The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 Charles D. Baker GOVERNOR Tel: (617) 626-1000 Karyn E. Polito Fax: (617) 626-1081 LIEUTENANT GOVERNOR http://www.mass.gov/eea Kathleen A.Theoharides SECRETARY
August 7, 2020
CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE ENVIRONMENTAL NOTIFICATION FORM
PROJECT NAME : Vineyard Wind Connector 2 PROJECT MUNICIPALITY : Barnstable, Edgartown, Mashpee and Nantucket PROJECT WATERSHED : Cape and Islands EEA NUMBER : 16231 PROJECT PROPONENT : Vineyard Wind LLC DATE NOTICED IN MONITOR : June 24, 2020
Pursuant to the Massachusetts Environmental Policy Act (M.G.L. c. 30, ss. 61-62I) and Section 11.03 of the MEPA Regulations (301 CMR 11.00), I hereby determine that this project requires the preparation of a mandatory Environmental Impact Report (EIR). This Certificate includes a Scope for the Draft EIR.
The project is a component of an 800-megawatt (MW) wind energy generating facility known as Park City Wind (PCW) to be constructed approximately 19 miles south of Martha’s Vineyard. The generating facility will occupy a section of the Proponent’s 261-square mile (166,866 acres) Lease Area designated as OCS-A 0501 that was awarded to the Proponent through a competitive lease sale conducted by the federal Bureau of Ocean Energy Management (BOEM). The Proponent plans to construct three wind generating facilities in the OCS-A 0501 lease area. The first, known as Vineyard Wind, is located in the northern part of the lease area; components of the transmission infrastructure associated with the Vineyard Wind project, known as the Vineyard Wind Connector 1 (VWC1) completed MEPA review in 2019 (EEA #15787). The PCW project and a third project will be located in the Southern Wind Development Area (SWDA) occupying the southern part of the OCS-A 0501 lease area. The PWC project is being developed in response to a solicitation for a commercial-scale wind project by the Connecticut Department of Energy and Environmental Protection (DEEP). According to the ENF, while the power from the project is being purchased by electric distribution companies in Connecticut, it will have a regional benefit by displacing fossil fuel-generated electricity in the electric grid operated by the Independent System Operator- New England (ISO-NE). On an annual basis, the EEA# 16231 ENF Certificate August 7, 2020
project will result in avoided emissions of 1.59 million tons per year (tpy) of carbon dioxide equivalent (CO2e), 850 tpy of oxides of nitrogen (NOx) and 450 tpy of sulfur dioxide (SO2).
Major elements of the PCW project include a wind turbine array with 50 to 81 wind turbine generators (WTG) that each will have a generating capacity of 10 to 16 MW; offshore electrical service platforms (ESPs); inter-array cable connections between WTGs and ESPs; offshore export cables; onshore export cables; and an onshore substation. The offshore export cables will follow an approximately 63-mile long route from the WTG array to the landfall site at Craigville Beach in Barnstable. The components of the project located within Massachusetts state waters are known as the Vineyard Wind Connector 2 (VWC2), which is the project name used for purposes of state permitting within the Commonwealth.
Project Description
Project components within the Commonwealth include two offshore export cables, each of which is a total of approximately 23 miles long, approximately 4.7 miles of onshore export cables in underground conduits and a new electrical substation. Each offshore export cable will include a three-core 220-kilovolt (kV) or 275-kV alternating current (AC) cable bundled with a fiber optic cable. The offshore export cables will be installed within an Offshore Export Cable Corridor (OECC) that was identified through the review and permitting of the VWC1 project. The OECC will be expanded by 985 feet (300 meters) to the west along its entire length and by 985 ft to the east through a section of Muskeget Channel. As expanded, the OECC will range in width from 3,100 ft to 5,100 ft, with a typical width of 3,800 ft. The cables will be buried approximately five to eight feet (1.5 to 2.5 meters) below the seafloor using a trenching tool or, if necessary, by dredging a deeper trench to ensure adequate burial depth. Where burial is not possible due to subsurface conditions, the cables will be laid on the ocean floor and covered with armoring.
The export cables will be transitioned from the offshore environment to landfall at Craigville Beach through 1,000- to 1,200-ft long underground conduits installed using Horizontal Directional Drilling (HDD). The landward end of the conduits will be located within an underground vault, where the three conductors in each cable (a total of six conductors) will be separated and installed in separate conduits within a buried concrete duct bank. The duct bank carrying the cables will follow an approximately 4.0 mile long route along roads and an electric transmission right-of-way (ROW) identified as ROW #343 to the site of a proposed substation on a 6.7-acre site on Shootflying Hill Road, where the voltage will be stepped up to 345 kV. Six 345-kV transmission cables will follow a 0.7-mile long route through three existing electric transmission ROWs (ROW #343, ROW #345 and ROW #381) from the proposed substation to the interconnection at the existing Eversource West Barnstable Substation off Oak Street and adjacent to Route 6.
Project Site
The OECC extends from the southern portion of Nantucket Sound between Martha’s Vineyard and Nantucket, enters an area in Nantucket Sound that is outside of state waters, then reenters state waters south of Barnstable. All sections of the cable route within state waters lie within the Cape and Islands Ocean Sanctuary (CIOS) and the Massachusetts Ocean Management Plan (OMP) planning area.
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The substation is proposed on a 6.7-acre site on Shootflying Hill Road. A motel is located on the northern portion of the site and the southern portion is wooded. The site is bordered to the north by Shootflying Hill Road and Route 6, to the west by a residential neighborhood, to the south by ROW #343 and to the east by land owned by the Massachusetts Department of Transportation (MassDOT) and the Cape Cod Chamber of Commerce. The site is located within the Zone II Wellhead Protection Area of a public drinking water supply well for the Town of Barnstable. The West Barnstable Substation is bordered to the south by Route 6, to the east by undeveloped land, to the north by the Oak Street Substation and to the west by undeveloped land and Oak Street.
According to the Natural Heritage and Endangered Species Program (NHESP), the project will be located within areas of Priority and Estimated Habitat for rare species. The offshore cable route passes through habitat of Roseate Tern (Sterna dougallii)1, Common Tern (Sterna hirundo), Least Tern (Sternula antillarum) and Piping Plover (Charadrius melodus).2 Northern Right Whale (Eubalaena glacialis), Humpback Whale (Megaptera novaeangliae), marine birds such as Long-tailed Duck , Northern Gannet, Razorbill, Wilson’s Storm Petrel, fulmars, loons, scoters, and shearwaters, and Loggerhead (Caretta caretta) and Leatherback (Dermochelys coriacea) sea turtles have been observed throughout Nantucket Sound.
The Massachusetts Division of Marine Fisheries (DMF) has indicated that the OECC includes areas of commercial and recreational fishing and habitat for a variety of invertebrate and finfish species, including channeled whelk (Busycotypus canaliculatus), knobbed whelk (Busycon carica), longfin squid (Doryteuthis pealeii), summer flounder (Paralichthys dentatus), windowpane flounder (Scophthalmus aquosus), scup (Stenotomus chrysops), surf clam (Spisula solidissima), sea scallop (Argopecten irradians), quahog (Mercenaria mercenaria), horseshoe crabs (Limulus polyphemus), and blue mussel (Mytilus edulis). Blue mussel and kelp (Saccharina latissima) aquaculture operations are also located within Horseshoe Shoals (a subtidal area of Nantucket Sound). Waters offshore of Craigville Beach contain mapped eelgrass (Zostera marina) habitat.
As shown on the Federal Emergency Management Agency’s (FEMA) National Flood Insurance Rate Map (FIRM) numbers 250010563J and 250010564J (effective July 16, 2014), Craigville Beach is located in a coastal flood zone with a velocity hazard (VE zone) with a base flood elevation (BFE) of 15 ft NAVD 88. The areas north of Craigville Beach and adjacent to the Centerville River are located within the 100-year floodplain (Zone AE) with BFEs of 13 ft and 13 ft NAVD 88, respectively.
The Massachusetts Board of Underwater Archaeological Resources (BUAR) has identified Nantucket Sound as an area of high sensitivity that is rich in submerged ancient Native American cultural resources and shipwrecks. A number of properties included in the Massachusetts Historical Commission (MHC) Inventory of Historic and Archaeological Assets of the Commonwealth (Inventory) and State and National Registers are located along the proposed onshore segment of the transmission route.
1 Species also federally protected pursuant to the U.S. Endangered Species Act (ESA, 50 CFR 17.11). 2 Ibid.
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Environmental Impacts and Mitigation
Potential environmental impacts of onshore components of the project include alteration of 7.0 acres of land, creation of 0.2 acres of impervious area, 0.4 miles (2,000 linear feet (lf)) of Land Subject to Coastal Storm Flowage (LSCSF), 0.1 miles (730 lf) of Riverfront Area and 0.2 miles (1,100 lf) of Barrier Beach in connection with installation of the duct bank and construction of the substation, and 10,400 sf of Barrier Beach and 10,400 sf of Riverfront Area associated with the use of the microtunnel method to install the duct bank under the Centerville River. Potential environmental impacts of offshore components include alteration of 112 acres of Land Under the Ocean (LUO) and dredging of up to 106,000 cubic yards (cy) of sediment in connection with installation of the offshore export cables. Both onshore and offshore components of the project will be located in rare species habitat and in areas with cultural, historic and archaeological resources.
The ENF briefly reviewed potential measures that may be implemented to minimize environmental impacts. The Scope below includes additional analyses and information that must be provided in the DEIR to assess the project’s environmental impacts and identify measures to avoid, minimize and mitigate impacts.
Permitting and Jurisdiction
The project is undergoing MEPA review and is subject to preparation of a mandatory EIR pursuant to 301 CMR 11.03(3)(a)(1)(b) and 301 CMR 11.03(7)(a)(4) because it requires State Agency Actions and will result in the alteration of ten or more acres of any other wetlands (LUO) and involves construction of electric transmission lines with a capacity of 230 or more kV, provided the transmission lines are five or more miles in length along new, unused or abandoned ROW. It also exceeds ENF thresholds at 301 CMR 11.03(3)(b)(1)(a) (alteration of coastal dune), 301 CMR 11.03(3)(b)(3) (dredging of 10,000 or more cy of material) and 301 CMR 11.03(7)(b)(4) (construction of electric transmission lines with a capacity of 69 or more kV that are over one mile in length). The project may meet or exceed ENF review thresholds at 301 CMR 11.03(1)(b)(3) (conversion of land held for natural resources purposes in accordance with Article 97 of the Amendments to the Constitution of the Commonwealth to any purpose not in accordance with Article 97) and 301 CMR 11.03(2)(b)(2) (disturbance of greater than two acres of designated priority habitat that results in a take of a state-listed rare species).
The Project will require a Section 401 Water Quality Certification (WQC) and a Chapter 91 (c. 91) License from the Massachusetts Department of Environmental Protection (MassDEP); Approval under MGL Chapter 164 Sections 69J and 72, and Chapter 40A Section 3 Zoning Exemption from the Energy Facility Siting Board (EFSB) and the Department of Public Utilities (DPU); a Road Crossing Permit from the Massachusetts Department of Transportation (MassDOT); Field investigation permits from MHC and BUAR; and Federal Consistency review by the Massachusetts Office of Coastal Zone Management (CZM). It may require a Conservation and Management Permit (CMP) from NHESP. The Project is subject to reviews under the OMP, Ocean Sanctuaries Act and the MEPA Greenhouse Gas (GHG) Emissions Policy (the Policy), and it may require Article 97 legislation.
The project requires Orders of Conditions from conservation commissions in Barnstable, Edgartown, Yarmouth, Nantucket and, potentially, Mashpee (or in the case of an appeal,
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Superseding Orders of Conditions from the Massachusetts Department of Environmental Protection (MassDEP)). It requires Development of Regional Impact (DRI) review from the Cape Cod Commission (CCC) and Martha’s Vineyard Commission (MVC).
The PWC project and the VWC2 require approvals from BOEM3; an Individual Permit from the Army Corps of Engineers (ACOE) under Section 404 of the Clean Water Act (CWA) and Section 10 of the Rivers and Harbors Act (Section 10); a Letter of Authorization or Incidental Harassment Authorization from the National Marine Fisheries Service (NMFS); Private Aids to Navigation authorization from the U.S. Coast Guard (USCG); and a No Hazard Determination from the Federal Aviation Administration (FAA); consultation with MHC in accordance with Section 106 of the National Historic Preservation Act (NHPA) of 1966 and M.G.L. Chapter 9, Sections 26-27C; and a National Pollutant Discharge Elimination System (NPDES) Construction General Permit and Outer Continental Shelf Air Permit from the Environmental Protection Agency (EPA).
Because the Proponent is not seeking State Financial Assistance, MEPA jurisdiction extends to those aspects of the project that are within the subject matter of required or potentially required Permits or within the area subject to a Land Transfer that are likely, directly or indirectly, to cause Damage to the Environment. The subject matter of the EFSB/DPU approvals, OMP review and the c. 91 License are sufficiently broad such that jurisdiction is functionally equivalent to full scope jurisdiction and extends to all aspects of the project that are likely, directly or indirectly, to cause Damage to the Environment.
SCOPE
The ENF provided a basic project description and conceptual plans. It identified the project’s potential impacts on land, wetland resources, benthic conditions in Nantucket Sound and temporary impacts associated with the construction period. The ENF identified potential measures to avoid, minimize and mitigate impacts. The DEIR should provide detailed plans, descriptions and data that sufficiently describe the proposed project, its impacts, and baseline environmental conditions for the purpose of State Agency and public review. It should follow Section 11.07 of the MEPA regulations for outline and content and provide the information and analyses required in this Scope. The DEIR should clearly demonstrate that the Proponent will take all feasible means to avoid, minimize and mitigate Damage to the Environment to the maximum extent feasible.
While the project referenced as VWC2 consists of activities in state waters, it is integrally related to the larger off shore wind development occurring beyond state waters that may have significant impacts on important resources and activities in the Commonwealth, such
3 During its review, BOEM must comply with its obligations under the National Environmental Policy Act (NEPA), the NHPA, the Magnuson-Stevens Fishery Conservation and Management Act (MSFCMA), the Migratory Bird Treaty Act (MBTA), the Clean Air Act (CAA), and the Endangered Species Act (ESA). BOEM will coordinate/consult with other Federal agencies including NMFS, United States Fish and Wildlife Service (USFW), EPA, and USGC). BOEM will also coordinate with the State pursuant to the Coastal Zone Management Act (CZMA).
5 EEA# 16231 ENF Certificate August 7, 2020 as commercial fisheries, navigation and rare species. To support meaningful agency and public review of the project and assessment of alternatives to avoid, minimize and mitigate impacts in state waters, the DEIR should include contextual and background information related to project elements in both federal and state waters, including efforts made to avoid, minimize and mitigate impacts both for the project as a whole and cumulatively across all related projects being undertaken by the Proponent and by other proponents in a similar time frame and geographical area within the Commonwealth. The ENF indicated that the Proponent has voluntarily agreed, at the request of CZM, to provide information for the entire project through the federal consistency review process. I expect that information that is or will become available through federal processes will be disclosed through the MEPA review process as it becomes available, both as directly relevant to areas of MEPA jurisdiction and as background and context to inform the state MEPA review. Specific topics and information from federal reviews that are required to inform this review are itemized in greater detail below.
Project Description and Permitting
The ENF described the offshore route and construction process at a conceptual level and provided maps based on data collected by CZM and by the Proponent for the VWC1 project. It identified locations of the proposed substation and interconnection and provided conceptual plans of these facilities. The ENF included a detailed alternatives analysis of potential routes and construction methods for the onshore cable.
The DEIR should include plans and a detailed description of existing conditions, including site topography, soil conditions, and infrastructure. It should describe the project and identify any changes to the project since the filing of the ENF. It should include updated site plans for existing and post-development conditions at a legible scale. The plans should depict existing and proposed conditions for all project elements, including the export cable, HDD, and land-based facilities. Plans should be provided at a legible scale and clearly identify buildings, impervious areas, and boundaries of tidelands, wetland resource areas, drinking water supply protection zones, rare species habitat, and information required in the OMP and the Scope below. The DEIR should provide plans detailing conditions within the OECC and expanded OECC; offshore and onshore cable routes; detailed description of offshore and onshore cable installation methods and associated impacts and proposed mitigation measures; design of the substation and interconnection to the transmission system; and stormwater management measures. The DEIR should identify and describe measures to avoid, minimize and mitigate the project’s impacts.
The DEIR should identify and describe State, federal and local permitting and review requirements associated with the project and provide an update on the status of each of these pending actions. It should include a description and analysis of applicable statutory and regulatory standards and requirements, and a discussion of the project’s consistency with those standards. Pursuant to the Coastal Zone Management Act (CZMA), CZM’s federal consistency authority extends to activities that have reasonably foreseeable effects on any coastal use or resources resulting from a federal agency activity or federal license or permit activity. Renewable energy leases and related authorizations by BOEM are listed federal actions of the state’s approved Coastal Management Program. CZM’s federal consistency review will be completed through the federal BOEM renewable energy program and National Environmental Policy Act (NEPA) filings; however, as requested by CZM, the DEIR should describe activities in adjacent federal waters to the extent practicable as well as potential effects on state resources
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and uses to allow for a more complete assessment of the entire project through this MEPA process. It should include a description of existing conditions and plans for existing and post- development conditions for all project elements, including the WTGs, ESPs, submarine cable, onshore cable, HDD, and land-based facilities. It should clearly describe selected methods of cable installation and the route segments where each method will be used. The DEIR should include a project schedule, describe construction sequencing and describe project phasing.
The ENF made reference to more detailed information about the project included in the Proponent’s EFSB filing. The EFSB filing included information not provided in the ENF that was prepared for the VWC 1 project and remains applicable to the VWC 2 project, including characterization of conditions in the existing OECC and an analysis of offshore export cable route alternatives. It also included additional information about the VWC 2 project that was not provided in the ENF, including details on alternative export cable landing sites, onshore export cable route alternatives and impacts, an Electromagnetic Field (EMF) analysis and a Fisheries Communications Plan. The information provided solely to EFSB was not acknowledged in comments received from State Agencies and is not reviewed herein. In order to provide a comprehensive description and analysis of the project for MEPA review, the DEIR should include all of the information identified in the Scope, whether or not it was included in the EFSB filing.
Alternatives Analysis
The ENF included an analysis of alternative onshore export cable routes and construction methods. It identified an alternate landfall location but did not compare the alternate location to the preferred landfall site and did not provide an analysis of alternatives to the proposed route of the offshore export cable route.
Onshore Cable Route
The DEIR provided a detailed analysis of two onshore export cable routes between the landfall site and the location of the proposed substation, including variants of each route, and two routes between the proposed substation and the West Barnstable Substation, including three variants of the preferred route. It reviewed alternative construction methods for crossing the Centerville River and Route 6.
Both of the routes from the landfall site to the proposed substation follow existing roads and ROWs. The Preferred Alternative is 4.0 miles long and follows a generally direct route north to the proposed substation site using Craigville Beach Road, Main Street, Old Stage Road, Shootflying Hill Road and ROW #343. As described below, this alternative would have temporary impacts on wetlands resource areas associated with Craigville Beach and the Centerville River. The ENF identified three variants of this route, including one that starts at the Covell’s Beach landfall site and includes a 0.4-mile long section to the beginning of the preferred route; a variant that diverges from the preferred route and follows a 1.2-mile longer route to avoid the Centerville Historic; and a variant that is 0.1 miles longer than the preferred route and enters the proposed substation road from the north on Shootflying Hill Road.
The second alternative, identified as the Noticed Alternative, is a 6.1-mile long route that follows many of the same roads as the Preferred Route and its variants, but avoids the use of any
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electric transmission ROWs. One variant adds a 0.4-mile long segment from Covell’s Beach to the start of the route, and another variant is a 5.4-mile long route that would diverge from the Noticed Alternative route and follow ROWs #345 and # 343 for a distance of 1.6 miles to the proposed substation site.
The DEIR reviewed three potential routes between the proposed substation and the West Barnstable Substation. The three routes avoid impacts to wetlands and follow existing roads and ROWs. The Preferred Route is 0.7 miles long. It would exit the south side of the substation, follow ROW #345 to ROW #381 and cross under Route 6 to a 2.8-acre parcel to be acquired by the Proponent that is adjacent to the West Barnstable Substation (“the 2.8-acre parcel”). A variant of similar length would exit the north side of the proposed substation, follow Service Road, then join ROW #381 and cross under Route 6. A third variant is 0.1 miles shorter than the Preferred Alternative. It exits the south side of the proposed substation site, follows ROW #343 to ROW #342, crosses Route 6 and enters the northeast portion of the West Barnstable Substation. All of the alternatives would use a trenchless method to cross under Route 6 to avoid impacts to traffic.
The ENF reviewed five construction methods for crossing the Centerville River, including Bridge Structure Replacement, Microtunnel, HDD, Direct Pipe and Adjacent Utility Bridge alternatives. The Microtunnel, HDD and Direct Pipe methods are similar to one another in that they involve installing a conduit or casing under the river using boring or drilling machines. The onshore export cables would then be placed in the conduit or casing to cross the river. The Direct Pipe alternative would require a large staging area occupying the parking lot at Craigville Beach and possibly part of the beach. Microtunnelling and HDD require that pits be excavated in the Riverfront Area on either side of the river but avoid direct impacts to other wetland resource areas. The Bridge Superstructure Replacement Alternative would involve replacing the deck of the existing bridge with a new deck that includes conduits for the onshore export cables. This alternative would impact wetland resource areas and require closure of the bridge during the construction period. The Adjacent Utility Bridge Alternative would involve the construction of an independent utility bridge north of the existing bridge. The utility bridge would include conduits for the export cables. Construction of the utility bridge would require lane closure and would impact riprap on the banks of the river for installation of pilings. According to the ENF, the Microtunnelling Alternative minimizes impacts to wetland resource areas and is the Preferred Alternative for crossing the Centerville River.
The DEIR should review any additional analyses or refinements of the alternative onshore routes, including the Preferred Alternative. According to the ENF, the Proponent may coordinate construction of the onshore export cables with a sewer project that will be undertaken by the Town of Barnstable. I encourage the Proponent and the Town to coordinate their projects as a means of minimizing their cumulative impacts. The DEIR should describe how the proposed routes, staging areas and/or construction methods of the onshore cable route alternatives would be affected by the needs of the Town’s sewer project. It should identify any additional impacts and mitigation measures as well as the impacts avoided by coordinating the projects. The DEIR should include an analysis of alternatives that minimize cumulative impacts of the onshore export cable routes for the VWC1, VWC2 and the Proponent’s planned second project in the SWDA by collocating conduits, duct banks, and substations or coordinating construction timing.
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The ENF identified Craigville Beach as the preferred landfall site and Covell’s Beach as an alternative location that is the Noticed Alternative for the EFSB proceedings. The DEIR should compare the environmental impacts associated with each landfall site and discuss the reasons for selecting Craigville Beach. I note that the Covell’s Beach was selected as the landfall site for VWC 1. The DEIR should evaluate the feasibility of installing conduits of sufficient size at either location to accommodate landfall of the offshore export cables for VWC1, VWC 2 and/or the Proponent’s second project in the SWDA.
Offshore Cable Route
The OECC was established as the Preferred Alternative for the VWC1 cable route during MEPA review of that project. The proposed expansion of the OECC is intended to accommodate the VWC2 project and the Proponent’s anticipated second project SWDA. Comments from State Agencies concur with the routing of the VWC2 cables through the OECC and did not recommend that alternate offshore routes be evaluated in the DEIR. The DEIR should include a summary of the alternatives analysis provided during MEPA review of the VWC1 project and document the rationale for the selection of the OECC as the Preferred Alternative.
According to the ENF, the offshore export cables will be separated from each other by a “typical” distance of 165 ft (50 meters) and the cable pair will be at least 330 ft (100 meters) from the nearest VWC1 offshore export cable. I note that the proposed separation of the VWC2 cables (by 50 meters) is approximately one-half of the proposed typical 330-ft (100-meter) distance between the VWC1 offshore export cables as disclosed in federal BOEM filings.4 The ENF filed for VWC1 also indicated that a minimum cable spacing of 50-100 feet would be needed and that at least 500 feet would be needed from the VWC1 cable pair to any other cable. These estimates appear to have been revised for the VWC2 filing.
The DEIR should clearly indicate whether the expanded corridor will be utilized for VWC2 or reserved for transmission cables from future buildout of the SWDA. To the extent the expansion is deemed necessary for VWC2, the DEIR should describe the scientific basis for this assessment, including the results of benthic survey data and engineering analyses demonstrating the need for sufficient cable spacing such that an expansion of the corridor may be warranted.. The DEIR should explain how these ranges were derived, whether the typical width corresponds to one cable pairing of the type contemplated for this project or can accommodate additional pairings, and whether these ranges correspond to any scientific or engineering standards for underwater cable design. It should evaluate the environmental impacts or benefits of different spacing and the effect on routing of potential future offshore export cables and demonstrate that alternatives have been chosen to minimize environmental impacts, including impacts associated with cable crossings. An alternative that establishes a cable corridor with the minimum width needed for cable installation would appear to be the least impactful alternative. The DEIR should fully explain any trade-offs inherent in the corridor width and cable separation such as increased impacts on some resources to avoid impacts to other resources. The DEIR should include an evaluation of potential construction methods that could minimize cumulative impacts from
4 See Volume I, page 3-25 of the Vineyard Wind Draft Construction and Operations Plan, dated June 3, 2020. Available on BOEM’s website at https://www.boem.gov/sites/default/files/documents/renewable- energy/Vineyard-Wind-COP-Volume-I-Section-3_0.pdf
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VWC1, VWC2 and the future buildout of the SWDA by coordinating cable siting and laying, both by the Proponent independently and by the Proponent and other off shore wind development anticipated to occur in a similar geographical area as the Vineyard Wind projects. The DEIR should document efforts made to coordinate construction timing and methods with other developers and related work activities and anticipated timetables of all relevant projects. The DEIR should include a cumulative impact assessment of VWC1, VWC2, and future buildout with respect to the expected total temporary (e.g., dredged areas) and permanent (e.g., cable protection) impacts to the underwater environment across the three construction windows.
According to the ENF, the Proponent determined that a shared transmission option is not feasible for the VWC2 project because it could not be implemented within the timeframe of the project and the OECC provides a more direct route between the OCS-A 0501 lease area and interconnection points on Cape Cod. The shared transmission option considered by the Proponent appears to be one in which transmission infrastructure would be shared with other unrelated projects and proponents. The DEIR should provide a thorough analysis of the use of shared transmission infrastructure that could be utilized for the Proponent’s projects, including VWC1, VWC2 and future buildout in the SWDA. The analysis should compare environmental impacts of a shared option to those of three individual export cables and review the logistical, operational, financial and engineering feasibility of shared transmission for the Proponent’s projects.
Ocean Management Plan
The project is subject to review under the OMP. The first OMP was developed in 2009 pursuant to the Oceans Act (Chapter 114 of the Acts of 2008), and subsequently updated in 2015. The OMP identifies and maps important ecological resources that are key components of the state’s estuarine and marine ecosystems— defined as “special, sensitive or unique resources” (SSU)—and identifies key areas of water-dependent uses including commercial and recreational fishing and navigation. The OMP contains siting and management standards applicable to specific ocean-based activities to protect SSU resources and water-dependent uses. For cable projects, the OMP identifies the applicable SSUs as core habitat areas for the North Atlantic Right Whale, Fin Whale and Humpback Whale and areas of hard/complex seafloor. Hard/complex benthic conditions include: exposed bedrock or concentrations of boulder, cobble or similar hard bottom; morphologically rugged seafloor conditions characterized by high variability in bathymetric aspect and gradient, such as sand waves; or artificial reefs, wrecks or functionally equivalent structures that provide a substrate for hard bottom biological communities.
The siting standards of the OMP and its implementing regulations (301 CMR 28.00) presume that a project alternative located outside mapped SSU resources is a less environmentally damaging practicable alternative than a project located within a mapped SSU resource. The OMP management standards require a demonstration that the project has undertaken all practicable measures to avoid damage to SSUs; and a demonstration that the public benefits of the project outweigh the public detriments to the SSU resource. The DEIR should demonstrate that the project will comply with the management standards by identifying the project purpose and constraints, reviewing alternatives that would avoid SSUs, providing sufficient details of existing and proposed conditions along the proposed cable route,
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documenting the impacts of the project and mitigation measures to minimize impacts, and addressing its public benefits.
The DEIR should document benthic conditions along the cable route by providing the results of surveys conducted in accordance with the recommendations provided by CZM, DMF and MassDEP. For most of the OECC, this information should be based on the same surveys and data used for the VWC1 project; State agencies did not identify any new surveys necessary for the OECC as established for the VWC1 project. The DEIR should provide the same data for the expanded areas of the OECC, including video, multi-beam and side-scan sonar, bathymetry and sediment grabs. The survey data should be used to establish precise boundaries of hard/complex bottom habitat and eelgrass to determine the project’s impacts to SSUs and to provide a comparison to post-construction conditions. The Proponent should consult with CZM, DMF and MassDEP regarding the survey methodology and form and presentation of the data. State agencies have requested that seafloor features for both the existing and proposed OECC be described using the Coastal and Marine Ecological Classification Standard (CMECS) used by federal agencies. The use of CMECS will ensure consistency between state and federal reviews of this and other projects, and should be used as the preferred format for presenting the benthic survey data in the DEIR to the extent feasible at the time of the DEIR filing. As recommended by CZM, the Proponent should make its collection of the seafloor images available through an interactive viewer, such as the one developed by the United States Geological Survey (USGS) at https://video.ioos.us/. Survey data should be compatible with the substrate map prepared for the OMP and made available in a Geographic Information System (GIS)-compatible format. The comment letters from CZM, DMF and MassDEP, which are incorporated herein, include detailed guidance on the information and analyses that should be provided in the DEIR.
The OMP includes mapped areas of commercial and recreational fishing and navigation in Nantucket Sound that could be affected by the project. The DEIR should describe activities that could be affected by the installation of the cable and survey activities, including restrictions on navigation, fishing and the placement of fixed or mobile fishing gear. According to the ENF, the Proponent will continue to coordinate with stakeholder groups representing commercial and recreational fishing to identify measures to minimize interference with fishing activity and impacts to habitat in fishing areas. The Proponent should also coordinate with municipal shellfish constables and aquaculture grant owners to ensure the Project avoids interference with shellfish relay or aquaculture operations. The DEIR should include a Fisheries Communications Pan for alerting mariners of the location and timing of project activities in Nantucket Sound.
The Oceans Act established an Ocean Development Mitigation Fee to be assessed for offshore development projects. The purpose of the fee is to compensate the Commonwealth for impacts to ocean resources and the broad public interests and rights in the lands, waters and resources of the OMP areas. The fee will be established through the MEPA review of the project’s impacts with input from State Agencies and the public. The OMP contains language and guidance as to the process and framework for determining the fee. The information and analysis contained in the DEIR, as well as consultation with agencies and input from public comment, will help to inform the Secretary’s determination of the mitigation. If the project is permitted, the fee must be deposited in the Oceans and Waterways Trust. The DEIR should demonstrate that the public benefits of the proposed total project outweigh the public detriments to OMP resources as required by 301 CMR 28.00.
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Wetlands and Water Quality
As noted, it is not entirely clear from the ENF whether the offshore export cables for VWC2 will be located within the currently defined OECC or the expanded OECC proposed in the ENF, or if the additional surveys proposed for the expanded area are intended for future permitting of the Proponent’s additional project in the SWDA; this should be clarified in the DEIR. I expect, and the ENF indicated, that the complete results of benthic surveys for the expanded areas will be provided in the DEIR. As noted, these surveys should be presented in the CMECS format, to the extent feasible by the time of the DEIR filing. If it is definitively determined that the VWC2 offshore export cables will be located entirely within the existing OECC, survey data for the expanded OECC should be included to provide documentation of potential cumulative impacts that would result from full buildout of the OCS-A 0501 lease area. In general, comments from State Agencies indicate that the OECC has been adequately characterized by the Proponent as part of the environmental review documentation prepared for the VWC1 project and that the same information should be provided for the expanded area, with the proviso that all data should be presented in the CMECS format.
Project activities that may impact wetlands include the installation of the offshore export cables, landfall transition and crossing of the Centerville River. The DEIR should provide revised estimates of impacts to wetland resource areas based on additional surveys of the expanded OECC, if applicable, and design refinements since the filing of the ENF. It should provide the data and analysis identified below and review how the project will satisfy the requirements of the Wetlands Regulations (310 CMR 10.00), WQC Regulations (314 CMR 9.00) and the Waterways Regulations (310 CMR 9.00).
Offshore Export Cable Installation
According to the ENF, the installation of the offshore export cables will impact 112 acres (approximately 4.9 million sf). This estimate includes 18.4 acres (802,000 sf) of impact due to installation the two cables in a 3.3-ft (1.0 m) wide trench for a distance of 23 miles; 56 acres (2.4 million sf) resulting from two 5.5-ft (1.5 m) wide installation plow skids in contact with the ocean floor during cable installation; 25 acres (1.1 million sf) associated with dredging sand waves at a 3:1 slope to bury cables to an adequate depth; and 12.7 acres (536,000 sf) caused by anchoring. The estimated impacts to LUO do not include any areas where cable armoring may need to be placed over the cable for protection. The DEIR should include updated estimates of impacts to LUO, including potential impacts due to cable armoring. It should describe the benthic conditions of areas to be impacted. According to the ENF, the detailed survey data for the expanded OECC will be used to finalize the project design and cable route selection and will enhance the potential for micro-siting during cable installation to avoid and minimize impacts to benthic habitat. The DEIR should provide a detailed description of the cable laying process, including procedures that could allow for micro-siting of the cable to avoid impacts to SSUs.
Each offshore export cable will be installed primarily in soft sediments using a trenching tool. This installation technique will create a 3.3-ft wide trench in which the cable will be buried to a depth of five to eight feet and covered with sediment. In areas where mobile sand waves are present on the ocean floor, either a trailing suction hopper dredge (TSHD) or jetting by controlled flow excavation will be used to dredge a trench with 3:1 slopes and a bottom width of 50 ft to adequately bury the cables. Where subsurface conditions prevent burial of the cable it
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will be placed on the seafloor and covered with protective armoring, which may include covered by rock, gabion rock bags, concrete mattresses or half-shell pipes. According to the ENF, no cable crossings are anticipated; however, cable protection would also be required if a crossing is necessary.
The DEIR should describe each of the cable installation methods that may be used, identify the conditions along the cable routes under which it may be used, its direct impacts on the seafloor and indirect impacts such as turbidity and sediment dispersion. As noted by CZM and MassDEP, disposal of dredged sediment within the OECC may cause a sediment plume that extends beyond the immediate work area. I recommend that the Proponent consult with MassDEP to ensure that its sediment sampling will be consistent with sampling and analysis requirements for the WQC permitting process. The DEIR should include a sediment dispersion model and identify measures to mitigate water quality and habitat impacts associated with dredge material disposal. It should explain how the burial depth and sediment cover of the cables will be verified and describe any additional burial or cable protection measures that may be necessary if the cable has not been adequately buried. The DEIR should detail procedures that will be used to achieve adequate burial depth and avoid armoring. It should describe the dimensions and physical characteristics, including habitat value, and installation methods of any armoring that may be required as a last resort; according to DMF, rock may have greater habitat value than concrete mattresses, which typically occupy a smaller area. The DEIR should identify any cable crossings that may be necessary and the proposed method of cable protection. It should describe any unique impacts that may result from cable crossings, including any increased potential for cables to become unearthed and potential increased impacts from electromagnetic fields and heat. The DEIR should describe expected transit and work speed of the cable lay vessels, the number and type of support vessels and whether the cable laying vessel will use dynamic positioning or kedging during the cable installation process; the use of dynamically positioned vessels is encouraged as a means of minimizing benthic impacts associated with anchors and anchor lines The DEIR should identify potential mitigation measures appropriate for each construction method and for any permanent impacts, such as habitat conversion from armoring.
The DEIR should describe a comprehensive post-construction monitoring plan developed in consultation with State Agencies. The monitoring plan should establish a robust pre- construction baseline for potentially impacted biota and habitat; evaluate Total Suspended Solids (TSS) dispersion during construction; measure changes in seafloor topography and disturbance of seafloor habitats, including eelgrass; evaluate the adequate burial of the cables in the near and long term; estimate recovery times of resources; colonization of invasive species in disturbed areas; and outline adequate methods and metrics to detect differences in biological or geological parameters within the construction corridor. The DEIR should describe how the post- construction monitoring plan will address these and other relevant factors to protect water resources and species habitat. To the extent the monitoring plan will be modeled on the plan completed for VWC1, a copy of the VWC1 post-construction monitoring plan should be submitted with the DEIR along with a description of how the components of the plan will be adapted for the VWC2 project.
Landfall
Installation of the offshore export cables by trenching will cease in waters approximately 1,000 ft from the landfall site at Craigville Beach. At this location, a conduit will be installed
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between the end of the offshore trench and the landfall site in the beach parking lot using HDD to avoid direct impacts from trenching to rare species habitat and wetland resource areas, including Coastal Beach, Coastal Dune and LSCSF. The cables will be pulled through the conduit to an underground transition vault, where and the six individual single-core onshore cables (three from each offshore export cable) will be placed within its own conduit in a duct bank and routed to the proposed substation.
The DEIR should detail HDD operations and describe impacts associated with the transition between construction techniques, such as potential release of drilling fluid in wetland resource areas or rare species habitat. It should provide a contingency plan describing measures that will be undertaken to minimize and contain turbidity and sedimentation should HDD drilling slurry be released into the environment.
Onshore Export Cable Installation
The duct bank carrying the onshore export cables will follow a 4.0-mile long route north from Craigville Beach, following roads and an existing ROW to the site of the proposed substation. It will be pass through LSCSF, Riverfront Area and LUO associated with the Centerville River. The cables will be installed under the river using a microtunnel to avoid direct impacts to wetland resource areas associated with the river. Microtunnel construction will involve the use of a boring machine to excavate a 430-ft long tunnel from a jacking shaft on the south side of the river to a receiving shaft on the north side. A 48-inch diameter concrete pipe will be installed in the tunnel to carry the conduits under the river. Staging activities at the jacking shaft will temporarily impact an area of 10,400 sf consisting of Barrier Beach, Riverfront Area and LSCSF. The DEIR should include a map of wetland resource areas that will be impacted by staging and microtunnelling activities. It should and identify construction period mitigation measures and how affected areas will be restored upon completion of construction.
Chapter 91 / Waterways
Sections of the export cables in, under or over the flowed tidelands of Nantucket Sound and the Centerville River, as well as associated dredging for installation of the cables, will be subject to licensing under c. 91 and the Waterways Regulations. The DEIR should clearly delineate the landward extent of c. 91 jurisdiction, including any filled tidelands along the shoreline. It should include a draft Navigation Plan that will be implemented during construction, and subsequent maintenance, repair and decommissioning activities, to minimize conflicts with commercial and recreational vessels. The DEIR should discuss the Project’s consistency with the applicable c. 91 regulations.
According to MassDEP, a facility generating electricity from wind power which requires an EIR pursuant to 310 CMR 9.12(2)(e) may be determined to be water-dependent if a comprehensive alternatives analysis demonstrates that the facility requires direct access to or location in tidal waters and cannot reasonably be located or operated away from tidal waters. For projects subject to an EIR, the alternatives analysis must be provided during MEPA review so that I may make a finding regarding water-dependency. As noted above, the ENF did not include an analysis of offshore export cable route alternatives. The DEIR should review the alternatives analysis that was conducted to select the OECC for VWC1 (and now VWC2 and possible future buildout of the SWDA). I will determine whether this project requires direct access to or location
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in tidal waters, as I did for the VWC1 project, upon review of the alternatives analysis provided in the DEIR.
Rare Species and Marine Fisheries
The offshore export cable routes extend through diverse marine environments within the Outer Continental Shelf, Nantucket Sound, and the CIOS. As noted by the NHESP, CZM, and DMF, the area includes habitat and prey species relied upon by rare species, including the North American Right Whale, as well as shellfish and finfish species that are important to the commercial and recreational fishing industries. According to NHESP, Massachusetts is a globally significant nesting, feeding, staging and overwintering area for numerous migratory birds. The state’s natural resources support almost 40 percent of the Atlantic coast breeding population of Piping Plover and approximately 50 percent of the North American Roseate Tern population, as well as significant nesting colonies of Common and Least terns.
The DEIR should include sufficient information about existing conditions along and adjacent to the proposed cable route to determine potential impacts to rare species, marine species, and their habitat. It should assess the impacts of the cable on commercial and recreational fishing activities, including impacts that will accrue during the installation of the cable. As requested by DMF, the distribution of marine resources that are sessile or of limited mobility, such as shellfish, whelks, squid eggs, should be documented in the DEIR. The DEIR should also review impacts associated with the operation and maintenance of the cable, including cable repair or monitoring activities, placement or maintenance of protective covering, and decommissioning. It should include an analysis of potential impacts associated with electromagnetic fields and heat and identify mitigation measures and a monitoring procedure. It should address establishment of time of year (TOY) restrictions and other mitigation measures to minimize impacts to species and habitats and continue to work with DMF to develop cable installation methods that minimize impacts to the squid fishery in state waters.
As noted above, the DEIR should provide background and contextual information from federal review processes to inform this state review. In particular, the DEIR should provide information on efforts made to address and mitigate impacts to commercial and recreational fisheries through federal review processes, including a description of outreach conducted with Massachusetts fishermen and other Massachusetts stakeholders, mitigation approaches that have been adopted or are being considered, and a review of economic data and methodologies that have been considered to calculate impacts to Massachusetts fisheries industries. As requested by DMF, the DEIR should discuss whether these methodologies will take into account Massachusetts Clean Energy Center (MassCEC) pilot studies and/or analyses conducted by the National Oceanic and Atmospheric Administration (NOAA). The DEIR should discuss efforts being made to further regional mitigation agreements and impact monitoring. A description or documentation of the VWC1 methodology used to develop fisheries mitigation should be submitted with the DEIR; in addition, the DEIR should provide a description of how it may be adapted to VWC2 and/or future projects, to the extent this information becomes available.
The DEIR should assess the direct and indirect impacts of the project on state-listed and migratory birds in the project area and identify mitigation measures as described below. In the FEIR Certificate on the VWC1 project, I indicated that the Proponent should work with NHESP and other EEA agencies to develop mitigation plans for marine mammals and avian
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species, including a comprehensive post-construction monitoring and adaptive management plan for avian species. I understand that consultations regarding mitigation and monitoring have begun through the federal review process for VWC1. The DEIR should provide an update on the federal review process relative to the protection of marine mammals and avian species, and explain how such approaches may be adapted for this project. The DEIR should discuss whether conservation measures such as the ones identified in NHESP comments will be considered through the federal review process. Any migratory survey data should be provided in the DEIR if completed by the filing of the DEIR, and preliminary or completed surveys for VWC2 should be provided to the extent they are available. If it is anticipated that mitigation or monitoring approaches considered for VWC1 will not be used as a model for VWC2, the DEIR should discuss the reasons for distinguishing VWC2 from prior projects. I recommend that the Plover Protection Plan included in the ENF relating to the cable landing location in Barnstable be refined on the basis of documentation prepared for VWC1 in response to the FEIR Certificate and/or federal review process to provide a conceptual framework for a mitigation plan for VWC2.
Substation and Interconnection
A new substation is required to step up the 220-kV or 275-kV voltage of the onshore export cable to 345 kV so it can be interconnected to the electrical transmission system. The substation will be constructed on a 6.7-acre parcel located near the intersection of Route 6 and Route 132. The site is located within a Zone II Wellhead Protection Area for the Town of Barnstable’s water supply. A motel and parking lot occupy the northern half of the site and the remainder is covered by woods. Construction of the substation will alter approximately three acres of undeveloped land at the site and add 0.2 acres of impervious area. The substation will include two step-up transformers, switchgear and a control room inside two metal enclosures and associated equipment and wiring. It will be enclosed by a fence around the perimeter of the site with a vegetated screening on the western and northern boundaries. The substation will be designed as a gas-insulated substation (GIS), which uses sulfur hexafluoride (SF6) to provide insulation. According to the ENF, the GIS design was selected because less space is required between components and the design provides better noise attenuation than an air-insulated substation (AIS). An AIS relies on ambient air between components to provide insulation and requires more space between the equipment. According to the ENF, the site is not large enough to accommodate an AIS substation.
To minimize potential impacts to drinking water, the substation will have a containment system designed to contain 110 percent of the volume of dialectric fluid anticipated to be used within the transformers and other equipment. According to the ENF, the Proponent has agreed to increase the size of the containment system to accommodate additional flow from precipitation under an extreme rain event. The Proponent will develop and implement a construction-period Spill Prevention, Control and Countermeasures Plan (SPCC) to minimize the potential for a release of fuel or other contaminants that could impact water quality. The site will include a stormwater management system designed to meet the requirements of the Massachusetts Stormwater Management Standards (SMS), including Best Management Practices (BMP) and Low Impact Design (LID) measures such as deep sump catch basins, dry wells for infiltration of roof runoff, infiltration basins, sediment forebays and grass swales.
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Six 345-kV transmission cables will be installed along a 0.7-mile long route from the proposed substation to the interconnection point at the Eversource West Barnstable Substation adjacent to Route 6. As described earlier, the cables will run along existing ROWs and cross under Route 6 via a conduits installed using the trenchless pipe jacking method that require a jacking shaft on the south side of the highway and a receiving shaft on the north side. The receiving shaft will be located on the 2.8-acre parcel. According to the ENF, the Proponent may install some of the equipment from the proposed substation on this parcel to provide greater flexibility in the design of the proposed substation, including larger buffer areas to the minimize noise and visual impacts of the substation. Additional equipment will be installed at the West Barnstable Substation to accommodate the interconnection; the equipment will be located entirely on the site of the West Barnstable Substation.
The DEIR should provide additional details on the design of the proposed substation, include wider buffers, noise abatement features and the stormwater management system. It should identify any substation components to be located on the 2.8-acre parcel and describe proposed modifications to the West Barnstable Substation. The DEIR should include an evaluation of the trade-offs between using the 2.8-acre parcel to construct an AIS substation to avoid the use of SF6 gas for insulating the substation and constructing a GIS substation. It should discuss compliance with MassDEP’s regulations capping emissions from SF6 gas, 310 CMR 7.72. It should review the water supply resources in the vicinity of the proposed substation and describe how groundwater will be protected from potential contaminants, including provision of full containment of all fluids within substation equipment. The DEIR should describe the project’s compliance with the Massachusetts Drinking Water Regulations (310 CMR 22.00). It should demonstrate that the project will not have a significant adverse impact on water quality pursuant to 310 CMR 22.21(1)(b)(5). The DEIR should describe project activities within the Route 6 ROW, identify the need for road closures or other impacts to traffic on Route 6 and review any requirements that MassDOT may impose on construction of the project.
Cultural Resources
Both offshore and onshore components of the Project are located in areas with significant cultural resources associated with ancient and historic period Native American activities and colonial settlement. In addition to the high density of shipwrecks, coastal waters affected by the project may include submerged ancient Native American cultural resources. A marine archaeological reconnaissance survey of the state waters portion of the OECC for the VWC1 project in Barnstable, Martha’s, Vineyard, Nantucket, and Yarmouth, determined that the offshore component of the waters within and in the vicinity of the OECC possessed a high density of post-contact period shipwrecks and contained numerous areas of submerged paleolandscapes with archaeological sensitivity for potentially containing submerged Native American archaeological deposits. Therefore, the project area may be archaeologically sensitive for both pre- and post-contact period (principally shipwrecks) underwater archaeological resources.
The Proponent should coordinate with BUAR and MHC on the marine archaeological survey of the state waters portion of the project area and the submission of reports detailing potential marine archaeological impacts within the state waters portion of the project area. The Proponent should also develop a plan to address the possibility that heretofore-unknown submerged cultural resources may be encountered during the course of the project, which
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includes steps to limit adverse effects and notify BUAR and MHC. A plan consistent with the BUAR’s Policy Guidance for the Discovery of Unanticipated Archaeological Resources should be provided in the DEIR.
Article 97 and Conservation Land
Sections of the onshore export cables will be located on parcels of land protected by Article 97, including Craigville Beach and associated parking lot and potentially a parcel on ROW #345 along the route from the proposed substation to the interconnection. The area of the beach and parking lot protected by Article 97 is not identified on plans and the activities and structures proposed on protected land is not clearly identified. The proposed 345-kV cables will pass under the parcel located in ROW #345 and no structures will be constructed on the surface of this parcel. Several parcels along alternative routes described in the ENF may also be subject to protection Article 97. The DEIR should clearly identify all project activities and structures located on or under Article 97-protected land and provide plans of the affected parcels. It should identify whether any maintenance easements will be required on protected land.
A change in use of Article 97 land requires a 2/3 vote of the legislature and compliance with the Executive Office of Energy and Environmental Affairs (EEA) Article 97 Land Disposition Policy (Article 97 Policy). A primary goal of the Policy is to ensure no net loss of Article 97 lands under the ownership and control of the Commonwealth. Allowances are made within the Policy for exceptional dispositions. If the project requires conversion of Article 97 land, the DEIR should include an analysis of the six criteria identified in the Article 97 Policy for determining when “exceptional circumstances” exist such that a disposition of Article 97 land may be appropriate:
• The Proponent of the disposition must conduct an analysis of alternatives, commensurate with the type and size of the proposed disposition, that achieve the purpose of the disposition without the use of Article 97 land, such as the use of other land available within the appropriate market area; • The disposition of the subject parcel and its proposed use may not destroy or threaten a unique or significant resource (e.g., significant habitat, rare or unusual terrain, or areas of significant public recreation); • Real estate of equal or greater value, and of significantly greater resource value is granted to the disposing agency; • The minimum necessary area of Article 97 should be included in the disposition and the existing resources continue to be protected to the maximum extent possible; • The disposition serves an Article 97 purpose or another public purpose without detracting from the mission, plans, policies and mandates of EEA and its appropriate department or division; and, • The disposition is not contrary to the express wishes of the person(s) who donated or sold the parcel or interests to the Commonwealth.
To the extent Article 97 legislation becomes necessary, I encourage the Proponent to consult with the Division of Conservation Services to ensure due compliance with the Article 97 Policy and ensure appropriate mitigation.
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Port Facilities
According to the ENF, construction of the project may be supported by port facilities in Massachusetts, including the New Bedford Marine Commerce Terminal facility, Brayton Point Commerce Center, Vineyard Haven and Fall River. Port activities may include crew transfers, storage and shipment of components and/or fabrication and assembly of components. The DEIR should describe potential use of these port facilities, including but not limited to any construction or expansion of buildings, docks or infrastructure, or dredging.
Climate Change
Executive Order 569: Establishing an Integrated Climate Change Strategy for the Commonwealth (EO 569) was issued on September 16, 2016. EO 569 recognizes the serious threat presented by climate change and directs Executive Branch agencies to develop and implement an integrated strategy that leverages state resources to combat climate change and prepare for its impacts. The Order seeks to ensure that Massachusetts will meet GHG emissions reduction limits established under the GWSA of 2008.
MEPA review of projects subject to an EIR must consider the reasonably foreseeable climate change impacts and GHG emissions of projects (and effects such as predicted sea level rise); and (2) ensure that projects subject to MEPA take all feasible measures to avoid, minimize, and mitigate “Damage to the Environment” (as defined in the MEPA statute), including GHG emissions. The GHG Policy and requirements to analyze the effects of climate change through EIR review is an important part of this statewide strategy. These analyses advance proponents’ understanding of a project’s contribution and vulnerability to climate change.
Greenhouse Gas (GHG) Emissions
This Project is subject to review under the May 5, 2010 MEPA GHG Policy because it exceeds thresholds for a mandatory EIR. The DEIR should identify features of the transmission line and substation that will minimize line losses, such as the use of premium efficiency substation transformers and other components. The DEIR should identify mitigation commitments to reduce construction period carbon dioxide (CO2) emissions and identify construction practices and/or design features that will minimize the leakage of SF6 gas, a potent GHG. As noted, the DEIR should include a review of potential benefits associated with constructing an AIS substation using the additional land available to the proponent at the 2.8- acre parcel. The DEIR should discuss compliance with 310 CMR 7.72. The DEIR should discuss and quantify the GHG emissions benefits that will accrue to the regional grid from construction of the project (including the offshore wind generator) through the displacement of fossil fuel sources, including, to the extent feasible, a quantification of benefits accruing to the Commonwealth.
Climate Change Adaptation and Resiliency
The region’s climate is expected to experience higher temperatures and more frequent and intense storms. The Northeast Climate Science Center at the University of Massachusetts at Amherst has developed projections of changes in temperature, precipitation and sea level rise for Massachusetts. This data is available through the Climate Change Clearinghouse for the
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Commonwealth at www.resilientMA.org. By the end of the century, sea level on Nantucket is expected to rise by 4.0 to 10.3 ft. The average annual temperature is projected to rise by 3.1 to 9.5 degrees Fahrenheit (F), including an increase in the number of days with temperatures over 90 F from 3 to up to 34 days compared to the 1971-2000 baseline period. During the same time span, the average annual precipitation is projected to increase by up to 5.5 inches. These changes are likely to be accompanied by increased frequency and intensity of storm events.
The DEIR should discuss how the project will incorporate comprehensive resiliency planning, given the location of onshore infrastructure directly on the coastline and the potential effects of increased intensity storm and heat events in other areas. The DEIR should identify, in particular, the planning horizon and recurrence intervals (100-year, 500-year storm, etc.) used to design the project. The DEIR should describe how particular project components (e.g., stormwater management systems, conduit burial depths, elevation of above ground infrastructure) have taken into account climate change data and projections in their design.
As noted above, the Proponent will design the containment system at the proposed substation with sufficient capacity to contain dialectric fluid mixed with precipitation from an extreme storm event. The DEIR should review the climate change assumptions used to size the containment and stormwater management systems at the proposed substation and evaluate the need for upgrades to the West Barnstable Substation. It should clearly identify the recurrence interval and planning horizon used to inform design, and how climate change data and projections have been incorporated into these design parameters. The DEIR should discuss whether other onshore components away from the coast will be vulnerable to climate change and intense storm or heat events, and, if so, what efforts were made to design those components to maximize climate resiliency.
The landfall site at Craigville Beach is located in a VE zone, indicating that it is potentially subject to storm surges and high wave energy caused by hurricanes and other storm events. According to CZM, the shoreline is vulnerable to erosion from severe storms, even though the beach may be accreting over the long term. As critical energy infrastructure, the project should be designed to withstand major storms under future sea levels. The DEIR should include an analysis of the likely nearshore, beach, and dune erosion at the preferred landing site during a major storm and identify measures incorporated into its design to withstand storm events under existing and future climate conditions. As discussed, the DEIR should clearly identify the design parameters used to inform design, including the planning horizon and recurrence interval, and discuss how climate change projections were incorporated.
Construction Period Impacts
The project must comply with MassDEP’s Solid Waste and Air Pollution Control regulations. The DEIR should discuss the use of alternative types of equipment for the construction of all, or part, of the project that may serve to reduce land alteration and the clearing required to accommodate construction access. The DEIR should describe potential construction period impacts (including but not limited to traffic management, materials management, parking, air quality and noise impacts) and outline feasible measures that can be implemented to eliminate or minimize these impacts in a draft Construction Management Plan (CMP). The draft CMP should identify construction access and truck traffic routes, staging areas, and how passive
20 EEA# 16231 ENF Certificate August 7, 2020 recreation use located adjacent to or along portions of the corridor will be safely maintained or impacted throughout the construction period.
I encourage the Proponent to adopt measures to reduce air quality impacts from certain categories of construction vehicles. The DEIR should provide information on the emission controls that will be used for all on-site construction vehicles and should provide a discussion on using construction equipment with engines manufactured to Tier 4 federal emission standards or best available control technology (BACT). I remind the Proponent that EPA has mandated that Ultra Low Sulfur Diesel (ULSD) fuel be used in all off-road construction equipment. The DEIR should confirm that the project will require its construction contractors to use ULSD fuel in off- road equipment and indicate whether it will incorporate additional measures to minimize construction-period emissions. The DEIR should address how the project will support compliance with the Massachusetts Idling regulation at 310 CMR 7.11.
According to MassDEP, there is one site along the onshore export cable route with a release of oil and/or hazardous material to the environment that is regulated under M.G.L. c. 21E, and the Massachusetts Contingency Plan [MCP – 310 CMR 40.0000]. The release is designated as Release Tracking Number 4-20277 and is associated with a residential property release at 1071 Shootflying Hill Road. and additional response actions are necessary at the site for closure under the MCP. The Proponent is advised that excavating, removing, and/or disposing of contaminated soil, pumping of contaminated groundwater, or working in contaminated media must be done under the provisions of M.G.L. c. 21E and the Occupational Safety and Health Act (OSHA). If oil and/or hazardous material are identified during the implementation of the project, notification pursuant to the MCP must be made to MassDEP, if necessary. A Licensed Site Professional (LSP) should be retained for this project given the potential impact of MCP-regulated sites on the proposed construction activities. The LSP may evaluate whether risk reduction measures are necessary to mitigate the presence of contamination. The DEIR should include a Spills Contingency Plan that identifies procedures for the containment and cleanup of any releases of hazardous materials.
Mitigation and Draft Section 61 Findings
The DEIR should provide a separate chapter summarizing proposed mitigation measures including draft Section 61 Findings for each anticipated State Agency Action. It should contain clear commitments to implement these mitigation measures, estimate the individual costs of each proposed measure, identify the parties responsible for implementation, and include a schedule for implementation.
Response to Comments
The DEIR should contain a copy of this Certificate and a copy of each comment letter received. To ensure that the issues raised by commenters are addressed, the DEIR should include direct responses to comments to the extent that they are within MEPA jurisdiction. This directive is not intended to, and shall not be construed to enlarge the scope of the DEIR beyond what has been expressly identified in this Certificate. The Proponent may use either an indexed response to comments format, or a direct narrative response.
21 EEA# 16231 ENF Certificate August 7, 2020
Circulation
The Proponent should circulate the DEIR to those parties who commented on the ENF, to any State and municipal agencies from which the Proponent will seek permits or approvals, and to any parties specified in section 11.16 of the MEPA regulations. The Proponent may circulate copies of the DEIR to commenters in a digital format (e.g., CD-ROM, USB drive) or post to an online website. However, the Proponent should make available a reasonable number of hard copies to accommodate those without convenient access to a computer to be distributed upon request on a first-come, first-served basis. The Proponent should send correspondence accompanying the digital copy or identifying the web address of the online version of the DEIR indicating that hard copies are available upon request, noting relevant comment deadlines, and appropriate addresses for submission of comments. The DEIR submitted to the MEPA office should include a digital copy of the complete document. A copy of the DEIR should be made available for review in the Barnstable, Edgartown, Mashpee and Nantucket public libraries.5
____August 7, 2020 ______Date Kathleen A. Theoharides
Comments received:
06/24/2020 Cape Cod Chamber of Commerce 07/08/2020 Ron Dagostino 07/09/2020 Massachusetts Historical Commission (MHC) 07/10/2020 William Lake 07/13/2020 Ann G. Berwick 07/14/2020 Michael Duclos 07/14/2020 Tom Soldini 07/20/2020 Barnstable Clean Water Coalition 07/22/2020 Cape Cod Commission 07/27/2020 Senator Julian Cyr, Cape and Islands District Representative Dylan A. Fernandes, Barnstable, Dukes and Nantucket District 07/27/2020 Natural Heritage and Endangered Species Program (NHESP) 07/27/2020 Board of Underwater Archaeological Resources (BUAR) 07/28/2020 Massachusetts Department of Environmental Protection (MassDEP)/Southeast Regional Office (SERO) 07/28/2020 Division of Marine Fisheries (DMF) 07/28/2020 Massachusetts Office of Coastal Zone Management (CZM)
KAT/AJS/ajs
5 Requirements for hard copy distribution or mailings will be suspended during the Commonwealth’s COVID-19 response. Please consult the MEPA website for further details on interim procedures during this emergency period: https://www.mass.gov/orgs/massachusetts-environmental- policy-act-office.
22
Ann G. Berwick 131 Lake Avenue Newton, MA 02459
July 13, 2020
Alex Strysky Environment Analyst MEPA Office Executive Office of Energy and Environmental Affairs [email protected]
Dear Mr. Strysky :
I am writing in support of Vineyard Wind Connector 2 and Park City Wind (the “project”). I was Undersecretary for Energy in Massachusetts from 2006 to 2010 and chair of the Massachusetts Department of Public Utilities from 2010 to 2015. From 2006 to 2015 I was also a member of the MA Energy Facilities Siting Board. I am a member of the board of Vineyard Power and am on the Mothers Out Front legislative team and chair of its legislative Rapid Response Team.
You have no doubt heard a great deal about the economic and environmental benefits of the project: an increase in the diversity and reliability of New England’s energy supply, especially critical during the winter and in light of nuclear plant closings; large financial savings for the New England grid; increases in tax revenues to local governments; and thousands of local jobs.
It’s easy to get mired in these details, but the bigger picture is simple: we need more renewable electricity, and then, counterintuitively, we need to use more electricity, for things like heating and cooling buildings and for transportation.
There is no serious dispute about where that electricity must come from. Here in New England there’s no resource that can compete with offshore wind. After a decade and a half of vigorous development of solar power in Massachusetts, which is an important resource even in our climate, we have 2,500 MW of solar nameplate capacity. At a 14% capacity factor, that means 350 MW of solar power.
Compare the capacity of offshore wind: at 800 MW nameplate capacity and a capacity factor of 45%, the project alone will contribute 360 MW of power to the NE grid. In other words, more energy from a single offshore wind project than from a decade and a half of solar development. The offshore wind projects under development in the U.S. add up to well more than 20,000 MW, with almost limitless technical potential.
Does the project have any negative impacts? Yes. There is no free lunch. However, any minimal impacts from this and other offshore wind projects in the queue are small compared to the massive impacts of climate change: on birds, on fisheries, on humans, and especially on the most disadvantaged communities.
Thank you for considering my comments.
Sincerely,
/s/
Ann G. Berwick
The COMMONWEALTH OF MASSACHUSETTS BOARD OF UNDERWATER ARCHAEOLOGICAL RESOURCES EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS 251 Causeway Street, Suite 800, Boston, MA 02114-2136 Tel. (617) 626-1014 Fax (617) 626-1240 www.mass.gov/orgs/board-of-underwater-archaeological-resources
July 27, 2020
Kathleen A. Theoharides, Secretary Executive Office of Energy and Environmental Affairs Attention: Alex Strysky, MEPA Unit 100 Cambridge Street, Suite 900 Boston, MA 02114
RE: Vineyard Wind, LLC: Vineyard Wind Connector 2 (EOEA #16231), Offshore Export Cables from Federal/Massachusetts Offshore Boundary to Barnstable, MA
Dear Secretary Theoharides,
The staff of the Massachusetts Board of Underwater Archaeological Resources (BUAR) has reviewed the above-referenced proposed project as detailed in the Environmental Monitor of 24 June 2020 and in the project Environmental Notification Form (ENF) prepared and submitted by Epsilon Associates, Inc., on behalf of Vineyard Wind, LLC. We offer the following comments.
The Vineyard Wind Connector 2 Project will link the Park City Wind offshore energy generation facility, proposed for the Southern Wind Development Area (SWDA) portion of Vineyard Wind’s Bureau of Ocean Energy Management (BOEM) federal waters Lease Area (OCS-A-0501), with an onshore substation in West Barnstable. Connection to this substation will be accomplished via one of two potential landfalls at either Craigville Public Beach or Covell’s Beach. Offshore elements of the proposed Vineyard Wind Connector 2’s Offshore Export Cable Corridor (OECC) will transit through approximately 23 miles (37 km) of state waters in the towns of Barnstable, Edgartown, Mashpee (possibly), and Nantucket. The proposed Vineyard Wind Connector 2 Project route will utilize much of the same OECC that underwent MEPA review for the Vineyard Wind 1/Vineyard Wind Connector 1 Project (EEA#15787); however, the specific locations and extents of the Vineyard Wind 1 and 2 Connector Project areas, and their potential impacts to submerged cultural resources located within them, remain not yet fully defined.
A marine archaeological reconnaissance survey of the state waters portion of the OECC for the Vineyard Wind Connector 1 Project in Barnstable, Martha’s, Vineyard, Nantucket, and Yarmouth, conducted under BUAR Special Use Permit (SUP) 17-003 by Vineyard Wind, LLC’s marine archaeological consultants, Gray & Pape, Inc., determined that the offshore component of the waters within and in the vicinity of the OECC possessed a high density of post-contact period shipwrecks and contained numerous areas of submerged paleolandscapes with archaeological sensitivity for potentially containing submerged Native American archaeological deposits.
In consideration of these results, as well as Nantucket Sound’s status as a National Register of Historic Places-eligible Traditional Cultural Property TCP) considered significant for the region’s Wampanoag Tribes, and the Vineyard Wind Connector 2 Project’s proposed utilization of much of the same OECC as the Vineyard Wind 1/Vineyard Wind Connector 1 Project, BUAR concludes that the Vineyard Wind Connector 2 Project area may be generally archaeologically sensitive for both pre-contact period and post-contact period (principally shipwrecks) underwater archaeological resources.
Printed on Recycled Paper
Therefore, BUAR requests that the proponent conduct a marine archaeological survey of the state waters portion of the proposed Vineyard Wind Connector 2 Project area. Such a survey of this element of the OECC would need to be undertaken by a qualified marine archaeologist under a BUAR SUP (distinct and separate from Gray & Pape, Inc.’s current SUP for the Vineyard Wind 1 project), in compliance with the BUAR’s Regulations (312 CMR 2.00). Activities allowed under this permit would include marine archaeological remote sensing survey, geotechnical sediment sampling, archaeological site examination, and undertaking necessary recovery and documentation of these resources in the permit area. All of this work must be conducted in accordance with the BUAR’s directives, standard conditions, Policy Guidance on Archaeological Investigations and Related Survey Standards for the Discovery of Underwater Archaeological Resources, and the project research design and survey plan submitted to BUAR for consideration and approval as part of the SUP application process. For projects subject to review under Section 106 of the National Historic Preservation Act of 1966, as amended (36 CFR 800), permittees are directed to consult with, provide their proposed research design and methodology to, and obtain the approval of, the State Historic Preservation Office/Massachusetts Historical Commission and the lead federal agency, in accordance with 36 CFR 800.4, prior to conducting the field investigation. The BUAR SUP does not relieve the permittee or any other person of the necessity of complying with all other federal, state and local statutes, regulations, by-laws and ordinances.
As part of the measures it will take to comply with federal, state, regional, and local plans and policies related to preserving historical and archaeological resources, the project proponent is reminded that it must consult with BUAR. Under Massachusetts General Law Chapter 6, sections 179-180, and Chapter 91, section 63, cultural resources located within the waters of the Commonwealth of Massachusetts are property of Commonwealth held in title through and subject to BUAR regulations. No one may “remove, displace, damage or destroy” any underwater cultural resources except through consultation with BUAR. Consequently, as title- holder to all underwater archaeological resources in Massachusetts waters, BUAR must be consulted for the Vineyard Wind Connector 2 Project, and project report(s) detailing potential marine archaeological impacts within the state waters portion of the Project area must be submitted to BUAR for review and comment.
Given the proposed Vineyard Wind Connector 2 Project area’s general archaeological sensitivity, the proponent will also need to develop an unanticipated discoveries plan to deal with the possibility that heretofore- unknown submerged cultural resources might be encountered during the course of the project, which includes steps to limit adverse effects and notify the Board and the Massachusetts Historical Commission, as well as other appropriate agencies. The Board suggests the proponent adopt a plan consistent with the Board’s Policy Guidance for the Discovery of Unanticipated Archaeological Resources.
The Board appreciates the opportunity to provide these comments as part of the MEPA review process. Should you have any questions regarding this letter, please do not hesitate to contact me by email at [email protected].
Sincerely,
David S. Robinson Director
/dsr Cc: Brona Simon, MHC Lisa Engler, Robert Boeri, Todd Callaghan, and Stephen McKenna, MCZM (via email attachment) Brandi Carrier, BOEM (via email attachment) Bettina Washington, WTGH/A THPO (via email attachment) David Weeden, MWT THPO (via email attachment) Alma Gordon and Alexis Moreis, CWT (via email attachment) Rachel Pachter, VW LLC (via email attachment) Kimberly Smith, Gray & Pape (via email attachment)
2
June 24, 2020
Mr. Alex Strysky, Environmental Analyst Massachusetts Environmental Policy Act Office 100 Cambridge Street Boston, MA 02114
RE: Environmental Notification Form, Vineyard Wind Connector 2 (EEA No. 16231)
Dear Mr. Strysky,
Thank you for the opportunity to comment on the Vineyard Wind Connector 2 Environmental Notification form. On behalf of our 1,236 member businesses and organizations, we support Vineyard Wind’s second project and the growth this new industry brings to our region. We urge the Massachusetts Environmental Policy Act Office to complete review on schedule and approve the Vineyard Wind Connector 2.
The Vineyard Wind Connector 2 will deliver 800 megawatts of renewable offshore wind energy to the New England electric grid, bring grid reliability to the region, and deliver billions in savings to New England ratepayers. Offshore wind projects bring economic benefits including new jobs and tax revenues, bolster the region’s blue economy, and invigorate the construction and maritime supply chains that are vital to the Cape Cod economy.
The Connector 2 proposal is similar to Vineyard Wind Connector 1 which has been fully permitted by the Commonwealth of Massachusetts. Similarities include a parallel cable corridor through Muskeget Channel and Nantucket Sound, installation techniques using jetplows to minimize short term impacts to the seabed habitat, horizontal directional drilling to tunnel cables beneath a public beach in Barnstable, and robust substation containment.
In a public-private partnership to benefit Barnstable residents and regional water quality, Vineyard Wind is working closely with the Town of Barnstable to collocate municipal sewer infrastructure with transmission cables in roadways, saving the town millions while accelerating installation of important wastewater infrastructure. This collaboration is planned for both Connector projects and is in addition to the Host Community Agreement that guarantees supplemental payments to the town of Barnstable, a value of $32 million over the life of the projects.
In its first project, Vineyard Wind has proven they are a thoughtful, collaborative, partner in the community and they have continued that approach with Connector 2 despite the global challenges presented in 2020. Vineyard Wind has held virtual information sessions for residents to learn about the proposed onshore and offshore transmission cables, onshore substation proposed at an existing motel property on Shootflying Hill Road, and grid interconnection at the existing 345-kV West Barnstable Substation on Oak Street. At this early stage in the permit review process, Vineyard Wind has also sent a letter to residents and businesses along the onshore cable route, given virtual presentations to community organizations, and briefed town leadership in virtual public meetings.
The Cape Cod Chamber of Commerce offices neighbor the proposed substation on Shootflying Hill Road. Vineyard Wind communicated their plans and we are comfortable that the proposal minimizes environmental impacts while maximizing benefits for residents. We understand the project has short term impacts associated with construction but believe the long-term benefits outweigh short term impacts. The site of the proposed substation on Shootflying Hill Road and the surrounding area is a wooded, residential area. There is an existing motel business on the site of the proposed substation where electricity will be stepped up to 345-kv for interconnection at the West Barnstable Substation approximately 1 mile away. All the cable infrastructure is proposed for burial along public roadways and existing rights- of-way. We note that Vineyard Wind has proposed a trenchless crossing of Cape Cod’s main traffic artery, Route 6, to avoid major disruptions to that critical roadway.
The Cape Cod Chamber of Commerce supports Vineyard Wind and this major new industry. We will continue to monitor Vineyard Wind Connector 2 as it continues through the MEPA environmental review process and we encourage favorable action. Thank you again for the opportunity to comment on this project.
Sincerely,
Wendy K. Northcross, CCE Chief Executive Officer
Cape Cod Chamber of Commerce, 5 Patti Page Way, Centerville, MA 02632 1-888-33CapeCod (888-332-2732) or 508-362-3225 CapeCodChamber.org, Facebook & Twitter at VisitCapeCod
Via Email
July 22, 2020 Kathleen A. Theoharides, Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs Attn: MEPA Office, Alex Strysky, MEPA Analyst 100 Cambridge Street, Suite 900, Boston, MA 02114
Re: Environmental Notification Form- EEA No. 16231-Vineyard Wind Connector 2, Barnstable
Dear Secretary Theoharides:
Thank you for the opportunity to provide comment on the above-referenced matter.
Cape Cod Commission staff believe the proponent has properly scoped in the ENF the relevant issues and alternatives to consider during the project’s subsequent MEPA review. After MEPA review concludes, the Cape Cod Commission will conduct Development of Regional Impact (DRI) review on the project.
Commission staff’s attached comments are geared primarily to DRI review of the project, namely the Cape Cod Regional Policy Plan (RPP) issues the Commission will take up during DRI review, and some of the specific plans, studies and other information the proponent will need to provide for DRI review. Nonetheless, the proponent’s submissions and responses to these comments during the MEPA process might assist state agency reviews as well.
Please do not hesitate to contact Commission staff with any questions about these comments.
Sincerely,
Kristy Senatori Executive Director
ENC cc: Project File via email- Holly Johnston, Epsilon Associates Mark Ells, Barnstable Town Manager Fred Chirigotis, Barnstable Cape Cod Commission Representative Harold Mitchell, Cape Cod Commission Chair Elizabeth Taylor, Cape Cod Commission Committee on Planning and Regulation Chair
Attachment- Cape Cod Commission Staff Comments- Vineyard Wind Connector 2 ENF
The Vineyard Wind Connector 2 project is similar in many respects to Vineyard Wind Connector 1, for which the Cape Cod Commission previously granted Development of Regional Impact approval. Accordingly, many of the DRI review issues, approaches and resolutions will likely be similar between the projects. Along these lines, and as Commission staff understands it, Vineyard Wind Connector 2 will be subject to the Host Community Agreement previously entered into between the proponent and the Town of Barnstable at the time Vineyard Wind Connector 1 was under review. The HCA was a significant consideration in the Cape Cod Commission’s review and approval of the first Vineyard Wind connector project.
The following are comments from the Cape Cod Regional Policy Plan’s goals and objectives relevant to the Vineyard Wind Connector 2 project:
Natural Resources (Open Space, Habitat, Wetlands, and Coastal Resiliency) Commission staff does not anticipate adverse impacts to natural resources from the proposed land installation routes presented, provided construction best management practices are followed. Commission staff encourage the Proponent to site project elements on previously disturbed land to the greatest extent feasible. Indeed, the preferred, noticed alternative, and variant land-based cable routes are primarily located within existing rights of way, mostly under existing paved surfaces.
The Proponent should conduct and submit a project Natural Resources Inventory (NRI) for DRI review, which would identify the presence of sensitive natural resources within the project footprint that could be impacted by the project.
According to the ENF, certain portions of the preferred route and variants cross land currently held for Article 97 purposes, including the existing parking lot and beach at the preferred landfall site and a utility ROW located between the proposed new and existing West Barnstable substation sites. These alternatives should be thoroughly investigated and impacts to resources on Article 97 lands avoided to the greatest extent feasible. If unavoidable, the Proponent may be required to seek legislative approval and mitigate for loss of Article 97 values.
The entire 2.8-acre parcel adjacent to the West Barnstable substation and the southern part of the 6.7-acre Shootflying Hill Road parcel are presently wooded and undisturbed. The parcel adjacent to the West Barnstable substation is also part of a large contiguous area of undeveloped land, including a Town of Barnstable Conservation Area and Barnstable State Forest, that likely provides habitat for wildlife. The Proponent should provide more detailed substation plans, including land and tree clearing and design details, so that reviewers may determine what level of impact the substation work might have on surrounding development, uses, and natural resources, and what mitigation actions might be proposed to address such impacts.
The proposed preferred landfall site, the Centerville River crossing, and portions of the cable routes and the proposed substation on Shootflying Hill Road are within the “Natural Area Placetype” as defined in the RPP and identified in the Commission’s RPP Data Viewer. Proposed cable routes also cross through wetland buffers and the preferred route between the proposed Shootflying Hill Road substation and the West Barnstable substation crosses through a vernal pool buffer. The NRI should address project activities that might impact these natural resource areas.
The preferred landfall site and alternative are within mapped rare species habitat. According to the ENF, rare species known to occur in the project area include piping plover, least tern, and roseate tern. The Craigville Beach and Centerville River project areas are also mapped BioMap2 Critical Natural Landscape for tern foraging area. The Proponent should continue to consult with NHESP on development of a protection plan to avoid and minimize impacts to rare species. Proposed horizontal directional drilling at
Cape Cod Commission Comments — Vineyard Wind Connector 2 ENF- July 2020 Page 2 the landfall should avoid impacts to potential bird nesting areas. Timing of construction to avoid bird nesting and foraging seasons will also be important.
Project activities proposed within the floodplain include horizontal directional drilling at the beach landfall and micro-tunneling at the Centerville River Crossing. Development within the floodplain is vulnerable to coastal storms and the effects of sea level rise. The Proponent should provide detailed information on how proposed methods and infrastructure are designed to address sea level rise and storms.
Commission staff support coordination of cable installation with town sewer installation to minimize extent and duration of impacts. The Proponent should provide some analysis of the cumulative impacts of the proposed cable installation and substation developments with existing development and other proposed developments including Vineyard Wind Connector 1.
Water Resources The proposed substation on Shootflying Hill Road is within mapped Wellhead Protection Area (Barnstable Fire District) and Marine Water Recharge Area (MWRA) (Barnstable Harbor).
The proponent proposes a possible expansion of the existing West Barnstable substation along its existing southeast border. The EIR should provide more detailed substation plans for the 2.8 acre forested parcel upon which the expansion would be proposed, including depiction of proposed tree clearing, grading, and design details. While there is currently a substation adjacent to this location, the area is mapped for Freshwater Recharge (Garretts Pond) and within an MWRA (Barnstable Harbor). Additional mitigatory actions might be required to address project impacts.
The proposed preferred transmission cable route runs through or adjacent to areas designated by the Commission for Wellhead Protection, Freshwater Recharge, MWRA, and Potential Public Water Supplies. Water resource considerations will largely be limited to the construction phase. Appropriate project management during and after construction should be sufficient to mitigate potential impacts to these resources.
Commission staff recommend including, as part of the EIR, additional information regarding the different substation design alternatives (e.g. Air Insulated Substation vs Gas Insulated; potential for re-allocation of substation equipment and development between Shootflying Hill and the West Barnstable parcels) to allow for comparison between the different alternative scenarios for developed footprint and impervious areas and how that might impact stormwater, open space, and other RPP considerations. The EIR should provide detailed information about the volume and types of materials anticipated for use at the substations that could pose a threat to ground and surface water quality, and proposed containment measures.
Commission staff recommend the applicant include in the EIR a stormwater management plan for construction (including erosion and sediment controls) and post-construction/ operation periods as well as a Spill Prevention, Control and Countermeasure (SPCC) plan.
Community Design The onshore transmission and onshore substations are the project elements most likely to have potential community character impacts. The proposed onshore transmission route includes several alternatives but all involve laying cables underground in the road right-of-way for the majority of the project’s length, which would not involve potential community character impacts. A variety of alternatives are proposed at the Centerville River crossing, including boring under the riverbed or increasing the height of the bridge superstructure by 2.7 feet and gradually lowering the adjacent finished roadway. From a community character perspective, the increased bridge height taken alone may be less than ideal, but it is unlikely to affect scenic views and in light of other resource concerns it is appropriate to consider. As long as the cables are not placed above the bridge deck where they would block open views to the river and marsh system, community character impacts will be limited.
According to the preliminary proposed project plans, the community character impacts of the various substation development proposals will likely be minimal, due to screening by existing and proposed
Cape Cod Commission Comments — Vineyard Wind Connector 2 ENF- July 2020 Page 3 naturally vegetated buffers, though it is difficult to say definitively without knowing the heights of the proposed substation structures. The proponent should identify the range of possible heights of the substation elements and provide landscape and perspective plans showing details of the proposed vegetated buffers to assess their effectiveness at screening the proposed substation expansion. Ultimately, the proposed substation development should be sensitive to the existing, surrounding context in which it will be located.
The new substation site, which currently houses a motel, has residential properties to the west, Shootflying Hill Road to the north, and undeveloped land to the east. To the south is an existing right of way currently used for power lines. The proposal for the Shootflying Hill Road parcel includes an approximately 40’ vegetated buffer along the northern and western sides of the site. Care should be taken to ensure existing vegetation and supplemental plantings are robust enough to provide visual screening of the site structures. Additionally, the buffer should contain both evergreen and deciduous plants to provide year- round screening. The project does not propose plantings along the eastern side of the site as it contains some of the access roadway and abuts undeveloped wooded land. To the extent possible, vegetation along the perimeter may still be desirable in the event the parcel to the east becomes developed at some point. There is no proposed vegetated screening along the southern boundary. Though this site is already developed, the existing development is located approximately on the front half of the parcel, leaving the back half of the parcel wooded. The proposed substation at maximum buildout here would result in clearing of much of the vegetation that currently exists on the site (approximately the back half of the parcel).
In addition to the Shootflying Hill Road parcel, the project may result in development of parcel #214- 001, east of the West Barnstable Substation north of Route 6. Development of this parcel would entail clearing a currently undeveloped parcel, but would reduce the amount of potential substation development on the Shootflying Hill Road parcel, allowing for greater vegetated buffers on the latter parcel. The proposed development of parcel #214-001 does not include vegetated buffers. This is likely not necessary on the northern and western sides of the parcel, as those abut the existing substation property. The southern property boundary parallels Route 6 and given the current layout of the roadway, and the existing vegetation within the layout, the development will likely not have significant visual impacts from Route 6. However, were the improved roadway to change and some of the existing vegetation to be removed, the project could potentially be visible from Route 6 and so including some vegetated buffer along the southern edge may be helpful in preempting this future potential visual impact.
Cultural Resources The project involves potential impacts to archaeological resources, both underwater and land-based, and possibly to historic resources along the land-based cable route. Regarding underwater archaeological resources, the proponent is coordinating with the Massachusetts Board of Underwater Archaeological Resources (MBUAR) to conduct off-shore surveys and identify appropriate mitigation to limit impacts to significant resources along the transmission route. The RPP supports protecting these resources by limiting disturbance of any that are identified as archaeologically significant.
While much of the on-shore transmission route will be located within previously disturbed roadbeds and road rights-of-way, the proposed route does pass through some known archaeological sites in Barnstable. The proponent will conduct a reconnaissance archaeological survey to examine transmission routes that have not been previously disturbed, and the results of this survey should guide the choice of alternative routes and variants. Every reasonable effort should be made to determine a feasible alternate route that avoids impacting significant archaeological resources within these sites.
The project is not expected to impact any above-ground historic structures directly, but the identified preferred route passes many inventoried historic properties along Craigville Beach Road, Main Street, South Main Street, Old Stage Road, and Phinney’s Lane. In addition, the northern-most portion of the route is adjacent to the Old Kings Highway Historic District and the noticed alternative route would lay cable along Oak Street and several historic properties there. The most significant historic resources in the project area are the Centerville National Register Historic District and the few individually listed National Register properties outside that district. Both the Centerville historic district and those areas close to the Centerville River are likely to have high archaeological sensitivity, so avoiding currently
Cape Cod Commission Comments — Vineyard Wind Connector 2 ENF- July 2020 Page 4 undisturbed areas will be important. The applicant should also clarify whether any above-ground structures are proposed adjacent to historic resources.
Transportation Construction period traffic management strategies for all modes of transportation should be detailed in subsequent submissions. Temporary traffic control plans should be prepared for the affected roadways, including intersections of major road crossings.
Continued discussions with the Town of Barnstable and MassDOT are encouraged for further coordination on future roadway and infrastructure projects that may coincide with the Vineyard Wind 2 offshore utility work, including the future Cape Cod Rail Trail extension project and the sewer installation in Centerville. On affected roadways where work will be performed in the shoulder area, consideration should be given to leaving a graded surface that would be suitable for future installation of sidewalks or multi-use paths, based on consultation and coordination with the Town.
Plans detailing the layout of the proposed substation site designs, including driveway location and design, should be included for DRI review.
Capital Facilities & Infrastructure/ Energy The proponent should discuss in greater detail how the project will increase grid resiliency for Cape Cod, including whether there has been any discussion about or consideration for energy storage capacity as part of the proposed substation development.
Ocean Resources The project is utilizing the same offshore cable route used for Vineyard Wind Connector 1, with some widening proposed. The ENF indicates that surveys for the widened sections of the OECC route will occur in 2020, but that using the same route will avoid impacts to North Atlantic Right Whale habitat and eelgrass resources. The horizontal directional drilling near the cable landfall will also avoid sensitive resources, including hard/complex bottom and eelgrass. The EIR should discuss the alternatives and impacts associated with different installation options for the cables once they exit the HDD corridor and are installed on/near the seafloor surface.
Given the additional lease areas identified in the BOEM offshore wind lease areas, Commission staff anticipates that future proposals will also seek to site cables through the identified corridor. The EIR filing should consider examining siting of the export cables within the OECC route area as close together as feasible to minimize impacts to sensitive habitats and utilize the ocean floor as efficiently as possible, while allowing for future maintenance needs.
DRI review will consider the cumulative impacts of the proposed cable installation together with existing development within the Nantucket Sound Ocean Resource Area, including the Vineyard Wind Connector 1. The Proponent should provide some analysis of the cumulative impacts to address this review standard.
The Project will traverse mapped habitat for rare birds. Proposed directional drilling should avoid impacts to bird species, but Commission staff will look for guidance from DMF and NHESP in determining the adequacy of the Project design, as well as construction timing, to avoid and mitigate the impacts to rare species, marine mammals, and other sensitive marine resources.
Commission staff will look for guidance from DMF, and the Proponent should include detailed plans for post-construction monitoring, to include long-term monitoring of species important to Cape Cod’s recreational, charter, and commercial fisheries, both inshore and offshore.
Cape Cod Commission Comments — Vineyard Wind Connector 2 ENF- July 2020 Page 5 The General Court of the Commonwealth of Massachusetts State House, Boston, MA 02133-1053
July 27, 2020
Mr. Alex Strysky, Environmental Analyst Massachusetts Environmental Policy Act Office 100 Cambridge Street Boston, MA 02114
RE: Vineyard Wind Connector 2 – Barnstable, Edgartown, Mashpee, and Nantucket (EEA No. 16231)
Dear Mr. Strysky,
Thank you for the opportunity to comment on the Vineyard Wind Connector 2 filed with the Massachusetts Environmental Policy Act Office. Vineyard Wind Connector 2 has many similarities to Vineyard Wind’s first project approved by the Commonwealth, including cables traversing a similar corridor below the seabed, using the same installation methods, and making landfall and connecting to the electric grid in Barnstable. We are writing you today to express our strong support for both Vineyard Wind’s second project, Park City Wind, and its grid interconnection in Barnstable, Vineyard Wind Connector 2.
The Commonwealth has led the nation in the pursuit of offshore wind – the 2016 Energy Diversity Act saw broad, bipartisan support, and an alliance of environmental, labor and business interests who saw not only the clean energy benefits, but also the opportunity to build a new business sector in the United States, one that will contribute to the transition of our energy grid to new, renewable sources of clean energy. That law ushered in the offshore wind era by directing our state utilities to procure 1600MW of offshore wind into our electricity grid, with another 1600MW authorized. With these procurements, offshore wind would supply nearly a quarter of the electricity used by homes and businesses in Massachusetts. Other states in the Northeast quickly followed our example and sought to procure clean affordable offshore wind energy for their ratepayers including Rhode Island, Connecticut, and New York.
Vineyard Wind’s Park City Wind project will bring an additional 800 megawatts of renewable offshore wind energy to the New England electric grid and will increase the reliability and diversity of the New England energy supply. The energy generated and transmitted from Park City Wind will reduce the region’s reliance on natural gas and oil for electricity generation and reduce year-round price volatility as natural gas supplies are already constrained. New offshore wind projects are also vital for meeting clean electricity supply demands impacted by the retirement of nuclear and, oil and gas power plants, a key step in reaching environmental justice in communities where air quality is impacted negatively by these fossil fuel facilities.
Beyond helping to prevent volatility, the Park City Wind project and the Vineyard Wind Connector 2 will create massive savings for the ISO NE system. According to an independent analysis by Leidos Engineering LLC, this project will save ratepayers within ISO-NE $2.28 billion over its 30-year lifespan.
An offshore wind project creates thousands of jobs over its lifespan and provides economic benefits for communities, states, and the region. With four offshore wind projects awarded by New England states, this will further establish the region as the hub of the offshore wind industry in United States. Vineyard Wind has made commitments to contract with local companies and is already investing in the development of a localized supply chain which will lay the foundation for a strong utility-scale offshore wind industry. These benefits include job creation throughout the lifetime of each project as well as leveraging economies of scale in the supply chain. The economic benefits extend directly to municipalities through increases in tax revenue, allowing towns to pursue new projects benefiting their communities. One example of this positive impact is visible in Barnstable, where Vineyard Wind signed a Host Community Agreement to include annual supplemental payments to the town beyond tax revenue from infrastructure. These annual payments combined with increases to property tax revenue will total $32 million over 25 years. The town of Barnstable has dedicated these funds towards water protection and new water wells in the town, clearly demonstrating the public good that comes from well-planned stakeholder engagement in offshore wind development.
The economic and environmental benefits of new offshore wind projects are a game changer for communities in our region and across the country, especially at a time when our nation is facing multiple crises including the climate crisis and economic impacts from the ongoing pandemic. We urge you to expeditiously review and approve Vineyard Wind Connector 2. Thank you again.
Respectfully,
Julian Cyr Dylan A. Fernandes State Senator State Representative Cape and Islands District Barnstable, Dukes and Nantucket District
MEMORANDUM
TO: Kathleen Theoharides, Secretary, EEA ATTN: Alex Strysky, MEPA Office FROM: Lisa Berry Engler, Director, CZM DATE: July 28, 2020 RE: EEA-16231, Vineyard Wind 2 Connector
The Massachusetts Office of Coastal Zone Management (CZM) has completed its review of the above-referenced Environmental Notification Form (ENF), noticed in the Environmental Monitor dated June 24, 2020 and offers the following comments.
Project Description Vineyard Wind’s first project, Vineyard Wind Connector 1, was previously reviewed in MEPA (EEA#15787) and received its Massachusetts permits. It will deliver approximately 800 megawatts (MW) to the ISO New England (ISO-NE) regional electrical grid from Vineyard Wind 1, a wind energy generation project in the late stages of federal permitting. Vineyard Wind 1 will be built in the northern zone of federal lease area OCS-A 0501. The remaining portion of the lease area not being developed for Vineyard Wind 1 is referred to as the Southern Wind Development Area (SWDA). Vineyard Wind’s second project is Vineyard Wind Connector 2. It will deliver approximately 800 MW to the regional electrical grid from Park City Wind, a wind energy generation project located in the northern part of the SWDA.
Vineyard Wind Connector 2 includes two three-core offshore export cables connecting an offshore electrical service platform (ESP) to a landfall site onshore. The two offshore export cables will transition to six single-core onshore export cables in transition vaults at the landfall site, then continue underground within a buried concrete duct bank. Landfall will be made via Horizontal Directional Drilling (HDD) with the transition to the onshore cable occurring within the parking lot at Craigville Beach, a Town of Barnstable public beach. The onshore route will predominantly follow existing public roadways to the proposed onshore substation. A section of the route requires the cable to pass beneath the Centerville River, where a micro-tunneling process is proposed. The substation will step up voltage to enable the interconnection with the electrical grid at the existing Eversource 345-kilovolt (kV) West Barnstable Substation. Onshore project elements will be located entirely within the Town of Barnstable. Offshore elements of Vineyard Wind Connector 2 will largely utilize the Offshore Export Cable Corridor (OECC) developed for Vineyard Wind Connector 1 that was previously reviewed in MEPA, with the exception that the OECC has been widened by approximately 985 feet (300 meters [m]) to the west, and along a segment through the Muskeget Channel area it has also been widened by approximately 985 feet (300 m) to the east. The typical width of the OECC is approximately 3,800 feet (1,150 m), with a range between approximately 3,100 to 5,100 feet (950 to 1,550 m). Within Massachusetts waters, the OECC will pass offshore through the towns of Edgartown, Nantucket, Barnstable, and possibly a corner of Mashpee before making landfall in Barnstable. The total length of the OECC from Park City Wind in the SWDA to the landfall site is approximately 63 miles (101 kilometers [km]), with approximately 23 miles (37 km) of the OECC located within state waters. Major elements of Park City Wind in the SWDA in federal waters will include wind turbine generators (WTGs) and foundations, ESPs and foundations, and inter-array cables.
At its nearest point, the SWDA where the infrastructure for Park City Wind will be located is just over 19 miles (31 km) from the southwest corner of Martha’s Vineyard (about 16 miles into federal waters) and approximately 23 miles (37 km) from Nantucket; the SWDA is approximately 41 miles (66 km) south of the Cape Cod mainland.
According to the ENF, elements of the project within Commonwealth jurisdiction, including MEPA review, cover portions of the two offshore export cables in state waters (approximately 23 miles [37 km] for each of the two cables), the transition to shore via HDD at the landfall site, all onshore transmission, the proposed onshore substation, and the 345-kV interconnection to the electrical grid, which will involve some expansion of the existing 345-kV West Barnstable Substation. Additionally, all offshore and onshore elements of the Park City Wind project will be subject to review under federal processes coordinated by the Bureau of Ocean Energy Management (BOEM) with federal consistency review of the federal actions being undertaken by CZM. According to Vineyard Wind, the remaining build-out of lease area OCS-A 0501 will also be included in the federal review, to the extent those project elements are known.
Project Comments The comments below identify areas where CZM looks forward to working with Vineyard Wind, as well as our state and federal partners, in the permitting process to ensure the project’s avoidance and minimization of impacts to sensitive resource areas.
Massachusetts Ocean Management Plan In its MEPA filings, Vineyard Wind 1 provided detailed plan view maps of the proposed project relative to existing ocean resources and uses addressed in the Massachusetts Ocean Management Plan (OMP) including eelgrass, hard bottom, and complex seafloor. In addition, the Vineyard Wind 1 project identified biogenic seafloor features. This ENF contains those same maps; however, there was no information presented for the expanded OECC sections. The additional data collected for the expanded OECC should be presented in the EIR and mapped in a seamless way with the data previously collected for Vineyard Wind 1. As with Vineyard Wind 1, CZM suggests that Vineyard Wind use its survey data to avoid or minimize large sand waves, and through careful cable route siting, make every effort to decrease the amount of dredging proposed in sand waves. CZM recommends that Vineyard Wind quantify, in both linear and areal extent, the amount of hard and complex seafloor that cannot be avoided and that may be impacted during the cable laying process (directly through plowing and dredging and also with anchoring activities). These areas of hard and complex seafloor that might be disturbed should also be mapped. In order to meet the siting standards in the OMP, Vineyard Wind must use its proposed cable alignments to avoid hard and complex seafloor to the maximum extent practicable and where it cannot be avoided, provide information that no less damaging environmentally practicable alternative exists. In addition, information should be presented to allow EEA to determine if the public benefits of the proposed total project outweigh the public detriments to OMP resources as in 301 CMR 28.00. The ENF contains a public benefits section (Section 1.6) that could be referred to in the EIR.
Seafloor Assessment The ENF presents data from the 2017-2019 seafloor assessment surveys as figures in Attachment G. While these figures are useful in depicting seafloor habitats, there are only a limited number of images presented. CZM suggests that Vineyard Wind make all of the seafloor images it has collected readily available through an interactive viewer (similar to what USGS
(https://video.ioos.us/) and Orsted have done for their seafloor imagery collections). To assist in interpretations and to ensure consistency, CZM suggests that Vineyard Wind use the federally approved Coastal and Marine Ecological Classification System (CMECS)1 to describe seafloor features instead of Auster 1998, which has been superseded. The EIR should report all of the new seafloor data (bathymetry, seafloor classification, sediment type, sediment cores, infauna community) acquired for the expanded OECC in the EIR and ensure that reviewers have access to the data from the Vineyard Wind 1 project as well.
Species of Concern For the Vineyard Wind 1 project, Vineyard Wind proposed to avoid wind turbine pile driving in offshore waters between January 1 and April 30 in order to protect marine mammals, to orient horizontal directional drilling (HDD) activities to avoid eelgrass, and to time HDD at Covell’s Beach to occur between August 31 and April 1 in order to avoid horseshoe crab spawning and Piping Plover nesting. Vineyard Wind was also working with DMF and its cable vendors to install the Vineyard Wind 1 export cable in a way that minimizes impacts to the squid fishery in state waters. The Piping Plover Protection Plan included in this ENF is a positive step toward addressing endangered species in the project area; however, CZM suggests that the EIR further details how the Vineyard Wind 2 project will be timed, staged, and sequenced to minimize impacts to all species of concern.
Coastal Resiliency The ENF indicates that the shoreline change history for the landing site was considered to determine its vulnerability to erosion. Since the shoreline change delineations average all changes over the long term, it is not a good indicator of the amount of erosion that would occur in a major storm. On shorelines such as the proposed landing site for this project, where the primary vulnerability is to relatively infrequent hurricanes, the shoreline change data do not characterize the erosion that would occur in a major storm. Since the Vineyard Wind 2 project is intended to supply energy, it is considered critical infrastructure and therefore should be designed based on the possible impacts of a major hurricane as well as sea level rise. The EIR should include an analysis of the likely nearshore, beach, and dune erosion at the preferred landing site during a major storm to ensure that the cables and associated infrastructure remain sufficiently buried
Cable Laying The ENF estimates that trenching and anchoring impacts associated with laying the two export cables will affect 18.4 acres (7.4 hectares [ha]) and 12.7 acres (5.1 ha) of seafloor, respectively. Vineyard Wind proposes to dredge the tops of sand waves to assist the cable laying tool in reaching adequate burial depth. Dredging will occur via a trailing suction hopper dredge or jetting by controlled flow excavation. In both cases, dredge spoils will be disposed of within the mapped OECC, although models for Vineyard Wind 1 suggest that the sediment plume may travel beyond the OECC. Dredged areas within sand waves are proposed to be 50 feet (15 m) at the bottom with 3:1 side a slope for each cable. Up to 106,000 cubic yards (81,000 cubic m) of dredging is proposed in state waters over 4.2 miles (6.8 km) for about 25 acres (10.1 ha) of direct seafloor disturbance. Sand wave dredging in federal waters will occur over 6 miles (9.6 km) for a total of 30 acres (12 ha) of direct disturbance. The length of cable in federal waters is expected to be 40 miles (64 km) which, with a disturbance of 3.3 feet (1 m) wide, would equal 32 acres (13 ha) of seafloor disturbed in federal waters. An additional 97 acres (39 ha) of seafloor would be disturbed by skid tracks of the installation tool. The ENF states
1 https://www.fgdc.gov/standards/projects/cmecs-folder/CMECS_Version_06-2012_FINAL.pdf
that areas where cable protection will be needed are still being estimated. An estimate of the linear and areal extent of permanent seafloor habitat conversion should be presented in the EIR.
Specifically regarding cable burial, it is important that all efforts be made to lay the cable at adequate depth to minimize the amount of cable protection required and to ensure that the cable does not become exposed in the long term. The ENF states that “methods for cable protection may include rock protection, gabion rock bags, concrete mattresses, or half shell pipes.” CZM discourages the use of armoring due to the detrimental impacts that can include increased scouring of the seafloor adjacent to the hard cover, increased substrate providing a vector for invasive species colonization, and impacts to commercial and recreational fishing operations. Instead of hard cover, CZM recommends additional efforts to bury any exposed cable to the appropriate depth or covering the cable with sandbags and gravel/cobble cover, as appropriate, to mimic adjacent seafloor conditions.
Underwater Archaeological Resources A marine archaeological reconnaissance survey of the state waters portion of the OECC for the Vineyard Wind Connector 1 in Barnstable, Martha’s, Vineyard, Nantucket, and Yarmouth, determined that the offshore component of the waters within and in the vicinity of the OECC possessed a high density of post-contact period shipwrecks and contained numerous areas of submerged paleolandscapes with archaeological sensitivity for potentially containing submerged Native American archaeological deposits.
In consideration of these results and the proposed utilization of much of the same OECC for the Vineyard Wind Connector 2 as the Vineyard Wind Connector 1, the project area may be archaeologically sensitive for both pre- and post-contact period (principally shipwrecks) underwater archaeological resources. CZM recommends that the proponent coordinate closely with the Massachusetts Board of Underwater Archaeological Resources (BUAR) on the marine archaeological survey of the state waters portion of the proposed Vineyard Wind Connector 2 area and the submission of reports detailing potential marine archaeological impacts within the state waters portion of the project area. The proponent should also develop a plan to address the possibility that heretofore-unknown submerged cultural resources may be encountered during the course of the project, which includes steps to limit adverse effects and notify the Board and the Massachusetts Historical Commission, as well as other appropriate agencies. A plan consistent with the BUAR’s Policy Guidance for the Discovery of Unanticipated Archaeological Resources should be adopted.
Monitoring Plan The EIR should describe a comprehensive monitoring plan for Vineyard Wind 2, developed in conjunction with CZM and other state agencies. The monitoring plan should: 1) establish a robust pre-construction baseline for potentially impacted biota and habitat; 2) evaluate Total Suspended Solids dispersion during construction; 3) measure changes in seafloor topography and disturbance of seafloor habitats, including eelgrass; 4) evaluate the adequate burial of the cables in the near and long term; 5) estimate recovery times of resources; and 6) outline adequate methods and metrics to detect differences in biological or geological parameters within the construction corridor.
Cumulative Impacts CZM recognizes and commends Vineyard Wind’s efforts to synchronize the construction and road disturbances necessary for shore side aspects of Vineyard Wind 1 with the Town of Barnstable’s planned sewer infrastructure improvements. As stated in the ENF, Vineyard Wind is again working with the Town to reduce the cumulative impacts of multiple linear infrastructure projects in public
roadways and to create cost savings for the Town. The ENF describes at least three projects that will arise out of Vineyard Wind’s lease OCS-A 0501. In the EIR, CZM recommends that Vineyard Wind include a cumulative impact assessment of its three projects including the expected total temporary (e.g., dredged areas) and permanent (e.g., cable protection) impacts across the three construction windows and requests that Vineyard Wind look for ways to minimize cumulative impacts in the offshore portion of the project by coordinating aspects of its three projects (e.g., cable siting and laying).
Decommissioning According to 30 CFR Part 385 and other BOEM requirements, Vineyard Wind must remove all installations and clear the seabed of all obstructions created by the project within two years of termination of its lease. Documents for Vineyard Wind 1 explained that decommissioning would include leaving onshore facilities in place, while removing the offshore export cable, scour protection, and hard protection atop cables. In addition, WTG and ESP structures would be removed to 15 feet (4.6 m) below the mud line and shipped to various ports for disposal. The EIR should more thoroughly describe the decommissioning process for Vineyard Wind 2 and Vineyard Wind’s financial commitment to decommissioning and appropriate landside disposal. The EIR should more thoroughly describe the decommissioning process for Vineyard Wind 2 and Vineyard Wind’s financial commitment to decommissioning and appropriate landside disposal. Further, previous experience with cables and pipelines in state waters indicates that due to the magnitude of potential environmental impacts resulting from the removal of linear structures in the seafloor, structures may be abandoned in place. This alternative should be presented and described in the EIR.
Mitigation Under the OMP regulations, the EEA Secretary can negotiate an Ocean Development Mitigation Fee to compensate for unavoidable impacts to public interests during construction in the ocean management planning area. For Vineyard Wind 1 the fee was $240,000, subject to adjustment based on final as-built impact calculations. The EIR for Vineyard Wind 2 should contain a proposal for mitigation that is based upon the full extent of the impact of the project including: direct cable laying and dredging area, dredged disposal area, sediment deposition area, and impacts to biota and habitat, as well as predicted permanent hard cover.
Vineyard Wind engaged in discussions with EEA, CZM, and DMF regarding mitigation for commercial and recreational fisheries that may be impacted by Vineyard Wind 1. Vineyard Wind should again coordinate with agencies and the MA fishing industry to establish appropriate mitigation for Massachusetts fisheries interests that might be affected by Vineyard Wind 2. The discussions should include compensation to Massachusetts fishermen for losses incurred during construction as well as the potential loss of fishing opportunities over the lifespan of the project. To facilitate these discussions, the EIR should report the recent history of fishing activity (landings and value) by sector and port across the entire project footprint (OECC and WDA).
Over the last few years BOEM, in conjunction with the U.S. Fish and Wildlife Service and research institutions, has supported many studies to help better define the foraging and migration behavior of various coastal birds in and adjacent to offshore wind lease areas. While there are some data about the avoidance or attraction of avifauna to wind farms in Europe, Cape Cod is a unique geographical feature in that it is the staging area for many birds traveling from the eastern margin of the northern hemisphere to the southern hemisphere in the fall, and northward along the coast in the spring, as well as home to significant breeding populations of coastal waterbirds including the state
and federally listed Roseate Tern and Piping Plover. It is important for bird migration studies to continue, to assist in the careful future siting of WTGs so that they do not overlap with migration routes and to provide data for adaptive management in the operations and maintenance of WTGs throughout the region. Based in part on consultation with the Massachusetts Division of Fisheries & Wildlife, CZM recommends that the EIR describe Vineyard Wind’s commitment to regional studies of avifauna migrations and mitigation for the impacts of wind turbines on migrating birds.
Federal Consistency Review Attachment E of the ENF contains the proponent’s federal consistency statement. The ENF states that “CZM jurisdiction over this Project extends to the entirety of the OECC within state waters, associated landfall sites, onshore routes, and substation.” This is true; however, CZM’s federal consistency authority extends to activities that have reasonably foreseeable effects on any coastal use or resources resulting from a federal agency activity or federal license or permit activity. Renewable energy leases and related authorizations by BOEM are listed federal actions of the state’s approved Coastal Management Program. While CZM’s review of the entire project to ensure consistency with policies of the Coastal Management Program will occur through the federal BOEM renewable energy program and National Environmental Policy Act filings, CZM requests that the proponent provide information on activities in adjacent federal waters to the extent practicable as well as potential effects on state resources and uses in subsequent MEPA filings to allow for a more complete assessment of the entire project through this MEPA process.
For further information on this process, please contact, Robert Boeri, Project Review Coordinator, at [email protected] or visit the CZM web site at www.state.ma.us/czm/fcr.htm.
LBE /rlb/tc/rh/sm/ cc: Nina Coleman, Director of Natural Resources, Barnstable, MA Gregg Frazier, Falmouth Harbor Master Stephen McKenna, CZM Cape & Islands Regional Coordinator DEP, Southeast Regional Office Yarmouth Conservation Commission Barnstable Conservation Commission Holly Carlson Johnston, Epsilon Associates, Inc. Rachel Pachter, Vineyard Wind Conrad Caia, Yarmouth Shellfish Constable Dan Horn, Barnstable Shellfish Constable Christopher Boelke, Sue Tuxbury & Alison Verkade, NMFS Ed Reiner, EPA Derek Standish, David Wong, DEP Kathryn Ford, John Logan, Eileen Feeney, DMF
From: Ron Dagostino To: Strysky, Alexander (EEA) Subject: Vineyard Wind Connector 2 Date: Wednesday, July 8, 2020 3:51:50 PM
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe. Hi Alex. I am writing to express my strong support for Vineyard Wind Connector 2. The climate and environmental benefits of the 800 MW offshore wind project that the connector is a part of are obvious given the climate change crisis we face. If that alone is not enough then consider the financial benefits. According to an independent analysis by Leidos Engineering LLC, this project will save ISO-NE $2.28 billion over its 30-year lifespan. Annual payments to Barnstable from a Host Community Agreement signed by Vineyard Wind, combined with increases to property tax revenue, will total $32 million over 25 years; the town has dedicated these funds towards water protection and new water wells in the town, and this demonstrates the public good that derives from well-planned stakeholder engagement in offshore wind development. The project will also likely result in the creation of hundreds - and perhaps thousands - of local jobs over its lifespan.
I urgently and emphatically encourage you to support this project's approval.
Sincerely,
Ron Dagostino West Tisbury, MA
Charles D. Baker Kathleen A. Theoharides Governor Secretary
Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner
July 28, 2020
Kathleen A. Theoharides RE: Environmental Notification Form Secretary of Energy and Environment Review Executive Office of Energy and EOEEA 16231 BARNSTABLE. Vineyard Environmental Affairs Wind Connector 2 originating from offshore 100 Cambridge Street, Suite 900 export cables from Federal/Massachusetts ATTN: MEPA Office offshore boundary, northerly to Craigville Boston, MA 02114 Public Beach in Barnstable (Preferred Route), and onshore underground cables to a new substation in Barnstable and ultimately to an interconnection at Eversource’s existing 35-kV West Barnstable Substation
Dear Secretary Theoharides,
The Southeast Regional Office of the Department of Environmental Protection (MassDEP) has reviewed the Environmental Notification Form (ENF) for the Vineyard Wind Connector 2, originating from offshore export cables from Federal/Massachusetts offshore boundary, northerly to Craigville Public Beach in Barnstable (Preferred Route), and onshore underground cables to a new substation in Barnstable and ultimately to an interconnection at Eversource’s existing 35-kV West Barnstable Substation, Barnstable, Massachusetts (EOEEA #16231). Vineyard Wind LLC, the Project Proponent provides the following information for the Project:
The Vineyard Wind Connector 2 includes two three-core offshore export cables connecting the offshore electrical service platform (ESP) located in the SWDA to the landfall site onshore. The two offshore export cables will transition to six single-core onshore export cables in transition vaults/joint bays at the landfall site, then continue underground within a buried concrete duct bank. The route for this duct bank will predominantly follow existing public roadway layouts to a proposed onshore substation. The substation will step up voltage to enable the interconnection with the electrical grid at the existing Eversource 345-kilovolt (kV) West Barnstable Substation.
Offshore elements of Vineyard Wind Connector 2 will largely utilize the OECC developed for the Vineyard Wind Connector 1, which will transit through state and federal waters. Within Massachusetts waters, the OECC will pass offshore through the towns of Edgartown, Nantucket, Barnstable, and possibly a corner of Mashpee before making landfall in Barnstable (see Figure 1-4 in Attachment B). The total length of the OECC from Park City Wind in the SWDA to the landfall site is approximately 63 miles (101 kilometers [km]), with
This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 MassDEP Website: www.mass.gov/dep Printed on Recycled Paper
EEA No. 16231 July 28, 2020 approximately 23 miles (37 km) of the OECC located within state waters. Onshore Project elements will be located entirely within the Town of Barnstable.
Bureau of Water Resources Comments
Wetlands and Waterways. The SERO Wetlands and Waterways Program has reviewed the Vineyard Wind LLC proposal to construct and maintain an approximately 800-megawatt offshore wind Project. The elements of the Project within state boundaries include a proposed onshore substation in the Town of Barnstable, onshore underground cables and approximately 23 miles of offshore export cables with a preferred landfall at Craigville Beach in the Town of Barnstable.
Wetlands Comments The proposed Vineyard Wind Connector 2 appears to be very similar to the Vineyard Wind 1 project that was recently approved by the MassDEP through Final Orders of Conditions. The Wetlands Program would request that the project proponent avoid any impacts to salt marsh and minimize impacts to the other wetland resource areas including riverfront area and barrier beach. The project proponent states in the ENF that the Project may result in temporary impacts to Coastal Dune. The Wetlands Protection Act Regulations at 310 CMR 10.28(3), state that any alteration of, or structure on, a coastal dune or within 100 feet of a coastal dune shall not have an adverse effect on the coastal dune by: (a) affecting the ability of waves to remove sand from the dune; (b) disturbing the vegetative cover so as to destabilize the dune; (c) causing any modification of the dune form that would increase the potential for storm or flood damage; (d) interfering with the landward or lateral movement of the dune; (e) causing removal of sand from the dune artificially; or (f) interfering with mapped or otherwise identified bird nesting habitat. The Wetlands Program requests that the project proponent clearly describe in the Notice of Intent filed for the activities, any impacts to coastal dunes and how those impacts will be mitigated or restored upon completion of construction. The Notice of Intent should also distinguish between impacts to degraded riverfront area and non-degraded riverfront area, if any, and how the project will meet the performance standards for those areas.
Waterways Comments Vineyard Wind LLC, the Company or Proponent, is currently in the process of permitting an 800- megawatt (MW) offshore wind Project (Vineyard Wind 2 in federal waters under the jurisdiction of the Bureau of Ocean Energy Management (BOEM). Within the Commonwealth’s boundaries include the offshore export cables in state waters (approximately 23 miles for each of two offshore export cables), all of the onshore cables, the proposed onshore substation, and the grid interconnection. The Vineyard Wind Connector 2 will connect Park City Wind to the New England bulk power grid and it is separate and independent from the Vineyard Wind Connector 1. A 401 WQC was issued on July 31, 2019 for the Vineyard Wind I Project. Vineyard Wind 2 is similar to Vineyard Wind 1 in its engineering design, permitting, and interconnection approach which include a wind turbine array, offshore electrical service platforms, offshore transmission to shore, onshore underground transmission, and an onshore substation that will step down transmission voltage for interconnection with the electrical grid.
Pursuant to 310 CMR 9.12(2)(e), if a facility generating electricity from wind power or an ancillary facility thereto which requires an EIR, the Department shall find such facility to be water-dependent if the EEA Secretary determines that the facility requires direct access to or location in tidal waters and cannot reasonably be located or operated away from tidal or inland waters, based on a comprehensive analysis of alternatives and other information analyzing measures that can be taken to avoid or minimize adverse impacts on the environment, in accordance with M.G.L. c. 30, §§61 through 62I. If an EIR is not submitted, the WRP shall presume the facility to be water-dependent.
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EEA No. 16231 July 28, 2020
On March 10, 2020, the Department issued Chapter 91 License No. 15011 approving Vineyard Wind Connector 1. The offshore components of Vineyard Wind Connector 2 are very similar to the prior Project as the export cables will be installed in the previously approved construction corridor with the exception that the preferred landfall will be at the Town-owned Craigville Beach in Barnstable. Portions of the construction corridor will be widened to accommodate the additional cables.
The proposed two (2) offshore export cables will require approximately 106,000 cubic yards of dredging within state waters in order to bury the cables approximately 5 to 8 feet below the sea floor. In addition to the Chapter 91 License required for the cables, a Chapter 91 Dredge Permit and 401 Water Quality Certification will be required to install the cables. The Proponent may choose to file a MassDEP BRP WW26 Combined Application for Chapter 91 and WQC.
The proposed onshore route will require that the cables cross over or under flowed tidelands of the Centerville River and is subject to Chapter 91 jurisdiction. Micro-tunnelling under the Centerville River is the preferred construction methodology to cross the river. Whether the cables cross over or under the river, this component of the Project shall be included in the Chapter 91 License Application. Plans accompanying the ENF show the approximation of the 1962 County Road Layout line over the Centerville River. In reviewing the Chapter 91 Application, the Proponent will be requested to provide a plan prepared by Registered Land Surveyor to ensure that no portion of the cable route is under private tidelands which is not owned or controlled by the Proponent.
It appears that the preferred onshore cable route or variant routes may pass over non-tidal streams that may be subject to Chapter 91 jurisdiction. However, assuming the cables will be embedded in the soil beneath the stream, they would be exempt from licensing pursuant to the Waterways Regulations at 310 CMR 9.05(3)(g). In the preparation of the EIR the Proponent is requested to identify any non-tidal rivers or streams that may be subject to Chapter 91 jurisdiction and confirm the construction methodology for these crossings.
The ENF does not adequately describe the construction methodology that will be utilized to make the cable connection approximately 1000’ offshore from Craigville Beach where the export cables will enter into the horizontal direction drill conduit. This component of the Project shall be addressed in greater detail in the EIR.
Stormwater Management Under the Stormwater Management section, the Proponent states: “The stormwater management design will meet or exceed the Massachusetts Stormwater Policy recommendations, and the Project will comply with MassDEP Stormwater Standards. The Project will also seek a National Pollutant Discharge Elimination System (NPDES) General Permit for construction activities from the U.S. Environmental Protection Agency (EPA)”. The ENF also states that the Draft Environmental Impact Report will present a stormwater management plan for the proposed substation site.
Dredging The ENF states that the submarine cable will be installed using either jetting, jet-plow or mechanical trenching, as well as proposed mitigation measures. For the installation of the two cables, total dredging could impact up to 4.6 acres (assuming two 10-inch-diameter offshore export cables installed along the 23-mile Offshore Export Cable Corridor) of Land Under Ocean (LUO) and dredge 106,000 cubic yards (81,000 cubic meters) sediment in state waters. The final proposed dredging volume and method should be provided as part of the MassDEP 401 WQC/Chapter 91 Dredging Permit applications. Pursuant to 314 CMR 9.07(2)(b)(5), for Projects over 10,000 cubic yards, the applicant
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EEA No. 16231 July 28, 2020 shall develop a Project-specific sampling and analysis plan (SAP) and this Plan shall be submitted in draft form to the Department for review and comment as part of the pre-application process. The final detailed SAP needs to be developed and approved by MassDEP prior to the submittal of a 401 WQC application. It is required in the 401 WQC permitting process to make sure that the Project meets the state water quality standards to avoid, minimize, and mitigate impacts to the biological communities and their habitats. Submittal of both raw data and secondary data is encouraged. A monitoring plan should also be provided to assess the impacts to water quality following the future removal or decommission of all installations.
Due to the scale of the dredging operation, sediment plums are expected to be created during operation. It is essential that the Proponent monitor the turbidity (and total suspended solids, if appropriate) both within the construction/dredging corridor and the immediate area beyond the work corridor. Dredging of the top portion of the sand wave may be necessary to allow the cable installation tool to reach the stable sediment layer under the base of the mobile sand unit/habitat. Dredging of sand waves will directly impact organisms within and adjacent to the dredge footprint. Although the impacts to water quality might be minor due to sediment dispersion and turbidity during cable-laying for a brief duration, the impact to the habitat is assumed to be minimal and of short duration because the disturbed bedform will evolve back to its original morphology over a relatively short time period as a result of prevailing tidal forces and associated sand migration. The Proponent should provide an estimated time period expected for the natural restoration of the ocean bottom morphology based on the best available information or professional experience. It is recommended that the Proponent adopt Best Management Practices (BMPs) to reduce turbidity as much as possible during construction phase. Pre-installation data such as grain size composition, substrate type, and bathymetric map along the installation route should be collected; monitoring of the sediment plume and water turbidity should be undertaken during cable installation; and changes in sediment composition and bathymetry mapping should be documented. After installation, a long-term monitoring report should be provided to document any changes to sediment profile in order to assess habitat recovery.
Horizontal Directional Drilling (HDD) The Project plans to install two approximately 660-foot-long conduits via HDD that will be used to bring the two offshore export cables onshore which will avoid hard bottom and co-located eelgrass near Spindle Rock. The proposed HDD site is at the Centerville River crossing. An HDD Contingency Plan on how to avoid and minimize impacts to water quality and natural resources in the Project area needs to be developed and approved by MassDEP.
Cable Installation The cables will be buried using a jet plow, jetting, or mechanical trenching, as suited for the bottom type in the immediate area. Dredging may be necessary in some areas, especially where large sand waves occur. The 401 WQC/Chapter91 permit application should provide more detailed information on why and how a cable installation tool can further minimize dredging and minimize the impact to benthic organisms and natural resources in the construction area.
Long-Term Natural Resource Monitoring The proposed Project area is an area with highly valuable ecological service and economical values provided by mammals, turtles, sea birds, fish, eelgrass beds, coastal wetlands, shellfish habitat (see Figure 1), calanus, shrimp, amphipods, crab, and sea stars. A large portion of the construction and operations such as dredging will have direct impact to the benthic resources due to the introduction of the wind turbine generators and electric service platforms. A systematic survey, such as the Before-After Control-Impact (BACI) design, prior to the start of construction activities should be conducted and consistent post-construction monitoring protocol should be used for assessing the
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EEA No. 16231 July 28, 2020 potential impact of the Project to these natural resources. The Proponent has committed to performing post-construction monitoring for examining the disturbance of and recovery of coastal and benthic habitats in the proposed action area. However, more detailed information such as monitoring frequency and sampling locations on recolonization and succession of benthic communities among different habitats is not clearly elucidated for a long-term monitoring plan. Given that so far there is no long-term study about the ecological changes of offshore wind farm (Slavik et al. 2017)1, the monitoring results from the Vineyard Wind 1 Project can be instrumental to offshore wind energy development in Massachusetts and beyond.
Long-term Invasive Species Monitoring The ENF does not describe whether or not the proposed Project may facilitate the establishment and spread of invasive species. Invasive species are considered to be one of the greatest threats to biodiversity resulting in severe ecological and economic damage. In coastal New England, invasive tunicates have become an emerging issue (Coalarusso 2018)2. New artificial structure creates hard substrate for invasive species colonization with the potential for impacts to commercial and recreational fishing operations. Warming ocean and coastal waters and species range expansions influenced by climate change will further compound these issues (Eberhardt et al. 2015)3. Therefore, a systematic monitoring plan for potential marine invasive species colonization needs to be developed prior to commencement of the Project. Corresponding appropriate management actions should also be adopted to control colonization of invasive species in these artificial habitats.
1 Slavik K. et al. 2017. The large scale impact of offshore wind farm structures on pelagic primary production in the southern North Sea. https://arxiv.org/abs/1709.02386. 2 Colarusso, P. 2018. Impacts of Invasive Tunicates on Eelgrass. Northeast Panel on Aquatic Nuisance Species Fall Meeting. Portsmouth NH. December 3 to 4, 2018 3 Eberhardt, A., J. Pederson and B. Bisson. 2015. Rapid Response Plan for Management and Control of the Chinese Mitten Crab - Northeast United States and Atlantic Canada. New Hampshire, MIT and Maine Sea Grant Programs.
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EEA No. 16231 July 28, 2020
Fig. 1 Benthic Shellfish Habitat: Coastal Martha’s Vineyard, Nantucket Island, and Cape Cod (from Northeastoceandata.org)
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EEA No. 16231 July 28, 2020
Required Baseline Data Needs Baseline data must be provided to MassDEP including, but not be limited to: Water Quality (e.g. turbidity and total suspended solid); Marine Habitat Survey; Eelgrass; Benthic Community; and Fisheries. Electronic data format such as Access or Excel is preferred and will be helpful in facilitating the 401 WQC review process.
Decommissioning The Proponent has stated that all off shore components of the Project will be removed at the end of the Project’s life. An alternatives analysis specific to the abandoning some components in place should be considered including the short-term impacts of removal and the longer-term impacts of material degradation on the marine environment.
Bureau of Waste Site Cleanup Comments
ENF #16231 – Based upon the information provided, the Bureau of Waste Site Cleanup (BWSC) searched its databases for disposal sites and release notifications that have occurred at or within the vicinity that might impact the proposed Project area. A disposal site is a location where there has been a release to the environment of oil and/or hazardous material that is regulated under M.G.L. c. 21E, and the Massachusetts Contingency Plan [MCP – 310 CMR 40.0000].
This Project involves the installation of a transmission line from Craigsville Beach (Barnstable) to a substation in West Barnstable. The proposed transmission line will be approximately five-miles long using buried concrete duct banks in existing roadways. There is one open MCP site located along the proposed route. Release Tracking Number 4-20277 is associated with a residential property release at 1071 Shootflying Hill Road, Barnstable. Further response actions are necessary at the site for closure under the MCP.
There are no other listed MCP disposal sites located at or in the vicinity of the Project that would appear to impact the proposed Project area. Interested parties may view a map showing the location of BWSC disposal sites using the MassGIS data viewer (Oliver) at: http://maps.massgis.state.ma.us/map_ol/oliver.php Under “Available Data Layers” select “Regulated Areas”, and then “DEP Tier Classified 21E Sites”. MCP reports and the compliance status of specific disposal sites may be viewed using the BWSC Waste Sites/Reportable Release Lookup at: https://eeaonline.eea.state.ma.us/portal#!/search/wastesite
The Project Proponent is advised that if oil and/or hazardous material are identified during the implementation of this Project, notification to MassDEP may be required pursuant to the Massachusetts Contingency Plan (310 CMR 40.0000). If OHM is encountered during the construction of this Project, addressing OHM encountered could likely be accomplished using the Utility-related Abatement Measures provisions at 310 CMR 40.0461 through 40.0469. A Licensed Site Professional (LSP) should be retained to determine if notification is required and, if need be, to render appropriate opinions and/or conduct response actions. The BWSC may be contacted for guidance if questions arise regarding cleanup
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EEA No. 16231 July 28, 2020
Bureau of Air and Waste Comments
Air Quality. Construction and operation activities shall not cause or contribute to a condition of air pollution due to dust, odor or noise. To determine the appropriate requirements please refer to: 310 CMR 7.09 Dust, Odor, Construction, and Demolition 310 CMR 7.10 Noise
The Proponent should determine if the new substation or the increase in equipment at the current substation will cause a significant increase in noise that will require mitigation.
Construction-Related Measures MassDEP requests that all non-road diesel equipment rated 50 horsepower or greater meet EPA’s Tier 4 emission limits, which are the most stringent emission standards currently available for off- road engines. If a piece of equipment is not available in the Tier 4 configuration, then the Proponent should use construction equipment that has been retrofitted with appropriate emissions reduction equipment. Emission reduction equipment includes EPA-verified, CARB-verified, or MassDEP- approved diesel oxidation catalysts (DOCs) or Diesel Particulate Filters (DPFs). The Proponent should maintain a list of the engines, their emission tiers, and, if applicable, the best available control technology installed on each piece of equipment on file for Departmental review.
Massachusetts Idling Regulation The ENF reports that the Project Proponent proposes to “require contractors to turn off construction vehicles when not actively in use.” MassDEP reminds the Proponent that unnecessary idling (i.e., in excess of five minutes), with limited exception, is not permitted during the construction and operations phase of the Project (Section 7.11 of 310 CMR 7.00). With regard to construction period activity, typical methods of reducing idling include driver training, periodic inspections by site supervisors, and posting signage.
Spills Prevention. A spills contingency plan addressing prevention and management of potential releases of oil and/or hazardous materials from pre- and post-construction activities should be presented to workers at the site and enforced. The Plan should include but not be limited to, refueling of machinery, storage of fuels, and potential on-site activity releases.
Solid Waste Management. As a result of its review of the Environmental Notification Form (“ENF”) for the Barnstable Vineyard Wind Connector 2 (“Project” or “site”), MassDEP’s Solid Waste Management Program is providing the following comments regarding the management of solid waste/ recyclable and asbestos materials generated from the Project pursuant to Massachusetts Solid Waste Regulations 310 CMR 16.00: Site Assignment Regulations For Solid Waste Facilities, 310 CMR 19.000: Solid Waste Management and 310 CMR 7.15: Asbestos Regulations.
The ENF indicates that demolition activities will be performed as part of the Project and will potentially generate solid waste and recyclable materials including but not limited to asphalt, brick, and concrete (ABC).
Waste materials that are determined to be solid waste (e.g., construction and demolition waste) and/or recyclable material (e.g., metal, asphalt, brick, and concrete) shall be disposed, recycled, and/or otherwise handled in accordance with the Solid Waste Regulations including 310 CMR 19.017: Waste Bans.
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EEA No. 16231 July 28, 2020 Asphalt, brick and concrete (ABC) rubble, such as the rubble generated by the demolition of buildings or other structures must be handled in accordance with the Solid Waste regulations. These regulations allow, and MassDEP encourages, the recycling/reuse of ABC rubble. The Proponent should refer to MassDEP's Information Sheet, entitled " Using or Processing Asphalt Pavement, Brick and Concrete Rubble, Updated February 27, 2017 ", that answers commonly asked questions about ABC rubble and identifies the provisions of the solid waste regulations that pertain to recycling/reusing ABC rubble. This policy can be found on-line at the MassDEP website: https://www.mass.gov/files/documents/2018/03/19/abc-rubble.pdf
For more information on how to prevent banned materials from entering the waste stream the Proponent should contact the RecyclingWorks in Massachusetts program at (888) 254-5525 or via email at [email protected]. RecyclingWorks in Massachusetts also provides a website that includes a searchable database of recycling service providers, available at http://www.recyclingworksma.com.
If you have any questions regarding the Solid Waste Management Program comments above, please contact Mark Dakers at (508) 946-2847.
Proposed s.61 Findings The “Certificate of the Secretary of Energy and Environmental Affairs on the Environmental Notification Form” may indicate that this Project requires further MEPA review and the preparation of an Environmental Impact Report (EIR). Pursuant to MEPA Regulations 301 CMR 11.12(5)(d), the Proponent will prepare Proposed Section 61 Findings to be included in the EIR in a separate chapter updating and summarizing proposed mitigation measures. In accordance with 301 CMR 11.07(6)(k), this chapter should also include separate updated draft Section 61 Findings for each State agency that will issue permits for the Project. The draft Section 61 Findings should contain clear commitments to implement mitigation measures, estimate the individual costs of each proposed measure, identify the parties responsible for implementation, and contain a schedule for implementation.
Other Comments/Guidance The MassDEP Southeast Regional Office appreciates the opportunity to comment on this ENF. If you have any questions regarding these comments, please contact George Zoto at (508) 946-2820.
Very truly yours,
Jonathan E. Hobill, Regional Engineer, Bureau of Water Resources JH/GZ
Cc: DEP/SERO
ATTN: Millie Garcia-Serrano, Regional Director David Johnston, Deputy Regional Director, BWR Gerard Martin, Deputy Regional Director, BWSC
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EEA No. 16231 July 28, 2020 Seth Pickering, Deputy Regional Director, BAW Jennifer Viveiros, Deputy Regional Director, ADMIN Dan Gilmore, Chief, Wetlands and Waterways, BWR David Hill, Wetlands and Waterways, BWR Alison Cochrane, Solid Waste, BAW Allen Hemberger, Site Management, BWSC
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The Commonwealth of Massachusetts Division of Marine Fisheries 251 Causeway Street, Suite 400, Boston, MA 02114 p: (617) 626-1520 | f: (617) 626-1509 www.mass.gov/marinefisheries
CHARLES D. BAKER KARYN E. POLITO KATHLEEN A. THEOHARIDES RONALD S. AMIDON DANIEL J. MCKIERNAN Governor Lt. Governor Secretary Commissioner Director
July 28, 2020
Secretary Kathleen Theoharides Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office Alex Strysky, EEA No. 16231 100 Cambridge Street, Suite 900 Boston, MA 02114
Dear Secretary Theoharides:
The Division of Marine Fisheries (MA DMF) has reviewed the Environmental Notification Form (ENF) by Vineyard Wind LLC for the Vineyard Wind Connector 2 project, which is part of the larger Park City Wind Project. The overall Park City Wind project includes an 800 MW wind turbine array (50-81 turbines) in the central section of BOEM Lease Area OCS A-0501, an offshore electrical service platform, 2 offshore export cables, and an onshore substation in Barnstable. A third phase of buildout, in the southern section of BOEM Lease Area OCS A-0501 is anticipated, and the third phase would use the same or similar offshore export cable corridor (OECC) with a different, currently unidentified, landfall location.
The Vineyard Wind Connector 2 project (VW2) represents the portion of the Park City Wind project that is within Massachusetts state waters (the OECC is 63 miles long with approximately 23 miles in Massachusetts) and includes only the OECC. VW2 will largely utilize the OECC developed for the Vineyard Wind Connector 1. The cable route would travel between Martha’s Vineyard and Nantucket through Muskeget Channel, then continue north through Nantucket Sound to landfall at Craigville Beach or Covell’s Beach in the Town of Barnstable. The proposed OECC would contain two 220-kV three-core alternating current (AC) cables. It would go through the town waters of Edgartown, Nantucket, Barnstable, and possibly Mashpee. The OECC would range in width between 3,100 and 5,100 feet across its range with an approximate average width of 3,800 feet.
One difference from the Vineyard Wind Connector 1 (VW1) is that the OECC has been widened by approximately 985 feet (300 meters [m]) to the west, and along a segment through the Muskeget Channel area it has also been widened by approximately 985 feet (300 m) to the east. Within the OECC, individual offshore export cables would be spaced approximately 330 feet away from the Vineyard Wind 1 cables, and 165 feet apart from each other. The target burial depth is 5 to 8 feet. Approximately 112 acres of seafloor is estimated to be impacted. In areas containing sand waves, dredging is anticipated to achieve adequate burial depth, resulting in estimated potential dredge volumes in state waters up to 106,000 cubic yards across a 25 acre area. An additional 18.4 acres and 12.7 acres of impact are anticipated from trenching and anchoring, respectively. For areas where burial is not feasible, hard structures may be used as cable protection in the form of rock, gabion rock bags, concrete mattresses, or half-shell pipes. Offshore cable installation is proposed using jetting, jet plow, plow, or mechanical trenching. Proposed dredging methods consist of trailing suction hopper dredge (TSHD) or jetting by controlled flow excavation. If TSHD is used, dredge material would be transported and deposited elsewhere within the surveyed area containing sand waves. Horizontal directional drilling (HDD) will be used for the approximate 1,000 to 1,200 foot section reaching the landfall site. A trenchless approach (microtunnel) is also proposed to traverse the Centerville River to avoid and minimize impacts to salt marsh at that river crossing.
Existing marine fisheries resources and potential project impacts are described in Attachment 1. The primary resources of concern in Nantucket Sound that are vulnerable to the adverse effects of cable laying and EMF include (but are not limited to) shellfish, longfin squid and squid eggs, knobbed and channeled whelk, and flatfish. Both commercial and recreational fisheries are active throughout the OECC area.
The ENF alludes to additional project information that will be included in the upcoming Draft Environmental Impact Report (DEIR) with an anticipated Fall 2020 submission timeline (Page 241). MA DMF offers the following comments on DEIR content referenced in the ENF for consideration in developing the DEIR:
MA DMF permits and affected activities • Through the “Nantucket Sound exception” included within the Magnuson Act, MA DMF exerts fisheries jurisdiction across all waters within Nantucket Sound [1]. A Letter of Authorization from MA DMF will be needed for any activities that could result in the collection of fishing gear in Nantucket Sound and Massachusetts state waters. A Scientific Permit from MA DMF will be needed for any activities that could result in the collection of marine plants or animals in Nantucket Sound and Massachusetts state waters. • The MA DMF bottom trawl survey operates throughout Nantucket Sound annually during spring and fall. Coordination with MA DMF is recommended to ensure lack of direct conflict with this survey during survey activities and cable installation. An up-to-date description of the Affected Environment
1 Page numbers reference the pdf document page numbers, not the printed document page numbers. • Dredging and cable trenching will likely impact existing marine resources that are sessile or with limited mobility (e.g., shellfish, whelks, squid eggs). These vulnerable species should receive particular attention in terms of documenting their distribution along the OECC as well as strategies for minimizing impacts to these resources. Many species trends have been affected due to warming waters, so characterization of these resources should be informed by up to date analyses of trawl survey data and interviews with fishermen. When anecdotal information is used, the source should be cited. • Provide a map that identifies the VW1 OECC and the changes associated with the VW2 corridor. Is the widening of the corridor for survey work and for cable laying, and does it extend the length of the corridor? • Through the Ocean Plan, the Commonwealth established a standard substrate map. We would like to see that the data produced by this effort be compatible with that substrate map, since it underlies the interpretation of hard/complex seafloor. The maps shown in the ENF are useful and illustrative, but it is more helpful to have the data in an online viewer and available for viewing in our own GIS systems. Toward that end, substrate analyses from project survey work should be produced in the same Excel spreadsheet as the Commonwealth’s substrate data and interpreted substrate units should be produced as an ArcGIS shapefile or geodatabase. All data should be provided digitally in formats compatible with ArcGIS to enable comparison with existing datasets. Acoustic mosaics should be provided as geotiffs at the maximum resolution possible. There should be at least four geotiffs provided: multibeam backscatter, sidescan sonar backscatter, multibeam bathymetry, and backscatter draped on bathymetry. The date of data collection should be easily discernable for all products. • The DEIR should also include detailed descriptions of the existing benthic habitat. Surveys of sediment type and benthic invertebrates should be conducted and included in the DEIR to weigh the alternatives; benthic shear stress and bathymetry are also important variables when describing benthic habitats. • The DEIR should use seafloor mapping methods that are up to date with interpretation methods being developed by NOAA and adaptable to CMECS. • The DEIR should include more recent eelgrass survey data for the nearshore waters adjacent to the potential landfall sites and meadows potentially impacted by turbidity. Eelgrass surveys should follow the guidance in DMF TR-43, “Technical Guidelines for the Delineation, Restoration, and Monitoring of Eelgrass in Massachusetts Coastal Waters” [2]. The ENF states that “no eelgrass will be impacted by this project” (Page 179) but there are areas of eelgrass in Nantucket Sound and close to Martha’s Vineyard that could be affected by turbidity. This potential should be addressed in the DEIR. • According to the ENF: “Marine surveys completed in 2017, 2018, and 2019 confirmed that portions of the OECC contain sand waves. Portions of the sand waves may be mobile over time; therefore, the upper portions of the sand waves may need to be removed via dredging so the cable-laying equipment can achieve the proper burial depth below the stable seabed to ensure cables stay buried” (Page 41). The proponent should describe the sand wave mobility using those marine surveys and should indicate how experience with VW1 will be utilized to modify the VW2 approach.
An expanded discussion of how scheduling, sequencing, and communication can be used to minimize impacts to fish and fisheries • Many potential impacts to marine resources and associated fisheries can be minimized by timing cable installation activities to avoid seasons of vulnerable life history phases and/or concentrated fishing effort along the OECC. The DEIR should describe planned timing of cable-laying activities with regards to co-occurring marine resources and stakeholders. The proponent’s experience with VW1 should be used to identify the communication mechanisms and stakeholder partners that will enhance coordination with fishermen. • Potential prohibition or relocation of fishing (fixed or mobile gear) for any length of time as a result of survey, installation, or repair procedures should also be described. The size, length, and potential economic impact of closures should be included in the description. • Centerville River has an alewife run and American eels. The microtunnel approach will not affect these resources, but the bridge superstructure replacement might. This should be taken into account in the DEIR. If turbidity-causing activities are planned in Centerville River, those activities should be identified and minimized through the use of a time of year restriction to limit work during the fish runs. Description of overall economic impact to fishing industries • The DEIR should present an analysis describing the potential economic impact on Massachusetts fishing industries associated with the Park City Wind Project and VW2. The analysis should include impacts on individual ports, as well. • Economic analyses should rely on the most up-to-date methods and datasets developed through the Mass CEC pilot studies projects and/or NOAA analyses. • Providing a range of potential impacts, including a no-fishing alternative, is needed. • A clear explanation of how the proponent is working toward mitigation agreements and how it is supporting regional impact monitoring is needed. An expanded discussion of cable covering • Anticipated areas requiring covering should be described in greater detail, both in terms of the spatial distribution and existing habitat characteristics. The DEIR should also describe the likelihood of concrete mattresses or rock material affecting fishing activities. • Information related to the habitat equivalency of rock placement, gabion rock bags, concrete mattresses, or half-shell pipes of cables should be provided and should cite relevant literature. The concrete mattresses are estimated to occupy less seafloor, but if the rock cover has a higher habitat value, it may be the preferred alternative despite occupying more seafloor
A detailed discussion of all installation methods proposed for offshore cables • MA DMF recommends that the proponent develop a comprehensive contingency plan in the DEIR outlining response protocols for a frac out event for the horizontal directional drilling (HDD) alternative for nearshore installation. Plans should include how frac outs will be avoided, as well as actual response and containment plans.
Presentation of monitoring plans • Many impacts are described as temporary, but monitoring is needed to confirm that they are (for example, impacts on salt marsh at Centerville River, eelgrass that gets impacted by turbidity from the project, and seafloor topography/bathymetry and sediment type). The DEIR should describe the monitoring plans. • Monitoring plans should be developed with input from the Agencies and should include annual reporting. • All monitoring plans should clearly identify the questions being addressed (i.e. the objectives of the monitoring plan). Electric and magnetic fields (EMF) and cable burial • Since cable burial will be relied upon to minimize adverse effects associated with EMF transmission, the EMF analysis should include a thorough description of how cable burial will be monitored on a regular basis to ensure the entire length of the cable will remain buried.
Cumulative impacts • Shared transmission and maximizing power coming in to landfall substations will lessen environmental impacts. The possibility of shared transmission was discussed on Page 24. The shared transmission is not preferred by the proponent due to the timing of the project (i.e. shared transmission will take longer to develop causing delays in delivering power). The proponent also described why a fully separate landfall at Craigville Beach is preferred over the Covell’s Beach VW1 substation (Page 75). The DEIR should describe in more detail what is being done to minimize additional offshore export cable laying and landfalls. For example, can one cable come to shore at Covell’s Beach and the other at Craigville, leaving more space at Craigville for future build out? Our understanding is that there are some legitimate limitations but we want to be sure that the substations and cable corridor are being used to the greatest advantage since that will limit future environmental disturbances. • Multiple cable laying activities over time increase seafloor impacts and impacts to fishing activities. The DEIR should include a proposed schedule that clarifies how this project’s timing compares to VW1. Questions regarding this review may be directed to John Logan or Kathryn Ford in our New Bedford office at [email protected] and [email protected].
Sincerely,
Daniel J. McKiernan Director
cc: Barnstable Conservation Commission Edgartown Conservation Commission Mashpee Conservation Commission Nantucket Conservation Commission Holly Carlson Johnston, Epsilon Associates, Inc. Amy Croteau, Barnstable Natural Resource Officer and Shellfish Constable Sue Tuxbury, Alison Verkade, NMFS Robert Boeri, CZM David Wong, DEP Ed Reiner, Tim Timmerman, EPA Bev Vucson, DFG Mike Pol, Eileen Feeney, Tracy Pugh, Steve Wilcox, Derek Perry, Erin Burke, Robert Glenn, Tom Shields, DMF
References
1. Bennett T. 2013 Navigating complex state and federal fisheries jurisdictions. Sea Grant Fellows Publications. Paper 65. http://docs.rwu.edu/law_ma_seagrant/65. 2. Evans NT, Leschen AS. 2010 Technical guidelines for the delineation, restoration, and monitoring of eelgrass (Zostera marina) in Massachusetts coastal waters. Massachusetts Division of Marine Fisheries Technical Report TR-43. http://www.mass.gov/eea/docs/dfg/dmf/publications/tr-43.pdf.
DM/JL/KF/sd
Attachment 1: Description of the Affected Environment, Nantucket Sound
The waters within Nantucket Sound and adjacent state waters along the proposed cable routes traverse habitat for a variety of finfish and invertebrate species (Figures 1 and 2). The Massachusetts Ocean Plan [1] identified several areas of important fish resources based on MA DMF trawl survey data (2015 Massachusetts Ocean Plan Figure 15). In particular, commercially and recreationally important species with high abundance in this region include channeled whelk (Busycotypus canaliculatus), knobbed whelk (Busycon carica), longfin squid (Doryteuthis pealeii), summer flounder (Paralichthys dentatus), scup (Stenotomus chrysops), and windowpane flounder (Scophthalmus aquosus) (Figures 1 and 2). Of these species, summer flounder, scup, and knobbed whelk are abundant throughout Nantucket Sound while channeled whelk, longfin squid, and windowpane flounder are in greater abundance further east along Nantucket Sound.
Figure 1. Abundance of select recreationally and commercially important fish and invertebrate species in Massachusetts spring bottom trawl surveys from 2000-2019. Tows for which the species of interest were absent are indicated by (+). Panels represent seasonal abundance of A) channeled whelk, B) knobbed whelk, C) longfin squid, D) summer flounder, E) scup, and F) windowpane flounder.
Figure 2. Abundance of select recreationally and commercially important fish and invertebrate species in Massachusetts fall bottom trawl surveys from 2000-2019. Tows for which the species of interest were absent are indicated by (+). Panels represent seasonal abundance of A) channeled whelk, B) knobbed whelk, C) longfin squid, D) summer flounder, E) scup, and F) windowpane flounder.
Of the species identified in trawl survey data, whelks and squid are particularly sensitive to benthic habitat disturbance due to limited mobility and deposition of demersal eggs, respectively. Recent stock assessments indicate that the whelk stock in Nantucket Sound is overfished and overfishing is still occurring. The biomass index based on the MA DMF trawl survey has declined by over 70% since the early 1980s. Longfin squid spawn in the spring in Nantucket and Vineyard Sounds and lay demersal egg clusters (i.e., mops) with peak activity in May [2-4; Fig. 3]
Figure 3. Biomass (kg per tow) of A) longfin squid and B) longfin squid demersal egg in Massachusetts spring bottom trawl surveys from 2000-2019. Tows for which the species of interest were absent are indicated by (+).
The cable route through Nantucket Sound also includes habitat for a variety of shellfish species. The offshore waters between Martha’s Vineyard and Nantucket are mapped surf clam (Spisula solidissima) habitat. The OECC also closely borders sea scallop (Argopecten irradians), quahog (Mercenaria mercenaria), and blue mussel (Mytilus edulis) habitat.
The various finfish and invertebrate resources along the cable corridors also support a variety of associated fisheries. The Massachusetts Ocean Plan [1] identified several areas of medium and high commercial fisheries activity and concentrated recreational fishing activity within the proposed cable route (2015 Massachusetts Ocean Plan Figures 16 and 28). Nantucket Sound waters within and adjacent to the proposed cable route are also classified as areas of high recreational boating density [5]. The commercial whelk fishery targets both channeled and knobbed whelk and is an important state-waters only fishery in Massachusetts that has expanded in recent years due to declines in southern New England lobster resources and increased whelk prices [6]. The channeled whelk fishery is of particular economic importance and annually ranks among the top fifteen in terms of ex-vessel value landings in Massachusetts. Based on dealer reports, nearly two million pounds of channeled whelk were landed in 2016 with an estimated value of $4.8 million USD. Most of these landings are derived from fisheries in Nantucket Sound (Figures 4 and 5). Blue mussel (Mytilus edulis) and kelp (Saccharina latissima) aquaculture operations are also present or in the process of being permitted for deployment within Horseshoe Shoals in close proximity to the proposed cable corridors.
2.5 Annual Trap Landings by SRA
2.0
1.5
Nantucket Sound (SRA 10) Vineyard Sound (SRA 13) 1.0
Buzzards Bay (SRA 14) Millions of PoundsofMillions Other SRAs
0.5
0.0 2000 2002 2004 2006 2008 2010 2012 2014 2016
Figure 4. MA channeled whelk landings 2000 – 2016 Source: MA Commercial Catch Reports [6].
Figure 5. Locations of yearly commercial sampling effort in the Massachusetts whelk fishery, MA DMF [6]. Nantucket Sound is also the epicenter of the horseshoe crab (Limulus polyphemus) fishery for the state of Massachusetts with > 80% of landings derived from this general region (Figure 6).
Figure 6. Landings data for the 2018 Massachusetts horseshoe crab fishery reported as percentages by region. The Nantucket Sound region accounted for 83% of state landings.
Waters within Nantucket Sound also provide habitat for a variety of whale and sea turtle species. An area of right whale (Eubalaena glacialis) core habitat is present south of Martha’s Vineyard in close proximity to the proposed cable corridor (2015 Massachusetts Ocean Plan Figure 24) while loggerhead (Caretta caretta) and leatherback (Dermochelys coriacea) sea turtles have been observed throughout Nantucket Sound [1,7].
Nearshore waters off the proposed Craigville Beach and Covell’s Beach landfall sites provide habitat for a variety of marine flora and fauna. The shoreline at both considered landfall sites is mapped as a horseshoe crab nesting beach. Horseshoe crabs deposit their eggs in the upper intertidal regions of sandy beaches from late spring to early summer during spring high tides [8]. Adult crabs congregate in deep waters such as channel areas and troughs during the day while waiting to move on to the beaches at night to spawn. Adults will also overwinter in these deeper water areas. Recent stock assessments conclude that horseshoe crab abundance in the New England region has improved from poor to neutral [9]. The waters offshore of the eastern and western ends of the landfall sites have been mapped previously by the Massachusetts Department of Environmental Protection (MA DEP) as eelgrass (Zostera marina) meadows (Fig. 7). Eelgrass beds provide one of the most productive habitats for numerous marine species [8] but have declined statewide in the past decade [10]. The waters offshore of the landfall sites are also mapped surf clam (Spisula solidissima) habitat.
Figure 7. Waters near the Craigville Beach and Covell’s Beach landfall sites previously (1995- 2015) mapped by the Massachusetts Department of Environmental Protection (MA DEP) as eelgrass (Zostera marina) meadows.
References 1. Brooks P, Callaghan T, Duff J, Ford K, Hunt C, Krauss S, et al. 2015 Massachusetts Ocean Plan. Volume 2. Baseline Assessment and Science Framework. https://www.mass.gov/service-details/massachusetts-ocean-management-plan. Accessed July 10, 2020. 2. Evans NT, Ford KH, Chase BC, Sheppard J. 2011 Recommended Time of Year Restrictions (TOYs) for Coastal Alteration Projects to Protect Marine Fisheries Resources in Massachusetts. Massachusetts Division of Marine Fisheries Technical Report, TR-47 https://www.mass.gov/service-details/marine-fisheries-technical-reports Accessed July 10, 2020. 3. McKiernan DJ, Pierce DE. 1995 Loligo squid fishery in Nantucket and Vineyard Sounds. Massachusetts Division of Marine Fisheries Publication No. 17648-75-200-1/95-3.47- C.R. 4. Schondelmeier BP, Hoffman WS. Characterization of the Massachusetts spring longfin squid fishery. Mass Div Mar Fish Rep May 21 2020. 2020. Available: https://www.mass.gov/doc/2020-longfin-squid-trawl-fishery-report/download 5. Northeast Ocean Data Portal. 2018 Northeast ocean data - maps and data for ocean planning in the northeastern United States. http://www.northeastoceandata.org/data- explorer/?recreation. Accessed July 10, 2020. 6. Nelson GA, Wilcox SH, Glenn R, Pugh TL. A stock assessment of channeled whelk (Busycotypus canaliculatus) in Nantucket Sound, Massachusetts. Massachusetts Division of Marine Fisheries Technical Report TR-66. 2018. 7. Dodge KL, Galuardi B, Miller TJ, Lutcavage ME. 2014 Leatherback turtle movements, dive behavior, and habitat characteristics in ecoregions of the Northwest Atlantic Ocean. PLoS ONE. 9: e91726. doi: 10.1371/journal.pone.0091726. 8. Barlow Jr. RB, Powers MK, Howard H, Kass L. 1986 Migration of Limulus for mating: relation to lunar phase, tide height, and sunlight. Biol Bull. 171: 310–329. 9. ASMFC Horseshoe Crab Stock Assessment Subcommittee. 2019 Horseshoe Crab Benchmark Stock Assessment and Peer Review Report. Atlantic States Marine Fisheries Commission 316 pp. http://www.asmfc.org/uploads/file/5cd5d6f1HSCAssessment_PeerReviewReport_May2019.pdf. Accessed July 10, 2020. 10. Costello CT, Kenworthy WJ. 2011 Twelve-year mapping and change analysis of eelgrass (Zostera marina) areal abundance in Massachusetts (USA) identifies statewide declines. Estuaries Coasts. 34: 232–242.
Vineyard Wind Connector 2 Comments Michael Duclos – 7/14/2020
Thank you for the opportunity to comment on the Vineyard Wind Connector 2.
I have been closely following the implementation of the Massachusetts Global Warming Solutions Act – GWSA, which has recently been amended to require a 90% GHG emissions reduction from 1990 levels by 2050.
At a high level, this plan is to replace nearly all fossil fuels used in the buildings and transportation sectors in Massachusetts by electricity, and provide huge quantities of ultra low CO2e electricity.
An Offshore Wind infrastructure that can provide the majority of the energy used in Mass. is absolutely indispensable to meeting the legally mandated Mass. GWSA GHG emissions reductions. There is simply no other politically and technologically feasible alternative.
As the Executive Summary of the 2019 UN Emissions Gap Report states: https://unepdtu.org/wp-content/uploads/2019/11/un-egr19-es-4e-extra.pdf
“However, since this did not happen, the required cuts in emissions are now 2.7 per cent per year from 2020 for the 2C goal, and 7.6 per cent per year on average for the 1.5C goal. Evidently, greater cuts will be required the longer action is delayed.” and
“Further delaying the reductions needed to meet the goals would imply future emissions reductions and removal of CO2 from the atmosphere at such a magnitude that it would result in a serious deviation from current available pathways. This, together with necessary adaptation actions, risks seriously damaging the global economy and undermining food security and biodiversity.”
So given Vineyard Wind - and other offshore wind projects to follow - are essential to address the existential threat of Climate Change, I support immediately approving this project.
The US has fallen far behind Europe, which has successfully deployed dozens of large scale Offshore Wind projects in the waters off Germany, Belgium, Denmark and the UK, with these impacts:
1. OSW in Europe has become a well understood, readily executed technology that is essential to mitigating climate change - and that expertise resides in Europe, which is why Vineyard Wind is importing this technology. I see this as a substantial strategic disadvantage to the energy security of the US, so we should immediately begin deploying, and learning from, large scale OSW in the US.
2. There is a large amount of real world performance data supporting the economy and efficacy of OSW, a proven technology about which we in the US have very little first hand experience, having only 5 operating OSW turbines in all of the US.
3. There are now well established processes for permitting large scale OSW in Europe, facilitating the rapid deployment of vast wind farms. We need to learn how to do this much more quickly in the US.
With the current COVID crisis and the potential impact to the construction of office space, and other employment, projects like Vineyard Wind can provide well paying jobs on our shores, and these projects could prove very helpful to the US recovery from the COVID crisis. A US OSW industry has the potential for many tens of thousands of well paying jobs, and tens of billions of dollars in beneficial economic impact over the next decade - so we need all these OSW benefits to begin to ramp up in the US immediately.
The displacement of fossil fuels from buildings (electrification) is part of the Mass. GWSA plan, and would avoid catastrophes like the Merrimack Valley gas explosions: https://en.wikipedia.org/wiki/Merrimack_Valley_gas_explosions as well as long term and enduring health impacts to children: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5800116/
Fossil Fuel combustion is an important source of PM 2.5 particulate matter which has substantial health impacts: https://www.epa.gov/pm-pollution/health-and-environmental-effects- particulate-matter-pm
The true cost of using large quantities of fossil fuels are not always obvious - but exist at an enormous scale: https://www.ucsusa.org/resources/hidden- costs-fossil-fuels
In May 2020, a new record high of atmospheric CO2 was reached, in spite of the suppression of economic activity due to COVID: https://www.esrl.noaa.gov/gmd/ccgg/trends/
For these, and a variety of other reasons, I urge you to promptly approve the Vineyard Wind Connector 2, and move the US on a path to leadership in the OSW industry. Each day we burn more fracked natural gas to generate electricity increases global warming impact that will remain for many decades.
Thank you very much for the opportunity to provide comments, and don’t hesitate to contact me if there are any questions.
Best Regards,
Michael Duclos
From: William Lake To: Strysky, Alexander (EEA) Subject: Support for Vineyard Wind Connector 2 Date: Friday, July 10, 2020 3:54:38 PM
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe. Dear Mr. Strysky:
Re: Support for Vineyard Wind Connector 2
I am writing to express my strong support for state approval of Vineyard Wind Connector 2, which will enable delivery onto the mainland of 800 MW of electricity to be generated by Vineyard Wind’s Park City Wind project.
This connector, and the wind farm it will serve, will be a significant part of the transition of New England’s energy supply from fossil fuels to a clean, renewable source – the wind that is plentiful on the northeast seacoast. Offshore wind projects in the region will deliver zero-carbon renewable energy and reduce carbon dioxide emissions. These benefits will greatly aid the Commonwealth’s efforts to decarbonize its energy supply and serve the urgent goal of mitigating global warming.
Over the last two years, East Coast states including Massachusetts have announced offshore wind energy procurement plans equivalent to $85 billion worth of investment and economic development opportunity. Offshore wind projects provide economic benefits for communities, states, and the region. These benefits include job creation throughout the lifetime of each project as well as leveraging economies of scale in the supply chain. Together, these plans will set up the region to be a leader in this emerging industry. The states in the region have the opportunity to collaborate to make this happen to their mutual benefit.
Offshore wind is the only available large-scale clean energy source in the region. Other parts of the country may have other resources – hydro power, geothermal, onshore wind, or whatever. But for our part of the country, offshore wind is it. If we are to convert to clean energy in order to do our part to combat climate change, we must do it largely with offshore wind
I congratulate you for undertaking the MEPA process and recommend that the necessary permit be approved as promptly as possible.
Thank you for your service to the environment and for considering this submission.
Sincerely,
William T. Lake
Aquinnah, MA
July 27, 2020
Kathleen A. Theoharides, Secretary Executive Office of Energy and Environmental Affairs Attention: MEPA Office Alex Strysky, EEA No. 16231 100 Cambridge Street Boston, Massachusetts 02114
Project Name: Vineyard Wind Connector 2 Proponent: Vineyard Wind LLC Location: Offshore export cables (from a proposed wind generation facility within Federal waters) through Massachusetts waters northerly through Nantucket Sound to Craigville Beach, Barnstable (Preferred Route). Alternate onshore routes from Craigville Beach and alternate landfall site at Covell’s Beach, Barnstable. Project Description: Utility- Transmission Cables Document Reviewed: Environmental Notification Form EEA File Number: 16231 NHESP Tracking No.: 17-37398
Dear Secretary Theoharides,
The Natural Heritage & Endangered Species Program of the Massachusetts Division of Fisheries & Wildlife (the Division) has reviewed the Environmental Notification Form (ENF) for the proposed Vineyard Wind Connector 2 and would like to offer the following comments.
The proposed offshore and onshore components of the project will occur within areas of Priority Habitat and Estimated Habitat for state-listed species. The Preferred Route offshore will occur within key migratory and foraging habitat for the state-listed terns listed below; portions of the Preferred Route onshore will occur within the nesting habitat of the Piping Plover.
Scientific Name Common Name Taxonomic Group State Status Sterna dougallii Roseate Tern Bird Endangered* Sterna hirundo Common Tern Bird Special Concern Sternula antillarum Least Tern Bird Special Concern Charadrius melodus Piping Plover Bird Threatened* *Species also protected pursuant to the U.S. Endangered Species Act (ESA, 50 CFR 17.11).
These species and their habitats are protected pursuant to the Massachusetts Endangered Species Act (M.G.L c. 131A) and its implementing regulations (MESA, 321 CMR 10.00) as well as the rare wildlife provisions of the Massachusetts Wetlands Protection Act and its implementing regulations (WPA, 310 CMR 10.37, 10.58(4)(b) and 10.59). This project will require a direct filing with the Division for compliance with the MESA and the WPA.
Renewable energy sources, such as offshore wind power, would reduce the reliance upon fossil fuels, provide zero-emissions energy generation, and are necessary to achieve the Commonwealth’s renewable energy requirements. Wind energy generation can have unintended impacts, particularly upon avian species. Thus, the wind energy planning, review and permitting processes must thoroughly and comprehensively assess impacts and risks to imperiled birds – this is particularly critical for imperiled bird populations with existing stressors, including, small population sizes, low reproduction or recruitment rates, and compounding factors related to climate change.
Background Massachusetts is a globally significant nesting, feeding, staging and overwintering area for numerous migratory birds, from common waterfowl to ESA-and MESA-listed bird species. A large proportion of the North American Roseate Tern (ESA- & MESA-Endangered) population and Atlantic Coast Piping Plover population (ESA- & MESA-Threatened) are reliant upon Massachusetts for reproduction. As such, Massachusetts’s responsibility for state- and federally-listed coastal waterbirds is disproportionately high. To that end, the Division has expended considerable funds and resources to protect and manage these birds, as well as restore nesting habitat.
As a result of management efforts occurring since the 1980s, Massachusetts supports over 740 pairs of Piping Plover (almost 40% of the Atlantic Coast breeding population). The Commonwealth also supports approximately 50% (about 2,200 pairs) of the North American Roseate Tern population on three islands actively managed by the Division since the 1990s (previously managed by other organizations since the 1960s). In addition, the Division manages significant nesting colonies of Common and Least terns.
ESA- and MESA-listed terns forage in the waters surrounding Massachusetts during the nesting, staging, and migratory seasons. The post-breeding tern aggregation (“staging”) beaches of Cape Cod, Martha’s Vineyard, and Nantucket are used during July – September. These sites are regionally and continentally important migratory preparation areas where adults care for fledged young until they become proficient at feeding themselves and birds put on body mass for their over-sea journey to wintering areas in South America. These staging areas appear to support a majority if not all the North American Roseate Tern population (Jedrey et al. 2010).
Onshore Components The Preferred Alternative for onshore components, including, cable route, new substation site and West Barnstable Substation improvements, excepting the proposed cable landfall location, mostly avoid areas identified as Priority and Estimated Habitat for state-listed species. The proposed cable landfall is located at Barnstable’s Craigville Beach which provides important nesting, habitat for the Piping Plover. Additionally, the beaches within larger Centerville Harbor provide nesting, feeding and staging habitat for state-listed terns species.
The Direct Pipe method for the Centerville River Crossing, Figures 1-17a through 1-17c, identifies significant construction staging and temporary impacts at Craigville Beach. For this method of installation, the Proponent should present an analysis of alternative construction staging locations and/or other methods to minimize or avoid impacts to the coastal beach and state-listed species nesting habitat. Additionally, the Proponent should provide clear accounting for all temporary and permanent coastal beach impacts for all proposed methods of cable installation.
The ENF presents Covell’s Beach, landing location for Vineyard Wind Connector 1, as an alternative cable landing location for Vineyard Wind Connector 2. The proposed offshore transmission route is presented as “...largely the same corridor utilized for the Vineyard Wind Connector 1.” The Division requests that the Proponent supplement the materials provided in the ENF with an analysis of alternatives that minimize the expanded development footprint by co-locating project components that occur within state-listed species habitats, to the extent feasible. Additionally, the Proponent should clarify anticipated construction timelines relative to the proposed projects, Vineyard Wind Connector 1 and Vineyard Wind Connector 2, to further inform the Division’s review.
The Proponent developed a draft Piping Plover Protection Plan, included as Attachment F to the ENF. Without additional details regarding project siting, methods of installation, construction timelines, and temporary impacts, etc., the Division cannot to assess whether the draft Piping Plover Protection Plan is adequate and sufficient to avoid both temporary and permanent impacts to state-listed species and their habitats.
Offshore Components Based on the information provided within the ENF, the offshore cable installation process is anticipated to impact 4.9 million square feet (112 acres) of wetlands in state waters. This does not include the cable installation, inter-array cables, foundations, wind turbine generators (WTG’s) and other components of the Park City Wind (800 MW) project within federal waters. The Division acknowledges that these components are within federal waters and will provide comments through the Bureau of Ocean Energy Management‘s (BOEM) National Environmental Policy Act (NEPA) process, when available. However, given the Division’s responsibility of managing and protecting ESA- & MESA-listed avian species and the importance of Massachusetts both nationally and continentally, the Division would like to offer the following comments relative to offshore components.
Acknowledged in BOEM’s Supplemental Draft Environmental Impact Statement (SDEIS) for Vineyard Wind 1, the construction and operation of wind turbine generators is expected to result in direct mortality of Common Tern, a MESA-listed avian species. Thus, cumulative impacts to MESA-listed species associated with Vineyard Wind 2 (aka Park City Wind) can also reasonably be expected.
As previously identified, a large proportion of the North American Roseate Tern population is reliant upon Massachusetts for nesting (primarily, on Bird, Ram & Penikese Islands managed by the Division). Massachusetts breeding Roseate Terns and those that breed in New York (Great Gull Island) convene in Massachusetts waters during the staging period (July - September) prior to migrating south. Thus, in addition to Common Terns, and because a large proportion of the population of this imperiled avian species is likely to forage within and travel through the Vineyard Wind Lease Area, wind turbines are anticipated to result in direct mortality to Roseate Terns along with other avian species (e.g. Least Tern and Piping Plover).
Therefore, the Proponent should consult with the Division to develop and integrate suitable conservation measures to mitigate unavoidable project impacts to affected imperiled avian species associated with Vineyard Wind 1, and now also Park City Wind. Conservation measures may include, but are not limited to, support for ongoing tern colony and plover monitoring and management and the restoration and enhancement of critical nesting habitats. These actions would provide meaningful and measurable benefits to the Roseate Tern and because terns typically nest in mixed species colonies, would also benefit other avian species.
The Division notes, as part of the Secretary’s February 1, 2019 Certificate on the MEPA FEIR for Vineyard Wind Connector 1, it was requested that the Proponent develop a comprehensive post-construction monitoring and adaptive management plan for avian species and support conservation measures that provide meaningful and measurable benefit to these species. To date, the Proponent has not provided such a plan or consulted with the Division regarding mitigative measures, as identified in both the NEPA and MEPA review processes.
Conclusion The Proponent should evaluate all alternatives to reduce or minimize impacts to avian species, for both onshore and offshore project components; this is particularly important relative to cumulative impacts from Vineyard Wind Connector 1, Vineyard Wind Connector 2 and their associated offshore components (Vineyard Wind 1 & Park City Wind), and potential future development within the Proponent’s current offshore Lease Area (OCS-A 0501), as well as their second offshore Lease Area (OCS-A 0522).
Given the Division’s responsibility to protect and manage imperiled avian resources, every effort should be made to avoid and minimize risks, as well as monitor and mitigate unavoidable Project impacts to the Commonwealth’s wildlife resources. Through such efforts, we can ensure that the Vineyard Wind projects not only contribute to meeting critical renewable energy needs, but also help to ensure healthy populations of coastal waterbirds, including vulnerable MESA and ESA-listed species, for the benefit of our citizens.
The Division will not render a final decision until the MEPA review process and associated public and agency comment period is completed, and until all required MESA filing materials are submitted by the Proponent to the Division. As our MESA review is not complete, no alteration to the soil, surface, or vegetation and no work associated with the proposed project shall occur until the Division has made a final determination.
If you have any questions about this letter, please contact Amy Hoenig, Endangered Species Review Biologist, at (508) 389-6364 or [email protected]. We appreciate the opportunity to comment on this project.
Sincerely,
Everose Schlüter, Ph.D. Assistant Director
cc: Vineyard Wind LLC Holly Carlson Johnston, Epsilon Associates, Inc. Barnstable Board of Selectmen
Barnstable Conservation Commission Barnstable Planning Department DEP Southeast Regional Office, MEPA Lisa Engler, CZM Bob Boeri, CZM
References
Jedrey, E. L., R. J. Harris, and E. A. Ray. 2010. Roseate Terns— citizens of the world: the Canada to Cape Cod connection. Bird Observer 38:146-150.
From: Tom Soldini To: Strysky, Alexander (EEA) Subject: Vineyard Wind Connector 2 Date: Tuesday, July 14, 2020 11:29:27 AM
CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe. Alex Strysky Environmental Analyst Massachusetts Environmental Policy Act Office
I am writing to voice my enthusiastic support for the Vineyard Wind Connector 2 project, and the Park City Wind project which the connector will facilitate.
These projects are an important part of the regional development of offshore wind, which is crucial to the Commonwealth’s (and the region’s) plan to fight climate change by de- carbonizing the New England electric grid. These projects alone will generate clean, renewable, cost-competitive energy for over 400,000 homes and businesses. They will reduce carbon dioxide emissions by more than 1.6 million tons per year. To put that in more practical terms, that is the equivalent of eliminating the emissions from 325,000 cars. In addition, according to an independent analysis by Leidos Engineering LLC, this project will save ISO- NE $2.28 billion over its 30-year lifespan.
We cannot make significant progress toward eliminating CO2 emissions without a massive increase in the available of renewable, inexpensive electricity. For the Northeast United States Offshore wind is, by far, the most practical way to accomplish that.
Beyond fighting climate change, the creation of the offshore wind industry in the United States will bring an important new economic opportunity at a time when it is urgently needed. The offshore wind projects announced by East Coast states represent an estimated $85 billion investment. Studies suggest that the offshore wind industry will create more than 80,000 jobs in the next ten years. The United States is already far behind European nations and companies in developing expertise in this growing industry. This investment will allow us to seed the formation of an industry with enough critical mass to become competitive in the coming years.
The economic benefits to local governments will also be realized through increases in tax revenue, allowing towns to pursue new projects benefiting their communities. One example of this effect is visible in Barnstable, where Vineyard Wind signed a Host Community Agreement which includes guaranteed yearly payments to the town. These annual payments combined with increases to property tax revenue will total $32 million over 25 years. The town of Barnstable has dedicated these funds towards water protection and new water wells in the town, clearly demonstrating the public good that comes from well-planned stakeholder engagement in offshore wind development.
I strongly urge you to act promptly, and decisively to approve Vineyard Wind Connector 2 and allow progress to move forward on this critical industry.
Sincerely, Tom Soldini Edgartown, Massachusetts