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COMMONWEALTH of MASSACHUSETTS ENERGY FACILITIES SITING BOARD Petition of NSTAR Electric Company D/B/A Eversource Energy Pursuan

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COMMONWEALTH of MASSACHUSETTS ENERGY FACILITIES SITING BOARD Petition of NSTAR Electric Company D/B/A Eversource Energy Pursuan COMMONWEALTH OF MASSACHUSETTS ENERGY FACILITIES SITING BOARD Petition of NSTAR Electric Company d/b/a ) Eversource Energy Pursuant to G.L. c. 164, § 69J ) for Approval to Construct and Operate a New ) 115-kV Electric Transmission Line Between the ) EFSB 19-06 Bourne Switching Station and West Barnstable ) Substation ) ) Petition of NSTAR Electric Company d/b/a ) Eversource Energy Pursuant to G.L. c. 164, § 69J ) for Approval to Construct and Operate a New ) 115-kV Electric Transmission Line Through the ) D.P.U. 19-142 Towns of Bourne, Sandwich, and Barnstable ) ) ) Petition of NSTAR Electric Company d/b/a ) Eversource Energy Pursuant to G.L. c. 40A, § 3 ) for Individual and Comprehensive Exemptions ) from the Zoning Ordinance of the Town of ) D.P.U. 19-143 Barnstable ) ) ) MAYFLOWER WIND ENERGY LLC’S PETITION FOR LEAVE TO INTERVENE Pursuant to 980 CMR § 1.05, 220 CMR § 1.03, and the Notice of Adjudication and Notice of Public Comment Hearing issued by the Energy Facilities Siting Board (the “Siting Board”) on May 7, 2020, Mayflower Wind Energy LLC (“Mayflower Wind” or “Mayflower”) hereby petitions the Siting Board for leave to intervene as a full party in the above-referenced consolidated proceedings. Mayflower Wind states the following in support of this Petition: Eversource’s Proposed Project 1. On November 8, 2019, NSTAR Electric Company d/b/a Eversource Energy (“Eversource”) filed a petition seeking approval from the Siting Board pursuant to G.L. c. 1 104515976.8 164, § 69J (the “Section 69J Petition”). In the Section 69J Petition, Eversource proposes to construct and operate an approximately 12.5-mile, overhead 115-kilovolt (“kV”) electric transmission line (the “New Line,” and together with related station improvement, the “Mid Cape Reliability Project”). The New Line would run along an existing Eversource right-of-way (“ROW”), ROW # 342, between Eversource’s Bourne Switching Station and West Barnstable substation. Description of Mayflower Wind 2. Mayflower Wind is an offshore wind energy developer with an address of 2 Drydock Avenue, Boston, MA 02210. Mayflower Wind is a joint venture project of Shell New Energies US LLC and EDPR Offshore North America LLC. As such, Mayflower Wind is backed by the combined capability, experience, commitment to innovation, and financial strength of a world-leading offshore energy developer and a world-leading wind power and renewable energy developer. 3. On May 23, 2019 the Massachusetts electric distribution companies (the “Distribution Companies”), in coordination with the Massachusetts Department of Energy Resources (“DOER”), issued a Request for Proposals for Long-term Contracts for Offshore Wind Energy Projects pursuant to Section 83C of Chapter 169 of the Acts of 2008, as amended by chapter 188 of the Acts of 2016, An Act to Promote Energy Diversity (“Section 83C II”). The RFP sought to procure at least 400 MW, and up to 800 MW, of offshore wind energy generation. Project developers, including Mayflower Wind, submitted bids in August 2019. Mayflower Wind proposed four potential projects – a 400 MW project and three proposals for 800 MW projects, including Mayflower Wind’s Project 2, the 804 MW Low Cost Energy proposal. Following a bid evaluation 2 104515976.8 process, including monitoring and assistance by an Independent Evaluator, the Distribution Companies selected Mayflower Wind’s Project 2 as the winning bid on October 30, 2019. On January 10, 2020, the Distribution Companies and Mayflower Wind executed the long-term Power Purchase Agreements (“PPA”). On February 10, 2020, the PPAs were filed for approval with the Department of Public Utilities (“DPU”) in dockets DPU 20-16, DPU 20-17 and DPU 20-18. 4. Mayflower Wind’s offshore wind energy generation project is located offshore from the southern coast of Massachusetts in federal waters, approximately 26 nautical miles (48 km) south of the island of Martha’s Vineyard and 20 nautical miles (37 km) south of Nantucket within federal lease area OSC-A 0521. Mayflower Wind is actively engaged in the process of developing a 1,200 megawatt (“MW”) offshore wind energy project, which will be used to supply clean, renewable energy to New England to meet state policy objectives, including to supply power under the PPAs. Mayflower Wind stated in its Section 83C II bid proposal that it intends to bring its power onshore in Falmouth, Massachusetts and then north through Cape Cod to an interconnection point on the regional transmission system at a switching station that Mayflower will build in Bourne, Massachusetts. Mayflower is currently pursuing a co-optimized strategy cooperatively with Eversource. Under the plan presented in Mayflower Wind’s 83C II proposals, a new 345-kV generator-lead circuit and a new 345-kV switching station in Bourne would tap in and out of Eversource’s 322 (Canal – Carver) and 342-2 (Canal – Jordan Tap) transmission lines along Eversource ROWs 342 and 380. Under that plan, Mayflower’s proposed switching station would be located adjacent to or in the immediate vicinity of Eversource’s Bourne 115kV Switching Station. Mayflower Wind is engaged 3 104515976.8 in discussions with Eversource to refine this co-optimization strategy and the infrastructure and permitting processes that will flow from that strategy. 5. Mayflower Wind’s selected bid and its preferred route are premised on using existing ROWs and other previously-disturbed land to minimize environmental impacts and costs to customers. One of the existing ROWs that Mayflower has planned to use is Eversource ROW 340, which Eversource identifies in its routing analysis as “Candidate Route 2 – Eversource ROWs 340, 345 and 381”, submitted in this proceeding as an alternative route that it considered but did not select for its Mid Cape Reliability Project.1 ROW 340 runs roughly south to north between Falmouth and Bourne to Eversource’s Bourne Switching Station. In July of 2019, Mayflower Wind submitted a co-location request with Eversource to enable Mayflower to use ROWs 340, 342 and 380, among other ROWs south of Eversource’s Bourne Switching Station, to install the 345-kV transmission facilities necessary to deliver power from the Mayflower offshore wind project to its intended point of interconnection on the regional transmission facilities at the Bourne switching station. Mayflower intends to ensure that no adverse impacts to Eversource’s existing and future customers result from its use of ROWs 340, 342 and/or 380. Eversource has not yet provided any final determination regarding this request, but has initiated and continued discussion with Mayflower Wind regarding co-optimization of potential uses of ROWs 340, 342 and/or 380 and the Mid Cape Reliability Project. 6. Offshore wind projects such as Mayflower Wind’s support important policies of the Commonwealth in the public interest, including those pertaining to energy, the environment, public health and the economy, and they carry out legislative mandates 1 See Eversource Petition Volume I, EFSB 19-06, (November 8, 2019), at 4-24. 4 104515976.8 including those embodied in the Act to Promote Energy Diversity, St. 2016, c. 188. Section 83C II requires the Distribution Companies, Eversource among them, to procure an initial target of 1,600 MW of offshore wind energy. Under the Act to Advance Clean Energy, St. 2018, c. 227, § 21, DOER has expanded the amount of offshore wind generation that will be procured under the Act to Promote Energy Diversity to 3,200 MW.2 Appropriate use of existing utility company ROWs, especially on Cape Cod, will be a critically important feature of carrying out these important state policies and legislative mandates, especially if they can be done on a co-optimization basis that recognizes likely load growth due to increased electrification of the transportation and building (heating and cooling) sectors. 7. Mayflower Wind does not now take a position in favor of or in opposition to the Mid Cape Reliability Project, including whether the Siting Board should approve the project, and if so under what conditions. Mayflower Wind appreciates that transmission upgrades, such as the one Eversource proposes here, may be needed to maintain reliability on Cape Cod and more generally in southeastern Massachusetts and Rhode Island, and to enhance the ability of offshore wind facilities to help meet the Commonwealth’s clean/renewable energy policies and similar policies in other New England states. Mayflower Wind’s primary interest in this proceeding is to ensure that Eversource designs and executes its Mid Cape Reliability Project in a way that will: (i) foster offshore wind development, (ii) avoid project alternatives that would adversely 2 The Act to Advance Clean Energy authorized DOER to solicit up to 3,200 MW, pending a DOER study about the “necessity, benefits and costs” of doing so. DOER’s study showed that, among other findings, an additional procurement for 1,600 MW of offshore wind energy has “a likelihood of cost-effectiveness that justifies additional solicitations,” so DOER will now require the EDCs to solicit an additional 1,600 MW of offshore wind energy. See Mass. Dep’t Energy Resources, Offshore Wind Study, at 5-6 (May 2019), available at https://www.mass.gov/files/documents/2019/05/31/OSW%20Study%20-%20Final.pdf. 5 104515976.8 affect Mayflower Wind’s planned interconnection to the regional grid, and (iii) preserve the ability to share use of existing ROWs to support the interconnection facilities necessary for Mayflower Wind’s project and its intended use of existing ROWs, including ROWs 340, 342, and 380 to interconnect at Bourne, and to minimize costs and environmental impacts in doing so. This Proceeding Will Substantially and Specifically Affect Mayflower Wind 8. In conducting adjudicatory hearings, the Siting Board “may allow any person showing that he may be substantially and specifically affected by the proceeding to intervene as a party in the whole or any portion of the proceeding, and allow any other interested person to participate by presentation of argument orally or in writing, or for any other limited purpose, as the agency may order.” G.L.
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