COMMONWEALTH OF MASSACHUSETTS ENERGY FACILITIES SITING BOARD Project Change request by NSTAR Electric Company d/b/a Eversource Energy. in EFSB 14-04/D.P.U. 14- 153/14-154. the facility approved Nos. EFSB 14-04A!D.P.U. 14-153A/14-154A by the Energy Facilities Siting Board in its Final Decision dated December L 2017. CERTIFICATE OF SERVICE I certify thar, in accordance with 980 Code Mass. Regs. § 1.03(4). on this 7th day of August, 2019, I caused a rme copy of the enclosed documents to be served electronically on al l parties of record or their counsel in EFSB 14-4A/D.P.U. 14-153A/14-154A. Dated: August 7, 2019 Jpshua M. Daniels (BBO# 673034) THE LAW OFFICE OF JOSHUA M. DANIELS P.O. Box 300765 Jamaica Plain, MA 02130 Tel.: (617) 942-2190 Fax: (617) 507-6570 jdanielsfl9danielsappeals.com COM'>10'lWI\ALTII OF :v!ASSJ\CHLSETTS ENERGY FACJLIITI'S SITING BOARD Project Change request by NSTAR Electric Company d/b/a Eversource Energy, inEFSB 14-04/D.P.U. 14- 153114-154, the facility approved l\os. EFSB 14-04A/D.P.C. J4-153A/14-154A by the Energy Facilities Siting I3oard in its Final Decision dated December 1, 2017. J AFFIDAVIT OF MARCOS LUJ\A, PH.D. Marcos Luna, Ph.D., does hereby depose m1d say as follows: I, Marcos Luna, Ph.D., on behalf of Green Roots, Inc., certify that the Record Request Responses submitted with this Affidavit, which bear my name, were prepared by me or under my supcrv.ision and are true and accurate to the best of my knmvlcdge and belief. SIGNED UNDER THE l'AINS AI\D PENALTIES o~· l'ERJURY TJIJS 7TH DAY OF AUGUST, 2019. ~~~~~------ COMMONWEALTH OF MASSACHUSETTS ENERGY FACILITIES SITING BOARD Project Change request by NSTAR Electric Company d/b/a Eversource Energy, in EFSB 14-04/D.P.U. 14- 153/14-154, the facility approved Nos. EFSB 14-04A/D.P.U. 14-153A/14-154A by the Energy Facilities Siting Board in its Final Decision dated December 1, 2017. AFFIDAVIT OF JOHN WALKEY John Walkey, does hereby depose and say as follows: I, John Walkey, on behalf of GreenRoots, Inc., certify that the Record Request Responses submitted with this Affidavit, which bear my name, were prepared by me or under my supervision and are true and accurate to the best of my knowledge and belief. SIGNED UNDER THE PAINS AND PENALTIES OF PERJURY THIS 7TH DAY OF AUGUST, 2019. _________________________________ John Walkey NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-6 August 7, 2019 Person Responsible: John Walkey Page 1 of 7 Record Request RR-EFSB-6 (Tr. 361-62) Identify any recommendations for proposed visual or safety mitigation measures for the Substation enclosure as it is presented in the visual renderings that Eversource has presented in EFSB-V-1(S1). Response At the outset, GreenRoots, answers this request by restating its main contention in this proceeding that the Substation should not be sited at the proposed new site or anywhere else in East Boston that would put the Substation in similarly close proximity to sources of obvious hazards and/or vulnerable populations as the proposed new site. See GreenRoots’ Pet. to Intervene at 3-6; GreenRoots’ Reply in Supp. of Pet. to Intervene at 3-4. By providing a Response to this Record Request, GreenRoots has not abandoned or forfeited that contention. With respect to visual impacts, the current design that Eversource has offered in EFSB- V-1(S1) appears little different (if at all) from that presented in Appendix E to Eversource’s Project Change Petition. Compare EFSB-V-1(S1), pp. 1-3, with Ex. EV-1, Appendix E, pp. 13-16. As GreenRoots stated in its February 22, 2019 Amended Comments, that “design looks more appropriate for the new Seaport or South Boston Waterfront and is not in keeping with East Boston and Chelsea Creek’s historic marine industrial architecture and design,” which typically makes use of brick or stone structures rather than a sterile-looking concrete structure surrounded by a fiberglass fence. See GreenRoots Letter to Kathryn Sedor, Esq. (Feb. 22, 2019), pp. 6-8. More specifically, East Boston’s industrial architecture reflects its long and rich history of maritime industry, including the many vibrant waterfront industries that provided employment to generations of East Bostonians, many of them newly arrived immigrants. The masonry construction of the industrial waterfront exhibits a level of investment and architectural detail belying the utilitarian nature of the structures themselves, and this attention to detail surpasses that which goes into most modern-day structures. Prime examples include 130 Condor Street, which currently houses a kindergarten and Head Start center: NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-6 August 7, 2019 Person Responsible: John Walkey Page 2 of 7 Other examples include many former warehouses that used to serve waterfront industries, many of which have been repurposed for nonmaritime uses over the years, including artists’ studios, automotive businesses, laundromats, and even residential housing: NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-6 August 7, 2019 Person Responsible: John Walkey Page 3 of 7 Atlantic Works artists’ studios, Border Street, East Boston. 285 Border Street, East Boston NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-6 August 7, 2019 Person Responsible: John Walkey Page 4 of 7 266 Border Street, East Boston Porter Street Lofts, East Boston NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-6 August 7, 2019 Person Responsible: John Walkey Page 5 of 7 Unfortunately, newer development threatens to wipe away an increasing share of this rich architectural history. GreenRoots submits that any new structure constructed in or near the Eagle Hill Historic District (established by the National Registry of Historic Places) should be designed so as to promote harmony with the existing architectural character, i.e., incorporating a brick- or stonework design consistent with the industrial-utilitarian style of the late 19th and early 20th century buildings that populate the area, as illustrated by the above examples. Designing electrical substations to match the architecture of older buildings is also not unprecedented. For example, Eversource maintains three substations at Kingston Street, Chatham Street and Hawkins Street in Boston that already do so: NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-6 August 7, 2019 Person Responsible: John Walkey Page 6 of 7 Kingston Street, Boston NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-6 August 7, 2019 Person Responsible: John Walkey Page 7 of 7 Chatham Street, Boston, MA -=- •• • NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-6 August 7, 2019 Person Responsible: John Walkey Page 8 of 7 Hawkins Street, Boston, MA From a safety perspective, one of GreenRoots’ concerns with the proposed Substation is the risk that unauthorized persons may enter the site and be injured or do harm. The fiberglass fencing that Eversource proposes is a ½” x ½” diamond mesh that extends 12 feet high from the sidewalk and incorporates no anti-climbing barriers along the top of the fence. While Eversource describes the fencing as unscalable, it is not obvious that only very few adults (to say nothing of adolescents) would be unable to climb over it. A solid wall made of brick or stone, as illustrated by the above examples, would be far more difficult for any potential trespasser to surmount, and also would not permit those with malicious intent to view the interior of the facility from the hill that lies to the north within the Condor Street Urban Wild. NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Record Request: RR-EFSB-20 August 7, 2019 Person Responsible: Marcos Luna, Ph.D. Page 1 of 1 Record Request RR-EFSB-20 (Tr. II:548-49) Identify and provide the map that Dr. Luna referenced during his cross-examination testimony that shows projected levels of flooding on Glendon Street due to stormwater or runoff from precipitation. Response The map that Dr. Luna referenced can be found in the record as Exhibit GR-7, which was submitted in connection with Dr. Luna’s prefiled direct testimony filed on June 7, 2019. The area in the vicinity of the proposed new site of the Substation, including Glendon Street, is circled on the Exhibit. NSTAR Elec. Co. d/b/a Eversource Energy Energy Facilities Siting Board EFSB 14-04A/D.P.U. 14-153A/14-154A Information Request: RR-EFSB-21 August 7, 2019 Person Responsible: Marcos Luna, Ph.D. Page 1 of 2 Record Request RR-EFSB-21 (Tr. II:568-69) For purposes of interpreting EFSB-GR-17(1): a. Identify the criteria used to determine the “[t]otal number of hurricane strikes by counties/parishes/boroughs” depicted by the maps that appear on pages 11 through 16 of 19.