Dominion Energy Services, Inc. Generation Construction ~ Dominion 5000 Dominion Boulevard, Glen Allen, VA 23060 ~ Energy® DominionEnergy.com Mr. James Bennett May 21, 2018 Director, Office of Renewable Energy Programs Bureau of Ocean Energy Management U. S. Department of the Interior 45600 Woodland Road Sterling, VA 20166 Subject: Amendment to the Coastal Virginia Offshore Wind Project (CVOW, formerly the Virginia Offshore Wind Technology Advancement Project or VOWTAP) Research Activities Plan (RAP) and Response to Comments Dear Mr. Bennett: Virginia Electric and Power Company, d/b/a Dominion Energy Virginia (Dominion, formerly d/b/a Dominion Virginia Power) on behalf of the Virginia Department of Mines, Minerals, and Energy (DMME), is pleased to submit this amendment to the Coastal Virginia Offshore Wind Project (CVOW, formerly the Virginia Offshore Wind Technology Advancement Project or VOWT AP) Research Activities Plan (RAP). The Final VOWTAP RAP was submitted to the Bureau of Ocean Energy Management (BOEM) on April 21, 2015, and subsequently received approval from BOEM on March 23, 2016. As discussed during our meeting on September 7, 2017, 0rsted has been retained as the Engineering, Procurement and Construction (EPC) contractor for the Project. Due to advances in technology since the Project's approval in March 2016, several modifications to the RAP are required to support the Project's current requirements for construction and operation. In accordance with 30 CFR 585.634(c), Dominion has prepared this letter to request BOEM's approval of the proposed modifications to the approved RAP in order to support a Project in service date of 2020. Detailed descriptions of the proposed modifications are provided in the following sections and a summary of the environmental effects and associated mitigation measures are provided in Attachment 1. The proposed modifications described herein include the following: • Site Assessment Activities • Certified Verification Agent Scope of Work • Permits, Approvals, and Consultations • Wind Turbine Generator Specifications • Turbine Foundation • Turbine Foundation Installation Strategy • Export Cable Installation Methods o Communications Cable Crossings • Onshore Interconnection Cable Route • Offshore Deployment and Construction • Underwater Acoustic Modelling • Air Emissions Calculations • Vessel in Distress • Construction Schedule Dominion originally submitted this RAP amendment on December 27, 2017. BOEM provided comments on the RAP amendment on February 16, 2018, which were further discussed during a conference call on March 29, 2018. In response to BOEM’s comments, Dominion has provided the comment response matrix as Attachment 2 to this revised amendment. Additionally, amendments to the Marine Archaeological Resources Assessment and the Visual Impact Assessment, a revised Terrestrial Archaeology Survey Report and an amendment to Historic Properties Assessment have been provided as Attachments 3, 5, 10 and 11, respectively, to this revised amendment. To support BOEM’s evaluation of the CVOW modifications, Dominion has enclosed the following materials to amend the contents of the approved RAP: • Attachment 1 – Summary of Environmental Effects and Proposed Mitigation Measures • Attachment 2 –RAP Amendment Comment Response Matrix • Attachment 3 – Amendment to Marine Archaeological Resources Assessment (CONFIDENTIAL – Provided Under Separate Cover) • Attachment 4 – Permits, Approvals, and Consultations • Attachment 5 – Amendment to Visual Impact Assessment • Attachment 6 – Revised Foundation Typical Drawing (CONFIDENTIAL – Provided Under Separate Cover) • Attachment 7 – Revised Drivability Assessment (CONFIDENTIAL – Provided Under Separate Cover) • Attachment 8 – Revised Underwater Acoustic Modelling • Attachment 9 – Representative HDD Drilling Fluid Material Safety Data Sheet • Attachment 10 – Revised Terrestrial Archaeology Survey Report (CONFIDENTIAL – Provided Under Separate Cover) • Attachment 11 – Amendment to Historic Properties Assessment • Attachment 12 – Air Emissions Supplement and Revised Air Emissions Calculations and Methodology Report • Attachment 13 – Vessels in Distress Requirement Waiver Request As demonstrated throughout this letter, the proposed modifications will have minor to negligible effects on the environmental assessments previously reviewed and approved by BOEM (Attachment 1). In addition, except as described in this update, the mitigation measures previously established in the RAP Approval remain appropriate and will be fully implemented. The following sections provide additional detail regarding the amendments to the RAP, and the associated environmental effects and proposed mitigation measures associated with those amendments. 2 OVERVIEW OF PROJECT PURPOSE AND NEED Despite the proposed Project modifications, the purpose and intent of the Project remains unchanged. The CVOW remains a research project. As described in the RAP, the five key research objectives of this Project and a summary of Dominion’s current approach to achieving the objectives based on the proposed Project modifications are provided below. Technical Innovation and Validation • First turbines to be installed in U.S. Federal waters. • First monopile foundation with 6MW turbines to be installed in the U.S. • Supervisory control system will monitor turbine operation in real time. • Power Boost technology will enable power output above nameplate capacity under certain circumstances. • Hurricane resilient design. Cost Reduction • Provide a necessary step towards future commercial-scale offshore development by utilizing latest technologies to reduce Capital Expenditure (CAPEX) and Operations and Maintenance (O&M) costs. Removal of Market Barriers • Provide a platform for removing first-of-a-kind risks that constitute barriers to the U.S. offshore wind industry, including: o Navigating permitting process; o Installing turbines that are new to the U.S. offshore wind market; and, o Providing a better understanding of U.S. supply chain requirements. Identify Potential Improvements to Permitting Process • Build on experience gained from the permitting process by: o Working with BOEM to gain approval of the RAP amendment in a timely manner; o Being the first project to test the post RAP/COP approval permitting process. Progressing Environmental Research and Understanding • Allow research on wind turbine wake effect by locating the turbines in close proximity to each other; and • Provide valuable data to enhance the understanding of the environmental effects of future offshore wind development in the U.S. DESCRIPTION OF THE PROPOSED CVOW MODIFICATIONS Site Assessment Activities (RAP Section 1.1) Dominion no longer intends to install the three metocean instrumentation platforms in the Research Lease Area as detailed in the Site Assessment Plan (SAP) submitted to BOEM in December 2014. However, a small wave and current buoy will be deployed approximately 2 months prior to construction. The buoy will be temporarily deployed within the area that has been previously surveyed and evaluated in support of the Project. The buoy will remain in 3 place for less than 1 year. The purpose of the buoy will be to monitor real time weather conditions in the project area prior to and during construction. Depending on the selected buoy type, its diameter will be 1.6 to 4.9 ft (0.5 to 1.5 m). The buoy will have an impact resistant stainless-steel hull and be equipped with solar panels on its upper half, which may also include a transmission antenna and a navigational flashing light. The wave buoy will be powered either by lead acid or lithium batteries charged through the solar panels. The buoy will not require a backup generator and will not contain any oils, fuels, or lubricants. The buoy mooring system will consist of an anchor weight (e.g., 1,763 lb [800kg]) and a mooring line designed as a combination of ropes and chains, which may also include floats. Based on a standard mooring configuration at a water depth of approximately 83.6 ft (25.5 m MLLW), the mooring scope will have a radius of 180 ft (55 m). A buoy with positive buoyancy will be placed a couple of meters from the clump weight to prevent entanglement and to eliminate any sweeping of the seabed. The anchor footprint on the seabed is approximately 10.7 (ft2) (1 m2) and the expected vertical penetration of the anchor weight into the seabed is less than -6.5 ft (-2 m). Please see the Amendment to the Marine Archaeological Resources Assessment, provided as Attachment 3 to this amendment, for the Qualified Marine Archaeologist’s (QMA) assessment of site assessment activities. The extent of the Project area is small, and therefore, one wave buoy will be sufficient to record the conditions at both turbine locations. The deployment location proposed is approximately 1,640 ft (500 m) to the east of the two turbine locations, which would provide sufficient clearance for the installation operations to occur (Table 1). The deployment will take place with an audited and certified vessel, fitted with a crane to safely deploy (and collect) the wave buoy. The wave buoy will be deployed and commissioned by one of Ørsted’s suppliers. A dynamically positioned vessel will complete the buoy deployment and decommissioning so no additional seafloor disturbance is anticipated. After completion of the WTG installation, the wave buoy will be decommissioned. Table 1. Wave and current buoy specifications. Easting Depth Mooring Scope Seabed Seabed Longitude1 Latitude1 Northing (Y)2