GEORGE W. WATSON III
One Financial Plaza, 14th Floor Providence, RI 02903-2485 Main (401) 709-3300 Fax (401) 709-3399 [email protected] Direct (401) 709-3351
Also admitted in Massachusetts and Connecticut
November 25, 2020
Kathleen Mignanelli Siting Board Coordinator Energy Facility Siting Board 89 Jefferson Boulevard Warwick, RI 02888
Re: In re: The Narragansett Electric Company d/b/a National Grid Notice of Intent to Construct 115 kV Loop Lines of Less Than 1,000 Feet (Wickford Junction Substation Loop Line)
Dear Kathleen:
I am enclosing for filing an original and seven (7) copies of the Notice of Intent pursuant to Rule 445-RICR-00-00-1.6(c) of the EFSB Rules of Practice and Procedure on behalf of The Narragansett Electric Company d/b/a National Grid for the construction of 115 kV loop lines at the new Wickford Junction Substation in North Kingstown.
Very truly yours,
George W. Watson, III
Enclosure
Copy to: A. Ralph Mollis, North Kingstown Town Manager Jeannette Alyward, North Kingstown Town Clerk Matthew F. Callaghan, Jr., Esq., North Kingstown Town Solicitor Mark Rielly, Esq. David Waterfall, Esq. Stacy M. Blundell STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS ENERGY FACILITY SITING BOARD
In re: THE NARRAGANSETT ELECTRIC COMPANY d/b/a NATIONAL GRID Notice of Intent to Construct a Loop Line of Less Than 1,000 Feet (Wickford Junction Substation Loop Line)
NOTICE OF INTENT TO CONSTRUCT
In accordance with Rule 1.6(C) of the Rhode Island Energy Facility Siting Board
(“EFSB”) Rules of Practice and Procedure, The Narragansett Electric Company d/b/a National
Grid (“TNEC” or the “Company”) hereby notifies the EFSB of TNEC’s intent to construct a 115 kV loop line1 of no more than 200 feet in North Kingstown, Rhode Island (“Project”). The
Project is required to connect the new Wickford Junction Substation (the “Substation”) that will be constructed at 1080 Ten Rod Road, North Kingstown, Rhode Island (the “Property”). TNEC is the fee owner of the Property, which hosts the existing Lafayette Substation (a distribution substation).2 Presently, a 300-foot wide transmission line right of way (“ROW”) abuts the
Property. Two transmission lines, including the L-190 115 kV Transmission Line (“L-190”), and one sub-transmission line are located in the ROW. The Substation will be located adjacent to the ROW, and the proposed 115 kV loop line will connect the Substation with the L-190, as depicted on the Site Plan for the Project which is attached as Exhibit A. The Substation is
1 Substations are connected to the transmission lines via tap lines or loop lines. Tap lines directly connect to the transmission line without creating a break in the line. This is akin to a lateral connection. Looped lines occur where the transmission line is broken, and each segment of the line is rerouted directly in and out of the substation. Looped transmission lines allow for the circuit to be sectionalized on either side of a substation while taps do not. 2 The Company intends to relocate the existing Lafayette Substation immediately adjacent to and within the fenceline of the new Wickford Junction Substation at a future date. Accordingly, the attached Site Plan reflects the location of the new Wickford Junction substation and the future Lafayette Substation. necessary to support the interconnection of customer-owned distributed generation projects to the electric grid.
TNEC files this notice pursuant to EFSB Rule 1.6(C) regarding new power lines of less than
1,000 feet with a capacity of 69 kV or more. According to the EFSB’s rules, the EFSB shall act upon this Notice, and any objection filed thereto, no later than forty-five days following the filing of this Notice. The Project does not constitute an “alteration” of a major energy facility because the length of the new loop line is less than 1,000 feet.3 See Rule 1.3(A)(4).
1. Identification of the Owner of the Facility
The owner of the relevant facilities is TNEC, a subsidiary of National Grid USA, Inc. 4
TNEC’s business address is 280 Melrose Street, Providence, Rhode Island 02907. The Project will be located on the TNEC-owned Property and within TNEC-held easements.
2. Detailed Description of the Proposed Loop Line
A. Length
The Project involves the construction of a new 115 kV loop line comprised of two supply lines, each no more than 200 feet in length, that will interconnect to the Substation. The loop line will connect the Substation to the existing L-190.
B. Route
In connection with the Project the Company will replace two existing wood structures with two steel three-pole deadend structures (#143 and #144) and install a third new steel three-
3 The loop lines are routed parallel to each other so it’s the Company’s practice to use the length of the loop line corridor as opposed to aggregate length of the line running in and out of the substation. 4 A chart identifying affiliates of the owner is attached hereto as Exhibit B.
2 pole deadend structure (#143A).5 New Structures #143 and #144 will be approximately 60 feet tall, and the other new structure (#143A) will be approximately 55 feet tall. The average L190 structure height around the Wickford Junction area is approximately 50 to 55 feet tall. The modest increase in height is necessary because the loop lines will travel slightly uphill to reach the Substation. The loop lines will terminate at substation deadend structures which are approximately 55 feet tall. Attached as Exhibit A is the Site Plan for the Project depicting the approximate location of the Project, the existing transmission and sub-transmission lines
(including the L190 Line), and the Substation.
C. Function
The Project is needed to interconnect the Substation with the Company’s existing L-190
Line and the 115 kV transmission system. The Substation is required to interconnect customer- owned solar photovoltaic distributed generation, which will connect to the substation via 34.5 kV lines, to the 115 kV transmission system. Customers have proposed to construct 14 large solar arrays totaling approximately 108 megawatts in capacity in the North Kingstown and Exeter areas, and will bear all costs associated with the Substation and Project.
3. The Project Does Not Constitute the Alteration of a Major Energy Facility
The Project does not constitute an “alteration” of a major energy facility because the proposed loop lines will be no more than 200 feet in length and the EFSB has expressly excluded power lines under 1,000 feet in length from the definition of “alteration” in Rule 1.3(A)(4):
“[t]he construction, modification or relocation of a power line of 69 kV or more which are less than 1,000 feet in length shall not be treated as an alteration….” As noted above, the Project
5 The Company also intends to replace one structure (#123) on the adjacent 34.5 kV 3311 sub-transmission line to make room for the Project. Since the 3311 line operates at less than 69 kV, it is a not a “major energy facility” subject to the EFSB’s siting jurisdiction.
3 work will occur entirely within TNEC property that is owned in fee or held by easement.
TNEC’s adjacent ROW is already occupied by two transmission lines and associated structures.
In this sense, the Project is substantially similar to other TNEC projects in which the EFSB determined that new transmission lines less than 1,000 feet in length do not constitute alterations of a major energy facility. See, e.g., Docket SB 2013-1 (decision dated April 1, 2013); Docket
SB-2013-02 (decision dated September 5, 2013); Docket SB 2015-01 (decision dated June 2,
2015); Docket SB 2015-02 (decision dated June 2, 2015); Docket SB 2015-5 (decision dated
November 16, 2015); and Docket SB 2020-01 (decision dated October 1, 2020).
Moreover, TNEC believes that this Project will not result in any significant impact on the environment or the public health, safety and welfare, and therefore does not require further investigation or approval by the EFSB. The implementation of appropriate best management practices and mitigation measures during construction will avoid or minimize the construction phase impacts to the natural and social environment. In addition, the loop lines will be designed, constructed and operated consistent with applicable codes and requirements.
4. Additional Information
The Company obtained local zoning relief for the substation from the Town of North
Kingstown Planning Commission and the Town of North Kingstown Zoning Board of Review.
The local zoning relief required public hearings with mailed hearing notices to abutters within
200 feet of the substation parcel. In addition, the Rhode Island Department of Environmental
Protection issued its RIDEM RIPDES Permit and Water Quality Cert on September 24, 2020.
4 CONCLUSION
For the reasons stated above, TNEC respectfully requests that the EFSB enter an Order pursuant to EFSB Rule 1.6(E) accepting this Notice of Intent to Construct the new 115 kV loop line and ruling that the Project may proceed without any further review by the EFSB.
THE NARRAGANSETT ELECTRIC COMPANY d/b/a NATIONAL GRID
By its Attorney,
______George W. Watson, III Robinson & Cole LLP One Financial Plaza, 14th Floor Providence, RI 02903
5 EXHIBIT A \\vhb\gbl\proj\Providence\73001.10\cad\ld\Planset\Site Plan.dwg vhb.com
2' WIDTH VARIES PER PLAN 2' WIDTH VARIES PER PLAN FINISH GRADE FINISH GRADE
SLOPE VARIES PER PLAN SLOPE VARIES PER PLAN
STRIP LOAM STRIP LOAM EXISTING GRADE EXISTING GRADE
MIRAFI 160N FILTER FABRIC 8" PROCESSED COMPACTED 8" PROCESSED COMPACTED GRAVEL (1" MINUS) SUBGRADE GRAVEL (1" MINUS) SUBGRADE
4" CRUSHED STONE 4" LOAM & SEED TOP DRESSING TOP DRESSING 1 Cedar Street (SEE NOTE 2) (SEE NOTE 2) Suite 400 NOTES NOTES Providence, RI 02903 REMOVE CONCRETE CURB AND 1. PROCESSED GRAVEL AND CRUSHED STONE SHALL BE IN ACCORDANCE WITH THE 1. PROCESSED GRAVEL SHALL BE IN ACCORDANCE WITH THE CURRENT VERSION 401.272.8100 GUARDRAIL, THEN RESET ONCE CURRENT VERSION OF THE RHODE ISLAND DEPARTMENT OF TRANSPORTATION OF THE RHODE ISLAND DEPARTMENT OF TRANSPORTATION STANDARD PROJECT IS COMPLETE STANDARD SPECIFICATIONS FOR ROAD AND BRIDGE CONSTRUCTION. SPECIFICATIONS FOR ROAD AND BRIDGE CONSTRUCTION.
2. CONTRACTOR SHALL APPLY CRUSHED STONE TOP DRESSING AS FINAL CONDITION 2. CONTRACTOR SHALL APPLY LOAM & SEED TOP DRESSING AS FINAL AFTER ALL OTHER CONSTRUCTION IS COMPLETED. CONDITION AFTER ALL OTHER CONSTRUCTION IS COMPLETED.
Permanent Access Drive Temporary Work Area 85.9± 86 N.T.S. Source: VHB N.T.S. Source: VHB 86.0± Legend 86.0± 87 RIGHT-OF-WAY/PROPERTY LINE TEMPORARY 86.5± 88 WORK AREA EASEMENT 89 LOW REPLACE WOOD POLE PULLOFF 90 WITH NEW WOOD DEADEND PULLOFF STRUCTURE OVERHEAD WIRE LIMIT OF WORK LIMIT OF DISTURBANCE REPLACE EXISTING WOOD 3-POLE PROPOSED 3-POLE DEADEND STRUCTURE WITH NEW DEADEND STRUCTURE EDGE OF ACCESS DRIVE STEEL 3-POLE DEADEND STRUCTURE EXISTING WOOD H-FRAME PROPOSED 3-POLE 4 MINOR CONTOUR STRUCTURE TO BE REMOVED DEADEND STRUCTURE 20 MAJOR CONTOUR
EROSION CONTROL BLANKET TEMPORARY SPOT ELEVATION CONSTRUCTION PLATFORM UTILITY POLE BY OTHERS TEMPORARY WORK AREA
109.0± 117.0 116.5 116.0 EROSION CONTROL BLANKET TEMPORARY 113 112 WORK AREA 114 117 PERMANENT GRAVEL (13%± SLOPE) 110 8% 115 MAX 117.5 ACCESS DRIVE
116 LIMIT OF WORK 111 119 120 112 2% IN DRIVE 117 121 117.8 NOTES: 113 118.3 117.3 122 118 1. DISTURBED AREAS OUTSIDE OF THE PERMANENT GRAVEL 114 8% MAX ACCESS DRIVE SHALL BE RESTORED WITH 4" LOAM AND 123 SEED WITH NEW ENGLAND CONSERVATION SEED MIX 115 119 119.0 AFTER CONSTRUCTION IS COMPLETED. LIMIT OF WORK 120.0 119.5 120 120 116 116 119 124 118 LIMIT OF WORK 116.5± 117 115 114 113 112 111 110 109 108 107
118 STONE SLOPE
12' SWING GATE 124 0 10 20 40 Feet 119
120 123 120 Wickford Junction 121 Substation LAYDOWN/ 122 TURNAROUND AREA
100 Addendum to Permit 123 PERMANENT GRAVEL ACCESS DRIVE No. RIR101919 JOIN TO EXISTING 115 1080 Ten Rod road GRAVEL PATH North Kingstown, Rhode Island
No. Revision Date Appvd. 125 O'Brien, Eric
119 WICKFORD JUNCTION SUBSTATION RIDEM PERMIT #RIR101919 Designed by Checked by EOB
Issued for Date 105 Permit Addendum October 23, 2019
Not Approved for Construction Drawing Title Site Plan Tuesday, October 22, 2019 1:29:45 PM
960SF
HOUSE 118
CONTROL 117
Plotted 116
119 ERICOBRIEN
110
864SF
HOUSE
CONTROL Drawing Number
125 119 C-1A
115 Sheet of 1 1 Tuesday, October 22, 2019 12:04:30 PM 114 Project Number 120
Saved 73001.10 EXHIBIT B The Narragansett Electric Company – Structure Chart