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Mayflower Wind Energy, LLC Energy Facilities Siting Board EFSB 19-06/D.P.U

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Mayflower Wind Energy, LLC Energy Facilities Siting Board EFSB 19-06/D.P.U Mayflower Wind Energy, LLC Energy Facilities Siting Board EFSB 19-06/D.P.U. 19-142/19-143 Information Request: EFSB-MWE-1 October 16, 2020 Person Responsible: Seth Kaplan Page 1 of 1 Information Request EFSB-MWE-1 Refer to MWE-SK-1, at 12. Please confirm that although Mayflower Wind Energy, LLC (“Mayflower Wind”) supports the Noticed Variation, Mayflower Wind does not require the construction and operation of the Noticed Variation to interconnect its planned projects consistent with the statement at page 12, lines 18-19 that these particular facilities will not benefit Mayflower Wind directly. Response: Although Mayflower Wind does not now believe it requires the construction and operation of the Eversource (also referred to herein as “the Company”) Noticed Variation to interconnect its planned project, it foresees that there may be benefit from the Noticed Variation in designing and possibly building the facilities to 345 kV. Given the potential for changes in interconnection design for offshore wind projects interconnecting on Cape Cod, designing and possibly building the Noticed Variation facilities to 345 kV may allow for more flexibility in interconnection of Mayflower Wind’s project and other offshore wind projects. 106604999.8 Mayflower Wind Energy, LLC Energy Facilities Siting Board EFSB 19-06/D.P.U. 19-142/19-143 Information Request: EFSB-MWE-2 October 16, 2020 Person Responsible: Seth Kaplan Page 1 of 1 Information Request EFSB-MWE-2 Would the construction and operation of the Noticed Variation to interconnect offshore wind facilities require the construction of additional facilities at the Bourne switching station to allow those projects to interconnect to the transmission grid? Response: Given the relatively low level of design detail currently available for the Noticed Variation, Mayflower Wind cannot state if the construction and operation of the Noticed Variation to interconnect offshore wind facilities would require the construction of additional facilities at the Bourne switching station to allow those projects to interconnect to the transmission grid. Based on the potential for large amounts of wind energy to interconnect at the Bourne switching station, however, it seems reasonable to expect that additional facilities would be required there. 106604999.8 Mayflower Wind Energy, LLC Energy Facilities Siting Board EFSB 19-06/D.P.U. 19-142/19-143 Information Request: EFSB-MWE-3 October 16, 2020 Person Responsible: Seth Kaplan Page 1 of 2 Information Request EFSB-MWE-3 Refer to MWE-SK-1, at 15. Please provide a complete explanation of Mayflower Wind’s “co-operative co-optimization” approach to interconnect its project as referenced at lines four through eight, including all documents provided in its filings with regulatory agencies. If the approach has been described in any agreements or other written correspondence exchanged between the Company and Mayflower Wind, please include those documents and explain whether the approach has been adopted by Mayflower Wind and the Company, and if not, why? Response: Mayflower Wind’s approach to bringing its project’s clean energy to the ISO-NE grid and to Massachusetts customers has always been to seek to minimize environmental impacts and costs through some use of existing transmission routes and rights-of-way (ROWs), to the extent feasible. Such an approach is intended both to enable delivery of the energy from Mayflower Wind’s project to the grid and provide reliability enhancements to the Company’s system for the benefit of its customers. In July 2019, Mayflower Wind submitted a co-location request with the Company. After submission of that request Mayflower Wind and the Company began the process of discussing a co-optimization approach to plan the facilities, to be built in the Company’s ROWs, that would allow for delivery of energy from the Mayflower Wind project while providing reliability benefits to the Company’s customers. That process is ongoing. The Company and Mayflower Wind have not come to any agreement on specifics and, therefore, do not have any documents or correspondence describing an agreed-upon approach. The co- optimization approach is dependent on studies and further discussions of the parties in the context of the interconnection process, including with ISO-NE as a party to the future interconnection agreement. On May 19, 2020, the Company filed with the Federal Energy Regulatory Commission (FERC) in Docket No. ER20-1855 a Preliminary Engineering and Design Agreement (PED Agreement) related to Mayflower Wind’s interconnection request that had been developed as part of the ongoing collaborative process that Mayflower Wind and the Company have been pursuing. That filing is included as Attachment EFSB-MWE-3(1). The PED Agreement, 106604999.8 Mayflower Wind Energy, LLC Energy Facilities Siting Board EFSB 19-06/D.P.U. 19-142/19-143 Information Request: EFSB-MWE-3 October 16, 2020 Person Responsible: Seth Kaplan Page 2 of 2 while not describing the co-optimization approach, does state an intent to evaluate such an approach. For example, Section 3 of Appendix B to the PED Agreement states in part: The Interconnecting Transmission Owner will evaluate potential ways to co-optimize the delivery of the Interconnection Customer’s power along with other planned future needs for ROWs #340 and #341. In no way does this evaluation prejudge or imply acceptance of the Interconnection Customer’s co-location request. Interconnecting Transmission Owner will provide this evaluation to Interconnection Customer as soon as practicable. Both Parties agree that, if Interconnecting Transmission Owner determines that a co- optimized approach is feasible, the Parties will enter into a second agreement outlining the mutual agreement and understanding of the Parties with respect to such co-optimization. The FERC accepted the PED Agreement by letter order dated July 14, 2020. In the months since then, Mayflower Wind and the Company have been discussing co-optimizing some of the Company’s existing transmission route(s) and ROWs in the context of interconnecting Mayflower Wind’s project. The Company has provided one document, dated September 14, 2020, to Mayflower Wind that describes at a conceptual level a potential co-optimization approach involving an interconnection configuration for Mayflower Wind combined with reliability enhancements for the Company’s customers. That document is included as Attachment EFSB-MWE-3(2), which has been redacted for the public record in order to avoid disclosure of Critical Energy Infrastructure Information (“CEII”) and confidential, commercially sensitive and proprietary information. An unredacted copy has been provided to the Siting Board under seal and subject to a Motion for Protective Treatment of CEII and confidential, commercially sensitive and proprietary information, dated October 16, 2020. These co-optimization discussions are ongoing and still at a conceptual stage and have not been reflected in any agreed-upon documented description, and are subject to further analysis by ISO-NE at the system impact study stage of processing Mayflower Wind’s interconnection request. 106604999.8 Mayflower Wind Energy, LLC Energy Facilities Siting Board EFSB 19-06/D.P.U. 19-142/D.P.U. 19-143 Attachment EFSB-MWE-3(1) Page 1 of 26 Document Accession #: 20200519-5145 Filed Date: 05/19/2020 107 Selden Street Berlin, CT 06037 Lisa B. Luftig Senior Counsel Direct Dial: 860-665-3394 Fax: 860-665-5504 E-mail: [email protected] May 19, 2020 Via E-Tariff & E-Filing The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: NSTAR Electric Company; Docket No. ER20-____ Dear Secretary Bose: Pursuant to Section 205 of the Federal Power Act1 and Part 35 of the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) regulations,2 NSTAR Electric Company (“NSTAR” or the “Company”) submits for filing an executed Preliminary Engineering and Design Agreement (“Agreement”) between the Company and Mayflower Wind Energy LLC (“Mayflower”). NSTAR has designated the Agreement as Service Agreement No. IA-NSTAR- 39, and the Company respectfully requests an effective date of the Agreement of May 19, 2020, the date of this filing. I. BACKGROUND AND DESCRIPTION OF AGREEMENT NSTAR is a public utility subsidiary of Eversource Energy, a Massachusetts business trust and public utility holding company under the Public Utility Holding Company Act of 2005.3 NSTAR owns and operates transmission facilities in Massachusetts that are used to provide Regional Network Service under Section II of the ISO New England Inc. (“ISO-NE”) Transmission, Markets and Services Tariff (“ISO-NE OATT”), and Local Network Service and point-to-point service under Schedule 21-NSTAR of the ISO-NE OATT. Eversource Service, a service company subsidiary of Eversource Energy, provides various corporate services to Eversource Energy’s subsidiaries, including NSTAR. 1 16 U.S.C. § 824d (2006). 2 18 C.F.R. Part 35 (2014). 3 Energy Policy Act of 2005, Pub. L. No. 109-58, § 1262, 119 Stat. 594, 972-73 (2005). Mayflower Wind Energy, LLC Energy Facilities Siting Board EFSB 19-06/D.P.U. 19-142/D.P.U. 19-143 Attachment EFSB-MWE-3(1) Page 2 of 26 Document Accession #: 20200519-5145 Filed Date: 05/19/2020 The Honorable Kimberly S. Bose, Secretary May 19, 2020 Page 2 Mayflower is proposing to develop a large generating facility (“Facility”) consistent with its Interconnection Request for Queue Position #829, submitted by Mayflower to ISO-NE on June 17, 2019. The Facility would interconnect to the Company’s 345 kV transmission system at the future 345 kV Bourne Substation in Cape Cod, MA. Mayflower, NSTAR and ISO-NE are not yet in the process of completing a Standard Large Generator Interconnection Agreement (“LGIA”) as contained in Schedule 22 of the ISO-NE OATT. However, ISO-NE has completed a Feasibility Study to evaluate the Facility’s impact on the regional transmission system, which identified the need for the construction of Interconnection Facilities by NSTAR.
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