Vineyard Wind Connector: Final Environmental Impact Report
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Vineyard Wind Connector: Final Environmental Impact Report EEA #15787 December 17, 2018 Submitted to Prepared by Executive Office of Energy and Epsilon Associates, Inc. Environmental Affairs 3 Mill & Main Place, Suite 250 MEPA Office Maynard, Massachusetts 01754 100 Cambridge Street, Suite 900 Boston, Massachusetts 02114 Submitted by In Association with Vineyard Wind LLC Foley Hoag LLP 700 Pleasant Street, Suite 510 Stantec, Inc. New Bedford, Massachusetts 02740 Geo SubSea LLC December 17, 2018 Secretary Matthew A. Beaton Attn: MEPA Office Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 Subject: Vineyard Wind Connector (EEA #15787) Final Environmental Impact Report Dear Secretary Beaton: On behalf of Vineyard Wind LLC (the Company, or Proponent), I am pleased to submit this Final Environmental Impact Report (FEIR) for the Vineyard Wind Connector1. A year ago, we submitted the Environmental Notification Form (ENF) for this groundbreaking project. We are most appreciative of the concerted effort made by the entire EEA team to provide a constructive review, and to do so on an ambitious schedule. As we enter the final step of the MEPA review process, Vineyard Wind is pleased with the refinements that have been made to Project, many of which reflect input from your resource agencies as well as the Town of Barnstable. We look forward to continuing to work with the EEA team to bring the MEPA process to a productive conclusion, thus completing a central component of the public review of the Project. The balance of this letter provides an update on Project milestones, an overview of the refinements and improvements made since the submittal of the SDEIR in late August, and an update on the BOEM review process. We are working hard to resolve an unexpected issue, specifically a request by Rhode Island commercial fishermen for a 45-degree change to the orientation of the offshore turbine rows. We do, however, remain on track to have all necessary approvals in hand by the summer of 2019. This will allow us to begin critical path onshore construction late in 2019, as planned. 1 The Vineyard Wind Connector includes the Massachusetts-jurisdictional elements of the 800 MW Vineyard Wind Project. The Massachusetts elements include most of the offshore export cables, the onshore underground cables, the proposed onshore substation, and the grid interconnection. Project Milestones since the SDEIR Progress on DPU Review of the Power Purchase Agreements (PPAs): As was described in the SDEIR, Executed Power Purchase Agreements2 were filed with the Department of Public Utilities (DPU) on July 31, 2018. On August 1, 2018, the Massachusetts Department of Energy Resources (DOER) filed a letter with DPU. DOER stated that “the Vineyard Wind offshore generation long term contracts provide a highly cost-effective source of clean energy generation for Massachusetts customers.” The letter continued to state that total net benefits to Massachusetts ratepayers over the term of the contract would be approximately $1.4 billion. Finally, the DOER noted that the 800 MW Vineyard Wind Project provides a “unique opportunity to maximize the value of the federal investment tax credit (“ITC”) as the value of the credit is scheduled to be gradually reduced and will not be available for projects that start construction after December 31, 2019.” The Power Purchase Agreements negotiated between Vineyard Wind and the Massachusetts electric distribution companies3 are currently under review by DPU. DPU issued the procedural notice and ground rules on September 6, 2018 and the briefing is due to be completed February 13, 2019; the review process is expected to conclude in March 2019. Host Community Agreement with the Town of Barnstable: On October 3, 2018, the Company and the Town of Barnstable signed a Host Community Agreement (HCA) that reflects a shared belief that the Project can benefit the Town of Barnstable and that potential impacts to the Town of Barnstable can and will be minimized and/or appropriately mitigated. The HCA reflects significant community support for the Project, for the Landfall Site at the Town-owned Covell’s Beach parking lot, and for ongoing cooperation between the Company and the Town of Barnstable. This cooperation was reinforced on October 18, 2018, when the Barnstable Town Council voted unanimously to grant Vineyard Wind an easement across Covell’s Beach and the adjacent parking lot. Switch to Covell’s/Barnstable route: Based in significant part on the signing of the HCA, the Company now considers the Covell’s Beach route in Barnstable to be the preferred cable routing option. Use of the Covell’s Beach landfall reduces the length of the total offshore cable route by approximately 4.5 miles and eliminates the need to cross the existing Nantucket Cable. Horizontal Directional Drilling (HDD) staged from the Covell’s Beach parking lot will allow the Project to avoid any impacts to the beach and intertidal zone. The underground duct bank from the Landfall Site to the proposed substation is entirely in roadway layouts and about 0.7 miles shorter than the New Hampshire Avenue route. EFSB, MEPA, and other agencies were advised of this change in the Company’s preference as quickly as possible following the signing of the HCA. 2 Power Purchase Agreements between Vineyard Wind and NSTAR Electric Company, Massachusetts Electric Company and Nantucket Electric Company, and Fitchburg Gas and Electric Light Company. 3 NSTAR Electric Company (d/b/a Eversource Energy), Massachusetts Electric Company and Nantucket Electric Company (d/b/a National Grid), and Fitchburg Gas and Electric Light Company (d/b/a Unitil). Page 2 of 6 Completion of EFSB evidentiary hearings: Following an extensive discovery process, nine days of EFSB evidentiary hearings were held in October, with hearings finishing ahead of schedule on October 26. Legal briefs were submitted on November 28, followed by reply briefs on December 12. The EFSB staff expects to issue its Tentative Decision in March 2019, with a Final Decision anticipated in early April 2019. New Bedford Marine Commerce Terminal lease signed: On October 22, 2018, Vineyard Wind signed an 18-month, $9 million lease for use of the 26-acre New Bedford Marine Commerce Terminal. Operated by the Massachusetts Clean Energy Center (MassCEC), the New Bedford Terminal was purpose-built to support construction of large-scale offshore wind projects. The Company is looking forward to fully utilizing the New Bedford Terminal and to doing business with the broad maritime support infrastructure in New Bedford harbor. MHI Vestas 9.5 MW Wind Turbine Selected: On November 27, 2018, Vineyard Wind announced that MHI Vestas Offshore Wind had been selected as the preferred supplier for the Project. MHI Vestas will supply the V164 9.5 MW offshore wind turbine for the Project, which is the largest wind turbine generator currently available and is extremely well suited to conditions along the eastern seaboard. Using this 9.5-MW wind turbine also adds important flexibility in the wind array layout and reduces the total area of the turbine array, further minimizing any impacts to commercial fishermen, especially those working out of Massachusetts and Rhode Island ports. BOEM Draft Environmental Impact Statement (DEIS): For the past year, the entire Vineyard Wind Project, including the offshore wind turbine generators, the inter array cables, the electrical service platforms, and offshore cables in federal waters has been undergoing a comprehensive review by the Department of the Interior’s Bureau of Offshore Energy Management (BOEM) with the assistance of a number of federal agencies (e.g., USCG, Army Corps, US EPA, NMFS) as well as cooperating state agencies (e.g., MCZM, RI CRMC, RIDEM). Your office and a number of Massachusetts resource agencies provided detailed scoping comments early in the DEIS process. The DEIS, prepared by BOEM and independent third-party consultants to BOEM, was released on November 30, 2018. The purpose of the DEIS is to help BOEM determine whether to approve, approve with modifications, or disapprove the Construction and Operations Plan (COP) submitted by Vineyard Wind. Based on our review of the DEIS to date, we are pleased to find the review largely as anticipated, with no significant unexpected findings of project impacts identified. A one-page Company-prepared synopsis of key findings of the DEIS is attached to this letter. BOEM issued a Notice of Availability (NOA) in the Federal Register on December 7, 2018, opening a 45-day public comment period which is expected to close on January 21, 2019. In January 2019, BOEM will conduct public meetings in New Bedford, Barnstable, Nantucket, Martha’s Vineyard, and Rhode Island. Input received at the public meetings, together with written comment letters, will be used to inform preparation of the Final Environmental Impact Statement (FEIS). The FEIS is expected to be completed in late April 2019 with the Record of Decision (ROD) anticipated in mid-July 2019. Page 3 of 6 Ongoing Project Refinements As the environmental review progresses, the Company’s engineering team continues to analyze the 2018 marine survey data and is advancing the design and cable routing process. This work includes discussions with, and receipt of bids from, submarine cable providers and installation contractors. This additional information has been used to refine the cable installation approach and associated impact calculations presented in the FEIR. The specifics include: More Capable Cable Installation Tool: As discussions with prospective cable installation contractors progress, the Company is able to consider cable installation tools with greater achievable burial depths (i.e., which could be 2.5 m [8 feet] or more), the use of which could further minimize dredging. Generally Reduced Sand Wave Dredging Volumes: The use of a more capable cable installation tool coupled with additional analysis of the 2018 survey data have allowed the Company to refine its estimates for dredge volume in sand wave areas.