State of New York Public Service Commission

CH-08 Page 1

STATE OF NEW YORK PUBLIC SERVICE COMMISSION ------x : In the Matter of : : WEST POINT PARTNERS, LLC : Case 13-T-0292 : Application of West Point Partners, LLC for a : Certificate of Environmental Compatibility and Public : Need Pursuant to Article VII of the Public Service Law : : ------x

WEST POINT PARTNERS, LLC RESPONSE TO NYPA-1 INFORMATION REQUEST

NYPA-1: Cable Engineering

In reference to the Applicant’s proposed cable system:

1. Please describe in full detail the cable type selected for the proposed project.

RESPONSE:

The cables for the West Point project are described in detail in Exhibit E-1 of the Application, with additional information provided in Applicant’s Response to Deficiency Item Number 12, which is attached for reference.

2. Please provide the basis for selecting the cable type for the project.

RESPONSE:

The cables will be manufactured and installed by Prysmian, an experienced global provider of cable systems who has served as cable contractor for affiliates of the Applicant on two HVDC submarine cable projects in the recent past. We accept Prysmian’s representation that the cable system it has selected for the West Point project will serve its purpose as intended.

3. Please provide operational data for all submarine cable installations similar or identical to that selected for the project, including a discussion of technology, voltage, transfer capacity and insulation. Provide the location, circuit length, number of cable splices and operation date for the installations discussed in the response to this request.

CH-08 Page 2

RESPONSE:

The Applicant’s affiliate, PowerBridge, LLC, has been directly responsible for two submarine cable installations:

a. Neptune Regional Transmission System, completed in June, 2007. This included submarine installation of a 500 kV HVDC cable system extending approximately 51 miles between Sayreville, NJ and Jones Beach, Long Island, NY, capable of transferring 660 MW in normal operation (up to 750 MW in “overload”). The cable was manufactured and installed by Prysmian (formerly Pirelli). The submarine portion of the route involved two cable splices. A cross section and additional technical data for the main Neptune cable are attached.

b. Hudson Transmission, completed in June, 2013. The submarine installation involved a 345 kV AC cable bundle extending approximately four miles beneath the Hudson River between Ridgefield, NJ and New York City, with transfer capacity of 660 MW. The cable was manufactured and installed by Prysmian. A cross section of the main Hudson cable is attached.

Name of Person(s) Preparing Response: Christopher Hocker Dated: March 19, 2014

2 CH-08 Page 3 ATTACHMENT - WPP Response to NYPA-1(1) Page 1 of 5

STATE OF NEW YORK PUBLIC SERVICE COMMISSION ------x : In the Matter of : : WEST POINT PARTNERS, LLC : Case 13-T-0292 : Application of West Point Partners, LLC for a Certificate of : Environmental Compatibility and Public Need Pursuant to : Article VII of the Public Service Law : : ------x

RESPONSE TO DEFICIENCY ITEM 12

DPS 12:

The documents do not comply with 16 NYCRR §88.1(b), which requires that the application include a detailed description of the type, size, number and materials of the conductors. The size (diameter) of the HVDC in-river and HVDC land cables and the size (diameter) of the fiber optic communications cable should be provided.

Response:

The diameter of the HVDC in-river cable, described in Exhibit E-1.2.1 of the Application and for which a typical cross section diagram is shown in Figure E-1-1, is 5.61 inches. The diameter of the HVDC land cable, described in Exhibit E-1.2.2 of the Application and for which a typical cross section diagram is shown in Figure E-1-2-Revised, is 5.00 inches. As described in Exhibit E-1.4 of the Application, a fiber optic communications cable will be installed alongside both the land and in-river power cables. The diameter of the in-river fiber optic cable is 1.38 inches and the diameter of the fiber optic land cable is 0.44 inches. Figures representing cross sectional drawings of the fiber optic land and submarine communication cables are attached. Figures E-1-1-Revised and E-1-2-Revised indicate the outer diameter of the cable.

Dated: August 22, 2013

J:\W296-000 West Point Partners Route Concept\Regulatory\Article VII\DPS Comments\Deficiency Letter_2013_0802\Final Package Parts\WPP_Deficiency_Response_Final.doc CH-08 Page 4 ATTACHMENT - WPP Response to NYPA-1(1) Page 2 of 5

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Title: Document N.: West Point HVDC Link PPL-11-147-SE-TP(l ).0 Date: May 01 , 2013 I Page: 1 /2 This document co ntains information proprietary to Prysmian Powerlink and shall not be reproduced or tra nsferred to other documents or disclosed to others or used for anv ouroose other than that for which it is furnished without the written oermission of Prvsmian Powerlink

..,;i: c 0 :,:; .,0 VJ I x., :a 0 u .,~ > 12 I E u ~ I I I w I ~ :J Ll: I (Diagrammatic Only- Not to Scale)

West Point Partners, LLC HVDC In-River Cable West Point Transmission Project Cross Section Athens to Buchanan, New York Revised: August 13, 2013 Scale: N.T.S. Figure environmental consulting & engineering services E-1-1-Revised Source: Prysmian Power Cables & Systems CH-08 Page 5 ATTACHMENT - WPP Response to NYPA-1(1) Page 3 of 5

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Title: Document N.: West Point HVDC Link PPL-11-147-SE-TP(l ).0 Date: May 01 , 2013 I Page: 2/2 This document co ntains information proprietary to Prysmian Powerlink and shall not be reproduced or tra nsferred to other documents or disclosed to others or used for anv ouroose other than that for which it is furnished without the written oermission of Prvsmian Powerlink

;i: "Oc 0 :;; .,0 Ul I x., :0 (.)" "O c .3 (.) ~ I I N wI I (Diagrammatic Only - Not to Scale) ~ :J Ll: I

4. Insulation screen Outer Cable Diameter = 5 inches

West Point Partners, LLC HVDC Land Cable West Point Transmission Project Cross Section Athens to Buchanan, New York Revised: August 13, 2013 Scale: N.T.S. Figure environmental consulting & engineering services E-1-2-Revised Source: Prysmian Power Cables & Systems CH-08 Page 6 ATTACHMENT - WPP Response to NYPA-1(1) Page 4 of 5

~ ~ P8YSl\lllA N Project: Customer: "' ~ PDWERLINK "'w "' SU9MAA IN 'E AN[) H,\I' West Point (WPP) POWERBRIDGE @ 'W""" E CABL ES & SVSTE ,tH Project N.: PPL-11-147

8 Title: Document N.:

PPL-11-147-SE-TP{2).0 TECHNICAL SPECIFICATION FOR OPTICAL FIBER SUBMARINE CABLE Date: May. 01, 2013 I Page: 6/7 This document contains information proprietary to Prysmian Powerlink and shall not be reproduced or transferred to other documents or disclosed to others or used for any purpose other than that for which it is furnished without the written permission of Prysmian Powerlink

5. DWA SUBMARINE OPTICAL CABLE CROSS SECTIONAL AREA

3' ""CJc: :e0 (/) "'I x :0"' 0 u

Diagrammatic only - not to scale - fibers are not in bundles

No. Description Thickness Outer Diameter (Norn.) Optical Fibers; Each fiber is uniquely identified by a fiber 01 up to 48 fibers color (see color scheme)

02 Water blocking filling compound and hydroget - - 03 Laser welded stainless steel tube - - 04 Polyethylene Oversheath - 12 mm 05 Galvanized steel wires (1st I 2nd layer) 3,0 I 3,5 mm - 06 PP bedding - - 07 PP serving - 35

West Point Partners, LLC FO In-River Cable West Point Transmission Project Cross Section ($ Athens to Buchanan, New York group Scale: N.T.S. Figure wnv lr\)nm~ntel consult llQ & eri glnee~lnO s~fVice• E-1-4 Source: Prysmian Power Cables & Systems CH-08 Page 7 ATTACHMENT - WPP Response to NYPA-1(1) Page 5 of 5 NOMINAL DESIGN PARAMETERS

~ Fiber Count 2-60 62-7 2 74-96 98-120 122-144 146-216 2 18-264 266-288 290-312 "' Buffer Tube Count 6 8 10 12 18 22 24 26 "'w @ Buffer Tube OD (mm) 2.65 2.65 2.65 2.65 2.65 2.65 2.65 2.65 2.65 E (mm) 11.1 12.0 13.7 15.4 17.3 17.6 19.0 20.0 21.3 Cable OD 8 (inches) 0.44 0.47 0.54 0.61 0.68 0.69 0.75 0.79 0.84 (kg/km) 82 98 125 158 19 7 191 2 28 255 285 Cable Weight (lb/kft) 55 66 84 106 132 128 1 53 171 191 (m) 12,800 12,800 12,800 12,636 10,013 9,675 8,302 7,493 6,605 Max. Length (ft) 41 ,984 41 ,984 41 ,984 41,446 32,843 31,734 27,231 24,577 21 ,664 (mm) 13.0 13.7 15.4 17. 1 19.0 Cable OD (inches) 0.51 0.54 0.61 0.67 0.7 5 (kg/km) 116 134 165 195 248 Cable Weight (lb/kft) 78 90 111 131 16 7 (m) 12 ,800 12,800 12,800 10,013 8,215 Max. Length - (ft) 41,984 41,984 41,984 32,843 26,9 45 CABLE CONSTRUCTION

·acket desi ns onl Outer Stren th Members where a licable Dielectric Central Stren

3: Water Blockin Ta e "O Gel-Filled Buffer Tube Containin u to 12 Fibers "0 ~ Ri cord (/) "I x :0" 0 (.)

ORDERING INFORMATION Select a part number according to the fiber count you want: Fiber Count D fJ DD 0002-0006 D D SlLAFE DD A 0008-0036 D D TlLAFE DD A Note: Standard lay-up for fiber counts of 1 2 or more is 0038-0312 D D 51LAFE DD A 12 fibers per tube. Please call for custom lay-ups.

Then, use the following options to complete the part number: D Fiber Type D Attenuation H = G.6 5 2.D Single-Mode Low Water Peak B = 0.35/0.3 5/0.25 dM

Example: If you need a 36 count Flexlink™ single jacket cable with G.652.D LWP Single-Mode fiber and 0,40/0.40/0.30 attenuation, order Part Number 0036HCT1 LAFESJA.

To place an order, contact us in one of the following ways: 700 Industrial Drive, Lexington SC 29072 - (800) 669-0808 (Inside Sales) - Fax (800) 951-5040 - [email protected]

Copyright 20 10 Pry smi an Communic ations Cabl es and Systems USA, LLC. All rights res erve d. Prysmian Featur es and spec ific ation s subjc:ct to change without notice. and Fl exlink are rradem,.- ks of Prysmi an. DS-001 Rl 2

West Point Partners, LLC FO Land Cable West Point Transmission Project Cross Section ($ Athens to Buchanan, New York group Scale: N.T.S. Figure wnv lr\)nm~ntel consult llQ & eri glnee~lnO s~fVice• E-1-5 Source: Prysmian Power Cables & Systems CH-08 Page 8 ATTACHMENT - WPP Response to NYPA-1(3[a]) Page 1 of 2 NEPTUNE RTS™

Sayreville NJ - Duffy Avenue Long Island NY l1Rl:.LL7

3. TECHNICAL SOLUTION

We give here some details about the proposed technical solution. Submarine Segment: The HVDC 500 kV 2100 mm2, paper insulated MIND cable (CHLENJFJ type) and MV 20 kV 1900 mm2, XLPE insulated cable (RE4H1 EJFJ type) are proposed.

3.1 HVDC 2100 mm2 500 kV Submarine cable

1 2 3 4 s 6 7 8 g 10

CONSTRUCTIONAL DETAILS

1 · Copper Conductor: Description: Copper conductor of segmental strips Nominal cross section: mm2 2100 Diameter of circular conductor: mm 51.9 2 · Conductor Screen 3 · Insulation: Description: Non-pressure assisted, mass impregnated, wood pulp paper tape insulation Thickness: mm 19.5 4 · Insulation Screen 5 ·Lead Alloy Sheath: Description : Extruded Lead Alloy Nominal thickness mm 3.45 Overall diameter : mm 100

July 2004 EXHIBIT C Page 5 of 12 CH-08 Page 9

NEPTUNE RTS™ ATTACHMENT - WPP Response to NYPA-1(3[a]) Page 2 of 2

Sayreville NJ - Duffy Avenue Long Island NY l1A1:LL'i

6 - PE Sheath: Description: Extruded black polyethylene sheath Nominal thickness mm 3.45 Overall diameter : mm 107 7 - Reinforcement: Description: Two layers of galvanised steel tapes Thickness mm 0.3 8 - Bedding: Description/type: Polyester Tapes 9 -Armour: Description: Galvanised steel wires Diameter of armour wire: mm 5.5 Nominal diameter mm 123 10 - Serving: Description/type: Polypropylene strings Nominal thickness mm 3.5 Overall diameter of the cable mm 131 I In air 53.5 Weight of cable kg/m I In water 44

Electrical Data

DC resistance of conductor at 20 °c Ohm/km 0.0086

DC resistance at maximum operating temperature Ohm/km 0.00978 Max. Losses at nominal load (600 MW) W/m 14.6 Max. Losses at continuous overload (660 MW) W/m 17.7 Max. Losses for 750 MW overload W/m 22.83

Capacitance to neutral µF/km 0.42

July 2004 EXHIBIT C Page 6 of 12 CH-08ATTACHMENT Page 10 - WPP Response to NYPA-1(3[b]) Page 1 of 1

~ PRYSMIAN www.prysmlan.com w CAIUS & S'f5Tl!M5

345 kV HUDSON TRANSMISSION PROJECT

Typical cross section drawing of underwater cable

l 2 3 4 5 6 7 B ""7)--9 10 lL 12 13

NOTTO SCALE L egend : Item Description 1 Fluid Du ct Conductor Cross section 2 nnn' 2000 Self supporting segmental strips of copper 3 Conductor screen 4 Insulation Impregnated PPL paper tapes 5 Core screen 6 Extruded 'E' lead alloy sheath 7 Bronze tape Reinforcement 8 Seoaration Extruded anti-corrosion iacket 9 Bedding 10 1st Armour - copper flat w:ire 11 Binding 12 znd Armour - Copper flat w:ire Extruded polyethylene Serving 13 Nominal diameter nnn 147 kg/m 65 Approx. cable weight: Im rnr in water kg/m 48 c 0 V> I U :J "0 :r:1 N0 "'.;- .;-- :r: UI Prysmian c avi e Sist eml Energia S.r.I. o'" w.. ::!' <( w ~ ~ ::::! o ~--~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~_.

Hudson Transmission Partners, LLC Typical Cross-Section The Hudson Project Submarine Self Contained Fluid Filled (SCFF) cable

Engineers Scientists Source: Prysmian Power cables and Syst.ems Figure consultants E1·1 CH-08 Page 11

WEST POINT PARTNERS, LLC RESPONSE TO NYPA-2 INFORMATION REQUEST

NYPA-2: Cable Engineering

In reference to Applicant’s proposed cable system that will cross any existing NYPA cables, please respond to the following:

1. How will the Applicant establish the precise location of existing NYPA cables?

RESPONSE: Per proposed Certificate Condition 16, prior to conducting the pre-installation grapnel run, WPP will meet with owners of infrastructure located in the River to, among other things, identify the precise location of such infrastructure. As needed, locations will be confirmed by means of magnetometer and/or sonar technology. 2. Provide the exact location where the Applicant’s cable system will cross NYPA cables. Attach all maps, diagrams and location data to the response.

RESPONSE: See the response to Central Hudson Gas & Electric Information Request 1 (attached). A grant of submerged lands to NYPA from OGS was identified at River Mile 66. This grant is within the area labeled “Pipeline and Cable Area” on Sheet 10 of Figure 2-3 in the Application. The exact location will be determined as described in response to NYPA Information Request 2(1). 3. Provide copies of the methods, procedures, and plans that the Applicant will use to construct that portion of its cable system that will cross NYPA cables.

RESPONSE: See the response to Central Hudson Gas & Electric Information Request 3 (attached).

CH-08 Page 12

4. Provide all environmental procedures, practices and protections that the Applicant intends to use within 500 feet of the location where the proposed cable system will cross NYPA cables.

RESPONSE: See response to NYPA Information Request 2(3).

5. Does the Applicant intend to cross above or below NYPA cables?

RESPONSE: Above.

6. Provide the sediment transport model, including identifying the quality of the sediment and river bottom material that the Applicant intends to use.

RESPONSE:

The sediment qualities are described in Section 4.5 of Exhibit 4 of the Application and Appendix 4B. The modeling results are provided in Appendix 4C. WPP does not intend to “use” sediment or river bottom material. The jet-plow installation technology fluidizes the existing sediment along the course of the planned cable route creating a temporary trench in which the cable bundle is deposited. The majority of the fluidized sediments resettle into the trench. Over time, river currents and tidal action will result in the deposition of naturally occurring sediment returning the riverbed to its original bathymetry.

Name of Person(s) Preparing Response: Christopher Hocker Dated: March 19, 2014

CH-08 Page 13 ATTACHMENT - WPP Response to NYPA-2(2)

WEST POINT PARTNERS, LLC RESPONSE TO CHGE-1 INTERROGATORY/DOCUMENT REQUEST

CHGE-1 (Borchert)

1. Please describe all actions taken by West Point Partners to identify the specific location and characteristics of all Central Hudson electric and gas facilities that could potentially be impacted by the proposed project, especially those Central Hudson facilities that cross the Hudson River?

RESPONSE:

Existing utilities located within the Hudson River in the Project Area were identified by reviewing geo-referenced NOAA nautical charts and survey maps of Grants and Easements available at the NYS Office of General Services (OGS Maps). The OGS maps were geo-referenced to the extent possible using the landmarks depicted on the maps. From these geo-referenced maps, the approximate horizontal position of the utility easements for CHGE and other utilities in the Hudson River were added to the Project’s AutoCAD database.

Name of Person(s) Preparing Response: Payson Whitney Dated: February 3, 2014 CH-08 Page 14 ATTACHMENT - WPP Response to NYPA-2(3) Page 1 of 5

CHGE-3 (Borchert)

3. Please describe specifically how West Point Partners will protect each of Central Hudson's gas and electric facilities that are located near or crossed by the proposed project from damage during the construction process for the proposed project?

RESPONSE:

The Applicant’s personnel have had significant experience in the crossing of utilities with buried submarine cable. The Neptune required 12 such crossings in 2006, most of which were in the Raritan River in New Jersey. The Hudson Project required one utility crossing in 2011 (the Transco pipeline in the Hudson River). The Applicant is fully aware of the potential risks and liabilities associated with utility crossings, since it bears these risks to the same extent as the utility owner, and has mitigated these by engaging an experienced installation contractor, verifying the location and depth of the utilities to be crossed, reaching acceptable mutual agreements with utility owners, and providing adequate commercial insurance. The attached Figure IR-DPS-14 illustrates a typical method that may be used for crossing existing utilities in the Hudson River. Also attached are depictions of crossing methods used for the Neptune project (water, gas, and telecommunication) and the Hudson project (gas). Methods range from simple unprotected crossing, to reducing the cable burial depth in order to maintain adequate separation between the cable and the utility, to mattressing with or without protective sleeves. The Applicant will hold discussions with CHGE about the details of each planned utility crossing and will reach agreement on mutually acceptable crossing arrangements prior to cable installation. In the Applicant’s experience, crossing methods are not particularly dependent on the type of utility (gas, water, electric, etc.) but are dependent on such factors as the depth of the existing utility, the required separation between the cable and the existing utility, and the physical properties of the sea or river bed. The details of the methodology are typically the subject of a mutual agreement with the utility owner. Name of Person(s) Preparing Response: Christopher Hocker Dated: February 3, 2014

3 CH-08 Page 15 ATTACHMENT - WPP Response to NYPA-2(3) Page 2 of 5

0 0 0 0 0 0 0 0 0 00 0 0 0 0 0 0 0 0 0 0 0 0 C• 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 00 0 0 0 VARIES PRESENT HVDC CABLES & FO RIVER BOTTOM BFT

VARIES

EXISTING UTILllY

PROFILE N.T.S.

PRESENT RIVER BOTTOM CONCRETE MATTRESS (2) HVDC CABLES

FIBER OPTIC CABLE(FO)

EXISTING UTILITY

CROSS-SECTION N.T.S.

West Point Partners, LLC Typcal Utlllty Crossing E$ West Point Transmission Project group

IR-DPS-14 Date: Januaty 2014 CH-08 Page 16 ATTACHMENT - WPP Response to NYPA-2(3) Page 3 of 5

~100· .SD' [30 m] [1D m]

SAi. II.II. ------·-·----·-··---·----·- .. --- ..·-- CH-08 Page 17

ATTACHMENT - WPP Response to NYPA-2(3) Page 4 of 5

SEABED SURFACE :!: I Exlllltna wvlca J -----· 1 Cablo Bundle I

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ATTACHMENT - WPP Response to NYPA-2(3) Page 5 of 5

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HUDSON PROJECT NOTE: - DRAWING NOT IN SCALE CH-08 Page 19

WEST POINT PARTNERS, LLC RESPONSE TO NYPA-3 INFORMATION REQUEST

NYPA-3: Cable Engineering

In reference to the Applicant’s proposed cable system that will cross NYPA cables, please respond to the following:

1. Describe in detail the protective measures that the Applicant will take to ensure that NYPA cables are not damaged because of construction or maintenance activities.

RESPONSE:

The details will be developed in consultation with NYPA in the process described in proposed Certificate Condition #16 and memorialized in an agreement with NYPA. The kind of measures available are described in the response to NYPA Information Request 2(3).

2. Describe the methodology that the Applicant intends to use to maintain the position of the West Point Partners Line where it crosses NYPA cables.

RESPONSE:

Utility infrastructure crossing plans will be prepared in advance of cable installation in cooperation with the infrastructure owner. At each crossing, the jet plow will follow the route’s pre-programmed coordinates to insure the correct location is maintained. If necessary, based on the crossing agreement, divers will be employed to ensure the cable is installed as planned.

CH-08 Page 20

3. Describe the procedures that the Applicant will employ if construction or maintenance activities are required to cease on the West Point Partners Line where it crosses NYPA cables because of necessary NYPA work on its cables or any other reason.

RESPONSE:

Such procedures will be the subject to an agreement reached with NYPA in the process described in proposed Certificate Condition 16.

4. Provide a copy of the Applicant’s proposed operations plan, including procedures for notifying NYPA about the Applicant’s construction and maintenance activities within 500 feet of NYPA’s facilities.

RESPONSE:

WPP’s cable vendor and installation contractor will create an Operation and Maintenance Plan that will address notification procedures for maintenance activities. Notification of NYPA concerning construction activities will be addressed in the crossing agreement developed in the process described in proposed Certificate Condition #16. Attached is a copy of the Submarine Cable and Inspection Plan for the Neptune project, provided for illustrative purposes.

Name of Person(s) Preparing Response: Christopher Hocker Dated: March 19, 2014

6 CH-08 Page 21 ATTACHMENT - WPP Response to NYPA-3(4)

PRYSMIAN POWER CABLES & SYSTEMS, LLC South Plainfield, New Jersey

SUBMARINE CABLE INSPECTION AND MAINTENANCE PLAN

for the

NEPTUNE REGIONAL TRANSMISSION SYSTEM

June 2008

Prepared by

Henningson, Durham & Richardson Architecture and Engineering P.C. in association with HDR Engineering, Inc. One Blue Hill Plaza Pearl River, NY 10965 CH-08 Page 22

TABLE OF CONTENTS

1.0 Introduction ...... 1 2.0 Post-Installation Inspection ...... 1 3.0 Routine Monitoring and Cable Inspections ...... 2 3.1 Methods...... 3 3.2 Frequency ...... 3 3.3 Reporting...... 5 4.0. Cable Maintenance and Repair ...... 5 5.0 Cable Decommissioning Plan ...... 7 CH-08 Page 23

1.0 INTRODUCTION

Neptune Regional Transmission System, LLC (Neptune) was granted federal, state, and local permits and approvals for the construction and operation of a 660 megawatt high-voltage direct- current (HVDC) transmission line. The transmission line extends from the Borough of Sayreville, Middlesex County, New Jersey to the Town of North Hempstead, Nassau County, New York. Construction began in September 2006 and was completed in June 2007. The submarine portion (approximately 51 miles) of the power transmission cable was buried below the seabed from the Sayreville converter station on the Raritan River in New Jersey to a point approximately 1,200-ft offshore and due south of Jones Beach State Park in New York. The submarine cable was laid and buried simultaneously using a hydro-plow (water-jetting technology).

A post-installation inspection, maintenance, and decommissioning plan for the submarine cable was developed as part of the federal and state permit conditions issued to Neptune by New Jersey Department of Environmental Protection (NJDEP) Permit No. 1219-02-0005.2 WFD 040001 Conditions 21 - 24, Condition 21, N.J.A.C. 7:7E-3.12) and New York State Public Service Commission (NYSPSC) (CASE 02-T-0036) Certificate Conditions 11 and 12. Permit conditions require Neptune to perform periodic inspection and maintenance of the submarine cable, as required.

Neptune prepared and submitted a submarine cable maintenance plan as part of the Environmental Management and Construction Plan (EM&CP) developed for the project (Appendix A). A detailed cable inspection and maintenance plan, reflecting the as-built cable location and initial cable inspection activities immediately following cable installation is provided in the following sections.

2.0. POST-INSTALLATION INSPECTION

Post-installation cable inspection occurred during and immediately following cable installation. Post-installation cable inspection consisted of remote telemetry to determine cable placement (i.e., horizontal position and burial depth relative to the seafloor) during hydro-plowing and diver CH-08 Page 24

inspection and subsequent burial where satisfactory results were not initially achieved by hydro- plow. Results of the post-installation inspection are provided in the April 2007 Neptune 500 kV HVDC Submarine Interconnector – Final Submarine Installation Report (Prysmian 2007). Post- installation as-built drawings of the submarine cable were submitted to: the New Jersey Department of Environmental Protection (NJDEP), the New York State Department of Environmental Conservation (NYSDEC), New York State Department of Public Service (NYSDPS), New York State Office of Parks, Recreation and Historic Preservation (OPRHP), U.S. Army Corps of Engineers (USACE), U.S. Coast Guard (USCG), National Oceanic and Atmospheric Administration (NOAA) Nautical Data Branch, Sandy Hook Pilots Association and fishing interest groups (i.e. the Garden State Seafood Association, National Fisheries Institute, and the North Atlantic Clam Association)..

Overall, cable installation to permit-required depths was achieved for over 95% of the entire route during initial lay-and-bury installation via hydro-plow. Cable installation to permit requirements over the remaining route (approximately 5%) was achieved via divers, primarily at those locations where the hydro-plow could not operate (e.g., active utility crossings). Cable installation at these locations was achieved through hand jetting via divers and/or through the installation of extra cable protection per permit conditions (e.g., separation sleeves, grout mattresses). Details of post lay-and-bury activities are described in the April 2007 Neptune 500 kV HVDC Submarine Interconnector – Final Submarine Installation Report (Prysmian 2007).

3.0 ROUTINE MONITORING AND CABLE INSPECTIONS

Neptune will perform routine monitoring and scheduled cable inspections to evaluate the cable condition, its location, burial depth and to identify maintenance or repair requirements. The cable inspection plan is based upon regulations adopted by NJDEP for submerged cables (N.J.A.C. 7:7E-3.12) as incorporated into project permit requirements (NJDEP Permit NO. 1219- 02-0005.2 WFD 040001 Condition 21 and NYS PSC Certificate Condition 11). Cable inspections will be coordinated with USCG (e.g., Notice to Mariners) and USACE, as necessary. CH-08 Page 25

3.1 Methods

Continuous monitoring of the cable will be accomplished through shore-side instrumentation, which monitors the cable for possible faults or damage (Level 1 Survey, see Table 1). If a fault is detected a number of techniques are employed to determine the location of the fault (e.g., bathymetric, side scan sonar, magnetometer or audio sensing) or physical surveys (e.g., diver inspections) (Table 1).

Table 1: Cable Monitoring and Inspection Methodologies

SURVEY METHOD DESCRIPTION AND USE Level 1 HVDC Control System Continuously monitors voltage and current at both ends of the cable

Level 2 Remote sensing using time domain Electronic pulse-echo measurement techniques are reflectometer (TDR) and/or a optical used to identify cable faults and to determine the time domain reflectometer (OTDR) distance and approximate location of the fault.

Level 3 Bathymetric Surveys Provides depth contour maps of the sea-bottom using a recording echo sounder (~200 kHz) and an integrated DGPS navigation system.

Level 3 Marine Magnetometer Surveys are conducted using towed marine magnetometer and an integrated DGPS navigation system to identify the location of metal objects.

Level 3 Side Scan Sonar Provides a sonic "photograph" of the sea floor using a towed or vessel-mounted high frequency transducer (100-500 kHz) and an integrated DGPS navigation system.

Level 4 Underwater Camera and Video Remote visual inspection of the seafloor and cable using ROV or towed camera/ video techniques.

Level 4 Remote sensing using magnetic probe Remote measurements of magnetic field from on-site vessel. deflections are used to determine fault locations on- site.

Level 5 Diver Inspections Visual and physical inspection of the seafloor and cable condition using SCUBA or commercial diving techniques.

3.2 Frequency

Within the first two years of cable installation, two (2) routine cable inspections will occur. Routine (i.e., annual) cable inspections will consist of remote sensing surveys to determine cable CH-08 Page 26

location and approximate cable burial depth relative to the seafloor. Routine cable inspections will consist of bathymetric, marine magnetometer and side scan sonar surveys (Level 3 Surveys) conducted along the submarine cable route from landfall at Jones Beach, New York to landfall at Sayreville, New Jersey. Routine cable inspections will occur once every five (5) years thereafter for the period that the cable remains in active service.

Additional cable inspections (i.e., unscheduled inspections) will occur as needed within environmentally sensitive locations (i.e., bottom trawl fishing areas, utility crossings and landfall locations) following significant storm events and reported incidents of potential cable damage (i.e., cable strikes or fouling from vessel anchors or fishing gear) or as may be warranted based on continuous monitoring or routine inspection results. Unscheduled inspections may consist of remote sensing (Level 3 and/ or Level 4 Survey Methods) or physical surveys (Level 5 Survey Methods) depending on the nature of the event.

Unscheduled or non-routine inspections will occur as soon as possible following a significant storm event (i.e., Nor’easter or hurricane) as defined by the NOAA National Weather Service (NWS) or following receipt of information suggesting that the cable has been damaged or uncovered to verify if that cable has been unburied. Significant storm events in the New York Bight can include violent winter storms (i.e., Nor’easters), with sustained winds greater than 64 miles per hour (56 knots), and hurricanes with sustained winds in excess of 72 miles per hour (64 knots).

Cable inspections following significant storm events or reports of potential cable damage will focus on specific areas of potential or known damage or those areas where the cable may have been uncovered (e.g., areas prone to sediment movement) using remote sensing (e.g., bathymetric, side scan sonar, magnetometer, audio sensing) surveys (Level 3 and/ or Level 4 Surveys). Sections of the submarine cable route indicating damage or changes in as-built condition may be further assessed by physical surveys (e.g., diver inspections) (Level 5 Surveys). CH-08 Page 27

3.3 Reporting

Neptune will report the results of continuous monitoring and routine (i.e., annual) cable inspections to USACE, USCG, NJDEP, NYS DPS, NOAA and fishing interest groups identified in N.J.A.C. 7:7-4.2(a)3. Reports will summarize monitoring methods and inspection results, and note changes in cable location (i.e., horizontal position and burial depth relative to the seafloor) or condition. Changes in cable location will be determined based on comparison to as-built and prior inspection information within the limitations of survey method accuracy. Annual inspection results will also include the results of unscheduled or non-routine inspections, as necessary (see below), and a summary of reported incidents of potential cable damage. Reports will also include a discussion of cable maintenance and repair activities occurring that year, and a schedule of planned or upcoming cable service activities. Submarine cable inspection reports will also indicate if and when the cable is taken out-of-service.

Reports will be submitted within three (3) months following annual inspections. Submarine cable conditions identified and found to be a hazard to bottom fishing gear, commercial traffic, or other marine activities will be reported to the appropriate agencies and groups within two (2) weeks of confirmation of the submarine cable condition.

Neptune will report changes in cable location or condition determined during unscheduled or non-routine inspections within two (2) weeks following cable inspection. Neptune will report changes in cable location based on unscheduled or non-routine inspections to USACE, NJDEP, NYS DPS, and NOAA.

4.0 CABLE MAINTENANCE AND REPAIR

Cable maintenance and repair requirements will depend on the nature of the maintenance activity (e.g., reburial) and/ or damage to the cable (e.g., external vs. internal fault). The need for cable repair, reburial or added protection measures will also depend on the cable location (e.g., navigation channel, utility crossing), which cable needs repair (e.g., fiber optic) and the extent of cable exposure or damage. CH-08 Page 28

Cable maintenance and repair activities are expected to generally occur within the final corridor of the cable route (i.e., within 10-20 m of the centerline of the cable). Cable repair may require the cable to be temporarily removed from service, uncovered or lifted from the seabed, and reburied prior to return to service. Cable repair activities will depend on the type and extent of cable damage or fault, and will be closely coordinated with NJDEP, NYSDPS, NYSDEC, USACE and USCG on a case-by-case basis (Table 2).

Reburial of the cable will occur within 90 days, if practicable, and no later than six months after cable repair or confirmation that the cable has become unburied.

Table 2: Examples of Cable Condition and Associated Maintenance/Repair Actions CONDITION ACTION

Cable exposed, moved or buried at less than Post-lay burial machine will be deployed from the repair barge and acceptable depth as determined by used to rebury the cable bundle to the required depth. Divers may comparison to as-built location. use water jetting to increase burial depth OR; Exposed cable will be covered with grout mattresses, bags of sand, or similar protection

Cable snagged with bottom fishing gear, Mechanical removal of any snags, damage inspection, repair if anchor or debris. warranted and relocate and/ or rebury as described above.

Cable damaged or not functioning per Uncover cable, repair in place, and rebury as described above OR; specifications (remote sensing using TDR Uncover, lift section from trench, repair in water, replace and and/or OTDR to identify the distance to the rebury as described above OR; fault and determine type of fault from shore Uncover, lift section from trench and onto floating platform for terminal stations). repair, replace, and rebury as described above

Neptune and Prysmian have an Emergency Response Plan and are prepared to respond immediately if necessary. An experienced repair crew will be available on-call. Support vessels, standard marine equipment, tugs, and commercial divers will be contracted as needed.

Neptune will coordinate cable inspection and maintenance activities with USCG and USACE, and will notify NJDEP, NYSDPS, NOAA, NYSDEC, and fishing interest groups identified in N.J.A.C. 7:7-4.2(a)3 upon receipt of information that the cable may be exposed (i.e., uncovered). Neptune will notify additional agencies (e.g., New York State Office of Parks, Recreation and CH-08 Page 29

Historic Preservation) if necessary, before any maintenance work associated with the submarine cable commences.

5.0 CABLE DECOMMISSIONING PLAN

Cable decommissioning (i.e., removal and/or abandonment) will comply with NYS DPS, NJDEP and USACE permit conditions, as well as New York State Office of General Services (NYSOGS) easement requirements. In the event of termination of easements or abandonment, Neptune may apply to leave the inactive cable in place, consistent with the NYSOGS and other pertinent easement decommissioning plans, if leaving the cable would not result in adverse impacts or unreasonably interfere with fishing or other uses of the seabed (pursuant to Special Condition O of the USACE Permit No. 2002-00134). Otherwise, within two years of the cable being removed from service or within two years of termination of pertinent easements, Neptune will remove the cable from the seabed, leaving the area in the same condition, as practicable, prior to cable removal. Decommissioning activities would be closely coordinated with NJDEP, NYSDPS, NYSDEC, USACE and USCG. CH-08 Page 30

WEST POINT PARTNERS, LLC RESPONSE TO NYPA-4 INFORMATION REQUEST

NYPA-4: Environmental

1. Please provide a copy of the Applicant’s Emergency Response Plan.

RESPONSE:

Applicant has not yet developed an Emergency Response Plan for this project. In the experience of Applicant’s affiliate, PowerBridge, such plans are specific to the circumstances of each individual project; moreover, separate plans are likely to apply during the construction and operating phases. Applicant will be willing to review its Emergency Response plans and procedures with NYPA to the extent they may be applicable to the protection of NYPA facilities.

2. Please provide any and all GIS data in ESRI ArcMap (v 9.2 or earlier) personal geodatabase and/or shapefiles for West Point Partners, LLC’s proposed transmission line.

RESPONSE:

Applicant is willing to share this data with NYPA to the extent it is needed to understand the planned cable route’s location vis-a-vis NYPA facilities, upon execution of a Non- Disclosure Agreement.

3. When does the Applicant intend to prepare a Spill Prevention, Control and Countermeasure (SPCC) plan? Will this plan describe Applicant’s communications protocol in the event an environmental release occurs from one of NYPA’s cables as a result of Applicant’s construction and/or maintenance operations?

CH-08 Page 31

RESPONSE:

Applicant will prepare its SPCC Plans at the time of preparing its Environmental Management and Construction Plan. A communications protocol regarding the environmental release from one of NYPA’s cables could be included in the agreement between Applicant and NYPA regarding the crossing of NYPA’s cables.

Name of Person(s) Preparing Response: Christopher Hocker Dated: March 19, 2014