STATE OF CONNECTICUT CONNECTICUT SITING COUNCIL

PETITION OF DOOSAN FUEL CELL, : PETITION NO. AMERICA, INC. FOR A DECLARATORY : RULING FOR THE LOCATION AND : CONSTRUCTION OF A 9.66 MEGAWATT : FUEL CELL GRID-SIDE DISTRIBUTED : ENERGY RESOURCE AT 600 IRANISTAN AVE., BRIDGEPORT, CONNECTICUT

PETITION OF DOOSAN FUEL CELL AMERICA, INC. AS AN AGENT FOR A DECLARATORY RULING

Pursuant to Conn. Gen. Stat. §§ 4-176 and 16-50k(a) and Conn. Agencies Regs. § 16-50j-38 et seq., Doosan Fuel Cell America, Inc. (“Doosan”), as an agent for and behalf of its Customer,

NuPower Bridgeport FC, LLC (“NuPower”), requests that the Connecticut Siting Council

(“Council”) approve by declaratory ruling the location and construction of a grid-side distributed resources project comprised of twenty one (21) new natural-gas fueled PureCell® Model 400 phosphoric acid fuel cells (“Fuel Cell”) and associated equipment (the “Facility”), providing

9.66-megawatts (“MW”) of power to the United Illuminating, Congress St. Substation,

Bridgeport, CT. The Facility will be installed by Doosan and owned and operated by NuPower.

The fuel cells will be maintained by Doosan.

Conn. Gen. Stat. § 16-50k(a) provides that:

Notwithstanding the provisions of this chapter or title 16a, the council shall, in the exercise of its jurisdiction over the siting of generating facilities, approve by declaratory ruling . . . (B) the construction or location of any fuel cell, unless the council finds a substantial adverse environmental effect or of any customer-side distributed resources project or facility . . . with a capacity of not more than sixty-five megawatts, as long as such project meets air and water quality standards of the Department of Energy and Environmental Projection.”

NuPower Thermal Bridgeport -1- Fuel Cell Petition I. INTRODUCTION

The proposed Facility will be a grid-side distributed resource under 65 MW that complies with the air and water quality standards of the Department of Energy and Environmental

Protection (“DEEP”). Doosan submits that no Certificate of Environmental Compatibility and

Public Need is required because the proposed installation will not have a substantial adverse environmental effect.

II. DESCRIPTION AND PURPOSE OF THE PROJECT

The proposed facility will be a distributed generation resource with grid interconnection at the Congress St. Substation owned and operated by United Illuminating. The Facility at 600

Iranistan Ave. will consist of a 3 ½ story steel and concrete structure located directly adjacent to

I-95 South bound on a vacant lot at the intersection of Iranistan Ave. and Railroad Ave

(Attachment #1). The proposed installation consists of twenty one (21) 460KW Model 400 Fuel

Cells manufactured by Doosan Fuel Cell America, Inc. in South Windsor, Connecticut (See

Attachment #4 for Model 400 Data Sheets). The overall dimension of the individual Fuel Cells is eight feet four inches wide by twenty-seven feet four inches long by nine feet eleven inches tall. The Fuel Cells are totally enclosed and factory-assembled and tested prior to shipment.

The proposed Facility will feed power through two separate dedicated power cable runs to the United Illuminating, Congress St. Substation at medium voltage. Power produced by the facility will be sold to United Illuminating Co. in accordance with a PURA approved power- purchase agreement (PPA) between United Illuminating and NuPower Bridgeport FC, LLC

Nupower Thermal Bridgeport -2- Fuel Cell Petition (Attachment #3). The completed facility will be capable of producing 9.66 MW of reliable power and up to 16.2 MMBtu/hr. of thermal energy to a district heating loop using a combination of high-grade and low-grade heat from the fuel cell. Natural gas supply for the facility will be provided by Southern Connecticut Gas.

When a utility grid outage occurs, the individual Fuel Cells will automatically disconnect from the facility electrical system using an internal breaker while continuing to operate providing all the internal loads needed to operate the Fuel Cells. Upon return of the utility supply, the fuel cells will monitor the grid for stability for five minutes and then will automatically reconnect and ramp up output.

The Fuel Cells are designed to have a minimum 20-year product life. This requires overhaul or replacement of major components after 10 years of operation. Components requiring overhaul include the cell stack assemblies and components in the fuel processing system.

III. SAFETY

The Fuel Cells are certified by CSA international to meet strict ANSI/CSA FC-1 2014 safety standards to protect against risks from electrical, mechanical, chemical, and combustion safety hazards. The Fuel Cells will be installed in strict accordance with NFPA 853. In accordance with Public Act 11-101, the fuel line pipe cleaning procedure uses inert nitrogen gas or atmospheric air. The following items are a few of the safety measures incorporated into the design. A draft emergency response plan is included in Attachment #5. Prior to operation of the facility, this plan will be reviewed with the City of Bridgeport Fire Marshall to determine any additional requirements they may have for an emergency response plan and safety training.

Nupower Thermal Bridgeport -3- Fuel Cell Petition A. Fire Protection

The Fuel Cell design incorporates a combustible gas sensor and thermal fuses located throughout the Fuel Cell cabinet. The detection of a potential combustible gas mixture, a fire, or the failure of this detection circuit will result in a Fuel Cell shutdown, closing of the natural gas supply valves, and a subsequent inert gas (nitrogen) purge of the Fuel Cell stack and fuel processing system. This event will also result in an alarm callout notification to Doosan service personnel. The Fuel Cell is designed with an integral stop button on the outside of the enclosure to enable immediate shutdown in the event of an emergency. There is also a site-installed manual gas shut-off valve and electrical disconnect switch easily accessible to emergency personnel.

First responders will have access to the site with the use of a Knox Security box positioned outside the gate directly adjacent to the natural gas shut off.

B. Gas Leak

The Fuel Cells are designed with a physical barrier that separates the equipment handling combustible gases (fuel compartment) from electrical or potential spark-creating equipment

(motor compartment). The fuel compartment is maintained at a negative pressure relative to both ambient and the motor compartment to ensure that any gas leaks do not reach the electrical equipment in the motor compartment. The cabinet ventilation system (“CVS”) is designed to dilute a potential gas leak in the fuel compartment to non-combustible levels.

Nupower Thermal Bridgeport -4- Fuel Cell Petition C. Cell Stacks and Hydrogen

The Fuel Cells operate by converting hydrogen to DC electricity. Hydrogen is lighter than air and thus does not pool like other fuels and will readily dissipate with proper ventilation, making it less likely to ignite. Also, the Fuel Cell does not store hydrogen; instead, it produces hydrogen-rich gas at a rate equal to what it requires to produce power. The Fuel Cell stack is wrapped in a fire-retardant blanket. There are no materials inside the unit that would sustain a flame. There is no large volume of gas or any ignition that occurs within the cell stack.

D. Phosphoric Acid

Phosphoric acid is an integral part of the fuel cell system, acting as the electrolyte within the fuel cell stack. Phosphoric acid is a surprisingly common substance that is contained in common cola drinks. A leak of phosphoric acid is not possible because there is no reservoir of liquid: phosphoric acid is constrained within the porous structure of the fuel cell stack material by capillary action.

E. Fluid Leak

The only fluid source is water. All piping systems and pressurized water vessels are designed and fabricated to the appropriate ASME codes. Water produced through the electrochemical process is “pure” water and is reclaimed and reused by the process. Water mixed with propylene glycol and a rust inhibitor (to prevent rust and freezing in colder climates) is also used in the external cooling module.

Nupower Thermal Bridgeport -5- Fuel Cell Petition IV. HAZARDOUS MATERIALS

As with other fuel cell technologies, hydrogen and oxygen combine in the presence of a catalyst, which causes an electrochemical reaction to produce an electric current. A phosphoric acid fuel cell uses an inorganic, concentrated phosphoric acid as the electrolyte, allowing the electrochemical reaction to take place. The Fuel Cell also employs on-board natural gas reforming as part of the balance of plant to provide hydrogen to the fuel cell. Within this Fuel

Cell, there are only two components that contain hazardous material: the Cell Stack Assembly

(“CSA”) and the Integrated Low-Temperature Shift Converter (“ILS”). Neither of these components present risk when servicing the Fuel Cell. The material in both the CSA and the ILS is classified as hazardous material for the purposes of shipping. The CSA is classified as a “bulk bin,” made from the repeating elements of the Fuel Cell stack. Some of these repeating elements are porous carbon graphite plates. The phosphoric acid used as the electrolyte is contained by capillary action within the pores of these plates. The ILS is a tank containing a self-heating solid catalyst composed of copper, zinc oxide, and alumina. Safety Data Sheets (“SDS”) are available in the NuPower Thermal Bridgeport, Draft Emergency Response Plan (See Attachment #5).

A. Shipping of Hazardous Material

The Fuel Cell is classified as “hazardous in transportation” under the U.S. Department of

Transportation (“DOT”) 49CFR regulations, and likewise as dangerous goods under the

International Maritime Dangerous Goods (“IMDG”) regulations. The description of hazardous materials contained within each Fuel Cell are listed in subsections B and C below.

Nupower Thermal Bridgeport -6- Fuel Cell Petition B. Integrated Low Shift Converter

The tank, a non-DOT specification container as described below, is a SELF HEATING

SOLID INORGANIC N.O.S. (contains metallic copper on zinc oxide and alumina), CLASS 4.2,

UN3190, PGII, 900 lb. net wt of hazardous material.

C. Cell Stack Assembly

The bulk bin, a non-DOT specification container as described below, is a SOLIDS

CONTAINING CORROSIVE LIQUID N.O.S. (contains phosphoric acid), Class 8, UN3244,

PGII, 1200 lb. net of hazardous material. The amount of phosphoric acid in the Fuel Cell complies with all applicable state and federal regulations. The exact amount of phosphoric acid is proprietary technical information and is less than the 5,000 lbs. reportable quantity under 40 CFR 117.3.

D. Integration into Fuel Cell Power Plant

The above items are individual components assembled side by side, with other non- hazardous components, to form one complete Fuel Cell. The containers holding the hazardous material are non-DOT specification containers. DOT regulations allow for the transportation of the hazardous material noted above in non-DOT specification portable tanks and closed bulk bins, as used for the shipment of the Fuel Cell. IMDG regulations require United Nations (“UN”) specified containers or an exemption for international ocean transport.

E. Servicing of Product with Hazardous Material Present

The hazardous material contained within the CSA and the ILS presents no danger to installation and service personnel because direct exposure to the material is not possible. Under

Nupower Thermal Bridgeport -7- Fuel Cell Petition normal operating conditions, each container, as defined above, will contain its hazardous material for the life of the component. When end of life requires replacement of either component, no special precautions need to be employed with respect to handling because hazardous material will not come in contact with service personnel.

F. Hazardous Waste

The Fuel Cell does not produce any hazardous waste.

V. THE SITE

The Facility is proposed to be located entirely on the Site. The proposed site location is a

0.51 acre parcel zoned Light Industrial under the zoning regulations of the City of Bridgeport

(the “City”) (Zoning Map Attachment #8). The Site is surrounded to the North by Railroad Ave. and the Metro North rail line, to the West by Iranistan Ave. and to the South by I-95 (Attachment

#7). The nearest residential properties are approximately 136 feet North of the Site across

Railroad Ave, Metro North Railway and Railroad Ave North.

The proposed installation consists of twenty one (21) 460KW Model 400 Fuel Cells manufactured by Doosan Fuel Cell America, Inc. in South Windsor, Connecticut (See

Attachment #4 for Model 400 Data Sheet). The overall dimension of the individual Fuel Cells is eight feet four inches wide by twenty-seven feet four inches long by nine feet eleven inches tall.

The Fuel Cells are totally enclosed and factory-assembled and tested prior to shipment.

The fuel cells and their associated cooling modules will be installed on a 3 ½ story steel and concrete structure (Attachment #6). The proposed installation will have four (4) 2500 kVA

Nupower Thermal Bridgeport -8- Fuel Cell Petition and one (1) 1500 kVA, 13.8kV/480V transformers, low voltage and medium voltage switchgear, and associated metering equipment. A reverse osmosis (RO) system will provide treated water to the fuel cell power modules. A centralized purge system will be installed, including compressed gas storage tank and associated piping. The proposed facility will be surrounded by an 8’ chain-link fence and access to the site will be restricted. The proposed Facility will be a maximum of 65 feet above ground level and does not fall under the FAA notification requirement of 14 CFR Part 77.9 (Attachment #9).

VI. PROJECT BENEFITS

Fuel cell technology represents an important step in advancing Connecticut’s goal of diversifying its energy supply through the use of renewable energy, as expressed in Connecticut

General Statutes Section 16-244 et seq. The Facility will serve as a cost-effective clean energy source as well as provide thermal energy. Further, this Fuel Cell installation will support the efforts of the State of Connecticut to be a leader in the utilization of fuel cell technology. The facility will bring benefits to the customers of the thermal loop, economic development opportunities to the City of Bridgeport, and environmental benefits to the entire state.

Because a fuel cell does not burn fuel, the system will significantly reduce air emissions associated with acid rain and smog. Emissions standards of Connecticut will further be discussed in the next section. The Facility is designed to operate in total water balance – no make-up water is normally required after start-up and no water discharges to the environment will occur under normal operating circumstances.

Nupower Thermal Bridgeport -9- Fuel Cell Petition VII. ENVIRONMENTAL EFFECTS

1. Water, Heat and Air Emissions

The proposed installation will have no substantial adverse environmental effect. The installation and operation of the Fuel Cell installation will meet all air and water quality standards of DEEP.

Section 22a-174-42 of the Regulations of Connecticut State Agencies (“RCSA”) governing air emissions from new distributed generators exempts fuel cells from air permitting requirements. Notwithstanding this exemption, the Fuel Cell meets the Connecticut emissions standards for a new distributed generator as shown in Table 1 below, and no permits, registrations or applications are required under rules based on the actual emissions of the Fuel

Cell. Furthermore, the Fuel Cells utilized at the facility are certified by the California Air

Resources Board to meet the Distributed Generation Certification Regulation 2007 Fossil Fuel

Emissions Standards (See Attachment #10).

Table 1: CT Emissions Standards for a New Distributed Generator

Air Pollutant CT Emissions Standard PureCell Model 400 Fuel (lbs/MWh) Cell System at Rated Power (lbs/MWh) Oxides of Nitrogen 0.15 .02 Carbon Monoxide 1 .01 Carbon Dioxide 1650 998

With respect to water discharges, the Fuel Cell is designed to operate without water discharge under normal operating conditions. To the extent that minimal water overflow may occasionally occur, such discharges will consist of de-ionized water and will be directed to the city’s sewer system. This discharge will be incorporated into the overall site design, and will be

Nupower Thermal Bridgeport -10- Fuel Cell Petition covered by the Site’s water discharge permit, if necessary. The Fuel Cell operates in water balance below 86°F. The initial fill requires 350 gallons of water per Model 400 system. The amount of make-up water above 86°F increases linearly from 0gpm to 1gpm per Model 400 system at 110°F. A reverse osmosis system will be used by the facility to provide treated make- up water.

The Facility will also meet state criteria thresholds and projected emissions for all greenhouse gases defined in as Section 22a-174-1(49) as shown in Table 2. Section 22a-174-

1(49) states the following: “Greenhouse gases” or “GHGs” means the aggregate of the following six components gases: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexa fluoride (SF6), any hydrofluorocarbon (HFC) or any perfluorocarbon (PFC).” There is no defined criteria threshold for these compounds, however Section 22a-174-1(21) provides a method for computing carbon dioxide equivalent emissions “CO2e.” The proposed Facility will have no emissions of SF6, HFC, and PFC. Emissions of CH4 and N2O will be very low and will not contribute significantly to the GWP of the proposed facility.

Table 2: PureCell® Model Emissions Data

Emission Projected GWP in 40 Projected CO2e Type Emissions CFR 98, Table A-1 CO2 41,916 ton/yr 1 41,916 ton/yr CH4 <0.42 ton/yr 25 <10.5 ton/yr N2O <0.21 ton/yr 298 <63 ton/yr SF6 N/A 22,800 N/A HFC N/A 12 to 14,900* N/A PFC N/A 7,390 to 17,340 N/A

Nupower Thermal Bridgeport -11- Fuel Cell Petition Current control technologies are not commercially available to reduce the greenhouse gas emissions from the Facility. The utilization of the waste heat in the Facility into the proposed district heat loop on site will offset CO2 emissions for customers of the heat loop. According to

Doosan’s analysis the proposed project will result in a net CO2 emissions reduction of 9,558 metric ton/yr of CO2 (Attachment #20).

2. Wildlife and Habitat

According to the relevant portion of the CT DEEP Bridgeport Natural Diverse Database

Areas Map (See attachments #11), the proposed Site is not located within the City of Bridgeport

Natural Diversity Data Base Areas.

3. Noise Analysis

The proposed site is located directly adjacent to I-95, a busy elevated highway with a high volume of truck traffic. Parcels in the immediate vicinity include light industrial, commercial, and residential. Background noise levels of the proposed site as measured by a professional acoustic engineer show intermittent night-time noise associated with truck traffic on

I-95 (Acoustic Survey Report, Attachment #12).

Results of acoustical testing and modeling indicate a potential for the project to have acoustical impacts on properties in close vicinity if no mitigating actions are completed. The proposed project will be constructed to allow for installation of the noise-treatment solutions to mitigate the acoustical impacts. Noise treatment solutions will only be installed on the facility as determined by acoustical testing during commissioning activities. Following completion of noise treatment solution installation acoustical testing will be conducted to demonstrate compliance with City and state noise ordinances.

Nupower Thermal Bridgeport -12- Fuel Cell Petition 4. Visual Impact

The site is bordered on the south and east by I-95 SB, the north by Railroad Ave and the

Metro-North Railroad, and the west by Iranistan Ave. A rendering of the proposed facility is included in Attachment #2. Some items such as pumps, heat exchangers, ducts, and piping are not included in the rendering. The proposed facility will be visible from adjoining surface streets, I-95, and the Metro-North Railroad. The proposed facility will fit with the light industrial nature of the area the project is situated.

5. Public Notice

Notice was provided via certified mail to all property owners, abutters and state and local officials pursuant to Conn. Agencies Regs.§16-50j-40(a). Doosan’s copy of the notice letter is included in Attachment #13. A list of abutters is included in Attachments #14. Applicable

Federal, State and Municipal officials of Bridgeport provided notice are listed in Attachment #15,

Certified mail receipts are included in Attachment #16.

Project Decommissioning Plan

Following the 20-year operational life of the Facility, the decommissioning plan is as follows:

A) Isolate, lock out and disconnect all piping for cooling module at the power module. Remove gas piping to the unit. Disconnect nitrogen purge system at power module.

B) Disconnect all electrical conductors and conduit at the Fuel Cell to include electrical power, cooling module power, and nitrogen pressure switch. Shore power to be maintained to the unit to maintain temperature as needed.

Nupower Thermal Bridgeport -13- Fuel Cell Petition C) Contractor will work in concert with Doosan’s Service Department personnel during decommissioning and shutdown.

D) Return Site to original condition with the exception of the concrete pads and steel structure.

E) The decommissioned Fuel Cells will be stripped, the parts are separated and either recycled, reclaimed or transported to landfill.

7. Aquifer Protection Area, Coastal Boundaries, and Flood Zones

Based on an analysis of the Federal Emergency Management Agency’s (“FEMA”)

National Flood Insurance Program (“NFIP”) flood mapping data for Bridgeport (See Attachment

#17), proposed project location is within the 100 yr. flood zone area, in an area with a base flood elevation of 12’. Fill will be added to the site as needed to bring the base elevation for all equipment 2’ above the flood elevation.

The City of Bridgeport has no Aquifer Protection Areas. The proposed project is located within the city of Bridgeport’s coast boundary zone (See Attachment #18). A coastal boundary zone permit application will be filed with the city during the municipal permitting process.

8. Cultural Resources.

Nupower Thermal Bridgeport -14- Fuel Cell Petition The proposed Facility will be located in an already developed vicinity, consequently construction and operation of the Fuel Cell will have no unpleasant effect on any cultural

(historical and archaeological) resources in the area.

9. Natural Gas Desulfurization Process

Sulfur is present in pipeline natural gas. It is primarily used as an odorant so leaks can be easily detected. Unfortunately, sulfur is also a poison to fuel cell systems and must be removed by the Fuel Cell. For further details of desulfurization please refer to the attached

Desulfurization Memo (See Attachment #19).

VIII. CONSTRUCTION AND MAINTENANCE

Doosan plans to start construction work by January 2021. Construction will take approximately eight (8) months, followed by approximately twelve weeks of testing and startup.

Regular working hours for the proposed project are Monday through Friday from 8:00 am to

5:00 pm. Doosan and its contractors will fully cooperate with the City Inspector and will follow all City of Bridgeport and Connecticut State construction policies and codes.

IX. LOCAL INPUT

The design and construction team Dan Fisher of ICDS, Walter Bonola Doosan fuel cell

America and Nupower Principle Scott Guilmartin all met with City officials to discuss the project. Bruce Nelson Building Official, Lynn Haig Director of Planning and Max Perez Director of Business Development were in attendance. The conceptual drawings were shared and

Nupower Thermal Bridgeport -15- Fuel Cell Petition discussed at the meeting. Doosan and ICDS presented an overview of the project including raising the grade above flood level, decorative fencing options and general appearance of the building.

X. CONCLUSION

As set forth above, Doosan requests that the Council issue a determination, in the form of a declaratory ruling, that the proposed installation above is not one that would have a substantial adverse effect, and, therefore, that a Certificate is not needed.

Respectfully submitted,

……………………….

Walter Bonola

Installation Manager

Doosan Fuel Cell America, Inc.

Nupower Thermal Bridgeport -16- Fuel Cell Petition LIST OF ATTACHMENTS

Attachment 1: Photos of project location

Attachment 2: Rendering of proposed project

Attachment 3: PURA Decision

Attachment 4: PureCell Model 400 Data sheet

Attachment 5: Draft Emergency Response Plan

Attachment 6: Site Plan

Attachment 7: Survey of property

Attachment 8: Zoning Map

Attachment 9: 14CFR Part 77.9

Attachment 10: California Air Resources Board Emission Certification

Attachment 11: DEEP Diverse Database Areas Map

Attachment 12: Acoustical Report

Attachment 13: Notice Letter

Attachment 14: Abutters List and Map

Attachment 15: List of Federal, State, and Local Officials

Nupower Thermal Bridgeport -17- Fuel Cell Petition Attachment 16: Copy of Cert. Mail receipts for letters to Abutters and Officials

Attachment 17: Flood Map

Attachment 18: Coastal Boundary Zone Map

Attachment 19: Doosan Fuel Cell Desulpherization Memo

Attachment 20: Avoided Emissions

Nupower Thermal Bridgeport -18- Fuel Cell Petition Attachment #1 Photos of Project Location

Attachment #2 Project Renderings

Note: Some items not included such as transformers, pumps, ducts and piping.

STATE OF CONNECTICUT

PUBLIC UTILITIES REGULATORY AUTHORITY TEN FRANKLIN SQUARE NEW BRITAIN, CT 06051

DOCKET NO. 18-08-14 PURA REVIEW OF THE COMBINED HEAT AND POWER PROJECT SOLICITATION PURSUANT TO CONN. GEN. STAT. SECTION 16-258e

October 2, 2019

By the following Commissioners:

John W. Betkoski, III Michael A. Caron

DECISION

TABLE OF CONTENTS

I. INTRODUCTION ...... 1 A. SUMMARY ...... 1 B. BACKGROUND OF THE PROCEEDING...... 1 C. CONDUCT OF THE PROCEEDING ...... 1 D. PARTIES AND INTERVENORS OR PARTICIPANTS ...... 2

II. POSITIONS OF PARTICIPANTS ...... 2 A. THE UNITED ILLUMINATING COMPANY ...... 2 B. NUPOWER ...... 3 C. THE OFFICE OF CONSUMER COUNSEL ...... 3 D. THE DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION ...... 4

III. AUTHORITY ANALYSIS ...... 4 A. COST OF SERVICE PRICING ...... 5 1. Return on Equity ...... 6 2. Pass-Through Entity Income Tax Rates...... 11 3. Payroll Taxes ...... 11 4. Investment Tax Credits ...... 11 5. Test Period Revenue ...... 12 6. Ongoing Process to Review COS Model...... 13 B. FIRM CUSTOMER COMMITMENTS FOR THE THERMAL ENERGY ...... 13 C. ELECTRIC DISTRIBUTION SYSTEM INTERCONNECTION COSTS ...... 17 D. GAS FACILITIES ...... 19

IV. FINDINGS OF FACT ...... 20

V. CONCLUSION AND ORDERS ...... 24 A. CONCLUSION ...... 24 B. ORDERS ...... 24

DECISION

I. INTRODUCTION

A. SUMMARY

In this Decision, the Public Utilities Regulatory Authority approves the request of The United Illuminating Company to enter into a Power Purchase Agreement with NuPower Bridgeport FC, LLC for a combined heat and power district energy project in Bridgeport, Connecticut pursuant to § 16-258e of the General Statutes of Connecticut, subject to certain conditions.

B. BACKGROUND OF THE PROCEEDING

The United Illuminating Company (UI or Company) issued a request for proposals (RFP) for energy and Connecticut Class I and/or Class III renewable energy certificates (RECs) from combined heat and power system (CHP) facilities in distressed municipalities in its service territory. See, December 21, 2018 Application of The United Illuminating Company for Review and Approval of Power Purchase Agreement (Application), pp. 1 and 2. NuPower of Bridgeport FC, LLC (NuPower) submitted a conforming bid (NuPower RFP Bid) for the NuPower Thermal Bridgeport fuel cell project (Project) in response to the solicitation. Id. p. 2. The NuPower RFP Bid was the only bid received by UI. Id. While UI did not initially accept the NuPower RFP Bid. UI reconsidered its decision and negotiated a PPA with NuPower. Id. However, instead of pursuing negotiations based on the pricing included in the NuPower Bid, UI proposed to NuPower that the parties negotiate a PPA with pricing based on a cost of service (COS) model. Id.

On December 21, 2018, UI submitted an application (Application) to the Public Utilities Regulatory Authority (PURA or the Authority) for (1) review and approval of an unexecuted power purchase agreement (PPA) between UI and NuPower. UI also seeks (2) authorization to recover all costs associated with the PPA, including all costs prudently incurred by UI to administer and enforce the PPA and an Authority determination of the appropriate return on equity for the COS model under the PPA. Finally, UI requests (3) acceptance by the Authority of the responsibility to review (a) the pro forma COS model, including the capital cost of the facility, (b) the true-up between the pro-forma and actual capital costs of the facility, approximately 90 days after the facility’s commercial operation date, and (c) if necessary, review the annual actual revenue requirement if it exceeds the pro-forma revenue requirement for that year by greater than 5%.

C. CONDUCT OF THE PROCEEDING

A Notice of Proceeding was issued on December 28, 2018, and a Notice of Request for Written Comments was issued on March 8, 2019. Two Notices of Admitted Evidence were issued, one on March 7, 2019, and the other on May 16, 2019.

By Notice of Hearing dated March 7, 2019, the Authority scheduled and conducted a public hearing on this matter on March 27, 2019, at its offices, Ten Franklin Square,

Docket No. 18-08-14 Page 2

New Britain, Connecticut.1 A Late-Filed Exhibits (LFE) Hearing was held on May 21, 2019 at those same offices.

Pursuant to a Notice of Admitted Evidence dated March 7, 2019, the Authority admitted into evidence the Edison Electric Institute’s Q3 2018 Regulatory and Financial Update: Rate Review Summary.

Pursuant to a Notice of Admitted Evidence dated May 16, 2019, the Authority admitted into evidence documents from Federal Energy Regulatory Commission (FERC) Docket ER18-1639-000 that included: (1) FERC Order Accepting Agreement, Subject to Condition, and Directing Briefs, 165 FERC ¶ 61,267, issued December 20, 2018 (FERC Order); and (2) Constellation Mystic Power, LLC, Revised Exhibit No. MYS-0011, Schedules Regarding ROE Analysis, Capital Structure, and Cost of Debt, filed September 17, 2018 (Mystic ROE Exhibit).

The Authority issued a Proposed Final Decision in this Docket on September 9, 2019. All participants were provided the opportunity to submit Written Exceptions and present Oral Arguments on the Proposed Final Decision.

D. PARTIES AND INTERVENORS OR PARTICIPANTS

The Authority recognized the following as Participants to this proceeding: NuPower of Bridgeport FC, LLC (NuPower), 103 North Park Avenue, Easton, CT 06612; Office of Consumer Counsel (OCC), Ten Franklin Square, New Britain, CT 06051; the Commissioner of the Department of Energy and Environmental Protection (BETP or DEEP), 79 Elm Street, Hartford, CT 06106; and The United Illuminating Company, 180 Marsh Hill Road, Orange, CT 06477.

II. POSITIONS OF PARTICIPANTS

A. THE UNITED ILLUMINATING COMPANY

UI stated that the Authority should approve the PPA if it concludes that it complies with the requirements of Conn. Gen. Stat. § 16-258e(b) and serves the long-term Interests of ratepayers. UI Brief, p. 4. UI argued that the PPA is the product of an arm’s length negotiation between UI and NuPower, and provides the financial foundation for the financing of NuPower’s fuel cell project and the associated thermal loop. Id. UI stated that the PPA is structured with COS pricing and approval of the PPA will require regulatory oversight and approval of costs to provide UI with the ability to pass contract costs through to its customers. Id. UI requested that the Authority’s decision in this docket also include an ongoing process to review (a) the pro forma COS model; (b) the true-up between pro- forma and actual COS approximately 90 days after the facility’s commercial operation date (COD); and (c) if necessary, review the annual actual COS if it exceeds the pro- forma COS for that year by greater than 5%. Id., p. 5.

UI also stated that the Authority should consider the level of ratepayer support that is dedicated to this project when setting an appropriate return on equity (ROE). Id. UI

1 There is no statutory requirement for a hearing.

Docket No. 18-08-14 Page 3 said that it has not performed an analysis to determine the appropriate ROE under COS ratemaking for a generation project of this scale owned by a single-asset entity like NuPower and the Company has no experience with fair and reasonable rates of returns for privately funded projects developed through a single purpose entity. Id.

UI asserted that it does not advocate the Authority adopt a specific ROE for this project, and the Company does not take a position on the appropriate ROE. Id., p. 8.

Finally, UI stated that the Authority should ensure UI’s cost recovery and authorize UI to recover all contract-related costs from all customers and credit any contract-related benefits to all customers, through a fully-reconciling component of electric rates for all customers of UI for the full term of the PPA. Id, p. 9. Further, consistent with prior Authority decisions, the Company proposes to reconcile these costs and benefits through the nonbypassable federally mandated congestion cost (NBFMCC) charge. Id., p. 9.

B. NUPOWER

NuPower claimed that the Project is a critical piece of the overall thermal loop development in downtown Bridgeport. By passing Conn. Gen. Stat. § 16-258e(b), the Connecticut legislature recognized that a 10MW fuel cell developed within an urban center and connected to a district heating system will bring benefits to the customers of the thermal loop (the thermal loop is being designed to be capable of bringing hot water to local institutions, businesses, and residences located in Bridgeport), economic development opportunities to the City of Bridgeport, and environmental benefits to the entire state. NuPower Brief, p. 27.

NuPower stated that the legislature specifically required that the solicitation be limited to the most populous municipalities in the state and by doing so, the legislature recognized the special relationship between district heating systems and densely populated urban centers. Id. According to NuPower, the legislature also recognized the cost structure necessary to develop the Project in an urban center and the unique obstacles that exist when a project cannot be sited outside of the urban center and given the intent of Conn. Gen. Stat. § 16-258e(b), the benefits of the Project to the thermal loop, Bridgeport, the region, and the State of Connecticut, PURA should approve the Project so that these benefits can be realized. Id.

C. THE OFFICE OF CONSUMER COUNSEL

The OCC argued that the Project is too expensive to be in the long-term interest of ratepayers for purposes of Conn. Gen. Stat. § 16-258e. OCC Brief, p. 6. The OCC further claimed that the Project, if approved and if it achieves its goals, will receive multiple subsidies from gas customers and electric customers. Id., p. 12.

The OCC also argued that the ROE issue is unimportant because the Project is unacceptably expensive at any ROE within the range discussed in the record. Id., p.13. The OCC claims that the NuPower affiliate that is the thermal energy transportation company does not yet have firm customer commitments for thermal energy services. Id., p. 15.

Docket No. 18-08-14 Page 4

The OCC concluded that, with net lifetime costs of over $60 million, the Project is too expensive to be in the long-term interest of ratepayers and the claimed benefits of the Project have either been poorly quantified or do not actually impact ratepayers. The OCC recognized the effort that has gone into the Project but, concluded that the project is simply not supportable under the “long-term interests of ratepayers” standard in Conn. Gen. Stat. § 16-258e. Id., p. 16.

D. THE DEPARTMENT OF ENERGY AND ENVIRONMENTAL PROTECTION

The BETP argued that the PPA was prematurely filed since, at the time, NuPower did not provide any firm commitments and thus does not meet the statutory requirement for firm commitments. BETP Brief, p. 9. BETP further argued that since no firm customers are known, the Authority cannot evaluate the whether the location of the fuel cell maximizes the efficiency of the thermal energy. Id.

The BETP also argued that the even if the Authority did not reject the Project as prematurely filed, it should reject the Project as not meeting the statutory requirement of being in the long-term interest of ratepayers. Id. The BETP asserted that the “significantly below 1.0 benefit-to-cost [ratio] of the [P]roject, the lack of any appreciable benefits to the electric system, the increase in expected carbon dioxide emissions from the [P]roject, and the reliance on multiple ratepayer incentive programs, demonstrate that the [P]roject is decidedly not in the interest of ratepayers.” Id. pp. 9–10 (footnote omitted).

III. AUTHORITY ANALYSIS

Conn. Gen. Stat. § 16-258e states, in part:

(b) No later than fifteen days after an electric distribution company enters into a power purchase agreement pursuant to subsection (a) of this section, the electric distribution company shall submit such agreement to the Public Utilities Regulatory Authority for review and approval. The authority shall evaluate such agreement and may approve such agreement if the authority finds that the agreement (1) complies with the requirements of this section, and (2) serves the long-term interests of ratepayers. The authority shall not approve any agreement supported in any form of cross subsidization by entities affiliated with the electric distribution company. A combined heat and power system acquired and built pursuant to a power purchase agreement entered into pursuant to this section shall not exceed a total nameplate capacity rating of ten megawatts in the aggregate. The electric distribution company may not, under any circumstances, recover more than the full costs of the agreement approved by the authority. The net costs of any such agreement, including costs incurred by the electric distribution company under the agreement and reasonable costs incurred by the electric distribution company in connection with the agreement, shall be recovered on a timely basis through a reconciling component of electric rates as determined by the authority that is nonbypassable when switching electric suppliers. Any net revenues from the sale of products purchased in accordance with any agreement entered into pursuant to this section shall be credited to customers through the same reconciling component of

Docket No. 18-08-14 Page 5

electric rates that is utilized to recover the costs of such agreement. Certificates issued by the New England Power Pool Generation Information System for any Class I or Class III source procured by an electric distribution company pursuant to this section may be (A) sold into the New England Power Pool Generation Information System renewable energy credit market to be used by an electric supplier or electric distribution company to meet the requirements of section 16-245a, so long as the revenues from such sale are credited to electric distribution company customers as described in this subsection, or (B) retained by the electric distribution company to meet the requirements of section 16-245a. In considering whether to sell or retain such certificates, the company shall select the option that is in the best interest of such company’s ratepayers, consistent with the procurement plan approved pursuant to sections 16-244c and 16-244m.

A. COST OF SERVICE PRICING

UI’s stated objective in adopting COS model was to reduce the total expected cost to customers by reducing NuPower’s development and construction cost risk (especially for electric and gas interconnection costs), and the risk of purely volumetric pricing, and thus allow NuPower to accept a lower return commensurate with the lower risk. Application, p. 2. While UI and NuPower have not agreed to a return on equity (ROE) for the proposed COS model, all other substantive issues have been resolved, and the PPA and COS model (other than ROE) submitted in this docket are the product of the negotiation between UI and NuPower. Id.

The COS model agreed to by UI and NuPower includes a pro forma COS that includes the projected cost to develop and construct the facility, to be trued up to the actual cost to develop and construct the facility, no later than 90 days after achievement of the COD. Id., p. 4. Thereafter, if for any year the actual COS for that year exceeds the pro forma COS for that same year by greater than 5%, the actual COS for that year will be submitted for the Authority’s review. Id.

Additionally, while UI and NuPower expect that actual costs will be close to pro forma costs for the majority of the line items in the pro form cost of service model, the cost of the facility’s electric interconnection is still highly uncertain. Id. UI understands that the pro forma cost of service model includes only a preliminary estimate of the cost to interconnect the facility to UI’s distribution system because only preliminary work on the interconnection application has commenced. Id. Additional study is required according to the standard interconnection process to obtain a more robust estimate of the cost to interconnect the facility. Id., p. 5. UI and NuPower have agreed to exclude the cost of electric interconnection from the 5% annual threshold between actual and pro forma cost of service. Id.

The Authority finds that structuring the PPA with cost of service pricing helped to lower the estimated going forward costs of the project, relative to the original NuPower Bid. The PPA, as structured, provides assurance of cost recovery for NuPower’s fuel cell project and the thermal loop. The heat generated from the CHP may be used to provide thermal energy to an urban downtown thermal loop and replace older inefficient boilers in

Docket No. 18-08-14 Page 6 a distressed municipality, provided adequate customer commitments for this product are achieved.

For the reasons stated herein, the Authority finds that the NuPower Project complies with the requirements of Conn. Gen. Stat. § 16-258e(b) and serves the long-term interests of ratepayers, and approves the request of The United Illuminating Company to approve the PPA, subject to certain conditions discussed below.

1. Return on Equity

NuPower provided testimony in the Application, in which it proposed a post-tax weighted average cost of capital (WACC) of 10.38%. Application, Exhibit C-1, p. 16. The proposed WACC was based on a capital structure of 50:50 debt to equity. Id. NuPower proposed long-term debt rate of 5.75% and a ROE rate of 15%. Id. NuPower states that it proposed a fixed capital structure for the life of the project in order to reduce investor uncertainty, which is a key factor for attracting investment capital. Nevertheless, NuPower acknowledges that the financing will change and mature over time. Id.

NuPower indicates that the Interim Decision dated December 5, 2018, in Docket No. 18-05-04, PURA Implementation of June Special Session Public 17-3 (Millstone Interim Decision) provided a building-block approach for determining a reasonable ROE to keep the Millstone nuclear facilities operating. Therrien and Stone Supplemental PFT, pp. 2-5. According to NuPower, in the Interim Decision, the Authority accepted 13.4% as a reasonable ROE for a hypothetical merchant natural gas plant based on the New England Independent System Operator’s (ISO-NE) Net Cost of New Entry Study (Net CONE Study), and that the ROE for a generic merchant gas plant should be adjusted upward to account for plant specific risks. Id. Specifically, NuPower states that the Authority determined that Millstone, under a merchant operation scenario, would deserve an ROE of at least 15%. Id. Thus, NuPower claims that the Millstone Interim Decision provided additional supports for its proposed 15% ROE for the fuel cell project. Id.

NuPower claims that the estimated ROE for its fuel cell project under a building- block approach is 21.90%. Therrien and Stone Supplemental PFT, pp. 5-12. The Company derived the 21.90% building-block ROE by adjusting the 13.4% ROE proposed in the ISO-NE Net CONE Study for a new entrant merchant gas-fired generator by four additional risk premia. Id. NuPower reduces this base ROE by 100 basis points for cost of service (COS) PPA pricing and increases it by 400 basis points for development risk; 150 basis points for technology risk; and 400 basis points for size risk. Id. NuPower claims that the estimated ROE of 21.9%, using a building-block estimation approach, supports the Company’s position that its proposed ROE of 15% is reasonable. Id. Also, to support its proposed 15% ROE, NuPower cites the Department of Energy’s 2016 study (2016 DOE Study) titled, “Fuel Cell Technologies Market Report 2016,” which noted that Intelligent Energy raised £30 million ($39 million) through the issuance of 13.0% senior secured convertible loan notes 2019, which NuPower labelled as ”a benchmark for ROE.” NuPower Brief, p. 17. NuPower also refers to the discussion on the cost of capital for power generation in the publication Economic Analysis and Policy (EAP Study), which postulated that for a merchant power generator, the marginal equity cost leans towards 15-16%, but towards 11-12% for an investment-grade integrated merchant utility. Id., p. 18.

Docket No. 18-08-14 Page 7

NuPower states that it is generally accepted that small companies have certain risk characteristics that are more prevalent than in larger companies. Therrien and Stone Supplemental PFT, p. 8. These include limited access to capital, management depth concerns, and liquidity concerns. Id. NuPower further states that for this reason, it is reasonable to include a “size premium,” or basis point adder to one’s estimate of ROE to account for small company size. Id., pp. 8 and 9.

NuPower indicates that the FERC Order and Mystic ROE Exhibit are irrelevant and immaterial and should not be given weight in this proceeding because there are related to a cost of service contract to prevent the retirement of 1,700 MW of capacity from the Mystic Units 8 and 9 during the June 2022 through May 2024 capacity commitment period. NuPower Brief. p. 24. According to NuPower, the FERC Order relates to the ROE to be granted to Mystic Units 8 and 9 generating plants that are threatening to retire. The closing of Mystic would not only affect 1,700 MW of existing generation, but the affiliated Everett liquefied natural gas (LNG) import facility. Id. NuPower also states that the FERC methodology for determining ROE can change because the FERC Order directed parties to file briefs based on the new proposed Coakley methodology for determining ROE in FERC cases, which the FERC order recognizes is a proposal and not a final policy, and that FERC has not made a decision on Mystic’s ROE. Id., p. 25. Moreover, NuPower indicates that evidence in the FERC Order is incomplete, and based on a discounted cash flow (DCF) analysis of publicly traded companies that are comparable to Mystic’s parent company Exelon, with revenues of $33 billion and with risks significantly different than that of a single asset 9.66 MW fuel cell project. NuPower implies that there is no showing of relevance or that the multi-billion dollar proxy companies in the Mystic proceeding associated with the FERC Order are similar to the NuPower project in the instant proceeding. Id. pp. 25 and 26.

The OCC states that the NuPower Project is too expensive at any ROE range. The total 20 year revenues at NuPower’s proposed 15% ROE is about $178 million, and about $157 million at the low end of 9.60%. The OCC also stated that the low-end ROE only reduces the estimated lifetime cost of the facility from $63 million to $42 million. OCC Brief, pp. 13–14. According to the OCC, NuPower did not provide any traditional ROE analysis that supports the correctness of its proposed 15% ROE, which is “completely out of the range of any PURA ruling in memory either for a utility or a generating plant with a long-term contractual backstop.” Id., p. 14. The OCC also cites testimony that the cap on ROE for a similar GenConn peaking COS contract is 10.75% and that UI was allowed only 25 basis points over its the approved distribution ROE, which is currently below 10%, for its own Bridgeport fuel cell project. The OCC further indicates that NuPower Project is a CHP unit with a long-term COS-based contract that mitigates much of the risk associated with its development and operation. OCC states NuPower does not deserve an ROE in excess of 11%. Id. Moreover, regarding the NuPower’s claim that it is not comparable to other independent power producers (IPP) with large portfolios and balance sheets, or to regulated utilities, the OCC theorized that NuPower could receive approval for a contract with a locked-in 15% ROE, then “turn around and assign the contract or partner with a larger entity, eliminate the balance sheet risk, and achieve a windfall.” According to the OCC, NuPower chose to pursue this project through LLCs of a small size and low capitalization instead of partnering with a larger entity; thus shifting and adding the risk of overpayment to UI’s customers. Id., p. 15

Docket No. 18-08-14 Page 8

UI indicated that the Parties had agreed to all terms of the PPA except for the 15% ROE proposed NuPower. Application, pp. 2 and 4. UI suggested that the NuPower’s PPA is different from those selected in DEEP’s RFPs because the related distributed generation project is combined with a thermal loop to capture the waste heat. Tr. 03-27-19, pp. 16-17. Also, UI wrestles with the level of ratepayers’ support for the fuel- cell project, given the public policy support for fuel cell manufacturers in Connecticut. Id., UI Brief, p. 8. UI also indicates that while it has not performed any analysis on the appropriate ROE for a single-asset entity such as NuPower and cannot identify a directly analogous project, UI inferred that NuPower’s project is comparable to other existing ratepayer supported peaking and fuel cell projects that similarly employed the COS models. Id., pp. 5 and 6. UI also recognizes a potential “flaw” in NuPower’s reliance on the Authority’s determination in Millstone Interim Decision regarding whether a 15% ROE may be appropriate for a merchant nuclear generator. Unlike the scenario set out in the Millstone Interim Decision, the NuPower CHP project would never be exposed to wholesale market risks, nor reliant on market revenues to meet its operating costs and returns on and of capital investments. Id. p. 7.

The Authority finds that the 15% ROE proposed by NuPower is excessive, not consistent with COS pricing mechanisms currently used, and fails to satisfy UI’s stated primary objective for the COS pricing approach, which is to “reduce the total expected cost to customers” and “allow NuPower to accept a lower return commensurate with the lower risk.” Application, p. 2. NuPower’s building-block approach for determining a reasonable ROE in support of its ROE request is not contemplative of COS-based projects, but rather, riskier merchant generators.

NuPower’s use of the calculated ROE for merchant entrants (13.4%) is not an appropriate ROE benchmark for calculating an allowed ROE for the Project. The fixed and variable costs of operating merchant units are recovered by the generation owner solely through effective and efficient operations and participation in the wholesale markets, and with no guarantee. The ISO-NE CONE and ORTP Analysis (CEA Study) describes the CONE and Net CONE values as the compensation a cost-effective new entrant would need to recover its capital and fixed costs under long-term equilibrium conditions. LFE No. 7, Attachment 1, p. 5. The offer review trigger price (ORTP) value is a benchmark price used to screen supply offers for competitiveness. Id. The Authority concludes that the inherent risks associated with the reference units used to develop the CONE, Net CONE and ORTP values are significantly higher than that a generator operating under a COS contract, which greatly reduces, if not eliminates, most of the risk the project may not recover its capital and fixed costs.

To illustrate the difference, the owner of Mystic Generation Station, a merchant generation facility, recently sought to retire units 8 and 9, which were retained by the ISO New England through a reliability-must-run COS contract, approved by the Federal Energy Regulatory Commission (FERC). The ROE proposed by Exelon, for the continued operation of Mystic units 8 and 9 under a cost of service scenario, is 10.26%. FERC Order, p. 8. For this proposed ROE level, various participants in the FERC Order proceeding still argued that the Mystic expert witness had adjusted the screening criteria for the proxy group in order to skew the result toward higher numbers. FERC Order, p. 10.

Docket No. 18-08-14 Page 9

In the Millstone Interim Decision, the Authority used an assumed rate of return requirement of 13.4%, adjusted upward to account for some added risk associated with operating a merchant nuclear plant. The Authority noted in the Millstone Interim Decision that a merchant operation scenario is one in which a resource is selling its output into the regional wholesale market and through bilateral contracts and is reliant on revenues realized through those sales to meet its operating costs and return requirements. Id. In the Millstone Interim Decision, the Authority did not determine the justness or reasonableness of the 15% rate of return, nor did it establish a specific rate of return to which the Millstone Station is entitled. Id.

The Authority finds that the NuPower Project, as proposed, does not have the same risk profile as a merchant generator. A COS scenario, like that of the Mystic Units referenced above, better represents the risk profile the NuPower Project faces, relative to the merchant scenarios described above. In determining the appropriate cost of capital to allow NuPower under the cost of service pricing, Conn. Gen. Stat. § 16-19e (a) requires that:

[t]he level and structure of rates be sufficient, but no more than sufficient, to allow public service companies to cover their operating costs including, but not limited to, appropriate staffing levels, and capital costs, to attract needed capital and to maintain their financial integrity, and yet provide appropriate protection to the relevant public interests, both existing and foreseeable . . .

The Authority considered similar cost of service-based pricing scenarios in determining an appropriate ROE.

UI currently has three fuel cell projects in its renewable connections program (RCP Projects). Tr. 05/21/19, p. 265. Two of UI’s three RCP Projects are located in distressed municipalities, Bridgeport and New Haven. Id. The allowed ROE that UI receives for the RCP Projects is 9.35%, which consists of UI’s current distribution ROE of 9.10% plus a 25 basis point adder, and is subject to adjustment as UI’s allowed ROE is amended in a general rate case. Id., p. 265; RCP Reconsideration Decision, p. 6.

Additionally, the Edison Electric Institute’s Q3 2018 Regulatory and Financial Update: Rate Review Summary (EEI 2018 Financial Update) shows that electric utilities filed 12 new rate reviews in third quarter of 2018; and the average requested ROE was 10.25% and the average awarded ROE was 9.53%. EEI 2018 Financial Update, p. 1.

The COS pricing mechanism provides for the return of, and return on, the prudent investment by NuPower for 20 years, similar to the business model for regulated utilities. The COS pricing mechanism proposed allows for the projected development and construction costs to be trued up to the actual costs. As a result, ratepayers share in the risk of project development. Further, the NuPower Project may true up its actual ongoing cost of service in any given year. The PPA parties have proposed that the Authority ensure that all costs associated with the operation of the NuPower CHP are recoverable through distribution rates charged by UI. The NuPower PPA comes with an assurance that the counterparty, a regulated utility, will make the periodic payments agreed to within the terms of the related contract.

Docket No. 18-08-14 Page 10

In its Written Exceptions, NuPower indicated that, from a cost of equity perspective, the Project is not comparable to UI’s RCP Projects. NuPower asserted that its Project is more risky to investors than the RCP projects because its construction and operation are subject to risks and penalties that could result in revenue loss or, in the extreme, termination of the contract. NuPower stated that, unlike UI, it does not have multiple revenue sources, or risk-mitigating ratemaking mechanisms such as decoupling mechanisms to reconcile costs and revenues; nor other rate adjustment mechanisms such as the nonbypassable federally mandated congestions charge. NuPower Written Exceptions, p. 3. Also, NuPower stated that UI’s investment in the RCP Projects of approximately $50 million is very small when compared to its rate base of about $1 billion. Id., pp. 3 and 4

NuPower stated that the Authority allowed UI 50 basis points over its utility business only ROE for very limited construction and operational risks that pale in comparison to the level of risks to be endured by NuPower under the proposed PPA. Id. NuPower reasserted that it is a single asset entity with significant financing, project development, construction, capital, and operational risks, without UI’s large balance sheet to absorb such risks. Additionally, NuPower claimed that a rating agency would combine the stand-alone nature of the Project with the construction and ongoing operation risks to further reduce its overall credit rating. Id. p. 5.

Furthermore, NuPower stated that in the proposed Second Interim Decision dated August 29, 2019, in Docket No. 18-05-04, PURA Implementation of June Special Session Public Act 17-3 (Millstone Second Interim Decision), the Authority approved a COS contract for half of Millstone’s output that essentially insulates 50% of Millstone’s output from merchant risk. NuPower Written Exceptions, p. 11. NuPower also stated that in the Millstone Second Interim Decision, the Authority allowed Millstone’s owner an ROE of 14%, which is higher than the expected ROE for a Connecticut regulated utility, in spite of Millstone’s advantages of depreciated capital costs and a lower cost structure. Id.

Given that NuPower does not have the same risk profile as a merchant generator, the Authority continues to find that the 15% ROE proposed by NuPower is excessive, and reduces the intended public benefits of the Project. Nevertheless, the Authority reconsiders its earlier ROE determination made in the September 9, 2019 Proposed Final Decision and agrees with NuPower that, while UI’s RCP projects are COS-based as well, the Project faces significantly more financing, construction, and operational risks than the RCP projects. The Authority agrees with NuPower that level of risk for the proposed Project is notably different from that of regulated utility-sponsored project such that the allowed ROE should provide the developer the capability to attract needed capital to fund the project. The Authority will therefore allow NuPower a ROE of 12% for the proposed PPA under a COS-pricing model. This allowed ROE will provide additional compensation to the Project for the added risks noted above, while not exceeding benchmark ROE of 13.4% for a merchant generator.2.

2 The Authority notes that applying the premiums for development risk, technology risk and size risk proposed in NuPower’s building-block approach, even to the regulated utility ROE, yields a ROE far in excess of 13.4%.

Docket No. 18-08-14 Page 11

2. Pass-Through Entity Income Tax Rates

For current and deferred income taxes, NuPower applied the top Federal personal income rate of 37% and Connecticut pass-through entity (PET) rate of 6.99%. NuPower indicates that adjusting its proposed revenue requirement for corporate tax rates instead of the higher PET rates increases the fixed energy component of the PPA price. The lower corporate tax rates decreases the total deferred taxes, which serve as a deduction to rate base. Consequently, this results in a higher average rate base over the life of the project and increases the cost of service. Late Filed Exhibit No. 5, p. 1.

The Authority’s review of both public and non-public exhibits supports NuPower’s conclusion that using the statutory corporate income tax rates instead of the personal income tax rates would result in higher revenue requirements for CHP Project. The Authority’s analysis shows that revenue would increase by approximately $10.7 million from increases to rate base as a result of reductions to the deferred taxes. The offsetting reductions to income taxes only totaled approximately $4.3 million. Hence, the Authority accepts NuPower’s position to use personal income tax rates to calculate current and deferred income taxes.

3. Payroll Taxes

In its pro forma exhibits for calculating variable revenue requirements for the CHP Project, NuPower included the employees’ portions of Medicare tax of $36,250, and Social Security tax of $15,922 in its calculation of the total other taxes. Response to Interrogatory EL-7 Attachment, p. 2. Also, the Company included the employer’s portions of Medicare tax of $36,250, and Social Security tax of $15,922. Id. NuPower does not and will not have any employees. Tr. 3/27/19, pp. 142. NuPower LLC has only two members or principals. Id. The Company confirmed that the maximum Social Security wage of $256,800 and Medicare wage of $2.5 million are for two employees and that the $2.5 million Medicare wage represents estimated cash outflow. Id., p. 143.

Based on the Authority’s inquiry, UI testified that it has never included employee portions of the payroll taxes in rate case applications. Late Filed Exhibit No. 3.

The Authority concludes that the cash outflow of $2.5 million upon which both the employee’s and employer’s portions of the proposed payroll taxes are calculated represents below the line distributions to the two members of NuPower LLC. Generally, self-employed person pays the entire 15.3% for Medicare and Social Security taxes, but half of these taxes are the employer’s portions, which are allowed as above-the-line deductions. In other words, the two NuPower’s members would deduct as a self- employment tax expense half of the 15.3% in their personal income tax returns. Therefore, the Authority concludes that NuPower should not include the non-deductive employee’s portions of the Medicare and Social Security taxes as business expenses recoverable from UI’s ratepayers.

4. Investment Tax Credits

In its pro forma exhibits, NuPower calculates and reduces income tax expenses by an annual total investment tax credits (ITC) of $650,700 over 20 years. Response to

Docket No. 18-08-14 Page 12

Interrogatory EL-7 Attachment, pp. 8 and 9. NuPower also calculates a maximum Internal Revenue Service (IRS) ITC of $14.49 million based on total capacity of 9.66 MW and ITC credit of $1.5 million per MW. Id.

The Authority takes issue with NuPower’s calculations of both the annual ITC amount and the IRS maximum ITC rate of $1.5 million per MW. The annual ITC deduction of $650,700 amounts to $13.014 million over 20 years and does not reflect 30% of the total reported gross plant of $69,132,244. Id., p. 7. Also, according to the United States Department of Energy, the tax credit cap for a qualified fuel cell energy property with a minimum capacity of 0.5 kW and an electricity-only generation efficiency of 30% or higher is $1,500 per 0.5 kW.3 As a result, the Authority finds that the annual ITC calculated by NuPower does not align with a qualified fuel cell property costing $69,132,244, or with total capacity of 9.66 MW.

5. Test Period Revenue

The PPA indicates that the Seller may sell and deliver to the Buyer or other third parties any energy and RECs produced by or associated with the Facility during the Test Period, which is defined as the period prior to the COD. Exhibit A, pp. 19, 29, and 30. The PPA also specifies that energy, RECs and capacity generated by or associated with the Facility during the Test Period not purchased by Buyer under Section 4.1 shall not be deemed Products. Id. p. 13. In response to an inquiry to UI regarding whether revenues that NuPower would generate during the test period would be credited ratepayers, UI appears to indicate that they would not. Tr. 3/27/19, pp. 54-55. UI states that the cost of service agreement starts at COD, and that the Test Period is outside of the scope of the 20 years allowed under Conn Gen. Stat. § 16-258e. Thus, costs incurred for any product purchased from NuPower, during the Test Period, will be essentially passed-through to customers. Id.

The Authority acknowledges the fact the PPA term will start subsequent to the Test Period. However, the capital costs and significant O&M expenses for the CHP Project that are recoverable from UI’s ratepayers would be incurred prior to the start of the PPA term. For a COS project, the Authority expects a clear stipulation that revenues earned during the Test Period by NuPower would either be used to mitigate the first year revenue requirement or reduce costs incurred prior to the start of the PPA term.

In its written exceptions, NuPower agreed that test period revenues for pre-COD costs should not be recovered again under the COS formula via the PPA. However, the Company claimed that it should retain revenues from costs incurred that are not recovered under the PPA and proposed a one-time 90-day post-COD compliance filing reconciling costs and revenues for test period. NuPower Written Exceptions, p. 19.

The Authority agrees that NuPower should be required to submit a post-COD compliance filing reconciling costs and revenues for test period. Any amount by which the revenues exceeded the test period costs should be credited to UI’s customers in NuPower’s first year fixed revenue requirements.

3 www.energy.gov/savings/business-energy-investment-tax-credit-itc

Docket No. 18-08-14 Page 13

6. Ongoing Process to Review COS Model

UI is authorized to seek recovery of all costs associated with the PPA, including all costs prudently incurred by UI to administer and enforce the PPA. In approving the PPA, the Authority acknowledges its responsibility to review (a) the pro forma COS model, including the capital cost of the facility, (b) the true-up between pro-forma and actual capital cost of the facility approximately 90 days after the facility’s COD, and (c) if necessary, review the annual actual revenue requirement if it exceeds the pro-forma revenue requirement for that year by greater than 5%.

The Authority will direct the PPA parties to submit a COS model for the actual capital cost of the Project for the 20-year term of the PPA, approximately 90 days after the facility’s COD. Further, the Authority will direct UI to submit any adjustments to the COS model in the applicable rate adjustment mechanism (RAM) proceeding.

B. FIRM CUSTOMER COMMITMENTS FOR THE THERMAL ENERGY

Conn. Gen. Stat. § 16-258e(a) includes a requirement that “the thermal energy produced by such combined heat and power system shall be subject to firm customer commitments to subscribe to thermal energy services from such thermal energy transportation company, as demonstrated by such thermal energy transportation company, for the term of the power purchase agreement entered into pursuant to this section.”

The PPA included terms which were meant to mirror the firm customer commitments requirement of the statute. Tr. 3/27/19, p. 77.

The following sections of the PPA specify the terms about thermal customer commitments:

 Section 3.1(a)(ii) requires that NuPower have a firm commitment from an off-taker for the thermal energy from the thermal loop for the term of the contract within 12 months of receiving approval from the Authority.

 Section 3.4(b) which, in relevant part, requires NuPower to construct the CHP system so that the facility “shall produce thermal energy that is subject to firm customer commitments to subscribe to thermal energy services from such thermal energy transportation company, as demonstrated by such thermal energy transportation company, for the term of [the PPA].”

 Section 7.2(n)(v) where NuPower affirms that the Facility, as defined in the PPA, “is subject to firm customer commitments to subscribe to thermal energy services for no less than the [term of the PPA].”

Application, Exhibit A (Public), pp. 16, 18, 36, and 38.

Docket No. 18-08-14 Page 14

According to the provisions of the PPA noted above, UI and NuPower established a milestone of one thermal energy customer commitment within 12 months of PPA approval. The remaining provisions simply mirror the statutory language requiring firm customer commitments. UI provided little guidance on how it would administer these provisions of the PPA, other than to say that it might require at least two firm commitments and to the extent that it believed NuPower did not meet these threshold requirements, then it would bring the matter before the Authority. Tr. 3/27/19, pp. 80 and 81. UI stated that it would accept guidance from the Authority on how to further enforce this requirement. Id., p. 78.

NuPower first provided a letter of intent, and later a signed contract, for some portion of the expected thermal energy from the CHP system with Approved Storage and Waste Inc. NuPower Reply Brief, Attachment A. NuPower appears to deem this lone contract as satisfying the firm commitments statutory requirement. Tr. 3/27/18, p. 188. NuPower stated further that it had additional potential customers to which it was marketing. Tr. 3/27/19 pp. 104, 127 and 128. NuPower has had discussions with the University of Bridgeport to develop a contract for the thermal energy; the University of Bridgeport thermal demand is large enough to utilize all of the potential thermal energy provided by the CHP system. Id., p. 125. Indeed, the Authority received letters expressing interest in the thermal loop from potential customers including the University of Bridgeport and The Windward Apartments. University of Bridgeport Letter dated June 12, 2019; CT Community Renewal Associates Letter dated June 18, 2019.

The BETP argued that the PPA was prematurely filed since, at the time, NuPower did not provide any firm commitments and thus does not meet the statutory requirement for firm commitments. BETP Brief, p. 9. BETP further argued that since no firm customers are known, the Authority cannot evaluate the whether the location of the fuel cell maximizes the efficiency of the thermal energy. Id.

The statutory language specifies only that there must be firm commitments for the term of the PPA. Since the statutory language does not specify either the required number of firm customer commitments or the required amount of thermal energy for any and all commitments, the Authority will use its discretion to determine what requirements are reasonable given the evidence at hand.

The only PPA term that addresses firm customer commitments as a practical matter is the milestone in Section 3.1(a)(ii) that requires one “off-taker” within 12 months of Authority approval. Application, Exhibit A (Public), p. 16. It appears to the Authority that NuPower has satisfied that requirement of the PPA in the signed agreement with Approved Storage and Waste, Inc. NuPower Reply Brief, Attachment A.

The question remains what level of thermal energy offtake is sufficient to satisfy the statutory requirement for firm customer commitments and whether the one contract with Approved Storage and Waste Inc. does just this. Indeed, it is already clear NuPower and UI differ in their interpretation of the contract terms for meeting the firm customer commitments statutory requirement: UI stated that it might require more than one commitment to satisfy the statutory requirement, but NuPower believed that only one contract, even the one currently with Approved Storage and Waste Inc., satisfies the statute. Tr. 3/17/19, 80, 81, and 188; NuPower Reply Brief, p. 21.

Docket No. 18-08-14 Page 15

The Authority finds that it is not in the long term interest of ratepayers to leave this question unanswered, especially since there is no common understanding between UI and NuPower. Therefore, the Authority will establish a clear standard by which to evaluate whether NuPower meets the requirements of the statute.

As the Authority noted above, the statute establishes only the requirement that there be firm customer commitments for the term of the PPA. While providing no further guidance about the quantity of thermal energy, the statute does indicate that its purpose is to evaluate district heating systems in furtherance of the Comprehensive Energy Strategy (CES). The Authority finds that the main benefit to ratepayers from this project is the advancement of the CES, which in this instance relates to meeting the state’s greenhouse gas emission reductions targets specified in Conn. Gen. Stat. § 22a-200a. This matches the main benefits proposed by NuPower itself: to develop and evaluate a district heating system’s capability to reduce both natural gas demand and greenhouse gas emissions. Application, Exhibit D (Public), pp. 4 and 5.

To evaluate district heating systems and their ability to reduce greenhouse gas emissions and natural gas demand requires actual thermal loop customers to offtake the thermal energy from the CHP system.

The Levitan analysis projected the direct carbon dioxide emissions of the facility over 20 years at 565,019 tons. Application, Exhibit B (Public), p. 3. The Levitan analysis compared an estimate of the avoided carbon dioxide emissions from the fuel cell displacing other New England generation sources based on projections over 20 years of the New England generation fleet and its expected emissions. Id. The expected avoided carbon dioxide emissions over 20 years was estimated at 544,940 tons. Id. Therefore, over the life of the PPA, and making assumptions that the generation fleet will reduce its carbon emissions profile over 20 years, Levitan projected that the fuel cell will result in a 20,079 ton increase in carbon dioxide. Id.; Response to Interrogatory EL-18. Converting from tons to metric tons (1 metric ton = 1.1 tons) gives projected fuel cell direct emissions of 513,654 metric tons (565,019 / 1.1), expected avoided emissions of 495,400 metric tons (544,940 / 1.1), and results in an increase in 18,254 metric tons of emissions. This estimate does not factor in potential carbon emissions reductions from the thermal loop.

NuPower submitted annual greenhouse gas emissions profiles for both the fuel cell and the thermal energy for the thermal loop. The emissions profile for the fuel cell alone was developed by Doosan and estimated two emissions profiles, one based on existing regional generation fleet as it existed in 2010, and one based on existing regional generation fleet as it existed in 2016. Supplemental Response to Interrogatory EL-18, Doosan Attachment and Ramboll Attachment. NuPower provided emissions profiles for the thermal loop with the assumption that all of the thermal energy from the fuel cell is being used. Id. The Table below displays annual emissions profiles as estimate by Levitan, Doosan and the Ramboll Group.

Docket No. 18-08-14 Page 16

Annual Predicted Emissions Profiles for Fuel Cell and Thermal Loop Direct Avoided Net Emissions Emissions Emissions (m. tons) (m. tons) (m. tons) Fuel Cell (Levitan)4 25,683 (24,770) 913 Fuel Cell (Doosan – regional fleet in 2010) 39,837 (53,967) (14,130) Fuel Cell (Doosan – regional fleet in 2016) 38,026 (47,584) (9,558) Thermal Loop at 100% capacity offtake5 n/a (7,925) (7,925) Application, Exhibit B, p. 3; Supplemental Response to Interrogatory EL-18.

Neither UI nor NuPower could comment with any authority on Levitan’s emissions calculations, but relied on Levitan’s expertise. Tr. 3/27/19, p. 15; Response to Interrogatory EL-18.

The Authority accepts that the scenarios above present a reasonable range within which to expect net negative or net positive CO2 emission reductions from the project. On one end of the spectrum, ratepayers are faced with a scenario of funding a project that results in a net increase in CO2 emissions (according to the Levitan analysis) if 10% or less of the thermal energy is utilized in the thermal loop.

NuPower has argued that Levitan’s assumptions regarding the change in renewable generation percentage of the fleet are questionable and that it is more reasonable to apply existing fleet profiles to evaluate the benefits of their program. NuPower Brief, pp. 12 and 13. The Authority finds the argument has some merit, but notes that using existing regional fleet instead of projected fleet characteristics, is just as questionable. This is obvious when comparing the avoided emission profiles of the 2010 and 2016 existing regional generation fleet noted in the Table above: the regional fleet has already shown a substantial change in emissions reductions.

The risk that UI ratepayers may fund an expensive project that increases emissions is exacerbated since there is only one small contract to date and that no district heating or thermal loop infrastructure exists. Tr. 3/27/19, pp. 122 and 127.

Therefore, the Authority finds that more thermal energy, whether a pilot program or not, must be subject to firm customer commitments before the Authority grants approval to help mitigate the risk of a UI ratepayer funded project increasing carbon emissions.

The Authority has considered the arguments made by NuPower in its Written Exceptions about the consequences of requiring the condition that firm customer commitments not less than 75% of the thermal energy be demonstrated by March 31, 2020. Proposed Final Decision, p. 16; NuPower Written Exceptions, p. 17. The Authority

4 For ease of comparison Levitan’s 20 year emissions profile was converted to an annual figure by dividing the figures by 20. 5 Ramboll provided the emissions in annual avoided carbon dioxide at 8,717 tons. Supplemental Response to Interrogatory EL-18, Ramboll Attachment. Converting that number to metric tons gives 7,925 metric tons (8,717 / 1.1).

Docket No. 18-08-14 Page 17 finds merit in NuPower’s assertion that these requirements may limit the potential customer base for the thermal energy and may introduce other unintended disadvantages. Id. Nevertheless, the Authority finds that the current level of firm customer commitments in the form of the one contract with Approved Storage and Waste Inc. is not sufficient to meet the statutory requirement that the project is in the long-term interest of the ratepayers.

Accordingly, to ensure that the project is in the interest of ratepayers, and to ensure that thermal loop can be evaluated, the Authority conditionally approves this PPA upon UI submitting for Authority review and approval a revised PPA that requires NuPower to demonstrate firm customer commitments for not less than 50% of the total annual thermal energy output no later than two (2) years from COD; such requirement shall continue for the duration of the PPA. Failure to meet this requirement shall be considered an Event of Default by Seller under Section 9.2, which the Seller shall be given one hundred twenty (120) days to cure.

No later than two years from COD, the Authority will require NuPower to submit a compliance filing demonstrating compliance with this condition, including copies of contract(s) signed by thermal energy customer(s) and the thermal energy transportation company. The contracts must provide a similar level of detail for the thermal offtake as demonstrated in the Letter of Intent that NuPower signed with Approved Storage and Waste Inc., especially pertaining to the details for the thermal offtake. Letter of Intent dated December 12, 2018, filed January 17, 2019. The level of detail must be sufficient to demonstrate to the Authority the exact the minimum annual thermal energy offtake and the daily and hourly thermal energy offtake requirements.

The Authority will require additional information from NuPower in order to evaluate the thermal loop and its ability to further the CES in distressed communities and its long- term benefit to UI ratepayers. Accordingly, NuPower will be required to submit to the Authority annual filings no later than one year following the COD of the Facility. The information requested will show the number of contracts signed, the thermal offtake contracted for, and the actual thermal energy delivered.

C. ELECTRIC DISTRIBUTION SYSTEM INTERCONNECTION COSTS

NuPower proposed an $8 million electrical interconnection cost to interconnect the project to UI’s distribution system. Response to Interrogatory EL-7, Attachment (Public), p. 3. All electrical interconnection costs will be passed through to electric customers through the COS model. Tr. 3/27/19, p. 65. This estimate was based on an initial projection from UI that included a cost range from minus 50% to plus 200%, or $4 to $24 million. Tr. 3/27/19, p. 35. According to UI, the upper bound on the costs are high because of all the uncertainty that could influence interconnection costs. The estimate was based on a review of circuit maps and did not include any detailed studies, field investigations, or a consideration of any adverse construction conditions such as the serviceability of existing facilities such as manholes, duct lines, and poles. Id., p. 33 and 36. System operating conditions such as voltage regulation at substations and thermal conditions in underground ducting, might also influence the interconnection costs. Id., p. 30. Other added costs might include city construction requirements that might require overtime

Docket No. 18-08-14 Page 18 work, area congestion, and the amount of underground and overhead work. Id., p. 87. All of these factors contribute to the large uncertainty surrounding interconnection costs.

UI must first receive a completed application to interconnect and a signed and paid for study agreement before it conducts the Impact Study. Id., pp. 26 and 27. UI had received an initial application from the equipment manufacturer prior to June 2018. UI Response to Interrogatory EL-4. By June 2018, UI indicated to NuPower and the manufacturer that it needed clarification about the application and that it needed additional operating information about generator to properly model its impact to the distribution system. Id.; Tr. 3/27/19, pp. 25 and 26. UI had not received completed application materials as of March 2019, and so had not begun the Impact Study by that time. Id., p. 26. Once the Impact Study is completed, UI would then conduct a Facilities Study to develop a detailed budgetary estimate. Id., pp. 27 and 28. Estimates from Facilities Studies typically have an uncertainty range of plus and minus ten to twenty percent. Id., p. 35. Impact studies typically take 30 business days to conduct. Id., p. 27. Facilities Studies take at least 30 business days to complete, which will increase with the increase of complexity of the study. Id., pp. 29 and 36.

In its Written Exceptions, NuPower insists that the Authority has overstated the risk for exceeding the proposed interconnection costs and urges the Authority to grant approval of the interconnection estimate as a separate pass through expense that is fully recoverable as proposed in the Application. NuPower Written Exceptions, pp. 20 and 21. The Authority rejects this claim and refers to the Authority’s findings above. The Authority continues to be concerned with these cost uncertainties. The PURA notes again that it is the ratepayers of UI that bear the interconnection cost overruns if the Authority were to grant approval of the interconnection estimate at this stage. The Authority finds this proposition unacceptable at this time and reminds NuPower that it inquired about the status of the distribution interconnection process and found that this process had been stalled due to NuPower not providing UI a complete interconnection application since the summer of 2018. Tr. 3/27/19, pp. 25 and 26. The Authority does not deem it reasonable that UI ratepayers should bear the risk of the interconnection cost overruns at this time.

The Authority finds that it is not in the interest of ratepayers to authorize interconnection costs that have such a large degree of uncertainty. Accordingly, the Authority defers making a final determination regarding cost recovery of interconnection costs until (1) a Facilities Study has been completed and submitted to the Authority, and (2) a revised estimate of interconnection costs is submitted for review and approval. The Authority directs UI to complete and submit to the Authority a Facilities Study by December 31, 2019. If a Facilities Study has not been completed by UI at that time, the Authority will require UI to file for an extension for submission for good cause shown. The Authority also directs NuPower to submit, no later than 30 days following UI’s submission of the Facilities Study, an updated interconnection cost estimate and cost recovery proposal based on UI’s Facilities Study. After receiving UI’s and NuPower’s compliance filings, the Authority will make a final determination regarding NuPower’s cost responsibility and cost recovery for interconnection costs.

To keep apprised of the distribution interconnection process and to ensure it is undertaken in a timely manner, the Authority directs NuPower and UI to provide monthly

Docket No. 18-08-14 Page 19 updates on the status of the interconnection process. At a minimum, the updates must include the following:

1. Current status: current study being undertaken or if the project is on hold. If the process is on hold, an explanation for the hold must be included. 2. Whether a completed application has been submitted and payment received by UI. 3. The length in business days it has taken to perform each study to date, including completed and active studies. 4. An explanation for any studies that have exceeded a thirty (30) business day window. 5. A list and description of any communications between UI and NuPower about the interconnection process for the preceding month.

D. GAS FACILITIES

The Southern Connecticut Gas Company (Southern) will build the natural gas distribution facilities necessary to serve the proposed fuel cell. Southern will provide service to the fuel cell facility under Rate Large General Service System Expansion (LGS- SE), for firm customers with an annual consumption equal to or greater than 30,000 ccf a year. Under Rate LGS-SE, customers can either elect to receive commodity service from Southern or a Third Party Supplier, as required under the tariff. Rate LGS-SE is a firm service tariff for all new commercial or industrial customers that qualify and began receiving service after January 1, 2014. Under that tariff, Southern commits to provide firm service 24 hours a day, 365 days a year at the contracted maximum Daily Quantity of gas and at the rates listed in the LGS-SE tariff.

Southern proposes to build 17,000 feet of 12” welded steel with a 199 psi maximum allowable operating pressure (MAOP) to provide the required capacity in the distribution system to support the daily and peak day demand of the fuel cell facility. Southern defines the proposed project as a system enhancement project that will provide additional capacity to the Housatonic Avenue regulator station, where the existing system has a MAOP of 60 psi. The existing distribution system served from that regulator station has enough capacity to serve an additional demand of 1,200 cfh. Any additional demand above 1,200 cfh, without a system enhancement project would lower pressures in the distribution system to unsustainable pressures. Southern’s Response to Interrogatory EN-5.

Southern’s proposed enhancement project would add approximately 147,000 cfh of additional capacity to the Bridgeport distribution system to serve customers’ design peak day demands. The fuel cell will consume 84,000 cfh, which equals 2,089 MMBtus/d of capacity. The existing system has 1,200 cfh of unused capacity remaining to serve future customers’ demands. Once the enhancement project is complete and the fuel cell facility is connected to the distribution system, 64,200 cfh (147,000 cfh – 84,000 cfh + 1,200 cfh) of capacity will be available to serve future customer growth in addition to the fuel cell. Southern’s Response to Interrogatory EN-5.

Based on the map Southern provided, the proposed 199 psi distribution main will parallel the existing 600 psi distribution main from the Coram Lane gate station to the

Docket No. 18-08-14 Page 20 existing regulator station on Housatonic Avenue. At that station, the gas pressure will be reduced from 199 psi to 60 psi and injected into the existing local distribution system to provide the required gas supply. Southern’s Response to Interrogatory EN-05, Attachment 1.

The fuel cell will consume 2,089 MMBtus/day of primary firm design peak day capacity supplied through Southern’s existing gas supply and capacity portfolio. Primary firm capacity is required to meet the operational requirements of the fuel cell and to ensure that its fuel source is uninterrupted, in accordance with the tariff. The gas will flow via the Tennessee Gas Pipeline Company (Tennessee) through the Coram Lane gate station in Milford. Southern indicated that it has more than enough primary firm design peak day capacity on Tennessee and through that gate station to supply the additional demand from the fuel cell. Southern’s Response to Interrogatory EN-6.

Southern has not performed a detailed construction cost analysis, but estimates the construction costs to be $6.6 million. NuPower would be required to pay a $1.6 million contribution-in-aid-of-construction (CIAC). Response to Interrogatory EL-16. Under Southern’s LGS-SE tariff, NuPower has the right to ask Southern to recalculate the Hurdle rate if the fuel Cell facility adds new equipment or new gas services are directly added to the portion of main supported by the customer’s CIAC. However, Southern testified that since the construction of the new main project is a 199 psi reinforcement project to bring additional capacity to the Housatonic Ave regulator station, the company does not intend to connect any new customers to that 199 psi main. Southern’s Response to Interrogatories EN-3 and EN-4.

The Authority reviewed Southern’s responses in the instant proceeding and finds that the construction of the 199 psi MAOP main will add enough capacity in the system to allow the fuel cell to run uninterrupted under a firm service tariff. Further, the Authority agrees that Southern will have sufficient interstate pipeline capacity in its gas supply portfolio to provide primary design peak day capacity for the fuel cell. Finally, the Authority finds that the $1.6 million CIAC that Southern requires NuPower to pay is proper because it will reduce the capital costs in the Hurdle Rate Model so that there is a positive net value over the 25 year analysis period.

IV. FINDINGS OF FACT

1. NuPower proposed a post-tax WACC of 10.38%.

2. The Company proposed a capital structure that is 50:50 debt to equity.

3. The Company proposed long-term debt rate of 5.75% and ROE rate of 15%.

4. In the Millstone Interim Decision, the Authority accepted 13.4% as a reasonable ROE for a hypothetical merchant natural gas plant based on the ISO-NE’s Net CONE Study.

5. NuPower claims that the Millstone Interim Decision provided additional support for its proposed 15% ROE for the fuel cell project. Id.

Docket No. 18-08-14 Page 21

6. NuPower claims that the estimated ROE for its fuel cell project under building- block approach is 21.90%.

7. The ROE for GenConn peaking COS contract is 10.75.

8. The NuPower CHP project would never be exposed to wholesale market risks, nor reliant on market revenues to meet its operating costs and returns on and of capital investments.

9. The Millstone Interim Decision did not call for a ROE determined by building up a CAPM ROE for risks already reflected in the MRP.

10. A merchant operation is a situation in which a resource is selling its output into the wholesale market and is reliant on revenues realized through those sales to meet its operating costs and return requirements.

11. The Millstone nuclear facilities are existing resources contemplating submitting a de-list bid in FCA.

12. NuPower’s “building-block” ROE method, is not an acceptable method for evaluating the cost of capital or making alternative investment decisions.

13. The ROE proposed for the Mystic units 8 and 9 is 10.26%.

14. EEI 2018 Financial Update shows that electric utilities filed 12 new rate reviews in the third quarter of 2018; and the average requested ROE was 10.25% and the average awarded ROE was 9.53%.

15. The three fuel cell projects in the RCP Reconsideration Decision are allowed UI’s allowed distribution ROE plus 25 basis points.

16. For current and deferred income taxes, NuPower applied the top Federal personal income rate of 37% and Connecticut PET rate of 6.99%.

17. The lower corporate tax rates decreases the total deferred taxes, which serve as a deduction to rate base.

18. Using corporate tax rates would result in a higher average rate base over the life of the project and increase the cost of service.

19. NuPower included the employee’s portions of Medicare tax of $36,250, and Social Security tax of $15,922 in its calculation of the total other taxes.

20. NuPower also included the employer’s portions of Medicare tax of $36,250, and Social Security tax of $15,922.

21. NuPower does not and will not have any employees.

22. NuPower LLC has only two members or principals.

Docket No. 18-08-14 Page 22

23. The Company confirmed that the maximum Social Security wage of $256,800 and Medicare wage of $2.5 million are for two employees and that the $2.5 million Medicare wage represents estimated cash outflow.

24. UI testifies that it has never included employee portions of the payroll taxes in rate case applications.

25. NuPower calculates and reduces income tax expenses by an annual total ITC of $650,700 over 20 years.

26. NuPower calculates maximum IRS ITC of $14.49 million based on total capacity of 9.66 MW and ITC credit of $1.5 million per MW.

27. The total ITC amount is 30% of the total reported gross plant addition.

28. The IRS maximum ITC rate is $1.5 million per MW.

29. The PPA indicates that the Seller may sell and deliver to the Buyer or other third parties any energy and RECs produced by or associated with the Facility during the Test Period.

30. The Test Period is defined as period prior to the COD.

31. Energy, RECs, and capacity generated by or associated with the Facility during the Test Period are not be deemed as Products under the PPA.

32. The capital costs and O&M expenses for the CHP Project are recoverable from UI’s ratepayers.

33. The PPA included terms which were meant to mirror the firm customer commitments requirement of the statute.

34. Section 3.4(b) which, in relevant part, requires NuPower to construct the CHP system so that the facility “shall produce thermal energy that is subject to firm customer commitments to subscribe to thermal energy services from such thermal energy transportation company, as demonstrated by such thermal energy transportation company, for the term of [the PPA].”

35. Section 7.2(n) where NuPower affirms that the CHP system “is subject to firm customer commitments to subscribe to thermal energy services for no less than the [term of the PPA].”

36. UI and NuPower established a milestone of one thermal energy customer commitment within 12 months of PPA approval and a mirroring of statutory language that requires firm commitments.

37. UI has committed to bring customer commitment matters before the Authority.

Docket No. 18-08-14 Page 23

38. UI has committed to seek and accept guidance from the Authority on how to enforce the firm customer commitment requirement.

39. NuPower filed a signed contract for some portion of the expected thermal energy from the CHP system with Approved Storage and Waste Inc.

40. NuPower proposed an $8 million electrical interconnection cost to interconnect the project to UI’s distribution system.

41. The interconnection cost estimate was based on an initial projection from UI that included a cost range from minus 50% to plus 200%, or $4 to $24 million.

42. The interconnection estimate was based on a review of circuit maps and did not include any detailed studies, field investigations, or a consideration of any adverse construction conditions such as the serviceability of existing facilities like manholes, duct lines, and poles.

43. System operating conditions, such as voltage regulation at substations and thermal conditions in underground ducting, influence the interconnection costs.

44. Added interconnection costs might include city construction requirements that might require overtime work, area congestion, and the amount of underground and overhead work.

45. UI must first receive a completed application to interconnect before it conducts the Impact Study.

46. UI had not received completed application for interconnection to the distribution system as of March 2019.

47. UI conducts the Facilities Study after the Impact Study to develop a detailed budgetary estimate. Estimates from Facilities Studies typically have an uncertainty range of plus and minus ten to twenty percent.

48. Impact studies typically take 30 business days to complete and Facilities Studies take a minimum 30 business days to complete.

49. Southern proposes to build 17,000 feet of 12” welded steel with a 199 psi MAOP to provide the required capacity in the distribution system to support the daily and peak day demand of the fuel cell facility.

50. NuPower would be required to pay a $1.6 million CIAC.

51. Southern indicated that it has more than enough primary firm design peak day capacity on Tennessee and through the Coram Lane gate station to supply the additional demand from the fuel cell.

Docket No. 18-08-14 Page 24

V. CONCLUSION AND ORDERS

A. CONCLUSION

After review, the Public Utilities Regulatory Authority conditionally approves the request of The United Illuminating Company to enter into a PPA with NuPower Bridgeport FC, LLC for a combined heat and power district energy project in Bridgeport, Connecticut.

B. ORDERS

For the following Orders, the Company shall submit one original of the required documentation to the Executive Secretary, 10 Franklin Square, New Britain, Connecticut 06051 and file an electronic version through the Authority’s website at www.ct.gov/pura. Submissions filed in compliance with the Authority’s Orders must be identified by all three of the following: Docket Number, Title and Order Number. Compliance with orders shall commence and continue as indicated in each specific Order or until the Company requests and the Authority approves that the Company’s compliance is no longer required after a certain date.

1. No later than November 1, 2019, UI shall submit a revised PPA for the Authority’s review and approval that incorporates the modifications to the thermal energy offtake provisions articulated in Section III.B, which are a condition of this Decision.

2. No later than December 31, 2019, UI shall submit a Facilities Study for Authority review and approval. UI shall not sign and execute the PPA until the Authority makes a determination regarding NuPower’s electrical interconnection cost responsibility and recovery. If UI cannot complete the Facilities Study by December 31, 2019, it may request an extension for submission of the Facilities Study for good cause shown. No later than 30 days following UI’s submission of the Facilities Study, NuPower shall submit to the Authority an updated interconnection cost estimate and cost recovery proposal based on UI’s Facilities Study.

3. No Later than the first business day of each month, starting November 1, 2019 and ending with the final submission of NuPower’s filing in Order No. 2 above, UI and NuPower shall individually submit monthly updates on the status of the interconnection process as detailed in Section III.C. Electric Distribution System Interconnection Costs.

4. No later than two years following the COD of the facility, NuPower shall submit to the Authority firm customer commitment(s) for not less than 50% of the total annual thermal energy capacity.

5. No later than 90 days following the COD of the facility, NuPower shall file with the Authority an exhibit reconciling costs and revenues for the test period. The filing shall indicate if the revenues exceeded the test period costs and if so, NuPower shall credit such excess amount to customers in its first year fixed revenue requirements.

Docket No. 18-08-14 Page 25

6. No later than 90 days following the COD of the facility annual filings thereafter, NuPower shall submit to the Authority worksheet(s) detailing the Project’s COS model for the actual capital cost of the facility for the 20-year term of the PPA. The filing shall also include worksheet(s) showing the truing-up of the projected capital and operating costs to actuals.

7. In its annual RAM filings following the COD of the facility and each annual filings thereafter, UI shall include worksheet(s) showing the calculation of the actual annual revenue requirement (ARR) for the NuPower facility and attest that the ARR did not exceed the pro-forma revenue requirement for that year by more than 5% based on NuPower’s COS annual filing required by Order No. 4.

8. No later than one year following the COD of the Facility and continuing annually for the full term of the PPA, NuPower shall file with the Authority the following information regarding the firm customer commitments for the thermal energy:

a. A list of total number of contracts with customers signed to date; b. Total annual and daily thermal energy contracted with each customer; c. Total annual thermal energy delivered for each year of the contract; d. Average daily and hourly thermal energy delivered for the preceding twelve month period; and e. An explanation for any thermal delivery shortfall from the preceding twelve month period.

DOCKET NO. 18-08-14 PURA REVIEW OF THE COMBINED HEAT AND POWER PROJECT SOLICITATION PURSUANT TO CONN. GEN. STAT. SECTION 16-258e

This Decision is adopted by the following Commissioners:

John W. Betkoski, III

Michael A. Caron

CERTIFICATE OF SERVICE

The foregoing is a true and correct copy of the Decision issued by the Public Utilities Regulatory Authority, State of Connecticut, and was forwarded by Certified Mail to all parties of record in this proceeding on the date indicated.

October 2, 2019 Jeffrey R. Gaudiosi, Esq. Date Executive Secretary Public Utilities Regulatory Authority

PureCell® Model 400

PURECELL SYSTEM BENEFITS PURECELL SYSTEM COMPETITIVE ADVANTAGES

Energy Security Long Life Grid-Independence Proven PAFC fuel cell technology that is Industry leading 10-year cell stack life Proven performance delivering power setting durability records assures high availability and low service cost when the utility grid fails

Energy Productivity Modular & Scalable Load Following Increased efficiency and continuous Solutions for multi-megawatt applications to Capable of dispatching power to match on-site generation reduces meet growing energy demand building needs energy costs Experience Small Footprint

Energy Responsibility Most knowledgeable and experienced team Highest power density among clean in the industry generation technologies Ultra-low emissions equals sustainability High Efficiency Flexible Siting Up to 90% total CHP Efficiency Indoor, outdoor, rooftop, multi-unit

RATED POWER OUTPUT: 460KW, 480VAC, 50/60HZ FUEL Supply...... Natural Gas Operating Mode Inlet Pressure ...... 10 to 14 in. water (2.5 - 3.5 mbar) Characteristic Units Power Eco 460kW 440kW EMISSIONS3,4 1 Electric Power Output kW/kVA 460/532 440/518 NOx ...... 0.02 lbs/MWh (0.009 kg/MWh) Electrical Efficiency %, LHV 43% 45% CO ...... 0.01 lbs/MWh (0.005 kg/MWh) Peak Overall Efficiency %, LHV 90% 90% VOC ...... 0.01 lbs/MWh (0.005 kg/MWh) 1 Gas Consumption MMBtu/h, HHV (kW) 4.09 (1,200) 3.77 (1,104) SO2...... Negligible Gas Consumption1,2 SCFH (Nm3/h) 3,995 (107) 3,674 (98.4) Particulate Matter...... Negligible High Grade Heat Output CO 1 (electric only) ...... 998 lbs/MWh (454 kg/MWh) MMBtu/h (kW) 0.72 (212) 0.55 (162) 2 1 5 @ up to 250°F (with High-Grade heat recovery) ...... 815 lbs/MWh (371 kg/MWh)

Low Grade Heat (with full heat recovery) ...... 485 lbs/MWh5 (220 kg/MWh) Output @ up to 140°F1 MMBtu/h (kW) 1.03 (301) 1.00 (292) OTHER Ambient Operating Temp ...... -20°F to 104°F (-29°C to 40°C) Relative Humidity …………………………………………………………… 0 to 100% Sound Level ...... <65 dBA @ 33 ft. (10m) Water Consumption ...... None (up to 86°F (30°C) Ambient Temp.)

Water Discharge ...... None (Normal Operating Conditions) CODES AND STANDARDS ANSI/CSA FC1-2014: Stationary Fuel Cell Power Systems UL1741 SA: Inverters for Use With Distributed Energy Resources NOTES 1. Average performance during 1st year of operation. 2. Based on natural gas higher heating value of 1025 Btu/SCF (40.4 MJ/Nm3) 3. Emissions based on 440 kW operation. 4. Fuel cells are exempt from air permitting in many U.S. states.

5. Includes CO2 emissions savings due to reduced on-site boiler gas consumption

Doosan Fuel Cell America, Inc. Corporate Headquarters 195 Governor’s Highway South Windsor, CT 06074 860.727.2253 www.doosanfuelcellamerica.com email: [email protected] The manufacturer reserves the right to change or modify, without notice, the design or equipment specifications without incurring any obligation either with respect to equipment previously sold or in the process of construction. The manufacturer does not warrant the data on this document. Copyright © 2019 by Doosan Fuel Cell America, Inc. All rights reserved. This document contains no technical information subject to U.S. Export Regulations. Rev 11.2019 PureCell® Model 400

SYSTEM DIMENSIONS Power Module

Top View Side View Cooling Module PHYSICAL SPECIFICATIONS

Power Module Cooling Module Length 29’ 4” (8.95m) 15’ 11” (4.85m) Width 8’ 7” (2.62m) 7’ 10” (2.39m) Height 10’ (3.02m) 6’ 0” (1.83m) Weight 57,000 lb (27,216 kg) 3,190lb (1,447 kg) Top View Side View

PURECELL ADVANTAGE

OFFSET 3x MORE CO2 USE LESS LAND

CAPACITY FACTOR

CO2 OFFSET Doosan Fuel Cell America, Inc. Corporate Headquarters 195 Governor’s Highway South Windsor, CT 06074 860.727.2253 www.doosanfuelcellamerica.com email: [email protected] The manufacturer reserves the right to change or modify, without notice, the design or equipment specifications without incurring any obligation either with respect to equipment previously sold or in the process of construction. The manufacturer does not warrant the data on this document. Copyright © 2019 by Doosan Fuel Cell America, Inc. All rights reserved. This document contains no technical information subject to U.S. Export Regulations. Rev 11.2019 Doosan Fuel Cell America, Inc. Fuel Cell Emergency Response Guide

NuPower Bridgeport FC, LLC

600 Iranistan Ave

Bridgeport, CT 06605

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. DISCLAIMER

Doosan Fuel Cell America reserves the right to change or modify, without notice, the design or equipment specifications of the PureCell® system Model 400 without obligation with respect to equipment either previously sold or to be sold. This guide is provided by Doosan Fuel Cell America, and no liability will accrue to Doosan Fuel Cell America based on the information or specifications included herein. No warranties or representations are made by this guide and no warranties or representations shall apply to the equipment except as stated in Doosan Fuel Cell America’s standard terms and conditions of sale applicable at the time of purchase, a copy of which will be provided upon request. The Model 400 is designed to provide safe and reliable service when operated within design specifications, according to all applicable instructions, and with the appropriate operating materials. When operating this equipment, use good judgment and follow safety precautions to avoid damage to equipment and property or injury to personnel. Be sure to understand and follow the procedures and safety precautions contained in all applicable instructions, operating materials, and those listed in this guide. All information in this document is as of February 10, 2020.

Policy

The following plan has been developed to minimize the severity of damage to human health, the environment, and property in the event of an unexpected failure.

Scope

This Emergency Response Guide shall be integrated into the site Emergency Response Plan. Information contained in this document is customized to meet local requirements and shall be shared with local responders as necessary. This guide in no way assumes or transfers liability or ownership. Doosan Fuel Cell America should be contacted if clarification is needed.

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. Emergency Contacts and Numbers

Local Emergency Number 911

Doosan Fuel Cell America Control Center (860) 727-2847

City of Bridgeport Fire Department Fire Department – Non-emergency number (203) 337-2070

Bridgeport Hospital Hospital – Non-emergency number 267 Grant St.

Bridgeport, CT 06610

Electric Utility Name: United Illuminating 800-722-5584

Gas Utility 888-268-2887

Name: Southern Ct. Gas *Gas Leaks Only: 800-513-8898

Local Oil & Chemical Spill Response Division 800-645-8265

Connecticut Oil & Chemical Spill Response Division 860-424-3338

EPA - Environmental Protection Agency Region 1 (800) 424-8802 Environmental Emergency

OSHA - Occupational Safety and Health Admin. (800) 321-6742 National Emergency Number Emergency Number

Poison Control Center (800) 222-1222 National Emergency Number

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. Fuel Cell Hazard Overview

Front Back

Rear View Front View 480 V Grid Disconnect

480 V Grid Emergency Disconnect Stop Button

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. Rear View Panel Primary Hazard Front View Panel Primary Hazard 1 (Computer Electrical = 120 VAC 12 (Reformer) Electrical = 480 VAC Terminal) Chemical = Air sensitive catalyst / combustibles Thermal = 600°F Reformer Pressure = 150 psi steam 2 (Swing Door) Electrical = 480 VAC 13 (Reformer) Electrical = 480 VAC Chemical = Air sensitive catalyst / combustibles Thermal = 600°F Reformer Pressure = 150 psi steam 3 (Mechanical Electrical = 480 VAC 14 (Reformer) Electrical = 480 VAC Entry) Chemical = Propylene Glycol Chemical = Air sensitive catalyst / combustibles Thermal = 350°F Steam Thermal = 600°F Reformer Pressure = 150 psi Steam Pressure = 150 psi steam 4 (Mechanical Chemical = Propylene Glycol 15 (DC Cell Stack) Electrical = 300 VDC Entry) Thermal = 350°F Steam Chemical = Solid phosphoric acid / combustibles Pressure = 150 psi Steam 5 (TMS) Electrical = 480 VAC 16 (DC Cell Stack) Electrical = 300 VDC Chemical = Propylene Glycol / Deionized Water / Chemical = Solid phosphoric acid / combustibles Resin Thermal = 350oF Steam Pressure = 150 psi Steam 6 (ILS) Electrical = 480 VAC 17 (DC Cell Stack) Electrical = 300 VDC Chemical = Air sensitive catalyst / combustibles Chemical = Solid phosphoric acid / combustibles Thermal = 600°F Reformer Pressure = 150 psi steam 7 (Fuel Electrical = 480 VAC 18 (DC Cell Stack) Electrical = 300 VDC Processing Area) Chemical = Air sensitive catalyst / combustibles Chemical = Solid phosphoric acid / combustibles Thermal = 600°F Reformer Pressure = 150 psi steam 8 (Fuel Electrical = 480 VAC 19 (Grid Connect Electrical = 480 VAC Processing Area) Chemical = Air sensitive catalyst / combustibles Disconnect) Thermal = 600°F Reformer Pressure = 150 psi steam 9 (Gas/Nitrogen Chemical = combustibles 20 (ESM) Electrical = 1400 VDC / 480 VAC Inlet) 10 (Reformer) Electrical = 480 VAC 21 (Blower 110) Electrical = 300 VDC Chemical = Air sensitive catalyst / combustibles Mechanical = Blower Thermal = 600°F Reformer Pressure = 150 psi steam 11 (Reformer) Electrical = 480 VAC ALL Roof Panels Multiple Hazards Chemical = Air sensitive catalyst / combustibles DO NOT WALK ON ROOF! Thermal = 600°F Reformer Pressure = 150 psi steam

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. Conditional Assessment

Normal Condition Potential Abnormal Condition Response

Fuel Cell Dark colored smoke exiting chimney or 1. Establish safe perimeter any other part of enclosure 2. Contact Doosan Fuel Cell America Control Center (860) 727-2847 White steam exiting power plant at exhaust chimney, above panel #6 (It Observable fire or heavy smoke at any 1. Press Fuel Cell ‘Stop Button’ – Only if can be a large amount of white point on fuel cell safely accessible! steam depending on ambient conditions) 2. Dial 911 or Local Emergency Response Number

3. Establish safe perimeter

4. Contact Doosan Fuel Cell America Control Center (860) 727-2847

Fuel Cell Grinding or loud intermittent noises 1. Contact Doosan Fuel Cell America Control Center (860) 727-2847

Observable fire or heavy smoke at any 1. Press Fuel Cell ‘Stop Button’ – Only if Moderate humming, clicking and fan point on fuel cell safely accessible! sounds 2. Dial 911 or Local Emergency Response Number

3. Establish safe perimeter

4. Contact Doosan Fuel Cell America Control Center (860) 727-2847

Cooling Module Smoke or fire coming from module 1. Press Fuel Cell ‘Stop Button’ – Only if safely accessible!

2. Dial 911 or Local Emergency Fan humming Response Number

3. Establish safe perimeter

4. Contact Doosan Fuel Cell America Control Center (860) 727-2847

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. Grinding or loud noise coming from fans 1. Contact Doosan Fuel Cell America Control Center (860) 727-2847

Cooling Module Small leak dripping from joint, valve or 1. Contact Doosan Fuel Cell America connection Control Center (860) 727-2847

Medium to large leak 1. Follow local spill response protocol No leaking from cooling loop piping or contact Clean Harbors Emergency or coils Cleanup Response (800) 645-8265

2. Contact Doosan Fuel Cell America Control Center (860) 727-2847

Mechanical Hi/Lo Grade Piping Small leak dripping from joint, valve or 1. Contact Doosan Fuel Cell America connection Control Center (860) 727-2847

Medium to large leak 1. Follow local spill response protocol Small amounts of condensate or contact Clean Harbors dripping from piping Emergency Cleanup Response (800) 645-8265

2. Contact Doosan Fuel Cell America Control Center (860) 727-2847

Disconnects/Other Equipment Smoke or fire coming from equipment 1. Dial 911 or Local Emergency Response Number

2. Establish safe perimeter No leaks or smoke 3. Contact Doosan Fuel Cell America Control Center (860) 727-2847

Compressed Gas Manifold (N2/H2) Leaks – may be able to hear hissing sound. 1. If Indoors – Evacuate Immediately! Dial 911 or Local Emergency Response Number

No leaks, May hear intermittent gas 2. Establish safe perimeter flow during purges 3. Contact Doosan Fuel Cell America Control Center (860) 727-2847

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. Fuel Cell Related Safety Data Sheets (SDS)

1 Propylene Glycol – DowFrost® 2 Phosphoric Acid – Solid 3 Reformer/ILS Catalysts 4 Anion/Cation Resin 5 Nitrogen / Hydrogen Compressed Gas Mixture (non-flammable)

Inspections

Inspection Type Equipment Requirements Frequency Required General Maintenance Laptop, Service Vehicle Monthly General Housekeeping N/A Monthly Waste and Chemical Storage* N/A Weekly Internal Combustible Gas Monitor AT-160 Calibration Kit Annual Fire Prevention N/A Monthly

*When applicable

Fuel Cell operation is monitored and controlled remotely 24 hours a day 7 days a week by the Doosan Fuel Cell America Control Center. Upset or abnormal occurrences outside of normal operating parameters are immediately identified and service technicians are dispatched within 24 hours to respond when required.

Emergency Procedures

Alarms There are no audible or visual alarms on Fuel Cell. Alarm conditions are relayed immediately to the Doosan Fuel Cell America Control Center. The Doosan Fuel Cell America Control Center will then contact the appropriate site personnel on the site’s emergency contact list. Emergency Shut Down Onsite Actuate Fuel Cell Stop Button Emergency Area Egress - Gas Odor Evacuate 330 Feet in all directions Emergency Area Egress - Fire Evacuate 330 Feet in all directions – CV000 automatic natural gas supply shut off Emergency Egress - General Fuel cell is unmanned remotely monitored and controlled. No Doosan Fuel Cell America employees attending unit unless service or maintenance is required.

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. Signage and labeling

Perimeter fencing will have signage clearly identifying that “No smoking, no ignition sources” on every side of the fence. Signage will be similar to the sign below:

General:

Safety Hazard Analysis

The PureCell® Model 400 fuel cell system has been designed to meet strict ANSI/CSA safety standards to protect against risks from electrical, mechanical, chemical, and combustion safety hazards. The following items are a few of the safety measures incorporated into the design.

Fire Detection and Protection:

The power plant design incorporates a combustible gas sensor as well as thermal fuses located throughout the power module cabinet to detect fire. The detection of a potential flammable gas mixture, a fire, or the failure of this detection circuit will result in a power plant shutdown and a subsequent inert gas (nitrogen) purge of the fuel cell stack and fuel processing system. This event will also result in an alarm callout notification to Doosan Fuel Cell America service personnel. The power plant is designed with an integral emergency-stop button on the outside of the enclosure to enable immediate shutdown in the event of an emergency. There is also a gas shut-off valve and electrical disconnect switch easily accessible to emergency personnel. There are no restrictions for type of fire suppression equipment.

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. Gas Leak:

Augmenting the internal combustible gas sensor, the power plant also monitors the flow rate of natural gas. If the gas flow rate exceeds the equivalent power production of the power plant then a shutdown will result. The largest possible accumulation from a leak prior to shutdown is below combustible limits. Fuel valves inside the power plant are “fail safe” and will return to their normally closed position upon loss of power. The power plant is designed to have a physical barrier that separates the equipment handling combustible gases (fuel compartment) from electrical or potential spark-creating equipment (motor compartment). The fuel compartment is kept at a negative pressure to contain and remove any potential gas leaks, whereas the motor compartment is pressurized by a fan source to prevent combustible gases from entering.

Hydrogen:

Hydrogen is lighter than air and thus does not pool like other fuels and will readily dissipate with proper ventilation making it less likely to ignite. Although hydrogen has low self-ignition characteristics, the fuel in the power plant is not pure hydrogen. Also, the power plant is not producing or storing hydrogen, it consumes hydrogen-rich gas equal to what it requires to produce power. The fuel cell stack is wrapped in a fire retardant blanket. There are no materials inside the unit that would sustain a flame. There is no large volume of gas or any ignition that occurs within the cell stack.

Phosphoric Acid:

Phosphoric acid is integral part of the fuel cell system, acting as the electrolyte within the fuel cell stack. Phosphoric acid is a surprisingly common substance that is contained in common cola drinks. A leak of phosphoric acid is not possible because phosphoric acid is not in liquid form once applied in the equipment. There is no reservoir of liquid. Phosphoric acid is contained in the porous structure of the fuel cell stack material by capillary action, similar to how ink is absorbed into a blotter.

Fluid Leak:

The only fluid source is water. All pressurized water vessels are designed to ASME boiler codes and inspected annually. All piping, welds, etc. meet pressurized piping standards. Water produced through the electrochemical process is “pure” water and is reclaimed and reused by the process. The other source of water is water used in the external cooling module, which is mixed with a polypropylene glycol and a rust inhibitor to prevent rust and freezing in colder climates.

Hazardous Waste:

The fuel cell does not produce any hazardous waste. Standard Material Safety Data Sheets (MSDS) are available upon request.

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. APPENDIX 1 – SAFETY DATA SHEETS

COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. COPYRIGHTED WORK © DOOSAN FUEL CELL AMERICA. THIS DOCUMENT CONTAINS THE PROPERTY OF DOOSAN FUEL CELL AMERICA. YOU MAY NOT POSSESS, USE, COPY OR DISCLOSE THIS DOCUMENT OR ANY INFORMATION IN IT FOR ANY PURPOSE, INCLUDING WITHOUT LIMITATION TO DESIGN, MANUFACTURE, OR REPAIR PARTS, WITHOUT EXPRESS WRITTEN PERMISSION. NEITHER RECEIPT FROM ANY SOURCE, NOR POSSESSION OF THIS DOCUMENT, CONSTITUTES SUCH PERMISSION. POSSESSION, USE, COPYING OR DISCLOSURE BY ANYONE WITHOUT EXPRESS WRITTEN PERMISSION OF DOOSAN FUEL CELL AMERICA CORPORATION IS NOT AUTHORIZED AND MAY RESULT IN CIVIL LIABILITY. POWER PLANT LEVEL 4 (60,000 LBS) LEVEL 2 (9 PPLT'S) (21 CM'S) EQUIP EQUIP LIFT LIFT

6'-0"

COOLING MODULE (4500 LBS) 10'-0" 39'-2"

6'-0" ©

203'-8"

LEVEL 3 (6 PPLT'S) EQUIP LIFT

SCRWA METER VAULT

R.O. WATER & BACKFLOW

39'-2" NITROGEN STORAGE 376'-6" TANK (UNDERGROUND)

IRANISTAN AVENUE MANHOLE ACCESS RAILROAD AVENUE NATURAL GAS

138'-0" MEDIUM VOLTAGE

FUTURE LEVEL 1 (6 PPLT'S) EXPANSION EQUIP

LIFT 4000A

4000A 1600A 4000A

XFMR XFMR XFMR XFMR XFMR 4000A

AREA RESERVED FOR HEAT TRANSFER EQUIPMENT

RETAINING WALL 330'-0"

INTERSTATE 95 (CT TURNPIKE)

(15'-0")

(15'-0")

(15'-0")

ELEVATION VIEW MAP REFERENCES:

1. RIGHT OF WAY MAP TOWN OF BRIDGEPORT CONNECTICUT TURNPIKE FROM THE FAIRFIELD-BRIDGEPORT TOWN LINE EASTERLY TO THE BRIDGEPORT-STRATFORD TOWN LINE SCALE: 1" = 80'. DATED: AUGUST 19, 1974 LAST REVISED 11/88. BY: CONNECTICUT DEPARTMENT OF TRANSPORTATION SITE BUREAU OF HIGHWAYS. MAP NO. 15-03 SHEET 3 OF 9.

2. RIGHT OF WAY MAP TOWN OF BRIDGEPORT CONNECTICUT RA TURNPIKE FROM THE FAIRFIELD-BRIDGEPORT TOWN LINE IL A R V OA EASTERLY TO THE BRIDGEPORT-STRATFORD TOWN LINE E D #2 SCALE: 1" = 80'. DATED: AUGUST 19, 1974 BY: CONNECTICUT ST DEN DEPARTMENT OF TRANSPORTATION BUREAU OF HIGHWAYS. GAR MAP NO. 15-03 SHEET 4 OF 9.

I - 95 3. MAP SHOWING LAND OWNED BY ROBERTA LICHTENSTEIN, E TRUSTEE RAILROAD & IRANISTAN AVENUES BRIDGEPORT, AV L ST H RA CONNECTICUT. SCALE : 1" = 20'. DATED: JAN. 1987 LAST MIRA T IL AD OU A R S V OA REVISED AUG 1987. BY: NASCIMBENI & JAHNE SURVEYORS, P.C. E D #1 MAP NO. M86-198.

I ST R ON 4. COMPILATION PLAN TOWN OF BRIDGEPORT MAP SHOWING JOHNS

A LAND RELEASED TO RAYMOND RIZIO, TRUSTEE INTERSTATE N VE 95- CONNECTICUT TURNPIKE AT IRANISTAN AND RAILROAD I A S GE AVENUE. SCALE: 1: 500 METERS. DATED: OCT. 2004. T RID 3 A 8 BY: THE STATE OF CONNECTICUT DEPARTMENT OF N

D TRANSPORTATION. A A E V DG N E E 5. INTERSTATE 95 @ BRIDGE 00105A MNRR, SOUTH AVE & R OA PARK AVE IN THE TOWN OF BRIDGEPORT PROJECT NO. D E D

170-3250. SCALE: 1" = 40'. DATED: SEPT 2014. BY: G

STATE OF CONNECTICUT DEPARTMENT OF TRANSPORTATION. E

R

O LOCUS MAP

A (NOT TO SCALE) D

NOTES:

1. FIELD SURVEY WAS PERFORMED BY ANCHOR ENGINEERING SERVICES INC. NOVEMBER 2018. SAN MH 2. HORIZONTAL DATUM BASED UPON MAP REFERENCE #1. 10 TF = 10.23

3. ELEVATIONS ARE BASED UPON NAVD 1988 OBTAINED VIA RTK GPS THROUGH SUPERIOR INSTRUMENT RTK NETWORK. MH

4. PARCEL IS IN ZONE AE (EL= 12)-SPECIAL FLOOD HAZARD AREAS (SFHAs) SUBJECT TO INUNDATION BY THE 1% ANNUAL CHANCE FLOOD FLOOD INSURANCE RATE MAP FAIRFIELD COUNTY, CONNECTICUT UI PANEL 437 OF 626 MAP NUMBER 09001C0437G JULY 8, 2013. 2748 10 TRAF BR CONC OW 5. SEWER MANHOLE INVERTS INACCESSIBLE DURING FIELD SURVEY. HH STREET A N RAMP W P ST H PR O INFORMATION BASED UPON MAP REFERENCE #5. SIGN IT O N E X E TR IM RE WV A AT TA TRAF FF E I IC L NI 6. UTILITY NOTE: UNDERGROUND UTILITY, STRUCTURE AND FACILITY L OC NG HH IN A W LOCATIONS DEPICTED AND NOTED HEREON HAVE BEEN COMPILED, E TI A ON L 8 L IN PART, FROM RECORD MAPPING SUPPLIED BY THE RESPECTIVE UTILITY " W AT COMPANIES OR GOVERNMENTAL AGENCIES, FROM PAROL TESTIMONY PED WALK ER AND FROM OTHER SOURCES. THESE LOCATIONS MUST BE CONSIDERED SIGNAL AS APPROXIMATE IN NATURE. ADDITIONALLY, OTHER SUCH FEATURES CONC PAD TRAF MAY EXISTON THE SITE, THE EXISTENCE OF WHICH ARE UNKNOWN TO W/ CABINET N/F 9 HH ANCHOR ENGINEERING SERVICES, INC.. THE SIZE, LOCATION AND UI STATE OF CONNECTICUT EXISTENCE OF ALL SUCH FEATURES MUST BE FIELD DETERMINED AND 2747 VERIFIED BY THE APPROPRIATE AUTHORITIES PRIOR TO CONSTRUCTION. GG C ON METRO NORTH DIG SAFE 1-888-344-7233. CR I ET E E R C RAILROAD D UR BIN G A G

E 6 6" N R R C P O SA I N A 37 UI IT S 6 AR D .4 Y 9' 10321 A T P N PR 8 OX A 3 I °4 MA 5 TE '2 L N 7 A + 10.39 " O E CA P TIO A UI P N 1 A R 3 P 2746 3 O P 6 4 UI 5 V K R V R X . 1 T A O R C 1022 I 3 A I M L E B N

X S O R ' M I A IS O I T SAN MH N N S M IO A T N C D S A TF = 10.60 E A L P N I P I N A U R R D E T V O 4 X INV = -11.80 +/- (66" RCP) E 3 I E E E M 8 A T N E 6 T W " E 3 U E L ° E O R 0 C

A 0 A C " T C N I L O

U 0 O N P R K E R # L ' C E 1 1 C B T 2 P R MH IC I " N

W 8 G YE LL OW

APPROXIMATE UI TR ELEC A AF 2833 P FI LOCATION P C MH RO LIN ELEC MH X E IM + 10.58 A TE APPROXIMATE LOCATION 1 0 LO 1 C 1 WATER 1 A 1

9 T IO C N O + 11.22 N E C LE R COMBINED MH C E T TE TF = 8.28 WG + 11.22 + 11.47 R C IC U R INV IN = -0.22 (15") B IN G INV OUT = 6.05 (15" OUT) AREA = 22246 SQ. FT. UI INV = -0.97 (48" RCP) OR 0.51 ACRES 2745

+ 11.65

GV UI 3564

COMBINED MH TF = 8.25 HYD INV = 5.80 (15" OVERFLOW) 12 INV = -8.75 (30" RCP) 12.12 10.83 11.43 330.75' S62°49'20"W CHAIN LINK FENCE + + 11.47 + + + 3.63' NON ACCESS HIGHWAY LINE 11.51 6.12' 4.74' 5.13' (MAP REFERENCE #4) 7.37' 8.02' CONC PIER

A I N

P CONC PIER P LIMIT OF BRIDGE PARAPET CONC PIER A R CONC PIER PIER CAP P O TOP OF PARAPET WALL PIER CAP P

X R ELEV. = 61.24 I

M O

A X

T I TOP OF PARAPET WALL M TOP OF PARAPET WALL E

A ELEV. = 58.83 ELEV. = 64.32 PIER CAP L TOP OF PARAPET WALL T INTERSTATE 95 SOUTHBOUND O E ELEV. = 67.53

C RIGHTS OF ACCESS DENIED (MAP REFENCE #4)

L RIGHTS OF ACCESS DENIED (MAP REFENCE #4) A

O

T

C

I T O A REE A T N T N S P R I U P B O H S R A 1 N W 0 O

"

6 X

W " I

M

G A

A LEGEND A T

T

E S

E AD R RO EDGE L PROPERTY LINE O C

CHAIN LINK FENCE A

T

I WATER LINE O

N GAS LINE

E

ELECTRIC LINE L E COMBINED SEWER C T SANITARY SEWER R I

C OVERHEAD WIRES

UTILITY POLE

UTILITY POLE WITH LIGHT

MAJOR CONTOUR 10

MINOR CONTOUR 8 20 0 20 40 60 80 HANDHOLE HH SCALE: 1"=20' WATER VALVE WV OR WG GAS GATE GG OR GV PEDESTRIAN SIGNAL PED REVISED 4/23/20: ADDED BRIDGE GUY WIRE PARAPET AND BORING LOCATIONS SPOT GRADE + 11.21 J:\1418\SURVEY\PLOT_SURVEY_Railroad_Ave_Bridgeport.dgn BORING 41 Sequin Drive Glastonbury, CT 06033 ANCHOR Phone: (860) 633-8770 Fax: (860) 633-5971 ENGINEERING SERVICES, INC. www.anchorengr.com

THIS SURVEY AND MAP HAS BEEN PREPARED IN ACCORDANCE WITH SECTIONS 20-300b-1 Civil Engineering Environmental Consulting Land Surveying Construction Management THRU 20-300b-20 OF THE REGULATIONS OF CONNECTICUT STATE AGENCIES-"MINIMUM STANDARDS FOR SURVEYS AND MAPS IN THE STATE OF CONNECTICUT" AS ENDORSED PROJ. ENGINEER ASF BY THE CONNECTICUT ASSOCIATION OF LAND SURVEYORS INC. IT IS AN EXISTING CONDITIONS PROJ. MANAGER WEW EXISTING CONDITIONS PLAN PLAN, BOUNDARY DETERMINATION CATEGORY DEPENDANT RESURVEY, CONFORMING TO HORIZONTAL ACCURACY CLASS A-2 AND TOPOGRAPHIC ACCURACY CLASS T-2. OFFICE REVIEW WEW BOUNDARY SURVEY

TO THE BEST OF MY KNOWLEDGE AND BELIEF THIS MAP IS SUBSTANTIALLY PREPARED FOR CORRECT AS NOTED HEREON. REVISIONS

4/23/20 NuPOWER LLC

WILLIAM E. WERTZ, CT. L.S. #70067 RAILROAD & IRANISTAN AVENUES BRIDGEPORT, CT

PROJECT DATE ANY ORIGINAL OR DUPLICATE OF THIS MAP IS NOT VALID UNLESS IT BEARS THE EMBOSSED SEAL OF THE SURVEYOR WHOSE REGISTRATION APPEARS ABOVE NO OTHER CERTIFICATION SHEET NO. 1 OF 1 OR WARRANTY IS EXPRESSED OR IMPLIED. SCALE: 1" = 20' 1418-01 12/10/18 H

e O r d i l Town of t R d n a g ow T T e o

ld w O P l n

R

d

r R

D o n g a L Trumbull e

l r e P d r k r n

e d n n D s a s i a

h a c C L o O d h L O o d R n

u n g R r

e r R w m d

e e l S o C

n T u e a ld v v b r l

u i w a L b i l O r R te n e ir y e C s L n S us i I t P of c L n r

G e v l r y m e

i t a

C d L e d t u c t a g n n s H

i H a n

e L a S l i

a e R-C l d l e l e C a l

i i

t f r l

l e g R-C d n o i oa n

D o R a a r h OR-R k r R r

oad W V Oa y y J F h R m d eig e d r Ral t d Me e o mo R M e M L ry L M D p a n n ne MU-EM d u u n b r c a R c d Road R i e Elmsfor a c c f y i e T r i o l o o i n e b i l r P u H P H l a D r n R q r D D

l e r w o e w a a d xt S k e r o y d o D L oa t y t o r R a k r lle s a o W d v r e R v i b l l

l o l i e e P C a S r n g R i d C r R-C a u d n M i a it d m o almetto Rd W erm r P n a a i R o R-A o a D p o c D M R d d s m o P y lu l e n ti r r l e u P e d i C D R a R s n intur N e o d C a M h l Ro r n a ire m i t our S a d J o

d S e

u e v p n a n a e a i

P Q s

o m g a v b e O d G G i r e R d y k e Pl le r W r R o F D yc etmore Rd o e n H A R e ad O o o r o C ay R v a tw n s v Ea y a e i i C l l n l e i t l d T

i W d e n r l i R r i L n R e e r l

o T R

e e o OR l d Pl a d o o D o ewo g c D D o p ed v D n W a w R r n

n s k o o r i r r d

r t e e

n l D M a y r r ll v R

c D r a e S

t r c s G a a R

d r

n D t o i A e MU-EM

r p

p r D

a e n a d n T H i D y r i

l I d w y d

e o D r M D

n o a s p e

r e o n

n e v e D r A v i ew i

d illvi K d c a H w o i n

u e R r D i A k D a

R P S in s g i a v d vl n e P i

N e Q k

n o e o a e t t K C o P o l a c k b

a o d N s R S i

D h i r L k a n c a s o f i e s r o L c o

c a r l O l k a r i b i e y h x e e n T o e l v M O d C l o l D a P o l i D S l k l S T i r a r l S r a o i r t r H n u B H O i s d R-C R-C w d o n O e oa C l n l D n l l R i s a l v a l el e R l n i h r s f l s e d C f o u i i d R r l n H R i k d e d r S c a C i o lov t e R C r Hil W l St l w i o r e Rd P d Bear Paw Rd b roadbridg e B n R in e Dr Ralph St a a n axton R d S OR L a n

u t y la S r D l t r o r e a e H k b e v D c d n Voi e E A gh R OR a t d o Av u e n l L n e R B w B r r a k e o o T k a e l t s v d d Indian Field Rd S i ld o b lv l r r A i i F o d S O C e r g

P u S h s e t l b R l t u Tru li

m n d L b e n v T u P ll A i a ve e e e l l n a T n r P r a G l G i r k n L l t a D r P A C a i OR S jan D t c Tro v o t e a C l g e e t S e d Old Town Rd d t i e i r Old Town Rd C e r u D b r t d Lake G n S a ra e m i ndv m d D b a d o r iew A A a e C r R ve l R r u o r f n b r A x A w e s R O o b e n t C t k n d h o o R t c p o rn o n t G t OR t R-C e e T d n r v l Forest e E s T F A a ll S n m s ton u M n e y D An b C s t e m i a o ra e u r r p t l r l r r h D t l d R Cir T mic Sylvan S ed g S d Yare a t G le in P t l n P u

G Dr o C Ranch ity B Vie H d n w y a Ave e d L

h R y s R-C v w R n

a r n p e e H P e m r s e P R-C D M r a A

k a i s k l ar rig l s e o a e P G ld y m i

Ave c d o a R A e n s a K r c o i C D n R to l u R-C e a l i d n r n Ct u P H i a o S r t o n l R d r e are t M h a o h OR l K W a D l s r d n e r e d y e o t t y t r m e S a R e e n R o g S a e n t o n s r r o Rockridge Cir l e o y y r e P w D r t R y e t erl a D G e Av ev o R l ew H B o r r P ndvi S S n d c t ou S OR-R S o P r r e e t G l l y a e r rd T Calv y le a re ert Pl a n B e a o S w d u h d t g G es D R H n ak m k

a L t r r l a i x d V e Te m s K c a O a R t n th P O e f a e c Ch D ns r S e m i i e t r u n P m i l i W g a n e S l C v a e t d t n e a C o s M F o a t o le d i n a o s t rr J a w a g d R Trel e S ie o d P e s a a y n r i r e D l G a l n r h rif v v R o o l t fin y r Ho a r a y o C Av l ie llywood A e a e ve l n o P e w n e G e g S em OR riffin i l d Ke l r c i g cir J D C R e S n d n S r R t s G E i t i t e H n L r R-A n t s e g V ou a to to rm ve V t S e v n Patricia Road el t A n r S r P St S e i e c A l id d c F l l s lm l e d t a i s P u rc oo S o W R H g t a r n S M t y S Bals in e s am Ave P y n y B g S R ga Ave t a n e Orte o l n a e Charcoal v u t T y r o v e n e n s a k h ue in o J t F y t n A n S C n A ir t l S ir t e S A v v t tt S H A C e t S a ve C e H M l a A e y Alb v t e a P t o la y v i l e A M e r l a S d P E u S r n R Car t u i Pond s ls a n H t la l r on Ave T d r a m a A ld a e e t N P o S v t o u R c l O t s il a t o A t l n m g e e li o P r s r v S e i e c r A m L n e l g L v e k t an v A si v R P A ng o d v S Pl e l ig i ve r A ld e t tory u t ic ed e A V t G C v e Cl v ifto A v n Pl S r r t A d n d e a s e D o n r m rla N o e n y d o R v o N u b d o P E W L t im A e o m r n a g r n D il D n n a e d le P ew e s S g i ve t E l v i A t K S a e n it s R v C re v OR e P d t t g C A e a d Av r i R S od s r

e lb D d g v S A e S s r A o e v r y A t t m D n ir e n Ev o t e si C v w an u l y A la s d v l e S w i T le n d t N R-C l w o t R-C e Va la o a E H v d W H o e R R-A A oo en y d R e e w W e l r ie e rs g r v o F P nt v n m e e a S a l n h r s A t R-C i a St s Pl c s R m e Edward t Evers P C S e Pl w l t y e r u v e e o v o A i t n S A n r i n d v S a s o S t n r a e e o e v D o i v e c s w v l e A k a r le A d t a A e e P l l g ow a a l r a i w M v d n r rk u T n E od v L C i c t e e e o e K l P i e W w G A n s i S r l r i v t R-C P o v S e o r o r s Co a l W ll urt B k P e l am e ug ilkin P r e v v W o s A R-C i A D S v l D t e P t R i e t n n v U o y A S S r g Valle fitt is p f m e c P d R-C o i S M ll o R-C l W a S a o t t i C s l r S t kin o C W t s i k le a A ur r a P ve t A nd m C v le o r e i t l n S C G D t A P l d C e t o m e t n t v P a A n R-C S w S y s J e a rs t e w r o v ad t e ro n d r A B p n C n E e i y u r u a o d z i v M S S o B n c D d g e p n S E a a R t R-A lv e n t u r r Z-P t OR-R e D h B D t r le a r l r S t P P e t d St v t o eter ve l i S o Ex l A R W t w ar l ge E r a P id e e rs R R-A t v y h Virginia Ave A n e e s o v Success E t A o le e rl a n S a o d e E n i S v t I R le L d A C n o t e Elm G S us d r t o i St e t S lh a R t n il n le t r H r r a e i Lake a o F C m A Minnesota Ave l e s P ce lb t v n ly S e A l e y E e M n v rr A r R R-C s a T in u i g Q k o e ig H a b r e t C S r e t v i e id A P r s tt t S Louisiana Ave nk e e e S a w e rm t P B Je e ho v t T OR-R a A S r d OR Wav k nro t erly Pl A t lde e v S o v R-C n A B W e to G rd E k o B e n f z i a s a e t l l rn y S R-C r c Pennsylvania Ave ir R-C P u r c r a l C t ar o P ill B l h u S n H e Q S x dia ob t m t In N t e t O S R-B G S o v a t Bear n e r k t dsley Park Ter t e I t n w n S s e t t A o f e d S S H n ie h v S o k lv n t a w l Ohio Ave to u e t d d a B h R t r o L r s S t t A t o S S e it S v rr d t t S i Bunnell's R-B e t R M S n r t L R-C i e S R-C t C ivingston Pl t n hop a s ee sey o A u P Hill M o Q Rd r o t R d n s Texas Ave m Pond P t d a o S St E a ny S e rmo t r r Ha t e rm t k S o e S ll h v Edna Ave A i A T A C nh er n v r v l h o P e o e C e D e R-BB R-A s a C e K row e e m n w r w l St Nelson Te t t b P a S h t S y l th S rr OR-R e u i t S R r m e R-B r s a T l h a t g R-C R-B n S i St i rm t Springdale n t i E B S A th z t r S v o r it R-B Alpine S w e t nt a m t e OR um n S W S S R R-B e t ic ue hard Q OR St son P est St a For r R-B k t A I S n A rk m R-BB t a d l R v C o i e S e a Fos t v o s ter S t A n q i d c R-B P r r S r fo t A

la e s ve o t r n A v i t r ton n e M u oc e a B R As C Hick u P hl ory St M ey r A l St v a o

e R-C b r s King r M t sbury S d Road a t e n a

S o H t l t C l P

m b e e OR l a r A r e h o B o Fairv l g S n iew Ave C u R-BB a n r a i P R-B n t s h H

m r e a r ir n B e o w o t l B n h o P e r l n i r p n H e l e t S a s e St d S l B S e a S y v a rkel r r e R-C ey t t e t t Pl e A o r S k e y a r b rk t B b d R o la S A H Magnolia St C e R-C o n r v m i o rm l o e e l o t P v a w h A L R l t T t ld S l h n S fie i g r t n o e P es l n e C e A d S i k W a t a l G n c m y d B e n t a R-B a T y l u r t v e S o S s

y R-C o S a i vo t D H r l a e e S n s t H o r v

o d b A A m R-B r t a C v d Y S ork a e t m S e o N in o t l o H F Rose P l St

o G o l A ve w l r A r t ew u n n R-C l v i OR h irv a Fa r i e OR-G e l f d a e P i E e o l G MU-EM P a ld n R-C z A l r i v R-A a n P S S e a t r OR-G t S R-B a S Te OR-G Ma r t so t t Palm St n M k r us R-C S R-BB R-B ila A a R g St t n v f ti t i n S t e e Hu y Bo l le s S d w t R-C a o P H n e A k l M OR-G v R-A e OR-G a

o t e O t nt Av Locust St R-C W o r n K rem S e l T n d n t r P OR e St S e t k k i S n r t ow R-C t y N B MU-EM g a e S R-C l o s

H d e P r i d OR-G t a c a h C e r a o l f r I-L i B g i D s e e g C o v Concord St on s P a l Ave A r c w d m a I-L d le n t o H I-L Har ta rd e rk t a S S ll e D h t S B n R-BB e o a t A C r o R-C M s un urt v a da 3 h ry e Ba St C t S rbie o S t ri Cir Ald ince St R-B s Qu t g t OR-G n S S i l R-B I t ria e d s pe Av la s A m A a n e G I x OR-G a n n e d v l ro t B t r e B s H s r S A e x o o o l e a e n lm F l k il d v 8 l Es r n n A ro A se C y S O n e v H x S a R ou f G d t le y h e t rt i t S w t t d o 2 e e et a S c a er H w t t t d c R-C l v i d r r E o k H S Zoning Districts d A w l a Canaan Ct D e T G v R-BB e R-C n t W St r n e d ew a ar t t t D S i S St l MU-LI l n S t r W io i ar a a M m R-C y R-B n S t e H R-A t t a S d S S P an r le l Ho R-A t e y y ov R-A, Residential - A Single Family Zone e m evelt St h S m er Ca u R-C Roos c v S n Tr e t o t aa H u A n R t e th o u B s ad S S l d t t th s S e r R-B t o r s e S F e s m n re v P le n I-L r e V a S c a R-C elv S h S W e t Silliman P t C t S t P S l a t n S t ar t R-C nd bi S ro R i Ro MU-LI t s R-AA, Residential - AA Single Family Zone y T tt iv h t R-B e u A e S S S r v r t t an n n e S m S Stillman G m d ru i e t lu y ran T S r Autumn St fie y n ld S d s lo Av t R A e M o N n C y t o o t P r S t g r e ic r Pond t o n e t C i S v n t t t h t n S S W e s n A f S u S n A e T i o h r e H ud n e s a H o r n L v i v r n e t g I S o l e A a e m n r t e t d B o v e R-B, Residential - B Two Family Zone w e l w l A y v g e p r t B a n v Spri ir D ng o n l o l A St d x s i n o v E t S se k a o y c y r e S D e r S n d r in y m S o D n e L t R-A t r d t T r n e o e S S e r e n o w e b l R o t t so r t B l r f i v o y D d e S a a A M R-BB l H C OR r M l d OR-G a n e H l d P o o v r ig G n t s e e P t P t S R-B a S ear B A T h m l St H e t ll S a

y r e R R m ve v n A y

R-BB, Residential - BB Two and Three Family Zone w e n S o i v a A e d i o t w P e n R-A r t v H

g t r d a i n e l l i A e B

t a h

e

k S r D i o l M W l

a f e o r t r e W R s e i r S R d t A o d g b t n T S e e e e d r r F m e fie o G ew e ld e e ary s S e v B n n t

A m S

r v R-C ve r t S W l o A

P e e A t t T ll Put m e

na e v OR m St v w g e e v

o u P R-C OR R-B e

A A i n d r A i OR-G S l t

h e a g r S t v p s

s r A s e A W B i o S R-C, Residential - C Multi-Family Zone e n s t l e l M

r o o r n a a e t ks h th h ll g hi a r e ias OR s N in V re F s St C A a a c i R-C S sh e ve P irba n c t a k B R-C rn C s S e G W t u v a . o A r N S e ler lan n v e d S l A he P A o W o ve t Boston Ave ve it r OR St S A ap te teph d C r ens S el H S t i T t L rf a t S i a r S R-CC, Residential CC - Residential High Density Zone e nc n G v t re c a d aw o r P r L d a S P l a r n e S al l h i v e n B t l x A c e t v S e OR l R r A l d t l n v n t e

S t a o e d a b e ur l s t S Stillm O e an S b s St S H u v i t S e n b t Lew P l e is Pl o R-A m n n

C S

e u y l

f a h a v f l a

A T l s P d

n m T i R-BB H e a so R-C M l To h r

e B N k o e NCVD, Neighborhood Center Village District c a m l o a d h OR r J p P m is t s S Clermo o S S o nt Ave ve a n ce e n Clermont A n li d Clermont Av A A g S e S v e t H t w o e K i S L c u e i t k a n S s R-C S Ogd n s en S g c a t

W r P t t t B o e e t S e e A l i o e i R-C n n B v ll c Ogden St A n t e k B d R-C v s A v i e MU-LI, Mixed Use - Light Industrial Zone s S o c T F e

l e t R H v o e v a d e l d r A A h i r ir Shelton S

m t St l n e S p l v e s a R-B i

o n f S t g q e v i r e

n r d a o t s A k e e M

S d o r t i A t d J r a m l v R-C R-C S u ll t e OR-R S P e t e e l i m

ia h S s rc f e u d m H t a ick S e m o s d o o St e i C l S P r o g S t v e i G P u d x

S i e Q A e M ea l d l c t v n S n t e R MU-EM, Mixed Use - Educational/Medical Zone l A r t A ctic i J n e S ane o t St e y i v e l e s r H l A R-C l MU-EM n t . P i f l d P t n K a a l i l c T u x

OR t H M J

M E K

D S

t o N a n S W MU-LI e o o n k r r a d m l w l o R-B e e a c l r a t c l P l t Artic S e o t S b lf n n S s P o n t e u

G S b k rasso T d t m er A um C l t S MU-W, Mixed Use - Waterfront Zone e o C Grant B OR-G t S H P t

r

u o r

o OR R-B d R Grant St

k N t A E

f o v a C i e OR-G e

r t s m e n t e l S v i t t o d

v S

S A A a s i OR A t l S e n v r n d A o t v a s e R-C a i v A g a t

p M e i k S r Ar aple v m S e t a n o M strong t

e o h f n C o t t EAST BRIDGEPORT i M e s nk St i e k W Fra l c o P S

l W a r l o OR, Office/Retail Zone d J e r t s B e a R r E t i & PEMBROKE CITY Ford Pl r C o P l r e i a v k z A a a d w e e W c e H r C v b ie Av y a Hu e i t A ron St P t l f t l S h t o o r h R-A n e e c l w OR o n ri ix a n b S e l B e Ba I-L o r nu S v D P m Ave e t R-B A g ve S George St Av ia in A t N m t OR-G, Office/Retail General d d t u a W d rs rn c e e e S a r v A o A R lm B o t h af ha d T c C C R-B MU-LI a A t t ve a l S R-A v P e ss St A l n S Cro e v h t ia i c to S B r n a a h o e r t st A B E e O E u L A v im a s a k r W e r i k ashingt u e s on Ave E Washingt r H C S on Ave o e t OR-R, Office/Retail Regional Zone l K A w e v i Cresce e v nt Ave W C ve t k atherin A a S a e S e e t R-B in d in O ld e t ra I-L Cr A S r escent T R-C n o Pl e to L e r a e Av l E P R-A Av t I-H l P e nt en re tr Le C ce sc C PDD, Planned Development District u ie x en s e h a St ingt ter St re r urc L S on C Clare h e A C nce St S R-A B ad t ve R-B t NCVD t t u W S r S e nt be Wa n v a m lt n A h u er r s rc L St e e e D l h l M t t r g y u S e R-A S r . S e n a H e e o v t t t T t Pu la E t a v ski S E e A t u W n u OR-G A i l e M ra n arti r t a s n L C OR g u ' W o r e ther s l r K i L r ing ll DVD-CORE, Downtown Core Village District n OR-G Dr is e i e b o t ve a on necticut A v k Con h o e S H t F t A p C N i S G l e o r n e v H P t ig r e hl R-C a e an e t A d A H w n v ve a S t i m n s il A R-C A to s c L n t le e S S p n Bur t e a n roug s t hs S r u t H A e S o l Ho J o l l v m t y o h S F o e t t S l l S l a e i r S s DVD-TOD, Downtown Transit-Oriented Development Village District e t P d Sa C nf t S o e e e a Peq n rd Ave e U y r uon a k n r m e k no r n s ck o A W S a d A t S r d q r G t v e C i n DVD-CORE a v v S u b e l u B ymo be n e e u o t r St n e t S Ja S S m e B t n w me t R-C s s r e S s D t R t t a R-C e e m e r S a a r P a c c H g o a d n n a u o e S l t e r i C r n l e A l h R-C l v o E B S OR t v S R-A e S d t A e t v t S m C e t DVD-CIVIC, Downtown Civic Village District l R-C c A w n

l i ana t P n Sherm Ord cu i Dora h an i n C o t ir n t G C c B R-BB t How n Goodwin St e H w e o S r R-C t St St n n g a Par o la l S old k Cr n e o o t k e G L o R-C n p l C w o t i a m B 5 h r k o S C k l th i r h DVD-WF M d l r t a B h M e S L t iln s i t t I-L lv e Sh a o i w r S e h S l R-C t a L rm e o a P g B n y n S t St MU-LI t s W W a A R-A o S S e v n OR n c e t r e l M u T t S P M t r D e C g o t B DVD-BLVD, Downtown Boulevard Village District i l n r i d r o k Ste sl DVD-CIVIC MU-LI R d w c rli u a i n e g R t l h l P S e a e w l w h C s t Ced d r S n a R-BB o r St S S e W t o t t R h l DVD-CORE g e l P u R 6 a o v OR o t R-C t A H c t s ll S H e h i i e f S e H i S c n w R-A e d lde Nic DVD-WF, Downtown Waterfront Village District t v h S li a o ols i l G S Y t D t e e C t t t B v O S a S a r A S lh lm 3 o o E v r t t t u e h m n OR d w a n P R-C P ve t S S h W e C l t A y p ie n DVD-WF d se ll e o S t r l o l r le a DVD-WF fo Ke P c S B l S at r e e t m il t tr tr t e R-B a e a S rc v H tf S e P STRATFIELD A n L r o 4

e r i d t S t P l d n a S A C v h o t e f ve OR-G o t a a A R-C R-C S R-A S d Ba W I-H, Industrial Heavy Zone w a l y ss r P n r d n ro C i o e R-A D t r o L fo i o t l t a r G t l m S l o t d e x t r t e S S S A l t R-C P all o A e r w e S W ric l v t i r n t g i q t ea V S e A a B h i n B o v t r nn la a e S B C c Pl t k W ot e ilm m e a v v s W a A A W h n d in t L I-L, Industrial Light Zone P o OR a g w B S e a i o s t e N r l a w h o i ar R-B l n f C v l e i a C e n T r d z w g e y a a r e e w t t e t v r H e o A f l C l i l i e v t t a t o t n r n S e r t A t k cu t Ca S e e S o n i l i e a W t re r P S n d B c d ve ar OR-G v o e Re C l C PDD

A o n t t A d n S A v w i o d L r r e oo m R-A C iffo v l a l e w E R-B C le u I-L Ct p r on a e ngt

Z-P, Zoological Park Zone R-BB e U i r M l ar

t v MU-W Y C R-BB n

S A t i

t S o

e l C e y v le n

A v e o M s r d r

d o u L a A u a e r R-C o r B a 5 v

o a t r l k 9 w G a f e t L a I- h R-BB n l lla c C y e ata d B e d e ar OR-G e C s r t Ce B a S t y I- e t Wa 95 w t R-BB o CVOD, Commercial Village Overlay District H B I-L l v C E d l t Orange St i l n m DVD-BLVD S to w t r n S t R-B n e A o t NCVD h S H D v o Jo n e r i o d e e l i l n W i v P r I-L s r e R-C N d S t r l u m e A o 5 R it r R-B C h r M v 9 e S ild A e m - t ner D I g r v a ta S e n n m OR OR-G MU-W ith R-C t o DVD-WF OR E S W S W r a t S F g P t le e C y o e St b

p s a a la t s r r B A t r e S o v t r e l l l S P A I-H t rd MU-LI v e a t e w S v o ct L e A p a d H s l o f R

r a t P a R-B S e R-A r t St er y g t on v e B Y Frem no t ta n t l a a S e W t n a H ty e o l r r C c R-C e e b a i S F k L r T S r s R-C r t ow e t t J e C n eff l S o o er t n e S s Su o e lo OR St v ve DVD-TOD I-H n g A t g r S e t A S e a g ec h t tts S d MU-LI e tta p t L R-C o s u a t o e C ro o ne l P S L A e e v y n e o S x A St t t Je v ate R-BB s S ffe e B St wi rso a e Ad n S s L am t s W s ic R-C St M k o o A r t k u d S n v len e i d Al t n a B R e i e e n g u A a v G t nt l v o r e r A o I e F e e t

r v v r A d e A a l S k r

n c S v t e H o S i y t e i f t o R D l s k n e e la c e W w fo S t a r Town of a t e n l d S e C w d B r OR-G S s a r t

n MU-LI h I-L a e A f i e A e N v L d n C G r i e s v R K

A r e D e o e e g A g

v a e S e u nt n s

e o i s r r l A li e F S m S D v t e n a S t k n MU-LI e R-A a t lb A ad Ave Av ve O Railro NCVD e o t r R-C Salt St e S a I-H s tat n C S g o I-L NCVD St e l L g n Fairfield o n ti e i B S r R-C h I-H e a s NCVD W d R-A t h fo b d MU-LI S o e r i t d a S M a Edg n v ewo B o A i d St A t i o s a e S u v r w v A e o i t n A e J a v t MU-LI R-C e S d S L n t ve NCVD so a S ad A f t ailro n t State S R h a St Jo OR-G BARNUM NCVD y ntic e la MU-LI At R t t u e R-B s

n St t -PALLISER S s ur e shb C t a l W ia l b r um Te R-C S l k I-L t MU-LI 5 Co ar I-9 e P v W t A y S a nr h He t r age St u r Front o e St t S n e n S C St I-95 Pi l I-H Cherry ra R t t i R-B m e C I-L I-H S d n o NCVD r A e n lu W o v e B A m R-B Burr Ct b t l S Cher a ry St l r P r d S e b y i C i k n a g i a e s a a H S t e e I id o H r m m n H S i a S t m a t S R t t R Town of t S n MU-W o e u t n n S i P MARINA a i S r s y b e n R-C c r Av r n A t o ity t a o s b g er u v S n t n e Uni e d c r B S t o k A G l PARK l v l e l v e A S P o R r C e W v t S s e rland St t s e a n O e l rl n n a u e OR e F t ll H la S S B P nd a R-CC e A e t t t lm lb rs S z io St e o R-C A m l n n a Stratford l t S b h S A e rn v t I-H M t ittier St e A r u ve Wh l t B y en A s S r ind a MU-EM t L c q l e e OR-G I-L OR S F e A t o v v A H ve r y e A OR-G e t a is s si av t er z e D en Ave B S iv Ra-nCs B H t n l i U r o A

t d s v H W S w e R-B S e R-BB o o e r c t i v d c A E i u w n n r k l e a l A s p s n A a v S r w e H d f Ave O v ldor o a e W e A l M c Av P e I-L r in v v e l rd e A t Wo id a h e e a P s k r r le r e t i n g n m d S S n R r t In a e e e R-A a t a ld v h t A S S o t e ne P S a r w r c P W G c o t ro v sb ti t Bridgeport Harbor R-B O a a C e n t O R-A a S l n r T t i S S k A r k r c c a lo o D M f M m i a t e e r n H l ti Osb I-H d n orne S G e T t r A e o m r v v u S t e e y S n t n t Anto R o S o S a R-C M t d R-CC e e

p R-BB p

o O h

t H e c

e S n v e r St r s s A e a Morri D d w n B l lo R ie a T e f R-A o R-CC n F R-C r e n R-C a w a u r C d m o t H S R-BB D rt k y o k Dr h St e view S Shell e Sound R-A K e d in t R-BB g S r a P St o R-C S e hell e r o S re Av R in t r deme c C Wal s R-CC n D e o s t u o o M r n r r lar a cu C S ir n C E a A t d e e l l e v l e f A o v d r v s an A i e w e d s A c d P O d o a S l l e B e r e r t i t S e rf h R-B w i s a S C F ve St te se A t ton W r elro urs R-BB i S M Th t St ls t ach o H Y ve n a A R-C R k S r R-B c o b i t w w sle tt St o st y co r o S s B t Pre A v ur St I-L e Arth R-C B e n H n a e d d e R-A tt o n S a F n L St M o t S rris R-B x t h Fe o B s r S r a e t e N R-C R-B h OR w Burr D o s t a u t e e v s S r Av i e l S n d o t to s S o rit o t h B n c Creek S P S o l t R-A t a S n ley d ck Ha S J t e ve t R-A A l la ram P n art OR-G CVOD d d B an S tl t Je ve R-B A d d r y ountfor fo r M n e C a St H R-C m o o u R-A t r Long Island Sound g t R-B t C S l n a n City of Bridgeport: e R-C o n l R-C L a e v r M d r v k A A d te N A s n d a v o la R-C e d a w e e n o v w o te y A W B t S F s BLACK ROCK w o a e R-C e t i i n rla v G w m h S a A n o c r v (H ARBOR) a t t d e H e S e H d B ton t n ar o t gs T bo S o h in S e r ea g iv v v w i L n r ie ie r l w w r t e a b P A Te e v R-B m v r d C a il e l A w a e G e S i C v r Ash o b r n a o H c t a C F e Creek ay B er Se we asid ath Zoning Map e A er B ve t Te ea S r c on R-A d S n t a La l e k d v e A i R-AA ve A M s r e v o r THE OFFICIAL ZONING MAP OF BRIDGEPORT, Prepared for: G R-C Qui nlan St CONNECTICUT, PREPARED FROM OFFICIAL ZONING City of Bridgeport RECORDS OF THE PLANNING AND ZONING COMMISSION, Planning & Zoning Commission

l P

ll a Sprague ADOPTED NOVEMBER 30TH, 2009, EFFECTIVE JANUARY 1ST, 2010 s r a Ln e P Prepared by: e Dr Pearsall Way orag Anch City of Bridgeport Balm forth St Office of Planning & Economic Development

999 Broad St. H

i l l t o Lane p Sailors 2nd Floor R-AA R

o

a

d e Bridgeport, CT 06604 n d a ry R L tte Ba s ld r O (203) 576-7221

o l l

i P

a e S n

r www.bridgeportct.gov o h

R-A T CHAIRMAN R-A Black Rock Harbor PLANNING AND ZONING COMMISSION

r D B e R-A a g t a te it r R-A R-A y rm P A R-A a R-A r k D r Amended: June 25th, 2018 R-A Eam es Blvd

Coastal Boundary Parcels Railroad Waterbodies 0 1,500 3,000 Feet Local Historic Districts Proposed project location Federal Aviation Administration, DOT § 77.9

exceeds 2,000 ft. in height above ground of the National System of Military and level (AGL), the FAA presumes it to be Interstate Highways where over- a hazard to air navigation that results crossings are designed for a minimum in an inefficient use of airspace. You of 17 feet vertical distance, 15 feet for must include details explaining both any other public roadway, 10 feet or why the proposal would not constitute the height of the highest mobile object a hazard to air navigation and why it that would normally traverse the road, would not cause an inefficient use of whichever is greater, for a private airspace. road, 23 feet for a railroad, and for a (e) The 45-day advance notice re- waterway or any other traverse way quirement is waived if immediate con- not previously mentioned, an amount struction or alteration is required be- equal to the height of the highest mo- cause of an emergency involving essen- bile object that would normally tra- tial public services, public health, or verse it, would exceed a standard of public safety. You may provide notice paragraph (a) or (b) of this section. to the FAA by any available, expedi- (d) Any construction or alteration on tious means. You must file a completed any of the following airports and heli- FAA Form 7460–1 within 5 days of the ports: initial notice to the FAA. Outside nor- (1) A public use airport listed in the mal business hours, the nearest flight Airport/Facility Directory, Alaska service station will accept emergency Supplement, or Pacific Chart Supple- notices. ment of the U.S. Government Flight Information Publications; § 77.9 Construction or alteration re- quiring notice. (2) A military airport under construc- tion, or an airport under construction If requested by the FAA, or if you that will be available for public use; propose any of the following types of (3) An airport operated by a Federal construction or alteration, you must agency or the DOD. file notice with the FAA of: (a) Any construction or alteration (4) An airport or heliport with at that is more than 200 ft. AGL at its least one FAA-approved instrument ap- site. proach procedure. (b) Any construction or alteration (e) You do not need to file notice for that exceeds an imaginary surface ex- construction or alteration of: tending outward and upward at any of (1) Any object that will be shielded the following slopes: by existing structures of a permanent (1) 100 to 1 for a horizontal distance and substantial nature or by natural of 20,000 ft. from the nearest point of terrain or topographic features of equal the nearest runway of each airport de- or greater height, and will be located scribed in paragraph (d) of this section in the congested area of a city, town, with its longest runway more than or settlement where the shielded struc- 3,200 ft. in actual length, excluding hel- ture will not adversely affect safety in iports. air navigation; (2) 50 to 1 for a horizontal distance of (2) Any air navigation facility, air- 10,000 ft. from the nearest point of the port visual approach or landing aid, nearest runway of each airport de- aircraft arresting device, or meteoro- scribed in paragraph (d) of this section logical device meeting FAA-approved with its longest runway no more than siting criteria or an appropriate mili- 3,200 ft. in actual length, excluding hel- tary service siting criteria on military iports. airports, the location and height of (3) 25 to 1 for a horizontal distance of which are fixed by its functional pur- 5,000 ft. from the nearest point of the pose; nearest landing and takeoff area of (3) Any construction or alteration for each heliport described in paragraph which notice is required by any other (d) of this section. FAA regulation. (c) Any highway, railroad, or other (4) Any antenna structure of 20 feet traverse way for mobile objects, of a or less in height, except one that would height which, if adjusted upward 17 feet increase the height of another antenna for an Interstate Highway that is part structure.

561

VerDate Mar<15>2010 18:16 Mar 01, 2012 Jkt 226045 PO 00000 Frm 00571 Fmt 8010 Sfmt 8010 Q:\14\14V2 ofr150 PsN: PC150

State of California AIR RESOURCES BOARD Executive Order DG-047 Distributed Generation Certification of Doosan Fuel Cell America, Inc. 460 kW PureCell Model 400

WHEREAS, the Air Resources Board (ARB) was given the authority under California Health and Safety Code section 41514.9 to establish a statewide Distributed Generation (DG) Certification Program to certify electrical generation technologies that are exempt from the permit requirements of air pollution control or air quality management districts;

WHEREAS, this DG Certification does not constitute an air pollution permit or eliminate the responsibility of the end user to comply with all federal, state, and local laws, rules and regulations;

WHEREAS, on October 26, 2017, Doosan Fuel Cell America, Inc. applied for a DG Certification of its 460 kW PureCell Model 400 fuel cell power plant and whose application was deemed complete on February 7, 2018;

WHEREAS, Doosan Fuel Cell America, Inc. has demonstrated, according to test methods specified in title 17, California Code of Regulations (CCR), section 94207, that its natural-gas-fueled 460 kW PureCell Model 400 fuel cell power plant has complied with the following emission standards:

1. Emissions of oxides of nitrogen no greater than 0.07 pounds per megawatt-hour; and

2. Emissions of carbon monoxide no greater than 0.10 pounds per megawatt-hour; and

3. Emissions of volatile organic compounds no greater than 0.02 pounds per megawatt-hour.

WHEREAS, Doosan Fuel Cell America, Inc. has demonstrated that its 460 kW PureCell Model 400 fuel cell power plant complies with the emission durability requirements in title 17, CCR, section 94203 (d);

WHEREAS, I find that the Applicant, Doosan Fuel Cell America, Inc., has met the requirements specified in article 3, title 17, CCR, and has satisfactorily demonstrated that the 460 kW PureCell Model 400 fuel cell power plant meets the DG Certification Regulation 2007 Fossil Fuel Emission Standards;

NOW THEREFORE, IT IS HEREBY ORDERED, that a DG Certification, Executive Order DG-047 is granted.

This DG Certification:

1) is subject to all conditions and requirements of the ARB’s DG Certification Program, article 3, title 17, CCR, including the provisions relating to inspection, denial, suspension, and revocation; and

2) shall be void if any manufacturer’s modification results in an increase in emissions or changes the efficiency or operating conditions of a model, such that the model no longer meets the DG Certification Regulation 2007 Fossil Fuel Emission Standards; and

3) shall expire on the 5th day of April, 2023.

Executed at Sacramento, California, this 6th day of April 2018.

/S/

Floyd V. Vergara, Esq., P.E. Chief, Industrial Strategies Division

n r d R D e L 8 ive t dg Jerusal o R i em Hl S rs l d L rtr y Rd id e a Ridge C p e L m R e P Oak n a b o w o d C d u n n 15 R y H Rd d k t r m o a d Hw R Roc t h R t R te vern s 1 s R r ta n Ta s u s y y L H r d 111 i d e S Exit 50t e Hawle p St l a r y a r ine 1 d y c kw i Exit 52 t a P S n P y tt P n r i n 1 i M P r Exit 52 h V a i l E o n er l u U d n nc r l S 15 M t m R R A y le g r e L Natural Diversity Data Base la v Hw effert R S Sa r t W e d d Ave d B D D e tat Eucli B a i S t l t R n Ln u li Exit 49N a g e a u s Tre m R r S r n m o D lu S rl d e i P P s Quail T et n T l u R R t Exit 49Se

R d r l n d n O a Ceil R a s w L a d y ind e em e R B a e t n Dr k ak Trumbull i v t r t O s os r i s d P e v i v v e A t g p Areas v wood Exit 7 e r m d El o S R D s x t w d i S R e Exit 9 ry rfa 7 l R l m la o i n i a l m y t e d S r F r A d e t a e 2 r L n e Ln D A m Ox Hill W t a s 1 w o g e i F R R W Easton e r e r t v s o t F Beardsley l H e P r d L D kwy e n a e a r D r g t v a u bric D in Q Wilb A rk a G w A L Dr g o Exit 47 Pa u y al BRIDGEPORT, CT u r r l d F y V e r n o n T e H n a En xit 8e ise ld Dr R D r o r r heffie D i 2 S l Old Town Rd l e un r d R i v e S r l R L r l d r L a 5 P D D o i A y le r r o 59 l a K d o a e n Lak C J o W eside Dr v y o b a S o e S T n a D o v V o d c A w W N re R h g N h i o R e n i tm e 8 o e n We h e s n December 2019 W d y D c i a r w R t d c s a r H l A H u f L h o o e b o n i H a te y e h D r e o a L n e n r w t i c d v t n T o S l d l u l Rd l r ook e e a br r L y x w d O S D t R A n Exit 6 e l s n D n o e v Exit 7 o r g e l P k r D d e m d D a g t B Plattsville R p ir v A c r o A e w h Dr t l p e w i l a s ld Rd R l n e n r n Fi l S a R di v In v r d A i T v a e t D D D E e l P g A r A Ln D k i L e Connors A r a s a k s n l t r n e l o r M k e z d n S v o s c s o A n o State and Federal Listed Species i P t a t E r e l e v t L R l n o a r S o o v u i i y ultan D a p St r b F g n d n L b n e d n A A k A m t n n l n r v R n o L u e R n t a r C l n i l h o a d T a l o T u n D P in T n t P r i y e o t S t f re l n l H d p t f D e n P u r S i a R d u l r K S u d k m e e G L n s t v n R m 2 e A G H l m F e r e E l t n S n u id o i il S L Critical Habitat t a r R o s e m e 108 u s R L od lba Av y v H Q e s s S t o St A a t S d d a d V e i S t S e e t d W t s A E d ig e a t e r a l R s St m g ld v P D l s v r nyon R g t u A t ve e e n C Ke e e d t e S ita A e y g e y C t R r v o a a n S v r H G n it s l A i S e n E c s o S H R P tte e s h P l i t n l e S D t o e e v s n e l o C c w d o l a T A M e Town Boundary y l d t A l e ey of d 12n 7 S i h m n ll p fi E S y d y a c e a tt S r D w d l V Se v i r n s t i V a n r k a l 5 e G a r i l R V e P i J e e D c e A a P y 9 t y w r y ter S o S l t B k e e Virg b S M t R R e v t Ex H l inia Ave l B r i l A S I k t e r d tt n n t i 25 r a r d a r l r a t e e E S t S e V w l d o A nroe F S t P NOTE: This map shows general locations A V Mo e Louisiana Ave t z R e t d J i t a v M P r S r a R d t tt a d d e S r i n H n S rr b i m H k St m e th e S Ohio Ave A Par h of State and Federal Listed Species and e C u M A r w t o e i r r R t P d n u t o h t v e y r n G o e o S v g d S s u e t e l i v r 1 i e g r n e r A a L S c A m Alpine St y e ne St m i n A 0 V Critical Habitats. Information on listed 15 r i m d E a L t t h A w y v u s T t A l S m r S d a 8 V n u e v a Stratfield S H s P A o Hickory St v t p P e S t A L o d e f i Toilsome Hill n t o e l l i i i t n t Exit 5 c e l m W n d B species is collected and compiled by the g R s w n eers R t t Pl h l S o d n S c S e d y u R S o s v a t t d v l e u t n r a e l e e d m t A R S t Rose St t y y S S r e y o S d R o S G m h S n t d d d E Natural Diversity Data Base (NDDB) e Ave r e R L d e b r Hillsid l s d n t S e u t d 5 r n i v e l o t e B s R a R L x v ocus c d t n l St t 2 y N l a a o a A v l a e l t i i S a a a s l a p A L t m t N r l e S D m H d d S y H A l from a variety of data sources . Exact o t F A c o o e R s R d i e l v r o l E N o h e w k A o y c H A r d i A C m f y n r o k V o t b H o t R t le H t a r S w o o v u n r S s s w l r e e P a l w a m t S o t e t o i e e e t D locations of species have been buffered to D e H In l t a o t t D c H o n t a P Stratford F T S S A S

M H M e W n e a r e k h d i S t e i e d b v t G S a r o v B C l e u r ana o g an h R A n a e R l r R 7 o Rd t d n i o l R l S e o r n d f o v B s ie F e o B K produce the generalized locations. 2 p L e o l d t d L d c i d e i t n t A C w n l v o r m p h l l o 1 v i S e g e a n e i a o n A o f l o o S h o L f n C A n t n v A l M y B g t u l i o a w v a u R P o v v l k A s l c e e d w e t T e a t c e d e w n m S e e i l o v g t J i r P d i L k r l S H R e n o H l d t H i e D A S c

W s S i a d E w H R k l B A w Bridgeport e e o S l r This map is intended for use as a n l r t t y o l d o i P n w o y T v e e a t r o a a v Mill Hill n d D 5 u l e v a t d n A u S 8 a l e t P w l r O a t r s l g A L S d r e v en W Exit 32 k S e

t k i d M H St t den S Og a preliminary screening tool for conducting a r e k W B d t

v

t R A u c R m e t i g i t l r v S a l r o o v A s r S a e l

d Melville Village d A m

a o d e r e t O n B n c f R v a A o F A e n a w Exit 3 i u A R i i Natural Diversity Data Base Review k T o l i t o v c Graham S v c d l 58 d d t s t B G a l e i l r e n an a

t S u R W t S a h N A S R l V O r c S

e w d M W o o l v o t v h

B

s e le O o Request. To use the map, locate the project r c r East Bridgeport p e i e f C m eorge St e l h G W n a t D k r y Ba r St i t rn iste L u oll a m A M t Av H l g k e a d r a w S K a o S D T Y S i C v F u r n t S C a H u o e rescen R t 113 o e t A t p F v e e n r boundaries and any additional affected areas. o h r i t t r a s d S S t e t k r e v S r S a e V r r v o n r p A A t S e i l r u rd Jane e l St e s d A o t p tf o l ra t t u d A t M v l s S R L r t t g n a e R n a i v e a s e If the project is within a hatched area there B n u a a k v n p q S d S t i n e r Exit 31 d A r l H K o o Floral Way d r e r r lg o e o A m A A t ll S t r e n v e R G a K c t n p R v J i m a am e S e v l v b n t S e A s e I s A S v H a n S x y l r S may be a potential conflict with a listed S e t o v A E A a r e P C t o m l t w m A h f n M k g t t ll S w e n d r i e r n i e a a li o s H i e v a ll S n i 3 e e e 5 e i o s N t d P d T l u ol v o a v r species. For more information, complete a v t n L B V e G S r P o R t d A Fairfield n r h r L a Bir w n A a e Exit 31 D dseye St t e i W t t

D e l w A fo e d S n i v S n S d P r C V r a e a V J v d S u z o a R R A A t a Request for Natural Diversity Data Base d s R d t l h e t t L i i i v Newfield o i W t a d r n t e o Sed r s V n y e g s gew e o t e o e ick A k S t v ve o d o n U h M r o s t B H i t r e p C e n w S t o lt P ll d o t S Exit 28 S l A o h n n v s u o S r i Tunxis Hill o h y m v t A s Exit 29 e State Listed Species Review form R w o S o e Exit 2 i A y B S e J l b M t o r M a v a s f H u o d d e s c o v r r a y r e a n A s H d e S n r v t P d W R m d o B u i e a d M e it n d a r h o C H A A Exit 30 n r r H e E S r g d (DEP-APP-007), and submit it to the NDDB d i n v A a S A R d i a w g t B v D u g v D H n D g c e G B l e e i e R W t n v e n n e o a d h y S e h t s c t r o k a y e t t Exit 30 c n r n D h o k n o r S a S D S J S s t z n A r o ef a t a e r along with the required maps and r S o t d e Exit 1 r a fe e d S t i t v ov t L rs s L e id t S F d o e a A e an s a on e H i o R v S H f S R K O w S t H e e M a atha e e L L way D W information. More detailed instructions are h v y t r d v r A e y F g e l R n A s l i d d s r i L g n a t t t S R A H g l le a b S l t ta l n s e a gs t t ve n e e t provided with the request form on our s m G u i ad A e t a o u r in s r Railro Exit o27 d R D S s A S H N l A n a ce B R R C e n mer n t w s e m S h v s v o t t J L C C o S Bridgeport y e a n e o y e 1 c o t e J r c r P s website. r Exit 25 v o 1 A A i 3 o C v n t g ve H n e w St A r A l r e L t e ine sity l d r 1 Ee xit 25 P h G t er u r s S v R e S v i t ni L e s n t c u S U o n d s e e e A Exit 26 r d h £ t B k c e n ¤ v o i v d S t L A t p a A t n s R W w d e e t S e i d h n t s l A n in t D S S vi r a L ip r a e w o a i d tl o v r D f B o M t A R o r G e r e lv www.ct.gov/deep/nddbrequest i S r d m d a e o d a i d 1 v l H Exit 24 t t v r e l F e w R S y k A P w n D R Bridgeport M R w o B d ra k ic d t l y o H F t a o a e a n Dr d S B e i u 1 r e a ew r n i t r r l v 3 U e t d n R o un G w C A So Use the CTECO Interactive Map Viewers R d 5 y n d F r w D s Bridgeport a d Black Rock

H a R F t T H e d 1 e a o L a i r t e o i r d s v v S l n v x S is at www.cteco.uconn.edu to more precisely u g i r l r C g £ A d e ¤ F R i n S t B n i 135 e d s e 113 K o o t a t d w Sd c S o V d V o n v h t l search for and locate a site and to view n S R A w n S S e B t

v R e n t d v m d e K e a n A u d v aerial imagery with NDDB Areas. Pe d R la e t n rry A v r S R w m Exit 23 d h a t o w i A l e g B n r ie M i Hen a k v s r ry St o B r t a g b e n n G a i o v W t L e B QUESTIONS: Department of Energy and i o W S l r m r S Lordship

t i G d o a Exitli 22 d r g Environmental Protection (DEEP) r n D E t R D e s s p S all Po e S hore d o line Mill Plain W on i t Dr 79 Elm St, Hartford, CT 06106 st s r o B r t B e e - t n Grover Hill P S U s iv o email: [email protected] y 5 n o R 9 n r e I q t l d R E d u d a J 5Exit 21 o R m a 9 C es e Phone: (860) 424-3011 r I w t ra B s i lvd f B a C g f o o P e lo l R P n r s t i d d al l D o d S B r R n F Post O ea t e c a h S p R i P r r S R d f e o e m h i n o e n f d h P it i a l d h e d a A T i ld v n u R S R L e P a R e d t o R l w ll d l ie e C f la y d t n F B r l S d e J l l O s v a a R d e e r x l R v d k M r is e a R R o h e C n f t d C d R 0 0.a5 1 d

T e Rita Ave r Miles ±

Prepared For: Doosan Fuel Cell America Inc.

Point of Contact: Walter Bonola

Prepared by: Acoustical Technologies Inc. 50 Myrock Avenue Waterford, CT 06385-3008

Subject: Bridgeport New Power Twenty-One Fuel Cells Airborne Noise Assessment At 600 Iranistan Avenue

Author: Carl Cascio

Date: May 8, 2020

Revision: 1 Acoustical Technologies Inc. Table of Contents Page

Summary 2

Introduction 4

Development of the Acoustic Assessment Plan 4

Acoustic Measurement Program 5

Data Analysis 8

Allowable Noise Levels 16

Impulse Noise 17

Prominent Discrete Tones 17

Infrasonic and Ultrasonic Noise 18

Overall Sound Pressure Levels 19

Conclusions 22

References 22

Country of Origin is the United States of America

Summary

This document makes an acoustic assessment that should help in meeting any acoustic noise concerns during the operation of twenty-one Doosan 460 KW fuel cells at the 600 Iranistan Avenue site in Bridgeport, CT. An acoustic assessment plan was developed and executed to acquire airborne acoustic information to explain and mitigate the potential airborne noise issues associated with operation of the Doosan fuel cells. It is important to show that the airborne noise generated by the fuel cells will not significantly impact the facility’s neighbors. On site acoustic testing after installation of the fuel cells is recommended to confirm that the acoustic environment at the nearby properties due to the fuel cells is acceptable.

2 Acoustical Technologies Inc. The airborne noise levels expected to be generated by the twenty-one Doosan fuel cells operating at the Bridgeport site were simulated by exciting a set of six co-located speakers at the fuel cell Cooling and Power Module positions. (The Cooling Module is the dominant noise source.) The six speakers produced an overall airborne noise level that was 6 to 12 dB higher than the levels measured for a similar Doosan fuel cell installed at New Britain High School in New Britain, CT. One-third octave band analysis showed the speakers to be near the New Britain fuel cell airborne noise levels at frequencies up to 250 Hertz where the airborne noise levels were low and to exceed the fuel cell signature by 5 to 20 dB at higher frequencies where the fuel cell signature was higher in noise level. Airborne noise with the speakers operating was measured at distances from 5 to 160 meters from the proposed fuel cell locations at the Bridgeport site. The speakers produced overall A-weighted sound pressure of approximately 86 to 87 dBA at 5 meters and 77 to 84 dBA at 10 meters (ref 20 microPascals) from the proposed fuel cell locations at ground level. Airborne noise from the speakers at nearby properties was measured at levels from 53 to 73 dBA. The highest property line measurement was 73 dBA at 571 Iranistan Avenue. Industrial Zone measurements on Railroad and South Avenues were lower because of the longer distance to the speakers. Beyond 80 meters the speakers could not be heard. Analysis of the speaker data indicated propagation losses from 8 to 25 dB from the fuel cell location to the nearby property lines. The acoustic source level at 10 meters from the operation of a Doosan fuel cell at New Britain High School was then used as a basis for making the Doosan fuel cell airborne noise estimates at all the locations. Airborne noise estimates from one fuel cell were than scaled up to 21 fuel cells using the “noisetools” application to account for the height of the installed Cooling and Power Modules. A power summation of the twenty-one individual Cooling and Power Module estimates was then used to produce an overall sound level at each of six property lines.

Operation of the twenty-one Doosan fuel cells without noise mitigation may produce noise levels above both the Industrial and Residential Zone noise limits at some of the closest nearby properties. Background noise levels at properties near Interstate I95 often exceed the 51 dBA night time noise limit. The closest Residential Zone properties may be above the night time residential noise limit of 51 dBA with predicted airborne noise levels of 58 to 62 dBA with the twenty-one fuel cells on. These predicted levels may not exceed the background noise by 5 dB. The nearest industrial property at 571 Iranistan Avenue could see a noise level of 70 to 71 dBA. Airborne noise levels along South and Railroad Avenues should be below 69 dBA. The highest expected residential airborne noise level may be 62 dBA at the residence at 720 Black Rock Avenue. Other nearby residences on Black Rock Avenue should see similar noise levels. Airborne noise from the twenty-one fuel cells might have to be mitigated to preclude the combined Cooling and Power Module noise from exceeding both the 70 dBA industrial limit and the night time residential limit of 51 dBA. This mitigation should be designed to provide sufficient sound attenuation to show that the airborne noise generated by the fuel cells will not significantly impact the facility’s very closest neighbors. The major goal to reduce the airborne noise to levels below 51 dBA or below 5 dB above background at the nearby residences on Black Rock, Garden and South Avenues is recommended. This will also reduce the airborne noise along Railroad Avenue where the few residences in the Industrial Zone will also benefit.

The Connecticut’s Noise Code (Reference 1) also calls for review of acoustic issues associated with impulse noise, prominent discrete tones, infrasonic and ultrasonic noise. Operation of the twenty-one fuel cells is expected to meet all of these requirements at all of the nearby properties.

3 Acoustical Technologies Inc. Introduction

Acoustical Technologies Inc. was tasked as part of a Doosan site permitting process with an assessment of potential acoustic issues associated with fuel cell airborne noise reaching the properties adjacent to 600 Iranistan Avenue in Bridgeport, CT. Responding to a request from Walter Bonola, a site visit was made on April 23, 2020. During the visit, a survey of the airborne noise levels produced by a set of speakers simulating the airborne noise produced by a Doosan Fuel Cell was made in order to identify potential airborne noise issues. Airborne noise measurements were taken to quantify the propagation of the simulated fuel cell airborne noise to the adjacent properties. Background airborne noise levels were also made with the speakers off. This document provides an acoustic assessment to assist in meeting acoustic noise concerns during the permitting process for the siting of twenty-one Doosan fuel cells at 600 Iranistan Avenue in Bridgeport, CT.

Development of the Acoustic Assessment Plan

The purpose of this effort is to acquire acoustic information useful in explaining the potential airborne noise issues associated with the operation of twenty-one Doosan 460-kiloWatt fuel cells at 600 Iranistan Avenue in Bridgeport, CT. The site at 600 Iranistan Avenue is located in a Mixed Use – Light Industrial Zone near Interstate 95 and is surrounded by a Mixed Use – Light Industrial Zone to the west and Industrial Light Zones to the north and south, as well as Residential Multi-Family Zones to the north, north east and south east. (The Bridgeport zoning map near the site is given below.) It is important to determine whether the airborne noise generated by the twenty-one Doosan fuel cells will impact these neighbors.

The acoustic impact is assessed in the following way. The 460-KW fuel cells are yet to be installed so there is no way to measure fuel cell operating airborne noise levels at the new site. The fuel cell airborne noise has been measured at other sites and both overall and one-third octave band airborne noise data of Doosan 400- and 460-KW fuel cells are available (References 2 and 3). The only difference between the 400-KW and 460-KW fuel cells is the electrical output of the cell stacks. The rest of the hardware including fans and fan noise remain the same between the models. Using this data, a set of six speakers have been programmed through a set of octave and one-third octave band filters to generate a noise spectrum similar to that of the new fuel cells. (It is assumed that the Cooling and Power Module noise in the two measured units are similar to the new units.) This spectrum will then be played through an audio amplifier to create the electrical voltage necessary to drive the six speakers. In order to overcome the potentially high background noise at the site the speaker output will be increased to levels that vary from 6 to 12 dB higher than the overall airborne noise level measured on one 460-KW fuel cell at a distance of 10 meters.

With the six speakers on, this approach then follows the traditional “What is the airborne noise level at the neighbor’s property line?”. The six speakers were run and airborne measurements made near the proposed fuel cell locations and at the nearest neighbor’s property lines. This measured site data can also be used to estimate noise levels at other neighbor’s property lines. Using the measurements for one fuel cell, the performance of twenty-one fuel cells will then be scaled up to account for all the fuel cells operating at the same time. The City of Bridgeport has

4 Acoustical Technologies Inc. a Noise Ordinance (Ref. 4) with similar noise requirements to the State of Connecticut’s Noise Ordinance and both have been consulted to assess the impact of the measured and estimated acoustic levels. Because of the closeness of the fuel cell site to the nearby properties noise mitigation may be recommended if the airborne noise estimated for the twenty-one fuel cells comes near or exceeds the airborne noise requirements at the neighbors’ property lines.

Acoustic Measurement Program

The acoustic data necessary to assess the impact of the twenty-one fuel cells are described below: Airborne sound pressure measurements and audio tape recordings were conducted at the 600 Iranistan Avenue site on April 23, 2020 during the daylight hours (11 am – 2 pm). This testing established both background airborne noise levels and simulated airborne noise levels with the speakers operating. The overall A-weighted airborne noise measurements were made with an ExTech model 407780A Digital Sound Level Meter (s/n 140401544) that was calibrated prior to and just after the test with a Quest model QC-10 Calibrator (s/n Q19080194). Measurements were taken with A-weighting (frequency filtering that corresponds to human hearing) and with the sound level meter in a Slow response mode. For reference, a noise level increase of 1 dB is equal to an airborne sound pressure increase of 12.2 per cent. The audio tape recordings were made with a Sony Digital Audio Tape Recorder (model TCD-D7 s/n 142000) with microphones on channels 1 and 2. The two PCB microphones (model 130F20 s/n 53933 and 130F20 s/n 53994) were powered by two Wilcoxon P702B power supply/amplifiers (s/n 1992 and 1995 respectively). The PCB microphones were also calibrated prior to and after the test with the Quest model QC-10 Calibrator (s/n Q19080194). All of the measurements were made with the microphones and sound level meter at a height above ground between five and six feet. A Hewlett Packard model HP3561A Dynamic Signal Analyzer, s/n 2338A00659, was used to perform A-weighted spectral analysis on the tape-recorded data. The tape-recorded data were also used to verify the ExTech sound level meter overall dBA readings.

At the 600 Iranistan Avenue site “speaker on” and background airborne noise measurements were taken near the two speaker locations and at the following nine nearby property lines:

Location Business Distance Zone Type A - 600 Iranistan Avenue Building North End 5 &10 meters MU Industrial Light B - 600 Iranistan Avenue Building South End 5 &10 meters MU Industrial Light P1 – 792 Railroad Avenue Residence 80/68 meters Industrial Light P2 – 780 Railroad Avenue Residence 65/63 meters Industrial Light P3 – 756 Railroad Avenue Business 50/68 meters Industrial Light P4 – 744 Railroad Avenue Greenskeeper Lawn 58/52 meters Industrial Light P5 – 571 Iranistan Avenue Business 60/25 meters MU Industrial Light P6 – 478 Iranistan Avenue Nunes Auto 80/75 meters Industrial Light P7 – 840 South Avenue Nunes Auto Repairing 75/85 meters Industrial Light P8 – 800 South Avenue Veolia Water 93/120 meters Industrial Light P9 – Garden & Railroad Ave Parking Lot 160/195 meters Residential M-Family

See the Google satellite map in Figure 1 for the approximate measurement locations. Position A was located at the center of the east end of the building while Position B was at the center of the

5 Acoustical Technologies Inc. west end. Measurements at 5 and 10 meters from these proposed operating Cooling and Power Module sites were simultaneously taken with the ExTech sound level meter and two microphones recording on the digital tape recorder. Figures 2 and 3 provide photographs of the site locations for Positions A and B as well as the sensors at 5 and 10 meters. At speaker locations A and B, a one to two-minute record of the acoustic noise was stored for the speakers in the “on” condition at the start and end of the airborne noise measurements. There was a decrease of about 4 dB in sound output from the speakers for Position B. One minute of background airborne noise data were also recorded after the speaker “on” measurements.

Figure 1. Bridgeport - 600 Iranistan Avenue Site Map from Google Maps

P11

P9

P4 P3 P1 P2

A

B P5

P8

P7

P6

P10

Airborne noise measurements taken outside are corrupted by rain and wind so a day was selected when the winds were expected to be 10 miles per hour or less. Table 1 provides the weather data at New Haven Airport (closest data to 600 Iranistan Avenue) for the acoustic measurements on April 23, 2020. Measurements were taken over the period from 11:00 am until 2:00 pm. The table below shows the temperature and wind speeds in hourly intervals. Wind conditions were very good for most of the day with only one period as high as 10 mph (12:53 pm). Acoustic

6 Acoustical Technologies Inc. measurements were further enhanced by the shielding provided by the railroad wall to the west. The wind did not affect the operating and background airborne noise measurements. There was no rain during the testing on April 23. The traffic noise from Interstate 95 next to the 600 Iranistan Avenue site generated most of the background noise for all of the measurement locations. Motor traffic along Iranistan, South and Railroad Avenues was light and few of the measurements had to be delayed until no traffic was present. Background noise levels at all but one of the measurement positions were acceptable with levels from 53 to 56 dBA. The locations nearest to the I95 highway had the highest levels (60 – 63 dBA). The noise level at Garden and Railroad (P9) was 61 dBA, 10 dB above the residential night time noise requirement. This background noise level would made it difficult to hear the speakers at any level below 55 dBA.

Figure 2. Position A – Building North End at the Bridgeport 600 Iranistan Avenue Site

770 Railroad Ave P1

10 m Speakers

10 m 5 m

North East Bldg Corner

Table 1. Approximate Bridgeport (East Haven) Weather Data on April 23, 2020 https://www.wunderground.com/history/daily/KHVN/date/2020-4-23

Wind Temp. Humidity Dew Point Barometer Wind Time (EST) Speed Condition (°F) (%) (°F) (in HG) Direction P1 (mph) P1 7:53 AM 41 F 49 % 23 F 30.06 in 6 mph WSW PartlyCloudy 8:53 AM 41 F 45 % 21 F 30.07 in 5 mph WNW Cloudy 9:53 AM 42 F 43 % 21 F 30.09 in 5 mph SSW Cloudy 10:53 AM 43 F 43 % 22 F 30.08 in 5 mph WSW Cloudy 11:53 AM 44 F 45 % 24 F 30.07 in 8 mph SSW Cloudy 12:53 PM 44 F 45 % 24 F 30.06 in 10 mph SW Cloudy 1:53 PM 44 F 51 % 27 F 30.05 in 6 mph WSW Cloudy 2:53 PM 45 F 46 % 25 F 30.03 in 9 mph WSW Cloudy 3:53 PM 45 F 52 % 28 F 30.02 in 9 mph SSW Cloudy 4:53 PM 45 F 52 % 28 F 30.00 in 3 mph S Cloudy

7 Acoustical Technologies Inc. Figure 3. Position B - Building South End at the Bridgeport 600 Iranistan Avenue Site

Speakers

5 m 10 m 571 Iranistan Ave

North West Bldg Corner

Note: The speakers were raised to a height of about 10 feet above ground to provide a better path for sound to reach over the railroad tracks to the north (as shown in Figure 2).

Data Analysis

This section analyzes the airborne noise levels measured at the Bridgeport site and then estimates the source level and transmission loss to nearby property lines expected during actual fuel cell operation. Both background noise levels at the Bridgeport 600 Iranistan Avenue site and the measured speaker operating noise levels are reported in Table 2. The background data are used to correct the measured operating airborne noise levels providing estimates of only the speaker 10 m noise contribution at each location. Table 3 then reports estimated equipment operating noise levels for a single fuel cell. A following section will then develop noise estimates for all twenty- one fuel cells. Comparing the twenty-one-fuel cell estimated levels with the state and city noise limits will identify which nearby locations may or may not meet the airborne noise requirements. Position P10 is at 753 South Avenue at the bottom of Figure 1. Position P11 is at 270 Black Rock Avenue and is shown at the top of Figure 1. These and P9 are the closest residences in the nearby Residential Zones and will be analyzed to determine their expected airborne noise levels.

The complete set of overall A-weighted airborne noise levels measured at the Iranistan Avenue site are provided in Table 2 for the conditions with the speakers on and off. The range from the speakers to the microphone locations shown in Table 3 were calculated with Google Maps. Each value is the range to the center of the Position A and B speaker locations. The closest location is P5, which is about 25 meters south west from Position B to the business across the street at 571 Iranistan Avenue. The second closest location is P3, which is about 50 meters to the north from Position A and is a business that is on the other side of the railroad tracks. The next closest measurement locations where the speakers could actually be heard were at distances from 52 to 8 Acoustical Technologies Inc. 80 meters from the speakers. Beyond 80 meters the speakers could not be heard. The closest residential zone property is 110 meters to the north at 270 Block Rock Avenue. The residential properties along Garden and South Avenues are at least 165 meters away. Airborne noise at the residential zone locations to the north, north east and south east could not be heard when the speakers were operating due to the high background noise level from Interstate 95.

Table 2. Measured Overall Sound Pressure Levels in dBA reference 20 microPascals

Speakers Bkgd Speakers Bkgd Location Background Background A Corrected B Corrected Speaker 5 m 87.1 65.3 87.1 85.9 62.3 85.9 Speaker 10 m 83.7 65.4 83.6 77.5 64.6 77.3 P1 – 792 Railroad Ave 57.0 58 <50 63.6 58 62.2 P2 – 780 Railroad Ave 58.5 57 53.2 61.2 57 59.1 P3 – 756 Railroad Ave 60.3 56 58.3 58.7 56 55.4 P4 – 744 Railroad Ave 60.3 59 54.4 58.2 59 <50 P5 – 571 Iranistan Ave 64.5 63 59.2 73.1 63 72.7 P6 – 478 Iranistan Ave 63.7 58 62.4 63.9 58 62.6 P7 – 840 South Ave 63.3 59.5 61.0 59.5 - P8 – 800 South Ave 63.6 60.6 60.6 60.6 - P9 – Garden&Railroad 60.4 61 <55 61.7 61 53.5

Figure 4. Bridgeport Zoning Map Showing the Doosan Fuel Cell Site

LI R-C

Site MU - LI I-L

R-C

9 Acoustical Technologies Inc. A comparison of the airborne noise produced at 10 meters by the Doosan fuel cell at the New Britain High School site with the airborne noise produced by the speakers at the Bridgeport site is shown in Figure 5. The speakers are near the fuel cell airborne noise for frequencies below 250 Hertz and greatly exceed the fuel cell airborne noise at the middle frequencies where the fuel cell airborne noise levels are the highest. The overall airborne noise levels are 12.1 and 5.8 dB higher for the speakers at Site A and Site B locations, respectively, as compared to what was expected from the Doosan 460 KW fuel cell that was measured at New Britain High School in New Britain, CT. The differences in level were subtracted from the Bridgeport measured levels to estimate the expected fuel cell’s acoustic signature at each location for a 10-foot-high source. These noise calculations are displayed in Table 3 below. The New Britain fuel cell airborne noise levels at 10 meters for one fuel cell were used with the Bridgeport speaker data to estimate the expected single fuel cell airborne noise for nearby neighbors at the Bridgeport 600 Iranistan Avenue property lines. Next, we will scale the expected airborne noise for twenty-one fuel cells.

Figure 5. At 10 Meters, 6 Speakers Generate Airborne Noise Above That of a Single Fuel Cell

Fuel Cell Versus Speaker Comparison in dBA re 20 uPa 80

70

60

50

40

30 Position A at 10 m 20 Position B at 10 m

10 Fuel Cell Average at 10 Meters

0

Frequency in Hertz

The estimated airborne noise levels to be produced by a single Doosan fuel cell are shown in Table 3. For each of the nine locations the Bridgeport measurements are corrected to account for the higher speaker levels. The fuel cell noise correction at the Site A Cooling Module location is estimated to be 12.1 dB because the speaker levels are that much higher than the New Britain fuel cell level. The speakers at the Site B Power Module were estimated to be 5.8 dB higher. (These estimates are based on the overall dBA readings for the two sets of measurements. If individual one-third octave band values were calculated and then averaged over the frequencies of interest, the result would be numbers about 1 higher. The lower, more conservative overall noise level values were used in this report to scale the speaker data.) 10 Acoustical Technologies Inc. The measurements at the 600 Iranistan Avenue site were taken at various distances from the speakers and then background corrected. Close to the speakers at 571 Iranistan Avenue the maximum airborne noise values are expected to be as high as 67 dBA for one fuel cell, which is slightly below the industrial noise limit. A pure power summation of 21 fuel cells would bring this number up to 80 dBA. This is not expected because most of the 21 fuel cells are much further away than 25 meters. Only three are at the west end of the building while the others can be as far as 60 meters away. However, the three closest fuel cells, if at ground level, would add about 4.7 dB to the noise level and produce about 72 dBA at the 571 Iranistan Avenue neighbor. The other significant difference from the Bridgeport measurements and the actual installation is that the Cooling Modules that generate most of the airborne noise will be located on the fourth floor of the building, some 51 feet above the ground level. This is 41 feet higher than where the speakers were and this difference in height needs to be addressed. All the other industrial properties are expected to have levels from a single fuel cell below 57 dBA for a single fuel cell. A pure power summation of 21 fuel cells would bring this number up to about 70 dBA, the industrial limit. This is not expected to happen because most of the units would be at greater distances and higher up on the building. The two highest levels at locations P3 and P6 will be analyzed to confirm that twenty-one fuel cells will not exceed the industrial noise limit. Nearby property in the Residential Zones to the north, north east and south east will also be analyzed.

Table 3. Expected Overall Sound Pressure Levels, dBA ref. 20 microPascals for One Fuel Cell

Range in Position A Speakers Position B Speakers Location Meters Correction Estimated at Correction Estimated at A A / B SPL in dBA B SPL in dBA P1 – 792 -12.1 -5.8 80/68 <50 <38 62.2 Railroad Ave 56.4 P2 – 780 -12.1 -5.8 65/63 53.2 41.1 59.1 Railroad Ave 53.3 P3 – 756 -12.1 -5.8 50/68 58.3 46.2 55.4 Railroad Ave 49.6 P4 – 744 -12.1 -5.8 58/52 54.4 42.3 <50 Railroad Ave 44.2 P5 – 571 -12.1 -5.8 60/25 59.2 47.1 72.7 Iranistan Ave 66.9 P6 – 478 -12.1 -5.8 80/75 62.4 50.3 62.6 Iranistan Ave 56.8 P7 – 840 -12.1 -5.8 75/85 61.0 48.9 - South Ave - P8 – 800 -12.1 -5.8 93/120 60.6 48.5 - South Ave - P9 – Garden -12.1 -5.8 160/195 <55 42.9 53.5 & Railroad 47.7

Red indicates locations above the industrial noise limit of 70 dBA – there are no levels that high

11 Acoustical Technologies Inc. The propagation of sound from the Cooling Modules on the fourth floor of a building is analyzed in the following way. The Cooling Module configuration has 21 modules in three rows of seven each. The first calculation concerns the propagation to the property at 571 Iranistan Avenue. The first three cooling modules are approximately 25 meters horizontal from the property line. The next three cooling modules are about 29.2 meters away, followed by three at 33.4 meters, followed by three at 37.6 meters, followed by three at 41.8 meters, followed by three at 46 meters, and followed by the last three at 50.2 meters. Sound estimates will be calculated at each of these distances and 4.8 dB added to the results for the three units at each distance. The estimates will be made for receiver heights of 5, 15 and 25 feet to account for multiple floors in the business at 571 Iranistan Avenue. The individual calculations will be power summed to account for all 21 fuel cell cooling modules. A similar process will be used for the Power Modules on the second and third floors of the building. The acoustic propagation tool at http://noisetools.net/noisecalculator2 will be used to provide the calculations for the individual modules. The input acoustic power for a single fuel cell is taken from Table 7 of Reference 2.

A typical Cooling Module calculation is shown in Figure 6 below. The cooling module is 51 feet (15.5 m) above ground while the 4th floor is at 45 feet (13.7 m). The middle of the building is about 17.8 meters from the west end of the building. The receiver is 78 feet (23.9 m) from the west end of the building at a height of 5 feet. The estimated SPL is 43 dBA from one cooling module. The other distances have Cooling Module airborne noise levels that vary from a high of 59.2 dBA at the west end to a low of 40 dBA at the east end. These levels are power summed.

Figure 6. 571 Iranistan Avenue Noise Estimate - Cooling Module in the Middle of the Building

12 Acoustical Technologies Inc. Table 4. Expected Overall Sound Pressure Levels, in dBA ref. 20 microPascals

Height 21 Total 21 Cooling 21 Power Max Max 5 Foot Location in feet Estimate Modules Modules Value Measurement P5 – 571

Iranistan Ave 5 69.9 67.2 66.6 P5 – 571 Noise Tool Est 71.4 Iranistan Ave 15 70.7 68.1 67.1 69.9 P5 – 571 Currently only

Iranistan Ave 25 71.4 69.2 67.5 2 story P6 – 478

Iranistan Ave 5 65.1 63.6 59.9 P6 – 478 Noise Tool Est 65.8 Iranistan Ave 15 65.4 63.8 60.2 65.1 P6 – 478 Required

Iranistan Ave 25 65.8 64.3 60.3 70 dBA P3 – 756

Railroad Ave 5 67.9 66.6 62.2 P3 – 756 Noise Tool Est 68.9 Railroad Ave 15 68.5 67.1 63.0 67.9 P3 – 756

Railroad Ave 25 68.9 67.5 63.4 P9 – Garden

& Railroad 5 57.6 56.3 51.8 P9 – Garden Noise Tool Est 58.1 & Railroad 15 57.9 56.6 52.0 57.6 P9 – Garden Required

& Railroad 25 58.1 56.8 52.1 51 dBA P10 - 753 (night time)

South Avenue 5 57.8 56.5 51.7 P10 - 753 Noise Tool Est 58.1 South Avenue 15 58.1 56.9 51.9 55.8 2 Story Only on South Ave P11 – 270

Black Rock 5 61.0 59.7 55.3 P11 – 270 Noise Tool Est 61.6 Black Rock 15 61.3 60.0 55.5 59.0 P11 – 270

Black Rock 25 61.6 60.4 55.6

The calculations for sources at different heights are based on the acoustic propagation tool at http://noisetools.net/noisecalculator2. To calibrate this tool, it was used to check the measurements that were made with the speakers at a height of 10 feet. Measured data from four of the property lines was compared to the “noisetools” result for the same speaker – receiver 13 Acoustical Technologies Inc. distances. The average difference between the measurements and the “noisetools” results was 0.2 dB. Because some differences were plus and some minus the standard deviation was 2 dB. For example, the measured level at 571 Iranistan Avenue was 72.7 dBA while the calculation was 69.7 dBA. To adjust for this variability 2 dB was added to the estimate for 21 fuel cells.

The calculation results for expected airborne noise are shown in Table 4 above. The highest airborne noise levels are expected to be at 571 Iranistan Avenue in the Industrial Zone. The expected level is just above the noise requirement and varies from 0.1 dB below to 1.4 dB above the allowed level depending on the receiver height (or floor). The maximum airborne noise at 478 Iranistan Avenue and 756 Railroad Avenue are at least 4 dB and 1 dB below the requirement, respectively. Other Industrial Zone properties should be further below the requirement. The three estimates for residential properties are expected to be from 6.6 dB to 10.6 dB over the residential zone night time noise limit of 51 dBA.

Figures 7, 8 and 9 show typical cooling and power module calculations for the properties at 478 Iranistan and 756 Railroad Avenue as well as the property at the corner of Garden and Railroad. Figure 7 shows the Cooling Module calculation for the units at the north end of the building. Figure 8 shows the Power Module calculation for the units at the south end of the building. Figure 9 shows the Power Module calculation for the units at the west end of the building. For each address the individual calculations are combined to produce a total noise level for the 21 Cooling Modules on the 4th floor as shown above. Similar calculations are made for the 21 Power Modules on the 2nd and 3rd floors. The third column has the total airborne noise. The two floors of Power Module noise estimates are combined in the results shown in the fifth column.

Figure 7. 478 Iranistan Avenue Estimate - Cooling Module at the Opposite End of the Building

14 Acoustical Technologies Inc. Figure 8. 756 Railroad Avenue Noise Estimate - Power Module at Opposite End of the Building

Figure 9. Garden & Railroad Ave Estimate – Cooling Module at Opposite End of the Building

15 Acoustical Technologies Inc. Allowable Noise Levels

The Connecticut regulation for the control of noise provides in CT section 22a-69-3 (Ref. 1) the requirements for noise emission in Connecticut. CT section 22a-69-3.1 states that no person shall cause or allow the emission of excessive noise beyond the boundaries of his/her Noise Zone so as to violate any provisions of these Regulations. The Bridgeport Noise Ordinance has the same noise levels as the CT Noise Ordinance but redefines daytime and night time as "Day-time hours means the hours between seven a.m. and six p.m. Monday through Friday, and the hours between nine a.m. through six p.m. on Saturday and Sunday” (Reference 4). These ordinances will be used to evaluate the noise generated by the twenty-one Doosan 460 KW fuel cells. Following sections discuss each type of noise using the results obtained from the New Britain and Mount Sinai fuel cell measurements as well as the Bridgeport speaker measurements.

The southern part of the Bridgeport zoning map near Iranistan Avenue is given in Figure 4. As stated above, this site at 600 Iranistan Avenue is located in a Mixed Use Industrial Light Zone near Interstate 95 and is surrounded by Mixed Use Industrial Light Zone to the west, Residential Zones to the north, north east and south east as well as Industrial Light Zones to the north and south. The closest residential property is 110 meters away on Black Rock Avenue to the north on the other side of the Amtrak tracks in a R-C Residential Multi-Family Zone. Other residences to the north east and south east are at least 160 meters away. Sound from the ATI speakers cannot be heard or measured at any of these locations. The acoustic estimates from position P9 show

that the speaker noise was below 55 dBA at a distance of 160 meters.

Figure 10. Acoustic Airborne Noise Weighting Curves

16 Acoustical Technologies Inc. Impulse Noise

The Connecticut noise code states in CT section 22a-69-3.2 (part a) Impulse Noise that no person shall cause or allow the emission of impulse noise in excess of 80 dB peak sound pressure level during the night time to any class A Noise Zone. Night time is defined as 10 pm to 7 am. CT section 22a-69-3.2 (part b) Impulse Noise states that no person shall cause or allow the emission of impulse noise in excess of 100 dB peak sound pressure level at any time to any Noise Zone. Bridgeport has the same 80 dB and 100 dB noise limits but defines night time as 6 pm to 7 am.

Impulse noise in excess of 80 dB was not observed on the tape-recorded data during any of the measurements of the Doosan 460 KW fuel cell made at the New Britain High School on 30 July, 2018. This fuel cell design is similar to the unit that will be installed in Bridgeport. Given the steady state nature of the fuel cell’s noise signature there should be no acoustic issues with the Bridgeport and State of Connecticut’s impulse noise requirements.

A few words are in order to discuss the difference between A-weighted and un-weighted impulse noise. A-weighting emphasizes the middle and higher frequencies while reducing the influence of the low frequencies. Figure 10 plots the A-weighting curve versus frequency in blue. Below a frequency of 1 kiloHertz the acoustic level is attenuated by increasing amounts. The reduction is about 10 dB at 200 Hertz, 20 dB at 90 Hertz and 30 dB at 50 Hertz. It also reduces the level at very high frequency being down in level by 10 dB at 20 kiloHertz.

Prominent Discrete Tones

The Connecticut regulation for the control of noise states in CT section 22a-69-3.3 Prominent discrete tones: Continuous noise measured beyond the boundary of the Noise Zone of the noise emitter in any other Noise Zone which possesses one or more audible discrete tones shall be considered excessive noise when a level of 5 dBA below the levels specified in section 3 of these Regulations is exceeded. Bridgeport’s noise regulations do not mention discrete tones. The CT Regulations establish different noise limits for different land use zones. Residential (homes and condominiums) and hotel uses are in Class A. Schools, parks, recreational activities and government services are in Class B. Forestry and related services are in Class C. By my reading of the regulations the 600 Iranistan Avenue fuel cells are a Class C emitter in an Industrial Zone. The noise zone standards in CT section 22a-69-3.5 state that a Class C emitter cannot exceed the following overall sound pressure levels:

To Class C 70 dBA To Class B 66 dBA To Class A 61 dBA (day) 51 dBA (night)

The discrete tones limits are 5 dBA lower so that no tone may be higher than the following:

To Class C 65 dBA To Class B 61 dBA To Class A 56 dBA (day) 46 dBA (night)

To address the discrete tone issue, we use measured data from the testing of a similar Doosan fuel cell (Reference 3). This data does not have A-weighting. The photo in Figure 11 plots the airborne noise measured 10 meters from the Mount Sinai Cooling Module (Reference 3) for frequencies from 0 to 1000 Hertz. This curve shows the two largest discrete tones produced by

17 Acoustical Technologies Inc. the Doosan Fuel Cell Cooling Module. The first tone is at 86 Hertz at a level of 65 dB reference 20 microPascals. The second tone is at 630 Hertz at a level of 56 dB reference 20 microPascals. (88.6 dB added to the dBV values in the figure.) The A-weighting corrections are -21.5 dB at 86 Hertz and -1.9 dB at 630 Hertz. Incorporating these corrections gives A-weighted levels of 44 dBA at 86 Hertz and 54 dBA at 630 Hertz (for one fuel cell) both at a distance 10 meters from the Cooling Module. The minimum transmission loss to the property to the south west is 8 dB and 21 Cooling Modules adds 7.2 dB so the maximum possible discrete tone would be 53 dBA at 571 Iranistan Avenue. This level is below the 65 dBA requirement in an Industrial Zone. The minimum transmission loss to the closest Residential Zone property to the north is at least 25 dB and 21 Cooling Modules add 11 dB so the maximum possible discrete tone would be 40 dBA at 270 Black Rock Avenue. This level is below the 46 dBA requirement in a Residential Zone. Operating the twenty-one Doosan fuel cells should produce airborne noise levels well below the CT discrete tone requirement at all the property lines. There should be no acoustic issue with the CT discrete tone noise requirements.

Infrasonic and Ultrasonic Noise

The Connecticut regulation for the control of noise states in CT section 22a-69-3.4 Infrasonic and Ultrasonic that no person shall emit beyond his/her property infrasonic or ultrasonic sound in excess of 100 dB at any time. 100 dB with respect to the reference of 20 microPascals is a sound pressure of 2 Pascals or 0.00029 psi. Infrasonic sounds are sound pressure fluctuations below a frequency of 20 Hertz. Ultrasonic sounds are sound pressure fluctuations at frequencies above 20,000 Hertz. Bridgeport’s noise regulations do not mention infrasonics and ultrasonics.

Narrow bandwidth sound pressure spectrums in dB reference 20 microPascals at the 10-meter Cooling Module location given in Reference 3 can be used to compare with these Infrasonic and Ultrasonic noise requirements. Mount Sinai Hospital airborne noise data were processed in the 0 to 100 Hertz and 0 to 100,000 Hertz frequency ranges. The bandwidth of each data point is 0.375 Hertz for the 100 Hertz range and 375 Hertz for the 100,000 Hertz frequency range. The infrasonic noise for frequencies up to 20 Hertz is shown in Figure 12. The maximum level at 10 meters is 57 dB reference 20 microPascals for one fuel cell. The entire 20 Hertz band can be power summed and equals 66 dB reference 20 microPascals, well below the requirement at 10 meters. The closest property is at 25 meters so the maximum possible infrasonic noise would be 65.2 dBA at the south western property line. All the other industrial locations will be below 63 dBA. The resident property at 270 Black Rock Avenue will see levels of 43 dB.

The ultrasonic noise for frequencies up to 100 KiloHertz is given in Figure 13. The maximum level at 10 meters is 20 dB reference 20 microPascals for one fuel cell. The entire 80 KiloHertz band from 20 to 100 kiloHertz has been power summed and equals a noise level value of 31 dB ref. 20 microPascals. Both of the infrasonic and ultrasonic noise levels will fall well below the 100 dB limit at a distance 10 meters from the Cooling Module. The ultrasonic airborne noise at the closest property will be 30 dB. All the other industrial locations will be below 28 dBA. The noise levels at the closest Residential Zone will be much lower (17 dBA) and there should be no issue with either infrasonic or ultrasonic noise at any of the neighboring properties. Fortunately, the measured noise levels are low at 20 kiloHertz and decrease with higher frequencies and thus, no ultrasonic acoustic issues are expected above 25 kiloHertz.

18 Acoustical Technologies Inc. Figure 11. Discrete Tones Produced by Fuel Cell Cooling Module (0 dBV = 88.6 dB re20µPa)

Figure 12. Infrasonic Noise from the Fuel Cell Cooling Module (0 dBV = 88.6 dB re 20µPa)

19 Acoustical Technologies Inc. Figure 13. Ultrasonic Noise from the Fuel Cell Cooling Module (0 dBV = 88.6 dB re 20µPa)

Overall Sound Pressure Levels

The Connecticut regulations for the control of noise state that (a) No person in a Class C Noise Zone shall emit noise exceeding the levels below:

To Class C 70 dBA To Class B 66 dBA To Class A 61 dBA (day) 51 dBA (night)

The Bridgeport 600 Iranistan Avenue site is in an Industrial Zone that is surrounded by other Industrial Zones and Residential Zones to the north, north east and south east. The nearby neighbors are classified as industrial with noise limits of 70 dBA. The nearby Residential Zones have a noise limit of 51 dBA at night and 61 dBA during the day. These limits may be increased by up to 5 dB above the background if the background noise levels are higher than the limits in the ordinance. The city of Bridgeport has the same noise limits as the State of Connecticut.

Acoustical Technologies Inc. measured the airborne noise from six speakers used to simulate the noise generated by a Doosan 640 KW fuel cell. The acoustic source level at 10 meters from the operation of a Doosan fuel cell at New Britain High School was then used as a basis for making Doosan fuel cell airborne noise estimates at all the measured locations. Airborne noise estimates from one fuel cell were than scaled up to 21 fuel cells using the “noisetools” application to account for the height of the installed Cooling and Power Modules. A power summation of the twenty-one individual Cooling and Power Module estimates was then calculated to produce an overall sound level at each of six property lines as shown in Table 4.

20 Acoustical Technologies Inc. Table 3 provides the single fuel cell estimates from the data taken on April 23, 2020. Table 4 provides the airborne noise estimates for twenty-one fuel cells operating simultaneously. The second column in Table 4 gives the approximate receiver height for each measurement location, with locations identified by a P number in Figure 1. Estimates for the first, second and third floors of nearby buildings were made. Column 3 gives the total estimated noise levels expected from twenty-one fuel cells. Column 4 gives the Cooling Module contribution. Column 5 gives the Power Module contribution. Column 6 gives the maximum noise level expected at each property. Column 7 gives the expected value at the first floor from the “noisetools” analysis. Values shown in red may be above the night time residential noise requirement of 51 dBA and the industrial noise requirement of 70 dBA.

Reviewing Table 4, it is clear that the expected airborne noise levels may be high near the closest residences and within 25 meters of the fuel cells at 571 Iranistan Avenue. A summary of the maximum expected levels (at the 3rd floor) are given in Table 5 below. The 1st floor values are approximately 0.5 to 1 dB lower. The P11 residence at 720 Black Rock Avenue is expected to see airborne noise levels of 62 dBA with all the fuel cells operating. Other homes along Black Rock Avenue should see similar airborne noise levels. This level may be 1 dB above the day time requirement and 11 dB above the night time requirement. The residences along Garden and South Avenues should see airborne noise levels of 58 dBA and lower. The nearby residential properties to the north, north east and south east may be above the night time noise requirement and require noise mitigation. The expected maximum airborne noise value at 571 Iranistan Avenue is marginally above the industrial noise requirement as shown in Table 5 below. A less substantial noise treatment for the 4th floor of the south end of the building would be useful in improving the noise performance at 571 Iranistan Avenue. (Treating the residential noise emanating on the north, east and south sides of the 4th floor may redirect sound energy towards the west side and 571 Iranistan). All of the other industrial property line estimates on Railroad and South Avenues should meet the 70 dBA Industrial Zone noise limits.

Operation of the Doosan fuel cells may have significant acoustic impact at all of the closest Residential Zone properties to the north, north east and south east sides of the 600 Iranistan Avenue site. The industrial property next to the 600 Iranistan Avenue site at 571 Iranistan Avenue may exceed the 70 dBA requirement. Railroad and South Avenue industrial properties should see airborne noise levels from the 21 fuel cells no higher than 69 dBA which is just below the industrial noise limit of 70 dBA. All of the other nearby industrial properties should not be affected by the operation of the fuel cells. Background airborne noise levels of 53 to 63 dBA from the traffic on Interstate 95 were measured during a normal working day. These background noise levels will drop during the overnight hours as the traffic levels decrease. (The L90 background level has to exceed 46 dBA before background noise can affect the night time noise limit. This may or may not happen.) As a result, the fuel cell noise may or may not become the dominant noise source for the nearby residences. Noise mitigation may be recommended to bring the fuel cell noise levels down to airborne noise values less than 51 dBA or less than the background plus 5 dB in the Residential Zones and below 70 dBA for the business at 571 Iranistan Avenue. On site acoustic testing after installation of the fuel cells is recommended to confirm that the acoustic environment at the nearby properties is acceptable.

21 Acoustical Technologies Inc. Table 5. Expected Airborne Noise Levels from Operating 21 Doosan Fuel Cells (ref. 20 µPA)

P3 P5 P6 Limit Location 69 dBA 71 dBA 66 dBA 70 dBA  Industrial

P9 P10 P11  Residential 58 dBA 58 dBA 62 dBA 51 dBA

Conclusions

The purpose of this effort is to evaluate the acoustical environment at the proposed 600 Iranistan Avenue fuel cell site in Bridgeport, CT. This has been accomplished and the results show that the operation of twenty-one Doosan 460 KW fuel cells may not meet all of the State of Connecticut and Bridgeport airborne noise requirements at all the nearby properties. Residential properties to the north, north east and south east could be affected by the airborne noise from the twenty-one fuel cells. An industrial property to the south west could also be minimally affected by the airborne noise from the twenty-one fuel cells. This industrial property may see airborne noise levels just above the 70 dBA limit in an Industrial Zone. The residential properties may see airborne noise levels above the 51 dBA limit in a Residential Zone. Airborne noise from the twenty-one fuel cells may have to be mitigated to preclude the combined fuel cells from exceeding the 70 dBA industrial and 51 dBA residential limits. The night time limit may be adjusted to be 5 dB above the high background noise levels caused by Interstate I95. The noise mitigation should be designed to provide sufficient sound attenuation to show that the airborne noise generated by the fuel cells will not significantly impact the facility’s closest neighbors.

References

1) CT DE&EP Noise Control Regulation RCSA Section 22a-69-1 to 22a-69-7.4 http://www.ct.gov/dep/lib/dep/regulations/22a/22a-69-1through7.pdf

2) New Britain High School Fuel Cell Acoustic Assessment, Acoustical Technologies Inc., August 8, 2018 3) Mount Sinai Rehabilitation Hospital Airborne Noise Assessment, Carl A. Cascio, Acoustical Technologies Inc., January 26, 2017 4) Bridgeport Noise Ordinance https://library.municode.com/ct/bridgeport/codes/code_of_ordinances?nodeId=TIT8HES A_CH8.80NOCORE

22

April 24, 2020

RE: Petition For a Declaratory Ruling That No Certificate of Environmental Compatibility and Public Need is Required (“Petition”) for the Installation of Twenty One , 460 KW Fuel Cells at 600 Iranistan Ave. Bridgeport, CT 06605.

Dear Recipient,

Pursuant to Section 16-50j-40 of the Connecticut Siting Council's (the "Council") Rules of Practice, we are notifying you that Doosan Fuel Cell America, Inc. intends to file a petition for declaratory ruling with the Connecticut Siting Council (“Council”) on or about May 1, 2020. The petition will request the Council’s approval of the installation of twenty one (21) 460kW fuel cell and ancillary equipment in support of a Utility-side, distributed generation project at 600 Iranistan Ave. Bridgeport, CT 06605. The fuel cells will be powered by natural gas and generated electricity will be distributed to the Grid.

The proposed placement of the fuel cells are directly adjacent to I-95 contained in a 2 ½ story structure.

If you have any questions regarding the proposed work, please contact any of the following:

Doosan Fuel Cell America, Inc. Connecticut Siting Council

Walter Bonola 10 Franklin Square 101 Riverside Dr. New Britain, CT 06051 East Hartford, CT 06074 Tel: 860.827.2935 860.727.2010 [email protected] Attachment #14 Abutters

9

6 7 8 3 4 5 1 2 15

10 14

11 12

13 Nupower Thermal - Abutters Mailing List

Mailing Mailing No Property ID Site Address Owner Name Mailing Address City Mailing State Zip 1 9055 790 Railroad Ave DOS JAY LLC 1540 Iranistan Ave Bridgeport CT 06604 2 9056 778 Railroad Ave Uszkiewicz, Adam 780 Railroad Ave #782 Bridgeport CT 06604 3 9057 770 Railroad Ave Trefz Management Co Inc PO Box 310 Bridgeport CT 06601 4 9058 756 Railroad Ave Trefz Management Co Inc PO Box 310 Bridgeport CT 06601

5 9059 746 Railroad Ave Lombardi, Kenneth G 8 Huntington St Suite 141 Shelton CT 06484 6 9060 740 Railroad Ave RR Ave LLC 26 Manor Dr Monroe CT 06468 7 9061 722 Railroad Ave RR Ave LLC 26 Manor Dr Monroe CT 06468 225 Black Rock 8 9062 Ave Calzone Brothers Partnershp 225 Black Rock Ave Bridgeport CT 06605 9 9072 141 Garden St New Beginnings Family 184 Garden St Bridgeport CT 06605 10 2580 816 South Ave 816 South Ave, LLC 816 South Ave Bridgeport CT 06605 11 2584 824 South Ave Nunes Maria Theresa & Maria 840 South Ave Bridgeport CT 06604 12 2583 500 Iranistan Ave Nunes Jose M & Maria F Nunes 500 Iranistan Ave Bridgeport CT 06605 13 2850 455 Iranistan Ave Iranistan Ave Venture LLC 154 Admiral St Bridgeport CT 06601 14 2821 32 Washburn St 54 Washburn Street LLC 54 Washburn St Bridgeport CT 06605 15 8960 619 Iranistan Ave Cabrera-Astudillo Kleber O 621 Iranistan Ave Bridgeport CT 06605 Attachment #15 Officials Notification List

Joseph Ganim Rep. Dennis Bradley

Office of the Mayor 853 Fairfield Ave.

999 Broad St. Bridgeport, CT 06604

Bridgeport, CT. 06604

Dennis Buckley Sen. Christopher Murphy

Planning and Zoning Commission One Constitution Plaza, 7th floor

45 Lyon Terrace Rm 210 Hartford, CT 06103

Bridgeport, CT 06604

Bruce A. Nelson Building Official Richard Blumenthal

45 Lyon Terrace 90 State House Square

Bridgeport, CT 06604 Hartford, CT 06103

Rep. Marilyn Moore DEEP

House District 22 Kaite Dykes, Commissioner

666 Cleaveland Ave. 79 Elm St.

Bridgeport, CT 06605 Hartford, CT 06106

Rep. Antonio Felipe State Council on Environmental Quality

House District 130 79 Elm St.

666 Iranistan Ave Hartford, CT 06106

Bridgeport, CT 06605 Raul Pino, M.D, MPH Greater Bridgeport MCOG

State Dept of Public Health 1000 Lafayette Blvd.

410 Capitol Avenue Bridgeport, CT 06604

Hartford, CT 06134

Melody A. Currey, Acting Commissioner William Tong, Attorney General

State Dept. of Agriculture 55 Elm St.

165 Capitol Ave Hartford, CT 06106

Hartford, CT 06106

John Urquidi, PE, Town Engineer Public Utilities Regulatory Authority

45 Lyon Terrace Rm 216 John W. Betkoski III – Vice Chairman

Bridgeport, CT 06604 Ten Franklin Square

New Britain, CT 06051

Office of Policy and Management Dept. of Emergency Services and Public Protection Melissa McCaw, Secretary James C. Rovella, Commissioner 450 Capitol Ave. 1111 Country Club Rd. Hartford, CT 06106 Middletown, CT 06457

Dept. Of Administrative Services State Dept. of Economic and Community Development Josh Geballe, Commissioner

David Lehman, Commissioner 450 Columbus Blvd.

505 Hudson St. Hartford, CT 06103

Hartford, CT 06106 Bridgeport Director of Planning

Thomas F. Gill

999 Broad St.

Bridgeport, CT 06605

Department of Transportation

Joseph Giulietti, Commissioner

2800 Berlin Tpke.

Newington, CT 06111

Department of Consumer Protection

Michelle H. Seagull, Commissioner

450 Columbus Blvd.

Hartford, CT 06103

Department of Labor

Kurt Westby, Commissioner

200 Foley Brook Blvd.

Wethersfield, CT 06109

Fox Rd Mill St Fawn Meadow Dr Oxford Dr Capitol Dr Judson St Stepney Rd Wildfire Ln Meadowlark Dr Normandy Rd Coral Dr

Tashua Ln Rouleau Ln Brittany Ave Darrin Dr Gisella Rd Video Ln Blueberry Ln Todds Way Lewis Rd River Rd

Seminole Trl Rd Natalie Tanglewood Rd Whitney Ave Firehouse Rd Bayberry Ln Solar Ridge Rd Barnswallow Dr Fern Dr Gene Dr Wimbledon Ln Green Haven Rd Golf Rd Bohus Ln Pumpkin Hill Rd Fairlane Rd 110 Sanford Dr Blackhawk Rd Rolling Brook Ln Commerce Dr Beard Sawmill Rd S Surry Ln Rosewood Ln V Wagon Trl Valley Rd Park Ave Oxen Hill Rd Old Mill RdShady Brook Ln Broadway Rd Wauneta Rd Daniels Farm Rd Towerview Dr Laurel Wood Dr Waterford Ln Cardinal Dr Research Dr Jade Tree Ln SareneeCir Fitch Pass Spinning Wheel Rd Gatehouse Rd Exit 12 Old Tree Farm Ln Stonehouse Rd Nichols Ave Fuller Rd Mallett Dr 25 Old Stratford Rd ORANGE

Algonquin Ln Dr Run Deer SV Roosevelt Dr Stowe Dr Blue Jay Dr Pilgrim Ln Isinglass Rd October Ln Lady Slipper Dr Jog Hill Rd SV108 Lynne Ter Skyline Dr Church Rd Carmel Rdg Chalon Dr

Beers St Deerfield Dr Wendover Rd Palomino Pass Canfield Dr Dr Progress Rock Rd Old Field Rd Cold Spring Cir Cart Ln Captains Walk Greenfield Dr Murphys Ln Burroughs Dr SHELTON Exit 12 Wedgewood Rd Trap Falls Road Ext Partridge Ln Westfield Dr Wolcott Ln Staples Rd Bibbons Rd Northwood Dr Meadow Rd Falcon Ln Deepwood Rd Limerick Rd Echo Hill Rd October Ln COASTAL BOUNDARY Beacon Hill Rd Cedar Hill Rd Andrew Dr

September Ln Ln Coram Bridle Trl Parrott Dr Masters Ln

Clemens Ave Blaho Dr BrookhedgeBrookside Dr Rd Stoneleigh Rd Kazo Dr Colonial Dr Longmeadow Rd Timothy Ln

Dayton Rd Dayton Louis St Augusta Dr Shelter Rock Rd Stemway Rd Meadowview Dr Honeybee Ln Soundridge Rd Calhoun Ave Mustang Dr Doe Hollow Dr Gray Rock Rd Andrews Rd State Hwy 25 Hidden Pond Ln Dome Dr Oakland Dr Scenic Hill Rd Herbert St Staples Rd Bibbins Rd Fairway Ln

Stones Throw Rd Cotton Tail Trl Randall Dr Mountain Dr Vixen Rd

CreeTrl

Lynwood Dr Daybreak Ln BRIDGEPORT, CONNECTICUT Country Club Rd Hemlock Dr Ridgeview AveGeorge St Stones Throw Ironwood Rd Putting Green Rd Finchwood Dr Fox Wood Rd Smoke Vly Mayflower Dr Seeley Rd Long Hill Ave Magnolia Cir Cromwell Rd Trap Falls Rd River Bend Rd Totem Trl Myrtlewood Dr Orchard Ln Centennial Dr Brookside Dr Sunrise Ave Hyde Ter Chatham Dr Sterling Rdg Meeting House Rd Saranac Rd Mariner Cir

White Tail Ln Meadow Ridge Dr Deepdene Rd Friar Ln Wopowog Trl Strobel RdWoodmere Dr Shadowood Ln Oak Blf Lobdell Ln Hemlock Trl Barrows Rd Apple Gate Ln Armstrong Rd Haverhill Rd Nokomis Dr Greenwich Pl Bridgeport Ave Hollis Dr Pemberton Dr Zephyr Rd Cardinal Cir Isinglass Ter Silver Hill Rd Sport Hill Rd Placid St Lakewood Dr Ojibwa Rd Reading Rd Sallyann Rd Lake Ave Great Neck Rd Newton St Coppel Ln OronoqueTrl Midland Rd MacDonald Rd Algonkin Rd Preston Rd Helena Rd Merrimac Dr Coe Ave Yutaka Trl Inverness Rd Madison Ave Marigold Ln Kellers Farm Rd Bittersweet Ln Blue Ridge Dr Leo Ln Hinman St Hickory Knoll Dr Pinewood Trl Honeysuckle Hill Ln Wordins Ln Old Country Ln Sherman Ave Hills Point Rd Ascolese Rd Laurie Rd Sweetbriar Dr Cherry Gate Ln Exit 11 Sterling Rd Copper Kettle Rd Patricia Dr Far Mill Dr LEGEND Ojibwa Trl Warner Hill Rd Wildwood Dr Walker Rd Old Hollow Rd Skytop Dr Huntington St Dairy Ln Three Trees Ln Kingsbury Dr Pamela PetersDr Ln Lavery Ln

Clark Rd Cider Mill Ln Lobsterback Rd Tory Ln Old Dike Rd Old Green Rd Red Fox Dr Highfield Dr Garwood Rd Brinsmayd Ave Pine Knob Ter Johnson St Route 127 Macmath Dr Hedgehog Cir Beach Memorial Rd Golden Hill Rd Kathleen Dr Skyview Dr Carriage Dr 127 Inca Dr Golden Hill St SV Dogwood Ln Ashwood Ter Lantern Rd Coastal Boundary Anita Ave Quality St Teeter Rock Rd Mitchell Rd Iroquois Ln Spruce Ln

Pilgrim Ln Elliott Rd Hedgehog Rd Adams Rd Clair Pl Hampton Rd Wood Ave Kaechele St Exit 9 State Hwy 25 Primrose Dr Rd Farm James 59 Alden Ave Ashwood Ter School Hill Rd SV Kachele St Dalecot Dr Hardy Ln Mischa Hill Rd Stowe Pl Onondaga Ln Yorktown Cir Norwood Ter Drew Cir Park St Cove Pt Center Rd Driftwood Ln Park Ln Marina Ave Beaver Dam Access Rd Oakview Dr Main St TRUMBULL Green Ridge Rd Nyack Ln Exit 55 Dell Cir Exit 11 North Trl Church Hill Rd Carousel Dr Canoe Brook Rd Flint St Griswold Ave Exit 9 Mischa Rd Booth Hill Rd Exit 55B 111 Garnet Rd SV Vista Pl Lake Rd Scattergood Cir Cottage St Granite Pl Wellington Rd Aragon Dr Middlebrooks Ave Wilbur Cross Hwy Lilac Ln Beverly Rd Beaver Dam Rd Tait Rd Oronoque Ln Redcoat Ln Route 111 Route 127 Stanczyk Dr Rangely Dr Evelyn St North St EASTON High Meadow Rd Dale Rd Regina St Little Plain Rd Alexandra Dr Lasky Dr Ward Pl Exit 55A EXPLANATION Old Sow Rd Old Oak Rd Brewster Pl Wisteria Dr Wilbur Cross Hwy Wheelers Farms Rd Brandy Ln Laurel St Merritt Blvd DamLakeview Access Dr Road Erwin St Woodcrest Ave Peters Ln

Puritan Rd Lincoln St Equitable Dr Smith Dr Wildwood Rd Seminole Ln Banks Rd Franklin St Agawam Dr Lillian Dr Moorland Rd Twin Brooks Dr Twin Circle Dr South Trl Wildwood Dr

Manor Dr Bayfield Ln Exit 53 Hillside Dr Jerome Ave Candlewood Rd Exit 54 Gilbert Dr Fernwood Rd Morehouse Rd State Hwy 111 Canterbury Ln Milford Pkwy Flat Rock DrFlat Rock Rd VL Brook Ter The coastal boundary map shows the extent of lands zoning board of appeals and a referral of a municipal Lorma Ave Shawnee Rd

Old Dairy Rd Revere Ln Old Barn Rd Geraldine Cir Larkspur Dr Ryders Ln Lauderdale Dr Gibson Ave Tanager Ln Oriole Ln Arden Rd Exit 10 Saint Johns Dr Commerce Dr Pepperidge Cir Harvester Rd Frederick St Leslie St and coastal waters as defined by Connecticut General project)) must be conducted in a manner consistent 58 Virginia Dr Barry Pl Kenwood Ln SV Blackhouse Rd Fern Cir MerrittExit Pkwy 53Meadowmere Rd Juniper Dr Nutmeg Ln Judith Ter Jesse Lee Dr High Ridge Rd Fairchild Rd Windy Rdg Crescent Dr Orchard St Exit 8 Shelton Rd Statute within Connecticut's coastal area. The coastal with the requirements of the Connecticut Coastal Garden St MacArthur Rd Circle Dr Ridgedale Rd Magnolia Rd Springwood Dr Lexington Way Gate Ridge RdMorningside Rd Buck Hill Rd Hilltop Cir Harvest Ridge Rd Keating Dr Pert St Edison Rd Sunset Ave Saybrook Rd Unity Rd Ferndale Rd Sturbridge Rd Frost Hill Rd Nutmeg Dr Old Oronoque Rd boundary is a continuous line delineated on the Management Act (CMA). As the Coastal Boundary is Crestwood Dr Inwood Rd Norton Rd State Hwy 59 Tamarak Cir

Lawrence Rd Tuckahoe Rd Adirondak Trl Hilltop Dr Oak Ridge Ln Tulip Tree Ct Fairview Ave Indian Rd Colony Ave Columbine Dr Elberta Ave Rutland Rd landward side by the interior contour elevation of the a hybrid of the Coastal Area, all state and federal Hall Rd Priscilla Pl Acorn Ln Booras Ln Rosemond Ter Woodridge Cir Sun RidgeTwin Ln Oaks Ter Riverside Ln Bailey St Cedar Crest Rd Jerusalem Hl Black Rock Tpke State Hwy 136 PlWesley Drewbarrie Ln Craig Ln Twitchgrass Rd Sunset Rd Oak Ridge Rd Cheshire St Prospect St State Hwy 8 one hundred year frequency coastal flood zone, as agency activities must be consistent with the Laurel Dr Leonard Pl Evergreen Ln Unity Dr Morning Dew Ln Plymouth Ave Exit 50 136 Cutspring Rd SV Chester Rd Greenfield Dr Exit 51 Exit 52 Tavern Rock Rd Chapel St Melrose Ave Elaine St Maefair Ct defined and determined by the National Flood requirements of the CMA. The coastal boundary is a Exit 49 ExitHawley 52 Ln Krueger Ln Founders Way Amante Dr Pine St Merrill Rd Killian Ave Raynor Ave Woolsley Ave Rollingwood Rd Zion Hill Rd Marsh Rd Senior Dr Sunnycrest Rd Insurance Act, or a one thousand foot linear setback hybrid of the original 1:24,000 version maps prepared Chestnut Hill Rd Lounsbury Rd Main St Lilibeth Dr Kings Row Wilson Rd Fensky Rd Blanchard Rd Wedgewood Dr Buttonwood Dr Exit 49N Leffert Rd Salem Rd Westport Pl River Rd Stonewall Ln Beech St Euclid Ave

Reservoir Ave Williams Rd Paddock Pl Paddock measured from the mean high water mark in coastal by DEP and the revised boundary mapping Rutlee Dr Exit 49S Caroline St Rocky Ridge Dr Plum Tree Ln Parkway Dr Quail Trl Nichols Ave Plane Tree Rd Oakview Dr Wildflower Ln Ruet Dr Wilbrook Rd Bunnyview Dr

Reilly Rd St Merwin Koger Rd Soundview Dr Bartling Dr Chatfield Dr Bayberry Ln waters, or a one thousand foot linear setback undertaken by twenty-two coastal towns. This layer Ceil Rd Plattsville Rd Rd Candlewood Exit 48 Lindeman Dr Gina Cir Exit 48 Hillston Rd Ross Dr Overview Dr Rocky Hill Ter Sunnyridge Pkwy Post Oak Rd Forest Rd Zion Hill Rd The Cir Bonnie View Dr Exit 9 River Valley Rd measured from the inland boundary of tidal wetlands, therefore does not replace the legal maps and may not Tersana Dr Oakridge Rd Barton Dr Harvest Moon Rd Russ Rd Brian Dr Elmwood Ave Stella St Fairfax Dr Butternut Ln Stuart Pl Lindberg Dr Armory Rd Fairchild Dr Covington Dr whichever is farthest inland; and shall be delineated be used for legal determinations. 8 Southworth St Joyce Ct Wendy Rd Exit 7 SV Winslow Rd Horseshoe Dr Johnson Ln Far Horizon Dr Bonheur Rd Cottage Pl Pauline St Okenuck Trl Rutland Rd Henry Albert Dr Chase Milford Raton Dr Blue Bell Ln Leighton Rd Gorham Pl Fox Hill Rd on the seaward side by the seaward extent of the Exit 47 Botsford Pl Rosebrook Dr Whippoorwill Ln Jennifer Ln Exit 8 Bear Paw Rd Cornfield Rd Flagler Ave Campbell Rd Green St Reiner DrBeardsley Pkwy Wilbar Dr Ochsner Pl Wilbar Rd Westwood Dr Stevenson Rd Rocky Hill Rd Hillcrest Rd Val Dr jurisdiction of the state. The following twenty-two towns have adopted Fawn Rd Loftus Cir Cannon Dr Morning Glory Dr Memory Ln Chickadee Ln Old Sport Hill Rd Macon Dr Sheffield Cir Linda Dr Quarry Rd Old Town Rd Avalon Gates Sunrise Ter Wigwam Ln Ford St Westport Rd White Plains Rd Dexter Dr Silver St Luanne Rd Waller Rd Sequoia Rd Village Ln Oronoque Rd municipal coastal boundaries: Chester, Clinton, Palmetto Rd Chopsey Hill Rd Penny Ave Timber Ridge Rd Bulldog Blvd Mile Cmn Brianna Ln Wood Dr Travis Dr Seabreeze Dr Daniel Dr Leonard Dr Johnson Ln Brenair Ter Toll House Ln Kaechele Pl Nautilus Rd Perry Ln

Beers Rd Folino Dr State Hwy 108 Darien, Deep River, East Haven, Essex, Fairfield, Marilyn Dr Oman Pl Any regulated activity conducted within the coastal Weaver Dr Wedgewood Pl Tranquility WayHarvest Ln Nancy Dr Lawlor Ter Rockwood Ct Doreen Dr State Hwy 8 Gaynos Dr Exit 6 Exit 7 Exit 36 Benneville Rd boundary by a municipal agency (i.e., plans of Greenwich, Groton, Guilford, Hamden, Ledyard, Weeping Willow Ln Oxbrook Rd Bailey Ln Pine Point Dr Holland Rd Ann Ter Canary Pl Gem St Asmara Way Federal St Oakleaf St Grinnell St Division St Birch Dr Rainbow Rd Wilson Ave Plains Rd development, zoning regulations, municipal coastal Madison, Milford, New Haven, New London, North Old Redding Rd Silver Ln Narrow Ln Delaware Rd Tina Cir Dobson St Broadbridge Rd Arrowhead PlLinksview Pl Andrus Dr Lakeside Dr Old Town Rd Indian Field Rd Abbott St WESTON Jefferson St Connors Ln Douglas St Winton Pl Common Rd Black Rock Rd Trojan Dr O View Ter MILFORD programs and coastal site plan review (i.e., site plans Haven, Norwalk, Old Lyme, Old Saybrook, Stamford Luther St Seltsam Rd Glenn Dr Anson St Exit 46 Anton Dr Emerald St Karen Ave Caswell St

Emerald Pl Exit 36 Fiske Ave Delwood Rd Sultan St Shelland St Beaverbrook Rd Eckart St Sylvan St Lynne Pl Kathryn Dr Delaware Dr Dogwood Dr Ranch Dr Oxford St submitted to zoning commission, subdivision or and Waterford. The coastal boundary maps for these Anton St Trumbull Ave DanielsAve Topaz Pl Daniel Dr Manor House Ln Junior St Frenchtown Rd Glenbrook Rd Huntington Tpke Sunflower Ave Highland Ave Pond Rd Erna Ave Boston Post Rd Carrie Cir Karen Ct SylvanAve Wiley St resubdivision plans submitted to planning towns may be at different scales than the original 2nd Hill Ln Bridgeview Pl Autumn Ridge Rd Matthew Dr Golf View Dr Service Road Soundview Ave Sulik Ter Raven Ter Heritage Dr Griffin Ave Freeman Ave

Funston Ave Dahl Ave Hoydens Ln Yaremich Dr Hazelwood Ter Charron St High View Dr Oakdale St commission, application for special permit or DEP draft maps and may contain minor adjustments Lourmel St Hooker Rd Emerson Dr Fairfax Rd Islandview Rd Lambert Dr Alvord St Edgemoor Rd Woodside Ave Motil Pl Stran Rd Mills Ln Alba Ave Pilgrim Rd Quail St Linwood St Westfield Rd Platt St Hollywood Ave Windward Rd Boylston St Washington St to the boundary. Leslie Rd Reeds Ln Bic Dr exception to the zoning or planning commissions or Evers Street Ext West Rd Hillcrest Rd Kenyon St Rustown Dr Lampwick Ln Easton Tpke Geduldig St Norland Ave Rita Ave Woodhill Rd Woodmont Ave Second Hill Ln Exit 35 Twin Lane Rd Kennedy Dr Evers St zoning board of appeals, variance submitted to Polk St Vincellette St Castle Dr

Tesiny Ave OverlookAve Hoydens Hill Rd Pitt St Burbank Ave Sassacus Dr Collingsdale Dr Ameridge Dr River Rd Broadbridge Ave Adp Plz 162 Phillips St S Jennings Ave V Mile Common Rd Peet St Glendale Ave Wilkins Ave Brookbend Dr State Hwy 162 Leslie Ln Seemans Ln Englewood Ave Mapledale Ave Ridge Rd Elizabeth Ter Valley View Rd North St Deramo Pl Valley Ave Beardsley Rd Carol Rd Silver Sands Pkwy Martha Pl Bluff St Munson St Woodrow Ave Parkway Dr Reed St Shrub Oak Ln Opal St Schoolhouse Rd Moffitt St Lakeview Ave 127 Colonese Rd SV Priscilla St Huntington Rd Windy Hill Rd Valley Cir Goldenrod Ave Indian Ave Foggwood Rd Exeter St Hart St Albright Ave Harriet Ave Marina AlbertDr Ave Hemlock Hills Rd Mount Pleasant Ave Stoehrs Pl Lincoln St Torsey St Eleven O Clock Rd Earl Ave State Hwy 110 Norway St Windsor Ave Exit 35 Beechmont Ave Pleasantview Ave Jewett Ave Ulrich Rd Utica St Monroe St Meadows End Rd Ezra St Louisiana Ave Abram St Queen St Wilcox St Edison St Valley Rd Andrew St West Ave Stella Ln Congress St Morehouse Dr Bankside St Oakwood St Primrose Ln Sky Top Ter Ardmore Ave Broadmere Rd Exit 34 Mistywood Ln Fairlea Ave Allyndale Dr Bittersweet Ln Rowe Ave Wheeler OldPark Elm Ave Rd Crest Ter Ruth St Ohio Ave STRATFORDPark St Casmir Dr Merritt St Birmingham St Lake St Mercer St Ward St Cricker Brook Ln Marsh Way Wilcoxson Ave Kent St Crown St Edna Ave McNairVought St Pl Oldroyd St Topfield Rd Meadowside Rd DATA SOURCES Dewhirst St Thorme St Pond St Garden St Homestead Rd Glengarry Rd Robert St Exit 5 Plymouth St Exit 34 Brion Dr Terry Pl Lucille Dr Amos St Alpine St North St Hemlock Rd London Ter Clark St Peck St Harvester Rd Auburn St Kenwood Ave Nichols TerHelen Pl Laughlin Rd Elbon St Summit St Berwyn St Bilyard St Pumpkin Delight Rd Park Ave Eaton St Arbor St Bridgeport Ave SaxonwoodLamplighter Rd Ln Burnsford Ave Exit 5 Hickory St Glendale Rd Lansdale Ave Aran Hill Rd Sky Top Dr Rocton Ave Kasper Dr Hazelwood Ave Eastlea Rd Tanglewood Ln Bennett St Frog Pond Ln Westlea Rd Marcroft St Alberta St Claudia Dr State Hwy 58 Exit 44 Cascade Dr Random RdValley Ln Beers Pl Daytona Ave Art St Bretton St Lindley St Magnolia St London Ter Wilson St Fallowfield Rd Romanock Rd Stonybrook Rd Wiebe Ave Hope Ct Lawman Rd Mulberry Hill Rd Savoy St Amsterdam Ave COASTAL BOUNDARY DATA - The original BASE MAP DATA - Based on data originally from Congress St Fairview Ave Hurd Ave Palisade Ave Stratfield Pl Wayne St Glenwood Ave Rose St King St Nonopoge Rd Hayes Dr Manila St Wood Ave Loomis St Klondike St North Ave

Lloyd Dr Grandview Rd Fairview St boundary maps were created in 1979 on stable mylar 1:24,000-scale USGS 7.5 minute topographic Midlock Rd Bailey Rd Edmund St Edmund Hickory Ave Towne House Rd Adley Rd Cedarwood Ln Exit 44 Westfield Ave Hunting St Gurdon St Locust St Johnson Ave Lockwood Rd Harwich Rd Pearl Harbor St Chase St Court D Sidney St Naugatuck Ave Sherley Pl Hillside Ave Elliott St Ridge St overlay using the 1:24,000-scale US Geological quadrangle maps published between 1969 and 1992. Homeland St Islandbrook Ave Boston Ave AsylumPark St Boundary St Lenox Ave York St

Davis Rd Aldo St Anson St Glennwood Rd Horace St Benson St Colonial Ave Colonial Red Barn Ln Wake St Wyoming St Dr Riverside Ellis St Robbie Cir Coach Ln Stratfield Rd Kittery St Nettleton Ave Red Oak Rd Toilsome Hill Rd Bronx Ave Patterson Ave Chatham St Palmer Brg Buena Vista Rd Imperial St Noble Ave Rosemere Ave HenryAve Survey topographic quadrangle maps (mylar film It includes political boundaries, railroads, airports, Nepas Rd Flushing Ave Summer St Main St Orchard St Florence Ln Canterbury Ln Hawley Ave WiklundAve Barnum Avenue Cutoff Banks North Rd Inwood Rd Goddard Ave Fairmount Ter French St Canaan Court Rd Monroe St Marion St Parade St Coventry Ln Winnepoge Dr format). The source for tidal wetland maps were the hydrography, geographic names and geographic Light St Rockland Rd Merritt Ave Short Hill Ln Truman St Jackman Ave Robin St Whitney Ave Center St Harrison Ave ® Wood House Rd Ferncliff Rd Salem St River St Granfield Ave Canaan Rd Lincoln Ave Godfrey Rd Melville Ave State Hwy130 130 Brett Rd Lindamir Ln Carver St Booth St S Rivercliff Dr Peak Ave Wells St Alexander Dr California St V legal 1:24,000 maps (mylar format) adopted by the places. Streets and street names are from Tele Atlas Morehouse Hwy Dorothy St Perth St Wheeler Ave Catamount Rd Joan Dr Deepwood Rd Birdsey St Barnum Ter 15 Buckley Dr King St Ferry Blvd Surrey Ln Lakeview Dr Spring St Bond St Franklin Ave Noble St Tahmore Dr Northwood Rd Exit 33 Hobson Ave S Light St V Lyman Ln Evergreen St Pond St Clover St Burr St Hale Ter Commissioner of DEP and transformed to 1:24,000 copyrighted data. Base map information is neither Brooklawn Pkwy Arlington St Success Ave Edgemont Rd Birch Pl Remer St Mary Ave Janet St Evergreen Hill Rd Linley Dr Southwood Rd Putnam St Benham Ave Tahmore Pl Federal St Bray Ave Broadway 8 Berkshire Ave Remington St Housatonic Dr Lucille St Edgewood Rd Lincoln Ave SV Seaflower Rd Porter St Regent Ter mylar-scale maps by the Office of Policy and current nor complete. Capitol Ave Miller Ave Lawrence St Charles St Exit 4 Bertrose Ave Old Black Rock Tpke Homefair Dr Brooklawn Ter Sedgewick St Weber St Fairfield Woods Rd Stillman St Orchard St Broad St Broadway Housatonic Ave Palamar Dr Brooks St Nells Rd Management (OPM) using an accurate pantograph. Elvira Ln Washington Ave Lewis Pl OregonAve Brambly Hedge Cir Hillside Rd Salem Rd Tuller Rd Thompson St Exit 32 Audubon Ln WarwickAve

Linden Ave Blakeman Pl SuttonAve Suburban Ave Windsor St Kent Ave

Bick Ter East Ave Garfield Ave Ogden St Pixlee Pl BrooklawnAve

OPM similarly converted FEMA's flood insurance RELATED INFORMATION Alice St St Bell

Melville Dr Housatonic Ave Hayes St St Otis

Woodridge Ave Exit 3 Ave Rockwell Old Point Rd High Ridge Rd Cleveland Ave Oakland St Galloping Hill Rd Arrowhead Ln Garden Dr St Dorus Brookdale Ave Hurd Ave Jane St Rd Nels White St Hallett St Mead St maps (various scales) to a 1:24,000 mylar overlay. Milford Ave Elm St Richard Pl Knowlton St Broad St Judson Pl BurrittAve Rolling Ridge Rd Taft Ave Ave Bowe Sea Flower Rd Willow St Knowlton St Lazlo Ter Brookview Ave Querida St Old Farm Ln Arctic St 113 Walton St High Park Ave Park High S BRIDGEPORTKossuth St V Andrews Ave High Point Ln Hollydale Rd William St Bridle Trl Thompson St The inland extent of coastal waters was plotted on This map is intended to be printed at its original Bishop Ave Hickory Ln Adolf Pl Prince St

Cornell Rd Mill HillAve Rachel Dr RidgefieldAve Shetland Rd Armstrong Pl Maple St Helen St Birch Ave Seaview Ave Seaview Exit 32 Acad Hill St Fairwood St Merwins Ln Warde Ter Old Farm Rd Victory St 1:24,000 USGS topographic maps following the dimensions in order to maintain the 1:24,000 scale (1 Old Oaks Rd Morgan Ave Mohawk St JacksonWood Ave Grant St Barnum Ave Ave West George St St White Sasapequan Rd Norman St Center Street Ext Deerwood Ave Oak St Yale St Bancroft Ave Hollister St BeardsleyAve Steiner St Cross St

Beach St procedures and sources described in The Boundary inch = 2000 feet). Miro St Lookout Dr Church St Jackson Ave Eleanor St LockwoodAve Jay Cir Catherine St Crescent Ave Mine Hill Rd Coral Dr 8th Ave

Oriole Ln Laurel Ave Harriet St Lines Pl Farist RdFairland Dr Bloomfield Dr Park Dr Herkimer St Seymour St Wells Pl Between Saltwater and Freshwater in Connecticut, State Hwy 15 Lota Dr North Ave Center St Knapps Hwy Fence Row Dr Ronald Dr Central Ave BruceAve 6th Ave Pulaski St Bunnell St Blueridge Rd Wade St Exit 31 Holmes St Sachem Rd Amelia St Unquowa Hill St Fulton St Court St

December 1978 prepared by the State of Connecticut, MAPS AND DIGITAL DATA - Go to the CT ECO Waterman St St East Shore Rd Grand St Summit Ln Samp Mortar Dr Bullard St James St Holly St Avon St Hamilton Ave 4th Ave Algonquin Rd Pacific St Hamilton St Sherwood Pl Cross Hwy Mountain Laurel Rd Springer Rd Renwick Dr Radel St Atwater St Harral Ave Nichols Ave Deacon St Lake St Brooklawn Ave Chestnut St Feeley St Department of Environmental Protection, Coastal website for this map and a variety of others. Go to the Cherry Ln Arch St 2nd Ave

State Hwy 127 Laurel Brook Ln Pansy Rd Webb Rd Pequonnock St Lyon Ter Merritt Pkwy Burroughs Rd 5th St Miles St Barryscott Dr 3rd St Gold St Hickey St Beechwood Ln Logan St Sands Pl Bittersweet Rd Middle St Lancelot Dr Pembroke St Area Management Program. DEEP website for the digital spatial data shown on Old Stratfield Rd Iranistan Ave Stillson Pl Harrison St Taft St Placid Ave ValleyviewPotters Rd Ln Berkeley Rd Wood Ter Coleman St 3rd St Fotch St Adams St Farmstead Hill Rd Pine Tree Ln Lenox Rd 1st St Exit 2 Nichols St Connector Ave Pierce Pl Read St Exit 31 Chelsea St Old Academy Rd Pope St Olive St Stratford Ave Beacon Point Rd this map. Martingale Ln Melody Ln Birdseye St Ann St Mead St Sedgewick Ave Everett St Riders Ln Frog Pond Ln Tunxis Hill Cut Off Carroll Ave Quarter Horse Ln Dunham Rd Wilmot Ave Alex St Roseville St Water St Connecticut Ave Judd St Villa Ave Lynnbrook Rd BriarwoodAve Beechwood Ave Hollister Ave

State Hwy 15 Vine St Main St Golden Pond Ln Mayfair Rd York Rd Chapman Ave Maplewood Ave Cannon St Roosevelt Ave Hill Brook Ln Moritz Pl Clinton Ave Exit 28 Pheasant Ln Sherwood Ave

Laurel Ct Berkley Rd Colorado Ave Waterview Ave Stratford Ave Old Academy Rd Tunxis Hill Rd West Ave Bank St Maiden Ln Exit 29 Stagg St Katona Dr Milford Point Rd FAIRFIELD Soundview Ave Union Ave Columbus Ave Woodend Rd Labbance Ln Oakwood Dr Exit 2 Wagon Hill Rd Howard Ave John St Stillson Rd Allen Rd Sterling St Victoria Ct Hubbell Ln Gilbert St Wooster Ave

Greenbriar Rd Exit 29 Exit 30 Beardsley St General St Grove St Surf Ave Harding Ave Borosky Rd Laurel St Poplar St Justice St Smiths Pt Pierce St Seeley St Smith St May St Horseshoe Ln Emmy Ln Deerfield St Hancock Ave Exit 1 Exit 27 15 Thornhill Rd High St Arising St Eagle St Exit 30 SV Verna Field Dr Hunyadi Ave Honeyspot Rd Benton St Mill RiverBrookside Rd Dr Bates St Primrose Ln Verna Hill Rd Lenox Ave Fremont St West Ave Trowel St Jennie Ln Greenfield Hill Rd Mountain Grove St Frontage Rd Larkin Ct Fair Oak Dr Liberty St Spring Hill Rd Ryan Ave

Szost Dr Dewey St Jefferson St Bay St Wellington Dr HershOrchard Rd HillShady Ln Hill Rd Robin Ln Wilton Rd Exit 27A Mayfair Pl Dudley Dr Reid St Warren St Jennings Rd Newfield Ave Ketcham Rd Holland Ave Lee Ave Duck Farm Rd State St Hanover St Lewis St Jeniford Rd Lafayette St Redding Rd Millspaugh Dr Margemere Dr Country Rd Breakers Ln Queens Grant Rd Sigwin Dr Brookdale Rd Berwick Ave Silliman Ave Hathaway Dr Exit 27A Dekalb Ave Dodge Ave Organ St Middlebrook Dr Soho Sq School St Myrtle Ave Lesbia St Watson Blvd Fleming Ln Larkspur Rd Pemburn Dr Bedford Ave Black Rock Ave State Hwy 135 Halley Ave RailroadExit Ave27 Broad St Cobblers Hill Rd StonybrookFiglar Rd Ave Finn St Eagles Nest Rd Hibiscus St Russell St Rutland Ave Eagles Nest Rd Sniffens Ln Silver Spring Rd Bronson Rd Railroad Ave R View Cir Glen Arden Dr Exit 26 Carroll Rd Castle Ave State Street Ext Daniel Ct Hanford Dr Sunset Cir Exit 25

Lagana Ln Honeyspot Rd Ext Alma Dr Exit 24 Cherry St Access Rd Knollwood Dr Lovers Ln Pine St Flower House Dr Burr Ct Exit 25 Admiral St Old Hickory Rd 1 Pine St Main St £ Exit 26 Ridge AveGregory St ¤ Short Beach Rd Albion St UniversityHazel AveSt Johnson Dr Orland St Bostwick Ave Hunter Rd Crestwood Rd Dawn St Wordin Ave South Ave State Hwy 113

Lawrence Rd Long Beach Blvd

Stephens Ln Ave Hancock State St Scofield Ave Governors Ln Bird St Linden Ave Hansen Ave Atlantic St Woods End Rd

Dawn Dr Cedar Rd Exit 24 Morehouse Ln Hill Farm Rd Grove Rd Dorne Dr Queens Grant Dr Ingleside Pl Sturges Hwy Rodgers Rd College Park Dr Jessica Ln Wormwood Rd Ocean Pl Barnum Dyke Walbin Ct Mill Plain Rd PrincetonKing St St Morris St Waldemere Ave Howe Dr Great Meadow Rd US Hwy 1 Frank St Atlantic Ave Vermont Ave Fairfield Ave Hope St Whites Hill Ln Green Acres Ln Canfield Ave Shell St Soundview Dr 1 £ Ellsworth St ¤ Wilson St Quaker Ln Meadow St Cemetary Rd Robert Ln Brewster St Yacht St Exit 23 Morehouse St 113 135 Fox St SV Stratford RdAsh St Home St Twin Brooks Ln Pell Meadow Dr SV Short Beach Rd Cedar Rd Ferris St Long Beach St Curtis Ave Sycamore Dr Cedar Ln Kings Hwy Jetland St Hulls Farm Rd Curtis Ave Doreen Dr Maple Dr Holland Hill Rd Colony St Soundview Dr Riverdale Dr Meadowbrook Rd Grasmere Ave Lordship Blvd Chestnut St Courtland Ave Fulling Mill Ln

Sturges Cmn SherwoodDr Grist Mill Ln Half Mile Rd

Warner Hill Rd Walnut St Newton St

Pine St Cedar St Hemlock St Birch St Prospect Dr Greenwood Ln Exit 23 Barnum Blvd Lordship Rd Maple St Bayberry Ln Taunton Rd Victoria Lawn Edge Hill Rd Pauline St Charbeth Ln Old Barn Rd Midland St Jennings Ct Sprucewood Ln Waterville Rd Beachview Ave Wakeman Rd Eames Blvd Winton Rd Barlow Rd Riverside Dr Dunnlea Rd Henry St Round Hill Rd Park Blvd Longview Ave Lake Ave Sasco River Ln Dorking Dr Seabright Ave Cove Pl

Gilman St

Elm St Pearsall Pl Grovers Ave High Meadow Rd Old Mill Rd 3rdAve Ocean Ave High Point Rd Barberry Rd Brookbend Rd Exit 22 Oak Bluff Ave Mill Hill Rd 2nd Ave

4thAve Eames Blvd Moss Ledge Rd Godfrey Ln Sturges Rd Washington Pkwy Daybreak Ln 1st Ave Long Lots Rd Belmont St Hilltop Rd 5thAve Papermill Ln FlintlockRd Mill Hill Ter Eliot St Range Rd Walls Dr Turney Rd Shoreline Dr Unquowa Rd Linda Ln

Battery Park Dr Mallard Ln Rest Area Benson HoraceRd Ct Hyde Ln Hunt Club Ln I 95 School Rd

Sailors Ln Acorn Ln Ulbrick Ln Exit 21 Oyster Rd Grist Mill Ln Mariners Way Forest Dr I 95 Hillcrest Rd Evelyn St Rockview Rd Old Rd Ivy Ln Village Ln Mill Hill Ln Somerset Ave Bradley St Hulls Hwy Unquowa Pl Craig Pl Pine CreekRd Ambler Rd Maple Ave Osborne Ln

Bulkley Ave Bauer Pl Brook Ln Daves Ln Exit 21 Colonial Dr Exit 20 Ludlowe Rd Linwood Ave Old Post Rd Keller Ln Taylor Pl Westfair Dr Exit 19 Lacy Pl Arbor Ter Kings Dr Beaumont St Beach Rd Judson Rd Dexter Rd Boston Post Rd Sherman St Fern St Old Rd Regents Park Fairfield Pl

PeaseAve Eunice Ave Arbor Dr Arbor Post Rd Lansdowne Kings Ln Crescent Rd Thorpe St Hurd St Rhoda Ave Birch Rd

Oakview Cir WESTPORTCmns Harvest Blaine St Mills St Catherine Ter Ruane St Oxford Rd Penfield Rd Edward St Cottage Ln Todds Way Jelliff DrSpruce St Paulding St Millard St Rowland RdLalley Blvd Taintor Dr Blake Dr Paul Pl Woodhill Rd Center St Pratt St Quintard Pl Oldfield Rd Chester Pl Sasco Hill Rd MAP LOCATION Welch Ter Tomahawk Ln Hillandale Rd Exit 19 FlaxRd Alden St Fox St

TurkeyCarrie LnHill Cir Pritchard Ln Westford Dr Ennis Ln Gould Ave Mona Ter Longdean Rd Couch Ln Flora Blvd Quincy St Taylor Ln Lee Dr Morningside Dr Westway Rd Harbor Rd

South St

Tiffany Ln Banks Pl Reef Rd Devon Rd Veres St Parsell Ln Sleepy Holw Tierney Ln Gate Ln Salt Meadow Rd College Pl Willow St One Rod Hwy Gorham Rd ¨¦§95 Clapboard Hill Rd Sasco Creek Rd

Ardara Dr Risley Rd Sasco Pt Pequot Ave Greens Farms Rd Old Dam Rd Fairfield Beach Rd

Turkey Hill Rd Dunhill Dr

Hedley Farms Rd Beachside Ln £ Maple Ln

State Plane Coordinate System of 1983, Zone 3526 Pine Creek Ave Lambert Conformal Conic Projection 95 North American Datum of 1983 ¨¦§

New Creek Rd

Beachside Ave

1 0.5 0 1 Miles

Bridgeport-Port Jefferson 1000 0 1000 2000 3000 4000 5000 6000 7000Feet

1 0.5 0 1 Kilometers

SCALE 1:24,000 (1 inch = 2000 feet) when map is printed at original size

STATE OF CONNECTICUT DEPARTMENT OF Map created by DEEP ENERGY & ENVIRONMENTAL PROTECTION January 2013 79 Elm Street Hartford, CT 06106-5127 Map is not colorfast Protect from light and moisture 

Avoided Emissions This method is consistent with the guidance of the U.S. EPA CHP Partnership

Customer: NuPower Date: 3/11/2019 Location: Bridgeport with heat loop

System: PureCell® Model 400 QNTY: 21 Electrical Utilization: 100% High Grade Heat Utilization: 100% Low Grade Heat Utilization: 0% Cooling Utilization: 0% Heating Fuel: Natural Gas eGrid Sub-region (see map): NEWE T&D Losses: 4.49%

Energy Balance Emissions Balance Annual Emissions Balance Electricity Fuel CO2 NOx SOx Sheet (kWh) (MMBTU) (metric tons - MT) Facility Avoided Emissions (84,000,054) (224,419) (47,584) (20.40) (4.31) On-Site Power Emissions 0 715,631 38,026 0.73 0.00 BALANCE (84,000,054) 491,212 (9,558) (19.66) (4.31)

Emissions Reduction Emissions Summary Metric Tons Equivalence % 2205 acres of CO2 9,558 trees 20%

NOX 19.66 1128 cars 96%

SO2 4.31 100% Water 35,775,623 gal 54.4 olympic pools 100% Utility emissions factors based on U.S. EPA eGRID year 2016 for fossil fuel generation in sub-region. U.S. EPA CHP Partnership Methodology can be found here: http://www.epa.gov/chp/documents/fuel_and_co2_savings.pdf