April 12, 2021 VIA ELECTRONIC FILING Hon. Michelle L. Phillips
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April 12, 2021 VIA ELECTRONIC FILING Hon. Michelle L. Phillips Secretary to the Commission New York State Public Service Commission 3 Empire State Plaza Albany, NY 12223-1350 RE: Case 20-T-0617: Application of Sunrise Wind LLC for a Certificate of Environmental Compatibility and Public Need for the Construction of Up to 6.2 Miles (320 kilovolt [kV]) of Direct Current (DC) Submarine Export Cable from the New York State Territorial Waters Boundary to the Smith Point County Park on Fire Island in the Town of Brookhaven in Suffolk County and Up to 17.5 Miles (320 kV) of Onshore Transmission Cable from the Landfall at Fire Island to a New Onshore Converter Station in the Town of Brookhaven and Up to 1 Mile (138 kV) of Alternating Current (AC) Onshore Interconnection Cable Connecting to the Existing Holbrook Substation in the Town of Brookhaven in Suffolk County Dear Secretary Phillips: On December 9, 2020, Sunrise Wind LLC (“Sunrise Wind”) filed an application (the “Application”) with the New York State Public Service Commission (the “Commission”) pursuant to Public Service Law (“PSL”) Article VII to secure a Certificate of Environmental Compatibility and Public Need (“CECPN”) to construct, operate, and maintain the Sunrise Wind New York Cable Project (the “Project”).1 On February 28, 2021, you issued a letter in this proceeding identifying certain deficiencies that need to be addressed before the Application can be deemed in compliance with PSL Article VII.2 In addition, since the Application was filed, Sunrise Wind has made certain modifications to the Project (e.g., a route refinement and site selection). As described in more detail below, enclosed for filing in this proceeding, please find Sunrise Wind’s redacted 1 Case 20-T-0617, Application of Sunrise Wind LLC for a Certificate of Environmental Compatibility and Public Need for the Construction of Up to 6.2 Miles (320 kilovolt [kV]) of Direct Current (DC) Submarine Export Cable from the New York State Territorial Waters Boundary to the Smith Point County Park on Fire Island in the Town of Brookhaven in Suffolk County and Up to 17.5 Miles (320 kV) of Onshore Transmission Cable from the Landfall at Fire Island to a New Onshore Converter Station in the Town of Brookhaven and Up to 1 Mile (138 kV) of Alternating Current (AC) Onshore Interconnection Cable Connecting to the Existing Holbrook Substation in the Town of Brookhaven in Suffolk County, 01b_Sunrise Wind LLC Article VII Application with Exhibits A and B (Filed Dec. 9, 2020). 2 Case 20-T-0617, supra, Letter from Secretary Phillips to Messrs. McManus, Mix, and Bellis Regarding Application Deficiencies (Issued Feb. 8, 2021) (the “Deficiency Letter”). Hon. Michelle L. Phillips April 12, 2021 Page 2 narrative responses to the items raised in the Deficiency Letter (the “Deficiency Response”) and a redacted version of the amendment to the Application (the “Amended Application”). The Deficiency Response includes individual, narrative responses to each item identified in the Deficiency Letter.3 Because Sunrise Wind was in the process of amending the Application to reflect recent Project decisions at the time the Deficiency Letter was issued and to ensure a complete evidentiary record, Sunrise Wind incorporated much of the information requested in the Deficiency Letter in the revised Exhibits and Appendices in the Amended Application listed below. As a result, each individual narrative response to the Deficiency Letter either includes the substantive information requested or directs the reader to the relevant, revised Exhibit or Appendix. The Amended Application reflects certain Project decisions made by Sunrise Wind that necessitate global updates to the Application, including, but not limited to: A route refinement for the Onshore Transmission Cable to utilize Victory Avenue in lieu of Montauk Highway at the Carmans River crossing; A route refinement for the Onshore Transmission Cable to utilize Surrey Circle and Church Road in lieu of William Floyd Parkway near the Long Island Rail Road crossing; The selection of the Union Avenue South Site as the Onshore Converter Station location; Route refinements for the Onshore Interconnection Cable to reflect the selection of the Union Avenue South Site and to utilize Union Avenue and existing utility- owned and controlled right-of-way; The determination that the Peconic Avenue Route Alternative for the Onshore Transmission Cable route is not reasonable; and Achieving the full 924 megawatts (“MWs”) of generation capacity from the Project rather than the previously disclosed 880 MWs, consistent with the governing agreement with the New York State Energy Research and Development Authority (“NYSERDA”).4 These Project decisions and associated discussions have been incorporated into the Amended Application. A list of the Revised Exhibits and Appendices filed with the Amended 3 Enclosed as Attachment 1 is a Table of Abbreviations that defines the terms used throughout the Deficiency Response. 4 Please note that Deficiency Response 22 includes appropriate New York State Independent System Operator, Inc. (“NYISO”) approvals for this modification. Hon. Michelle L. Phillips April 12, 2021 Page 3 Application that incorporate these post-filing Project design decisions is provided in the table below. For ease of review, Sunrise Wind prepared both clean and redline revised Exhibits and Appendices and encloses both versions of each revised Exhibit and Appendix for filing. Application Reference Documents in Amended Application Description of Updates Exhibit 2 – Location of Facilities Clean, Revised Exhibit 2, including Reflects route refinements and Revised Figures 2.3-1, 2.3-2, 2.3-3, 2.3- selection of site for Onshore 4, and 2.3-5; Converter Station and reflects Redlined Exhibit 2, with figures listed information solicited in Deficiency above Letter. Exhibit 3 – Alternatives Clean, Revised Exhibit 3, including Reflects route refinements, selection Revised Figures 3.4-1, and 3.6-1; of site for Onshore Converter Station, Redlined Exhibit 3, with figures listed and description of alternatives and above reflects information solicited in Deficiency Letter. Exhibit 4 – Environmental Impact Clean, Revised Exhibit 4, including Reflects route refinements and Revised Figures 4.2-1, 4.2-2, 4.2-3, 4.2- selection of site for Onshore 4, 4.3-1, 4.4-1, 4.5-1, 4.5-2, 4.5-3, 4.6-1, Converter Station and reflects 4.7-1, 4.7-2, 4.7-3, and 4.12-1; information solicited in Deficiency Redlined Exhibit 4, with figures listed Letter. above Exhibit 5 – Design Drawings Clean, Revised Exhibit 5, including Reflects route refinements and Revised Figures 5.3-3, 5.3-4, and 5.3-5; selection of site for Onshore Redlined Exhibit 5, with figures listed Converter Station and reflects above information solicited in Deficiency Letter. Exhibit 7 – Local Ordinances Clean, Revised Exhibit 7; Reflects route refinements and Redlined Exhibit 7 selection of site for Onshore Converter Station and reflects information solicited in Deficiency Letter. Exhibit 8 – Other Pending Filings Clean, Revised Exhibit 8; Reflects route refinements. Redlined Exhibit 8 Exhibit 9 – Cost of Proposed Clean, Revised Exhibit 9 (Redacted);5 Reflects information solicited in Facility Redlined Exhibit 9 (Redacted) Deficiency Letter. Exhibit E-1 – Description of Clean, Revised Exhibit E-1, including Reflects route refinements and Proposed Line new Figures E-1.2-1, E-1.2-2, E-1.2-3; reflects information solicited in Redlined Exhibit E-1, with figures listed Deficiency Letter. above Exhibit E-2 – Other Facilities Clean, Revised Exhibit E-2; Reflects selection of site for the Redlined Exhibit E-2 Onshore Converter Station location. Exhibit E-3 – Underground Clean, Revised Exhibit E-3; Reflects route refinements. Construction Redlined Exhibit E-3 Exhibit E-4 Engineering Clean, Revised Exhibit E-4 (Redacted); 6 Reflects information solicited in Justification Redlined Exhibit E-4 (Redacted) Deficiency Letter. Exhibit E-5 – Effect on Clean, Revised Exhibit E-5, including Reflects route refinements and Communications Revised Figure E-5.2-1; selection of site for Onshore Converter Station and reflects 5 Simultaneous with the filing of this Amended Application, Sunrise Wind is filing confidential versions of the redline and clean Addendum with the Administrative Law Judges in this proceeding under separate cover. 6 Simultaneous with the filing of this Amended Application, Sunrise Wind is filing confidential versions of the redline and clean Addendum with the Administrative Law Judges in this proceeding under separate cover. Hon. Michelle L. Phillips April 12, 2021 Page 4 Application Reference Documents in Amended Application Description of Updates Redlined Exhibit E-5, with figure listed information solicited in Deficiency above Letter. Exhibit E-6 – Effect on Clean, Revised Exhibit E-6, including Reflects route refinements and Transportation Revised Figure E-6.2-1; selection of site for Onshore Redlined Exhibit E-6, with figure listed Converter Station. above Appendix 1-A – Public Clean, Updated Appendix 1-A; Reflects route refinements, selection Involvement Plan Redlined Appendix 1-A of site for Onshore Converter Station, and outreach and notices conducted after filing Application. Appendix 1-B – Agency Outreach Clean, Updated Appendix 1-B; Reflects route refinements, selection and Correspondence Redlined Appendix 1-B of site for Onshore Converter Station, and outreach conducted after filing Application. Appendix 4-B – Visual Resources