: I am writing this letter of enthusiastic support for the continued progress of the Vineyard Wind offshore energy project. It is now clear to all interested persons that bringing this project to fruition will make a very substantial contribution to the environmental goals outlined in the Massachusetts Law requiring that a major portion of the state's energy must come from renewable sources. We have been following the development of this project through the Vineyard Power Cooperative since its inception in 2010. The VPC has been very careful to describe to the local community on Martha's Vineyard all aspects of the ultimate project so that the citizenry of the island understand its environmental and economic benefits while clearly demonstrating that the visual aspects with the turbines located 14 miles south of MV would be minimal.

Offshore wind energy, during the time of the Cape Wind Project, had acquired a very negative public perception on the Cape and Islands area generally. The VPC, by contrast, in explaining all aspects of the project, including the potential energy cost savings to Vineyard residents, has generated a remarkable degree of enthusiasm to see this project successfully implemented. It is impossible to fully measure the beneficial impact on the environment of having the Vineyard Wind project successfully concluded. As the first major commercial offshore wind energy project in the country, it will help to change public attitudes nationally toward the acceptance of wind energy as an essential part of the country's effort to limit the environmental damage from fossil fuel consumption. The signing of the Community Benefit Agreement between the Vineyard Power Cooperative and Vineyard Wind. will hopefully serve as a model of how to get the local community behind such a project for the betterment of the entire region. It is clear that all aspects of potential environmental concerns including the protection of various species of marine mammals have been carefully considered. It Is also clear that the economy of Martha's Vineyard will benefit materially during both the construction phase of the project and on an ongoing basis with 50 excellent maintenance positions located on the island.

We would hope the the Vineyard Wind project continues to move through the State approval process as expeditiously as possible for the Region's and the Nation's benefit.

Alexander R. M. Boyle Elizabeth B. Roberts

97 Longview Road West Tisbury, Mass. 02575 Patel, Purvi (EEA)

From: Amanda Braga Sent: Friday, January 25, 2019 9:14 PM To: Patel, Purvi (EEA)

To help protect you r priv acy, Microsoft Office prevented automatic download of this picture from the Internet.

Amanda Braga Student Marketing Intern Southcoast Energy Challenge 202 Spring Street Marion, MA 02738

January 22, 2018

Mr. Matthew Beaton, Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office Purvi Patel, EEA No. 15787 (Vineyard Wind Connector) 100 Cambridge Street, Suite 900 Boston MA 02114

Dear Matthew Beaton, My name is Amanda Braga, the Student Marketing Intern for the Marion Institute. I enrolled in completing an internship for the Southcoast Energy Challenge because I pursued an interest in marketing and the upcoming industry on solar and wind energy. My role as the Student Marketing Intern working for the Marion Institute allowed me to showcase the spectacular events we had in order to reshape the Southcoast energies consumption. I had written a press release that had been published in various newspapers and me and my colleagues worked at the Farmer’s Market in New Bedford to convince individuals to sign up for free energy audits. But the most essential job I provided for the community is promoting a sustainable option which is renewable energy.

That is why I am reaching out to you in favor of this upcoming project that Vineyard Wind has in store. Over the summer, Vineyard Wind had come to my city (New Bedford) to discuss this upcoming plan for our community. This project is a step in the right direction towards becoming sustainable and environmentally friendly. Not only does this project reshape our environment, but it also promotes the development of a community by employing 3,600 jobs. It also will

1 reduce 1.6 million tons of carbon which is not only beneficial for our environment but for our health, reducing asthma, various cancers, diseases and many other illnesses that have been contributed to the burning of fossil fuels. The most important factor that people care about the most is money. Renewable energy will help save money in your wallet. The Mass Debt Energy Resources (DOER) confirmed that within 20 years, Vineyard Wind will save Massachusetts ratepayers 1.4 billion dollars. I am passionate about the environment that we live in today and as a student interested in marketing, I would love to broadcast stories such as these because this idea is a pathway to success. Being able to educate citizens in this community about how we can change detrimental problems is a contributing factor towards getting people aware and interested. People will become more determined and appreciative of this plan once the project is finished and individuals see the beneficial impacts stemming from this project. I just wanted to take the time to thank you for all your hard work and dedication put towards making our environment sustainable financially, mentally, and futuristically. This is a strive for change and I am thrilled to see the positive changes that awaits for this community.

Sincerely,

Amanda Braga

2 Secretary Matthew A. Beaton Attn: MEPA Office, Purvi Patel Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA, 02114

RE: FEIR Vineyard Wind Connector, EEA No. 15787

Dear Secretary Beaton:

I am writing to strongly support the approval of the Final Environmental Impact Report for the Vineyard Wind Connector.

After much inquiry, BOEM has determined that the negative impacts to the environment and nearby communities would be minor or negligible. The project developer has paid close attention to the comments of stakeholders and, importantly, the number of turbines has been reduced. Any negative impacts of the project pale in comparison to the alternative, which is an increase in the region’s reliance on natural gas.

As a Chilmark homeowner and member of the board of Vineyard Power, I am especially appreciative of the project’s inclusive process. Vineyard Wind has been accessible and responsive to the community, as evidenced by its Community Benefit Agreement with Vineyard Power.

Further, the Offshore Wind Accelerator Fund and Windward Workforce Fund provide $12 million to ensure the offshore wind industry is anchored in Southeastern Massachusetts and will employ local residents. Vineyard Power, working with Adult Community Education MV and off-island higher educational institutions, have begun an island workforce education and training program for mid-career changers and students at the Martha’s Vineyard High School.

The development of the offshore wind industry is a boon for the State as a whole. The recent announcement that Vestas, a manufacturer of wind turbines for projects around the world, will open an office in Boston is an example of the benefits of the Vineyard Wind project for Massachusetts.

Different kinds of low-carbon resources are appropriate in different parts of the country. In the Southwest, it’s solar. In the Northwest, it’s hydro. In the Plains states, it’s onshore wind. In the Southeast, it may be nuclear. In the Northeast, there is no low-carbon resource that comes close to being competitive with offshore wind. For us, solar is great, but with current technology it’s a relatively small resource. Canadian hydro is great, too, but we don’t control the transmission routes, which run through northern New England. It’s offshore wind that is the huge and accessible resource for us here in New England and the mid-Atlantic states.

I hope that your review will approve the FEIR for the Vineyard Wind Connector, and appreciate your attention to my comments.

Very truly yours,

/s/

Ann G. Berwick

From: Ann Rosenkranz To: Patel, Purvi (EEA) Subject: Vineyard Wind project: Public Comment Date: Wednesday, January 23, 2019 7:27:54 PM

Dear Sir/Mme;

In light of the three recent reports on climate change issued by the Intergovernmental Panel on Climate Change, the UN Environmental Programme and the US Federal government, it is critical that we make a swift transition to renewable energy and abandon our reliance on fossil fuels. The Vineyard Wind offshore wind project will help us do just that.

According to the facts, the wind project will help reduce our MA carbon emissions by over 1.6 metric tons per year (apparently the equivalent of taking 325,000 vehicles off the road). It will provide 400,000 homes with wind power energy and would meet the MA goal of 3200 MV of offshore wind, meeting 25% of the state's energy needs with the clean, renewable, locally sourced energy. The fact that it is locally sourced with a community oriented development approach is an important aspect of this well thought out project. The project has sought to be transparent with frequent public input at every step of the way. Special attention has been focused on the needs and concerns of the fishing industry, indigenous tribal interests, the protection of endangered and local wildlife species, and the minimizing of environmental impacts.

We cannot risk a poor prognosis for environmental, social and economic outcomes by failing to move quickly to renewable energy in an effort to reduce greenhouse gases.....and the window of opportunity to abate global warming is closing rapidly. The Vineyard Wind project offers one path to a sustainable future, a healthy planet and provides a plan to nurture the continuation of life on earth as we know it.

Vineyard Wind will be the US's first large offshore wind farm. I hope it will be a model for others to follow. I highly support this worthwhile and much needed endeavor.

Sincerely,

Ann Rosenkranz 102 Skiffs Lane Vineyard Haven, MA 02568 [email protected] From: Ashley Yehl Flanagan To: Patel, Purvi (EEA) Subject: Support for Vineyard Wind Date: Wednesday, January 23, 2019 4:35:16 PM

Hi there,

I'm emailing as a resident of Dennis in support of the Vineyard Wind Project and it will be a great Ffirst step in Massachusetts’ commitment to 3,200 MW of offshore wind.

Thanks very much, Ashley From: Bethia Brehmer To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Thursday, January 24, 2019 5:41:10 PM

Please support to save our precious planet Patel, Purvi (EEA)

From: Bryan Mornaghi Sent: Thursday, January 24, 2019 4:48 PM To: Patel, Purvi (EEA) Subject: Vineyard Wind

I support their Draft EIS. We need this project.

Bryan Mornaghi Somerville, MA 02145

1 From: Carl Borchert To: Patel, Purvi (EEA) Subject: Vineyard Wind Energy Project Date: Wednesday, January 09, 2019 7:20:55 PM

To Whom It May Concern,

I write in support of the Vineyard Wind Energy Project proposed for federal waters southwest of my home on Nantucket Island. With a power rating of roughly 800 megawatts the project would displace over 2 million tons of carbon dioxide from the atmosphere annually. It would be like taking over 350,000 cars off the roads of Massachusetts every year. I live 30 miles out to sea and we are on the front lines of climate change with more powerful storms, rising sea levels and coastal flooding. Offshore wind projects like Vineyard Wind would help us reduce our carbon emissions and help to mitigate these devastating effects.

I write in total support of this viable clean renewable energy project. Please do all that is in your power to advance it and see it to the construction phase and project completion.

Thank you for your attention to this important matter.

Sincerely yours,

Carl K. Borchert Nantucket Island From: Carol B. Chittenden To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Thursday, January 24, 2019 5:02:54 PM

Dear Ms. Patel,

I wish to voice my support for Vineyard Wind. I’m not an expert, I’m not an investor, I’m just Joe (Joanne) Citizen. But the reasons to move forward with it are enormous and urgent. The benefits will be widespread. The reservations, by contrast, seem small, soluble, and often motivated by immediate personal gain. Vineyard Wind has been responsive to concerns, and flexible in its approaches. I hope the project receives the necessary approvals.

Sincerely,

Carol B. Chittenden Falmouth, MA From: Candy Shweder To: Patel, Purvi (EEA) Subject: Vineyard Wind Support Date: Thursday, January 24, 2019 4:58:56 PM

To Whom it May Concern:

The people at Vineyard Wind have been working diligently to provide renewable off-shore wind energy for the Cape and Islands. They have met with many concerned groups including fishermen, homeowners, etc.

In the last few months we have been apprised of the dire situation-- much worse than was previously known-- about the CO2 levels. We must wean ourselves from fossil fuels!

Vineyard Wind is a good start. They have done their homework and I trust they have the best interests of the Cape and Islands at heart.

With this project, Massachusetts will become a national leader in the off-shore wind energy field. They have the support of Environment Massachusetts, the MA Climate Action Network, the Association to Preserve Cape Cod, the Cape Cod Climate Change Collaborative and the entire Cape and Islands state legislative delegation.

Please support this project.

Sincerely,

Carol Shweder 4 Fulling Mill Hill PO Box 316 Chilmark, MA 02535 [email protected] From: Christopher Anderson To: Patel, Purvi (EEA) Subject: Comment on Vineyard Wind’s Final Environmental Impact Report Date: Friday, January 25, 2019 9:29:57 AM

Dear Purvi,

As a West Tisbury resident impacted by the proposed Vineyard Wind project, I write in support of its environmental, energy, and economic benefits, which per the Final Environmental Impact report sufficiently mitigate the negative impacts on wildlife, commerical fishing, and other environmental factors.

Christopher Anderson 36 Stonebridge Rd West Tisbury, MA 02575 From: David Charles To: Patel, Purvi (EEA) Cc: [email protected] Subject: I support Vineyard Wind Date: Wednesday, January 16, 2019 3:42:03 PM

I fully support the Vineyard Wind offshore wind project.

I have long supported such initiatives and am a charter member of the Vineyard Power Cooperative.

I am concerned about the effects of climate change and the benefits to our country of being energy independent. This important project is an opportunity to do more than just talk about the problem. Approving and building the Vineyard Wind project will be a very tangible demonstration of our commitment and resolve.

Vineyard Wind’s 800 MW offshore wind project will reduce CO2 emissions from the ISO New England system by approximately 1,680,000 tons per year. This will be a very important step in meeting our renewable energy and greenhouse gas reduction goals.

The Project has conducted an extensive and sustained outreach effort with the communities on the Cape and the Islands and signed the nation’s first offshore wind Community Benefit Agreement with Vineyard Power Cooperative. This outreach effort has included local residents, their elected and appointed officials, local tribes, fishing and marine interests, environmental advocacy groups, and other interested parties. Vineyard Wind has listened carefully to the feed back provided in these discussions and pledged to continue an extensive outreach effort as the project moves forward.

The project has conducted extensive surveys and other studies and has carefully selected submarine and onshore cable routes. All cables will be securely buried using proven installation techniques.

Short-term disturbance to residents along the land cable routes will be minimized by proper construction planning, scheduling, and traffic management. Affected streets will be restored and repaved, leaving them in “like new” condition.

Any temporary local inconvenience should be weighed against the important and large-scale societal benefits of the project. Moreover, the Project is committed to developing Host Community Agreements with the affected Towns.

In collaboration with the University of Massachusetts Dartmouth’s School for Marine Science and Technology (SMAST), Vineyard Wind has committed to conduct pre- and post- construction assessments of fisheries and associated ecological conditions.

Vineyard Wind is committed to working with the fishing industry so that both the wind and fishing industries can grow together offshore Massachusetts. One example is that Vineyard Wind, in consultation with local fishermen, established specific vessel transit lanes in the turbine layout design.

For these reasons and many more, I support the project. David E. Charles 22 Saddle Club Road Edgartown, MA 02539

1325 James Court Yardley, PA 19067 From: Don Mallinson To: Patel, Purvi (EEA) Subject: Vineyard Wind"s Report Date: Friday, January 25, 2019 11:23:53 AM

Saving our environment from polluting fossil fuels is priority one. Offshore wind turbine farms will go a long way to establishing this priority. I am pleased that Vineyard Wind in its final environmental impact report has been making accommodations to help save right whales and commercial fisheries, for examples. They have even accommodated several Cape towns by having their cable come ashore at a local beach rather than environmentally and commercially sensitive Lewis Bay. These kinds of accommodations make Vineyard Wind a thoughtful landlord for this local part of the planet. Respectfully, Don Mallinson 746 Carriage Shop Rd E Falmouth MA 02536 [email protected] 774-255-1745 From: Don Mallinson To: Patel, Purvi (EEA) Subject: Vineyard Wind Final EIS Comments Date: Wednesday, December 19, 2018 12:03:30 PM

So many individuals and organizations have expressed a vested in this wind farm that it is virtually impossible to satisfy them all. Listen to them, accommodate them as much as possible, but remember the greater goal is to save the planet by relying much more on renewable, sustainable energy and less, much less, on polluting fossil fuels. Everyone, even fishermen, wants to breathe without needing a face mask. Respectfully, Don Mallinson 746 Carriage Shop Rd East Falmouth MA 02536 [email protected] 774-255-1745 From: Donna Northrup To: Patel, Purvi (EEA) Subject: Vineyard Wind Project Date: Thursday, January 24, 2019 1:15:54 PM

I am submitting a comment in favor of the Vineyard Wind project as I understand tomorrow is the last day I can do so. I approve the location and approve the idea that Massachusetts will become even more renewable fuel sufficient with this new program. I also am happy to know that we will be reducing the CO2 output that is so harmful to our environment. Donna Northrup, resident and voter in Dennis Port, MA-Cape Cod From: Dorothy McIver To: Patel, Purvi (EEA) Subject: Comments on Vineyard Wind"s Final Environmental Impact Report Date: Saturday, January 19, 2019 8:43:11 PM

Dear Ms Patel,

We are writing to you to convey our comments about the Final Environmental Impact Report for the Vineyard Wind Connector, which would bring electricity from Vineyard Wind's offshore wind farm to shore in Massachusetts.

This project is important to us because it will help alleviate our dependence on fossil fuels while providing a clean renewable source of energy. Vineyard Wind will become the first commercial scale off shore wind farm in the country and we hope it will be the first of many such projects because we have no time to waste. We must drastically reduce our use of fossil fuels and reduce climate change emissions and the resulting impacts on our environment and Vineyard Wind will help us meet our state's remission reduction goals.

We are pleased to see that Vineyard Wind has made every effort to reduce the environmental impacts on local communities and to address the concerns of those in the fishing industry who feel they might be adversely affected. Vineyard Wind has listened to these concerns and taken steps to alleviate them.

Using wind power will also result in health benefits as it will improve our air quality and result in fewer cases of asthma and other respiratory illnesses which are prevalent in our region.

And we will see a growth of well paying green jobs (more than 3000) and lower electrical rates for consumers. Wind power is a resource our coast line is well suited for and we need to take advantage of the opportunities awaiting us. There is very little time left to mitigate the effects of climate change and we need to make changes at a much accelerated rate if we are to leave a habitable planet for our descendants.

So we urge you to approve this valuable project and continue to support the development of renewable energy projects in our state.

Sincerely,

Dorothy McIver

Member of Greening Greenfield (a grassroots environmental citizens group of 11 years )

88 Columbus Ave

Greenfield,MA 01301

413-772-3747

Virus-free. www.avast.com

January 18. 2019

Dear Secretary Beaton and Ms. Patel, I am writing today in support of the Vineyard Wind Connector, which would bring 800 MW of clean, renewable energy from the country’s first commercial-scale offshore wind project onshore in Barnstable, Massachusetts. The Final Environmental Impact Report (FEIR) submitted by Vineyard Wind reflects refinements and improvements to the company’s initial proposal and demonstrates their commitment to working collaboratively with local communities to deliver real benefits to the state.

As a solar developer whose companies have been doing business in the Commonwealth since 1979, I understand the critical importance of policy leadership in providing a foundation upon which new industries can grow and thrive. Similar to the Commonwealth’s early work on solar, Massachusetts is leading the nation’s efforts to establish a vibrant and robust offshore wind industry. We stand to capture significant economic and job creation benefits as a result. In fact, the recent news regarding MHI Vestas’s decision to open its US headquarters in Boston shows that our efforts are already bearing fruit.

At the same time, offshore wind will go a long way to ensuring we meet the emission reduction targets set established by the Global warming Solutions Act. The FEIR notes that Vineyard Wind’s project will reduce New England’s electricity sector emissions by as much as 1.6 million tons per year. The project also stands to lower electricity prices and could deliver total benefits worth more than $1.4 billion dollars.

In light of the potential benefits, limited environmental impacts, and Vineyard Wind’s track record of listening to and working with local communities, I strongly encourage you to allow Vineyard Wind Connector to move forward.

In addition to approving the project, the Baker administration should use the 2% per year rate of increase in the state’s renewable portfolio standard in the planning for a smarter grid, together with a commitment to install 25% of solar generation in Massachusetts. Longer term policies and regulations need to be established today for both small and larger scale solar and wind plus storage through 2030. Taken together, policies like these have the potential to do even more to positively transform our energy system, lower costs for all ratepayers, and significantly reduce greenhouse gas emissions in the region.

Thank you for your consideration.

42, Eighth Street, Suite 4413, Boston, MA 02129 1 1-617-337-0199, [email protected] www.PopeEnergy.com

Sincerely,

Doug Pope President

Best Regards,

Doug Pope President

42, Eighth Street, Suite 4413, Boston, MA 02129 2 1-617-337-0199, [email protected] www.PopeEnergy.com From: David Dow To: Patel, Purvi (EEA) Cc: David Dow Subject: Support for Vineyard Wind Project Date: Friday, January 25, 2019 10:50:51 AM

As a retired marine scientist and grassroots environmental activist, I support the Vineyard Wind project. I used to be the Recreational Fisheries Coordinator in the Northeast at the Fisheries Lab in Woods Hole and feel that epibenthic organisms will attract black sea bass which are migrating into southern New England waters from th Mid-Atlantic region and highly migratory species which pass through our region. I used to live in Slidell, La. where the oil/gas platforms were sites where saltwater angling occurred. Wind energy is more sustainable, less polluting than oil/gas extraction.

I don’t know the details of agreement proposed by Vineyard Wind for commercial fishing interests, so that I can’t comment on it. I have been working with the Atlantic States Marine Fisheries Commission; Mid-Atlantic Fishery Management Council and New England Fishery Management Council to move towards an adaptive, ecosystems-based management approach which would include other human uses of the ocean and the effects of human stressors like eutrophication and climate change.

I gather that Vineyard Wind has reached agreements with major ENGOs on limiting construction activities when North Atlantic right whales and humpback whales are feeding in the region. The prey of these whales (zooplankton for NARWs and small forage fish for humpback whales) have changed distribution in space/ time in Southern New England waters, so that some type of observing system will be required during construction. That are other human activities (US Naval training; oil/gas exploration with seismic blasts; increased commercial shipping; increases in fixed fixing gear; etc) which pose greater threats to whale populations than the Vineyard Wind project in my opinion as a retired marine scientist.

Agreement has been reached to bring the power onshore in Barnstable for connection to the regional electric grid. I would encourage the state to explore developing a “smart grid” on Cape Cod that would allow use of this electricity when power is lost during extreme weather events. Since I suffer from sleep apnea, I had to purchase a generac emergency generator for when I lose power which was an expensive investment. Many senior citizens live on Cape Cod and have to go to shelters during extreme weather events (a number of which lost power during Blizzard Nemo and Hurricane Bob). Solar power and wind energy are a sustainable power resources option as we move into the future.

Thanks for your consideration of these comments.

Dr. David D. Dow East Falmouth, Ma. From: F Mor To: Patel, Purvi (EEA) Subject: Vineyard Wind support Date: Thursday, January 24, 2019 4:59:51 PM

Dear Purvi,

I am writing in support of the Vineyard Wind project in Massachusetts. Having an alternative to coal, oil and gas power generation is a step forward in the right direction.

Thank you,

Federico Morales 18 Brentwood Rd Kingston, MA 02364 From: Franziska Amacher To: Patel, Purvi (EEA) Subject: Off shore wind farms Date: Wednesday, January 09, 2019 11:15:50 AM

Please note our support for this important renewable energy.

Franziska Amacher FAIA LEED NCARB WBE

AMACHER & ASSOCIATES Architects 237 Mount Auburn Street Cambridge, MA 02138 617 354 8707 www.amacher-associates.net From: GLHarcourt To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Thursday, January 24, 2019 7:43:12 PM

Please support and promote Offshore Wind and in particular, Vineyard Wind, which has been leading the way responsibly and carefully while including local communities, taking public input seriously and by giving back to local communities. There is no greater threat to our future than climate change and acting quickly and decisively to promote clean energy is a step in the right direction. Thank you in advance for thinking of future generations.

Sincerely, Gary L. Harcourt Oak Bluffs, MA

Gary Harcourt Against The Grain, Cabinetmakers Inc. P.O. Box 1919 19 Morgan Luce Lane Vineyard Haven, MA 02568 [email protected] 508-560-2834 www.atgcabinetmakers.com

Confidentiality Notice The information contained in this communication is confidential and/or proprietary business or technical data. If you are not the intended recipient, you are hereby notified that any dissemination, copying or distribution of this communication, or the taking of any action in reliance on the contents of this communication, is strictly prohibited. If you have received this communication in error, please immediately notify us by return message, and delete or destroy all copies of this communication. Thanks! From: Gordon Starr To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Friday, January 25, 2019 11:51:06 AM

Hello, I live on Cape Cod, in Barnstable and I support the Vineyard Wind project. There are some environmental disturbances but they are minor and mostly temporary. I feel the benefits from this project are valuable and needed as quickly as possible, as we transition to renewables.

Gordon Starr 85 Pilots Way West Barnstable, MA. 02668 508 362 4252

January 13, 209

Program Manager, Office of Renewable Energy Bureau of Ocean Energy Management 45600 Woodland Road, Sterling, Virginia 20166

To Whom It May Concern,

Please accept the following comments in support of Vineyard Wind’s offshore wind project. The draft Environmental Impact Statement (DEIS) issued by your agency clearly demonstrates that the project has taken the necessary steps to minimize potential negative impacts to the environment and local communities. I also support the project because it’s being developed by a local company with strong ties to the community. The Bureau of Ocean Energy Management (BOEM) should approve this project and allow it to move forward.

As a Massachusetts resident and owner of a solar energy installation company, I can speak directly to the need to encourage the development of responsibly-sited and managed renewable energy projects in our region. Properly executed, renewable energy projects have the potential to deliver substantial local economic and environmental benefits while joining the global effort to combat climate change. The DEIS provides an overview of a project that will do far more good than harm. Vineyard Wind is committed to working with local communities as the project moves into the construction phase and beyond.

It is imperative that we transition to 100% renewable energy systems to mitigate climate change, but we also need to pay attention to who is able to participate in the transition as well as who receives the benefits. As a locally owned solar installer, we are focused on returning energy dollars back to the local economy, unlike national third party owned developers that export our dollars to investment groups. The same is likely to be true in the emerging offshore wind sector with companies that have local ties to the community showing interest in developing projects in a responsible manner to ensure the communities where they are based receive a large share of the benefits.

As the first commercial-scale offshore wind farm in the country, Vineyard Wind’s project has the potential to set the standard for an industry that is at risk of being dominated by multi-national oil and gas giants with a less than stellar environmental protection and community outreach track record. Allowing this project to proceed will put the other offshore wind developers on notice and let them know what steps they will need to take to obtain the necessary permits for their projects.

For all the reasons listed above, BOEM should grant this project all the necessary approvals.

Thank you for your consideration.

With kind regards,

Gregory Garrison, President Northeast Solar January 13, 2019

136 Elm Street • Hatfield MA • 01038 Mr. Matthew Beaton, Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) MEPA Office Purvi Patel, EEA No. 15787 (Vineyard Wind Connector) 100 Cambridge Street, Suite 900 Boston, MA 02114

Dear Secretary Beaton and Ms. Patel,

I am writing to express my support for Vineyard Wind Connector. The Final Environmental Impact Report (FEIR) paints a picture of a project that will deliver significant benefit to the Commonwealth of Massachusetts. In addition to the 800 MW of clean energy it will generate, I support the project because it is being developed by a local company with strong ties to the local community.

The Commonwealth of Massachusetts should be doing everything it can to encourage the rapid deployment of responsibly-sited and collaboratively developed renewable energy projects. As the owner of a Massachusetts based solar installation company, I can speak directly to the need to encourage the development of locally-owned projects that deliver real benefits to communities. Locally-owned distributed solar projects, for example, result in greater investment in the local economy than third-party owned systems owned by large national corporations. The same is to be true in the emerging offshore wind sector with companies that have local ties to the community showing a greatest interest in developing projects in a responsible manner to ensure that local communities receive a large share of the benefits.

Vineyard Wind is a local company, based in New Bedford, that has worked for the better part of a decade to develop a renewable energy project that will jumpstart an industry while at the same time providing long-lasting benefits to the Massachusetts economy. Vineyard Wind Connector, and the offshore wind farm, is the type of project we need to see more of.

For all of these reasons, I strongly encourage you to allow Vineyard Wind Connector to move forward.

Thank you for your consideration.

With kind regards,

Gregory Garrison, President Northeast Solar

136 Elm Street • Hatfield MA • 01038 From: Jan Kubiac To: Patel, Purvi (EEA); Patel, Purvi (EEA) Subject: Comment for Secretary Matt Beaton re: Vineyard Wind Connector Date: Monday, December 24, 2018 8:11:08 AM

December 24, 2018

MEPA Analyst Purvi Patel

Dear Ms. Patel,

I have written earlier in support of Vineyard Wind and wind energy in general and I’ve come to appreciate what a painstaking process this has been for VW Connector and the EFSB. I am still confident that VW is capable and in earnest in protecting our environment and its negotiations with our communities. However, I do have a growing concern that the process of moving forward on renewable energy projects, including VW, continues to be subject to the objections of those who have less of an understanding of the urgency of climate change. I hope we can develop a devotion to solutions to this crisis that overrides any temptation to defend a dangerous status quo. We need an indomitable spirit of cooperation in sustainability, renewable energy and energy efficiency to turn the corner on this crisis. Everyday that we don’t go forward in addressing this global emergency makes our climb steeper and more treacherous. VW Connector will be an important step in addressing our electricity needs with clean energy and in joining the established global wind energy industry with a substantially improved technology.

Sincerely,

Jan Kubiac Citizens Climate Lobby Member PO Box 408 West Yarmouth, MA 02673

74-216-0864 From: [email protected] To: Patel, Purvi (EEA) Subject: Comments on the FEIR Date: Monday, January 21, 2019 11:46:22 PM

Dear Mr. Patel:

I would like to submit comments on the Massachusetts Final Environmental Impact Report (FEIR) for the Vineyard Wind Connector. After extensive examination of the Vineyard Wind Offshore Wind Project in Massachusetts, the Bureau of Ocean Energy Management (BOEM) has concluded that there is negative or minimal impacts to the environment and communities.

The State of Massachusetts and most of the world have determined that burning fossil fuels releases such dangerous amounts of carbon into the atmosphere that it causes and will continue to have a deleterious effect directly on the health of people and on climate change. The consequent effect will continue to warm the planet, cause sea rise, cause innumerable weather disasters, and reduce arable land. This affects not only Massachusetts but also, importantly, the entire nation, as well as the entire world. In particular, it greatly affects where I live in West Tisbury, MA on Martha's Vineyard, an island which in the future will largely be claimed by the rising sea if the world does not act to reduce and eventually eliminate the burning of fossil fuels. This must be done mostly by changing over to renewable sources of energy. Offshore wind power is a key element of that renewable energy.

I see it as a comparison of risks. The risk of the Offshore Wind Project's impact on the environment and communities, including fisheries, is very, very low. The risk that the continued burning of fossil fuels at the current pace will cause the above described effects is not only very high, but virtually a certainty. Low risk versus a virtual certainty -- that makes it a clear choice. Thus, do all that is possible to convert to renewable, clean energy. At a minimum, we are 30 years late in seriously committing to act on developing clean energy. We cannot afford to delay it any further.

Thus, I strongly support the Offshore Wind Project in Massachusetts and the approval of the Final Environmental Impact Report for the Vineyard Wind Connector.

Thank you for considering my comments.

Sincerely,

Jeffrey K. Kominers Board Member Island Wind, Inc. From: Jerald K To: Patel, Purvi (EEA) Subject: supporting Vineyard Wind Date: Friday, January 25, 2019 10:30:30 AM

Ms. Patel:

I am a resident of Martha's Vineyard, and am writing in support of Vineyard Wind's proposed Energy Facility Offshore Massachusetts. Many others have written more knowledgeably about the environmental advantages of the Project. I would simply add that I appreciate the work that has gone into making the turbines as environmentally responsible as seems currently feasible. For the sake of your families and ours, we need alternate energy sources to allow the atmosphere to clean itself as soon as it can.

Thank you,

Jerald Katch Chilmark, MA From: James Leonard To: Patel, Purvi (EEA) Date: Thursday, January 24, 2019 5:19:37 PM

Hello! I would like to express my support for the Vineyard Wind renewable energy project.

I've been tracking the progress of this initiative for many months now. The recent environmental impact reports pointed out several areas needing attention-- protection of fishing grounds, shipping lanes, and limiting wildlife damage to name a few. The Vineyard Wind group appears to be making progress to address the majority of major concerns as the production phase ramps up.

Please consider this note a request for ongoing support for this important development--for the Cape and Islands, but also for Massachusetts as a whole. With development of renewable energy at scale, we can lead the way for the rest of our nation--much like we've done with expanding healthcare coverage over the past decade.

Regards, Jim Leonard 27 Park Street Norfolk, MA 02056 508 528 3939 From: joanne treistman To: Patel, Purvi (EEA) Subject: vineyard wind Date: Friday, January 25, 2019 8:49:42 AM

Here on the Cape we know the value of our winds and the value of energy we can reap from those winds. Please push this forward to lower our dependence on fossil fuels. Our family uses solar power now and we want all our neighbors to have access to natural energy.

Thank you

Joanne Treistman Falmouth MA From: john matley To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Thursday, January 24, 2019 7:36:02 PM

I strongly feel that Vineyard Wind should be allowed to proceed. I have watched their efforts to satisfy the demands of fishing and environmental interests and they have answered all questions brought to them. My extreme interest is due to the the status of my grandchildren's right to a world in keeping with what nature intended, not one that is burning up through fossil fuel emissions. Thank you for considering my request, John Matley From: Jonathan Hartzband To: Patel, Purvi (EEA) Subject: FEIR Date: Monday, January 21, 2019 5:18:54 PM

Dear Secretary Beaton,

I am writing in support of the approval of the final environmental impact report for the vineyard wind connector. Renewable energy needs to be be the focus of our energy future, What vineyard wind is doing is not only building the first major offshore wind farm in the United States but they are laying the path for others to follow. If not now, when? Time is critical and with climate change already impacting so many parts of our world I truly believe that it is our turn to act. As a full time resident and property owner on Martha's Vineyard I understand there will be disturbances during the construction phase of this project. I think the the long term benefits far outweigh the short term disturbances. This is a giant step in beginning to make our commonwealth less dependent on fossil fuels, if we lead others will follow. I hope you will approve the final Enviornmental impact review for the vineyard wind connector.

Thank you for your time, Jon Hartzband West Tisbury Ma Board member - Vineyard power co-operative inc. From: Jonathan Ryder To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Wednesday, December 19, 2018 8:09:15 AM

Ms. Patel,

I would like to make a comment in regards to Vineyard Wind. A few years ago, the Republican National Committee made "Drill, Baby, Drill" a major slogan. Well, I have a response to that:

SPIN, BABY, SPIN!

I support Vineyard Wind 100%; I would support it 1,000,000% if that was mathematically possible. Climate Change is happening. We are seeing the effects right now. The predictions for the end of the century fall somewhere between "devastating" and "apocalyptic." We need to change the way we generate power. The solution for this is not a single action, but a series of actions. Wind Power is one of those actions. And while it is far from perfect, the only way to improve it is to stick a bunch of turbines up, see how they work, and then use those observations to improve the next generation. Stick turbines up wherever they will fit. If a Kennedy complains about the view getting "ruined"..... tough beans!

In closing, I would like to repeat:

SPIN, BABY, SPIN!!!!!!

Respectfully, Jonathan Ryder Riverside, RI From: Kirstin Moritz To: Patel, Purvi (EEA) Subject: Support for Vineyard Wind Date: Thursday, January 17, 2019 4:53:57 PM

Dear Sir, I would like to send support for the Vineyard Wind project. We desperately need to build up wind energy resources in our country and the Cape area has great wind resources. This project is perfect....and I am fully aware of issues around wind turbines as we here in Falmouth managed to destroy our renewable energy producing abilities because of community opposition, which was very short sighted, to our wind turbines.

So the Vineyard Wind project should avoid community opposition and serve us all very well. Please approve this project. Kirstin Moritz, resident , Falmouth, Ma

Sent from my iPad From: Kristin Daley To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Tuesday, January 22, 2019 7:32:00 PM

I’m in favor of the Vineyard Wind project. Please support. Thank you.

Kristin Daley PO Box 1024 Oak Bluffs, MA 02557 From: [email protected] To: Patel, Purvi (EEA) Subject: Vineyard Wind proposal Date: Tuesday, January 22, 2019 7:44:37 AM

Purvi,

I want to let you know that I support the project and hope you will as well.

Some key points from a Vineyard Power document:

It will provide 800 MW of clean, renewable energy with little negative impacts to the environment or communities. Vineyard Wind has been an accessible, transparent and responsive community partner throughout the process. As a coastal community, Martha’s Vineyard is particularly vulnerable to Climate Disruption and Ocean Acidification.

Thank you for your consideration.

-Larry Apfelbaum Vineyard Haven, MA From: Lindsay Mis To: Patel, Purvi (EEA) Subject: support of the Vineyard Wind project Date: Tuesday, January 22, 2019 1:11:00 PM

This email is to demonstrate support of the Vineyard Wind project. My organization Massachusetts Design Art & Technology Institute is located in New Bedford, where the tech and research economy is growing more than ever thanks to the wind industry. The effects are inspiring and is furthering ingenuity in the community. My organization celebrates how technology overlaps with design and art, because the communities in New Bedford and the SouthCoast should grasp the innovations coming thanks to the incoming renewable energy developments. My family was once a supporter of the controversial nuclear energy as a cleaner means than coal, now we are in support of wind. Wind once pushed the sails of New Bedford's whale ships and now can push the turbines along the coast. Do not be uninspired by the government shut-down. Please keep your vision to have Vineyard Winds stay in the SouthCoast of NB. The community welcomes the new industry.

Thank you,

Lindsay Miś

Executive Director, DATMA

Massachusetts Design Art & Technology www.DATMA.org

Office Hours: Monday -Friday from 9am-5pm PH 774.264.3696

336 Acushnet Avenue, Suite C, New Bedford, MA 02740 From: Louise Amyot To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Wednesday, January 23, 2019 4:01:08 PM

Dear Mr. Patel,

I have read about the Vineyard Wind application to build an offshore windfarm off the coast of Martha's Vineyard and I am writing to express my complete support for this project.

It is urgent, if we are to survive the effects of climate change, that we humans make big changes to the way we do things and FAST! Windmills, offshore, are the fastest, safest way to do this with the least possible disruption of life as we know it.

For those who are concerned about aesthetics, let me remind everyone that flooded shorelines and homes destroyed by floods and/or hurricanes are much more expensive, painful and ugly than a few windmills in the distance. I have seen many windmills in the Midwest and did not find them offensive to look at in any way. Also, at sea, windmills are not likely to cause the kinds of atmospheric conditions that some individuals claim to feel when the wind farms are placed on earth in proximity to people.

While I understand that fishermen have some concerns, I also have read about all the modifications that Vineyard Wind has made to their plans in order to mitigate any likely disturbances that might affect local fisheries. I have also read that any such disturbances are likely to be short-lived and quickly overcome.

Change is always difficult but changes that promise to protect our people and our communities are changes that we must accept for the sake of our future and that of our fellow creatures. We owe it to all living beings to do something drastic and fast in order to save the Planet from our more selfish and demanding selves!

This is your chance to be a hero, Mr. Patel. Please approve this project and continue supporting the development of renewable energy projects in the state.

Thank you for your consideration.

Regards,

Louise Amyot Greenfield, Massachusetts From: Maureen Condon To: Patel, Purvi (EEA) Subject: I totally support Vineyard Wind! Date: Thursday, January 24, 2019 8:51:59 PM

We need to protect the environment and Vineyard Wind should be part of that effort. We only have a decade or so to drastically decrease our dependence on fossil fuel. Please give the green light go ahead to Vineyard Wind.

Sincerely,

Maureen Condon 10 Meadowbrook Lane Harwich Port, MA 02646 From: Mike Jacobs To: Patel, Purvi (EEA) Subject: FEIR Vineyard Wind Connector, EEA No. 15787 Date: Thursday, January 10, 2019 8:04:58 AM

January 10, 2019 Secretary Matthew A. Beaton Attn: MEPA Office, Purvi Patel Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA, 02114

RE: FEIR Vineyard Wind Connector, EEA No. 15787

These comments support the approval of the Final Environmental Impact Report prepared by Vineyard Wind for the Vineyard Wind Connector. This process has resulted in an improved proposal, resulting in a project the Federal Bureau of Ocean Energy Management has found only negligible or minor negative impacts to environment and communities, Notable in the process has been the reduction in the number of turbines and the proposal to move the cable landing to Barnstable.

The importance of the Vineyard Wind Connector, as a means to provide carbon-free energy to the Commonwealth cannot be overlooked. Absent the Vineyard Wind Connector, the Commonwealth would be certain to increase its use of natural gas. With the proposed project, the use of gas in electricity generation will be reduced every day.

The project proponent has described temporary impacts, which will be confined to the construction period. The impacts of the alternative, an increase in the use of natural gas, will have continuous impacts on Massachusetts for as long as the state has residents along the coast. The permitting of a new energy supply will always have trade-offs, but there can hardly be a more dramatic difference between the choices in this case.

Vineyard Wind has prepared this document as part of the process that began with community input and now comes to its final stage. These are “necessary meaningful steps to change our fuel mix to a low-carbon mix that contains a significant amount of renewable energy" as described by the Association to Preserve Cape Cod.

I hope that your review will approve the FEIR for the Vineyard Wind Connector.

Sincerely, -signed- Michael B. Jacobs Chairman, Vineyard Power Co-operative, Inc. Chilmark, Massachusetts

Patel, Purvi (EEA)

From: Nicola Blake Sent: Tuesday, January 15, 2019 6:25 PM To: Patel, Purvi (EEA) Subject: Comment on Vineyard Wind’s FEIR - I support Vineyard Wind!

Secretary Matthew A. Beaton Attn: MEPA Office, Purvi Patel

I am a PhD Chemist/Environmental scientist and home owner in West Tisbury, Martha’s Vineyard.

I am writing in support of Vineyard Wind.

I have long followed the progress of Vineyard Power/Wind and I know that the people at Vineyard Wind have worked long and hard to try to make reliable off-shore renewable wind energy a reality for New England/the US. They have addressed (and continue to) address concerns about cables (we have had power cables to the Vineyard and Nantucket for a long time now), fishing concerns, potential visual impacts, economic impact/bringing training and jobs to the Vineyard, etc. I have been very impressed by their diligence and efforts at community outreach.

With Carbon Dioxide (CO2) levels topping more than 410 ppm in just the last several months - a level not seen in millions of years ( https://www.scientificamerican.com/article/we-just-breached- the-410-ppm-threshold-for-co2/# ) - I believe that we desperately need to wean ourselves away from our reliance on fossil fuels. To do this, we need to drastically cut carbon emissions, and to accelerate our transition to a low- carbon future – leading to more stable coastlines and to a healthier planet.

I am confident that Vineyard Wind will be a good neighbor to me in my Martha’s Vineyard home and for my Cape and Islands community - and that they will attract good jobs for our youth.

The Vineyard Wind project is a very important step in meeting our renewable energy and greenhouse gas reduction goals. It will also help to establish Massachusetts as a national leader in the offshore wind energy field and I wholeheartedly support it!

Overall - I am very excited to have this operation in/near my community - and I welcome Vineyard Wind!

Thanks for your attention.

Nicola Blake

Nicola J. Blake 128 Old County Rd West Tisbury, MA 02575 [email protected] Cell: 603-545-9906

2 Patel, Purvi (EEA)

From: Nicole Morris-McLaughlin Sent: Friday, January 25, 2019 3:26 PM To: Patel, Purvi (EEA) Subject: Attn: MEPA Office Purvi Patel, EEA No. 15787 (Vineyard Wind Connector)

Boston MA 02114

Dear Matthew Beaton,

I am the Program Manager of the Marion Institute’s Southcoast Energy Challenge and our mission is to advocate for clean, affordable energy that is accessible to everyone. The Vineyard Wind Project aligns with our mission; construction of the Project will serve the public interest by increasing the reliability and diversity of the regional and statewide energy supply while reducing greenhouse gas emissions from the regional power generation grid. I urge Massachusetts to move the permitting process along efficiently and expeditiously.

Vineyard Wind’s team of environmental scientists, engineers, and attorneys have worked hard to incorporate the available results of the 2018 marine surveys and to present the detailed data in a user-friendly way. For each route configuration that is continuing through the review process, environmental impacts are comparable on the whole, and have been avoided, minimized, or mitigated consistent with MEPA standards.

The Vineyard Wind team participated in two informative and collaborative discussions on construction sequencing and the possible need for time of year restrictions or other protective measures. I believe Vineyard Wind is making good progress towards a construction approach which will allow the Project to meet its scheduled power supply commitments while working in safe weather conditions and respecting significant marine environmental concerns.

The total net benefits to Massachusetts ratepayer over the term of the contract would be approximately $1.4 billion. DOER noted that the 800 MW Vineyard Wind Project provides a “unique opportunity to maximize the value of the federal investment tax credit (“ITC”) as the value of the credit is scheduled to be gradually reduced and will not be available for projects that start construction after December 31, 2019 .” In addition to the estimated 1,680,000 tons-per-year of CO2 emissions reductions across New England, the Project will create substantial economic benefits for southeastern Massachusetts and the Commonwealth as a whole. This decrease in

1 burning fossil fuels will significantly improve the health of residents in Massachusetts, saving them money and improving their quality of life.

Vineyard Wind is constantly engaging with local officials and local communities, with extensive outreach to, and discussions with, the commercial and recreational fishing community. To date, Vineyard Wind has had over 125 meetings with individual fishermen or fishing organizations from New Bedford, the Cape and the Islands, and in neighboring Rhode Island. Vineyard Wind is incorporating input and information from the fishing industry into the Project’s design and operations.

Vineyard Wind has engaged with the non-profit I work for, the Marion Institute on multiple occasions making themselves available for conversation with us and the people we represent, including creating a tour of the New Bedford Marine Commerce Terminal along with bringing in multiple speakers for our 15 high school interns this summer.

The community that the Southcoast Energy Challenge serves, New Bedford, is an Environmental Justice Community and the fact that clean wind energy will be able to replace burning fossil fuels around this community, decrease the cost of electricity and create much-needed good jobs. Vineyard Wind has committed $12 million to the Offshore Wind Accelerator Fund and Windward Workforce Fund to ensure the offshore wind industry is anchored in Southeastern Massachusetts and will employ local residents in the community. Vineyard Wind’s project is a wonderful gift to our region and it cannot happen soon enough.

Sincerely, Nicole Morris-McLaughlin Southcoast Energy Challenge Program Manager Marion Institute

2 From: Patricia Rego To: Patel, Purvi (EEA) Cc: Nicole Morris-McLaughlin ([email protected]) Subject: Submission: Public comment to the Vineyard Wind FEIR Date: Wednesday, January 23, 2019 2:42:08 PM

TO: Mr. Matthew Beaton, Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office Purvi Patel, EEA No. 15787 (Vineyard Wind Connector) FROM: Patti Rego, on behalf of the Marion Institute, Marion, MA RE: Letter of support for the Vineyard Wind Project, EEA No. 15787 (Vineyard Wind Connector)

Dear Secretary Beaton,

The Marion Institute, a 501c3 non profit organization, supports a sustainable Southcoast and as such, supports the Vineyard Wind project in New Bedford, MA.

Wind energy is a sustainable resource that generates no pollution or hazardous waste and therefore has a direct and immediate benefit to health impacts associated with air pollution, such as asthma. With wind power, the region can reduce CO2 emissions by over 1.6 million tons- that's the equivalent of taking 325,000 cars of the road!

As an organization committed to helping people live fuller, healthier lives in Southcoast Massachusetts, and around the globe, we support wind power as a clean power source alternative that will help to reduce the amount of pollutants in the air, caused by traditional forms of energy creation.

Thank you for your time and your interest in this area's future.

Sincerely,

Patti Rego Marketing Director Marion Institute 202 Spring Street Marion, MA 02738 M, T, TH: call 508.748.0816 x117 W, F - call 347.452.9488 www.marioninstitute.org

Join Marion Institute on FaceBook! From: Paul Pimentel To: Patel, Purvi (EEA) Subject: FEIR Vineyard Wind Connector, EEA No. 15787 Date: Thursday, January 10, 2019 2:51:16 PM

January 11, 2019 Secretary Matthew A. Beaton Attn: MEPA Office, Purvi Patel Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA, 02114

RE: FEIR Vineyard Wind Connector, EEA No. 15787

These comments support the approval of the Final Environmental Impact Report prepared by Vineyard Wind for the Vineyard Wind Connector. This process has resulted in an improved proposal, resulting in a project the Federal Bureau of Ocean Energy Management has found only negligible or minor negative impacts to environment and communities. Notable in the process has been the reduction in the number of turbines and the proposal to move the cable landing to Barnstable.

The proposed project will supply up to 800MW of carbon free, renewable energy to Massachusetts; that’s enough to provide 6% of the Commonwealth’s overall energy consumption. It’s a big part of Massachusetts’ commitment to 1,600 MW of offshore wind. It’s the first utility scale offshore wind project in the US and it’s a big step in addressing the greatest existential threat to mankind. It will save ratepayers money, and boost our economy with new jobs.

Vineyard Wind has prepared this document as part of the process that began with community input and now comes to its final stage. These are “necessary meaningful steps to change our fuel mix to a low- carbon mix that contains a significant amount of renewable energy" as described by the Association to Preserve Cape Cod.

I hope that your review will approve the FEIR for the Vineyard Wind Connector.

Sincerely,

Paul F. Pimentel Director, Vineyard Power Co-operative, Inc. Edgartown, Massachusetts

From: 2 To: Patel, Purvi (EEA) Cc: [email protected]; [email protected] Subject: Vineyard Wind Date: Friday, January 25, 2019 2:58:53 PM

To: Purvi Patel

From: Paul Minus, Senior Advisor, Cape & Islands Faith Communities Environmental Network

I reach out to you as a Cape Cod resident (Orleans) who has made his principal retirement activity for two decades working to protect the environment. Most of my time the last two years has been spent helping to give birth to the Faith Communities Environmental Network, a coalition of 19 groups from multiple faith traditions now spread across the Cape and Islands. Each of these groups is led by people whose religious faith has impelled them to give passionate and persistent leadership to their respective congregations in working to protect God's good creation.

We have been doing this in a period when Vineyard Wind has emerged as a key player increasing the availability and use of wind energy to provide clean power for large numbers of homes - and we have followed this development closely and are strongly supportive of it.

I am joined by large numbers of colleagues in urging you and other Massachusetts leaders to do everything possible to move Vineyard Wind's critical project rapidly through this important review process, so that it may take its rightful place as a pre- eminent example to the rest of the nation as a wise, responsible example of how to harness the earth's natural systems to provide energy widely to the American people.

Thank you. From: Peter Bachant To: Patel, Purvi (EEA) Subject: Comments on Vineyard Wind FEIR Date: Thursday, January 17, 2019 8:10:54 PM

To Whom it May Concern:

I am writing in regards to the Vineyard Wind Project FEIR. After reading this report it is clear that there are minor short-term negative effects that may be caused by this project, but that the environmental and economic benefits far outweigh these. I fully support the construction of this wind farm.

Sincerely, Peter Bachant From: Phil Cavallo To: Patel, Purvi (EEA) Subject: In Favor of Vineyard Wind Date: Thursday, January 24, 2019 5:06:42 PM Attachments: image001.png

Dear Ms. Patel,

I am writing to you to have my support be heard for this historic project to be built south of Martha’s Vineyard. As a member of the renewable energy industry and as a business owner in Massachusetts I can state that this is the future of our energy supply and this wind farm should be pursued wholeheartedly. The project will create jobs, bring new industry to the region, increase the tax base, educate people to learn new skills and save the environment.

In Europe this level of planning and development has been on going for over a decade. Germany and the UK are leaders in this industry and the USA should be one too. We have a great available and abundant wind resource off of the cost of MA and we should take advantage of it while helping reduce carbon emissions and reduce the climate change effects.

Please let me know if I can be any further assistance in this matter.

Sincerely,

Phillip Cavallo

______

Phillip Cavallo President & CEO

Beaumont Solar Co. 200 North Street New Bedford, Ma. 02740

508-990-1757 x-205 office 508-685-8023 cell 508-990-1756 fax www.beaumontsolarco.com

From: Carl Borchert To: Patel, Purvi (EEA) Subject: Vineyard Wind Energy Project Date: Wednesday, January 09, 2019 7:28:25 PM

To Whom It May Concern,

The Vineyard Wind Energy Project can breath new life into our state with it’s positive economic benefits. The port of New Bedford and the Marine Commerce Terminal are 2 examples. The port of Vineyard Haven is another. We can also develop a supply chain here for all the different components necessary for construction of offshore wind farms. This can help us transition away from dirty fossil fuels and create thousands of jobs.

I urge you to do all in your power to advance this project to completion.

Thank you, Randi Allfather Nantucket Island [email protected]

January 16, 2019

Secretary Matthew A. Beaton Attn: MEPA Office, Purvi Patel (EEA #15787) Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114

Dear Secretary Beaton,

On behalf of our approximate 3,500 members on the island of Martha’s Vineyard, we would like to express our full support for all aspects of the Vineyard Wind Connector including their proposed cable landing and interconnection on Cape Cod.

As a community that is connected to the New England grid by four high voltage power cables coming to our shores, we understand the impact of these structures in our local waters. The benefits of this project far outweigh its possible temporary and localized disturbances and a failure to approve this project would have far more devastating and long-lasting negative impacts on the region, by perpetuating the reliance on fossil fuels to meet our growing energy needs. These impacts include ocean sea level rise, ocean acidification, coastal zone erosion, and exposure to increasing storm strength and frequency.

The project’s 800 MW of renewable electricity will reduce CO2 emissions from the grid by approximately 1.68 million tons/year, which is the equivalent of removing 325,000 vehicles off the road. This project is a giant leap in meeting our Commonwealth’s renewable energy and greenhouse gas reduction goals and will deliver power where it’s needed most, at the end of the electrical grid on Cape Cod, thereby improving resiliency and greening our grid. It will also help to establish southern New England as the focus of a new industry and supply chain that will greatly benefit the local economy.

On behalf of all of our members, we thank you for providing us an opportunity to provide feedback into the project.

Sincerely,

Richard Andre President - Vineyard Power Cooperative

P.O. Box 1077, West Tisbury, MA 02575 t. 508.693.3002; [email protected] www.vineyardpower.com From: Bob Mason To: Patel, Purvi (EEA) Subject: Reference EEA No. 15787 (Vineyard Wind Connector) Date: Saturday, January 12, 2019 10:49:24 AM

I am in support of this wind project that will supply 800MW of carbon free, renewable energy to Massachusetts; enough to power 425,000 homes. This wind farm development site identified after a 5-year stakeholder and community engagement process with the Federal government which included representation from all six towns on Martha’s Vineyard and the Martha’s Vineyard Commission.

The companies managing the project (Avangrid and Copenhagen Infrastructure Partners) have extensive offshore wind experience worldwide and financial capabilities to finance large infrastructure projects. And Vineyard Wind has been an accessible, transparent and responsive community partner throughout the process. This is evident in the Community Benefit Agreement executed with Vineyard Power.

After extensive research, data collection and stakeholder input, BOEM has found mostly negligible or minor negative impacts to environment and communities and there are many environmental and economic benefits. This is a first step in Massachusetts’ commitment to 1,600 MW of offshore wind. The Mass Dept of Energy Resources (DOER) determined this wind farm will save Massachusetts ratepayers $1.4 billion over 20 years. And Martha’s Vineyard will benefit from the location of the project’s Operation & Maintenance facility.

Robert Mason 5 Caleb's Common Circle Edgartown, MA From: ROBERT MYERS To: Patel, Purvi (EEA) Subject: Vineyard Wind approach is a model for future offshore wind projects. Date: Thursday, January 24, 2019 6:07:00 PM

"Come sail your ships around me" Nick Cave From: Rodolfo Cardona To: Patel, Purvi (EEA) Subject: Wind project Date: Wednesday, January 09, 2019 4:55:33 PM

I wish to express my complete approval for the Wind Mills project. In view of the present U.S. Government denial of climate change and consequent new legislations that allows for coal use and many other insane decisions, it is more urgent than ever to go ahead with the Wind project. Yours sincerely, Rodolfo Cardona w Skipper's view Lane, Aquinnah, MA 02535 From: Ron Dagostino To: Patel, Purvi (EEA) Subject: EEA No. 15787 (Vineyard Wind Connector) Date: Wednesday, January 09, 2019 3:05:09 PM

To Whom It May Concern,

As a resident of Martha's Vineyard and a long-time board member of Vineyard Power, I wholeheartedly express my full support for the Vineyard Wind project. BOEM has found mostly negligible or minor negative impacts to environment and communities, and the suggested alternative actions to reduce the number of turbines and move the preferred cable landing to Barnstable have already been incorporated into the project plan. Vineyard Wind has committed $3 million to a Wind and Whales Fund to advance technologies and programs to ensure offshore wind can co-exist with marine mammals. This is consistent with the accessible, transparent, and responsive community partner stance that Vineyard Wind has taken throughout the process -- as evidenced also by the the Community Benefit Agreement executed with Vineyard Power. I personally am deeply concerned about the existential threat of climate change. This project will be the first utility-scale offshore wind project in the United States, and it represents an extremely important step in addressing climate change. It can and should lead to an enormous offshore wind benefit for the eastern part of the United States. Every part of the country needs to do what it can -- solar in the southwest, hydro in the northwest, onshore wind in the plains states -- and offshore wind in the east. Locally, Martha’s Vineyard will benefit from the location of the project’s Operation & Maintenance facility, which will generate up 50 full-time jobs earning a middle class income. There will be an additional multiplier effect for many small businesses on the Vineyard as well. Many local families have experienced the pain of an adult child not being able to stay on the Vineyard due to the high cost of living and a lack of good, year-round jobs. This project has both global impact and local impact, and it needs to happen as soon as possible.

Sincerely,

Ronald Dagostino PO Box 1658 West Tisbury, MA 02575-1658 From: sayre phillips To: Patel, Purvi (EEA) Subject: Renewed hope for Cape wind power Date: Wednesday, December 19, 2018 8:47:55 AM

Dear Purvi Patel, as long time Cape property owners , my husband and I supported off shore windpower against what we saw as shortsighted opposition. Now that the evidence of climate change must be clear to everyone we have a chance to go ahead with projects that are essential if we are to have a future, Sayre Sheldon, West Hyannisport. From: Sharon Davis To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Friday, January 25, 2019 1:32:59 PM

As longtime residents of the Cape, we fully endorse Vineyard Winds proposed wind project. Cape sea levels are rising and the only responsible way to mitigate climate change is to change the way in which we produce and use energy. We encourage state legislators and regulators to fully endorse and support this effort.

Sharon and Paul Davis Orleans, MA From: Sharon Rounds To: Patel, Purvi (EEA) Subject: Off Shore Wind Farm Date: Friday, January 25, 2019 11:19:25 AM

Hello:

I am writing in support of this project and in agreement with Vinyard Wind's plans to protect right whales and other sea life.

Thank You, Sharon Rounds 99 Long Pond Road Brewster, MA 02631

WHEREAS, Vineyard Wind is committed to developing offshore wind power projects in the U.S. with ro WHEREAS, Vineyard Wind is committed to developing offshore wind power projects in the U.S. with robust standards of environmental protection during pre

- development, construction, and operations and maintenance activities

, while making a meaningful contribution to science that can support the responsible development of America’s vast offshore wind resources;

WHEREAS, the protection of the N orth

A tlantic right whale is a top priority, the Parties recognize and agree that protective actions set forth herein must be done in a manner that ensures human health and safety when working in the offshore environment; bust standards of environmental protection during pre - development, construction, and operations and maintenance activities , while making a meaningful contribution to science that can support the responsible development of America’s vast offshore wind resources; WHEREAS, the protection of the N orth A tlantic right whale is a top priority, the Parties recognize and agree that protective actions set forth herein must be done in a manner that ensures human health and safety when working in the offshore environment;

From: Sheila B. Place To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Tuesday, January 08, 2019 4:37:03 PM

Dear Ms. Patel,

I’m writing in support of Vineyard Wind’s 800 MW wind turbine project south of Martha’s Vineyard, Clearly, there’s a new sense of urgency, as we’ve learned today that U.S. emissions of greenhouse gasses rose 3.8 percent in 2018. Climate scientists tell us we have ten years to bring our emissions down to sustainable levels, and with the recent growth in emissions, that window may have just narrowed.

Decreasing, quickly, our reliance on fossil fuels is absolutely necessary if we are to respond to this crisis. Renewable energy may save us, and a project the size of Vineyard Wind’s can make a major contribution to reducing the need for fossil fuels.

I understand there will likely be some impacts during construction, but I believe Vineyard Wind’s focus on stakeholder concerns will do much to mitigate those impacts.I am sympathetic to the fisherman in the area and their concerns about the turbines, but we know a warming ocean is most likely the greatest threat to their livelihood. There have already been notable migrations of fish heading north to find colder water. Ocean acidification due to warming is causing further harm, especially to shellfish.

The long term benefits of renewable energy seem to clearly outweigh any short term impacts. We have the science in hand, and a robust solution in view. I’m glad the regulatory process is thoughtful and careful, but we need projects like this to move forward, and soon..

Sincerely, Sheila Place From: Steven Carvalho To: Patel, Purvi (EEA) Subject: Vineyard Wind Date: Thursday, January 24, 2019 10:54:30 PM

Greetings,

My name is Steven Carvalho Jr, and I am a student at Old Rochester Regional High School speaking on behalf of the company Vineyard Wind, who is striving to revolutionize the energy sources that are used throughout Massachusetts, and essentially, the nation. Vineyard Wind's goal is to build the first large scale offshore wind farm, providing clean, safe, and renewable energy. This project, assuming all goes according to plan, could be fully operational by the year of 2021. Using this method to power the state would benefit the economy, and society greatly. A controversial subject, however, is the affects that a wind farm could have on the environment. While people are worried about the state pf the marine life, Vineyard Wind has already accounted for such issues, as they are dispensing three million dollars out of their fifteen million dollar budget to marine mammals, ensuring their health and safety. When it comes to being able to transport water collected without disturbance to the environment, the company plans to include substations in Barnstable, Massachusetts to do so, making sure that there are little to no environmental detriments. Another environmental issue that has risen recently has been carbon dioxide emissions, and with this project, Vineyard Wind can offset the emissions by 1.6 million metric tons annually, which is the equivalent of removing 325,000 cars off of the road. Therefore, the environment should be the least of the concerns. Vineyard Wind should be heavily considered as a contributor to the future of the state of Massachusetts and the nation's energy discussions.

Thank you for your time, Steven Carvalho Jr Old Rochester Regional High School Mattapoisett, Massachusetts 02739

Patel, Purvi (EEA)

From: Susan Wasserman Sent: Monday, January 14, 2019 4:24 PM To: Patel, Purvi (EEA) Subject: BOEM-2018-0069

TO WHOM IT MAY CONCERN;

I am totally in favor of this project that will supply at least 425,000 Massachusetts homes with renewable, carbon-free energy! Environmental concerns that have been raised, along with fishermen’s opposition, can all be negotiated and that process has already begun. Please approve Vineyard Wind. It’s in the best interest of our citizens and the climate!! Thank you. Susan Wasserman, PO Box 3069, West Tisbury, MA. 02575

1 From: Tom Soldini To: Patel, Purvi (EEA) Subject: EEA No. 15787 (Vineyard Wind Connector) Date: Thursday, January 24, 2019 9:36:04 PM

Secretary Beaton:

I am a resident of Edgartown, Massachusetts. I am writing to express my wholehearted support for the Vineyard Wind Connector, and to urge the Executive Office of Energy and Environmental Affairs to minimize delays in the permitting process to the greatest extent possible.

This project, and indeed the development of offshore wind as a major source of renewable, clean energy, is of the utmost importance to the citizens of the Commonwealth of Massachusetts, the United States, and the entire world. It is the single largest opportunity we have to replace coal, oil, and gas as primary sources of electricity in the eastern United States.

The climate altering impacts of an economy based on burning fossil fuels is clear, and the danger is growing daily. In just the past few days, peer-reviewed studies have shown that the ice caps in Antarctica and Greenland are receding much more rapidly than even the most pessimistic scenarios imagined. In the case of Greenland, the study suggests that we may “be at a tipping point” for the ice melt. The effects of such an acceleration are likely to be flooding of coastal cities, displacement of tens of millions of people, and extensive damage to agricultural and aquacultural production.

A number of concerns have been raised regarding the project’s possible impact to marine life and navigational safety. Those unknowns must be respected, and thoughtfully accounted for by the offshore wind operators. Vineyard Wind is doing so. The project has been endorsed by both the Alliance to Protect Cape Cod, and The Cape Cod Climate Collaborative. Both organizations cite the clear, certain impacts to marine wildlife from climate change as the driving impetus for developing this project as an urgent countermeasure.

While offshore wind is relatively new to the United States, it has been in commercial use globally for nearly 30 years. Thousands of turbines have been operating for extended periods. With all this real-world experience there is no evidence to indicate significant hazards to marine life and to maritime navigation than cannot be effectively mitigated with techniques in use today. We must not allow fear of the unknown to delay us from acting to prevent a certain disaster.

I strongly urge the Executive Office of Energy and Environmental Affairs to conduct the rest of its review thoroughly and efficiently so the we can put this technology safely to use before it is too late to counter the effects of climate change. Time is not on our side. Respectfully,

Tom Soldini Edgartown, MA

January 18, 2019

Mr. Matthew Beaton Secretary of Energy and Environmental Affairs Massachusetts Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office Purvi Patel, EEA No. 15787 (Vineyard Wind Connector) 100 Cambridge Street, Suite 900 Boston, MA 02114

Dear Secretary Beaton,

On behalf of the more than twelve hundred-member businesses and organizations in the Cape Cod Chamber of Commerce, I wish to lend our strong support to Vineyard Wind’s proposed wind energy facility off the Massachusetts coastline and offer these comments on the recently submitted Final Environmental Impact Report.

Since 1921, the Cape Cod Chamber of Commerce has worked to strengthen and promote the economic viability, cultural richness, environmental sensitivity and the social needs of Cape Cod. The Cape Cod region is grounded in a Blue Economy – one where its water resources drive economic prosperity. This acknowledgement forces recognition that the environment is our economy, and that balancing both is critical to our region’s health and wellness. Investment in sound energy policy is a critical component to the region’s health and prosperity.

While the construction of offshore wind infrastructure in federal waters is new, the preparation for this day has been underway for over a decade. With the creation of the Massachusetts Task Force in 2009, the State and Federal Government have been engaged in an organized and collaborative effort with local stakeholders to identify the most advantageous wind development areas, while at the same time minimizing adverse impacts on other commercial uses and the marine environment. The submission of a Final Environmental Impact Report by Vineyard Wind represents an important milestone in the nation’s progress towards the birth of a new and important industry off our Commonwealth’s coastline.

The environmental review process is a critical one, and although arduous, aims to protect the health of our ocean ecosystems – something very important to coastal regions such as ours. We are encouraged by the findings developed in Bureau of Ocean Energy Management’s (BOEM) Draft Environmental Impact Statement (BOEM- 2018-0069) that show either negligible or minor impacts for nearly all categories reviewed, and moderate but mitigatable impacts to the fishing industry. For certain, fishing is one of our most historic and important coastal industries from an economic and cultural heritage standpoint. We are encouraged by Vineyard Wind’s commitment to working with the fishing industry to hear its concerns and find ways to minimize impacts to the extent possible. As an example, Vineyard Wind has an on-staff Fisheries Liaison, as well as Fisheries Representatives who represents the interests of fishermen to the project and help make sure the project is getting the information it should have about the fishing industry.

Vineyard Wind represents an opportunity to end our long-held designation as the terminus of the energy supply pipeline in the United States and would tie directly into the Cape Cod power grid, powering over 400,000 homes. This can result in improved resiliency and emergency planning in the region’s historically unreliable electric grid,

Cape Cod Chamber of Commerce, 5 Patti Page Way, Centerville, Cape Cod, Massachusetts 02632 1-888-33CapeCod (888-332-2732) or 508-362-3225 and the addition of new storage capacity through distributed projects on the Cape Cod, Martha’s Vineyard and Nantucket.

In term of economic development, Vineyard Wind’s represents $1.87 billion in direct economic benefits to Massachusetts including 3,600 new jobs and its development will spur the development of a domestic supply chain for the offshore wind industry to support the many other wind areas currently under lease by the Federal Government as they move into construction.

The creation of a major new industry such as offshore wind in the public domain is a major undertaking for sure. It is impossible to predict any and all circumstances that will occur as we launch this new industry. For that reason, we believe that Vineyard Wind is an excellent partner. They have demonstrated a sound commitment to incumbent industries, the environment, and minimizing impacts to the ocean environment. We believe they will continue this commitment throughout the project’s development and operation.

It’s time we move forward toward a new energy future focused on clean sources that provide the power we need as a society and minimize impacts on the natural environment and global climate.

Sincerely,

Wendy K. Northcross, CCE Chief Executive Officer

Cape Cod Chamber of Commerce, 5 Patti Page Way, Centerville, Cape Cod, Massachusetts 02632 1-888-33CapeCod (888-332-2732) or 508-362-3225

From: William Stark To: Patel, Purvi (EEA) Subject: Support for Vineyard Wind"s Draft Environmental Impact Statement Date: Thursday, January 24, 2019 11:26:38 AM

To the Office of Energy and Environmental Affairs,

After writing a research paper on the effectiveness of national renewable energy I have found that, one of the largest problems that United States faces today is the national ignorance of where energy comes from. Americans only care if their electricity works, not how it works, or where it comes from. Yet with the negative effects of greenhouse gas emissions becoming increasingly visible, the environmental community must get the general public informed of the energy crisis of today. The demand for power in the US will only increase, therefore we must be searching for a zero emissions power producer, to create a sustainable national power supply system. Offshore wind power has broken away as the most viable option. Massachusetts' Vineyard Wind, the first large scale offshore wind company in the US, is being extremely diligent in protecting the environment throughout the lifespan of their turbines. They oriented their wind farm so that migratory paths of birds are not affected. In addition, the underwater foundations of the turbines provide an artificial reef to local fish, and prized fishing grounds for recreational fisherman. Vineyard Wind’s 800 megawatt system will also annually reduce 1.6 million tons of carbon being released into our atmosphere. Not only does wind power have an extremely minimal effect on the environment, it is also able to be successful on a national scale, a feat no other renewable energy source can boast. Citizens of Massachusetts must support renewable energy such as offshore wind. We live in one of the best locations in the United States to produce wind energy, therefore it is irresponsible and inconsiderate to not support companies such as Vineyard Wind.

Thank you.

William Stark Old Rochester Regional High School From: William Lake To: Patel, Purvi (EEA) Subject: FEIR: Vineyard Wind Connector, EEA No. 15787 Date: Thursday, January 10, 2019 11:18:53 AM

Secretary Matthew A. Beaton Attn: MEPA Office, Purvi Patel Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA, 02114

RE: FEIR: Vineyard Wind Connector, EEA No. 15787

I am writing to support the approval of the Final Environmental Impact Report for the Vineyard Wind Connector.

The review processes for the Vineyard Wind project and its associated Connector have led to improvements in the original proposal, most notably the decisions to move the cable landing to Barnstable and to reduce the number of turbines. As the Federal Bureau of Ocean Energy Management has found, the project will have only negligible or minor negative impacts on the environment and local communities.

On the other side of the balance, the benefits of the project will be very great. As the first major offshore wind farm in the United States, Vineyard Wind will lead the development of an offshore wind industry for the northeastern United States, producing significant amounts of renewable energy that will help to wean the country from its reliance on energy sources that inject carbon into the atmosphere and contribute to global climate change. It will also help to establish southern New England as the focus of a new industry and supply chain that will greatly benefit the local economy.

As the project proponent has acknowledged, the Vineyard Connector will have temporary impacts, which will be confined to the construction period. Vineyard Wind has expressed its commitment to monitoring and minimizing those impacts. And a failure to approve the project would have far more devastating and long-lasting negative impacts on the region and the country, by perpetuating the reliance on fossil fuels to meet our growing energy needs. The benefits of the project far outweigh its possible temporary and localized disturbances.

Because the effects of climate change are increasingly recognized to be occurring faster than predicted -- and will be especially harmful to coastal areas -- time is of the essence. I hope that the Commonwealth will avoid any unnecessary delay in approving the project.

Sincerely, /signed/ William T. Lake Board Member, Vineyard Power Co-operative, Inc. Aquinnah, Massachusetts From: Zelda Gamson To: Patel, Purvi (EEA) Subject: Vineyard Power Date: Wednesday, January 09, 2019 2:46:32 PM

Dear Mr. Patel, As a longtime member of Vineyard Power, I am strongly in support of their wind power proposal and hope it will be approved soon. Sincerely, Zelda Gamson, PhD Professor Emerita University of Massachusetts Boston