KEEGAN WERLIN LLP
ATTORNEYS AT LAW 99 High Street, Suite 2900 BOSTON, MASSACHUSETTS 02110-3113 ——— (617) 951-1400 Catherine J. Keuthen E-mail: [email protected]
February 14, 2020
Donna Sharkey, Presiding Officer Energy Facilities Siting Board One South Station Boston, MA 02110
Re: NSTAR Electric Company d/b/a Eversource Energy, EFSB 19-03/D.P.U. 19-15
Dear Ms. Sharkey:
Enclosed please find an original and three copies of the Initial Brief of NSTAR Electric Company d/b/a Eversource Energy in the above-referenced matter. Also enclosed is a certificate of service.
Thank you for your attention to this matter.
Very truly yours,
Catherine Keuthen
Enclosures cc: Service List
COMMONWEALTH OF MASSACHUSETTS ENERGY FACILITIES SITING BOARD
) NSTAR Electric Company ) d/b/a Eversource Energy ) EFSB 19-03/D.P.U. 19-15 )
CERTIFICATE OF SERVICE
I hereby certify that, pursuant to 980 C.M.R. 1.03(4), I have on or before this day served a true copy of the enclosed documents, electronically, upon all parties of record in this proceeding.
Dated at Boston, Massachusetts this 14th day of February 2020.
Catherine J. Keuthen Keegan Werlin LLP 99 High Street Boston, MA 02110 (617) 951-1400
COMMONWEALTH OF MASSACHUSETTS ENERGY FACILITIES SITING BOARD DEPARTMENT OF PUBLIC UTILITIES
) Petition of NSTAR Electric Company d/b/a ) Eversource Energy Pursuant to G.L. c. 164, §§ 69J ) and 72 for Approval to Construct, Operate and ) EFSB 19-03/D.P.U. 19-15 Maintain a New 115-kV Underground ) Transmission Line Between the Existing Dewar ) Street and Andrew Square Substations in the ) City of Boston ) )
INITIAL BRIEF OF NSTAR ELECTRIC COMPANY d/b/a EVERSOURCE ENERGY
Respectfully Submitted,
By its attorneys:
Catherine J. Keuthen, Esq. Cheryl A. Blaine, Esq. Keegan Werlin LLP 99 High Street, Suite 2900 Boston, MA 02110 (617) 951-1400
Dated: February 14, 2020
TABLE OF CONTENTS
I. INTRODUCTION...... 1
II. PROCEDURAL HISTORY ...... 2
A. Public Notice, Public Comment Period and Intervention ...... 2 B. Evidentiary Hearing and Evidentiary Record ...... 4
III. PROJECT SUMMARY...... 4
A. The Project ...... 4 B. Project Route ...... 5 C. Substation Work...... 7 Andrew Square Substation ...... 7
Dewar Street Substation ...... 8
D. Construction Methodology for Underground Cable Installation ...... 9 E. Construction Schedule and Hours ...... 15 F. Outreach and Coordination Efforts ...... 17 Municipal Outreach ...... 17
2. Community Outreach ...... 18
3. Coordination with Other Planned Development ...... 19
G. Costs ...... 21
IV. THE PROJECT SATISFIES THE STANDARDS FOR SECTION 69J APPROVAL ...... 22
A. The Company Has Established That the Project Is Needed...... 22 Standard of Review ...... 22
The Project Is Needed to Maintain Reliability in the Project Area ...... 24
3. Conclusion on Need ...... 35
B. The Company Evaluated a Reasonable Range of Possible Project Alternatives in Determining That the Project Was Superior in Meeting the Identified Need...... 36 Standard of Review ...... 36
-i- Evaluation of Project Alternatives...... 36
C. The Company’s Route Selection Process Considered a Reasonable Range of Siting Alternatives and Resulted in a Project That Provides a Reliable Supply of Energy While Minimizing Environmental Impacts and Costs...... 46 Standard of Review ...... 46
Methodology...... 47
Identification of Study Area, Universe of Routes and Candidate Routes ...... 48
Environmental and Constructability Analysis of Candidate Routes ...... 50
Comparison of Routes ...... 53
Selection of Project and Noticed Alternative Routes ...... 57
Conclusion on Route Selection Process ...... 58
D. Comparison of the Preferred Route and the Noticed Alternative Route ...... 59 Standard of Review ...... 59
Environmental Impact Comparison of the Preferred Route, the Noticed Alternative Route and the Noticed Variation...... 61
Cost Comparison of the Preferred Route and Noticed Alternative Route...... 65
Reliability Comparison of the Preferred Route and the Noticed Alternative Route...... 66
Conclusion on Route Alternatives Comparison...... 67
E. The Company Has Appropriately Identified and Proposed Measures to Mitigate Environmental Impacts...... 68 Construction ...... 68
Land Use ...... 72
3. Parkland Impacts ...... 73
4. Traffic and Transportation Impacts ...... 74
5. Wetlands and Water Resources ...... 77
6. Public Shade Trees ...... 78
7. Use of Sulfur Hexafluoride ...... 79
-ii- 8. Subsurface Contamination...... 80
9. Safety and Health Considerations ...... 81
10. Visual Impacts ...... 81
11. Electric and Magnetic Fields ...... 83
12. Noise Impacts ...... 84
13. Historic and Cultural Resources ...... 88
14. Conclusion on Environmental Impacts ...... 88
F. The Project Is Consistent with the Current Health, Environmental Protection and Resource Use and Development Policies of the Commonwealth ...... 89 The Project Is Consistent with the Health Policies of the Commonwealth .... 89
The Project Is Consistent with the Environmental Protection Policies of the Commonwealth...... 90
The Project Is Consistent with the Resource Use and Development Policies of the Commonwealth ...... 92
Conclusion ...... 93
V. THE PROJECT SATISFIES THE STANDARDS FOR SECTION 72 APPROVAL ...... 93
VI. CONCLUSION ...... 95
-iii- I. INTRODUCTION
On March 1, 2019, NSTAR Electric Company d/b/a Eversource Energy (“Eversource” or the “Company”) filed petitions with the Energy Facilities Siting Board (the “Siting Board”) and the Department of Public Utilities (the “Department”) pursuant to G.L. c. 164, §§ 69J (“Siting
Board Petition”) and 72 (“Section 72 Petition”), respectively, for approval to construct, operate and maintain an approximately two-mile, 115-kilovolt (“kV”) underground electric transmission line (the “New Line”) between two existing Eversource substations, Andrew Square Station #106 located in South Boston (“Andrew Square Substation”) and Dewar Street Station #483 located in
Dorchester (“Dewar Street Substation”). The New Line and the related modifications at the
Andrew Square and Dewar Street Substations are referred to herein as the “Andrew Square to
Dewar Street Transmission Reliability Project” or the “Project.” The Section 72 Petition (docketed as D.P.U. 19-15) was referred to the Siting Board by the Department and consolidated with the
Siting Board Petition (docketed as EFSB 19-03) for review. NSTAR Electric Company d/b/a
Eversource Energy, EFSB 19-03/ D.P.U. 19-15, Referral and Consolidation Order (April 15,
2019). The Siting Board conducted a single adjudicatory proceeding and developed a single evidentiary record for the consolidated petitions.
The existing transmission lines that supply the Andrew Square and Dewar Street
Substations are part of the local transmission system that serves the Boston neighborhoods of
Dorchester, South Boston and Roxbury (the “Project Area”). The Project Area includes several critical customers, including hospitals and other medical facilities, schools, government agencies and departments, museums, large commercial customers and high-rise buildings. Currently, the local transmission system does not have adequate transmission resources available to reliably serve the area load under certain contingency conditions. Accordingly, the primary purpose of the
-1- Andrew Square to Dewar Street Transmission Reliability Project is to strengthen the local transmission system to support the load requirements in the Project Area. The Project will serve the public interest by maintaining reliable electric service to Eversource’s electric customers while minimizing cost and environmental impacts in accordance with G.L. c. 164, §§ 69J and 72. The
Project complies with all applicable standards of the Siting Board and the Department and, accordingly, the Company’s Siting Board and Section 72 Petitions should be approved.
II. PROCEDURAL HISTORY
A. Public Notice, Public Comment Period and Intervention
Contemporaneous with its March 1, 2019 filings with the Siting Board and the Department, the Company sent copies of the Siting Board and Section 72 Petitions to the City Clerk for the City of Boston (“Boston” or the “City”). Exh. EV-3.
On May 23, 2019, the Department issued a Notice of Adjudication and Notice of Public
Comment Hearing (the “Notice”) with a “Please Read” cover sheet. The Notice established the date of June 26, 2019 for a public comment hearing at Boston College High School and a deadline of July 11, 2019, for the filing of written comments and petitions to intervene or for limited- participant status in the proceeding. See Notice. In compliance with the Presiding Officer’s directives, the Company took the following actions:
(1) On June 5, 2019, the Company sent by first-class mail a copy of the Notice with the “Please Read” cover sheet (each provided in English, Spanish, Chinese and Vietnamese) to the
Boston City Clerk and requested that the Notice be posted until July 12, 2019 and that a copy of the Company’s Petition (which had been previously provided on March 1, 2019) be made available for public viewing during regular business hours until a final written decision has been issued in this proceeding. Exh. EV-3.
-2- (2) On June 5, 2019, the Company sent by first-class mail a copy of the Notice with the “Please Read” cover sheet (each provided in English, Spanish, Chinese and Vietnamese) to the
Boston City Planning and Development Agency and to the President of the Boston City Council.
Exh. EV-3.
(3) On June 5, 2019, the Company sent by overnight mail a copy of the Notice with the
“Please Read” cover sheet (both in English, Spanish, Chinese and Vietnamese) and a copy of the
Company’s Petition to the Boston Public Library (each provided to the South Boston Branch and the Uphams Corner Branch), with instructions to post the Notice until July 12, 2019 and to make the Petitions available for public viewing during regular business hours until a final written decision has been issued in this proceeding. Exh. EV-3.
(4) On June 11, 2019, the Company sent by first-class mail approximately 6,150 copies of the Notice with the “Please Read” cover sheet (each provided in English, Spanish, Chinese and
Vietnamese) to: (1) all persons owning real estate abutting the Andrew Square and Dewar Street
Substations and the proposed right-of-way (“ROW”) for the preferred and noticed alternative routes for the Project, owners of land directly opposite on any public or private street or way and abutters to the abutters within 300 feet of the edge of the ROW (“Abutters List”); and (2) all persons currently residing at the addresses on the Abutters List based on data from the City’s Live
Street Address Management Addresses database. Exh. EV-3.
(5) The Company caused the Notice to be published:
• On June 6, 2019 and June 13, 2019, in El Mundo in Spanish; • On June 11, 2019 and June 18, 2019, in The Boston Globe in English; • On June 11, 2019 and June 18, 2019, in The World Journal in Chinese; and • On June 11, 2019 and June 18, 2019, in Thang Long in Vietnamese.
Exh. EV-3.
-3- The Siting Board conducted the public comment hearing on June 26, 2019 at Boston
College High School. The Siting Board received timely-filed petitions to intervene from Mary
McCormack and Bill Brennan, both of whom are residents at locations abutting the route(s) of the
Project (referred to herein as “Intervenors”). The petitions were granted on September 3, 2019.
No requests for limited-participant status were filed.
B. Evidentiary Hearing and Evidentiary Record
The Siting Board held five days of evidentiary hearings on December 3, 5, 10, 12 and 13,
2019. The Company presented a total of 11 witnesses for cross examination:
(1) Jamil Abdullah, Lead Engineer for Transmission, Eversource (2) Nicole Bowden, Project Outreach Specialist, Eversource (3) John Zicko, Director of Substation Design Engineering, Eversource (4) Tracy Adamski, Vice President, Tighe & Bond (5) Nathan Dennis, Project Manager, EN Engineering (6) Erin Engstrom, Senior Community Relations Specialist, Eversource (7) Theresa Feuersanger, Supervisor of Rights and Survey, Eversource (8) Michael Zylich, Senior Environmental Engineer, Eversource (9) Robert Andrew, Director of System Solutions, Eversource (10) John McLaughlin, Senior Planning Engineer, Eversource (11) Christopher Soderman, Acting Director of Transmission Line Engineering, Eversource
The Intervenors did not submit written direct testimony or present witnesses.
Over 375 exhibits were entered into the evidentiary record, including the Company’s petitions, its responses to Information Requests and Record Requests, and hearing exhibits.
III. PROJECT SUMMARY
A. The Project
The Project would involve the construction of the New Line, a two-mile underground 115- kV line (solid dielectric cable) between the Andrew Square and Dewar Street Substations, with a
150 MVA summer normal rating, which will operate in conjunction with the two existing radial transmission lines from the Company’s K Street Substation #385 (“K Street Substation”) that
-4- currently supply the Andrew Square Substation and the two that currently supply the Dewar Street
Substation. Exhs. EV-1 at 1; EV-2 at 3-2. The Project also includes the modifications at the
Andrew Square and Dewar Street Substations needed to connect the New Line with the existing transmission system. Id. Approximately two miles of duct bank will be installed to support: (1) four eight-inch conduits; (2) two four-inch and two two-inch communication conduits; (3) eight cable splice vaults (manholes); and (4) eight communication hand-holes. Exh. EV-2, at 3-2. The cable size will be 3,500 kcmil, which will support the firm capacity of both Andrew Square
Substation (134 MVA) and Dewar Street Substation (150 MVA). Id.; Figure 3-2.
B. Project Route
The total length of the Project route is 10,454 feet (approximately two miles). Exh. EV-2, at 5-1. The route exits Andrew Square Substation east on Ellery Street, turns south on Boston
Street and east on Father Songin Way, continues on O’Connor Way, and then turns east onto Kemp
Street, then south on O’Callaghan Way until the intersection of Old Colony Avenue. Id. The route continues south on Old Colony Avenue and then Morrissey Boulevard after Kosciuszko Circle, at which point it turns southwest onto Old Colony Terrace, then south onto Savin Hill Avenue and down Grampian Way. The route then turns south on Playstead Road, west on Springdale Street, under I-93 and the Massachusetts Bay Transit Authority (“MBTA”) tracks, and into Dewar Street
Substation. The route will follow Old Colony Avenue to avoid crossing the Kosciuszko Circle with open trench construction. Exh. LU-1(1); Tr. 5, at 179-180.
The Project route crosses Pattens Cove/Savin Hill Cove and is in the vicinity of several major conservation areas, including the Old Harbor Reservation Parkways. Exh. EV-2, at 5-1.
Existing road widths range from 15 feet (Playstead Road) to 60 feet (Columbia Road), with a medium existing utility density. Id. There are five MBTA bus stops and an MBTA Station along
-5- the route. Id. The Project route requires high impact crossings at Columbia Road/Morrissey
Boulevard and at I-93 and the MBTA railroad tracks.1 Id.
The crossing of I-93 and the MBTA railroad tracks is proposed to occur near Springdale
Street, which is a paper street. Exh. EV-2, at 4-25, 5-1. This crossing is of an eight-lane highway with a raised median and an MBTA commuter railroad with four tracks and gravel embankment.
Id. The proposed crossing will be installed using a trenchless methodology. Exh. EV-2 at 5-1.
The location proposed for this crossing is at a location where the Boston Water and Sewer
Commission (“BWSC”) successfully pipe jacked a 60-inch conduit. Id.; Exh. EFSB-RR-9.
The predominant adjacent land use is residential, with some commercial and industrial, one school, one place of worship and four parks and recreation facilities. Exh. EV-2, at 5-
1. The Mary Ellen McCormack Housing Community, a large public housing development near the Project route, is proposed for redevelopment (“McCormack Redevelopment”) and the residents will be relocated out of the area during the redevelopment’s phased construction process. Id. The
Company has coordinated with the Boston Housing Authority (“BHA”) and Winn Development
Company (“Winn”) (the company selected by the BHA to construct the McCormack
Redevelopment) regarding Project design and, to the extent possible, the Company plans to coordinate construction of the Project with the timing of this activity to minimize construction- related impacts to the residents. Id.; Tr. 1, at 45, 50; Tr. 2, at 198-202. Wetland and water resources in the vicinity of the Project route include floodplain, the Patten’s Cove area and Chapter
91 tidelands. Exh. EV-2, at 5-2 and 5-27. Work within these resource areas is within developed and previously disturbed areas. Id.
1 High impact crossings are crossings of more significant transportation corridors (under a bridge, railroad or highway) where, because of the amount of traffic and traffic patterns, greater consideration of alternative construction methods, such as horizontal directional drilling, is required. Exh. EV-2, at 4-15.
-6- C. Substation Work
Andrew Square Substation
Eversource’s Andrew Square Substation is located on Ellery Street at Southampton Street in South Boston, on 2.02 acres of property owned by Eversource. Exh. EV-2, at 5-4. The station abuts MBTA tracks to the west and south, Southampton Street to the north, and Boston
Street, commercial, and multi-family residential uses to the east. Id. Route I-93 and I-93 Frontage
Road are located on the far side of the tracks from Andrew Square Substation, and MBTA Andrew
Station (subway and busway) is located across the Southampton Street and Ellery Street intersection. Id. Property uses near Andrew Square Substation are a mix of commercial and multi- family residential uses. Id. The proposed equipment improvements to Andrew Square Substation will be installed along the north and south sides of the Substation, within the existing fence line.2
Exh. EV-2, at 5-4.
The following equipment will be installed at the existing Andrew Square Substation to accommodate the New Line:
• A hybrid air-insulated switchgear/gas insulated switchgear (“AIS/GIS”) module (including two 115-kV breakers, two source terminals, a common load terminal, and all associated switches, arresters, instrument transformers, interconnecting bus between each of the existing 115-kV Lines 106-526 and 106-527 to the new hybrid AIS/GIS); and
• Relay and control panels in an existing control house.3
2 The transmission line will enter and exit the Andrew Square Substation on the northern side of the Substation property because the number of underground obstructions inside the Substation fence would make routing the cable through the station difficult and because the intersection of Boston Street and Ellery Street is also heavily congested with underground utilities. Exhs. EFSB-G-13; EFSB-G-14. 3 The Company plans to replace the existing control houses at both the Andrew Square and Dewar Street Substations to modernize the control and protection associated with these substations. Construction of the foundations for the new control houses is planned to start in the first quarter of 2021 and the new control houses are expected to be in service by the time the Project is constructed. Exhs. EFSB-G-6; EFSB-G-7. The need for the control and relay upgrades is separate and distinct from the need for the Project and the upgrades are required absent the Project. Id.
-7- Exhs. EV-2, at 3-4 and Figures 3-3 and 3-4; EV-2, at 5-4. No fence line expansion or removal of existing equipment is required to accommodate the necessary Project improvements. Id. There will be no changes to land use resulting from the work at Andrew Square Substation as all work will be performed within the existing substation property. Id.
Dewar Street Substation
Eversource’s Dewar Street Substation is located at the end of Dewar Street approximately
180 feet past Auckland Street in Dorchester, Boston, on 4.36 acres of property owned by
Eversource. Exh. EV-2, at 5-6. The station abuts MBTA tracks to the east, the Boston Public
Schools Welcome Center, a school bus parking area, and maintenance areas to the west and south, and Dewar Street to the north. Id. Route I-93 is located on the far side of the MBTA tracks from
Dewar Street Substation, and an industrial property is located on the opposite side of Dewar Street.
Id. Property uses in the vicinity of Dewar Street Substation are primarily industrial and commercial, with one apartment building on Auckland Street. Id. Potentially sensitive abutters to
Dewar Street Substation are few because the area is largely industrial except for the residents of the nearby Savin Hill Apartments. Id.
To interconnect the New Line, the Company will install the following at Dewar Street
Station:
• a hybrid AIS/GIS module on an elevated platform (including two 115-kV breakers in series, two source terminals, a common load terminal and all associated switches, arresters and instrument transformers, and interconnecting bus between each of the existing 115-kV Lines 483-524 and 483-525 to the new hybrid AIS/GIS module);
• relay and control panels in an existing control house; and
• a 100-foot shielding mast.
-8- Exh. EV-2, at 3-4, 5-6 and 5-7. No fence line expansion or removal of existing equipment is required to accommodate these necessary Project improvements. Id. at 5-7. The proposed equipment improvements to the Substation will be installed along the east side of the Substation, within the existing fence line. Id.
Work at the Andrew Square and Dewar Street Substations to interconnect the New Line will take place intermittently over an approximately 20-month period. Exh. EV-2, at 5-4 and 5-6.
Construction activities will include site preparation and the installation of new electrical equipment, support structures and foundations. Id.
D. Construction Methodology for Underground Cable Installation
The proposed underground cable will consist of 3,500 kcmil cross-linked polyethylene- insulated cable in high density polyethylene (“HDPE”) conduits. Exh. EV-2, at 5-8. The duct bank will consist of four 8 and 5/8-inch-diameter HDPE conduits, as well as two 4-inch-diameter polyvinyl chloride (“PVC”) conduits, and two 2-inch-diameter PVC conduits to carry communications lines and a ground continuity conductor. Id. at 5-9. The duct bank will be encased in a thermal concrete envelope. Id. The four principal phases of construction for an underground cable project within streets are: (1) manhole/splice chamber installation; (2) trenching and duct bank installation; (3) cable pulling, splicing and testing; and (4) final pavement restoration. Id.
Installation of the underground transmission line will generally require a linear work zone along the construction corridor. Exh. EV-2, at 5-9. It is anticipated that areas where typical open trench excavation will occur will require an approximately 11-foot wide workspace and that deep excavation at some dense utility intersections (as determined during the detailed design phase) may require an approximately 18-foot wide work area. Id. Manhole and splice vault installations typically require an approximately 20-foot wide work area. Id.
-9- Each trench segment will be 100 to 200 feet in length. Exh. EV-2, at 5-9. Trench construction is generally a linear progression, with tasks occurring concurrently or in progressive sequence. Approximate durations for activities anticipated to occur within each trench segment are: (1) survey, one day; (2) pavement cutting, one day; (3) pavement removal, one to two days;
(4) excavation, one to three days; (5) conduit installation, one to three days; (6) concrete installation, three to five days; (7) back fill and repaving, two to three days. Exh. EFSB-CM-4.
Based on these estimates, construction is estimated to be between 10 and 18 days for each segment.
Id. All phases of construction will not necessarily be completed in one segment prior to advancing to another segment. Exhs. EV-2, at 5-9; EFSB-CM-4; EFSB-CM-5. There may be cases where work on an unfinished segment may be temporarily halted due to unforeseen conditions or to catch up in other areas, and work would proceed in other segments. Id. Installation of manholes generally takes seven to ten days beyond that anticipated for trench excavation, duct bank installation, and pavement patching, and additionally approximately four days at each manhole to pull cable and five days to splice the cables. Exhs. EV-2, at 5-12; EFSB-CM-3; RR-EFSB-20.
The Company has estimated the number of work crews needed to meet the above estimates, although the actual number of crews and workers that will be required could change based on
Project-specific considerations such as allowable work zone size, hours of construction, time of day and construction zone access. Exh. EFSB-CM-1. Moreover, the actual number of work crews allowed with be determined in consultation with the City during the process for the issuance of grants of location. Id.
The Company is developing traffic management plans (“TMPs”) that will detail how access will be maintained to abutting residential, commercial and industrial properties during construction, both during working and non-working hours. Exh. EFSB-CM-7. Prior to finalization
-10- of TMPs, the Company will meet with City officials and abutters to understand their access requirements and modify plans, as necessary. Id. During and after work hours, the Company will take appropriate measures to allow safe and unencumbered access to abutting residential, commercial and industrial properties. Id. As needed, road plates will be placed over any excavations to allow unencumbered access to abutting residential, commercial and industrial properties. Id.
1. Manhole/Splice Chamber Installation
Manholes will be installed along the underground cable route to facilitate cable installation and splicing and allow access for maintenance requirements and future repairs. Exh. EV-2, at 5-
10 and 5-12. Each manhole will be approximately 10 feet wide by 12 feet high and 32 feet long and will be spaced approximately 1,500 to 1,800 feet apart. Exh. EV-2, at 5-10. Factors contributing to final placement of the manholes include allowable pulling tensions, consideration of sidewall pressure on the cables as they are pulled around a bend, and the maximum length of a cable that can be transported on a reel based on the reel’s width, height and weight, and accessibility. Id. The duration of construction typically is seven to ten days per location but may take longer if underground utility relocation is necessary. Id. Additional time is required for pulling cable (approximately four days) and splicing cable (approximately five days). Id. Once in operation, manholes will be inspected on a routine basis, normally every three years. Operators inspect the condition of cable joint(s), the cable support brackets, the link box connections, and integrity of concrete walls, as well as the junction of conduits as they enter and leave the manhole.
Id. The manhole cover is also inspected to determine whether it is stable and flush with the road surface. Id.
-11- 2. Trenching and Duct Bank Installation
The underground duct bank will be constructed using open-cut trenching. Exh. EV-2, at
5-12. The width of the trench will be marked on the street, Dig Safe will be contacted, and the location of the existing utilities will be marked. Id. The pavement will be saw cut and the existing pavement will be removed by pneumatic hammers and loaded into a dump truck with a backhoe.
Id. Pavement will be handled separately from soil and will be recycled at an asphalt batching plant. Id. A backhoe will excavate the trench to the required depth though, in some areas, excavation may be done by hand to avoid disturbing existing utility lines and/or service connections. Id. It is the Company’s standard installation practice to maintain a minimum of 18 inches of separation (both vertical and horizontal) from abutting utilities. Exh. EFSB-CM-27. In addition, the Company will maintain agreed-upon separation from other utilities to minimize the need to add protective devices. Id.; Exh. RR-EFSB-4. Where required, wood sheeting or temporary mechanical supports, such as strapping, will be employed during construction, particularly when the proposed duct bank is placed under other existing utilities. Id. All such supports will be designed and installed in coordination with the existing utility owner. Id.
The Company anticipates removing up to three truckloads of soil per day per crew. Exh.
EFSB-CM-16. Soil will be loaded directly into a dump truck for temporary off-site stockpiling or hauling to an off-site facility for recycling, re-use or disposal. Exh. EV-2, at 5-13. The soil will not be stockpiled along the edge of the roadway, thus reducing the size of the required work area and reducing the potential for sedimentation and nuisance dust. Id.; Exh. EFSB-CM-16. Rock encountered during excavation will be removed by mechanical means and brought to an off-site facility for recycling, re-use or disposal. Id. Once excavated, the trench will be sheeted and/or shored as required by soil conditions, Occupational Safety and Health Administration (“OSHA”) safety rules, and local and state regulations. Id. Shoring is designed to permit passage of traffic
-12- adjacent to the trench and will allow for the trench to be covered with a steel plate to allow traffic over the trench during non-working hours. Id.
Because intersections have the greatest concentration of underground utilities, the street intersection is excavated in advance so obstructions can be identified, and the HDPE conduit locations can be determined before the main trenching work crew reaches the intersection. Exh.
EV-2, at 5-13. The Company’s goal is to find a slot for the duct bank that maximizes separation from existing utilities and minimizes the number of utility crossings. Exh. RR-EFSB-4. When designing underground transmission line projects, the Company works with the appropriate agencies to determine the location of the duct bank, taking into consideration that moving the
Company’s duct bank further away from certain existing utilities may move it closer to others. Id.
The Company also uses utility record data and field surveys to identify areas of increased utility density and where trench depths could be deeper than a typical trench. Exhs. EV-2, at 5-16; EFSB-
CM-5. The Company will conduct a subsurface investigation to verify survey data and identify unknown obstructions. Exhs. EV-2, at 5-16; EFSB-CM-5. Construction may be slower than estimated due to utility density, obstructions or trench depth, and temporary or permanent relocation of existing utilities. Id.
Once the open trench is prepared, the conduits will be assembled and lowered into the trench. Exh. EV-2, at 5-13. The area around the conduits will be filled with thermal concrete
(3,000 pounds per square inch). Id. After the concrete is placed in the trench, it will be backfilled with fluidized thermal backfill or native soil, depending on local requirements, and a temporary pavement patch will be installed. Id. Upon Project completion, the road will be restored in accordance with the Department’s “Standards to be Employed by Public Utility Operators When
-13- Restoring and of the Streets, Lanes and Highways in Municipalities” (D.T.E. 98-22) as well as the
City’s paving standards. Id.; Exhs. EFSB-CM-6; EFSB-CM-15; EFSB-CM-19.
3. Cable Installation and Testing
Prior to cable installation, each conduit will be tested and cleaned. Exh. EV-2, at 5-14.
Three cables will be installed between two adjacent manholes where a cable reel will be set up at the “pull-in” manhole and a cable puller will be set up at the “pull-out” manhole. Id. A hydraulic cable pulling winch and tensioner will be used to individually pull cable from the pull-in to the pull-out manhole, which will be repeated until all cables have been installed. Id.
Once adjacent cable sections are installed, they will be spliced together inside the manholes. Exh. EV-2, at 5-14. Splicing typically requires 40 to 60 hours to complete at each manhole. Id. The splicing activities will take place over four or five extended workdays at each manhole location. Id. Cable splicing is a 12-hour/day activity completed by specialized contractors. Id. Extended workdays for cable splicing would entail multiple work shifts that would extend into evening hours and, in some cases, throughout the night (e.g., three shifts over 24 hours).
Id. The splicing operation requires a splicing van and a generator. An air conditioning unit may be used to control the moisture content in the manhole. Id. The portable generator will provide the electrical power for the splicing van and air conditioning unit and will be muffled to reduce noise. Id. Typically, the splicing van will be located over one manhole access, the air conditioner will be located near the second manhole access and the generator will be placed in a convenient area that does not restrict traffic movement around the work zone. Id.
Once the complete cable system is installed, it will be field-tested from the substations.
Exh. EV-2, at 5-14. At the completion of successful testing, the line will be energized. Id.
-14- 4. Trenchless Crossing
As noted above, the Project will require one trenchless crossing for approximately 230 feet, under interstate highway I-93 and the MBTA tracks in the vicinity of Springdale Street, west of the Dewar Street Substation. Exhs. EV-2, at 4-25; EFSB-LU-8. Although the crossing methodology has not been finally determined, the Company is confident that it will be able to successfully pipe jack in this area because the BWSC recently accomplished a similar pipe jack under I-93. Exhs. EV-2, at 4-25; 5-1; RR-EFSB-9; Tr. 2, at 184. Engineering design of the trenchless crossing will be advanced by acquiring geotechnical data (from soil borings and test pits) at the location of the crossing. Exh. EFSB-C-8. Data on the soils and water table will confirm whether jack and bore is the optimal trenchless crossing method. Id. The crossing is expected to take two weeks to complete and there are no residences within 100 feet of the exit point of the crossing and only one residence within 100 feet of the entry point. Exh. EFSB-LU-8.
5. Pavement Restoration
Following installation of the duct bank and splice chambers in public roadways, roadway surfaces will be restored to a condition as good as or better than the pre-construction condition, to meet the standards of the state agencies including the Department’s and the City’s repaving standards.4 Exhs. EV-2, at 5-14; EFSB-CM-15; EFSB-CM-19; EFSB-G-38; Tr. 1, at 80.
E. Construction Schedule and Hours
Construction of the Project is anticipated to occur over a 20-month period. Exh. EV-2, at
5-15. Construction hours will be developed in accordance with local noise ordinances, regulated construction hours and coordination with the Massachusetts Department of Conservation and
4 While the Company and the City have not solidified repaving plans for the Project, the Company will continue to discuss and coordinate the final repaving approach and plan with the City. Exhs. EFSB-CM-6; EFSB-CM-15; EFSB-CM-19. The City’s repaving requirements will be formalized during the Public Improvement Commission’s permitting process for grants of location. Exhs. EFSB-CM-19; EFSB-CM-24.
-15- Recreation (“DCR”) and the City; however, the Company proposes to work Monday through
Friday from 7:00 AM to 6:00 PM and on Saturdays only if necessary. Id. at 5-16; Tr. 2, at 222.
The City limits construction hours to 7:00 AM to 6:00 PM, Monday through Friday. Id. DCR may require alternative construction hours in non-residential areas. Id. The Company will coordinate with the City and DCR to seek approval when work outside of these hours is necessary.
Id. The Company will also coordinate with the City and the MBTA to determine areas where construction hours will be limited (e.g., in front of schools or the MBTA train station). Id.; Exh.
EFSB-RR-15; Tr. 2, at 234. In certain locations, night work may be proposed to allow advancement of Project construction in areas with traffic congestion or other construction projects being advanced simultaneously. Id.
In areas where manhole installations, cable splicing, and/or culvert crossings are not required, the Company expects that time spent performing construction activities in front of any single abutter’s property will be approximately three to four days. Exh. EV-2, at 5-15. The duration of time spent in front of a specific abutter’s property for manhole installation, cable-pulling and cable splicing will be approximately 16 to 20 days, broken out for each task as follows:
• 7 to 10 days to install manholes; • 4 days of pulling activity (two days in each pull direction); and • 5 days for splicing.
Id. The actual duration of these activities can vary based on a variety of factors, including existing utility conditions and below-grade conditions. Id.
The Company anticipates that it may not be permitted to work within public roads during the winter months due to the winter moratorium for in-street construction. Exh. EV-2, at 5-15;
Exh. EFSB-CM-2. However, some activities, such as splicing at manholes, cable installation, civil and electrical construction in the substations, relaying and control houses and testing may be
-16- allowed despite the moratorium. Id. The Company will request approval to work during the winter moratorium from the Boston Department of Public Works. Id.
F. Outreach and Coordination Efforts
Municipal Outreach
Consistent with the Company’s typical practice of consulting with municipal authorities at the outset of facility development, the Company initiated discussions with the City to introduce the Project in December of 2017. Exh. EV-2, at 1-5 and Table 1-1. Since then, the Company’s outreach efforts have been aimed at briefing local officials and other agency and neighborhood stakeholders on the need for the Project, consulting with numerous stakeholders on the route selection, detailing the overall Project schedule and explaining the permitting and siting processes, including opportunities for public input.5 Id.; Exh. EFSB-G-21.
The Company will continue these efforts during the siting and permitting process and will maintain a focused communications program throughout construction, including outreach to municipalities and local businesses along the route regarding construction staging and laydown plans and TMPs, as such details become available. Exh. EV-2, at 1-5; Exh. EFSB-G-22. This outreach program is designed to engage the community, foster public participation and solicit feedback from stakeholders. Id.
5 The Company does not require a permit from the Boston Planning and Development Agency (“BPDA”) for the Project, nor has it typically required permits from the BPDA for other transmission projects in the City, and the BPDA has not been routinely involved in the review of the Company’s transmission projects. Tr. 1, at 35-43. Accordingly, the BPDA was unaware of the extent to which the Company had coordinated with various City of Boston departments (such as the Public Improvement Commission, Boston Water and Sewer, Boston Public Work Department and Boston Parks and Recreation), the Massachusetts Department of Transportation, the MBTA, DCR, the BHA and Winn regarding route selection and other aspects of the Project when it submitted a letter to the EFSB regarding the Project. Exh. EFSB-G-40. The Company is now in regular communication with representatives of the BPDA to discuss the Project and representatives of the BPDA are now routinely participating in Project-related meetings with the Company and other City officials. Tr. 1, at 41; Exh. EV-18.
-17- 2. Community Outreach
The Company has also undertaken, and will continue to undertake, an extensive community outreach effort which may include, at the direction of the EFSB, translators and translation of key documents to facilitate the meaningful opportunity to participate by all. Exh.
EV-2, at 6-3. The Company held Open Houses in South Boston and Dorchester to provide information to the public about the Project and to provide an opportunity for the public to ask questions and share concerns. Exhs. EV-2, at 1-6; EFSB-RS-2. In preparation for the Open
Houses, invitations were sent to property owners within a quarter-mile of the Andrew Square and
Dewar Street Substations and 300 feet from the route of the New Line, door-to-door outreach was conducted and advertisements were placed in several local newspapers. Id. Eversource is committed to responding promptly to all inquiries and has established and publicized a Project hotline and email address so that the public can communicate directly with the Company. Id.;
Exh. EFSB-G-2. Going forward, Eversource will execute a comprehensive construction community outreach plan designed to make residents and businesses along the Project route aware of the Project schedule, scope of work and what to expect when work is taking place in their neighborhood. Exhs. EV-2, at 1-6; EFSB-CM-2; EFSB-NO-4; EFSB-T-3. The Company will hold additional Project Open Houses in the community at the start of construction for abutting property owners, local businesses and other stakeholders interested in learning more about the
Project and scope of work. Exh. EFSB-T-3. The Company will notify abutters of the start of construction and of each phase of planned construction activities. Exh. EFSB-T-3. The Company will also post weekly construction updates on the Project webpage. Exh. EFSB-T-3. Additionally, the Company will work with the local chamber of commerce, neighborhood services,
-18- neighborhood groups and local business groups to ensure that Project updates and information will be available throughout the Project’s duration.6 Exh. EV-2, at 1-7.
The Company plans to continue providing updates and communicating with the Mary Ellen
McCormack Tenant Task Force and the Andrew Square and Columbia/Savin Hill Civic
Associations regarding the Project. Tr. 1, at 57.
3. Coordination with Other Planned Development
The Company coordinated with several stakeholders, including the DCR, BHA/Winn, the
Massachusetts Department of Transportation (“MassDOT”), and the BWSC to receive input from those entities on their proposed projects and to coordinate design and in-street construction schedules with the Company’s Project. Exhs. EV-2, at 1-5; EFSB-RS-3; EFSB-T-4; EFSB-T-5;
Tr. 2, at 198-202.
DCR plans to upgrade the portion of Morrissey Boulevard between Neponset Circle and
Mt. Vernon Street near the JFK/UMass MBTA Station to raise parts of the roadway to address flooding issues, improve drainage, improve safety for all modes of transportation including pedestrians and cyclists, and improve access to abutting recreational properties. Exh. EFSB-CM-
9. Pursuant to information provided by DCR, the Company’s design plan for the Project incorporates the preliminary design plans for the reconstruction of Morrissey Boulevard. Exh.
EFSB-G-12. Although DCR has not finalized a schedule for its development plans, discussions
6 The Company has established a Project hot-line that can be contacted 24 hours a day and the Company can be emailed at [email protected] with Project-related concerns. Exh. EFSB-CM-10. A Project-specific website, which displays key Project information, has also been established and prominently displays all methods of contact. Id. A field outreach specialist will conduct door-to-door outreach alerting residents of the many ways of contact regarding the Project and all methods of communication in regard to the Project will be made available to City of Boston representatives to share with the community if contacted. Id. Also, if the City so chooses, weekly traffic updates can be placed on the City’s webpage under the “Stay Connected” section, which provides email updates from the City, including information on big events and upcoming traffic and parking restrictions. Id.
-19- and coordination with the Company are ongoing and will continue as both projects are advanced.
Exh. EFSB-G-12; Tr. 2, at 198-202.
The Company is also working to coordinate project design and in-street construction schedules with Winn regarding the McCormack Redevelopment. Exhs. EV-2, at 1-5; EFSB-CM-
8. Prior to filing its petition, the Company met with Winn to present the Company’s possible routes, received input and addressed questions. Id. The installation of the new distribution duct banks and manholes for the McCormack Redevelopment could be coordinated with the Project provided the schedules align and a new connection request agreement is in place. Exh. EFSB-G-
27. Although Winn has yet to solidify plans regarding the McCormack Redevelopment, the
Company continues to meet with the BHA and Winn to coordinate construction schedules, to the extent possible, and to receive and address any concerns regarding the Project. Id.; Exhs. EFSB-
CM-8; EFSB-G-8; EFSB-G-9; EFSB-G-10; EFSB-G-11; EFSB-G-26; EFSB-G-28; EFSB-G-31;
Tr. 1, at 48-49.
The Company has also met with, and plans to coordinate with, the Boston Department of
Public Works regarding the City’s planned road improvements along Old Colony Terrace,
Playstead Road and Grampian Way in the Savin Hill neighborhood and the Boston Parks and
Recreation Department on the planned McConnell Park Redevelopment. Id.; Exhs. EFSB-G-16;
EFSB-G-40; EFSB-CM-9; EFSB-CM-13. As Project development proceeds, the Company will continue to meet with various City departments, DCR and other utility infrastructure owners to provide updates on the Company's Project and review opportunities to coordinate any related projects. Id.; Exhs. EFSB-CM-14; EFSB-CM-25. Although the Company does not have finalized plans for coordinating construction of the Project with the other local projects at this time, the
Company will continue to investigate opportunities to do so, while being mindful of potential
-20- impacts on schedule and cost. Exh. EFSB-LU-19. The potential advantages of coordinating in- street civil construction efforts include:
• less impact to abutters and road users, including reduction in traffic impacts. • installation of multiple utility infrastructure elements such as electric transmission, electric distribution, cable, telephone, gas, sewer, water etc., in the same excavation, particularly in the McCormack Redevelopment area, would reduce overall impact to abutters. • adjacent projects could participate in cost-sharing activities, such as excavation and repaving roadways. • coordinating work schedules, particularly along Morrissey Boulevard, could shorten Project schedules and reduce effects on abutters and users of the roadway.
The Company has some flexibility in its construction schedule to accommodate moderate delays to coordinate with other projects and will do so, where appropriate, to realize the potential advantages of coordination listed above.7 Exhs. EFSB-LU-18; EFSB-LU-19; EFSB-RS-3; EFSB-
T-7; Tr. 1, at 55-56; Tr. 2, at 203-204. For each of the projects discussed above, while the timing of their construction may not align perfectly with the construction of the Project, the Company’s coordination with these agencies regarding Project design has provided both time and cost savings benefits. Tr. 2, at 199-200. The Company intends to continue Project communications in the form of meetings, standard mail, email and conference calls with state and municipal stakeholders to identify any overlap in construction with the Project and/or approval conditions that may occur.
Exh. EFSB-CM-25; Tr. 1, at 97.
G. Costs
The current cost estimate for the Project along the Preferred Route is approximately $68.3 million (2019 dollars), estimated at a planning grade level (-25%/+25%). Exhs. EV-2, at 1-5;
EFSB-C-6. This planning grade estimate consists of the following: (i) underground transmission
7 Nevertheless, if there were a long-term delay with the progress of another project, the Company may need to proceed with construction of the Project given the immediate reliability need for the Project. Tr. 2, at 203-204.
-21- line, $52 million; (ii) Andrew Square Substation work, $9.7 million; and (iii) Dewar Street
Substation work, $6.6 million. Exh. EFSB-C-6. The Company anticipates that, because the proposed Project costs are 100% non-PTF, 98% of the costs will be recovered from NSTAR East retail customers and 2% from other wholesale customers. As a result, no Project costs are expected to be recovered in regional transmission rates.8 Exh. EFSB-C-7.
IV. THE PROJECT SATISFIES THE STANDARDS FOR SECTION 69J APPROVAL
A. The Company Has Established That the Project Is Needed.
Standard of Review
G.L. c. 164, § 69J provides that the Siting Board should approve a petition to construct if the Board determines that the petition meets certain requirements, including that the applicant’s proposed facilities are consistent with the policies stated in G.L. c. 164, § 69H to provide a reliable energy supply for the Commonwealth with a minimum impact on the environment at the least possible cost. In carrying out its statutory mandate, the Siting Board must find that additional energy resources are needed as a prerequisite to approving a proposed energy facility. NSTAR
Electric Company d/b/a Eversource Energy, EFSB 17-02/D.P.U. 17-82/17-83, at 13-14 (2019)
(“Eversource Sudbury”); NSTAR Electric Company d/b/a Eversource Energy, EFSB 14-
04/D.P.U. 14-153/14-154, at 8 (2017) (“Eversource Mystic-East Eagle”); NSTAR Electric
Company d/b/a Eversource Energy, EFSB 14-02/D.P.U. 14-73/14-74, at 6 (2017) (“Eversource
Walpole-Holbrook”); NSTAR Electric Company d/b/a Eversource Energy, EFSB 15-03/D.P.U.
15-64/15-65, at 6 (2017) (“Eversource Mystic-Woburn”).
8 Based on lessons learned from other recent transmission projects, the Company’s cost estimating practices have continued to evolve, giving it greater confidence in the level of accuracy. Exhs. RR-EFSB-5; RR-EFSB-7. For example, the Company now performs a unique risk assessment for each project, identifying potential risks, the likelihood of occurrence and the financial impact. Id.
-22- The Siting Board evaluates whether there is a need for additional energy resources to meet:
(1) reliability objectives; (2) economic efficiency objectives; or (3) environmental objectives.
Eversource Sudbury at 15; Eversource Mystic-East Eagle at 8; Eversource Walpole-Holbrook at
7; Eversource Mystic-Woburn at 6. Accordingly, the need for a facility can be demonstrated by showing need on any (or all) of those three bases. ECC Remand, 1 DOMSB 213, EFSB 90-100R at 180-81, n.264 (1993); Eversource Mystic-East Eagle at 8; Eversource Walpole-Holbrook at 7;
Eversource Mystic-Woburn at 6.
To ensure reliability, each transmission and distribution company establishes planning criteria for construction, operation, and maintenance of its transmission and distribution system.
Compliance with the applicable planning criteria demonstrates a “reliable” system. Eversource
Sudbury at 15; Eversource Mystic-East Eagle at 8-9; Eversource Walpole-Holbrook at 7;
Eversource Mystic-Woburn at 6-7.
To determine whether system improvements are needed, the Siting Board: (1) examines the reasonableness of the applicant’s system reliability planning criteria; (2) assesses whether reviewable and appropriate methods for assessing system reliability over time are used based on system modeling analyses or other valid reliability indicators; (3) determines whether the relevant transmission and distribution system meets these reliability criteria over time under normal conditions and under reasonable contingencies, given existing and projected loads; and
(4) evaluates whether acceleration of conservation and load management programs, and pursuant to Chapter 249 of the Acts of 2004, the use of other alternatives to the facility, including other methods of transmitting or storing energy, might eliminate or slow the need for such additional
-23- energy resources.9 Eversource Sudbury at 15; Eversource Mystic-East Eagle at 9; Eversource
Walpole-Holbrook at 7; Eversource Mystic-Woburn at 7.
When a petitioner’s analysis of system reliability and facility requirements is driven, at least in part, by load projections, the Siting Board reviews the underlying load forecast. Eversource
Sudbury at 15; Eversource Mystic-East Eagle at 9; Eversource Walpole-Holbrook at 7-8;
Eversource Mystic-Woburn at 7. The Siting Board requires that forecasts be based on substantially accurate historical information and reasonable statistical projection methods that include an adequate consideration of conservation and load management. G.L. c. 164, § 69J; Eversource
Sudbury at 15; Eversource Mystic-East Eagle at 9; Eversource Walpole-Holbrook at 8; Eversource
Mystic-Woburn at 7. To ensure that this standard has been met, the Siting Board requires that forecasts be reviewable, appropriate and reliable. Id. A forecast is reviewable if it contains enough information to allow a full understanding of the forecast method; a forecast is appropriate if the method used to produce the forecast is technically suitable to the size and nature of the company to which it applies; and a forecast is considered reliable if its data, assumptions and judgments provide a measure of confidence in what is most likely to occur. Id.
As demonstrated throughout this proceeding, the Project satisfies the Siting Board’s standards and relevant precedent for jurisdictional facilities.
The Project Is Needed to Maintain Reliability in the Project Area
Two pairs of Company-owned and operated, radial 115-kV transmission lines supply the
Company’s Andrew Square Substation (Lines 106-526 and 106-527) and Dewar Street Substation
9 Pursuant to Chapter 249 of the Acts of 2004, applicants proposing a new transmission line are required to provide “(3) a description of alternatives to the facility, such as other methods of transmitting or storing energy . . . or a reduction of requirements through load management.” In addition, applicants are required to demonstrate that “projections of the demand for electric power. . . include an adequate consideration of conservation and load management.” G.L. c. 164, § 69J.
-24- (Lines 483-524 and 483-525) from the Company’s K Street Substation. Exh. EV-2, at 2-1, 2-2.
These radial lines are the sole transmission source serving a large number of customers
(approximately 58,000 customers supplied from Dewar Street Substation and over 34,000 customers supplied from Andrew Square Substation) in the Project Area, which includes a number of critical customers including a dozen hospitals and other medical facilities, schools, including the University of Massachusetts Boston and Roxbury Community College; government agencies and departments (including the Suffolk County House of Corrections and the Boston Police
Department headquarters); institutions such as the JFK Library and the Franklin Park Zoo; large commercial customers such as South Bay Mall and Ink Block; and hotels and high rise buildings with significant elevator loads. Exhs. EV-2, at 2-1 to 2-3; EFSB-N-19; EFSB-N-32. Based on this unique customer mix in the densely and highly populated urban center of Boston, a prolonged outage would have serious public health and safety consequences. Exh. EFSB-N-32. To maintain the integrity of the power system that serves customers in this area, the Company must ensure that adequate transmission resources are available to reliably serve the area load under certain contingency operating conditions. Exh. EV-2, at 2-2.
Andrew Square Substation supplies over 34,000 customers in portions of South Boston, the South End and Roxbury and has four 115/14-kV step-down transformers (Transformers 110A,
110B, 110C and 110D), with a total capacity of 178 MVA, and four sections of 14-kV switchgear.
Exh. EV-2, at 2-2. None of the transformers has any overload/long-time emergency capability.
Exh. EV-2, at 2-2. Upon the loss of any of the transformers, a 14-kV Automatic Bus Restoral
(“ABR”) system will close the tie breakers automatically so that all the load at Andrew Square will be supplied via the remaining three in-service transformers. Exh. EV-2, at 2-2. Andrew
-25- Square Substation’s firm capacity, based on the loss of one transformer, is 133.5 MVA. Exh. EV-
2, at 2-2.
Dewar Street Substation supplies approximately 58,000 customers in Dorchester and portions of Jamaica Plain and Roxbury. Exh. EV-2, at 2-3. Dewar Street Substation has two
115/14-kV step-down transformers (Transformers 110A and 110B), with a total capacity of 280
MVA, and four sections of 14-kV switchgear. Exh. EV-2, at 2-3. Upon the loss of either transformer, a 14-kV ABR system will close the bus tie breakers automatically so that all the load at Dewar Street will be supplied via the remaining in-service transformer. Exh. EV-2, at 2-3.
Dewar Street Substation’s firm capacity based on the loss of one transformer is 150 MVA. Exh.
EV-2, at 2-3.
The Company’s transmission system as a whole is an integral part of delivering electricity to customers in New England. The K Street to Andrew Square 115-kV Lines 106-526 and 106-
527 and the K Street to Dewar 115-kV Lines 483-524 and 483-525 are radial transmission lines and, therefore, are considered part of the local transmission system, rather than the regional transmission system. Exh. EV-2, at 2-2, 2-3. Regional transmission lines are classified as: (1) pool transmission facilities (“PTF”) by the Independent System Operator of New England (“ISO-NE”);
(2) part of the Bulk Electric System (“BES”) governed by North American Electric Reliability
Corporation (“NERC”); and, in some cases, (3) part of the Bulk Power System (“BPS”) by
Northeast Power Coordinating Council Inc. (“NPCC”). While regional transmission lines within the regional power system in New England are planned and operated in accordance with ISO-NE,
NERC and NPCC criteria, the four existing lines and the New Line, as well as the Andrew Square and Dewar Street Substations, are classified as non-PTF elements given the radial arrangement of
-26- the supply to the load and they are not part of the BES.10 Exhs. EV-2, at 2-3; EFSB-N-4. As such, the transmission lines serving the Project Area do not fall under ISO-NE or NERC criteria. Exh.
EFSB-N-4. Therefore, the need for the Project was determined by the Company in accordance with its own planning standards for local transmission facilities.
The Company strives to serve all its customers reliably and consistently by designing and constructing its non-PTF facilities (including the transmission lines and substations in the Project
Area) to comport with NERC, NPCC, and ISO-NE regional criteria and to ensure that adequate transmission resources are available to serve forecasted load to all customers under various conditions and contingencies. Exh. EV-2, at 2-3; Tr. 4, at 469. If non-PTF transmission facilities are unable to reliably serve load, the Company plans and implements system additions and upgrades to address the identified inadequacies. Exh. EV-2, at 2-4. The Company evaluates its transmission system to determine whether it has sufficient capability to serve the forecasted load under normal conditions (all facilities in-service), and under specified contingencies where one
(N-1) or multiple (N-1-1) lines are out of service. Exh. EV-2, at 2-4.
a. The Company’s Consequential Load Loss Guideline Triggers Review of the Project Area
The Company conducts transmission system planning assessments of consequential load loss (“CLL”) and develops solutions for the Eversource transmission system in accordance with its own planning criteria set forth in a document entitled “Consequential Load Loss Guideline”
(hereinafter referred to as “SYS PLAN-015”).11 Exh. EV-2, Appendix 2-1. The impetus for the
10 K Street, Andrew Square, and Dewar Street Substations are classified as BPS stations and the transmission lines serving the Project Area do fall under NPCC criteria. 11 Consequential load loss refers to the load that is no longer served by the transmission system as a result of transmission facilities being removed from service by the operation of a protection system designed to isolate the fault. Exh. EV-2, at 2-4. Consequential load loss is the load that is lost when there is a fault on a line and the load is disconnected and deenergized as a result of the operation of the protection system. Tr. 4, at 349.
-27- development of SYS PLAN-015 was to consider and evaluate the outage impacts of contingencies to local customers served from the transmission system that are not addressed in other regional planning standards.12 Exh. EFSB-N-16.
SYS PLAN-015 is intended to complement regional standards by also determining the outage event impact to local customers that are served by transmission facilities. Exh. EFSB-N-
16. Under SYS PLAN-015, where there are two radial underground transmission lines, the
Company’s review is triggered when it identifies greater than 50 MW of consequential customer load loss in the event of an N-1-1 contingency. Exh. EV-2, at 2-4, Appendix 2-1, at 1, 3. Prior experience with the loss of transmission facilities in the City of Boston, including a long outage on one of the lines between K Street and Dewar Street Substations and a fire at the Company’s
Scotia Street Substation, prompted Eversource’s concern for the potential for extended (multiple days or weeks in length) outages affecting a large number of customers and led to the determination
12 The 50 megawatt (“MW”) criterion covers the areas of the Eversource system with higher load and population densities (and, therefore, higher impact) and was developed to be a reasonable and appropriate threshold for evaluating the scope and consequences of loss of load in an urban area served by underground facilities. Exh. EFSB-N-34(R1). Although ISO-NE also has a Load Interruption Guideline, the need for the Project is associated with the Eversource local transmission system that falls outside the scope of the ISO-NE guidelines and differs from SYS PLAN-015 in its intent and application. Exh. EFSB-N-17; Tr. 4, at 350. The ISO-NE guideline applies only to PTF and intends to identify acceptable thresholds from a broader transmission grid impact perspective. Exh. EFSB-N-17. It establishes a financial criterion with respect to transmission facilities being recovered in regional rates versus local rates while SYS PLAN-015 is focused on reliability of service. Tr. 4, at 470. The SYS PLAN-015 guideline, which considers the resulting impacts of an event to local customer load, is applicable to local transmission facilities owned by Eversource that are not evaluated for load interruption in the ISO-NE regional planning processes. Id. The major differences between the guidelines are that the ISO-NE guideline does not consider the time duration of the outage and the Eversource CLL criteria specifically addresses underground cables because the duration to locate faults and repair a cable is typically longer than for an overhead circuit. Exh. EFSB-N-23; Tr. 4, at 352. As using the ISO-NE criteria exposed large blocks of customers, particularly those served from substations supplied by underground cables, to sustained outages under certain contingencies, the Company determined that the exposure to the loss of underground cable supply required a distinctly separate criteria for such installations. Exh. EFSB-N-36.
-28- that exposure to the loss of underground cable supply required a priority review.13 Exhs. EFSB-
N-34(R1); EFSB-N-37; Tr. 4, at 467, 526-528.
SYS PLAN-015 provides that when the amount of load that would be interrupted exceeds the 50 MW CLL threshold, measures should be evaluated that would mitigate or eliminate the duration and/or impact of such events. Exh. EV-2, Appendix 2-1, at 3. The Company will then identify solutions that would ensure the entire identified loss of load is either avoided by a solution, a contingency plan, or a combination thereof. Exhs. EFSB-N-25; EFSB-N-26; Tr. 4, at 488-489.
Initially, the Company evaluates whether upgrades can be designed that would address the CLL trigger without the need for new transmission facilities. Exhs. EFSB-N-29; EV-2, Appendix 2-1, at 3. Whenever practical, the Company considers the capability of load transfers within the distribution network to reduce or eliminate the consequential load loss, while ensuring that the remaining elements of the system must continue to operate reliably within their normal ratings.
Exh. EV-2, at 2-4. However, when the amount of load interrupted results in a consequential load loss in the affected area and load transfer capability within the distribution network is insufficient or does not exist, the Company assesses the outage impacts, and evaluates the cost, and feasibility
13 In 2012, a fire at the Company’s Scotia Street Substation caused the simultaneous outage of two underground transmission facilities that supply both Eversource Scotia Street and Carver Street Substations in downtown Boston. Exh. EFSB-N-34(R1); Tr. 4 at 359. The outage of the two underground transmission lines caused the loss of power to more than 20,000 customers for varying periods of up to five days. Exh. EFSB-N-34(R1). The affected area involved significant commercial and residential loads and high-rise buildings and the loss of power presented significant safety challenges for the people living and working in the area. Id. Fire damage at Scotia Street affected the transformers and it was several days before one unit could be returned to service. Id. In the interim time period, the Company deployed approximately 25, 2-W mobile generators and used “street jumpers” to pick up as much load as possible from the Carver Street Substation, which involved digging open trenches in streets, laying in 14-kV distribution cables and covering the trench with steel plates. Id.; Tr. 4, at 359. Personnel had to be stationed around the clock nearby to guide the public around the installation. EFSB-N-34(R1). The Company could not use a portable transformer because there wasn’t sufficient physical space on which to locate it. Tr. 4, at 361. The Scotia Street event demonstrated that prolonged outages of essential utilities has an unacceptable impact on customers, causing many services to high rise, large buildings, hospitals and businesses to be significantly disrupted. Exh. EFSB-N-34(R1); Tr. 5, at 617-622. The extremely disruptive impacts to the public and the resulting environmental impacts (noise, traffic, emissions) from this incident informed the Company’s guideline to completely, not partially, restore load when two underground lines are lost. Tr. 5, at 566-568.
-29- of other potential measures to mitigate or eliminate the duration and/or impact of such events.
Exh. EV-2, at 2-4.
Special consideration is given in SYS PLAN-015 to load served by substations that are supplied by two underground transmission lines. Exh. EV-2, at 2-3. When two underground cables are lost, the Company looks for a solution to bring the loss of load to zero, because otherwise the remaining load could stay unserved for weeks while the problem is identified and fixed. Tr. 4, at 490; Tr. 5, at 575-577. These stations serve a considerable number of customers and the underground transmission lines used in these densely populated areas to supply large customer loads cannot, in most situations, be transferred across the distribution system due to system and/or physical limitations. Exh. EV-2, at 2-3 and 2-4. Furthermore, typically, more time is required to locate the source of an underground cable failure and conduct required repairs, resulting in prolonged duration outages (e.g., potentially many days, weeks or months depending upon the nature of the failure and location of the necessary repair). Exhs. EV-2, at 2-4; EFSB-N-16; Tr. 4, at 460. The prolonged outage of two cables in a densely populated urban residential area could result in significant consequences such as long customers outages requiring emergency deployments, public safety concerns, and economic impacts to urban business districts and tourism. Exhs. EFSB-N-23; EFSB-N-35; Tr. 4, at 461.
The 50 MW underground cable threshold was established based on the Company’s determination that there was a correlation between CLL and areas of the system with higher load and population density when the CLL was 50 MW or greater.14 Exh. EFSB-N-7; Tr. 4, at 354.
14 Before finalizing SYS PLAN-015, Eversource assessed the ISO-NE load loss guideline and criteria developed for other utilities responsible for serving major metropolitan areas. Exhs. EFSB-N-7; EFSB-N-33; EFSB-N-37; Tr. 4, at 355-356. The criteria in SYS PLAN-015 are somewhat less restrictive (e.g., some utilities in large urban settings have a 0 MW threshold), but in line with the criteria used by these utilities. Id.; Exhs. RR-EFSB-27; RR- EFSB-28.
-30- The 50 MW threshold for underground cables in SYS PLAN-015 is lower than the threshold for overhead lines because: (1) failures for underground cables typically require complex and extensive repairs; (2) underground cables are typically used in densely populated areas to supply large customer loads that in some situations cannot be transferred across the distribution system due to system and/or physical limitations; (3) restoration in an area served by underground cables is more complicated and time consuming than in areas served by overhead lines, resulting in prolonged outages; (4) there is typically minimal transfer switching capability in underground cables to support load transfers to adjacent substations; and (5) underground cables are often installed in locations where above ground space for infrastructure is typically constrained. Exhs.
EV-2, at 2-3 – 2-4, Appendix 2-1, at 3; EFSB-N-23; EFSB-N-32.
b. A Solution Is Needed to Avoid Long Customer Outages in the Project Area
Andrew Square and Dewar Street Substations are each supplied by two radial underground transmission lines and these stations serve a considerable number of customers in a densely populated area. Exh. EV-2, at 2-3. The Company identified that far in excess of 50 MW of customer load would be lost in the event of an N-1-1 contingency involving either of the radial underground transmission lines serving Andrew Square and Dewar Street Substation. Exh. EV-2, at 2-5 - 2-6.
Using detailed system models and the 2018-2028 Eversource substation load forecast,15 the Company determined that the transmission lines serving Andrew Square and Dewar Street
15 Eversource developed peak load forecasts for the Andrew Square and Dewar Street Substations consistent with its substation forecasting methodology, beginning with a system level peak demand forecast developed by using an econometric model that evaluates historical peak demand as a function of peak day weather conditions and the economy and does not rely solely on historical growth rates. Exhs. EFSB-N-3; EFSB-N-9. Once the Eversource system level forecast is finalized, the substation level forecasts are developed using an econometric model that evaluates substation historical demand as a function of the Eversource system peak demand history and forecast. Exh. EFSB-N-3. After a trend forecast is produced for each substation, the forecast is then adjusted for energy efficiency, solar and large customer projects. Id. In addition, any identified large development projects that could not otherwise be predicted by the econometric forecasts are applied to substations. Id.
-31- Substations would have sufficient capacity under N-1 contingencies should one cable to either the
Andrew Square or Dewar Street Substations fail and be out-of-service for an extended period of time.16 Exh. EV-2, at 2-4; Tr. 4 at 349. However, during an N-1-1 contingency, at both existing and projected peak load levels, the transmission configuration is not adequate to reliably serve the area. Exh. EV-2, at 2-4; Tr. 4, at 350.
The 2018-2028 Eversource substation load forecast projected a summer peak load for
Andrew Square Substation of 121.6 MVA in 2018, increasing to 128.3 MVA by 2028.17 Exh. EV-
2, at 2-5. An N-1-1 contingency (the loss of one transmission circuit followed by the loss of a second transmission circuit in the area) would result in the loss of supply to Andrew Square
Substation. Exh. EV-2, at 2-5. The 2018-2028 Eversource substation load forecast projected a summer peak load for Dewar Street Substation of 124.7 MVA in 2018, marginally decreasing to
121.8 MVA by 2028 as the result of implementation of additional energy efficiency (“EE”).18 Exh.
EV-2, at 2-6. An N-1-1 contingency would result in the total loss of supply to Dewar Street
Substation. Exh. EV-2, at 2-6. The need for the Project is reliability-based and is not impacted
16 In June 2016, Eversource completed construction of the South Boston Reliability Project, which was approved by the Department of Public Utilities in D.P.U. 13-86. Exhs. EV-2, at 2-5; EFSB-N-1. As part of that project, the Company energized and placed in service two new underground transmission lines in South Boston, Lines 106- 526 and Line 106-527, between K Street Substation and a connection point on Columbia Road in South Boston. Id. The transmission line work split the former wye joints on Columbia Road so that two 115-kV cables would supply Andrew Square Substation and two cables would supply Dewar Street Substation. Id. Prior to the South Boston Reliability Project, an N-1-1 event for loss of both supply cables out of K Street Substation would result in the loss of all load at both Dewar Street and Andrew Square Substations. Exh. EFSB-N-14. As a result of that project, Andrew Square and Dewar Street Substations are each currently supplied by two 115-kV lines, each with normal ratings greater than the 2018-2028 Eversource substation load forecast for Andrew Square and Dewar Street Substations, thus providing the existing transmission system with sufficient capacity under N-1 contingencies should one cable to either Andrew Square or Dewar Street Substations fail. Exh. EV-2, at 2-6. Further, with the South Boston Reliability Project in place, under N-1-1 contingency events, the loss of two stations was reduced to loss of one station only and reduced the amount of load and customers lost. Exh. EFSB-N-14. However, the loss of both cables from K Street to either of the stations would still drop the load at that station. Exh. EFSB-N-1; Tr. 4, at 465. 17 The actual summer peak load in 2018 for Andrew Square Substation was 114.4 MVA. 18 The actual summer peak load in 2018 for Dewar Street Substation was 121.0 MVA.
-32- by small changes in load growth rates. Exh. EFSB-N-18; Tr. 4, at 389. Even if load in the Project
Area decreases, the Project is needed to protect against contingencies that would cause an entire station outage and loss of supply to a large urban area. Id.; Tr. 4, at 387-388, 482. Nevertheless, although load growth is not a factor in driving the need for the Project, given the existing significant potential load loss at Andrew Square and Dewar Street Stations (each presently supply area load in excess of 100 MW), load growth does increase the magnitude of potential load loss.
Exhs. EFSB-N-12; EFSB-N-13; RR-EFSB-32; Tr. 4, at 486.
After determining the potential CLL following an underground cable failure, Eversource examined the load transfer capability within the distribution network to determine if it could reduce or eliminate the consequential load loss that would occur under the N-1-1 contingencies. Exh.
EV-2, at 2-5. The Company’s analysis showed that there was not adequate capacity to switch a sufficient amount of load to other distribution sources.19 Tr. 4, at 364. The Company can accomplish emergency switching by sectionalizing the faulted piece of equipment on the circuit at one station and connecting the line to an adjacent feeder to tie into an adjacent station to pick up the load. Tr. 5, at 540. However, both the adjacent feeder and station must have sufficient capability to accept the additional load and, even if they do, this is only a temporary solution until the fault is repaired. Tr. 5, at 540-541. Specifically, in order to transfer load, there must be distribution feeder interconnection points, spare capacity in existing distribution feeders or the ability (including the availability of sufficient space) to install new switchgear and create new feeders. Tr. 5, at 562-563.
19 In addition, generation re-dispatch would not be a solution because generation would be de-energized under the N-1-1 contingencies at issue. Tr. 4, at 383-384.
-33- For the load loss at Andrew Square Substation, the Company identified that a total of 27
MVA of emergency transfer switching to the neighboring K Street, Dewar Street, Colburn Street and Hyde Park Substations was possible. Exh. EV-2, at 2-5. However, an N-1-1 contingency would result in the loss of supply to Andrew Square Substation of more than 94.6 MVA in 2018 and would increase to 111.3 MVA of unserved load by 2028. Exh. EV-2, at 2-5. Therefore, the amount of available distribution transfer switching would be insufficient to restore power to all the affected outage customers served by Andrew Square Substation. Exh. EV-2, at 2-5. Post emergency transfer switching, there would be approximately 30,000 customers supplied from
Andrew Square Substation that could not be restored. Exh. EV-2, at 2-5.
Eversource also examined the load transfer capability within the distribution network to determine if it could reduce or eliminate the consequential load loss that would occur under the N-
1-1 contingency that would result in the total loss of supply to Dewar Street Substation. Exh. EV-
2, at 2-6. The Company identified that a total of 15.1 MVA of emergency transfer switching to the neighboring Andrew Square, Hyde Park and Colburn Street Substations was possible. Exh.
EV-2, at 2-6. This distribution transfer switching would not be sufficient to restore power to all the affected outage customers served by Dewar Street Substation. Exh. EV-2, at 2-6. The loss of one transmission circuit followed by the loss of a second transmission circuit would result in the loss of supply to Dewar Street Substation of more than 109.6 MVA in 2018 and would increase to
111.8 MVA of unserved load by 2028. After emergency transfer switching, there would be approximately 53,000 customers supplied from Dewar Street Substation that could not be restored.
Exh. EV-2, at 2-6. Thus, even after emergency transfer switching, in the event of an N-1-1 contingency on either set of lines, there would be substantial unserved load for the affected substation. Id.; Exh. EFSB-N-19.
-34- After determining that distribution switching would be inadequate in the event of loss of both lines to either Andrew Square or Dewar Street Substation, the Company examined whether portable generators and / or transformers could serve the customer load that would be lost in the event of an N-1-1 contingency. Tr. 4, at 364-371. This solution would not be practical because of proximity to customers and space limitations both at the substations and in the urban streets where multiple portable generators would need to be located near the load they would be supplying. Id. Furthermore, all these emergency actions, (emergency distribution switching, portable generators and/or transformers) have a substantial impact on the environment, including noise, lack of parking and disruption. Tr. 5, at 599-600.
The Company determined that a line failure resulting in the loss of load to not only residential, commercial and industrial customers, but also to critical institutional customers, is not acceptable, especially given that failures of underground transmission cables typically require extensive repairs, resulting in long outage durations. Exh. EV-2, at 2-6. During such an extended duration outage of underground facilities, the affected customers would remain out of service and there would be no means to either resupply or restore their electrical service until the failure could be repaired. Id.
3. Conclusion on Need
Currently, the loss of transmission supply from K Street Substation to either Andrew
Square or Dewar Street Substations would result in loss of service to customers in the Project Area served by one of these Substations. Exh. EFSB-N-31. The Project is needed due to the limited ability to transfer loads among distribution stations and the potential extended duration loss of electric transmission supply to a large customer base in the Dorchester, South Boston and Roxbury sections of the City. Id. The proposed New Line will solve two problems by interconnecting
-35- Andrew Square Substation and Dewar Street Substation and providing each with an alternative source of supply from K Street Substation. Exh. EV-2, at 2-1; Tr. 4, at 380. The Project is an integrated, long-term solution that is immediately needed to reliably serve customers in the event of a contingency loss of supply to Andrew Square or Dewar Street Substations.
B. The Company Evaluated a Reasonable Range of Possible Project Alternatives in Determining That the Project Was Superior in Meeting the Identified Need.
Standard of Review
The Siting Board is required to evaluate proposed projects to ensure a reliable energy supply for the Commonwealth with a minimum impact on the environment at the lowest possible cost. See G.L. c. 164, § 69H. In addition, Section 69J requires a proposed project proponent to present alternatives to the proposed facility, which may include: (a) other methods of transmitting or storing energy; (b) other sources of electrical power or natural gas; or (c) a reduction of requirements through load management. Eversource Mystic-East Eagle at 29; Eversource
Walpole-Holbrook at 17; Eversource Mystic-Woburn at 18.
In implementing its statutory mandate, the Siting Board requires a petitioner to show that, on balance, its proposed project is superior to alternative approaches in terms of reliability, cost, environmental impact and ability to meet a previously identified need. Eversource Mystic-East
Eagle at 29; Eversource Walpole-Holbrook at 17; Eversource Mystic-Woburn at 18. In addition, the Siting Board requires a petitioner to consider reliability of supply as part of its showing that the proposed project is superior to alternative project approaches. Id.
Evaluation of Project Alternatives
The Company comprehensively identified and analyzed various alternatives to address the identified need for the Project. Exh. EV-2, 3-1. In order to determine the approach that best balances reliability, cost and environmental impact, and consistent with Section 69J and Siting
-36- Board precedent, the Company evaluated a series of project approach alternatives for their potential to meet the need identified in the Project Area. Id. The evaluation process involved four distinct assessments: (1) a No-Build Alternative; (2) two transmission alternatives; (3) distribution transfer switching to neighboring substations; and (4) non-transmission alternatives (“NTAs”), including new generation, either alone or supplemented by EE, demand response, and energy storage technologies (collectively referred to as “Project Alternatives”). Id.
The Company assessed each Project Alternative to determine whether it could effectively address the identified need (i.e., the N-1-1 transmission loss of supply to either the Andrew Square or Dewar Street Substations). Exh. EV-2, 3-1. The Project Alternatives that were determined to adequately address the need were further analyzed to determine their comparative electrical capacity, constructability, cost, environmental impact and reliability. Id. Through this analysis, the Company demonstrated that the Project is the alternative that best meets the identified need, with a minimum impact on the environment, at the lowest possible cost. Id.
a. No-Build Alternative
The No-Build Alternative was dismissed from further consideration because without improvements to the existing electric supply system to address the area deficiencies, which exist at current load levels, the Project Area would be subject to potentially significant loss of load that would affect a large number of customers. Exh. EV-2, 3-1 to 3-2.
b. Transmission Alternatives
In addition to the Project (referred to as Transmission Alternative No. 1 in the Company’s alternatives analysis), which involves the construction of an underground 115-kV line between the
Andrew Square and Dewar Street Substations,20 the Company evaluated Transmission Alternative
20 The work required for Transmission Alternative 1, the Project, is described in Section III.A. above.
-37- No. 2, which would involve the construction of two new underground 115-kV lines - one between the K Street and Andrew Square Substations and one between the K Street and Dewar Street
Substations.21 Exh. EV-2, at 3-2 and Figures 3-1 and 3-5.
The installation of a new solid dielectric cable from K Street Substation to Andrew Square
Substation, for either transmission option, would include approximately 1.4 miles of duct bank to support: (1) four eight-inch conduits; (2) two four-inch and two two-inch communications conduits; (3) five splice cable vaults (manholes) and five communication hand-holes. Exh Ev-2, at 3-5 and Figure 3-6. Transmission Alternative No. 2 would also require the installation of a new
(solid dielectric cable) from K Street Substation to Dewar Street Substation including approximately 3.1 miles of duct bank to support the following: (1) four eight-inch conduits; (2) two four-inch and two two-inch communication conduits; (3) 11 cable splice vaults (manholes); and
(4) 11 communication hand-holes. Id. at 3-6. To connect the two new 115-kV lines at K Street
Substation for Transmission Alternative No. 2, the Company would terminate the new K Street to
Andrew Square 115-kV line into an existing spare board position. Exh. EV-2, at 3-6. The new K
Street to Dewar Street 115-kV line would be bifurcated into an existing board position. Id. The required work to interconnect each new line at its respective station would be the same as with the
Project. Id.
21 Transmission Alternative No. 2 would require two lines because Andrew Square and Dewar Street Substations are each supplied only radially by two cables and, therefore, an N-1-1 contingency situation involving either of these cables would result in the loss of supply to the substation being supplied. Exh. EFSB-PA-1. Installing only the K Street to Andrew Square line, would bring a third supply to Andrew Square Substation and address the N-1-1 contingency leading to the loss of load at that substation, but would not address the N-1-1 contingency leading to the loss of load at Dewar Street Substation. Id. Dewar Street Substation would need to transfer all its load in order to resolve the remaining N-1-1 contingency, but neighboring substations could not accept a sufficient amount of load. Id. Furthermore, even if load were reduced by additional distributed generation and energy efficiency, distribution switching would not be sufficient to prevent the loss of load at Dewar Street Substation in the event of an N-1-1 contingency. Id.
-38- The Company compared the Project with Transmission Alternative No. 2 based on cost, reliability and environmental impacts. Exh. EV-2, at 3-7. The conceptual grade cost estimates (-
25%/+50%), including the transmission lines and associated station work, was $68.3 million for the Project and $140.5 million for Transmission Alternative No. 2. Id.; Exh. EFSB-PA-2. The
Project’s cost is significantly less than Transmission Alternative No. 2, which would require installation of two transmission lines and a significantly greater amount of conduit and cable
(approximately 4.5 miles) compared to the Project’s approximately two miles of conduit and cable.
Exh. EV-2, at 3-7.
While the Project and Transmission Alternative No. 2 would both add the needed transmission capacity to the system by establishing a third transmission source to Andrew Square and Dewar Street Substations, the Project has enhanced reliability benefits. Exh. EV-2, at 3-7.
For Alternative No. 2, the K Street to Dewar Street 115-kV Line would need to share a switching position at K Street Substation. Exh. EV-2, at 3-7. This approach would degrade the reliability of this interconnection because an outage of the shared transformer at K Street Substation would reduce the reliability of the 115-kV supply to Dewar Street Substation. Exh. EV-2, at 3-7.
The potential environmental impacts for Transmission Alternative No. 2 would be significantly greater than for the Project because more than twice the amount of cable would need to be installed and upgrades would be needed at an additional substation. Exh. EV-2, at 3-8. The
Company’s desktop analysis of key environmental elements for both transmission alternatives demonstrates that the Project has less potential environmental impacts for 10 of the 12 environmental parameters that were compared. Exh. EV-2, at 3-9. Transmission Alternative No.
2 would also result in the construction of approximately 9,295 feet more of 115-kV transmission main, impact approximately 166 more residential properties and approximately 23 more
-39- commercial/industrial properties and abuts approximately 5,621 more linear feet of public transportation routes. Id. It also has more hazardous waste sites within 500 feet of the ROW, more highway and major bridge crossings and more shade trees. Id. Based on this comparison, the
Company concluded that the Project is superior to Transmission Alternative No. 2 based on the potential for environmental impact. Id.
Given that the Project will be a more reliable solution, will cost less and will have fewer environmental and land use impacts than Transmission Alternative No. 2, the Company determined that the Project is the superior transmission alternative. Exh. EV-2, at 3-9.
c. Distribution Alternatives
The Company also evaluated two potential distribution alternatives to the Project: increased emergency distribution transfers and a new distribution substation.
i. Emergency Distribution Transfers to Neighboring Substations
As discussed above, the implementation of existing emergency transfer switching to nearby substations would not address the need for the Project. Therefore, the Company thoroughly investigated the ability of increased distribution emergency transfer switching beyond the levels currently available to resolve the impact of the N-1-1 conditions for both the Andrew
Square and Dewar Street Substations. Exhs. EV-2, at 3-10, Tables 3-3 and 3-4; RR-EFSB-36.
The Company’s analysis shows that the existing distribution system can support only a limited increase in additional transfer switching and that there are major challenges to expanding the distribution system’s ability to support additional transfer switching. Tr. 5, at 561. First, load transfers to a nearby station cannot result in transformer loading that would exceed that station’s normal capacity. Exh. RR-EFSB-36. Moreover, transfer capability is limited by several factors at the neighboring substations, such as the availability of breaker positions, space constraints limiting the addition of new breaker positions, and distribution system topology and capability.
-40- Exh. RR-EFSB-36. In addition, transfer capacity is limited by distribution feeder capacity. Id.
There must be sufficient distribution feeder capacity on circuits with existing distribution ties to support transfer switching. Exh. RR-EFSB-36. If there is not, there must be either the potential to create new ties from nearby distribution feeders when ties do not already exist or the potential to construct new feeders that will tie to existing feeders from the substation to be relieved. Exh.
RR-EFSB-36.
With these constraints on increasing transfer capability in mind, the Company examined whether, and to what extent, increasing distribution transfers between Andrew Square and Dewar
Street Substations and from those stations to the nearby K Street, Colburn Street and Hyde Park
Substations was feasible.22 Additional emergency distribution transfer switching to Colburn Street
Substation is not possible because it would exceed Colburn Street’s normal capacity.23 Exhs.
EFSB-PA-3(R1); EFSB-PA-4(R1); RR-EFSB-37. Additional emergency distribution transfer switching to Hyde Park Substation is not possible because the station does not have any spare 14- kV breaker positions in the existing distribution switchgear and there are land constraints at the station that preclude the installation of new distribution switchgear. Exhs. EFSB-PA-3(R1);
EFSB-PA-4(R1); RR-EFSB-36.
The maximum amount of increased emergency distribution transfer from Andrew Square
Substation that could be achieved without exceeding the receiving transformers’ normal capacity limits would require the installation of two distribution lines between Andrew Square Substation
22 Although the Scotia Street, Carver Street and Kingston Street Substations are also near Andrew Square Substation, these substations are secondary network substations. Exh. EV-2, at 3-10. There is no transfer switching capability to these adjacent stations because there are no interconnections between these secondary network substations and neighboring substations. Id. 23 Even if station loads at neighboring substations decrease, they do not result in a corresponding amount of increased transfer capability because the distribution feeders that tie the two substations must also have a drop in capacity. Exhs. EFSB-PA-5; RR-EFSB-36; Tr. 5, at 570, 596.
-41- and Dewar Street Substation and the installation of two distribution lines between Andrew Square
Substation and K Street Substation. Exh. EFSB-PA-3(R1). A limit of two new distribution lines could be installed at K Street Substation because, while this substation has space for additional facilities, the streets approaching the substation have limited space for new underground facilities.
Exh. RR-EFSB-37. In addition to the four new lines, the Company would need to add two 14-kV board positions at Dewar Street Substation, which would be accomplished by adding two breaker positions to the existing switchgear. Exh. EFSB-PA-3(R1).
The only additional reduction in the load at risk at Dewar Street Substation that could be achieved through distribution transfer switching without violating the receiving transformers’ normal capacity limits would require installing a distribution line between Andrew Square
Substation and Dewar Street Substation. Exh. EFSB-PA-4(R1).24 In addition to the new line, the
Company would need to add one 14-kV board position at Andrew Square Substation, which would be accomplished by adding a breaker position to the existing switchgear. Exh. EFSB-PA-4(R1).
The feasible additional distribution transfer switching from Andrew Square and Dewar
Street Substations described above would not offer full backup upon loss of transmission supply to these substations, in contrast to the proposed Project. Exhs. EFSB-PA-3(R1); EFSB-PA-4(R1).
Specifically, the Company examined potential load transfer capability from Andrew Square and
Dewar Street Substations based on 2018 and 2023 load, looking at the maximum support neighboring substations could provide within their physical substation footprint constraints and transformer rating limitations. Exh. RR-EFSB-37. Andrew Square Substation can currently transfer 21 MVA of its load to the K Street, Colburn Street, Dewar Street and Hyde Park
24 Although Colburn Street and Hyde Park Substations are also near Dewar Street Substation, as discussed above, additional distribution transfers to Colburn Street and Hyde Park Substations are not possible. Exh. EFSB-PA- 4(R1).
-42- Substations and an additional 28 MVA could be transferred if the four distribution feeders were added, leaving 72.5 MVA of Andrew Square Substation at risk. Exh. RR-EFSB-37. Dewar Street
Substation can currently transfer 15.1 MVA of its load to the Andrew, Colburn Street, and Hyde
Park Substations and an additional 6 MVA could be transferred if a new distribution line were installed between Andrew Square and Dewar Street Substations, leaving 103.6 MVA of Dewar
Street Substation at risk. Exh. EFSB-P-4(R1). These amounts of consequential load loss in a dense urban area are well above Eversource’s 50 MW load loss criterion and unacceptable to the
Company due to potentially prolonged restoration periods. Exhs. EFSB-PA-3(R1); EFSB-PA-
4(R1).
Given the amount of load that would still be at risk even after this additional transfer switching, the Company also explored the option of adding facilities (transformers, distribution switchgear), to existing substations. Exh. RR-EFSB-37. As noted above, Colburn Street
Substation is limited by the substation’s normal capacity and Hyde Park Substation has no physical space available for expansion and, while K Street Substation has space, the streets approaching the
K Street Substation have limited space for new underground facilities. Exh. RR-EFSB-37. Dewar
Street Substation does have available space that could be used to construct additional distribution facilities to connect to the Andrew Square Substation load. Exh. RR-EFSB-37. However, while installation of 115-kV equipment and a new 140-MVA network style transformer (similar to the two units already at Dewar Street) could address both the Dewar Street and Andrew Square
Substation issues, extensive new underground conduit and manhole systems for new distribution feeders would need to be installed within the distribution network in city streets to increase the transfer of load. Exh. RR-EFSB-37. In addition, two new duct banks would be needed in order to supply the Andrew Square Substation load. Exh. RR-EFSB-37. The cost of the distribution
-43- duct banks alone would exceed $100 million, far in excess of the cost of the Project. Exh. RR-
EFSB-37. Because of the cost and the additional environmental impacts associated with construction of the additional duct banks, the Company did not pursue this option further. Exh.
RR-EFSB-37.
In conclusion, existing distribution transfers, plus new distribution transfers created by adding four new feeders to the area, would not be adequate to address the need for both Andrew
Square and Dewar Street Substations. Exh. RR-EFSB-37. Accordingly, the Company rejected increasing distribution transfer switching as an alternative because it would not eliminate the potential substantial consequential load loss.
ii. New Distribution Substation
As an alternative to the Project, the Company also considered the construction of a new
115/14-kV substation and associated transmission lines to relieve Andrew Square and Dewar
Street Substations. Exh. EV-2. at 3-13. The Company estimated that a new 115/14-kV substation, together with the installation of three to four miles of new transmission supply lines that would be needed, would cost significantly more than $150 million. Id. Because the development of a new substation as an alternative to address the identified transmission reliability needs in the Project Area would be significantly greater than the cost of the proposed Project
($68.3 million), the Company rejected this alternative. Id.
d. Non-Transmission Alternatives
The Company considered a wide variety of technologies in assessing possible NTAs to address the identified need. Exh. EV-2, at 3-14. However, most NTA technologies were not suitable alternatives to address the identified need because they are capable of supporting only the load temporarily or reducing the load, rather than supplying the entire load at either Andrew Square
-44- or Dewar Street Substation, without support from the regional transmission system for a long-term
N-1-1 contingency event. Id. Battery storage is technically infeasible by itself to meet the need because it would be unable to charge from the grid in a post-contingency situation and would be limited to only the limited hours of energy on hand. Id. Notably, commercially available storage systems would have the capacity to cover only a short portion of one day, which would be insufficient for a longer outage associated with an underground cable. Id. Likewise, photo-voltaic
(“PV”) solar facilities would not be an effective solution for a long-term outage because they are highly intermittent and non-dispatchable resources that could support the load only temporarily during hours of the day when there is sunlight available. Exh. EV-2, at 3-14. Even if paired with battery storage, PV facilities would not be a feasible solution because such facilities require a significant amount of land for siting these facilities, which is not available in the Project Area. Id.
Existing solar facilities in the area are already reflected in the load forecast and there are limited opportunities for large increases due to the urban nature of the Project Area. Tr. 5, at 612.
Demand-side programs and distributed generation are also not suitable alternatives because they can only reduce the load and cannot serve load by themselves in an isolated manner. Id. The amount of load that can be reduced by these technologies is insufficient compared to the overall load at both Andrew Square and Dewar Street Substations. Id.
Given that no other technically feasible non-transmission technology could meet the identified need, the Company’s NTA analysis focused on whether conventional generation, either alone, or in combination with other technologies, would be feasible or cost effective. There are currently no conventional generation projects proposed in the Project Area in the ISO-NE interconnection queue, so the most likely NTA solution would be the construction of two new, fast-start combustion turbines (at least one combustion turbine would need to be located at both
-45- Andrew Square and Dewar Street Substations). Exh. EV-2, at 3-15. The cost to install two 112
MW fast-start units would be approximately $412 million, significantly greater than the cost of the Project and, depending on the configuration and the design, additional units at each substation could also be required to provide a reliable backup supply. Id. Among other constraints, the
Company would need to identify and purchase property in South Boston to locate the combustion turbines and associated infrastructure. Interconnecting the generators into the Andrew Square and
Dewar Street Substations would require a line to connect the generators to the substations, as well as expansion of both substations, with scope and cost similar to the substation upgrades associated with the proposed Project. Exhs. EV-2, at 3-14; EV-2, at 3-14. These land acquisition and interconnection challenges would add substantial costs to this alternative solution. Id.
e. Conclusion on Project Alternatives.
Eversource’s Project Alternative analysis demonstrates that the Project will best address the need to improve reliability to the Project Area. Exh. EV-2, at 3-16. Relative to the other substation and transmission alternatives studied, as well as increased distribution transfer switching, the Project best meets the need with the least environmental and construction impacts at the lowest possible cost. Id. The Company’s analysis showed that new conventional generation, the only technically feasible NTA, would be impractical and costly. Id. Accordingly, the installation of an Andrew Square to Dewar Street 115-kV line was the solution carried forward to the routing analysis.
C. The Company’s Route Selection Process Considered a Reasonable Range of Siting Alternatives and Resulted in a Project That Provides a Reliable Supply of Energy While Minimizing Environmental Impacts and Costs.
Standard of Review
G.L. c. 164, § 69J requires the Siting Board to review alternatives to planned projects. In implementing this statutory mandate, the Siting Board requires a petitioner to demonstrate that it
-46- has considered a reasonable range of practical siting alternatives and that the proposed facilities are sited in locations that minimize costs and environmental impacts while ensuring supply reliability. NSTAR Electric Company d/b/a Eversource Energy, EFSB 16-02/D.P.U. 16-77, at 21
(2018) (“Eversource Needham”); Eversource Mystic-East Eagle at 63; Eversource Walpole-
Holbrook at 32; Eversource Mystic-Woburn at 26
To do so, an applicant must satisfy a two-pronged test: (1) the applicant must first establish that it developed and applied a reasonable set of criteria for identifying and evaluating alternative routes in a manner that ensures that it has not overlooked or eliminated any routes that, on balance, are clearly superior to the proposed route; and (2) the applicant must establish that it identified at least two noticed sites or routes with some measure of geographic diversity. Id. In applying this
“clearly superior” standard, the Siting Board has found that a “methodical approach” to identifying potential routes, such as one focused on existing corridors, ensures that applicants do not overlook clearly superior routes. Boston Edison Company d/b/a NSTAR Electric, 14 DOMSB 233, EFSB
04-1/D.T.E. 04-5/04-7, at 44 (2005) (“NSTAR Stoughton”). Relatedly, in narrowing down potential options, the Siting Board has approved processes that eliminate routes based upon permitting complexities, and high projected costs. NSTAR Stoughton at 44.
Methodology
Consistent with previously established approaches for evaluating electric transmission routing options and Siting Board precedent, the Company conducted a systematic and comprehensive analysis of routing alternatives for the Project to identify a reasonable variety of potential candidate routes for screening and analysis in order to ensure that a clearly superior route was not overlooked and that the Project route was selected consistent with the Siting Board’s standards and applicable precedent. Exh. EV-2, at 4-1 – 4-2. The goal of the Company’s routing analysis was to identify a technically feasible route that achieved the required transmission system
-47- reliability improvements by interconnecting the specified substations while minimizing the potential impacts the candidate routes may have on the developed and natural environment. Id.
After developing a geographic study area (the “Study Area”) and identifying routing opportunities and constraints, a focused set of route selection guidelines was then applied to find potential routes and route variations in the Study Area to identify a “Universe of Routes.” Exh.
EV-2, at 4-2. From the Universe of Routes, the Company identified “Candidate Routes” that were viable routes that met the need for the Project and were consistent with the objectives of the
Company’s routing analysis. Id. This iterative process was designed to ensure that no clearly superior route was overlooked. Exh. EV-2, at 4-1.
Ultimately, the Candidate Routes were evaluated, scored, weighted and ranked by applying a set of objective environmental and constructability criteria and evaluating conceptual cost estimates. Exhs. EV-2, at 4-10 to 4-25. The Company used its rigorous evaluation and ranking process to identify the Preferred Route - the route option that best balances minimization of environmental impacts (including developed and natural environment impacts and constructability constraints) with reliability and costs. Exh. EV-2, at 4-24-25.
The analysis also identified a Noticed Alternative Route that provides a geographically distinct alternative to the Preferred Route, while also attempting to strike a balance among the aforementioned factors. Id.
Identification of Study Area, Universe of Routes and Candidate Routes
Following the establishment of the routing objectives,25 the Company reviewed the area between the existing Andrew Square and Dewar Street Substations and demarcated a geographic
25 The routing objectives were: (1) comply with all applicable statutory requirements, regulations and state and federal siting agency policies; (2) achieve a reliable, operable and cost-effective solution; (3) maximize the reasonable, practical and feasible use of existing linear corridors (e.g., transmission line, highway, railroad,
-48- “Study Area,” to concentrate the investigation of potential routes. Exh. EV-2, at 4-4. The Study
Area is located entirely within the South Boston and Dorchester neighborhoods of the City of
Boston and consists of a densely developed, urban neighborhood that includes residential, commercial and some industrial areas. Exh. EV-2, at 4-4.
The Company identified potential routes and route variations in the Study Area using recent aerial photos, United States Geological Survey (“USGS”) maps, Massachusetts Geographic
Information System, aerial photography and field reconnaissance, as well as input from stakeholders. Exh. EV-2, at 4-5, 4-9. Company representatives met with federal, state and municipal officials, residents, business owners and other stakeholders to discuss the Universe of
Routes under consideration for the New Line and to obtain input on these routing options. This process began in December 2017 and included more than 22 meetings. Exh. EV-2, at 4-3 and
Table 4-1. Although there were many potential options for routing the New Line that could weave through existing narrow streets, the Company aimed to compile the more direct routes between the two substations within the Study Area. Exh. EV-2, at 4-5. Routes were screened out if they did not meet the routing objectives or were clearly inferior or impracticable to construct. Exh. EV-
2, at 4-5 - 4-9. Specifically, the Company eliminated from further consideration route options involving use of the MBTA ROW and I-93 because they could not support the Project objectives of providing reliable infrastructure in a timely and cost-effective manner due to construction feasibility constraints. Exh. EV-2, at 4-9. Based on this screening analysis, the Universe of Routes was narrowed to a set of four feasible Candidate Routes, all of which would travel underground in
or pipeline ROW); (4) minimize the need to acquire property rights; and (5) maximize the potential for direct routing options over circuitous routes. Exh. EV-2, at 4-2.
-49- existing public roadways, and cross highways and MBTA corridors. Exh. EV-2, at 4-10. A brief summary of the Candidate Routes is presented below.
Candidate Route Summary
Candidate Route Route Length Streets (miles) Morrissey Boulevard 2.0 Ellery Street, Boston Street, Father Songin Way, O’Connor Way, Kemp Street, O’Callaghan Way, Old Colony Avenue, William T Morrissey Boulevard, Old Colony Terrace, Savin Hill Avenue, Grampian Way, Playstead Street, Springdale Street Sydney Street 1.6 Ellery Street, Boston Street, Howell Street, Dorchester Avenue, Locust Street, Buttonwood Street, Mount Vernon Street, Columbia Road, Sydney Street Dorchester Avenue 1.6 Ellery Street, Boston Street, Father Songin Way, Dorchester Avenue, Dewar Street Pleasant Street 1.7 Ellery Street, Boston Street, Columbia Road, Pond Street, Pleasant Street, Reach Street, Dorchester Avenue, Dewar Street
Exh. EV-2, at 4-8.
Environmental and Constructability Analysis of Candidate Routes
The Company next evaluated the four Candidate Routes by scoring each of them using a set of 14 criteria that compare the relative levels of potential environmental, technical, and human built/developed impacts, and constructability constraints. Exh. EV-2, at 4-10. The criteria were grouped into the following three subcategories:26
• Natural environmental criteria: (1) public shade trees; (2) wetland resources; and (3) potential for subsurface soil contamination. Exh. EV-2, at 4-10 – 4-14.
26 Impacts to lands subject to Article 97 of the Amendments to the Constitution of Massachusetts (“Article 97”) were not included in the route selection criteria because, at the time the Company performed its route selection analysis, no routes included parkland. Subsequent to selecting the Preferred Route, the Company agreed to obtain rights to construct the Project on land the City considers to be parkland. See Section IV.E.3.d below for further discussion. The consideration of Article 97 issues in the route selection process would not have impacted the selection of the Morrissey Boulevard route as the Preferred Route and the Sydney Street route as the Noticed Alternative Route. Tr. 2, at 171-172.
-50- • Technical criteria: (1) existing road width; (2) existing utility density; (3) existing transmission lines; and (4) high impact crossings. Exh. EV-2, at 4-14 – 4-15.
• Built environment criteria: (1) residential land uses; (2) commercial/industrial land uses; (3) sensitive receptors; (4) public transportation facilities (5) historic and archaeological resources; and (6) traffic impacts. Exh. EV-2, at 4-16 to 4-20.
• Constructability criteria: (1) trenchless crossings; (2) existing utility density; (3) length of route; and (4) hard angles. Exh. EV-2, at 4-23 to 4-25.
Following the development of criteria to be used for the analysis, the Company assigned weights to each individual criterion based upon an assessment of the potential for temporary and permanent impacts and to reflect stakeholder input (including both municipality and public feedback). Exh. EV-2, at 4-10. As shown in the table below, the weighting scale ranges from 1 to 5, with 1 being the lowest weight and 5 being the highest weight that could be applied to a particular environmental criterion. Exh. EV-2, at 4-10.
-51- Routing Analysis Criteria Weights Summary
Criterion Assigned Weight Natural Environment Public Shade Trees 327 Wetland Resource Areas 2 Potential to Encounter Subsurface Contamination 4 Technical/Constructa Existing Road/ROW Width (less than 30 feet) 228 bility Existing Utility Density29 5 Existing Transmission Lines 5 High Impact Crossings 5 Built Environment Residential Land Use 430 Commercial and/or Industrial Land Use 4 Sensitive Receptors 3 Bus Stops/T Stations31 3 Length along Public Transit/MBTA ROW 3 Historical and Archaeological Resources 1 Traffic Impacts 5
Exh. EV-2, at 4-21, Table 4-4.
27 The public shade tree criterion was assigned a weight of three, recognizing the importance of street trees to the neighborhoods. Exh. EFSB-RS-4. 28 Existing road/ROW width is assigned a weight of two, while all other technical criteria are assigned a weight of five. Exh. EFSB-RS-10. While the existing widths of the roadways can constrain the work area for construction, controls such as parking restrictions or detours, can be incorporated during the work. Id. When assessing the technical criteria for the installation of a new transmission line in the Project Area, the proximity to existing transmission lines, utility density and the challenges with traversing high impact crossings are more significant technical challenges than road width and, therefore, are given a greater weight. Id.
29 The Company’s existing utility density and existing transmission lines criteria for assessing routes do not overlap. The existing utility density criteria refers to the combined analysis of three subcategories: useable corridor, utility crossing, and heat generating sources. Exhs. EFSB-RS-9; EFSB-LU-2. Useable corridor was calculated by averaging the available space in the ROW between existing utilities. Id. Utility crossing refers to the number of times the proposed route would cross an existing utility. Id. 30 This criterion was based on residential units rather than residential structures. Exh. EFSB-RS-5. 31 Public transportation is broken down into to criteria, bus stops/T stations and length along public transit. Bus stops/T stations addresses the need to account for address pedestrian access to and from the stops as they are impacted by construction and the potential for impact on travel times for buses resulting from stop relocations or temporary stop consolidations at multiple stops. Exh. EFSB-RS-7. The length of bus routes was used as a criterion to represent the distance that a candidate route would coincide with the transit route, which could impact the travel time due to construction traffic. Id. These two criteria could be consolidated into one category, but using two criteria provided a more granular evaluation of the routes. Id.
-52- After identifying the environmental criteria and assigning weights, the Company completed a scoring evaluation for each Candidate Route where each was scored, weighted and ranked to reflect its ease of constructability and its potential for impacts to the developed and natural environment. Exh. EV-2, at 4-11. After gathering data for each Candidate Route, the
Company assessed each criterion and identified the Candidate Route that had the largest number for that criterion. Id. Consistent with recent transmission project reviews before the Siting
Board,32 all other routes/designs were then compared against this number to arrive at a “ratio score” for each Candidate Route on a scale of 0 to 1. Id. The lowest ratio score equates to the lowest potential for impact. Id. For each criterion, the ratio score was then multiplied by its assigned weight to produce a weighted score that evaluated the criterion by its relative importance. Id.
The ratio and weighted scores for each criterion were added to arrive at “total ratio scores” and “total weighted scores.” Exh. EV-2, at 4-11; Exh. RR-EFSB-1. The total weighted scores were then sorted in order from low to high, to identify a given Candidate Route’s “rank.” Id. The lowest weighted score would equate to the lowest potential for impact with emphasis on certain criterion as previously described in this section. Id. The rankings developed in the Company’s routing analysis are based on the total weighted scores. Id.
Comparison of Routes
The Company’s comparative analysis of the Candidate Routes is presented below. The analysis demonstrates that the Company’s route selection process was rigorous, thorough and objective, thereby supporting the Company’s selection of the Preferred Route for the Project as
32 The Company’s use of ratio scoring in this proceeding is in accordance with the ratio scoring methodologies presented to the Siting Board in other recent and pending cases. See, e.g., Eversource Sudbury at 74-75; NSTAR Electric Company d/b/a Eversource Energy and New England Power Company d/b/a National Grid, EFSB 15- 04/D.P.U. 15-140/15-141 (“Eversource/NEP Woburn-Wakefield”); Eversource Mystic-East Eagle at 66-68, 74; Eversource Mystic-Woburn at 29-32.
-53- the route that is constructible and best balances considerations of environmental impacts, cost and reliability. By any reasonable measure, none of the alternative constructible routes presented in this proceeding is clearly superior to the Preferred Route.
a. Environmental and Constructability Analysis
The table below presents a summary of the four Candidate Routes ranked by total weighted environmental score. Exh. EV-2, at 4-23, Table 4-6. The lowest total weighted score equates to the lowest potential for impact (ranked 1), and the highest total weighted score equates to the highest potential for impact (ranked 20), with the emphasis on certain criteria as described above.
Exh. EV-2, at 4-23.
Environmental Rank by Total Weighted Scores
Total Candidate Route Length Weighted Rank Route (miles) Score Morrissey Boulevard 2.0 27.8 1 Sydney Street 1.6 28.4 2 Pleasant Street 1.7 31.0 3 Dorchester Avenue 1.6 36.6 4
Exhs. EV-2, at 4-23, Table 4-6; RR-EFSB-1; RR-EFSB-1(1). As shown in the table above, the
Morrissey Boulevard Candidate Route had the lowest weighted score and would result in the lowest potential for impact of all the Candidate Routes evaluated. The Sydney Street Candidate
Route has the next lowest potential for impact. Exh. EV-2, at 4-23.
b. Cost
As part of the route selection process, the Company evaluated the total cost estimates for each Candidate Route in order to rank the various Candidate Routes. Exhs. EV-2, at 4-23 to 4-24,
Table 4-7. The Company’s development of cost estimates follows standard industry practice, both in terms of timing and level of accuracy. Exh. EFSB-C-1. Initially, cost estimates for all candidate
-54- routes were developed using an average cost-per-mile based on recent projects to generate an estimate with a -50%/+200% level of accuracy. Id. A planning grade estimate (-25%/+25%) was developed for Morrissey Boulevard based on detailed engineering drawings. Exh. EV-2, at 4-24.
Id. A conceptual grade estimate (-25%/+50%) was developed for Sydney Street based on preliminary engineering drawings. Id. Order of magnitude estimates (-50%/+200%) were developed for Dorchester Avenue and Pleasant Street based on conceptual engineering drawings.
Id.33 Many factors could affect the actual cost of a transmission line project, including cost and availability of materials and equipment, labor, the presence of contaminated soils, and the potential for work hour restrictions. Id. For an underground line, subsurface conditions such as the type and depth of soil and rock that must be excavated in order to place the duct bank could also significantly affect project cost, as could the proximity of transmission lines and the density of underground utilities. Id. A summary of the conceptual cost estimates is provided in the table below.
33 The Company compared the cost estimates without any adjustments to account for the varying levels of accuracy. Exh. EFSB-C-1; Tr. 2, at 121-125. The Company’s development of cost estimates follows standard industry practice, both in terms of timing and level of accuracy. Id. Initially, cost estimates for all candidate routes were developed using an average cost-per-mile based on recent projects to generate an estimate with a -50%/+200% level of accuracy. Id. Based on the Company’s route analysis, the Company chose Preferred and Noticed Alternative Routes and performed certain field engineering, which enabled the Company to refine the cost estimates to a -25%+50% level of accuracy. Id. As design and engineering for the Project along the Preferred Route advanced and more information became available regarding existing conditions, the Company was able to develop a cost estimate at a -25%+25% level of accuracy. Id.
-55- Candidate Route Cost Estimates
Candidate Route Substation Transmissio Cost/mile Total Rank Percent more Cost n Cost (millions) (millions) than lowest (millions) (millions) cost option Morrissey $16.3 $52.0 $26.0 $68.3 1 Boulevard Sydney Street $16.3 $53.3 $33.3 $69.6 2 +2%
Dorchester Avenue $16.3 $54.5 $34.1 $70.8 3 +4%
Pleasant Street $16.3 $58.2 $34.2 $74.5 4 +9%
Exhs. EV-2, at 4-24, Table 4-7.
c. Reliability.
The Company considered whether there was a difference among the Candidate Routes regarding reliability of the proposed new line. Exhs. EV-2, at 4-24. While all Candidate Routes are underground and have relatively small differences in design that would not result in any substantial difference in the level of reliability risk, the Company determined that existing transmission lines in the Sydney Street corridor make it the least desirable Candidate Route from a reliability perspective.34 Id. Whenever practical, the Company works to minimize the length of parallel underground transmission lines in order to reduce the risk of one single event being the cause of multiple element failures. Id.
34 Because utility congestion is common in urban environments, the Company is not always able to avoid some paralleling of transmission circuits in the same corridor or ROW when constructing new lines, as would be the case for the Sydney Street Route. Exh. EFSB-RS-14. Paralleling of transmission circuits presents certain challenges, such as ensuring there is sufficient separation between existing and new circuits (which could involve, for example, the relocation of existing utilities to achieve optimum separation between the existing and new circuit to avoid mutual heating and reduced cable ratings). Id.; see Tr. 1, at 24, 30-32. In addition, adding another circuit to an existing corridor increases risk to the transmission system because a single event (e.g., due to excavation of the road, or other disturbance) could impact all infrastructure in that corridor. Exh. EFSB-RS-14. While the existence of other transmission lines along the Sydney Street Route would present challenges during construction and operation to ensure that system reliability is maintained, this does not affect the reliability as to present a significant flaw for the Sydney Street Route and it is still a viable alternative route. Id.
-56- Selection of Project and Noticed Alternative Routes
The table below presents a comprehensive summary of the four Candidate Routes and their relative rankings with respect to the natural environment, technical constructability, built environment, overall score and cost. Exh. EV-2, at 4-24.
Ranking Summary of Candidate Routes
Candidate Natural Technical Built Total Cost Route Environment Constructability Environment (million) Morrissey 6.8 7.4 13.6 27.8 $68.3 Boulevard Sydney Street 5.7 12.2 10.5 28.4 $69.6 Dorchester 4.7 10.6 21.4 36.6 $70.8 Avenue Pleasant Street 5.8 8.3 16.9 31.0 $74.5
Exh. EV-2, at 4-24, Table 4-8; RR-EFSB-1; RR-EFSB-1(1). As shown in the table above, the
Morrissey Boulevard Route has the lowest overall scoring rank and the lowest overall cost. It is more desirable from a reliability perspective than the Sydney Street Route because it has fewer existing transmission lines in the corridor. Exhs. EV-2, at 4-24; EFSB-RS-14. As discussed in more detail in Section D below, which provides a comparative analysis of environmental factors of the Morrissey Boulevard and Sydney Street Routes, the Morrissey Boulevard Route is superior to the Sydney Street Route because it will have less land use, traffic and noise impacts than the
Sydney Street Route. Exh. EV-2, at 5-38. For these reasons, the Morrissey Boulevard Route was chosen as the Preferred Route. Id. The Sydney Street Route has the second lowest overall rank
(both on scoring and cost) and maintains a reasonable degree of geographic diversity compared to the Preferred Route; accordingly, it was identified as the Noticed Alternative Route. Id.
In addition to the environmental, cost and reliability review, the Company considered the following engineering assessments and stakeholder meeting feedback in the route selection:
-57- • Ability to coordinate with other construction projects: Morrissey Boulevard and the Mary Ellen McCormack Housing Community are proposed to be redeveloped within the general timeframe as the proposed Project; meetings with DCR and BHA have confirmed the potential for design and construction coordination of their projects with the Company’s Project on the Morrissey Boulevard Route, which would result in a minimization of impacts to the environment and adjacent property owners.
• Minimization of impacts to BWSC infrastructure: According to BWSC, the area west of I-93 and north of Columbia Road along the Sydney Street Route contains combined sewers, and BWSC requires that a utility corridor within roads in that area be reserved for future combined sewer separation projects, making the Sydney Street Route less desirable.
• Known ability to trenchless cross under I-93/MBTA tracks at the crossing near Dewar Street Substation: Per discussions with BWSC on June 26, 2018, BWSC provided information that it was able to successfully pipe jack under I-93 and the MBTA tracks in the vicinity of Springdale Street, west of the Dewar Street Substation, along the Morrissey Boulevard Route.
Exhs. EV-2, at 4-25; EFSB-RS-3; Tr. 1, at 25; 71; 89. This additional assessment, particularly with respect to the available underground utility corridors, data regarding successful trenchless crossing, and the ability to coordinate with other construction projects, confirmed the selection of the Morrissey Boulevard Route as the Preferred Route.
Conclusion on Route Selection Process
The route selection process undertaken by the Company comprehensively addresses the
Siting Board’s standards applicable to jurisdictional energy facilities. As shown herein, the
Company has “developed and applied a reasonable set of criteria for identifying and evaluating
alternative routes.” See Eversource Mystic-East Eagle at 63; NEP Salem at 34-35. In
accordance with the standard of review, the Company objectively and comprehensively
developed and assessed a wide array of potential routes within the bounds of the Study Area.
Exh. EV-2, at 4-26. At the conclusion of this process, the Company identified a Preferred Route
and a Noticed Alternative that provided the best balance of environmental impacts, costs, and
-58- reliability and enable the Company to meet the identified need. Id. The Company’s systematic
approach to identifying and assessing potential routes ensured that no clearly superior routes
were overlooked or ignored. The Siting Board should therefore approve the Company’s route
selection process in this proceeding.
D. Comparison of the Preferred Route and the Noticed Alternative Route
Standard of Review
In implementing its statutory mandate to ensure a reliable energy supply for the
Commonwealth with a minimum impact on the environment at the lowest possible cost, the Siting
Board requires a petitioner to show that its proposed facility is sited at a location that minimizes costs and environmental impacts while ensuring a reliable energy supply. To determine whether such a showing is made, the Siting Board requires a petitioner to demonstrate that the proposed route for the facility is superior to the alternative route on the basis of balancing cost, environmental impact and reliability of supply. Eversource Mystic-East Eagle at 76-77;
Eversource Walpole-Holbrook at 38-39; Eversource Mystic-Woburn at 33.
An assessment of all impacts of a proposed facility is necessary to determine whether an appropriate balance is achieved both among conflicting environmental concerns as well as among environmental impacts, cost and reliability. A facility that achieves that appropriate balance meets the Siting Board’s statutory requirement to minimize environmental impacts at the lowest possible cost. Eversource Mystic-East Eagle at 77; Eversource Walpole-Holbrook at 39; Eversource
Mystic-Woburn at 33.
In order to determine if a petitioner has achieved the proper balance among various environmental impacts and among environmental impacts, cost and reliability, the Siting Board determines if the petitioner has provided sufficient information regarding environmental impacts and potential mitigation measures to enable the Siting Board to make such a determination. The
-59- Siting Board then determines whether environmental impacts would be minimized. Similarly, the
Siting Board evaluates whether the petitioner has provided sufficient cost and reliability information in order to determine if the appropriate balance among environmental impacts, cost and reliability is achieved. Russell Biomass, LLC and Western Massachusetts Electric Company,
17 DOMSB 1, EFSB 07-4/D.P.U. 07-35/07-36, at 28-29; Cape Wind Associates, LLC and
Commonwealth Electric Company d/b/a NSTAR Electric, 15 DOMSB 1, EFSB 02-2, at 53 (2005);
Cambridge Electric Light Company, 12 DOMSB 305, EFSB 00-3/D.T.E. 00-103, at 24 (2001)
(“Cambridge Electric”).
Accordingly, the Siting Board examines the environmental impacts, reliability and cost of the proposed facilities along the routes under consideration for approval to determine whether:
(1) environmental impacts will be minimized; and (2) an appropriate balance will be achieved among conflicting environmental impacts as well as among environmental impacts, cost and reliability. In this examination, the Siting Board compares the primary and alternative routes to determine which is superior with respect to providing a reliable energy supply for the
Commonwealth with a minimum impact to the environment at the lowest possible cost.
Eversource Mystic-East Eagle at 77; Eversource Walpole-Holbrook at 39; Eversource Mystic-
Woburn at 33.
The Company conducted a comprehensive analysis of the environmental attributes, reliability and costs of the Preferred Route, the Noticed Alternative Route and the Noticed
Variation and concluded that the Preferred Route is superior based upon a full consideration of reliability, costs and environmental factors. Therefore, the Company requests that the Siting Board approve the use of the Preferred Route for the Project.
-60- Environmental Impact Comparison of the Preferred Route, the Noticed Alternative Route and the Noticed Variation.
The Company performed a comparative analysis of adjacent land uses and environmental and cultural resources along the Preferred Route and the Noticed Alternative Route, evaluating the following environmental factors:35
(1) adjacent land use (Exh. EV-2, at 5-20 to 5-21); (2) traffic and transportation (Exh. EV-2, at 5-21 to 5-26); (3) wetlands and water resources (Exh. EV-2, at 5-26 to 5-28); (4) public shade trees (Exh. EV-2, at 5-28 to 5-29); (5) subsurface contamination (Exh. EV-2, at 5-29 to 5-31); (6) visual (Exh. EV-2, at 5-31); (7) electric and magnetic fields (Exh. EV-2, at 5-31 to 5-33); (8) noise (Exh. EV-2, at 5-33 to 5-36); and (9) cultural resources (Exh. EV-2, at 5-36 to 5-37).
Both the Preferred and Noticed Alternative Routes are entirely within public roadways or previously developed areas and would not require substantial removal of vegetation to facilitate construction. Exh. EV-2, at 5-19. Neither route would result in permanent impacts to the land use, environmental and cultural resources that were evaluated and the minor temporary impacts would be largely mitigated. Exh. EV-2, at 5-37. However, the Preferred Route is superior in three of the criteria evaluated and, coupled with additional considerations discussed below, the Preferred
Route has clear advantages. The following table provides a comparison of the two route alternatives based on the evaluation of these criteria.
35 All work proposed at the Andrew Square and Dewar Street Substations is the same and creates the same minimal impacts for both the Preferred Route and the Noticed Alternative Route. Therefore, this was not a factor in the Company’s route selection. Exh. EV-2, at 5-39.
-61- Land Use, Environmental and Cultural Resources Impact Comparison of the Preferred and Noticed Alternative Routes
Evaluation Criteria Morrissey Sydney Street Boulevard Noticed Alternative Preferred Route Route Land Use + - Cultural Resources = = Potential for Traffic + - Congestion Public Shade Trees = = Wetlands and Water - + Resources Potential for Subsurface = = Contamination Visual = = EMF = = Noise + - Notes: + Indicates less potential for impact, which means superior for use - Indicates more potential for impact, which means inferior for use = Indicates comparable impacts
Exh. EV-2, at 5-38. The Preferred Route is superior to the Noticed Alternative Route for the following criteria:
Land Use: The Preferred Route is longer but is adjacent to more commercial and industrial uses rather than residential uses. Exh. EV-2, at 5-21. The Noticed Alternative is adjacent to more residential uses and most of the route is along dense residential neighborhoods. Id. Because construction of the Project along the Preferred Route will allow for coordination with other proposed projects including the reconstruction of Morrissey Boulevard and the McCormack
Redevelopment, it offers a unique opportunity to minimize construction-related impacts to adjacent land uses. Id. Thus, because less of the Preferred Route is adjacent to dense residential neighborhoods and because the Company will be able to coordinate Project design and construction with other projects, the Preferred Route will have less land use impacts than the
Noticed Alternative. Id.
-62- Potential for Traffic Congestion: To compare potential traffic impacts of the Preferred
Route and Noticed Alternative Route, the Company reviewed existing traffic and parking conditions, roadway widths, travel lanes, and the presence of public bus service along each route, as well as the options for traffic mitigation along each route. Exh. EV-2, 5-22. Each route would require implementation of TMPs and close coordination with the City, DCR and neighborhood of
Dorchester to ensure that traffic delays are minimized. Id. Traffic management measures, including use of police details and implementation of detours and lane closures would be required regardless of the route selected. Id. While the Noticed Alternative Route scored more favorably in the transportation impact criterion than the Preferred Route for the routing analysis, additional factors were considered that reflected favorably for the Preferred Route, including:
(1) construction work hours will be more flexible along Morrissey Boulevard because there are no residential uses along it; (2) Morrissey Boulevard has a greater capacity to absorb the reduction of a lane during construction, and provides more flexibility for transportation management options;
(3) traffic impacts will be limited on Morrissey Boulevard during peak hours; (4) work will be conducted outside of travel lanes along Morrissey Boulevard, where possible, as portions of the route will be along the shoulders and median areas; (5) I-93 serves as a regional alternative route to avoid construction impacts along Morrissey Boulevard; (6) coordination with Winn
Development will minimize impacts to residents during work on O’Callaghan Way; and
(7) coordination with DCR will minimize transportation-related impacts along Morrissey
Boulevard. Thus, there are clear advantages to the Preferred Route with respect to traffic impacts to neighborhoods. Exh. EV-5, at 5-25.
Noise: The level of construction-related noise associated with underground line construction would be similar along most of the Preferred Route and the Noticed Alternative
-63- Route. Exh. EV-2, at 5-36. Moreover, because the Preferred Route will be performed in coordination with other construction projects, including the McCormack Redevelopment and the
Morrissey Boulevard redevelopment projects, the Company determined that the Preferred Route is superior to the Noticed Alternative Route from a construction noise perspective because it will be incrementally less impactful. Id. Also, the Preferred Route is adjacent to more commercial, industrial and institutional land uses, while the Noticed Alternative is located adjacent to more dense residential neighborhoods. Id.
Although the Noticed Alternative is superior with regard to the wetlands and water resources criteria, impacts associated with wetlands and water resources along the Preferred Route will be mitigated by limiting work within previously disturbed areas and through the coordination with other proposed construction projects, to the extent practicable.
One public shade tree will need to be removed or materially pruned on the Preferred Route.
Exhs. EV-2, at 5-28; EFSB-V-4; EFSB-V-9. However, the Company will coordinate with the
Boston Tree Warden and the adjacent landowner regarding mitigation. Exh. EV-2, at 5-27; Tr. 2, at 249-250. Similar impacts to public shade trees would be anticipated along the Noticed
Alternative Route, where there are more shade trees along that route. Exh. EFSB-V-4. For all other criteria, impacts resulting from construction of the Project on the Preferred Route would be similar to the impacts resulting from the construction of Project on the Noticed Alternative Route.
Exh. EV-2, at 5-38.
The Company coordinated with several stakeholders, including DCR, BHA/Winn,
MassDOT, and the BWSC, and received input from those entities on the Company’s route selection. Exhs. EV-2, at Table 4-1; EFSB-RS-3; EFSB-G-33; EFSB-G-35. BWSC expressed a strong preference for the Morrissey Boulevard Route and their input was particularly relevant in
-64- that it was very familiar with underground utilities and subsurface conditions that would impact the installation of a new electrical transmission line. Id.; Tr. 1, at 68-69. Based on analysis of the existing conditions, including a survey of existing underground utilities along each route, and with stakeholder input, the Preferred Route was chosen for the following reasons:
• Underground utility density is less than on roadways along the Noticed Alternative route, including Dorchester Avenue, allowing for more efficient installation, and fewer conflicts with existing infrastructure. • Successful pipe jacking had previously occurred under I-93 and MBTA tracks in the vicinity of 65 Bay Street and Springdale Avenue. • The single water crossing is at an existing culvert, and the design intends to use an existing utility bay within the culvert to avoid impacts to the water body. • The Company is coordinating construction of the Project with planned redevelopment projects by DCR and BHA along the Preferred Route, resulting in reduction of impacts to community members and a reduction in Project cost associated with curb-to-curb paving.
Exh. EFSB-RS-3; Tr. 1, at 25; 71; 89.
As the Project advances from preliminary design to a final design phase and then transitions into the construction phase, the Company will continue to minimize potential impacts to the natural and developed environments affected. Id.; EV-2 at 4-2; 5-13. The Project will be designed and constructed to incorporate all necessary best management practices; comply with federal, state, and local rules and regulations; and provide mitigation for any impacts that cannot be avoided.
Id.; EV-2, at 4-2; 5-13.
Cost Comparison of the Preferred Route and Noticed Alternative Route.
Consistent with Siting Board precedent, the Company performed certain field engineering, which enabled it to develop a planning grade cost estimate, with a -25%+25% level of accuracy, for the Preferred Route and a conceptual grade estimate, with an accuracy of -25% to +50%, for the Noticed Alternative Route. Exhs. EV-2, at 5-38; EFSB-C-1. The Company estimated the cost of the Preferred Route to be approximately $68.3 M and the Noticed Alternative Route to be
-65- approximately $69.6 M. Exh. EV-2, at 5-38. The estimated costs for both routes reflect that the underground line needs to be constructed in a very densely populated urban area, with significant underground utility density. Exh. EFSB-C-4. This leads to lower productivity rates during construction due to the time and cost involved in relocating utilities to clear the way for the installation of the duct bank without any adverse impacts to existing infrastructure. Id. Based on the current cost estimates, the Preferred Route is slightly preferable to the Noticed Alternative
Route. Exh. EV-2, at 5-38. Even though the Noticed Alternative is a shorter length, the cost estimate is somewhat greater due to engineering and construction-related challenges along this route, including proximity to existing transmission facilities and density of underground utilities.36
Id.; Exh. EFSB-C-3; Tr. 1, at 89-91. Construction-related challenges that cause the higher cost of the Noticed Alternative Route versus the Primary Route include utility density, population density, street width, and the number of intersections. Exh. EFSB-C-6; Tr. 1, at 89-94.
Reliability Comparison of the Preferred Route and the Noticed Alternative Route.
The Preferred Route and Noticed Alternative Route are each a reliable means for providing a 115-kV line connection between Andrew Square Substation and Dewar Street Substation. Exh.
EV-2, at 5-38. However, the Noticed Alternative Sydney Street Route would present a potential single point of failure for three underground transmission lines because the New Line would be installed on significant portions of the same street containing the two existing K Street – Dewar
Street 115-kV lines. Id. Future physical road construction, including saw cutting the road or the installation of other gas/sewer/water facilities on Sydney Street, could compromise and breach the
36 Due to significant existing utility congestion in Dorchester Avenue, the duct bank would need to be locate deeper than otherwise or other utilities would need to be relocated to find room for the new infrastructure. Tr. 1, at 89-90. This relocation of utilities or deeper construction installation would impact both cost and schedule. Tr. 1, at 91- 93.
-66- integrity of the electric transmission infrastructure, resulting in the simultaneous outage of all three
115-kV underground transmission lines supplying Dewar Street Substation. Id. The outage of these three underground transmission lines would result in a prolonged loss of supply to Dewar
Street Substation. Id. Therefore, it is far preferable to route the New Line in a different street from where the existing K Street-Dewar Street 115-kV lines are located. Id. Although not always feasible, routing a new line in a location where there are not existing electric transmission lines provides a substantial improvement in the reliability of transmission supply to substations. Id.
Therefore, because the Preferred Route provides the opportunity to locate the New Line is a different location from existing in-street transmission lines, it is superior to the Noticed Alternative from a reliability perspective. Id.
Conclusion on Route Alternatives Comparison.
The Preferred Route has fewer potential impacts to adjacent land uses and is superior with respect to the potential for traffic and noise impacts. Exh. EV-2, at 5-20 – 5-26, 5-33 – 5-36. The cost estimate for the Preferred Route is slightly less than that of the Noticed Alternative Route and will be superior from a reliability perspective. Exh. EV-2, at 5-38 – 5-39. Moreover, the Morrissey
Boulevard Route was determined to be superior route because it provides the potential opportunity for coordination with DCR on the reconstruction of Morrissey Boulevard and with the McCormack
Redevelopment. Lastly, this route was favored because of the known ability to pipe jack under I-
93 and the MBTA tracks near the Dewar Street Substation and less potential for interference with future infrastructure within the roadways. Id. Accordingly, the Company requests that the Siting
Board approve the use of the Preferred Route for the Project.
-67- E. The Company Has Appropriately Identified and Proposed Measures to Mitigate Environmental Impacts.
Consistent with Siting Board standards, the Company conducted a detailed analysis of the environmental impacts of the Project and has shown that these impacts are largely temporary in nature and will be minimized to the extent practicable. The Company has thoroughly identified and evaluated a full range of environmental impacts, including construction, wetlands and water resources, historic and cultural resources, traffic and transportation, public shade trees, hazardous waste, visual, EMF, noise, and protected habitats. See, e.g., Exhs. EV-2, at § 5.0.
Construction
As a general matter, construction impacts will be temporary and will be limited to the period of time required for construction, which the Company anticipates will occur over an approximately 20-month period. Exh. EV-2, at 5-15. Construction hours will be developed in consultation with the City and DCR; however, in accordance with the City noise ordinances, the
Company proposes to work between 7:00 a.m. and 6:00 p.m. on weekdays. Id. DCR may require alternate construction hours in non-residential areas. The Company will coordinate with the City and DCR to seek approval when work outside of these hours is necessary. Id. The Company will also coordinate with the City, DCR and the MBTA to determine areas where construction hours may be limited (e.g., in front of schools, MBTA stations, etc.). Id. In certain locations, night work may be proposed to allow advancement of Project construction in areas with traffic congestion or other construction projects being advanced simultaneously. Id.
Construction mitigation measures will help minimize the potential for temporary impacts to the human and natural environments. Exh. EV-2, at 5-15. Typical mitigation for stormwater runoff and associated erosion and sedimentation, fugitive dust, construction vehicle emissions and soils and solid waste management are discussed below for underground line construction. Id.
-68- a. Stormwater Runoff, Erosion and Sedimentation Control
The Company will develop and maintain a Stormwater Pollution Prevention Plan
(“SWPPP”) for the Project that will identify controls to be implemented to mitigate the potential for erosion and sedimentation from soil disturbance during construction. Exhs. EV-2, at 5-16;
EFSB-W-6. The SWPPP will include a construction personnel contact list, a description of the proposed work, stormwater controls and spill prevention measures, and inspection practices to be implemented for the management of construction-related storm water discharges from the Project.
Exh. EV-2, at 5-16. The SWPPP will be adhered to by the contractor during all phases of Project construction in accordance with the general conditions prescribed in the Project’s U.S.
Environmental Protection Agency (“USEPA”) Stormwater Construction General Permit. Id.
The Company will require that the construction contractor designate a construction supervisor or equivalent to be responsible for coordinating with the environmental monitor, conducting regular inspections, ensuring compliance with permit requirements, providing appropriate training and direction to the construction crew regarding compliance with Project permits and approvals and construction mitigation commitments. Exh. EV-2, at 5-17.
Construction personnel will undergo pre-construction training on appropriate environmental protection and compliance obligations prior to the start of construction of the Project. Id. Copies of all permits and approvals will be provided to and reviewed by the Company’s project managers and construction supervisors and will also be provided to contractors prior to construction as part of the contract documents. Id. The Company requires contractors to keep copies of these documents on site and available to all Project personnel during construction. Id. These documents and applicable conditions will also be reviewed during the construction kick-off meeting in the
-69- field between Company representatives and contractor personnel. Id. Regular construction progress meetings will be held to reinforce contractor awareness of these mitigation measures. Id.
An environmental monitor working on behalf of Eversource will periodically conduct inspections of erosion and sediment controls and ensure compliance with the Company’s construction procedures and environmental policies, and with federal, state and local permit requirements and conditions. Exh. EV-2, at 5-16. In roads where work is to be performed adjacent to storm drains and stormwater is directed to a storm drain, the Company will install and maintain filter fabric barriers to prevent sediment from entering the storm drain system, which will be removed when construction is complete. Id.
Other measures to mitigate soil erosion will include the prompt removal of soils from the excavated trench. Exh. EV-2, at 5-17. Soils will not be stockpiled along the road(s) but instead will be loaded directly into trucks to be hauled to an offsite disposal/re-use area, or to a temporary construction laydown area to limit the potential for soils to be washed with stormwater into nearby storm drains. Id.
b. Air Quality
Dust will be controlled at the construction sites by the use of dump trucks to move soil out of the construction zone and by covering temporary soil stockpiles. Exhs. EV-2, at 5-5, 5-8 and
5-18; EFSB-A-3. The Company may also require contractors to place water trucks with misters in or near the work areas during construction activities to be used in combination with street sweeping within the roadway construction areas. Id.
In addition, the Company uses ultra-low sulfur diesel (“ULSD”) fuel in its own diesel- powered construction equipment and will direct its contractors to retrofit any diesel-powered non- road construction equipment rated 50 horsepower or above to be used for 30 or more days over
-70- the course of the Project with USEPA-verified (or equivalent) emission control devices (e.g., oxidation catalysts or other comparable technologies). Exh. EV-2, at 5-18. ULSD has a maximum sulfur content of 15 parts per million as opposed to low sulfur diesel fuel, which has a maximum sulfur content of 500 parts per million. Id. By using ULSD fuel, there is a 97 percent reduction in the sulfur content as compared to low sulfur diesel fuel.
The Company and its contractors will also comply with state law (G.L. c. 90, § 16A) and
MassDEP regulations (310 C.M.R. 7.11(1)(b)), which limit vehicle idling to no more than five minutes. Exh. EV-2, at 5-18. There are exceptions to these idling requirements for vehicles being serviced, vehicles making deliveries that need to keep their engines running, vehicles that need to run their engines to operate accessories and when idling is absolutely necessary (e.g., as a matter of safety). Id. It is the responsibility of every person on a job site to be in full compliance with all safety and environmental rules and policies and supervisors and foremen are responsible for enforcement of these rules on a continuous basis. Id. In addition, the use of anti-tracking pads and regular sweeping of the pavement of adjacent roadway surfaces during the construction period will minimize the potential for construction traffic to kick up dust and particulate matter. Id.
c. Construction Wastes
Waste materials generated along the route during installation of the transmission duct bank and manholes will be promptly removed and re-used or properly disposed of at a suitable facility.
Exh. EV-2, at 5-18. The largest quantity of construction waste will likely be from soils excavated from the trench and locations where manholes are installed. Id. This material will be removed from the trench and hauled to an appropriate off-site disposal/re-use location or to a temporary construction laydown area for on-site re-use. Id. Concrete and asphalt will be recycled at a local asphalt plant. Id. In the event contaminated soil or other regulated materials are encountered along
-71- the route, soils will be managed pursuant to the Utility-Related Abatement Measure (“URAM”) provisions of the Massachusetts Contingency Plan (“MCP”) at 310 C.M.R. 40 et seq. Id. The
Company will contract with a licensed site professional as necessitated by conditions encountered along the Project alignment, consistent with the requirements of the MCP. Id.; Exh. EFSB-CM-
17.
d. Dewatering Protocols
If groundwater is encountered during construction, it will be recharged back to the subsurface if feasible, by either discharging back in the open excavation or discharging to the nearby ground surface via a filter bag or dewatering corral (if necessary). Exh. EV-2, at 5-19. If on-site recharge of groundwater is not an option, either a vacuum truck will be used to pump out and appropriately dispose/recycle groundwater encountered or it will be discharged into the municipal stormwater and/or sewerage systems (with coordination with, and written consent of, the City and USEPA beforehand). Id.
Based on the above, the Company has properly minimized construction impacts associated with the Project.
Land Use
The potential for the Project to affect land use is very limited because all construction will be underground in City streets. Exh. EV-2, at 5-19. Temporary impacts to residences, businesses and sensitive receptors may include traffic disruption, including road closings and construction noise. Id. at 5-21. Construction hours will be limited in the vicinity of schools and proper construction best management practices will be in place to reduce noise and air quality impacts.
Id. There will be no permanent impacts to land use, environmental or cultural resources. Id. There will be no changes to land use resulting from the work at the Andrew Square and Dewar Street
-72- Substations as all work will be performed within the existing substation properties. Exh. EV-2, at
5-3 and 5-7.
Thus, the Company has properly minimized land use impacts associated with the Project.
3. Parkland Impacts
Portions of the Project route along Morrisey Boulevard are on land under the care and control of DCR.37 Exh. EFSB-RS-1. Along that stretch, the transmission line will be routed within the median, which is the preference of DCR. Id.; Tr. 1, at 62. The Company obtained confirmation from DCR counsel that, as long as the Project route remains in the paved roadway or median of
Morrissey Boulevard, approval pursuant to Article 97 of the Amendments to the Constitution of
Massachusetts (“Article 97”) would not be required. Exhs. EFSB-G-32 and RR-EFSB-2; Tr. 1, at
61. Thus, only a grant of location and a construction access permit would be needed for that work along Morrisey Boulevard. Id.
Approximately 322 linear feet of the Project route is along Springdale Street, a paper street and a private way that is adjacent to McConnell Park on one side and two privately-owned parcels and one City-owned parcel on the other. Exhs. EFSB-G-42; EFSB-LU-14; RR-EFSB-33; Tr. 2, at 150-151. The City owns McConnell Park and the adjacent portion of Springdale Street to the centerline. Id.; EFSB-LU-15. The City also owns the portion of Springdale Street to the centerline that is adjacent to the City-owned parcel on the north side of Springdale Street. Exh. EFSB-LU-
14(1). Most of Springdale Street is grassed over. Tr. 2, at 152-153. There are existing municipal utilities in Springdale Street and the City is proposing to install a stormwater/sewer system in the private way to address water runoff at McConnell Park. Tr. 2, at 152-153.
37 Article 97 provides that state- and municipal-owned lands and easements originally taken or acquired as natural resource land cannot be used or disposed of for other purposes, except by a law enacted by a two-thirds vote of each branch of the Legislature. Property in the care, custody or control of the DCR is assumed to be subject to Article 97.
-73- Based on conversations with the City, the City considers the portions of Springdale Street that are adjacent to City-owned property to be open space and an extension of the park and, therefore, subject to Article 97.38 Exhs. EFSB-G-37; Tr. 2, at 150. Accordingly, the Company will seek to acquire rights under Article 97 to install the lines as proposed within the road layout of Springdale Street.39 Tr. 2, at 150-151. There are no permanent impacts to Article 97 lands along the Project route, as the Project will be installed entirely underground.
Thus, the Company has properly minimized impacts to parkland associated with the
Project.40
4. Traffic and Transportation Impacts
Traffic impacts associated with the Project will be temporary in nature and confined to the period necessary to construct the Project. Exh. EV-2, at 5-21. Work within areas of traffic congestion or near certain sensitive receptors (e.g., schools, hospitals, MBTA stations, fire and police stations) will be managed to minimize impacts to traffic and disturbances affecting nearby residences and businesses. Id. at 5-22. A variety of mitigation measures will be used as part of
38 Prior to filing the Petition, the Company undertook research to determine whether the City acquired its fee interest in Springdale Street for park purposes or whether the way is otherwise subject to Article 97. Exh. EFSB-G-42; Tr. 2, at 152-153. It is the Company’s view that the City did not acquire the fee in Springdale Street as parkland and has not taken steps to convert that portion of Springdale Street into parkland and, therefore, the Company believes that Springdale Street is not subject to Article 97. Id.; Tr. 2. at 174-175. The City does not dispute the Company’s research but views the way as an extension of McConnell Park and believes the public also views it as such. Id. In support of the City’s position, the Company will proceed to obtain the rights for the line installation under Article 97. Id. 39 As a result of the Company’s decision to seek rights under Article 97 to install the transmission line in Springdale Street, the Project is now subject to discretionary review under the Massachusetts Environmental Policy Act (“MEPA”), G.L. c. 30, §§ 61-62I for “conversion of land held for natural resource purposes” per 310 CMR 11.03(1)(b)(3). Tr. 2, at 156. The Company will soon file an Environmental Notification Form with MEPA. Id. at 158. Because no other MEPA thresholds are triggered (i.e., there are no wetland or rare species impacts associated with the Project), the Company believes further MEPA review in the form of an Environmental Impact Report will not be required. Id. 40 As for other areas of Project construction, the Company will undertake outreach initiatives for abutters along Springdale Street and users of McConnell Park regarding construction. Tr. 2, at 190. Access will be provided for abutters, the trench will be plated each night, temporary fencing would be installed to secure the work site, police details will be used, as appropriate, for traffic control and pedestrian monitoring. Tr. 2, at 190-194.
-74- the implementation of the Project TMPs that will minimize traffic disruption during construction and, consequently, reduce the potential for inconvenience to drivers and those using public transportation, as well as any potential secondary effects on local businesses.41 Id. Access to local businesses and residences will be maintained throughout Project construction. Id.; Exh. EFSB-
CM-7. The Company will meet with City officials and abutters to understand their access requirements. Exh. EFSBCM-7. The Company will also work with the MBTA to coordinate its work in front of the JFK/UMass MBTA Station to ensure minimal disruption. Exh. RR-EFSB-15.
During and after work hours, the Company will take appropriate measures to allow safe and unencumbered access to abutting residential, commercial and industrial properties. Id. As needed, road plates will be placed over any excavations to allow unencumbered access to abutting residential, commercial and industrial properties. Id.
Traffic impacts associated with substation improvements at the Andrew Square Substation are expected to be minor and temporary in nature because the substation property is large enough to accommodate any construction vehicles and staging areas. Exh. EV-2, at 5-5 and 5-7.
The Company is committed to minimizing and mitigating traffic impacts associated with
Project construction to the maximum extent practicable. Exhs. EFSB-T-13; EFSB-T-18. In particular, the Company will work closely with DCR, MassDOT and the City to develop TMPs for construction. Exh. EFSB-T-4; Tr. 2, at 215. The TMP will include active and passive traffic management measures, including the use of police details, at appropriate locations. Topics to be addressed in the TMP will include:
• Width and lane location of the work zone to minimize impacts to vehicular traffic;
41 In developing the TMP, the Company uses the Manual on Uniform Traffic Control Devices for Streets and Highways published by the Federal Highway Administration, which defines standards for traffic control devices on all public streets, highways, bikeways and private roads open to public travel. Exh. EFSB-CM- 20.
-75- • Work schedule and duration of lane closures, road closures, or detours (where applicable);
• The use of traffic-control devices such as barricades, reflective barriers, advance warning signs, traffic regulation signs, traffic-control drums, flashers, detour signs, and other protective devices to be placed as shown on plans and as approved by the City and DCR;
• Locations where temporary provisions may be made to maintain access to homes and businesses;
• Routing and protection of pedestrian and bicycle traffic;
• Maintenance of MBTA service and school bus service;
• Communication with adjacent businesses, so critical product deliveries are not interrupted by construction;
• Determination of the impact to roadway level of service due to short-term lane closure(s);
• Notification of municipal officials, local businesses and the public of the timing and duration of closed curbside parking spaces and travel way restrictions; and
• Coordination between the Company and police and fire departments to ensure that emergency access through the route be provided at all times.
Exhs. EV-2, at 5-26; EFSB-T-5; EFSB-T-9; EFSB-T-11; EFSB-T-14. The scope of the TMP will include analysis of the roads affected by construction. Id. The TMP will be submitted for review and approval by appropriate state and municipal authorities prior to construction. Id. Traffic- control plans will be developed consistent with the FHWA Manual of Uniform Traffic Control
Devices for Streets and Highways and the MassDOT publication, “Work Zone Safety.” Id. The
Company will closely coordinate with local officials and abutting property owners. Id.; Tr. 1, at
82-83.
The Company has prepared preliminary draft staging plans as a precursor to the more detailed TMPs. Exhs. EFSB-T-10; EFSB-T-16; RR-EFSB-16. The preliminary plans are based on the current design of the Project and are subject to coordination with and input from the City and DCR. Id. Additional information (e.g., information from the ongoing geotechnical borings
-76- and test pit program) can be expected to result in some changes to the transmission line alignment and thus the plans. Id.
Lastly, in addition to the development of TMPs, to further mitigate traffic and other construction-related impacts, the Company will execute a comprehensive construction community outreach plan to keep property owners, businesses, and municipal officials, including fire, police, and emergency personnel, up-to-date on planned construction activities. Exhs. EFSB-T-3; Tr. 2, at 227. In sum, the Company has extensive experience constructing utility infrastructure projects in urban environments. Exh. EFSB-T-18. While there may be traffic delays, such delays are temporary and police details will be able to keep traffic moving through the construction area. Id.
The Company is committed to working closely with the City, local businesses and residents to minimize traffic impacts from the Project to the maximum extent possible through the mitigation measures described above. Id.
Based on the above, the Company has properly minimized traffic impacts.
5. Wetlands and Water Resources
Wetland and water resources include river crossings, wetland crossings, riverfront area and
Chapter 91 jurisdiction limits. Exh. EV-2, at 5-26. Regarding wetlands, approximately 488 linear feet within Buffer Zone and 24,212 square feet of Bordering Land Subject to Flooding and Land
Subject to Coastal Storm Flowage will be crossed by the Project. Id. at 5-27. Approximately
14,517 square feet of tidelands, including historically filled tidelands, with the jurisdiction of G.L. c. 91 will be crossed by the Project. Id. In addition, the Project will involve one waterbody crossing (Savin Hill/Pattens Cove), where the New Line would be constructed in a utility bay within an existing culvert. Id.; Tr. 1, at 71; Tr. 3, at 322. Given that the underground cable construction associated with the Project will be within existing paved roadways and disturbed
-77- ROWs, no permanent impacts to wetlands or streams are anticipated. Id. There are no wetland or water resources on or near the Andrew Square and Dewar Street Substations. Id. at 5-3 to 5-8.
The potential temporary impacts are limited because resource areas described above are previously disturbed areas and areas proposed for redevelopment. Id. at 5-27. Moreover, the
Project will not require any filling or clearing within vegetated wetlands. Id. To address the potential for erosion and sedimentation within wetland resource areas, a SWPPP will be prepared for the Project that will specify erosion control measures to be implemented. Id.; Exh. EFSB-W-
6; Tr. 3, at 321. Furthermore, the Eversource BMP manual will be followed. Id.; Exh. EFSB-W-
7. The Company is committed to protecting wetlands and water resources through the mitigation measures as described above.
Accordingly, the Company has properly minimized impacts to water resources.
6. Public Shade Trees
The Company anticipates that only one tree will need to be removed or materially pruned as part of Project construction. Exh. EFSB-V-4; EFSB-V-9. This tree is within the sidewalk of
Playstead Avenue and is located near the trench for the new line. Id.; Exh. EFSB-V-9; Tr. 2, at
249-250. No permanent impacts to the other 43 public shade trees identified along the Project route are anticipated as part of the installation of the underground transmission line. Exh. EV-2, at 5-28. As is typical for this mostly residential environment, the canopies of certain trees extend out over the road. Id. Given the tree canopy in some locations, select tree trimming may be required to accommodate construction equipment. Id.; Exh. EFSB-V-10. Prior to construction, the Company will review locations where trees are in close proximity to the Project and will document the existing condition of the trees at those locations. Exh. EV-2, at 5-29. Tree protection protocols will be reviewed with the local tree warden at that time. Id. Where tree roots are encountered during excavation, mechanical excavation will cease, roots will be exposed by hand
-78- (to the least extent possible) and will be kept moist and covered with wet burlap or plastic throughout the exposure period. Id. Thermal backfill will be placed in the trench in a manner to avoid impacting tree roots. Id. The Company will work with the City to identify appropriate mitigation for trees that are affected by construction and will commit to replacement of trees or vegetation on a one-to-one basis with compatible tree or vegetation species. Exh. EFSB-V-4. The proposed improvements to the Dewar Street and Andrew Square Substations are not anticipated to affect public shade trees. Exh. EV-2, at 5-5 and 5-8.
Based on the above, the Company has properly minimized impacts to public shade trees.
7. Use of Sulfur Hexafluoride
Circuit breakers and gas-insulated bus work that will be installed as part of the Project at both the Dewar Street and Andrew Square Substations will contain sulfur hexafluoride (“SF6”).
Exhs. EV-2, at 5-4 and 5-7; EFSB-A-1. Eversource tracks SF6 data on a system-wide basis following USEPA guidelines. Id. at 5-4; Exh. EFSB-A-2. New equipment installed for the Project will be specified for an annual emission rate of 0.1%, which complies with the Massachusetts standard of 1.0% per year (310 C.M.R. 7.72). Id. SF6 is shipped in cylinders approved by the
Department of Transportation and is handled in accordance with the gas and equipment manufacturers’ work practices. Id. New SF6 equipment is filled by Eversource or by qualified contractor personnel working under Eversource supervision, who have been trained by the equipment manufacturer and follow the equipment filling and topping off instruction guides. Id.
When equipment is retired, the SF6 gas is recovered and reclaimed by a vendor, minimizing atmospheric releases. Id. Eversource continues to participate in the SF6 emissions reduction partnership Memorandum of Understanding that it entered into with the USEPA in December 2003 and monitors and reports its annual usage and leakage of SF6 in accordance with the terms of that
-79- agreement. Id. Eversource also reports its annual leakage of SF6 according to the USEPA’s
Mandatory Greenhouse Gas Reporting Rule. Id.
Based on the above, the Company has properly minimized impacts regarding its use of SF6 for the installation and operation of new equipment at the substations.
8. Subsurface Contamination
Subsurface excavation associated with the Project has the potential to encounter contaminated soils from historical releases and/or urban fill in the vicinity of the Project. Exh.
EV-2, at 5-29. There are nine historic contaminated sites located within 500 feet of the Project route. Id. There is one historic contaminated site located approximately 200 feet from the Andrew
Square Substation and one historic contaminated site located approximately 500 feet from the
Dewar Street Substation. Exh. EV-2, at 5-5 and 5-8. The potential to encounter subsurface contamination associated with those two sites is minimal. Id. There is an Activity and Use
Limitation (“AUL”) on the Andrew Square Substation property; accordingly, the proposed construction at the Andrew Square Substation site will be completed in accordance with the AUL and the URAM provisions of the MCP. Id. at 5-5.
The Company will undertake an extensive soil and groundwater pre-characterization program to properly characterize the soils and groundwater for management during construction.
Exhs. EV-2, at 5-13; EFSB-CM-17. Any contaminated soils encountered during Project construction will be managed pursuant to the URAM provisions of the MCP. Id. at 5-30. The
Company will prepare a soil and groundwater management plan and will contract with a licensed site professional as necessitated by conditions encountered along the Project alignment, consistent with the requirements of the MCP. Id. All excess soil will be managed in accordance with local,
State and Federal regulations. Id.
-80- Based on the foregoing, the Company has potential minimized impacts from subsurface soil contamination.
9. Safety and Health Considerations
The Company will design, construct and maintain the Project so that the health and safety of the public are protected. Exh. EV-2, at 6-1. This will be accomplished through compliance with all applicable federal, state and local safety regulations, as well as industry standards and guidelines established for assuring worker safety and the protection of the general public. Id. For example, all construction sites will adhere to the Federal Highway Administration’s Manual of
Uniform Traffic Control Devices to ensure that both vehicular and pedestrian traffic are safely routed around all street and curbside construction activities. Exhs. EV-2, at 5-26; EFSB-S-6;
EFSB-S-7; Tr. 3, at 334-335. The facilities will be designed in accordance with sound engineering practices using established design codes and guides published by, among others, the Department, the Institute of Electrical and Electronic Engineers, the American Society of Civil Engineers, the
American Concrete Institute and the American National Standards Institute. Id. Following construction of the facilities, all transmission structures and substation facilities will be clearly marked with warning signs to alert the public to potential hazards. Id.
10. Visual Impacts
Because the transmission line portion of the Project is underground, the only potential temporary visual impacts are associated with trimming of tree canopy during construction of the transmission line. Tr. 2, at 252-253. Only one public shade tree will be removed or materially pruned as part of the Project. Exh. EFSB-V-9; Tr. 2, at 249-250. The Company will reach out to the adjacent property owner to discuss visual mitigation measures as appropriate. Tr. 2, at 249-
250. No other shade trees are anticipated to be directly impacted by the installation of the
-81- underground transmission line within the existing paved roadways of the Project route. Exh. EV-
2, at 5-31.
The Andrew Square Substation is surrounded by commercial and residential uses on three sides with train tracks and the Southeast Expressway on the fourth side. Exh. EV-2, at 5-7; Exh.
EFSB-V-2. All equipment proposed at the Andrew Square Substation for the Project except for a single, 75-foot-high shielding mast, will be below the height of existing station equipment and is expected to have a minimal visual impact. Id. The proposed construction is likely to require the removal of one tree that is within the fence line of the Andrew Square Substation. Exh. EFSB-
V-8. The removal of this tree is anticipated to have minimal visual impacts from Boston Avenue as it is located behind the Substation fencing and there are other trees that are within proximity to this tree that will remain. Id.; Tr. 2, at 245-246. The existing landscaping, fencing and walls will adequately screen the proposed equipment except for the shielding mast, for which there is no practical screening method. Id. Accordingly, no new visual buffering is proposed for the Andrew
Square Substation. Id.; Tr. 2, at 246.
The Dewar Street Substation is located at the end of a dead-end street, and is surrounded by commercial uses (contractor yards, bus storage, etc.) on three sides and by the train tracks and the Southeast Expressway on the fourth side. Exh. EV-2, at 5-7; Exh. EFSB-V-2. The equipment proposed for the substation will be slightly higher than the highest point of the existing transformers. Id. Because of the location and surrounding uses at the Dewar Street Substation and the height of the equipment proposed to be installed the Project, no new visual buffering is proposed for the Dewar Street Substation. Id.; Exh. EFSB-V-7; Tr. 2, at 245-246.
Based on the above, foregoing, the Company has minimized the visual impact of the
Project.
-82- 11. Electric and Magnetic Fields
Because the New Line is proposed underground, there will be no external electric field created. Exh. EV-2, at 5-32.
Most of the Project will be under public roadways, though some sections are proposed to be constructed under the sidewalks or other pedestrian areas. Exhs. EFSB-MF-1; EFSB-LU-1;
EFSB-MF-10. There are five locations where the current alignment is routed out of the roadway.
Exh. EFSB-MF-10.
The Company modeled magnetic field levels associated with the New Line both within and at the edges of the ROW at sections representative of the post-Project circuit configurations under average annual loading conditions:
Magnetic Field milligauss (mG) Section Configuration +/- 25 feet Max Above Cable Average Load 1.1 13 Trench Peak Load 1.4 17 Average Load 1.8 18 Splice Vault Peak Load 2.3 22 Average Load 1.8 21 Flat Section Peak Load 2.2 27
Id. The calculated magnetic field levels associated with the Project are many times lower than the health-based guidelines issued by the International Commission on Non-Ionizing Radiation
Protection for continuous public exposure to magnetic fields (2,000 milligauss [mG]; ICNIRP,
2010). Id.
The Company will implement measures to reduce magnetic fields from the proposed transmission lines, including providing the minimum phase spacing possible, while maintaining
-83- the transmission line thermal capability. Additionally, by configuring the cables in a delta configuration, magnetic fields have been further reduced. Exh. EFSB-MF-5.
Based on the above, the Project will not have a significant effect on EMF and, thus, magnetic field impacts associated with the Project have been properly minimized.
12. Noise Impacts
The noise impacts associated with the Project are limited to temporary construction noise.
Exh. EV-2, at 5-33. Noise impacts from construction at both Andrew Square and Dewar Street
Substations will likewise be temporary in nature and will end when Project construction ends. Id.;
Exh. EFSB-NO-11. There will be no operational noise impacts from the Project, including at the substations. Id. The Company anticipates that the Project will comply with the City noise ordinances and regulations, as well as regulations of MassDEP. Exh. EFSB-NO-1.
There are four principal phases of construction for underground cable projects within the streets conducted in sequence at each location. Exh. EV-2, at 5-33. Several phases of construction will likely be ongoing simultaneously along various sections of the route, such as: manhole placement; roadway cutting; excavation of fill; conduit placement; and backfilling and temporary paving. Id. During later portions of the Project, cable pulling and splicing (electrical) phases may overlap with ongoing civil construction activities. Id. The potential for noise impacts from Project construction is a function of the specific receptors along the route as well as the equipment used and proposed hours of operation. Id. The sensitive receptors along the Project route are primarily residences. Exh. EFSB-NO-3. The anticipated duration of exposure varies depending on location but exposure is anticipated to be approximately two weeks for manhole installation, approximately two weeks for the pipe jacking operation and approximately one to two weeks for the installation of the duct bank. Id. Construction is anticipated to occur during normal work hours of Monday through Friday from 7:00 AM to 6:00 PM. Exh. EFSB-NO-5. At some locations, or at the request
-84- of the City or DCR, the Company may seek approval to work at night or on Saturdays. Exhs. EV-
2, at 5-33; EFSB-NO-5; EFSB-T-7; Tr. 2, at 222.
Transmission line construction will generate noise levels that are periodically audible along the Project route, at conductor pulling sites, and at staging areas. Exh. EV-2, at 5-33. The construction equipment to be used will be similar to that used during typical public works projects
(e.g., road resurfacing, storm sewer installation, water line installation). Id. In general, the sound levels from construction activity will be dominated by the loudest piece of equipment operating at the time. Id. Therefore, at any given Project location, the loudest piece of equipment will be the most representative of the expected sound levels in the area. Id. There are approximately 184 residential units on properties located within 50 feet from the proposed ductbank and manhole locations, with the closest residence measured to be approximately 12 feet away. Exhs. EFSB-
LU-6; EFSB-NO-9. In addition, there are approximately five sensitive receptors within 50 feet from the proposed ductbank and manhole locations, which include recreational facilities, schools, and churches. Exh. EFSB-LU-6. The closest structure to the proposed work considered to be a sensitive receptor is Our Lady of Czestochowa at the corner of Dorchester Avenue and Father
Songin Way, which is located approximately 20 feet away from the transmission line route. Exh.
LU-1(1). The closest residences to the Andrew Square and Dewar Street Substations are 25 feet and 430 feet, respectively. Exh. EFSB-LU-21.
The Company presented maximum sound levels from typical equipment that will be used during construction of the underground cable at a reference distance of 50 feet. Exh. EV-2, at
Table 5-10; Exh. EFSB-NO-2. The typical sound levels are based on actual field measurements recorded by Eversource noise consultants at similar projects in October and November 2015 and show that familiar sounds with similar noise levels that can be expected during Project construction
-85- include: lawn mower at 90 decibels (“dBA”), snow blower at 85 dBA, garbage disposal at 80 dBA and an air conditioner at 60 dBA. Id. Because sound levels from a point source drop off at a rate of six dBA per doubling of distance, the reference sound levels at 50 feet will decrease by six decibels for locations 100 feet back from the edge of construction. Id. For example, maximum backhoe sound levels at 100 feet would be expected to be approximately 74 dBA. Id. Construction equipment is generally not operated continuously and has significant variation in power and usage.
Id. Sound levels would fluctuate, depending on the construction activity, equipment type and separation distances between source and receiver. Id. Other factors, such as vegetation, terrain and noise attenuating features, such as buildings, will act to further reduce construction noise levels. Id. Regarding splicing activities, the Company’s actual field measurements taken during cable splicing operations show that the primary source of noise during splicing work is the generator providing power for the splicing operations, where sound levels from this operation ranged from 60 to 67 dBA at 50 feet. Exh. EV-2, at Table 5-10.
To minimize noise disturbances to adjacent residences during the construction of the
Project, the Company will endeavor to limit construction activities that potentially could generate excessive noise, to those hours allowed by the City. Exh. EFSB-NO-13. The Company will mitigate noise during construction by requiring:
• well-maintained equipment with functioning mufflers; • strict compliance with MassDEP’s Anti-Equipment Idling regulations; • use of only necessary equipment for the task; and • training of all construction contractors in the Company’s requirements with respect to well-maintained equipment, anti-idling and other relevant policies.42
42 The use of physical noise barriers is not typically the Company’s first response to addressing a claim of excessive noise. Exh. EFSB-NO-7; Tr. 3, at 266-268. The Company would first explore other opportunities to reduce noise, including requiring the use of newer, lower noise equipment. Id. If sound levels are still a concern, temporary noise barriers may be employed; however, noise barriers can substantially restrict movement within the work zone and can slow the pace of construction. Id. As much of the construction is linear and within traveled ROW, the use of temporary noise barriers can also further restrict traffic
-86-
Exhs. EV-2, at 5-36; EFSB-NO-6; Tr. 3, at 267-270. Noise from cable splicing operations would be minimized through use of specialized low sound equipment such as low-noise generators, and by reducing or eliminating the use of motorized equipment during evening and overnight work.
Id.
All construction noise associated with the Project is regulated by the City of Boston noise ordinances and the City of Boston Air Pollution Control Commission, as well as MassDEP. Exhs.
EV-2, at 5-35; EFSB-NO-1. Under the local regulations, the maximum dBA allowed as measured
50 feet from the source, is 86 dBA. As noted above, the typical sound levels for transmission construction at 50 feet, including splicing operations, is less than 86 dBA. Id. The City also limits to noise to 50 dBA at residential property lines between the hours of 6:00 PM and 7:00 AM, unless an off-hours permit is obtained from the Commission of Inspectional Services Department. Should off-hours construction be required, the Company will seek an Off-Hours Permit. Id; Exh. EFSB-
NO-1.
Based on the above, all daytime and nighttime noise impacts from the Project are predicted to fully comply with the applicable City noise ordinances, Boston APCC regulations and MassDEP noise policy when compared to measured background sound levels at the closest sensitive receptor locations. Id.
As the Company anticipates coordination with the McCormack Redevelopment, construction impacts in the vicinity of this high-density residential area will be minimized. Exh.
movement adjacent to the work zones. Id. The use of such equipment may introduce additional factors into the work environmental that could pose hazards to workers and the general public, such as restricting site lines and difficulty in anchoring these types of systems. Id. For these reasons, the Company typically does not consider the use of temporary noise barriers unless a complaint is made and cannot be resolved through implementation of other best management practices. Id.
-87- EV-2, at 5-36. Finally, the Company will work with its neighbors to inform them of the sequencing and timing of the construction activities.
Based on the above, noise impacts associated with the Project have been properly minimized.
13. Historic and Cultural Resources
Although the Project route passes or intersects numerous historic properties and archaeological sites, no direct or indirect impacts to these resources are anticipated. Exh. EV-2, at 5-37.43 The Project elements adjacent to historic properties or districts will consist only of in- street installation of the transmission line and the construction and operation of the Project will not affect any buildings or structures. Id. Neither the Dewar Street nor Andrew Square Substations is located within any National or Local Historic District or any Inventoried Area. Exh. EV-2, at
5-6, 5-8.
For these reasons, impacts to historic and archaeological resources have been minimized.
14. Conclusion on Environmental Impacts
As described above, the Company has demonstrated that its plans for the construction and operation of the Project have appropriately minimized environmental impacts associated with construction, land use, historic and cultural resources, traffic and transportation, wetlands and water resources, public shade trees, hazardous and solid waste, visual, EMF, noise, protected habitats and air.
43 The Project route passes adjacent to 56 registered or eligible historic properties and archaeological sites and intersects 5. There is one archeological site within 0.25 miles of the Project route. Exh. EV-2, at 5-37.
-88- F. The Project Is Consistent with the Current Health, Environmental Protection and Resource Use and Development Policies of the Commonwealth
Pursuant to G.L. c. 164, § 69J, the Siting Board shall approve a petition to construct a facility if, inter alia, the Siting Board determines that “plans for expansion and construction of the applicant’s new facilities are consistent with current health, environmental protection, and resource use and development policies as adopted by the commonwealth.” The Project not only satisfies the requirements of this statute, but also is fully consistent with other important state energy policies as articulated in the Electric Utility Restructuring Act of 1997 (the “Restructuring Act”), the Green Communities Act (Chapter 169 of the Acts of 2008) and the Global Warming Solutions
Act (Chapter 298 of the Acts of 2008). Exh. EV-2, at 6-1.
The Project Is Consistent with the Health Policies of the Commonwealth
The Project will be consistent with applicable health policies of the Commonwealth. The
Restructuring Act provides that reliable electric service is of “utmost importance to the safety, health, and welfare of the Commonwealth’s citizens and economy . . . .” See Restructuring Act,
§ 1(h). The Legislature has thereby expressly determined that an adequate and reliable supply of energy is critical to the state’s citizens and economy. The Project will be fully consistent with this policy because the Project will enhance the reliability of the electric power transmission system in the Project Area, enabling the Company to continue to ensure the availability of sufficient and reliable electric service to the citizens and businesses of the Commonwealth and the region, a matter that greatly affects public health and safety. Exh. EV-2, at 6-1. In addition, all design, construction and operation activities will be in accordance with applicable governmental and industry health and safety standards such as the National Electric Safety Code and OSHA regulations and will have no adverse health effects. Id.
-89- The Project Is Consistent with the Environmental Protection Policies of the Commonwealth
The Project is also consistent with the environmental protection policies as set forth in
Chapter 164 of the General Laws and in other state and local environmental policies. Exh. Ev-2, at 6-1. First, the Restructuring Act provides that the Company must demonstrate that the Project minimizes environmental impacts consistent with the minimization of costs associated with the mitigation, control and reduction of the environmental impacts of the Project. Id. Accordingly, an assessment of all impacts of a proposed facility is used to determine whether an appropriate balance is achieved both among conflicting environmental concerns, as well as among environmental impacts, costs and reliability. Id. As demonstrated above, the Company has proposed specific plans to carefully mitigate environmental impacts associated with the construction, operation and maintenance of the Project, consistent with cost minimization. Id. As such, the Project is consistent with the environmental policies of the Commonwealth as set forth in Chapter 164 of the General Laws and the Restructuring Act. Id.
More generally, the Project will obtain all environmental approvals and permits required by federal, state and local agencies and will be constructed and operated to comply fully with all relevant state and local environmental policies. Exh. EV-2, at 6-2 and Table 6-1. Thus, the Project will contribute to a reliable, low cost, diverse energy supply for the Commonwealth with minimal environmental impact. Id. By meeting the requirements for acquiring each of the requisite state and local permits, the Project will comply with applicable state and local environmental policies.
Exh. EV-2, at 6-2. In addition, the Project is consistent with the Commonwealth’s Environmental
Justice (“EJ”) Policy, as promulgated by the predecessor to the Executive Office of Energy and
Environmental Affairs (“EOEEA”) and as recently updated by then-Governor Patrick through
Executive Order #552, signed on November 25, 2014, because the Company has pursued an
-90- inclusive community outreach plan to facilitate the meaningful opportunity for stakeholders to participate in the Siting Board proceeding and because the Project does not exceed any environmental impact thresholds under MEPA that would necessitate enhanced analysis under the
EJ Policy. Exh. EV-2, at 6-2 to 6-3.
The Project is also fully consistent with the Green Communities Act. Exh. EV-2, at 6-3.
The Green Communities Act is a comprehensive, multi-faceted energy reform bill that encourages energy and building efficiency, promotes renewable energy, creates green communities, implements elements of the Regional Greenhouse Gas Initiative, and provides market incentives and funding for various types of energy generation. Id. The Green Communities Act (as amended and supplemented by St. 2012, c. 209, An Act Relative to Competitively Priced Electricity) can be expected to result in greater renewable supplies and substantial new conservation initiatives in future years. Id. The Project’s improvements to the transmission system will strengthen and support the load requirements in the Dorchester, South Boston and Roxbury neighborhoods of the
City of Boston, as well as ensure the reliability of transmission service to this area under an N-1-
1 contingency. The more robust system also will enable a more efficient and flexible operation of the grid consistent with the Green Communities Act. Id.
For similar reasons, the Project is likewise consistent with “An Act to Promote Energy
Diversity” (“Energy Diversity Act”), which Governor Charles Baker signed into law on August 8,
2016. St. 2016, c. 188. Exh. EV-2, at 6-4. The Energy Diversity Act is a multi-faceted energy bill that, among other things, facilitates the procurement and integration of renewable energy generation resources, including new offshore wind energy generation, firm service hydroelectric generation and new Class I RPS eligible resources. St. 2016, c. 188, § 12. The Project will improve the reliability of the regional transmission system and thereby create a more robust
-91- transmission system that is better able to accommodate various energy resources that may come online in the future as a result of the Energy Diversity Act. Exh. EV-2, at 6-4. Accordingly, the
Project is consistent with the Energy Diversity Act.
Lastly, the Project is consistent with the Global Warming Solutions Act (“GWSA”). Exh.
EV-2, at 6-3. The GWSA established aggressive greenhouse gas (“GHG”) emissions reduction targets of 25 percent from 1990 levels by 2020 and 80 percent from 1990 levels by 2050. Id.
Pursuant to the GWSA, the Secretary of the EOEEA issued the Clean Energy & Climate Plan for
2020 in December of 2010. Id. Among other provisions, the GWSA obligates administrative agencies such as the Siting Board, in considering and issuing permits, to consider reasonably foreseeable climate change impacts (e.g., additional GHG emissions) and related effects (e.g., sea level rise). Id. The proposed improvements will have no adverse climate change impacts or negative effects on sea levels. Id. Consequently, the Project is consistent with the GWSA. Id.
The Project Is Consistent with the Resource Use and Development Policies of the Commonwealth
The Project, which will contribute to the long-term maintenance and reliability of the electric transmission system in the Dorchester, South Boston and Roxbury neighborhoods of
Boston, will be constructed and operated in compliance with Massachusetts’ policies regarding resource use and development. Exh. EV-2, at 6-4. For example, in 2007, the EOEEA’s Smart
Growth/Smart Energy policy established the Commonwealth’s Sustainable Development
Principles, including: (1) supporting the revitalization of city centers and neighborhoods by promoting development that is compact, conserves land, protects historic resources and integrates uses; (2) encouraging remediation and reuse of existing sites, structures and infrastructure rather than new construction in undeveloped areas; and (3) protecting environmentally sensitive lands, natural resources, critical habitats, wetlands and water resources and cultural and historic
-92- landscapes. Id. As shown in this proceeding, the Project will be located primarily within existing roadways and does not require the establishment of new rights-of-way; thus, no previously undisturbed property will be affected by the siting, construction or installation of the Project. Id.
The Project, therefore, complies with and furthers the Commonwealth’s policies regarding resource use and development. Id.
Conclusion
Based on the foregoing, the Company has satisfied the requirement in G.L. c. 164, § 69J that the proposed Project is “consistent with current health, environmental protection, and resource use and development policies as adopted by the [C]ommonwealth.”
V. THE PROJECT SATISFIES THE STANDARDS FOR SECTION 72 APPROVAL
G.L. c. 164, § 72 requires, in relevant part, that an electric company seeking approval to construct a transmission line must file with the Department a petition for:
authority to construct and use or to continue to use as constructed or with altered construction a line for the transmission of electricity for distribution in some definite area or for supplying electricity to itself or to another electric company or to a municipal lighting plant for distribution and sale . . . and shall represent that such line will or does serve the public convenience and is consistent with the public interest . . . The [D]epartment, after notice and a public hearing in one or more of the towns affected, may determine that said line is necessary for the purpose alleged, and will serve the public convenience and is consistent with the public interest.44
The Department considers all aspects of the public interest in making a determination under
Section 72. Eversource Mystic-East Eagle at 164; Eversource Walpole-Holbrook at 100;
44 Pursuant to statute, the electric company must file with its petition a general description of the transmission line, provide a map or plan showing its general location, and estimate the cost of the facilities in reasonable detail. G.L. c. 164, § 72. The Company included all of this necessary information as part of the Section 72 Petition. Exh. EV- 8. In addition, in compliance with the Department’s Section 72 Checklist, the Company provided the following information: (1) a draft hearing notice (Exh. EV-1, Attachment 1); (2) USGS locus maps and diagrams of the proposed transmission line route (Exh. EV-2, at Section 4); and (3) a list of all permits needed for the Project (Exh. EV-2, at 6-7).
-93- Eversource Mystic-Woburn at 83; see Boston Edison Company v. Town of Sudbury, 356 Mass.
406, 419 (1969) (“Boston Edison”). Section 72, for example, permits the Department to prescribe reasonable conditions for the protection of the public safety. Eversource Mystic-East Eagle at 164;
Eversource Walpole-Holbrook at 100; Eversource Mystic-Woburn at 84 citing Boston Edison, 356
Mass. at 419-20. All factors affecting any phase of the public interest and public convenience are weighed by the Department in a determination under Section 72. Town of Sudbury v. Department of Public Utilities, 343 Mass. 428, 430 (1962).
In evaluating petitions filed under Section 72, the Department examines: (1) the need for, or public benefits of, the present or proposed use; (2) the environmental impacts or any other impacts of the present or proposed use; and (3) the present or proposed use and any alternatives identified. Eversource Mystic-East Eagle at 164; Eversource Walpole-Holbrook at 100-01;
Eversource Mystic-Woburn at 84. The Department then balances the interests of the general public against the local interest and determines whether the line is necessary for the purpose alleged and will serve the public convenience and is consistent with the public interest. Id.
Given the nearly identical statutory standards in Section 72 and Section 69J, the
Department and the Siting Board have been granted the statutory authority to conduct coordinated reviews of jurisdictional transmission lines. See G.L. c. 25, § 4; G.L. c. 164, § 69H. Because the
Project will contribute to a necessary supply of energy for the Commonwealth with a minimum impact on the environment at the lowest possible cost, there is a need for, and public benefits from, the construction and operation of the proposed transmission lines. Cambridge Electric, at 52-53.
Accordingly, pursuant to Section 72, the Project is necessary for the purpose alleged, will serve the public convenience and is consistent with the public interest. Id. at 56-57.
-94- VI. CONCLUSION
For the foregoing reasons, Eversource respectfully requests that the Siting Board approve its request under G.L. c. 164, § 69J and G.L. c. 164, § 72 to construct, operate and maintain the
Project.
Respectfully Submitted,
NSTAR ELECTRIC COMPANY d/b/a EVERSOURCE ENERGY
By its attorneys,
Catherine J. Keuthen, Esq. Cheryl A. Blaine, Esq. Keegan Werlin LLP 99 High Street, Suite 2900 Boston, MA 02110 (617) 951-1400
Dated: February 14, 2020
-95-