Sealink Position Paper Addressing the Reliability Needs of the Region

NEW HAMPSHIRE TRANSMISSION

SeaLink Position Paper Addressing the Reliability Needs of the Region

Addendum April 2014 Greater Boston Stakeholder Letters Index

Massachusetts Page number

1. Governor Patrick – January 13, 2014 1 2. Attorney General Coakley - March 18, 2014 3 3. Mayor Walsh (City of Boston) – October 24, 2014 5 4. Former Mayor Menino (City of Boston) - February 8, 2013 7 5. Select State Delegation Reps. & Senators – December 9, 2014 8 6. State Representative Miceli (19th Middlesex) – December 11, 2014 11 7. Mayor Christensen (City of Malden) - January 14, 2014 13 8. Mayor Kennedy (City of Lynn) – March 11, 2014 15 9. Senator DiDomenico (Everett) – April 2, 2014 17 10. Mayor Kirk (City of Gloucester) - April16, 2014 18 11. Mass. Municipal Wholesale Electric Coop – December 15, 2014 20 12. Asst. General Manager Boyle (MBTA) - March 4, 2014 23 13. David Begelfer, CEO (NAIOP) - April 18, 2014 26 14. Bob Rio, SVP (AIM) - June 6, 2014 27 15. President Tozza (Bike to the Sea, Inc.) – March 17, 2014 29

New Hampshire 16. Governor Hassan – January 22, 2014 31 17. U.S. Senator’s Shaheen & Ayotte - June 18, 2014 32 18. Senator Stiles (Seabrook) & select reps - April 2, 2014 33 19. NH DOT – December 4, 2013 36 20. Town Manager Manzi (Seabrook) - March 3, 2014 39 21. President Lalime (Friends of Seabrook Rail Trail) – March 19, 2014 42

Regional 22. NESCOE letter – March 22, 2013 46

Page 1 Page 2 THE COMMONWEALTH OF MASSACHUSETTS OFFICE OF THE ATTORNEY GENERAL ONE ASHBURTON PLACE

BOSTON, MASSACHUSETTS 02108

MARTHA COAKLEY (617) 727-2200 ATTORNEY GENERAL www.mass.gov/ago

March 18, 2014

Gordon van Welie President and Chief Executive Officer ISO New England One Sullivan Road Holyoke, MA 01040

Dear Mr. JC—^ V-A)^—-—

As the Greater Boston area faces significantly elevated energy and capacity costs due to generation retirements and increasing load, as well as transmission reliability needs that must be addressed in the near term, I urge the Board of ISO New England to deliberate carefully as it considers the competing proposed transmission solutions to ensure that necessary transmission investment is planned on a least cost basis.

The region has a rare opportunity to choose between two competing solutions that can meet the requirements identified in the Greater Boston Needs Assessment. My understanding is that precise cost estimates have yet to be made generally available to stakeholders in a formal stakeholder process. When that time comes, we expect to participate in a transparent process in which we can evaluate whether the preferred solution has minimized the present value of the costs to consumers. The costs considered should not be limited to the capital expenditure, but should also include all revenue requirements and avoided costs, such as cost of capital, depreciation expense, operation and maintenance expense, administrative and general expense, taxes, congestion costs during construction, and any other costs that are identified by stakeholders. Additional costs that may be imposed as a result of siting requirements should be considered as well.

We recognize that the cost estimates fall within a broad range, from minus 25 percent of the project estimate to 50 percent over budget. This range is an improvement over the past project planning practices, but it still poses an unacceptably large risk to consumers. If the developers are willing to cap their recovery for project costs, that cap should be taken into account in choosing between them. Cost overruns should be scrutinized to determine if the causes could lead to findings of imprudence. Finally, while my office maintains that neither competing project should qualify for incentive rate treatment, ISO New England should require the developers to disclose any incentives that they will seek before FERC.

O Page 3 I want to thank you and your expert staff for the excellent work that you have done in considering our long term transmission needs. My office looks forward to supporting your efforts to maintain reliability in the Greater Boston area while minimizing long-term costs to consumers.

Cordially,

Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25

April 18, 2014

Secretary Richard K. Sullivan, Jr. Executive Office of Energy and Environmental Affairs 100 Cambridge St., Suite 900 Boston, MA 02114

RE: Greater Boston Reliability Study

Dear Secretary Sullivan:

As you are aware, our members need reliable electricity seervice at competitive prices. I understand that Massachusetts customers will soon be asked to pay for a new transmission project to solve some reliability problems in the Greater Boston area. The decision by ISO New England on what should be built to solve those problems will have significant implications for our members in terms of reliability and energy costs in the short run and the long run.

As our members can tell you, when a real estate investment is being contemplated, they have to consider all costs. When the ISO makes its decision, it too should look at all costs to ratepayers when comparing alternative transmission projects. Whether it is the initial investment costs or the ongoing transmission costs or the source cost of the energy, they should all be considered and balanced against the long term reliability of the energy.

At this time, NAIOP has no recommendation regarding whicch of the proposed transmission projects should be selected. However, we ask you to communicatee to the ISO that its evaluation process needs to be comprehensive and should fully consider all of the costs and all of the benefits each alternative has to offer.

I would be happy to discuss this further with you at your connvenience.

Sincerely yours,

NAIOP MASSACHUSETTS

David Begelfer Chief Executive Officer cc: Barbara Kates-Garnick, Undersecretary for Energy, EOEEA Ann Berwick, Chair, Department of Public Utilities

144 Gould Street Suite 140 Needham, MA 02494 ph: 781-453-6900 www.naiopma.org

Page 26

June 6, 2014

Maeve Vallely-Bartlett Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge St., Suite 900 Boston, MA 02114

Re: Greater Boston Reliability Study

Dear Secretary Vallely-Bartlett:

AIM would like to submit these comments relating to energy infrastructure investments in Massachusetts.

AIM is the state's largest nonprofit, nonpartisan association of Massachusetts employers. AIM's mission is to promote the well-being of its thousands of members and their employees and the prosperity of the Commonwealth of Massachusetts by improving the economic climate, proactively advocating fair and equitable public policy, and providing relevant, reliable information and excellent services.

As you know, AIM has been actively involved in the energy debate for many years. Throughout that time, we have consistently supported competitive energy markets and have long advocated for a transparent and competitive selection process for all types of power, including renewable power.

This is a critical time for New England. We face a host of issues, from reliability concerns to retiring generation. Energy prices have reached historic highs during the winter, straining the ability of some companies to profitably operate in Massachusetts. In almost every survey our members consistently rank the cost and reliability of electricity and energy as one of their primary concerns going forward.

We have been following the Greater Boston Reliability Study closely over the past year, as it will have significant implications in terms of reliability and energy and capacity costs for the Boston area. This is the first time two reliability projects have competed to serve Greater Boston. AIM understands that the competitive process has already demonstrated value through significant reductions in cost estimates and technical innovation.

Page 27 AIM believes that ISO-New England should use a broad set of criteria in comparing these projects. In particular, this evaluation should include: 1) all costs that ultimately impact ratepayers’ bills, including congestion costs during construction; 2) the resiliency of the network, and the repair and economic costs of disruptions; and 3) the speed with which a project can be implemented to improve capacity and reliability in the region.

At this time, AIM has no recommendation regarding which of the projects should be selected. However, we ask that you continue to work with ISO-New England so that its evaluation process is comprehensive and fully considers all of the costs and all of the benefits each project has to offer to Massachusetts ratepayers.

Thank you for your leadership on this issue.

Sincerely yours,

Robert A. Rio, Esq. Senior Vice President and Counsel Government Affairs

cc: Barbara Kates-Garnick, Undersecretary for Energy, EOEEA David Cash, Commissioner, Department of Environmental Protection Mark Sylvia, Commissioner, Department of Energy Resources, EOEEA

- 2 - Page 28

Bike to the Sea, Inc. c/o James Tozza, President 12 Saugus Avenue Saugus, MA 01906 781-558-3535

March 17, 2014 Secretary Richard K. Sullivan Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston MA 02114 Re: SeaLink Project Dear Secretary Sullivan: For over 20 years, Bike to the Sea Inc. (B2C) has advocated for the creation of the Northern Strand Community Trail (NSCT). The NSCT, already partly completed with the assistance of EEA’s Recreational Trail program, is a regional recreational trail that when fully built out will extend about 10 miles from the Mystic River Reservation in Everett through the communities of Malden, Revere and Saugus, ending at the Nahant Beach Reservation in Lynn. The SeaLink project proposes to use nearly the entire length of the NSCT corridor en route from Lynn to the power grid in Everett. Our focus is to complete and improve the surface of the corridor as a recreational trail. B2C also sees itself as a steward of the NSCT ROW recreational and natural resources. The board of directors of B2C appreciates that the proponents of the SeaLink project pro-actively reached out to our organization and hope the positive tone and open approach continues as the project advances. We do recognize the NSCT ROW already serves as a utility corridor for both gas and electric and that SeaLink will be another major addition. We look forward to partnering with private, state and federal organizations that look to utilize, maintain and develop the corridor for those purposes. B2C sees the SeaLink electric cable project as an opportunity to advance two key EEA priorities – the creation of a statewide greenway network and a more reliable and resilient electrical grid. We’re sure that the SeaLink proponents can adequately speak to the benefits of their project for the electrical system; we offer our qualified support for this project with the hope and expectation that the Commonwealth use this opportunity to benefit the greenway network. Qualifications SeaLink proponents should fund planning, public meetings and public out reach initiatives to develop design details appropriate for each host community that the trail passes through. As a subsurface project, the SeaLink project needs to be designed and constructed in a manner that will not conflict with the use of the corridor as the NSCT trail or future transportation needs. If SeaLink requires any above surface infrastructure, that infrastructure needs to be designed and located to allow safe trail use. We strongly prefer that the cable be routed to avoid digging up existing paved sections of the trail and that any trail section impacted be repaired across the full width of the trail, avoiding linear, parallel cuts that often occur during subsurface routing of cables under streets. Linear, parallel cuts pose particular hazards to bicyclists and skaters. Mutual Opportunities The surface of the Saugus and soon to be built Revere section of the trail consist of a recycled asphalt aggregate that can be readily improved using paving or stone dust. Routing the cable under the trail in Saugus and Revere

Page 29 then re-surfacing the trail with paving or stone dust would improve the trail while capping cap over the proposed underground electric cable. In addition to the built environment, B2C sees the ROW as important natural habitat and works to protect and enhance the corridor to that end. The NSCT trail when properly maintained also provides access for both the natural gas and electric utilities that share the corridor. To help preserve this benefit, we suggest that the SeaLink proponents lead an effort to create a cooperative agreement with the other utility companies that share the corridor (National Grid, Tennessee Gas etc.) to develop and fund a shared maintenance program. This program would be coordinated with the host communities and include yearly high mowing of the corridor to manage tree, shrub and invasive plant growth and keep the corridor as open meadow. Advancing the Completion of the Trail In Everett we encourage SeaLink to work with the City of Everett and MBTA to plan and fund the extension of the NSCT from West and Wellington Streets where it currently ends, to the Mystic River, following the commuter rail line, thus creating a direct off-road link from Everett to the recreational trails on the Mystic River. For both Everett and Malden, the SeaLink Project proponents should work with the City’s of Everett and Malden to layout conduit for trail lighting. For Saugus, B2C respectfully asks SeaLink look at the structural integrity of the train trestle on the Saugus River. In Lynn, B2C with support of the Saugus River Watershed Council and General Electric funded a 75% design of the Lynn Section of the trail from Boston Street to Summer Street. SeaLink proponents should provide funds so that B2C can work with the City of Lynn to identify a route to the sea from NSCT. Additionally, an initial Brownfield’s review of the Lynn section of the trail will facilitate both SeaLink and trail development and will ultimately be required for both projects to move forward in Lynn. Urgency As sections of the trail have been completed, more and more residents have become regular users. A narrowing window of opportunity exists for the SeaLink project to be constructed before the trail becomes an integral part of community life. As trail use increases and amenities are added, construction of the SeaLink project will cause more and more disruption. Conclusion B2C urges SeaLink to continue to work pro-actively with B2C and local, state and federal agencies and officials to develop partnerships to facilitate both improvements to our greenway and electrical networks. Sincerely yours,

James Tozza, President cc: Mayor DeMaria and Jamie Erickson, City of Everett Mayor Christenson and Beth Debski, City of Malden Mayor Rizzo and Cate Blackford, City of Revere Town Manager Scott Crabtree, Saugus Mayor Judith Flanagan Kennedy, City of Lynn

Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40 Page 41

March 19, 2014

Honorable Maggie Hassan Office of the Governor 107 N. Main Street Concord, NH 03301

Dear Governor Hassan:

We are writing you to show support for the proposed Sealink underground electric transmission project, a 68 mile, 520-megawatt underground/undersea cable from the Seabrook Transmission Substation in our town, to the Mystic Substation in Everett, Massachusetts. This Project would use high voltage direct current (HVDC) technology to efficiently and securely move power to directly connect two critical substations by way of a new, independent transmission corridor. As a bi-directional line, Sealink would be available to support customers on both ends of the cable and improve reliability of the New England transmission system as a whole.

The developer of the Sealink project, New Hampshire Transmission (NHT) has met with some of our Board of Directors from Friends of Seabrook Rail Trail (FSRT) and explained the purpose of the project, the proposed route and the wonderful benefits it can provide, if it is approved. We also know that NHT met with our Town Selectmen in February and they all voted in favor of supporting the project in our community.

Page 42 Friends of Seabrook Rail Trail have just found out this week from NHDOT's Director of Rail Transit that we will not be able to use the steel rails that were left on the corridor to finance the building of our trail, as they need them for repairs on other active corridors. We will also be responsible for disposing of the hazardous ties if we sign the Management Agreement because we were told, they don't have funding for that. That has presented a giant setback to our plans, and as you can imagine a terrible blow to our hopefulness of a rail trail in a few years.

We at FSRT, have been working diligently for several years on the vision of developing the Seabrook Rail Trail on the abandoned rail corridor that runs through Seabrook. FSRT have volunteered many hours with rail trail clean-ups, hosting countless fund raising events like our annual 5k road races and bike swaps. We have also continued to promote community awareness of the benefits that an off road recreational trail would bring to our citizens.

The town of Seabrook is truly in need of an alternative means of transportation, especially in our heavily congested border town. We also need a safe outdoor venue to exercise with our families and connect with other communities, as our rail trail will be part of the NH Seacoast Greenway that runs from Seabrook to Portsmouth, and also the East Coast Greenway, a 2500 mile traffic free path linking east coast cities from Florida to Maine.

This corridor would be part of the proposed transmission route for the SeaLink Project. We look forward to working with NHT to take advantage of the unique opportunity to utilize the cable installation process as a means to facilitate improvements to this important community resource in Seabrook. This opportunity to further develop the recreational trail, with limited community impact from construction and operation of the converter station and transmission line, makes this project a win-win opportunity that is very significant to our community.

The SeaLink project is very important to the people of Seabrook. We urge you to proactively support the development of SeaLink at the state and regional level, including urging the Independent System Operator in New England to move this project forward so that we can address critical reliability problems in the Greater Boston and New Hampshire seacoast areas.

Page 43 As a leader in innovation, technology and energy issues, New Hampshire should support the construction of new transmission lines that can continue to provide power during the worst of storms. Based on our understanding of the SeaLink project, it seems like a significant step in the right direction when it comes to the construction of reliable transmission lines. As you also know, the undergrounding of transmission lines has become a significant issue in our state, and I understand that the alternative to SeaLink would be a new overhead line in an already crowded right-of-way from New Hampshire to Massachusetts.

Please take into account all the wonderful benefits it will bring to not only Seabrook, but the NH Seacoast and all of NH, when considering your support of this project. Thank You.

Helen Lalime Nuala Leong

President FSRT Secretary FSRT [email protected]

cc:

Gordon van Welie, President and Chief Executive Officer, ISO New England

Amy Ignatius, Chairman, New Hampshire Public Utilities Commission Robert R. Scott, Commissioner, New Hampshire Public Utilities Commission Martin P. Honigberg, Commissioner, NH Public Utilities Commission

Meredith A. Hatfield, Director, New Hampshire Office of Energy and Planning Thomas Burack, Chairman, New Hampshire Site Evaluation Committee

Page 44

Emails and Addresses:

Gordon van Welie, President and Chief Executive Officer ISO New England Inc. 1 Sullivan Rd Holyoke, MA 01040

[email protected] Amy L. Ignatius, Chairman, New Hampshire Public Utilities Commission New Hampshire Public Utilities Commission 21 S. Fruit St, Suite 10 Concord, N.H. 03301-2429

[email protected] Robert R. Scott, Commissioner, New Hampshire Public Utilities Commission New Hampshire Public Utilities Commission 21 S. Fruit St, Suite 10 Concord, N.H. 03301-2429

[email protected] Martin P. Honigberg, Commissioner, New Hampshire Public Utilities Commission New Hampshire Public Utilities Commission 21 S. Fruit St, Suite 10 Concord, N.H. 03301-2429

[email protected] Meredith A. Hatfield, Director, New Hampshire Office of Energy and Planning NH Office of Energy and Planning Governor Hugh J. Gallen State Office Park Johnson Hall, 3rd Floor 107 Pleasant Street Concord, NH 03301

[email protected] Thomas S. Burack, Chairman, New Hampshire Site Evaluation Committee NH Department of Environmental Services 29 Hazen Drive, PO Box 95 Concord, NH 03302-0095

Page 45

New England States Committee on Electricity

To: Stephen Rourke, ISO-NE From: NESCOE Date: March 22 , 2013 Subject: Transmission Project Solution Comparisons for Reliability Projects CC: [email protected]

NESCOE writes to share its general perspective on ISO-NE’s Solution Study project comparisons and to request enhancements to the current process. Specifically, NESCOE encourages ISO-NE to apply a sufficiently broad range of both quantitative and qualitative criteria in selecting the most cost-effective project among competing transmission alternatives to meeting a system reliability need. These criteria should be clearly defined and presented to states and stakeholders in the form of a standardized matrix that tracks the full set of factors ISO-NE considered in its project-to-project assessment.

NESCOE also identifies below additional non-price criteria that, under appropriate circumstances, ISO-NE should consider in making its determination. NESCOE further requests that ISO-NE work with project developers to refine cost estimates and consider adopting cost containment features.

While we are writing in part due to issues that have been identified in the context of the Greater Boston Solutions Study Group’s ongoing evaluation of competing projects, NESCOE’s comments are not and should not be construed as NESCOE or any state favoring one proposed project over another in that particular study. At this time, neither NESCOE nor any state has sufficient information to have formed any such judgment. Rather, NESCOE’s comments are process-focused and intended to suggest improvements to the general process and applied globally as part of the solution evaluation process when ISO-NE is considering alternative projects.

Range of Factors Considered

ISO-NE already appears to have adopted a standard practice for considering a broad set of factors in evaluating alternative solutions to a reliability need. In its Sample Standard Transmission Analysis Solution Study Report, ISO-NE sets forth “a common and consistent format, structure and content for reporting the results of studies conducted for the New England transmission system that evaluate alternative solutions to identified need.”1 Section 7 of the Report lists the following criteria that ISO-NE will apply in comparing alternative solutions:

1 The Report is available at http://www.isone.com/rules_proceds/isone_plan/othr_docs/index.html.

1 Page 46

• Operational Performance • Constructability • Construction Outage Requirements/Impacts • Interface Impacts (Internal/External) • Siting Issues Such As Environmental Impact or Right-Of-Way Acquisition • Expansion Capabilities • Lifetime Efficiency/Expectancy • Maintenance Requirements • Expected In Service Dates • Costs (Including items that may impact project selection such as: Construction Costs, Outage Costs, Cost of Losses, NPV, etc.)

All of these illustrative criteria are important. However, in NESCOE’s experience, the full range of the ISO-NE’s analysis is not explicit in every case. For example, do construction costs include all components needed for operation or only those that have been priced to date? Are congestion costs related to outages associated with construction included in the analysis?

ISO-NE can, and in our view should, enhance the transparency of the Solution Study evaluation process by clearly defining all of the factors considered in its analysis and formally adopting and implementing a standard matrix for use in presenting to states and stakeholders the full set of factors applied in a project-to-project evaluation. This matrix should track, and more fully detail, the range of factors reflected in the Section 7 list.

State Public Policies Identified by the States as Non-Price Criteria

In addition, when balancing the attributes of multiple projects that are priced competitively in meeting a reliability need, ISO-NE should consider as qualitative criteria whether and the degree to which a project might provide ancillary regional benefits by advancing public policies reflected in state laws that the states identify. In response to FERC Order 1000, New England identified a process to consider public policies in transmission planning. While Order 1000 compliance filings establishing a formal structure for states to identify such policies remain pending at FERC, between now and when Order 1000 procedures become effective, the current planning process for meeting reliability needs can and should recognize unique circumstances warranting the consideration of state public policy goals. Consistent with Order 1000, and provided there is an adequate opportunity for state input, ISO-NE should consider the advancement of those state policies identified by the states as a non-price criteria when evaluating competing reliability projects. The states are pleased to work with ISO-NE on this aspect of the analysis.

2 Page 47

Project Cost Estimates

According to ISO-NE’s Planning Procedure 4 (PP4), at the Solution Study stage, project cost estimates are only required to be within -25% to +50% of expected cost. NESCOE is concerned about the width of this band when project selection is heavily weighted toward the cost of competing solutions. NESCOE strongly encourages ISO-NE to work with project proponents to narrow the estimate bandwidth. It would be false economy and unhelpful to states’ subsequent consideration of a project at the siting phase for ISO-NE to conclude that one project costs less than another if the cost difference is within the estimation error. ISO-NE should also make every effort to ensure that all relevant costs and all components of project cost are included in the estimate: characteristics of competing projects can vary significantly, as can the practices of different developers for arriving at cost estimates.

Furthermore, it is not clear to NESCOE whether ISO-NE is requiring project proponents to use the Project Cost Estimate Template contained in Attachment D to PP4. This template was incorporated into PP4 based on the recommendations of the Project Cost Estimation and Controls Working Group. As you know, in 2008, ISO-NE, NECPUC, and New England transmission owners established the Working Group “to develop recommendations leading to more consistent and transparent estimates for proposed transmission projects.”2 By standardizing the practice for reporting project cost estimates, the template facilitates stakeholder review of cost estimates and side-by-side comparisons of proposed projects. The detailed breakdown of project costs in the template further helps to achieve improved cost estimates and enables close scrutiny of such costs. ISO-NE should require use of the Project Cost Estimate Template if it is not already doing so and, in any case, should make these cost estimate reports available for state and stakeholder review.

It is also not clear to NESCOE that developers of projects exceeding the cost thresholds in PP4 are providing cost estimate updates in accordance with Section 4 of Attachment D to PP4. While the ISO-NE website includes a cost update template, project updates are not reflected.3 These updates are critical to facilitate project cost tracking and understanding of evolving project scope and design changes. NESCOE would appreciate an update from ISO-NE on the status of project cost estimate updates.

Finally, NESCOE remains concerned about project cost overruns. In evaluating alternative projects, NESCOE encourages ISO-NE to give consideration to whether competing projects are willing to cap costs, propose creative ways to limit consumer risk of cost overruns, or otherwise reduce the risk of cost overruns that consumers pay.

2 2009 ISO-NE Regional System Plan at 158. 3 http://www.iso-ne.com/trans/pp_tca/req/proj_cst_est/index.html.

3 Page 48

Thank you for considering these perspectives on the current Solutions Study process and suggested enhancements. NESCOE looks forward to further discussion with ISO-NE on this emerging set of issues.

4 Page 49 www.NextEraEnergy.com

29161 Page 50