HomeMy WebLinkAbout20220429_NOI_NE Wind Barnstable Part 1New England Wind 1 Connector
Notice of Intent
Massachusetts Wetland Protection Act (M.G.L. c. 131 §40)
Chapter 237 of the Barnstable General Ordinance
April 29, 2022
Prepared by
Epsilon Associates, Inc.
Submitted to
Barnstable Conservation
Commission
200 Main Street
Hyannis, MA 02601
Submitted by
Park City Wind LLC
New England Wind 1
Connector
Notice of Intent
Massachusetts Wetlands Protection Act (M.G.L. c. 131 §40)
Chapter 237 of the Barnstable General Ordinance
Submitted to:
BARNSTABLE CONSERVATION COMMISSION
200 MAIN STREET
HYANNIS, MA 02601
Submitted by:
PARK CITY WIND LLC
125 High Street, 6th Floor
Boston, MA 02110
Prepared by:
EPSILON ASSOCIATES, INC.
3 Mill & Main Place, Suite 250
Maynard, MA 01754
In association with:
FOLEY HOAG LLP
STANTEC, INC.
GEO SUBSEA LLC
April 29, 2022
Table of Contents
5526.10/New England Wind 1 Connector i Table of Contents
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
TABLE OF CONTENTS
Notice of Intent - New England Wind 1 Connector, Barnstable, MA
MASSACHUSETTS DEP, WPA FORM 3
TOWN OF BARNSTABLE NOI SUBMISSION CHECKLIST – Chapter 707
ATTACHMENT A PROJECT NARRATIVE 1
1.0 Introduction and Project Overview 1
1.1 Current Permitting Status 1
2.0 Project Purpose and Public Benefits 5
3.0 Existing Conditions within the Town of Barnstable 7
3.1 Offshore Export Cable Corridor (OECC) 7
3.1.1 Special, Sensitive, and Unique (SSU) Habitats 10
3.1.1.1 Hard/Complex Seafloor 10
3.1.1.2 Hard Bottom Habitat 11
3.1.1.3 Complex Bottom 11
3.1.1.4 Eelgrass 12
3.1.2 Shellfish Habitat 13
3.1.3 Rare Species Habitat 13
3.2 Craigville Public Beach Landfall Site 14
3.3 Onshore Transmission Route 15
3.3.1 Wetlands along the Duct Bank Route 15
3.3.2 Centerville River Crossing 16
4.0 Proposed Construction Activities and Impacts 17
4.1 Offshore Cable Installation 17
4.1.1 General Offshore Installation Methods 18
4.1.2 Anticipated Offshore Project Impacts 22
4.1.2.1 Cable Installation Tool 24
4.1.2.2 Anchoring 25
4.1.2.3 Cable Protection 27
4.1.2.4 Sand Wave Dredging 28
4.1.3 Sediment Dispersion and Turbidity 30
4.2 Onshore Construction 32
4.2.1 HDD Construction Methodology 32
4.2.1.1 HDD Construction Sequence and Schedule 33
4.2.1.2 Management of Drilling Fluids and HDD Contingency
Plan for Seepage 36
4.2.2 Duct Bank Construction and Centerville River Crossing 38
4.2.2.1 Duct Bank Construction and Cable Installation 38
4.2.2.2 Centerville River Crossing 41
4.2.3 Anticipated Impacts to Coastal Resource Areas from Onshore
Construction 44
5526.10/New England Wind 1 Connector ii Table of Contents
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
TABLE OF CONTENTS (Continued)
5.0 Regulatory Compliance 45
5.1 Water-Dependent Projects 46
5.2 Limited Project Status 46
5.3 Wetland Resource Areas and Performance Standards 47
5.3.1 Riverfront Area 48
5.3.2 Land Under the Ocean 48
5.3.2 Coastal Dune/Barrier Beach 51
5.3.3 Land Containing Shellfish 52
5.3.4 Salt Marsh 55
5.4 Interests Protected under Barnstable Wetlands Protection Bylaw 56
6.0 Mitigation Measures 58
ATTACHMENT B FIGURES
Figure 1 Project Overview, USGS Locus
Figure 2 Offshore Export Cable Corridor (Barnstable waters), NOAA Chart
Figure 3 OECC and SSU Areas in Barnstable waters
Figure 4 Shellfish Suitability Areas and the OECC in Barnstable waters
Figure 5 Rare Species Habitats within Installation Corridor in Barnstable Waters
Figure 6 NHESP-Mapped Habitat near Craigville Public Beach Landfall Site
Figure 7 Wetland Resource Areas at Landfall Site and Centerville River Crossing
Figure 8 Wetland Resources Areas – Onshore Transmission Route
Figure 9 Centerville River Crossing – Microtunnel – Aerial View
Figure 10 HDD Staging and Transition Vault/Joint Bay Locations, Craigville Public Beach Landfall Site
Figure 11 Typical Duct Bank Cross-Sections
ATTACHMENT C MARINE SURVEY CHART (BARNSTABLE WATERS)
ATTACHMENT D PHOTOGRAPHS OF CRAIGVILLE PUBLIC BEACH LANDFALL SITE
ATTACHMENT E DUCT BANK ENGINEERING PLANS
ATTACHMENT F HDD ENGINEERING PLANS
ATTACHMENT G PIPING PLOVER PROTECTION PLAN
ATTACHMENT H MICROTUNNEL ENGINEERING PLANS
ATTACHMENT I DUNE RESTORATION PLAN
5526.10/New England Wind 1 Connector iii Table of Contents
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
TABLE OF CONTENTS (Continued)
ATTACHMENT J ABUTTER INFORMATION
i List of Abutters
i Affidavit of Service (to be finalized once hearing date is set)
ATTACHMENT K WETLAND FEE TRANSMITTAL FORM
ATTACHMENT L NHESP MESA DETERMINATION
LIST OF TABLES
Table 1-1 Environmental Permits, Reviews, and Approvals for the New England Wind 1
Connector and Park City Wind 1-3
Table 3-1 Temporary Wetland Resource Area Impacts for Centerville River Crossing
Microtunnel (square feet) 3-17
Table 4-1 Impacts to Land Under the Ocean from Installation of Two Offshore Export Cables
within Barnstable Waters 4-23
Table 4-2 Estimated Anchoring Impacts from Installation of 2 Offshore Export Cables in
Barnstable Waters. 4-26
Table 4-3 Landfall Site HDD Installation Schedule 4-36
Table 4-4 Summary of Duct Bank and Trench Dimensions (feet) 4-39
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Attachment A
Project Narrative
5526.10/New England Wind 1 Connector 1 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
ATTACHMENT A PROJECT NARRATIVE
1.0 Introduction and Project Overview
Park City Wind LLC (the Proponent) is in the process of developing and permitting an offshore
wind project with a nameplate generating capacity of approximately 800 megawatts (MW). The
offshore wind farm will be located in federal waters, specifically in the northern portion of Bureau
of Ocean Energy Management (BOEM) Lease Area OCS-A 0534 which, at its closest point, is
approximately 41 miles (66 km) south of the Cape Cod mainland.
The New England Wind 1 Connector (NE Wind 1 Connector, the “Project”) is comprised of the
Massachusetts-jurisdictional elements of the broader Park City Wind project (i.e., portions of the
offshore transmission that are in Massachusetts waters, as well as the onshore transmission, the
onshore substation, and the grid interconnection in the town of Barnstable). Figure 1 in
Attachment B provides an overview of the NE Wind 1 Connector.
This Notice of Intent (NOI) addresses those aspects of the Project that are located within the Town
of Barnstable and subject to regulations established under the Massachusetts Wetlands
Protection Act (WPA) and Barnstable Wetlands Protection Ordinance. This includes
approximately 6.8 miles of Offshore Export Cable Corridor (OECC) within Barnstable’s offshore
waters, the landfall site at a town-owned parking lot at Craigville Public Beach, the trenchless
crossing of the Centerville River, and those portions of the onshore transmission system that are
located within the jurisdiction of the Barnstable Conservation Commission.
Specifically, the Proponent seeks an Order of Conditions from the Barnstable Conservation
Commission for work in and within 100 feet of Land Under the Ocean, Coastal Dune, Barrier
Beach, Riverfront Area (RFA), and Land Subject to Coastal Storm Flowage (LSCSF). The Proponent
is seeking approval under the Massachusetts WPA Regulations and the Barnstable Wetlands
Ordinance as a Limited Project for alteration of Land Under the Ocean within Barnstable’s
offshore waters, and for temporary alterations to Coastal Dune, Barrier Beach, RFA, and LSCSF
associated with onshore construction activities (see Section 5.2); this is despite the fact that the
Proponent believes the Project does meet the wetland performance standards. All Project-
related construction activities and their associated impacts to wetland resource areas in
Barnstable are described in this NOI. The majority of the onshore export cable route, including
the site of the proposed substation, is located outside of wetland resource areas.
1.1 Current Permitting Status
The Park City Wind project and NE Wind 1 Connector are currently under extensive review by a
range of federal, state, and regional agencies to ensure that impacts to the marine environment
are avoided and minimized.
5526.10/New England Wind 1 Connector 2 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
All proposed elements of the larger Park City Wind project are being reviewed by BOEM and other
participating federal and state regulatory agencies under the National Environmental Policy Act
(NEPA). This review will include preparation of Draft and Final Environmental Impact Statements
developed by an independent third party in consultation with review agencies and stakeholders
(the Draft Environmental Impact Statement [DEIS] and Final Environmental Impact Statement
[FEIS] will be publicly available documents as part of the federal review).
While the federal review processes are underway, state-level environmental review for the NE
Wind 1 Connector is being led by the Executive Office of Energy and Environmental Affairs (EEA),
Massachusetts Environmental Policy Act (MEPA) Office (which completed its review on January
28, 2022), and the Energy Facilities Siting Board (EFSB).
Rigorous environmental reviews will be highly scrutinized by a host of other state and federal
permitting and review agencies including the U.S. Army Corps of Engineers (USACE), U.S.
Environmental Protection Agency (EPA), Massachusetts Department of Environmental Protection
(MassDEP), Massachusetts Division of Marine Fisheries (DMF), and Natural Heritage and
Endangered Species Program (NHESP). In addition, portions of the NE Wind 1 Connector will be
reviewed by the Cape Cod Commission and Martha’s Vineyard Commission.
The principal environmental permits, reviews, and approvals required for the Park City Wind
project and NE Wind 1 Connector (as well as their approval status as of this submission) are listed
in Table 1-1. By meeting the requirements for each of these review programs, permits, and
approvals, the Project will demonstrate compliance with applicable state and local environmental
policies.
5526.10/New England Wind 1 Connector 3 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Table 1-1 Environmental Permits, Reviews, and Approvals for the New England Wind 1 Connector
and Park City Wind
Agency/Regulatory Authority Permit/Approval Status
Federal (for Park City Wind)
Bureau of Ocean Energy Management
(BOEM)1
Construction and Operations Plan (COP)
approval/Record of Decision (ROD)
COP filed July 2020
National Environmental Policy Act (NEPA)
Environmental Review
Initiated by BOEM
June 30, 2021
Consultation under Section 7 of the
Endangered Species Act (ESA) with National
Marine Fisheries Service (NMFS) and U.S. Fish
and Wildlife Service (USFWS), coordination
with states under the Coastal Zone
Management Act (CZMA), government-to-
government tribal consultations, consultation
under Section 106 of the National Historic
Preservation Act (NHPA), and consultation
with NMFS for Essential Fish Habitat
To be initiated by
BOEM
Facilities Design Report and Fabrication &
Installation Report
To be filed (TBF)
U.S. Environmental Protection Agency
(EPA)
EPA Permits under Section 316(b) of the Clean
Water Act (CWA), including National Pollutant
Discharge Elimination System (NPDES)
Permit(s)
TBF
Outer Continental Shelf (OCS) Air Permit TBF
U.S. Army Corps of Engineers (USACE) Clean Water Act (CWA) Section 404 Permit
Rivers and Harbors Act of 1899 Section 10
Individual Permit
Joint application TBF
U.S. National Marine Fisheries Service
(NMFS)
Letter of Authorization (LOA) or Incidental
Harassment Authorization
TBF
U.S. Coast Guard (USCG) Private Aid to Navigation (PATON)
authorization
TBF
Federal Aviation Administration No Hazard Determination (for activities at
construction staging areas and vessel transits,
if required)
TBF
1 In its review of the COP, BOEM must comply with its obligations under the National Environmental Policy Act
(NEPA), the National Historic Preservation Act (NHPA), the Magnuson-Stevens Fishery Conservation and
Management Act, the Migratory Bird Treaty Act, the Clean Air Act, and the Endangered Species Act (ESA). Thus,
BOEM coordinates and consults with numerous other federal agencies including the National Marine Fisheries
Service (NMFS), United States Fish and Wildlife Service (USFWS), the Environmental Protection Agency (EPA),
and the United States Coast Guard (USGC) during the review process. BOEM also coordinates with the state
under the Coastal Zone Management Act (CZMA) to ensure that the project is consistent with the state’s coastal
zone management program.
5526.10/New England Wind 1 Connector 4 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Table 1-1 Environmental Permits, Reviews, and Approvals for the New England Wind 1 Connector
and Park City Wind (Continued)
Agency/Regulatory Authority Permit/Approval Status
State/Massachusetts (for the NE Wind 1 Connector)
Massachusetts Environmental Policy Act
Office (MEPA)
Certificate of Secretary of Energy and
Environmental Affairs (EEA) on Final
Environmental Impact Report
Environmental
Notification Form
filed June 11, 2020,
Draft Environmental
Impact Report (DEIR)
filed March 19, 2021
(Certificate received
June 25, 2021), Final
Environmental
Impact Report (FEIR)
filed December 15,
2021 (Certificate
received January 28,
2022).
Energy Facilities Siting Board (EFSB) G.L. c. 164, § 69 Approval Filed May 28, 2020
Massachusetts Department of Public
Utilities (DPU)
G.L. c. 164, § 72, Approval to Construct
G.L. c. 40A, § 3 Zoning Exemption
Filed May 28, 2020
Massachusetts Department of
Environmental Protection (MassDEP)
Chapter 91 Waterways License and Dredge
Permit
Water Quality Certification (Section 401 of the
CWA)
Joint Application TBF
Massachusetts Department of
Transportation (MassDOT)
Highway Access Permits (Barnstable) TBF
Massachusetts Board of Underwater
Archaeological Resources (MBUAR)
Special Use Permit 17-003 (issued to
archaeologist, not Park City Wind LLC)
Permit renewal
approved February
26, 2021
Natural Heritage and Endangered Species
Program (NHESP)
Conservation and Management Permit (if
needed)
TBF (if needed)
MESA
Determination
issued April 1, 2022
with conditions so
the Project will not
result in a Take of
state-listed species.
Massachusetts Historical Commission
(MHC)
State Archaeologist Permit #4006 (950 C.M.R.
§ 70.00) (issued to archaeologist, not Park City
Wind LLC)
Permit #4006 for
Reconnaissance
Survey received May
12, 2020. Permit
#4006 amended and
extended March 2,
2021 (survey
complete).
5526.10/New England Wind 1 Connector 5 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Table 1-1 Environmental Permits, Reviews, and Approvals for the New England Wind 1 Connector
and Park City Wind (Continued)
Agency/Regulatory Authority Permit/Approval Status
State/Massachusetts (for the NE Wind 1 Connector)
Massachusetts Division of Marine
Fisheries (DMF)
Letter of Authorization and/or Scientific
Permit (for surveys and pre-lay grapnel run)
TBF
Massachusetts Office of Coastal Zone
Management (CZM) /
Rhode Island Coastal Resources
Management Council (CRMC)
Federal Consistency Determination (15 CFR
930.57)
Filed with COP as
Appendix III-S
Regional (for portions of the NE Wind 1 Connector within regional jurisdiction)
Cape Cod Commission (CCC) Development of Regional Impact (DRI) Review
(Barnstable County)
TBF
Martha’s Vineyard Commission (MVC) DRI Review (Dukes County) TBF
Local (for portions of the NE Wind 1 Connector within local jurisdiction)
Barnstable Conservation Commission Order of Conditions (Massachusetts Wetlands
Protection Act and, as applicable, municipal
wetland non zoning bylaws)
This application.
Barnstable DPW and/or Town Council Street Opening Permits/Grants of Location TBF
Barnstable Planning/Zoning Zoning approvals (if necessary) TBF
Edgartown Conservation Commission Order of Conditions (Massachusetts Wetlands
Protection Act [WPA] and, as applicable,
municipal wetlands non zoning bylaws) for
OECC within Edgartown waters
Filed March 23, 2022
Nantucket Conservation Commission Order of Conditions (Massachusetts WPA and,
as applicable, municipal wetland non zoning
bylaws) for OECC within Nantucket waters
Filed March 7, 2022
2.0 Project Purpose and Public Benefits
The purpose of the Project is to deliver approximately 800 MW of clean, renewable wind energy
to the New England electrical grid. By doing so, the Project will serve the public interest by
increasing the reliability and diversity of the regional energy supply.
The NE Wind 1 Connector and Park City Wind are expected to create a range of environmental
and economic benefits for southeastern Massachusetts, the Commonwealth as a whole, and the
entire New England region. These benefits will extend across the design, environmental review,
and permitting phase, the procurement, fabrication, and construction/commissioning phase, the
multi-decade operating phase, as well as the future decommissioning effort.
Project benefits are expected to include:
i Clean renewable energy at large scale and a high-capacity factor: The location of the
associated WTGs well offshore in a favorable wind regime, coupled with the efficiency of
the WTGs, will enable the Project to deliver substantial quantities of power on a reliable
basis, including during times of peak grid demand. WTGs for Park City Wind will be among
5526.10/New England Wind 1 Connector 6 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
the most efficient models currently available for offshore use. It is expected that the
WTGs will be capable of operating with an annual capacity factor of approximately 50%.
Based on EPA data 2 and assuming a Project generating capacity of approximately 800
MW, WTGs of this efficiency and capability will reduce ISO-NE CO2e emissions by
approximately 1.59 million tpy. This is the equivalent of removing approximately 310,000
automobiles from the road. In addition, nitrogen oxide (NOx) emissions across the New
England grid are expected to be reduced by approximately 850 tpy with sulfur dioxide
(SO2) emissions being reduced by approximately 450 tpy.
i Reducing winter energy price spikes: The Project adds high and stable winter capacity
factor offshore wind generation to the region, increasing resources available to meet
electric demand needs with offshore wind-generated energy, freeing up natural gas
resources to be used for necessary home heating demands. The Project will therefore be
unaffected by the risk of potential fossil fuel constraints and will help alleviate price
volatility. The Project could reduce the need to run the gas- and oil-burning Canal Units
1 and 2 on Cape Cod, especially during winter peak events when winds are high and
conditions ideal for wind energy generation.
i Improving the reliability of the electric grid in Southeastern Massachusetts: The Project
will connect to the bulk power system on Cape Cod, and thus will increase the supply of
power to Barnstable County and other parts of southeastern Massachusetts, an area
which has experienced significant recent (and planned) generation unit retirements.
Because of its interconnection location and generation type, adding an additional
approximately 800 MW of offshore wind generation to the current power generation
portfolio will provide fuel diversification and enhance the overall reliability of power
generation and transmission in the region and in particular the southeast Massachusetts
area, which has seen, and will continue to see, substantial changes in generation capacity.
This will mitigate future costs for ensuring reliable service for Massachusetts customers.
i Additional economic benefits for the region: Project construction will generate
substantial economic benefits, including opportunities for regional maritime industries
(tug charters, other vessel charters, dockage, fueling, inspection/repairs, provisioning).
i New employment opportunities: The Proponent is committed to spurring and facilitating
the creation, development, growth, and sustainability of a long-term offshore wind
industry in New England, including a robust local supply chain, a well-trained local
workforce throughout development, construction, and operations activities, local port
facilities capable of fabrication and construction of key project components, and
2 Based on avoided emission rates from EPA’s Emissions & Generation Resource Integrated Database
eGRID2018(v2) released March 2020.
5526.10/New England Wind 1 Connector 7 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
advanced manufacturing capabilities, all of which will cement New England as a leader in
offshore wind. The Proponent estimates the Project will generate over 4,700 direct full-
time equivalent (FTE) job years and 2,100 indirect FTE job years over its lifetime, primarily
in Connecticut and Massachusetts.
i Support for Massachusetts policies: The Project is entirely consistent with the
Commonwealth’s Global Warming Solutions Act (GWSA) goals because supplying
emissions-free energy to the New England electric grid will displace fossil fuel sources,
including in Massachusetts, which would otherwise operate to supply that power.
The Proponent is currently in late-stage discussions with the Town of Barnstable for an Host
Community Agreement (HCA) for the Project and expects the HCA for the Project will contain very
similar or identical economic terms as those in the 2018 HCA for Vineyard Wind Connector. On
October 21, 2021, the Barnstable Town Council authorized the Town Manager to finalize and
execute the HCA with the Proponent. Assuming the relevant terms are identical, the Project’s
HCA would guarantee that, in addition to property tax assessments, the Project would pay a total
Host Community Payment of $16 million, plus an additional $60,000 (adjusted upward annually
by 2.5%) for each year the Project is in operation beyond 25 years. In addition to HCA payments
and property tax payments to Barnstable for the Project, additional revenues are also anticipated
for the Commonwealth and municipalities in the form of higher tax payments resulting from
Project activities and employment (including personal income taxes, sales taxes, corporate and
payroll taxes, and real and personal property taxes) in every Project phase.
A more extensive discussion of Project benefits was provided in Section 1.7 of the FEIR. The FEIR
can be found at https://www.parkcitywind.com/permitting.
3.0 Existing Conditions within the Town of Barnstable
3.1 Offshore Export Cable Corridor (OECC)
Offshore Project components within Barnstable waters are limited to installation of two offshore
export cables along an approximately 6.6-mile (10.6-km) stretch of the OECC as well as the
approximately 0.2-mile (0.3-km) offshore-to-onshore transition via horizontal directional drilling
(HDD) at the landfall site. The OECC was thoroughly evaluated and approved for the Vineyard
Wind Connector, and it remains largely the same for the NE Wind 1 Connector. One difference is
the OECC has been widened by approximately 985 feet (300 m) to the west, bringing its typical
width to approximately 3,800 feet (1,150 m). Since the two cables from the Vineyard Wind
Connector will already be installed within the previously identified OECC, this widening will
provide greater flexibility throughout the route design process as part of ongoing efforts to avoid
and minimize impacts to sensitive habitats. The areas of widening were surveyed in 2020. The
NE Wind 1 Connector includes two offshore export cables, both of which will be located within
the OECC. In addition, the Proponent has performed a comprehensive assessment of the
geophysical and geotechnical conditions along the route, including the presence of seabed
features and considerations such as sand waves, magnetic anomalies, coarse deposits, rocks or
5526.10/New England Wind 1 Connector 8 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
boulders, water depths, and seabed slopes. Within the OECC, the two export cables will be
installed with sufficient separation to allow for safe installation and any future repair work, if
required. The OECC within Barnstable waters is shown on Figure 2 in Attachment B.
Offshore wind projects are unique infrastructure that utilize rapidly changing technologies
deployed in a dynamic marine environment. The high-energy marine environment can cause
features like shoals to be in a constant state of change, resulting in corresponding water depth
changes. Experience in the offshore wind industry in Europe as well as offshore cable installations
in the U.S. has demonstrated that use of an installation corridor can provide flexibility in the
engineering and installation stages to maximize the likelihood of successful cable burial while also
avoiding and minimizing environmental impacts.
Geological conditions within the OECC are well understood, and the site geology and conditions
are suitable for cable installation. Through the OECC survey work completed as part of Vineyard
Wind/Vineyard Wind Connector, supplemented by additional surveys in 2020, a large amount of
survey data has been collected and the Proponent has a strong understanding of the OECC in
terms of potential environmental impacts and construction feasibility. Prior to 2020 surveys,
more than 2,307 nautical miles (4,272 km) of geophysical trackline data, 123 vibracores, 83 cone
penetrometer tests, 82 benthic grab samples with still photographs, and 50 underwater video
transects had already been gathered in support of OECC characterization. Further data collection
was performed for the OECC expansion areas in 2020.
Using all these accumulated data, the Proponent has conducted a comprehensive geotechnical
evaluation of the shallow subsurface conditions present along the OECC and has determined that
cable installation is feasible. While geological conditions vary within the corridor, including
limited locations with more challenging conditions for cable installation, conditions are overall
within acceptable risk levels. In addition, reconnaissance survey work for Vineyard
Wind/Vineyard Wind Connector, which included coverage of the western portion of Muskeget
Channel and routes to the east of Horseshoe Shoal in Nantucket Sound, did not identify areas
where conditions appeared more favorable for cable installation. To the contrary, such
reconnaissance survey work identified features outside the OECC such as shoals, large
concentrations of boulders, deep channels, and high currents that would make cable installation
and maintenance in an alternate location more challenging. These factors would increase health
and safety risk during installation and maintenance, risk of not achieving sufficient burial depths,
and risk of cable exposure. The Proponent has also assessed the OECC for installation feasibility,
which includes ensuring that water depths are suitable for fully loaded cable installation vessels,
slopes are workable for typical cable installation tools, sufficient room is available for anchoring,
etc. Based on these detailed geotechnical and installation feasibility analyses, the Proponent has
determined that the identified cable corridor is the most suitable for cable installation and the
needs of Park City Wind/NE Wind 1 Connector.
5526.10/New England Wind 1 Connector 9 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Results from the marine surveys performed since 2017 have been used to identify the proposed
OECC. This selection was addressed in detail in the MEPA environmental review process (Section
2.1.3.1 of the DEIR and Section 2.1.1 of the FEIR), and reflected selection of the shortest offshore
route with the fewest environmental impacts while remaining technically suitable for cable
installation.
The principal technical and environmental considerations and constraints factoring into the
geography of the OECC include:
1. Feasibility of cable installation, including required spacing from other cables;
2. Burial risk assessment/work to limit possibilities of cable failure;
3. Avoiding and/or minimizing impacts to special, sensitive, or unique (SSU) areas mapped
in the Massachusetts OMP;
4. Avoiding and/or minimizing anchorage areas and areas with mapped shipwrecks and
boulders;
5. Environmental and/or permitting constraints and avoidance of impacts;
6. Minimizing cable length to reduce transmission losses and cost;
7. Adequate capacity delivered to the grid connection point;
8. Available landfall locations;
9. Maintaining a water depth of at least 20 feet, and avoiding shoals;
10. The route should not turn more than 30 degrees at a time, with a minimum turn radius
of 165 feet (50 m);
11. Avoiding slopes where the seafloor bathymetry changes dramatically;
12. Crossing large seabed slopes and existing offshore cables in a perpendicular, or nearly
perpendicular, orientation; and
13. Crossing navigation corridors in a perpendicular orientation.
The offshore cable corridor within Barnstable Conservation Commission jurisdiction is shown on
Figure 2. The total length of the corridor within Barnstable waters is approximately 6.8 miles (6.6
miles [10.6 km] of cable burial and 0.2 miles [0.3 km] of HDD). The Project will avoid core habitat
for whales, and the corridor will avoid most hard/complex bottom habitat mapped in the
Massachusetts Ocean Management Plan (OMP) (see below).
5526.10/New England Wind 1 Connector 10 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
3.1.1 Special, Sensitive, and Unique (SSU) Habitats
The Massachusetts OMP identifies “special, sensitive, and unique” (SSU) habitats to which
impacts should be avoided and minimized, where practicable.
For cable projects generally, these SSU areas include hard/complex bottom, eelgrass, and marine
mammal habitats such as core habitat for the North Atlantic Right Whale (no such core habitat is
mapped within Barnstable waters). Some habitats are known to change and move over time (e.g.,
complex bottom formed by sand wave fields) while others are prime habitats despite seasonal
and long-term changes in organism abundance (e.g., eelgrass).
As described above, the OECC will avoid most hard/complex bottom habitat mapped in the OECC
(see Figure 3). The Proponent’s marine surveys have been used to refine the OMP mapping of
hard bottom and complex bottom based on higher-resolution survey data, with results depicted
on Figure 3 as well as the map set provided in Attachment C.
Within Barnstable, as shown on Figure 3, the preliminary cable alignments within the OECC
predominantly avoid hard bottom, but they are unable to avoid a broad area of complex
seafloor/bedforms that covers most of the corridor towards its southern end in Barnstable
waters.
The discussion below addresses hard bottom and complex bottom as well as eelgrass mapped
within the OECC in Barnstable waters based on the Proponent’s marine survey results.
3.1.1.1 Hard/Complex Seafloor
This broad characterization of the seafloor was first developed by the Massachusetts Office of
Coastal Zone Management (CZM) and is documented in the “Regional Sediment Resource
Management Work Group Report – 2014 Massachusetts Ocean Management Plan Update” (CZM,
2014). Defined by CZM in this report, complex seafloor is “a morphologically rugged seafloor
characterized by high variability in bathymetric aspect and gradient.” CZM (2014) determined the
complex seafloor areas by utilizing a USGS 30-meter by 30-meter low-resolution bathymetry
dataset and calculated areas of high rugosity using a Vector Ruggedness Measure (VRM) tool,
based on a method developed by Sappington et al. (2007) with a 9x9-cell neighborhood size. The
values produced by the VRM analysis range from 0 to 1, with 0 indicating no seabed complexity
and 1 indicating complete seabed complexity. The seabed was classified as complex for VRM
values greater than 3/8 standard deviation from the mean value of the whole dataset (CZM,
2014).
Using the CZM (2014) analysis as a guide, which is consistent with the hard/complex bottom
revised for the 2021 OMP, the Proponent performed an analysis of multibeam depth sounding
data. A VRM was performed on the 0.5-meter by 0.5-meter high-resolution bathymetry collected
along the OECC using a 9-cell search radius. Polygons were then created from the VRM grids by
clipping the extents to include only values greater than the mean value plus 3/8 standard
5526.10/New England Wind 1 Connector 11 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
deviation which resulted in a cutoff of 0.0035 and greater to indicate a complex seafloor. Results
of the ruggedness analysis on the 2018 dataset show much more detail and complexity due to the
data point spacing considered. Smaller, localized features exhibiting high enough slope gradients
and sharp bathymetry aspects are in some areas individually mapped.
Results indicate increased seafloor ruggedness is associated with the bedform habitat, hard
bottom habitat, and biogenic structures/surface organics habitat. An overall boundary for the
hard/complex seafloor characterization presented in the OMP is thus the combination of all three
of these benthic habitats. For the purposes of the NE Wind 1 Connector, the Proponent has
separated areas of bedforms (i.e., complex bottom) from hard bottom, since these benthic
environments are distinctly different habitats.
3.1.1.2 Hard Bottom Habitat
Hard bottom areas in portions of Nantucket Sound include high concentrations of coarse material
(>50 % gravel, cobbles, boulders in a sand matrix) which, even though considered an
unconsolidated sediment surface, form a relatively hard substrate to which sessile benthic
organisms can attach. Most of these are associated with glacial moraine deposits and consist of
rock piles and scattered individual rocks (i.e., boulders) of varying abundance on the seafloor.
Some areas are predominantly gravel and cobbles with the sand matrix and a sparse distribution
of boulder-sized material. No bedrock outcrops exist within the OECC.
As shown on Figure 3 and in the plan set depicting results from the marine surveys within
Barnstable waters (see Attachment C), there are some small areas of hard bottom that the
preliminary cable alignments avoid. The cable alignments are unable to avoid a broad area of
complex seafloor/bedforms that covers most of the corridor towards its southern end in
Barnstable waters. However, it is important to note that while some temporary impacts to
complex seafloor/bedforms are unavoidable, almost all of the OECC will remain unaffected by the
cable installation; rather, two narrow strips of seabed, one for each cable alignment, will be
impacted by the cable installation.
3.1.1.3 Complex Bottom
As shown on Figure 3 and in Attachment C, within Barnstable waters the OECC almost entirely
avoids areas of complex bottom except for an area toward the southern reach of the OECC in
Barnstable waters where an area of complex seafloor/bedforms covers most of the corridor
width. In this area and elsewhere along the OECC, bedform fields (i.e., ripples, megaripples, and
sand waves) of varying sizes are present and are morphologically dynamic. Due to the mobility of
the sediments in this habitat, development of infaunal communities is greatly reduced compared
to more stable seabed areas. While this equates to a lower productive infaunal benthic regime,
the bottom morphology and dynamics of the fields is reportedly attractive to finfish. The areal
extent of these bedforms is constantly changing with subtle environmental shifts in water depths,
5526.10/New England Wind 1 Connector 12 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
sediment grain size, and current flow. This is a laterally extensive habitat due to the
predominantly sandy seafloor and tidal currents flowing over the bottom and constantly
reworking sediment.
Some areas of Nantucket Sound have active sand waves that can exceed 12 feet (3.7 m) in height.
Marine survey work has enabled the Proponent to assess these areas, which may require some
pre-cable-laying dredging to ensure that the necessary burial depth can be achieved and
maintained. The stretch of the OECC where sand wave dredging may be needed is largely
coincident with areas mapped as complex bottom as shown on Figure 3. It is important to note
that dredging, if performed, would not occur along the entire stretch where sand waves may be
present; rather, dredging would only be performed to remove the tops of each sand wave to the
extent needed at the time of construction to ensure sufficient burial within the stable seabed.
Dredging will be performed as close in time to cable installation as possible to avoid mobile sand
waves re-covering the dredged area.
A number of possible sand wave dredging techniques are under consideration and are described
in detail in Section 4.1.2.4. For both offshore export cables combined, the Proponent’s engineers
anticipate that the length of dredging in Barnstable waters could be approximately 2.0 miles (3.2
km). It is important to note that since sand waves are mobile features with shifting morphology,
this length of dredging is an estimate.
3.1.1.4 Eelgrass
Eelgrass (Zostera marina) beds form an important habitat in the coastal environment that
provides refuge and sustenance for a large number and variety of species, as well as serving as a
critical component of sediment and shoreline stabilization. Preliminary routing for the Project
considered data from MassDEP’s Eelgrass Mapping Project as well as the OMP, and the Proponent
has performed specific eelgrass surveys within the installation corridor.
The 2018 marine survey documented one previously unidentified area of eelgrass within
Centerville Harbor, southeast of the Craigville Public Beach Landfall Site. This area was first
identified by video survey, in which sparse patches of eelgrass were noted around Spindle Rock.
A subsequent diver investigation provided a thorough mapping of the area. This patch of eelgrass
is co-located with an area of hard bottom (a rock pile), where patches of eelgrass intertwined with
macroalgae inhabit the discontinuous sandy bottom in and around the rock pile. During 2018
surveys, the eelgrass in this area exhibited the bright green coloring common for healthy eelgrass
during the growing season.
As shown on Figure 3, the HDD trajectory will enable the Project to entirely avoid impacts to this
area of eelgrass as well as the co-located hard bottom. As a result, the preliminary cable
alignments completely avoid eelgrass along the entire OECC, including in Barnstable waters.
5526.10/New England Wind 1 Connector 13 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
3.1.2 Shellfish Habitat
The Division of Marine Fisheries (DMF) has mapped areas throughout the Commonwealth as
suitable shellfish habitat for Bay Scallop, Surf Clam, Quahog, Soft Shell Clam and Blue Mussel.
These are believed to be suitable for these species of shellfish based on the expertise of DMF and
local Shellfish Constables, input from commercial fishermen, and information contained in maps
and studies of shellfish in Massachusetts. DMF shellfish suitability areas include sites where
shellfish have been observed since the mid-1970s but may not currently support any shellfish, and
therefore represent potential habitat areas.
As shown on Figure 4, the Project’s OECC and preliminary cable alignments almost entirely avoid
shellfish suitability areas in Barnstable waters. The transition from offshore cable burial to the
HDD will occur close to the boundary for mapped suitable habitat for Surf Clam (Spisula
solidissima) located in the nearshore area of Centerville Harbor. The use of HDD will avoid almost
all impacts to the mapped suitable habitat by using HDD to pass beneath most of the nearshore
Surf Clam habitat without disturbing the surface of the seafloor. However, it is estimated that
typical cable installation would occur through approximately 200 linear feet of that habitat. The
actual length could be more or less than 200 linear feet based on the final HDD design.
3.1.3 Rare Species Habitat
The Massachusetts Natural Heritage and Endangered Species Program (NHESP) has mapped all
state waters within Nantucket Sound and Muskeget Channel as priority habitat of state-listed rare
species (Massachusetts Natural Heritage Atlas, 15th Edition, 2021). As a result, the portion of the
OECC that passes within Barnstable waters will necessarily cross priority habitat (see Figure 5 in
Attachment B). The Proponent is consulting with the NHESP in accordance with the
Massachusetts Endangered Species Act (MESA) (321 CMR 10.14) to ensure that impacts to
offshore rare species are avoided or minimized to greatest extent practicable.
In addition, NHESP has established Priority Habitat along the Centerville Harbor shoreline for
Piping Plover that includes the beach and some of the dunes adjacent to the Craigville Public
Beach parking lot (see Figure 6 in Attachment B). At this location, the Project will utilize HDD to
avoid any disturbance to mapped habitat, and in consultation with NHESP the Proponent has
developed a Piping Plover Protection Plan for construction activities at the landfall site (refer to
Attachment G).
Project construction on land at the Craigville Public Beach Landfall Site will remain entirely outside
of mapped habitat, and the HDD will be performed entirely within existing paved surfaces.
Furthermore, since the proposed cable installation method at the landfall site is HDD and would
extend underneath the beach, there will be no disturbance to any areas of mapped Piping Plover
habitat. In discussions with NHESP, potential noise disruption to existing nests was raised as a
concern, and a mitigation option was discussed with the agency. NHESP suggested that if the HDD
could begin before April 1 or after August 31, then a pair of birds would be aware of the noise
prior to selecting a nesting location. As a result, the Proponent has made the commitment that
5526.10/New England Wind 1 Connector 14 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
HDD activities at the landfall site will begin in advance of April 1, or will not begin until after August
31, to avoid and minimize noise impacts to Piping Plover during the breeding season. (HCA
provisions for the Project are anticipated to restrict work at the landfall site during the summer
months.)
The Centerville River crossing and the onshore duct banks are located outside of mapped habitat.
The Proponent submitted a MESA Checklist pursuant to 321 CMR 10.18 for review in March 2022.
On April 1, 2022, the NHESP issued a MESA Determination that with compliance with the Piping
Plover Protection Plan, the Project will avoid a Take (see Attachment L).
Pursuant to 310 CMR 10.37, the Proponent will submit a copy of this NOI to the NHESP.
3.2 Craigville Public Beach Landfall Site
Since the Project’s early planning stages, Craigville Public Beach has been regarded as an excellent
cable landfall site because it is stable, located in an area with favorable nearshore water depths,
and has a large, paved parking lot that can accommodate construction staging and operations. It
also has direct inland egress by way of sufficiently wide public streets to the grid interconnection
point at the existing Eversource West Barnstable Substation.
The Craigville Public Beach Landfall Site is located within a 3.5-acre paved parking area associated
with a public beach that is owned and managed by the Town of Barnstable. The landfall site is
located in the central part of the Centerville Harbor bight in an area where the shoreline is
relatively stable. Adjoining land uses include homes along the north side of Craigville Beach Road,
a private beach club (Craigville Beach Club) and associated parking to the west, a private bath
house and parking to the east (owned by the nearby Christian Campground), and some open
space. The area is most heavily used during the summer season. The Craigville Public Beach
Landfall Site has adequate staging area and favorable route options to the proposed substation
site. Representative photographs of the Craigville Public Beach Landfall Site are provided in
Attachment D.
The paved parking lot will be the staging area for HDD, which will accomplish the offshore-to-
onshore transition of the two export cables while avoiding any impacts to the coastal beach or
nearshore areas. HDD is described in greater detail in Section 4.2.1, and HDD engineering plans
are provided in Attachment F.
An area of coastal dune is located just north of the parking lot in the narrow area between the
parking lot and Craigville Beach Road. Observed dune vegetation includes Seaside Goldenrod
(Solidago sempervirens) and American Beach Grass (Ammophila breviligulata). The coastal dune
and other coastal wetland resource areas present at the Craigville Public Beach Landfall Site are
depicted in Figure 7. The detailed duct bank route is shown on the engineering plans in
Attachment E. As described in Section 5.3.2, approximately 585 square feet of the Coastal Dune
5526.10/New England Wind 1 Connector 15 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
will be temporarily disturbed during installation of the proposed duct bank between the paved
parking lot and Craigville Beach Road, although the dune will be restored according to the dune
restoration plan provided as Attachment I.
3.3 Onshore Transmission Route
The onshore transmission route begins just inland from the Craigville Public Beach Landfall Site
(described in Section 3.2). Wetland resources along the onshore duct bank route are described
in Section 3.3.1, and the Centerville River crossing is specifically described in Section 3.3.2.
3.3.1 Wetlands along the Duct Bank Route
The onshore duct bank route will temporarily disturb coastal wetland resource areas in the vicinity
of the Craigville Public Beach Landfall Site (see Figures 7 and 8). In this area, the Project will pass
beneath approximately 0.2 miles (1,100 linear feet) of a barrier beach system located between
Nantucket Sound and the Centerville River estuary which includes roadways, residential
properties, and parking lots. Within the barrier beach system, installation of the buried duct bank
will occur almost entirely within the paved surfaces of Craigville Beach Road and the paved
parking lot at the landfall site. The only unpaved areas to be disturbed within the barrier beach
are a narrow strip of remnant Coastal Dune located between the paved parking lot and Craigville
Beach Road and a previously developed residential property at 2 Short Beach Road, which will be
used for staging a trenchless crossing of the Centerville River (see Section 3.3.2 for additional
information about the Centerville River crossing).
The duct bank route will also cross approximately 0.4 miles (2,000 linear feet) of LSCSF in the
vicinity of the landfall site. This includes the portion of the Project located within the barrier
beach system as well as segments inland of the Centerville River estuary. Within LSCSF, duct bank
installation will take place in previously altered areas, and the Project will have no permanent
impacts to this resource since the underground duct bank will not alter existing topography or
flood storage capacity.
Approximately 0.1 miles (730 linear feet) of Riverfront Area (RFA) will be crossed in the vicinity of
the Centerville River. As described above, work within RFA will be limited to previously developed
and degraded areas including the roadbed of Craigville Beach Road and the residential property
located at 2 Short Beach Road. No naturally vegetated areas of RFA will be altered either
permanently or temporarily by the proposed duct bank installation beneath the Centerville River.
Other wetland resource areas are also present at the Centerville River, which ebbs and flows with
each tidal cycle. These include Land Containing Shellfish, Land Under the Ocean, areas of Salt
Marsh along the toe of the riprap embankments that flank the north and south bridge approaches,
as well as Coastal Bank represented by the embankments and bridge abutments. The upper
boundary of the salt marsh was delineated by Epsilon scientists on May 28 and June 15, 2020.
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
North of the Centerville River crossing, the onshore duct bank will be installed within existing
roadway layouts (beneath pavement or within 10 feet of pavement) where direct impacts to
wetland resource areas will be avoided. However, one segment along Shootflying Hill Road will
pass within the state or locally jurisdictional 100-foot buffer zone of freshwater wetland resource
areas including Land Under Water, Inland Bank, and Beach associated with Wequaquet Lake (see
Figure 8). As elsewhere, the duct bank will be installed within the existing roadway layout beneath
pavement or within 10 feet of pavement and will have no permanent impacts on the wetland
resource areas.
A detailed multi-sheet graphics set illustrating wetlands along the Preferred Route is provided as
Figure 8.
Although the Proponent anticipates utilizing the preferred route as described above, at this time
there is a possibility that Variant 2 of the preferred route could be utilized instead. This variant is
shown on Figure 8. It passes through the same wetland resource areas as the preferred route and
also the 100-foot buffer zones of freshwater wetlands located further inland. As shown on Figure
8, this variant will pass through an additional approximately 300 feet of LSCSF and 400 linear feet
of RFA associated with a culverted stream along South Main Street near the Weaver Road
intersection. The duct bank in these areas will be installed within the roadway layout beneath
pavement or within 10 feet of pavement and will not result in any direct impacts to the resource
areas. Variant 2 will also pass through the 100-foot buffer zone of wetlands located on either side
of the paved roadway in this same area, but appropriate erosion and sedimentation controls will
avoid any impacts to these resources.
3.3.2 Centerville River Crossing
The onshore transmission route will cross the Centerville River approximately a quarter mile north
of the landfall site, where Craigville Beach Road crosses the river with an existing two-lane bridge.
Near the Craigville Beach Road bridge, the river is approximately 260 feet wide, although it is
significantly constricted by rip-rapped approaches and abutments on either side of the bridge,
which has a clear span of only 75 feet (23 m). A fringe of salt marsh occurs along the riverbanks
on either side of road, and a 200-foot-wide Riverfront Area extends from each riverbank. The
bridge, reconstructed in 2002, is a fixed-span structure and its relatively low profile allows for the
passage of only small boats. This low profile also means the existing bridge deck lies within the
100-year floodplain. The bridge deck is approximately 50 feet (15 m) wide and accommodates
two lanes of traffic, with two sidewalks and a separate fishing platform on its south side.
The existing bridge deck cannot support the additional weight of the cables and it is not feasible
to maintain existing hydraulic clearance beneath the bridge with the addition of cables, which
would be installed under the bridge. For those reasons the Project is not proposed within the
existing bridge deck or attached to the structure to maintain reliability and avoid potential risk
during storm conditions. While determining the most appropriate method for crossing the
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Centerville River in this location, Project engineers assessed the viability of multiple design
options, including replacement of the bridge superstructure, trenchless techniques (microtunnel,
HDD, and direct pipe), and construction of a new utility bridge parallel to the existing bridge.
The Proponent also discussed options for the Centerville River crossing with the Town of
Barnstable and the Massachusetts Department of Transportation (MassDOT). Based on those
consultations and engineering considerations, microtunnel has been selected as the proposed
crossing technique. Microtunnel is a trenchless crossing technique that will avoid any impacts to
the river itself and will leave the existing bridge unchanged, as opposed to installation of a new
independent utility bridge or replacement of the existing bridge. Wetlands impacts associated
with the microtunnel are described below and are summarized in Table 3-1.
Table 3-1 Temporary Wetland Resource Area Impacts for Centerville River Crossing Microtunnel
(square feet)
Crossing Technique Temporary Impacts
Barrier
Beach
Land Under
the Ocean
Salt Marsh Riverfront
Area
Coastal
Beach
Microtunnel 9,400 0 0 9,400 0
Microtunnel is a pipe jacking operation that utilizes a microtunnel boring machine (MTBM)
pushed into the earth by hydraulic jacks in preparation for insertion of a concrete casing (as
opposed to HDD, which drills a curved trajectory through which a conduit is subsequently
installed) (see Section 4.2.2.2 for a more detailed discussion of microtunnel construction). All
activities would be outside the river and riverbanks themselves but would temporarily affect
approximately 9,400 square feet of the 200-foot RFA and barrier beach associated with
equipment set up and staging; microtunnel would have no permanent impacts to either resource
area. The work would also be located within LSCSF and within the regulatory buffer zone of salt
marsh and land under the ocean, but again the activity would have no permanent impacts. The
microtunnel operation is depicted on Figure 9 and in the engineering plans in Attachment H. This
trenchless construction method will avoid impacts to other wetland resource areas located
adjacent to the Centerville River including Salt Marsh, Land Under the Ocean, Land Containing
Shellfish, and Coastal Bank. Each of these resource areas are shown on Figure 7.
4.0 Proposed Construction Activities and Impacts
4.1 Offshore Cable Installation
This section describes the methods of cable installation that could be used to install the two
proposed offshore export cables within the OECC in Barnstable waters. It also includes a
description of the anticipated impacts from cable installation and associated activities (e.g., vessel
anchoring).
5526.10/New England Wind 1 Connector 18 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
4.1.1 General Offshore Installation Methods
The entirety of the two offshore export cables, including the length within Barnstable waters, will
have a target burial depth of 5 to 8 feet (1.5 to 2.5 meters) below stable seabed, which Project
engineers have determined is more than twice the burial depth that is required to protect the
cables from potential anchor strikes or fishing activities. Several possible techniques may be used
during cable installation to achieve the target depth (see description below). Generally, jetting
methods are better suited to sands or soft clays, whereas a mechanical plow or mechanical
trenching tool is better suited to stiffer soil conditions but is also effective in a wider range of soil
conditions. While the actual offshore export cable installation method(s) will be determined by
the cable installer based on site-specific environmental conditions and the goal of selecting the
most appropriate tool for achieving adequate burial depth, the Proponent will prioritize the least
environmentally impactful cable installation alternative(s) that is/are practicable for each
segment of cable installation.
The majority of the export cables are expected to be installed using simultaneous lay-and-bury
via jetting techniques (e.g., jet-plow or jet trenching) or mechanical plow. However, the various
installation methods identified below are retained as options to maximize the likelihood of
achieving sufficient burial depth while minimizing the need for possible cable protection measures
and accommodating varying weather conditions. The two most common methods are described
below under “Typical Techniques.” Additional techniques that may be used more rarely are
described below under “Additional Possible Specialty Techniques.” These specialty methods may
be needed in areas of coarser or more consolidated sediment, rocky bottom, or other difficult
conditions to ensure adequate burial depth is achieved (though it is worth noting that the OECC
alignment avoids and minimizes passage through areas of hard bottom to the extent feasible).
Typical Techniques
i Jetting techniques (e.g., jet-plow or jet-trencher): Based around a seabed tractor, a sled,
or directly suspended from a vessel, the tool typically has one or two arms that extend
into the seabed (or alternatively a plow share that runs through the seabed) equipped
with nozzles which direct pressurized seawater into the seafloor. As the tool moves along
the installation route, the pressurized seawater fluidizes the sediment allowing the cable
to sink under its own weight to the appropriate depth or be lowered to depth by the tool.
Once the arm or share moves on, fluidized sediment will naturally settle out of
suspension, backfilling the narrow trench. Depending on the actual jet-plow equipment
used, the width of the fluidized trench could vary between 1.3 and 3.3 feet (0.4 – 1 m).
While jet-plowing will fluidize a narrow swath of sediment, it is not expected to result in
significant side cast of materials from the trench. Offshore cable installation will result in
some temporary elevated turbidity, but this is expected to remain relatively close to the
installation activities (see Section 4.1.3 for a discussion of sediment dispersion modeling).
5526.10/New England Wind 1 Connector 19 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
i Mechanical plowing: A mechanical plow is pulled by a vessel or barge and uses a cutting
edge(s) and moldboard, possibly with water jet assistance, to penetrate the seabed while
feeding the cable into the trench created by the plow. While the plow share itself would
likely be only approximately 1.6 feet (0.5 m) wide, a 3.3-foot (1-m) wide disturbance area
is also conservatively assumed for this tool. The narrow trench will infill behind the tool,
either by slumping of the trench walls or by natural infill, usually over a relatively short
period of time.
Other Possible Specialty Techniques
i Mechanical trenching: Typically used only in more resistant sediments, a rotating chain
or wheel with cutting teeth or blades cuts a trench into the seabed. The cable is laid
behind the trencher and the trench collapses and backfills naturally over a period of time.
i Shallow-water cable installation vehicle: While any of the above typical techniques could
be used in shallow water, the Project envelope also includes specialty shallow-water tools
if needed. This system would use either of the Typical Techniques described above but is
deployed from a vehicle that operates in shallow water where larger cable-laying vessels
cannot efficiently operate. The cable is first laid on the seabed, and then a vehicle passes
over or alongside the cable while operating an appropriate burial tool to complete
installation. The vehicle is controlled and powered from a shallower-draft vessel that
holds equipment and operators above the waterline.
i Pre-pass jetting: Prior to cable installation, a pre-pass jetting run using a jet-plow or jet
trencher may be conducted along targeted sections of the cable route with stiff or hard
sediments. A pre-pass jetting run is an initial pass along the cable route by the cable
installation tool that loosens the sediments without installing the cable. The pre-pass
jetting run maximizes the likelihood of achieving sufficient burial during the subsequent
pass by the cable installation tool when the cable is installed. Impacts from the pre-pass
jetting run are largely equivalent to cable installation impacts from jetting described
under “Typical Techniques” above.
i Pre-trenching: A trench is excavated by a plow or other device, and the sediment is placed
next to the trench. The cable is then laid in the trench. Separately or simultaneous to
laying the cable, the sediment is returned to the trench to cover the cable. It is unlikely
that the Project will use a pre-trench method, as site conditions are not suitable since
sand would simply fall back into the trench before the cable-laying could be completed.
Pre-trenching is typically used in areas of very stiff clays, where a displacement plow is
used to create a wide trench within the seabed into which the cable is laid.
5526.10/New England Wind 1 Connector 20 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
i Pre-lay plow: In limited areas of resistant sediments or high concentrations of boulders,
a larger tool may be necessary to achieve cable burial. One option is a robust mechanical
plow that would push boulders aside while cutting a trench into the seabed for
subsequent cable burial and trench backfill. Similar to pre-trenching, if this tool is needed
it would only be used in limited areas to achieve sufficient cable burial.
i Boulder relocation: Any boulders identified along the cable alignments will need to be
relocated prior to cable installation, facilitating installation without any obstructions to
the burial tool and better ensuring sufficient burial. Boulder relocation is accomplished
either by means of a grab tool suspended from a crane onboard a vessel that lifts
individual boulders clear of the route, or by using a plow-like tool which is towed along
the route to push boulders aside. Boulders will be shifted perpendicular to the cable
route; no boulders will be removed from the area.
i Precision installation: In situations where a large tool is not able to operate, or where
another specialized installation tool cannot complete installation, a diver, or Remotely
Operated Vehicle (ROV) may be used to complete installation. The diver or ROV may use
small jets and other small tools to complete installation.
i Jetting by controlled flow excavation: Jetting by controlled flow excavation uses a
pressurized stream of water to push sediments to the side. The controlled flow
excavation tool draws in seawater from the sides and then jets this water out from a
vertical down pipe at a specified pressure and volume. The down pipe is positioned over
the cable alignment, enabling the stream of water to fluidize the sediment around the
cable, which allows the cable to settle into the trench. This process causes the top layer
of sediments to be side cast to either side of the trench. This method will not be used as
the conventional burial method for the offshore export cables, but may be used in limited
locations, such as to bury splice joints or to bury the cable deeper and minimize the need
for cable protection where initial burial of a section of cable does not achieve sufficient
depth. Typically, a number of passes are required to lower the cable to the minimum
sufficient burial depth, resulting in a wider disturbance than use of a jet-plow or
mechanical plow. Jetting is not to be confused with a jet-plow or jet trencher used for
typical cable installation described above. Jetting can also be used for dredging small
sand waves.
Cable burial will temporarily displace marine sediments, but in normal operations these displaced
sediments return to the ocean floor in the wake of the cable installation vehicle generally within
a few meters of the furrow created by the cable installation. Particle sediment monitoring studies
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
recently completed for the Block Island Wind Farm’s offshore cable installation found that
displaced sediments were an average of 12.5 feet (3.8 m) from the trench with a thickness of 2.8
inches (7 cm).3
For any of the offshore export cable installation methodologies described above, the trench would
be expected to backfill naturally after passage of the installation tool since surveys have identified
only granular material (not clays) along the OECC. Where cobbles are present on the seafloor,
they are mixed with granular material (e.g., sand), and therefore even though cobbles may be
present, the sediment is expected to behave as a frictional material, resulting in natural backfilling
of the trench. Given the high-energy marine environment along the OECC, this trench backfilling
is likely to occur in a short period of time; this process was most recently evidenced in the
Martha’s Vineyard Hybrid Cable Project installed from Falmouth to Tisbury (on Martha’s Vineyard)
over an approximately seven-month period in 2013-2014.
In accordance with normal industry practice, a pre-lay grapnel run will be made to locate and clear
obstructions such as abandoned fishing gear and other marine debris in advance of cable
installation. Operations for the pre-lay grapnel run will consist of a vessel towing equipment that
will hook and recover obstructions such as fishing gear, ropes, and other debris from the seafloor.
The Proponent estimates this activity will begin any time up to two months prior to cable
installation. Any abandoned fishing gear recovered will be disposed of or returned to its owner
in accordance with requirements of the Massachusetts DMF and other relevant Massachusetts
regulations.
The proposed offshore cables will be deployed from a turntable mechanism aboard a cable ship
or cable barge and installed along a surveyed alignment. This alignment will be within the OECC
to enable the avoidance or minimization of impacts. For the integrity of the cable, installation is
ideally performed as a continuous action along the entire cable alignment up to splice joints. The
route engineering process is extensive to avoid and minimize impacts to areas of hard bottom and
complex bottom, for example, and to maximize the likelihood of successful cable burial. While a
straight-line route is, under ideal circumstances, the most efficient, this route engineering process
includes micro-siting around features such as boulders or other obstacles. The pre-lay survey will
be the final opportunity to make any additional micro-siting alterations to the intended cable
alignment before installation, and as such is the final step of major route planning. Because the
cable alignment is the product of careful route engineering and the length of available cable is
finite, real-time micro-siting during cable installation is limited. Such micro-siting would only
occur if a significant challenge arose such as an unforeseen obstacle. The specific, as-built cable
alignment will be recorded by the cable installation contractor during installation to record the
precise location (x and y) of each offshore export cable as well as the achieved burial depth (z).
3 James Elliott, K. Smith, D.R. Gallien, and A. Khan. 2017. Observing Cable Laying and Particle Settlement During
the Construction of the Block Island Wind Farm. Final Report to the U.S. Department of the Interior, Bureau of
Ocean Energy Management, Office of Renewable Energy Programs. OCS Study BOEM 2017-027. 225 pp.
5526.10/New England Wind 1 Connector 22 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Cable burial tools (e.g., jet-plow, mechanical plow) can be mounted on a sled pulled by the cable-
laying vessel or can also be mounted on a self-propelled underwater tracked vehicle. The tracked
vehicle would run along the seafloor using a power feed from the cable-laying vessel. This type
of vehicle is routinely used for wind energy cable projects in Europe and has proven effective in
dynamic marine environments similar to the proposed Project route.
Typical cable installation speeds are expected to range from 100 to 200 meters per hour, and it is
expected that installation activities for the offshore export cables will occur 24 hours per day. It
is anticipated that installation activities for the offshore export cables will require continuous
construction once begun. During installation, the cable will be deployed from a turntable on the
installation vessel or barge and buried beneath the seafloor. For the integrity of the cable, this
activity is ideally performed as a continuous action along the entire cable alignment up to splice
joints.
Although the Proponent is considering the use of dynamic positioning (DP) vessels, many portions
of the OECC are too shallow for DP cable-laying vessels. As a result, anchored cable-laying vessels
are assumed to be necessary along the entire length of the OECC, as discussed in Section 4.1.2.2.
However, the Proponent will use DP vessels to the maximum extent practicable to minimize actual
impacts from anchoring during construction.
The Proponent’s preferred installation approach is to install the offshore export cables
sequentially. Given that installation of both cables at the same time would require two separate
vessel spreads, at considerable expense and with additional logistical challenges, it is unlikely that
both cables would be installed at the same time.
The proposed offshore export cables will be installed within largely the same OECC as Vineyard
Wind Connector’s offshore export cables. The cables will typically be separated by a distance of
approximately 165 to 330 feet (50 to 100 m) to provide appropriate flexibility for routing and
installation and to allow room for maintenance or repairs. This separation distance could be
further adjusted, pending ongoing routing evaluation, to account for local conditions such as
deeper waters, micro-siting for sensitive habitat areas, or other environmental or technical
reasons. Spacing will be adequate to minimize the risk of damaging previously installed cable
(e.g., the first cable of the pair) while providing sufficient space for future maintenance and repair
activities, should they be necessary.
4.1.2 Anticipated Offshore Project Impacts
Table 4-1 provides the most current estimates for seabed impacts associated with the installation
of the two proposed offshore export cables in Barnstable waters. As described in Section 3.1,
results from multiple seasons of marine surveys have enabled the Proponent to refine the
mapping of hard bottom, complex bottom, and eelgrass within the OECC, and the Proponent’s
engineers have defined preliminary cable alignments within the OECC to avoid and minimize
impacts to hard bottom and complex bottom (the Project will not impact eelgrass or core habitat
of the North Atlantic Right Whale).
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Table 4-1 Impacts to Land Under the Ocean from Installation of Two Offshore Export Cables
within Barnstable Waters
Offshore Export Cable Corridor Characteristics
Total Length (statute miles)1 13.2
(2 cables along 6.8 miles of the OECC, minus
~0.2-mile HDD for each cable)
Trench impact zone (acres)2 5.3
Disturbance zone from tool skids/tracks (acres)3 16.0
Direct dredging impacts (acres)4 10.8
Anchoring (acres)5 3.7
Cable Protection (acres)6 0.2-0.6
Nearshore Grounding (acres)7 4.8
1 Route lengths provided in statute miles, with 1 mile = 0.87 nautical miles. This length is based on the length of OECC within
Barnstable waters.
2 Based on information from the Proponent’s engineers, depending on the tool used for cable installation (e.g., jet-plow,
mechanical plow, etc.), the direct trenching impact area will vary between 1.3 and 3.3 feet (0.4 – 1 m) in width. The impact
area provided in the table reflects the most conservative 3.3-foot (1-m) impact width.
3 Depending on the tool used for cable installation (e.g., jet-plow, mechanical plow), each skid/track on the installation tool
will have the potential to cause minor disturbance along an area approximately 5 feet (1.5 m) wide, although the functional
impact is expected to be minor. The impact area identified in the table reflects the temporary impact from two skids/tracks,
and therefore assumes a 10-foot-wide (3-m-wide) disturbance zone.
4 Direct dredging impacts are calculated based on the estimated length of dredging and assumed sideslopes of approximately
1:3. Since the dredging area will overlap with the 3.3-foot (1-m) wide trench impact zone and 10-foot (3-m) wide skid
disturbance zone, these areas have been subtracted from the dredging impact area to avoid double-counting impacts. See
Section 4.1.2.4 for more details.
5 See Section 4.1.2.2.
6 Although the Proponent’s priority is to achieve sufficient burial depth and avoid cable protection, some cable protection
may be required. The estimated length of cable protection in Barnstable waters is approximately 0.16 miles (0.26 km).
The area of potential impact from cable protection is provided as a range, since the impact width may vary between 10
feet (3 m) and 30 feet (9 m) depending on the method utilized (see Section 4.1.2.3).
7 See Section 4.1.2.2.
Anticipated impacts associated with specific operations required to complete the offshore export
cable installations in Barnstable waters are discussed in the following sections.
For all portions of the OECC, recolonization and recovery to pre-construction species assemblages
is expected given the similarity of nearby habitat and species. Nearby, unimpacted seafloor will
likely act as refuge area and supply a brood stock of species, which will begin recolonizing
disturbed areas post-construction. Recovery timeframes and rates in a specific area depend on
disturbance, sediment type, local hydrodynamics, and nearby species virility.4 Previous research
conducted on benthic community recovery after disturbance found that recovery to pre-
4 Dernie, K. M., Kaiser, M. J., & Warwick, R. M. (2003). Recovery rates of benthic communities following physical
disturbance. Journal of Animal Ecology, 72 (6),1043-1056.
5526.10/New England Wind 1 Connector 24 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
construction biomass and diversity values took two to four years.5 Other studies have observed
differences in recovery rates based on sediment type, with sandy areas recovering more quickly
(within 100 days of disturbance) than muddy/sand areas.6
4.1.2.1 Cable Installation Tool
Offshore export cable installation tools are described in detail in Section 4.1.1. A variety of tools
may be used for portions of the OECC, many of which are specialized and would be used only in
limited areas where specific conditions are encountered. Typical techniques include jetting
techniques (e.g., jet-plow or jet trenching) or a mechanical plow, either of which would have a
temporary trench disturbance up to approximately 3.3 feet (1 m) wide. In addition to the trench
impact on the seafloor, the cable installation tool may move along the seafloor on skids or tracks.
These skids or tracks, each up to approximately 5 feet (1.5 m) wide, will slide over the surface of
the seafloor, and as such have the potential to disturb benthic habitat; however, they are not
expected to dig into the seabed, and therefore the impact is expected to be minor. Since the
cable installation will affect a corridor that will pass similar habitats on adjacent sides, the area
affected by cable burial or skids/tracks on the installation tool is expected to recolonize relatively
quickly.
As described in Section 4.1.3, while cable installation activities will result in some temporary
elevated turbidity and localized sediment dispersion in the water column, the sediment, which is
briefly fluidized by the cable installation tool, will quickly settle out of the water column.
A BOEM study published in March 2017 assessed impacts from cable-laying activities associated
with construction of the Block Island Wind Farm.7 That study identified formation of a temporary
2.7-inch-high “overspill levee” on either side of the cable placement. The overspill levee consisted
of material deposited outside of the trench during jet-plow activities. The BOEM study indicated
that overspill levees were observed an average distance of 12.5 feet (3.8 m) from the centerline
of the trench (for an average total impact width of 25 feet) at an average thickness of 2.7 inches
(7 cm). Importantly, the study described the overspill levees as very temporary features that were
only apparent for a few days following cable installation, and that they were gone within one to
two weeks. The study authors noted:
5 Van Dalfsen, J. A., & Essink, K. (2001). Benthic community response to sand dredging and shoreface nourishment
in Dutch coastal waters. Senckenbergiana marit, 31(2),329-32.
6 (1) Freiwald, A., Fosså, J.H., Grehan, A., Koslow, T., Roberts, J.M. (2004). Cold-water Coral Reefs. UNEP-WCMC,
Cambridge, UK; and (2) Rogers, A. (2004). The biology, ecology and vulnerability of deep-water coral reefs.
International Union for Conservation of Nature and Natural Resources. 10 pp.
7 James Elliott, K. Smith, D.R. Gallien, and A. Khan. 2017. Observing Cable Laying and Particle Settlement during
the Construction of the Block Island Wind Farm. Final Report to the U.S. Department of the Interior, Bureau of
Ocean Energy Management, Office of Renewable Energy Programs. OCS Study BOEM 2017-027. 225 pp.
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
We attribute the ability to discern the overspill levees to surveying during jet-trenching and
within a few days after the jet-trenching occurred from the mainland cable lay… We have
noted that on post-lay surveys conducted 1 to 2 weeks after trenching, that overspill levees
are rarely distinguishable.8
Given the dynamic marine environment, the Proponent anticipates that the trench area,
regardless of which cable installation method is used, will be quickly reworked by currents,
refilling possible low portions of the trench as quickly as they would remove any potential
“overspill levees”. The Proponent is committed to developing an appropriate benthic habitat
monitoring plan (BHMP) for the Project in consultation with state and federal agencies. In
October 2021, the Proponent consulted with agency representatives from CZM, MassDEP, and
DMF to specifically discuss a framework for benthic habitat monitoring of the cables proposed for
NE Wind 1 Connector/Park City Wind; the framework was presented in Section 2.1.4 of the FEIR.
The Proponent will continue to work cooperatively with state and federal agencies during
permitting to develop a final plan intended to document habitat and benthic community
disturbance and recovery following construction. The Proponent anticipates this plan will be
memorialized in the Section 401 Water Quality Certification (WQC) to be issued by MassDEP.
The Proponent will prioritize the least environmentally impactful cable installation alternative(s)
that is/are practicable for each segment of cable installation. In addition to selecting an
appropriate tool for the site conditions, the Proponent will work to minimize the likelihood of
insufficient cable burial. For example, if the target burial depth is not being achieved, operational
modifications may be required. Subsequent attempts with a different tool (such as controlled
flow excavation) may be required where engineering analysis indicates subsequent attempts may
help achieve sufficient burial.
4.1.2.2 Anchoring
In certain locations, the Proponent is assessing the potential use of Dynamic Positioning (DP)
vessels, but many portions of the OECC are too shallow for DP cable-laying vessels. Because of
the shallow waters in Barnstable, conservatively, anchored cable-laying vessels are expected to
be used along the entire length of the OECC in Barnstable waters. Anchored vessels will avoid
sensitive seafloor habitats to the greatest extent practicable. Contractors will be provided with a
map of sensitive habitats prior to construction with areas to avoid and shall plan their mooring
positions accordingly. Vessel anchors will be required to avoid known eelgrass beds and will avoid
other sensitive seafloor habitats and SSU areas (e.g., hard, or complex bottom) as long as it does
not compromise the vessel’s safety or the cable installation. Where it is considered impossible or
impracticable to avoid a sensitive seafloor habitat when anchoring, use of mid-line anchor buoys
will be considered, where feasible and considered safe, as a potential measure to reduce and
8 James Elliott, K. Smith, D.R. Gallien, and A. Khan. 2017. Observing Cable Laying and Particle Settlement during
the Construction of the Block Island Wind Farm. Final Report to the U.S. Department of the Interior, Bureau of
Ocean Energy Management, Office of Renewable Energy Programs. OCS Study BOEM 2017-027. p.46.
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
minimize potential impacts from anchor line sweep. Mid-line buoys are placed somewhere along
the length of an anchor line to support the weight of the line and hold a portion of the line off the
seabed. By suspending the anchor lines, mid-line buoys prevent the line from dragging and
scouring the seafloor, which minimizes anchor sweep and associated impacts. Vessel operators
will determine when the use of mid-line anchor buoys is considered infeasible and/or unsafe.
The discussion below presents a conservative estimate of potential anchoring impacts in
Barnstable.
Project engineers estimate approximately 323 square feet (30 m2) of disturbance from each
anchor (assuming an approximately 10-ton anchor), such that a vessel equipped with nine anchors
would disturb approximately 2,900 square feet (270 m2) per each anchoring set.9 A nine-point
anchor spread provides greater force on the cable burial tool than a spread with fewer anchors,
enabling greater burial depth, and the assumptions herein include a larger anchor to
accommodate larger installation vessels. In addition, anchored vessels may deploy up to two spud
legs at each anchoring location to secure the cable-laying vessel while its anchors are being
repositioned. Each deployment of two spuds would affect approximately 108 square feet (10 m2)
of seafloor, making the total disturbance per anchoring set approximately 3,008 square feet (280
m2). Potential impacts from anchoring are summarized in Table 4-1, and the calculation of
impacts from anchoring is shown in Table 4-2. Anchoring will not be performed in eelgrass.
Table 4-2 Estimated Anchoring Impacts from Installation of 2 Offshore Export Cables in Barnstable
Waters.
Impact from Anchoring
Length in Barnstable waters (miles) 13.2 (both cables combined minus HDD length)
Disturbance per anchoring set 3,008 sf
# of repositioned anchoring sets* 53
Total temporary impact 3.7 acres
* Assumes an anchored installation vessel may need to reposition every approximately 1,312 feet (400 m).
In addition to the anchoring impacts presented in Table 4-2, to install the cable close to shore
using tools that are best optimized to achieve sufficient cable burial, the cable laying vessel may
temporarily ground nearshore, impacting an area of up to 2.4 acres (9,750 m2) per cable (4.8 acres
total). These temporary potential impacts are included in Table 4-1. Any anchoring, spud leg
deployment, or grounding will occur within surveyed area of the OECC.
9 The impacts from anchor sweep are not quantified at this time due to the difficulty of estimating potential
anchoring practices at this planning stage.
5526.10/New England Wind 1 Connector 27 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
4.1.2.3 Cable Protection
The Proponent’s priority will be to achieve adequate burial depth of the two offshore export
cables and to avoid the need for any cable protection. However, it is possible that achieving
adequate burial depth may be unsuccessful in areas where the seafloor is composed of
consolidated materials, making complete avoidance of cable protection measures unlikely. In the
event sufficient burial depth cannot be achieved, alternative cable protection methods may be
necessary. The Proponent will seek to avoid and/or minimize the use of such cable protections,
and cable protection will only be used where necessary, thus minimizing potential impacts.
Except for limited areas where the sufficient cable burial is not achieved and placement of cable
protection on the seafloor is required, offshore export cables are not anticipated to interfere with
any typical fishing practices. Should cable protection be required, it will be designed to minimize
impacts to fishing gear to the extent feasible, and fishermen will be informed of the areas where
protection is used. Any type of cable protection has the potential to snag fishing gear, but such
protection is designed to minimize the risk of such snagging.
If needed, the methods for cable protection will be:
i Rock placement: Rocks could be laid on top of the cable to provide protection. If rocks
were to be placed, they would be installed in a controlled and accurate manner on the
seafloor using a dynamic positioning fall-type vessel. Rocks used for cable protection
would be sized for site-specific conditions; where feasible, this protection will consist of
rocks approximately 2.5 inches (6.4 cm) in diameter or larger.10 The target range in rock
sizes used in this type of cable protection is typically between approximately 2 and 6
inches (50-150 mm) in diameter.
i Gabion rock bags: This method involves rocks encased in a net material (e.g., a polyester
net) that can be accurately deployed on top of the cable and subsequently recovered, if
necessary, for temporary or permanent cable protection. Each bag is equipped with a
single lifting point to enable its accurate and efficient deployment and recovery. These
rock bags have been deployed in other high-energy marine environments such as the
North Sea, and the net material used for the rock bags is designed to have an
approximately 50-year lifespan. These bags typically contain gravel approximately 0.8
inches (20 mm) in diameter, since this allows the bag to somewhat conform to the shape
of the exposed cable.
i Concrete mattresses: These “mattresses” are prefabricated flexible concrete coverings
consisting of high-strength concrete profiled blocks cast around a mesh material (e.g.,
ultra-violet stabilized polypropylene rope) that holds the blocks together. This mattress
construction provides flexibility, enabling the mattress to settle over the contours of the
10 Some rocks may be fragmented into smaller pieces during handling, transport, and installation.
5526.10/New England Wind 1 Connector 28 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
cable and seafloor. The mesh in this application would be designed to have a decades-
long lifespan. The mattress may also include aerated polyethylene fronds, which will float
(resembling seaweed) and encourage sediments to be deposited on the mattress.
i Half-shell pipes or similar (only for cable crossings or where the cable is laid on the
seafloor): These products are made from composite materials and/or cast iron with
suitable corrosion protection and are fixed around the cable to provide mechanical
protection. Half-shell pipes or similar solutions are not used for remedial cable protection
but could be used at cable crossings or where cable must be laid on the surface of the
seabed. The half-shell pipes do not ensure protection from damage due to fishing trawls
or anchor drags (although they will offer some protection, they will not prevent damage).
Project engineers estimate that approximately 0.16 miles (0.26 km) of cable protection may be
required along both offshore export cable alignments, combined, within Barnstable waters.
Assuming concrete mattresses are used, the Proponent’s engineers have determined that cable
protection of approximately 10 feet (3 m) wide will be sufficient to protect the cable. Should rock
placement be used for cable protection, a greater width of approximately 30 feet (9 m) would be
needed to account for sideslopes.11 If gabion bags are utilized, any width can be installed by using
multi-compartment bags. However, at this time the Proponent’s engineers do not anticipate
needing a width greater than 10 feet using gabion bags (i.e., the same width as the concrete
mattresses) unless perhaps they are utilized temporarily at the seaward end of the HDD conduit
prior to cable pull-back. The impact calculations for cable protection, presented in Table 4-1,
show the range of possible impacts based on the varying widths of cable protection methods.
The Proponent intends to avoid or minimize the need for cable protection to the greatest extent
feasible through careful site assessment and thoughtful selection of the most appropriate cable
installation tool to achieve sufficient burial. Areas requiring cable protection, if any, will be the
only locations where post-installation conditions at the seafloor may permanently differ from
existing conditions; however, such cable protection would only be expected within hard bottom
areas, and the cable protection itself would function as hard bottom.
4.1.2.4 Sand Wave Dredging
As described in Section 3.1, some portions of Nantucket Sound have areas of complex bottom
composed of active sand waves, which have been assessed over multiple seasons of marine
surveys. Sand waves are dynamic features with changing morphology that move across the
11 There are currently no anticipated cable crossings for the proposed Project. Should a cable crossing become
necessary, cable protection of up to 30 feet (9 m) wide may be necessary. In addition, based on the actual
conditions encountered at splice joint locations, cable protection width may vary, but if wider than 9 feet (3 m)
the cable protection at splice joints is expected to fall within total cable protection estimates.
5526.10/New England Wind 1 Connector 29 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
seafloor. As a result, where sand waves are large, it may be necessary to perform pre-cable-laying
dredging to remove the tops of these features along the cable alignment to ensure sufficient
burial within the underlying stable seabed.
The stretch of the OECC where sand wave dredging may be needed is largely coincident with areas
mapped as complex bottom as shown on Figure 3. It is important to note that dredging, if
performed, would not occur along the entire stretch where sand waves may be present; rather,
dredging would only be performed to remove the tops of each sand wave to the extent needed
at the time of construction to ensure sufficient burial within the stable seabed. Dredging will be
performed as close in time to cable installation as possible to avoid mobile sand waves recovering
the dredged area.
Dredging will be limited to only the extent required to achieve adequate cable burial depth during
cable installation. Where dredging is necessary, it is conservatively assumed that the dredged
area will typically be approximately 50 feet (15 m) wide at the bottom (to allow for equipment
maneuverability) with approximately 1:3 sideslopes for each of the two cables. The depth of
dredging will vary with the height of sand waves, and hence the dimensions of the sideslopes will
likewise vary with the depth of dredging and sediment conditions. This dredge corridor includes
the up to 3.3-foot-wide (1-m-wide) cable installation trench and the up to 10-foot-wide (3-m-
wide) temporary disturbance zone from the tracks or skids of the cable installation equipment.
For both offshore export cables combined, the Proponent’s engineers anticipate that the length
of sand wave dredging in Barnstable waters could be approximately 2.0 miles (3.2 km) and the
area impacted by dredging in Barnstable waters could be approximately 10.8 acres (inclusive of
sideslopes but excluding the overlapping impacts from trenching and tool skids). The estimated
volume of dredged material in Barnstable waters is up to approximately 23,800 cubic meters
(31,000 cubic yards). Due to the morphology of the sand wave features, and their mobility across
the seafloor, even small changes in the cable alignments can result in changes to the potential
dredge volumes. Actual dredge volumes will depend on the final cable alignments and cable
installation method; a cable installation method that can achieve a deeper burial depth will
require less dredging. The average dredge depth is expected to be approximately 1.6 feet (0.5 m)
and may range up to a maximum of approximately 17 feet (5.25 m) in localized areas.
With respect to potential habitat impacts, sand wave areas are intrinsically dynamic and unstable,
and while dredging will be avoided and minimized wherever possible, those areas are typically
sub-optimal areas for benthic organisms.
Dredging could be accomplished by several techniques. European offshore wind projects have
typically used a TSHD. A TSHD vessel contains one or more drag arms that extend from the vessel,
rest on the seafloor, and suction up sediments. Dredges of this type are also commonly used in
the U.S. for channel maintenance, beach nourishment, and other uses. For the Project, a TSHD
would be used to remove enough of the top of a sand wave to allow subsequent cable installation
within the stable seabed. Where a TSHD is used, it is anticipated that the TSHD would dredge
5526.10/New England Wind 1 Connector 30 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
along the cable alignment until the hopper is filled to an appropriate capacity, then the TSHD
would sail several hundred meters away and deposit the dredged material within an area of the
surveyed corridor that also contains sand waves (see Figure 3).
A second dredging technique involves jetting by controlled flow excavation. Controlled flow
excavation uses a pressurized stream of water to push sediments to the side. The controlled flow
excavation tool draws in seawater from the sides and then propels the water out from a vertical
downpipe at a specified pressure and volume. The downpipe is positioned over the cable
alignment, enabling the stream of water to fluidize the sediments around the cable, which allows
the cable to settle into the trench. This process causes the top layer of sediments to be side cast
to either side of the trench; therefore, controlled flow excavation would both remove the top of
the sand wave and bury the cable. Typically, a number of passes are required to lower the cable
to the minimum sufficient burial depth.
A TSHD can be used in sand waves of most sizes, whereas the controlled flow excavation
technique is most likely to be used in areas where sand waves are less than 6.6 feet (2 m) high.
Therefore, the sand wave dredging could be accomplished entirely by the TSHD on its own, or the
dredging could be accomplished by a combination of controlled flow excavation and TSHD, where
controlled flow excavation would be used in smaller sand waves and the TSHD would be used to
remove the larger sand waves.
No dredging is proposed in hard-bottom areas (e.g., boulders, cobble bottom). The only dredging
proposed for the Project is where large sand waves, features that can be considered “complex”
due to their bathymetric relief, necessitate pre-cable-laying dredging to ensure that the necessary
burial depth can be achieved. As noted previously, sand waves, although they do provide
bathymetric variability, are seafloor features that change quickly and hence do not enable the
formation of complex benthic communities.
4.1.3 Sediment Dispersion and Turbidity
To gain a thorough understanding of the sediment dispersion resulting from the Project’s cable
installation operations, a Hydrodynamic and Sediment Dispersion Modeling Study was prepared
by RPS and was presented in Section 8.2.1 of the Project’s DEIR, which was provided to the
Barnstable Conservation Commission. The DEIR can also be found at
https://www.parkcitywind.com/permitting. The Proponent requests that the more detailed
information in the MEPA filing be incorporated by reference into this submission. Results of the
study are summarized below:
The modeling was performed to characterize the effects associated with the offshore cable
installation activities. The effects were quantified in terms of the above-ambient total suspended
solids (TSS) concentrations as well as seabed deposition of sediments suspended in the water
column during cable installation activities.
5526.10/New England Wind 1 Connector 31 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
The Hydrodynamic and Sediment Dispersion Modeling Study shows that impacts from cable
installation activities are expected to be localized and short term, as most of the mass settles out
quickly and is not transported for significant distances by the currents. Above-ambient TSS
concentrations stemming from cable installation for the various model scenarios remain relatively
close to the cable alignment, are constrained to the bottom of the water column, and are short-
lived. Above-ambient TSS concentrations substantially dissipate within one to two hours and fully
dissipate in less than four hours for most of the model scenarios. Similarly, for the vertical injector
model scenario, above-ambient TSS concentrations substantially dissipate within one to two
hours but required up to six hours to fully dissipate, likely due to the relatively slower installation
rate and deeper trench (greater volume disturbed per unit length). Above-ambient TSS
concentrations greater than 10 mg/L typically stay within approximately 650 feet (200 m) of the
cable alignment. Importantly, all suspended sediments are expected to settle out within a matter
of hours (less than 4-6) from disturbance during typical cable installation. Simulations of typical
cable installation parameters (without sand wave removal) in the OECC indicated that deposition
of 1 mm (0.04 in) or greater (i.e., the threshold of concern for demersal eggs) was constrained to
within approximately 330 feet (100 m) from the route centerline and maximum deposition was
typically less than 5 mm (0.20 in) (the threshold of concern for shellfish), though there was a small
isolated area associated with the vertical injector model scenario with deposition between 5 to
10 mm (0.2 to 0.4 in).
For context, BOEM stated in the DEIS for the Vineyard Wind project that “suspended sediment
concentrations between 45 and 71 mg/L can occur in Nantucket Sound under natural tidal
conditions, and increases in suspended sediment concentrations due to jet-plow are within the
range of variability already caused by tidal currents, storms, trawling, and vessel propulsion.”12
Further, BOEM concluded that it expects only minor impacts on water quality due to suspended
sediment during installation, dredging, and cable-laying because of the brief duration and small
area of impact.
For all portions of the OECC, recolonization and recovery to pre-construction species assemblages
is expected given the similarity of nearby habitat and species. Nearby, unimpacted seafloor will
likely act as refuge area and supply a brood stock of species, which will begin recolonizing
disturbed areas post-construction. Recovery timeframes and rates in a specific area depend on
disturbance, sediment type, local hydrodynamics, and nearby species virility.13 Previous research
conducted on benthic community recovery after disturbance found that recovery to pre-
12 Vineyard Wind Offshore Wind Energy Project, Draft Environmental Impact Statement, U.S. Department of the
Interior, Bureau of Ocean Energy Management, Office of Renewable Energy Programs, December 2018.
13 Dernie, K. M., Kaiser, M. J., & Warwick, R. M. (2003). Recovery rates of benthic communities following physical
disturbance. Journal of Animal Ecology, 72 (6),1043-1056.
5526.10/New England Wind 1 Connector 32 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
construction biomass and diversity values took two to four years.14 Other studies have observed
differences in recovery rates based on sediment type, with sandy areas recovering more quickly
(within 100 days of disturbance) than muddy/sand areas.15
In summary, results of the Hydrodynamic and Sediment Dispersion Modeling Study demonstrate
that impacts will be short-term, as excess TSS concentrations are expected to only persist for a
few hours and deposition is expected to typically be less than 5 mm, which is less than the
sensitivity threshold for benthic organisms. Conservative impact assumptions show that impacts
on fish and shellfish will be limited in area and duration and will allow for rapid recovery to pre-
installation conditions. The Project will use cable installation techniques that minimize sediment
disturbance and dispersion consistent with the best available practices.
4.2 Onshore Construction
4.2.1 HDD Construction Methodology
HDD is the primary means of minimizing Project-related impacts to the beach, intertidal zone, and
nearshore areas, as well as ensuring that the cables remain sufficiently buried and permanently
out of the human environment at the shoreline. HDD is a trenchless installation technique that
will avoid disturbance to the shoreline and nearshore areas by negating the need to open-
excavate existing coastal wetland resource areas; it will also avoid disturbing recreational use of
the beach. At the landfall site, the proposed HDD would be approximately 1,000 to 1,200 feet
(300-365 meters) long and angled offshore to avoid an area of hard bottom and co-located
eelgrass (see Figure 3). Although the HDD trajectory is still undergoing engineering refinement, it
is estimated that the trajectory will result in the HDD passing at a depth of approximately 40 feet
below the ground surface at MHW. Plan and profile views of the proposed HDD are provided in
the engineering plans in Attachment F, and the HDD construction layout is shown in Figure 10.
HDD would be performed in the off-season using a staging area in the paved Town-owned
Craigville Public Beach parking lot west of the bath house. The entire parking lot east of the bath
house, and a significant portion of the parking lot west of the bath house, would remain available
during construction. The Proponent will work with the Town of Barnstable to ensure that
acceptable access is available to the beach during construction.
14 Van Dalfsen, J. A., & Essink, K. (2001). Benthic community response to sand dredging and shoreface nourishment
in Dutch coastal waters. Senckenbergiana marit, 31(2),329-32.
15 (1) Freiwald, A., Fosså, J.H., Grehan, A., Koslow, T., Roberts, J.M. (2004). Cold-water Coral Reefs. UNEP-WCMC,
Cambridge, UK; and (2) Rogers, A. (2004). The biology, ecology and vulnerability of deep-water coral reefs.
International Union for Conservation of Nature and Natural Resources. 10 pp.
5526.10/New England Wind 1 Connector 33 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
4.2.1.1 HDD Construction Sequence and Schedule
The construction sequence for installation via HDD at the landfall will consist of the following
methods:
1. Entry Pit: Land-based HDD rigs are typically staged behind a shallow entry pit, which for
this Project will measure approximately 10 by 20 feet for each drill path entry point. The
entry pit will provide the contractor with access to the proper trajectory for drilling and
will also serve as a reservoir for drilling fluids (i.e., a slurry consisting predominantly of
water and bentonite, a naturally occurring, inert and non-toxic clay) used to convey soil
cuttings from the borehole.
2. Installation of Temporary Surface Casing: A steel pipe, 54 inches or 60 inches in diameter,
will be installed along the entry tangent of the HDD bore for a distance of approximately
100 feet through the shallow, relatively loose formation. This will provide a stable
corridor for tooling to enter the bore as well as for the drilling fluids and cuttings to be
conveyed to the entry pit reservoir. Upon installation of the HDPE conduit, the surface
casing will be removed.
3. Pilot Hole: A small pilot hole (typically eight to twelve inches in diameter) will be drilled
from the entry pit to a pre-determined location offshore, where the offshore cable
installation will terminate. The pilot hole will be drilled at an entry angle of typically 8 to
18 degrees such that it arcs down beneath the nearshore coastal resources and extends
to a minimum depth of approximately 40-50 feet below the ground surface at MHW. The
path of the pilot hole will follow a tangent trajectory, maintaining a constant depth of
cover beneath the seafloor, before starting to ascend toward the desired exit point on
the seafloor that will be the transition point between the offshore cable installation and
the seaward end of the HDD. Drilling fluid (a bentonite slurry) will be used to stabilize the
borehole, convey soil cuttings out of the bore, cool and lubricate the drill bit, stem, and
other downhole tooling, and will also serve to seal the wall of the borehole.
4. Surfacing of HDD Pilot Hole: After completion of the borehole, the drill rod will be
advanced for a short distance so it can be located by divers. At the HDD exit point, a
temporary receiving pit will be excavated. Given the coarse-grained nature of sediments
at the HDD exit hole location and the small diameter of the pilot hole, little turbidity is
expected as the drill head reaches the seafloor surface. Although not anticipated
(because injection of bentonite fluid will be halted prior to the drilling head reaching the
seafloor), a small amount of bentonite clay could be released at the exit point of the HDD
operation, and the contractor may install silt curtains at the exit point; alternatively,
where the pilot hole exits the seafloor, the contractor may lower a gravity cell that would
capture any incidental bentonite drilling fluid released from the end of the HDD drill.
Bentonite clay is an inert, naturally occurring substance and is appropriate for use in
5526.10/New England Wind 1 Connector 34 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
sensitive environments because it poses minimal environmental risks; for this reason,
bentonite is commonly used for the HDD process. Nevertheless, the contractor will
minimize the amount of bentonite near the exit hole.
5. Reaming and HDPE Conduit Insertion: After the pilot hole has been established, divers will
replace the cutter head on the end of the drill rod with a reamer. Upsizing of the bore
hole can be achieved by forward or reverse reaming of the pilot hole. The reaming head
will enlarge the pilot hole to the necessary diameter, typically 1.5 times the outside
diameter of the conduit, ahead of the pull-back of the HDPE conduit into the underground
bore. The HDPE pipe lengths can be thermally fused and staged offshore. The leading
head of the HDPE conduit is then attached to the pullback assembly, consisting of a
reamer and a swivel, and pulled into the borehole by the HDD rig. Cuttings from the
reaming/pull-back effort will be pumped from the HDD drill pit back to HDD settling tanks,
then passed to a reclaim/cuttings separation tank. Filtered water will be released if it
meets water quality requirements, and waste cuttings solids will be properly and legally
disposed of as solid waste or landfill material.
6. Cable Insertion and Transition: Upon conclusion of the reaming and conduit pullback, the
end of the conduit will remain exposed on the seafloor. If there will be significant time
between conduit installation and cable insertion (e.g., as a result of a time-of-year or
other seasonal restriction), the conduit may be temporarily protected by filling the
receiving pit with concrete mattresses, rock bags, or similar material that can be easily
removed when it is time to insert the cable, after which the seabed will to return to its
pre-installation conditions. The conduit will likely have a messenger wire passing through
it with a cap on each end until the cable is installed. Divers will assist with the messenger
line retrieval/operations and perform cable pull-in monitoring while the offshore cable is
inserted into the installed conduit and pulled through the conduit to the land connection.
The seaward end of the conduit would then be reburied beneath the seafloor, likely using
divers will with hand-jets (i.e., a narrow, high-pressure stream of water) or through other
control flow methods. Thermal grout may be used to fill the interstitial space between
the offshore export cable and the cable conduit to enhance the thermal characteristics of
the cable (i.e., to enhance heat dissipation from the cable). Use of a cap/boot will prevent
grout from entering the marine environment.
7. Disposal of drill cuttings and drill fluids: The HDD installation method will produce a slurry
of two co-mingled byproducts: drill cuttings and excess drill fluids (water and bentonite
clay). During drilling, this slurry will be collected from the reservoir pit and will be
processed through a filter/recycling system where drill cuttings (solids) will be separated
from reusable drill fluids. Non-reusable material consisting of drill cuttings and excess
drill fluids will be trucked to an appropriate disposal site. This material is typically
classified as clean fill, and it is anticipated that will be the case for this Project. The
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
material may have an elevated water content, which could require transport to occur in
sealed trucks. Typical disposal sites for this type of clean fill include gravel pits or farm
fields/pastures.
8. Landward Manholes and Infrastructure: Each offshore cable will be pulled back through
the conduit installed via HDD, from which it will enter one of two proposed transition
vaults or bays, where it will transition to onshore cabling.
9. Site Restoration: The contractor will restore the location of the entry pit to match existing
conditions. Any paved areas that have been disturbed will be properly repaved, per the
Proponent’s HCA with the Town of Barnstable. The temporary receiving pit will be filled
back in with the same material once the offshore export cable has been brought to land,
thereby restoring the ocean bottom to pre-installation conditions.
Throughout HDD operations, the Proponent will ensure shore-side site security, and traffic control
which will be coordinated with Town officials.
As described in Section 3.1.3, the Proponent has assembled a PPPP that proposes the same HDD
schedule as will be utilized for the Vineyard Wind Connector (see Attachment G). This schedule,
which was formulated in consultation with NHESP to avoid and minimize noise impacts to Piping
Plover during the breeding season, will begin HDD activities before April 1 or after August 31. (The
HCA with Barnstable is anticipated to further restrict work in the late summer after August 31,
limiting it to later in the year.)
Representative photographs of the Craigville Public Beach parking lot and adjacent areas are
provided in Attachment C.
Work will be done in the off-season (i.e., not during the busy summer months). Given the nature
of HDD activities, the operation works best if pursued in 12-hour shifts. A summary of the
estimated time requirements for drilling 1,000 to 1,200 feet is shown in Table 4-3 below. In
summary, the duration of two drill paths of approximately 1,000 to 1,200 feet (300 to 365 m) at
the landfall site, including set-up, staging, drilling, and shutdown & demobilization, would be
approximately 16 weeks, depending on the drilling conditions and weather encountered.
Estimated time requirements could be more, or less, depending upon geotechnical inputs, final
engineering design, and associated drilling and construction requirements.
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Table 4-3 Landfall Site HDD Installation Schedule
Time
(in weeks)
Weeks per Drill Path (assumes 12-hours per shift, 6 shifts per week) 6
Expected Number of Drill Paths 2
Total Weeks, on Site Drilling Activity 12
Mobilization/Demobilization/Staging (weeks) 4
Total Estimated Time at HDD Site (weeks) 16
4.2.1.2 Management of Drilling Fluids and HDD Contingency Plan for Seepage
HDD is a well-known and commonly utilized installation technique for this type of project, and
with proper construction management the risk of drilling fluid release is very low. As described
above, it is important to note that the Project will use a drilling fluid composed of bentonite clay
or mud. This benign, naturally occurring material will pose little to no threat to water quality or
ecological resources in the rare instance of seepage around the HDD operations.
The HDD installation method will produce a slurry of two co-mingled byproducts: drill cuttings
and excess drill fluids (bentonite clay or mud). During drilling, this slurry will be collected from
the reservoir pit and will be processed through a recycling system where drill cuttings (solids) will
be separated from reusable drill fluids. Once the drilling fluid cannot be recycled any further, the
non-reusable material consisting of drill cuttings and excess drill fluids will be trucked to an
appropriate disposal site. This material is typically classified as clean fill, and it is anticipated that
will be the case for this Project. The material may have an elevated water content, which could
require transport to occur in sealed trucks. Typical disposal sites for this type of material include
gravel pits or land farmed as upland field or pasture.
Effective construction management contingency plan procedures during HDD operations will
minimize construction-period disturbances for nearby land uses and will also minimize the
already-remote potential for drilling fluid seepage (i.e., frac-out). Drilling fluid seepage can be
caused by pressurization of the drill hole beyond the containment capacity of the overburden soil
material. Providing adequate depth of cover for the HDD installation can substantially reduce this
potential impact and as described above, the Project will use a drilling fluid composed of
bentonite clay or mud that will pose little to no threat to water quality or ecological resources
should seepage occur. Nonetheless, the Proponent will adhere to operational standards to
minimize the chances of drilling fluid seepage.
The trajectory of the HDD installation has been a primary consideration for contingency planning
and prevention of drilling fluid seepage, as well as installation of a temporary surface casing for
the first approximately 100 feet of each HDD trajectory as described in Section 4.2.1.1. The HDD
drill hole will descend from the HDD pit location to a depth of more than 40 feet below the
5526.10/New England Wind 1 Connector 37 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
seafloor before rising toward the exit hole on the seafloor where installation will transition to
cable burial. The geometry of the drill hole profile can also affect the potential for drilling fluid
seepage. In a profile that makes compound or tight-radii turns, down-hole pressures can build,
thus increasing the potential for drilling fluid seepage. The proposed drilling profile, with its
smooth and gradual vertical curves, will avoid this potential effect. In addition, horizontal
curvature of the HDD route has been avoided to minimize the potential for pressure buildup
caused by drill hole geometry.
The drilling crew will be responsible for executing the HDD operation, including actions for
detecting and controlling drilling fluid seepage. The process and actions of the drilling crew will
be closely supervised. HDD is a technically advanced process, and the Proponent will ensure that
the drill crews have the proper training and oversight to minimize the potential for drilling fluid
seepage and to respond to seepage promptly and competently should it occur. Each drilling
situation is unique, in that the behavior of subsurface material is highly variable and can be
difficult to predict. No in-hole monitoring equipment can detect drilling fluid seepage, only
pressure and monitoring of actual drilling fluid volume returns, and therefore a combination of
factors must be properly interpreted to assess conditions that have the potential to cause
seepage.
A seep occurs when the path of least resistance for the pressurized drilling fluid to flow into the
subsurface materials immediately surrounding the down-hole tooling is less than the path along
the borehole. This situation is most common during pilot hole drilling, when the annulus between
the borehole and the drill pipe is the smallest. The most obvious sign of a drilling fluid seepage is
the loss of drilling fluid circulation at the drilling pit. One of the functions of drilling fluid is to seal
the hole to maintain down-hole pressure. The loss of returning drilling fluid is a sign that pressure
is not being maintained in the drill hole and seepage is possibly occurring. If there is a reduction
in the quantity of drilling fluid returning to the drill site (i.e., loss of circulation), this could be a
warning sign. However, some reduction in the volume of returning drilling fluid is also normal
during the drilling process, when a loose sand or gravel layer may be encountered that would
require additional drilling fluids to fill voids in the substrate. Consequently, drilling fluid loss in
and of itself is not an indication of a potential seepage, but rather the loss of drilling fluid in
combination with other factors may indicate a potential seepage. For example, if there is a loss
of drilling fluid and the return cuttings do not show a large quantity of gravel, this could indicate
a loss of containment pressure within the borehole.
Detecting a potential seep prior to it occurring is dependent upon the skill and experience of the
drilling crew. For this reason, the Project will utilize a specially assigned drill crew. The drilling
crew will monitor certain aspects of the drilling operation to detect fluid loss, including but not
necessarily limited to the following:
i Drilling pit returns, where a sudden loss of drilling fluid would indicate that fluid may be
lost to geological materials or a release at the seafloor surface;
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i Down-hole pressure, which will be compared to the calculated confining pressure during
pilot hole drilling;
i Returning drilling fluid volumes and rates, which will be compared to the volumes and
rates of drilling fluid pumped down-hole; and
i Pump pressures and flow rates.
The drill crew will be responsible for immediately notifying the Project Manager if seepage occurs.
The Project Manager will immediately assess the situation and estimate the quantity of drilling
fluid lost and the square footage of area potentially affected. If drilling fluid seepage is detected,
the drilling crew will take immediate corrective action, securing the affected area and
immediately implementing the project mitigation plan as appropriate. The primary factor causing
seepage would be pressure from the drilling fluid pumps, so the most direct corrective action will
be to stop the rig pumps. By stopping the pumps, pressure in the drill hole will quickly dissipate,
and with no pressure in the hole seepage will cease. Pumps will be stopped as soon as seepage
is suspected or detected. In the event of seepage, the Proponent will notify MassDEP.
Corrective actions for conditioning the drill hole should seepage occur differ with specific issues
encountered during a particular HDD operation. Common corrective actions include, but are not
limited to:
i Transitioning the down-hole tooling in a drill hole closer to the entry or exit location to
reestablish drilling fluid returns, and “swabbing” out the drill hole;
i Modifying drilling pressures and/or pumping rates to account for an unanticipated or
changing soil formation;
i Pumping drilling fluid admixtures into the drill hole at the location of seepage to solidify
or gel the soil; and
i Suspending drilling operations for a period of time to allow the drill hole to set up.
4.2.2 Duct Bank Construction and Centerville River Crossing
Duct bank construction is described in Section 4.2.2.1, while the Centerville River crossing is
described in Section 4.2.2.2.
4.2.2.1 Duct Bank Construction and Cable Installation
Installation of the onshore export cables will occur in two stages: the first stage will consist of
installing the concrete duct bank and splice vaults that will house the onshore export cables and
associated infrastructure; the second stage will consist of pulling/installing the export cables
through the duct bank conduits and completing splices and terminations. Construction of the
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onshore cable duct bank system will be performed via open trenching with equipment such as
excavators and backhoes. All work will be performed in accordance with local, state, and federal
safety standards, as well as any Project-specific local requirements.
The duct bank will contain six single-core cables consisting of a copper or aluminum conductor
covered by solid XLPE insulation and separate fiber optic cables. The cables will not contain any
fluids. Each onshore export cable will have its own 8 to 10-inch-diameter PVC or HDPE conduit
within the concrete duct bank. This duct bank, shown in typical cross-section in Figure 11, will be
an array of PVC or HDPE pipes or sleeves encased in concrete. Up to eight conduits spaced
approximately 12 inches apart will be installed within the duct bank to accommodate onshore
conductors and spare conduits, with additional smaller conduits for fiber optic communications
cables; grounding will be accommodated within the duct bank trench.
For the majority of the onshore route, these conduits will be arrayed four conduits wide by two
conduits deep, with the total duct bank measuring approximately 5 feet (1.5 m) wide and 2.5 feet
(0.8 m) deep. To accommodate this 4x2 duct bank array, the top of the trench will be
approximately 9 to 11 feet wide. A more upright design arrayed two conduits wide and four
conduits deep is also possible, which would measure approximately 2.5 feet (0.8 m) wide and 5
feet (1.5 m) deep (see Table 4-4). Depending on the configuration of existing subsurface utilities,
this duct bank arrangement could be modified along short stretches to enable deeper burial depth
to respect utility separation requirements.
Table 4-4 Summary of Duct Bank and Trench Dimensions (feet)
Duct Bank Trench
Conduit
Layout Width Depth Depth Width at
Bottom
Width at Top
(0.3 side slope)
Width at Top
(0.5 side slope)
4x2
(flat)
5 2.5 5.5 5.5 8.8 11
2x4
(upright)
2.5 5 8 3 7.8 11
The target depth of cover in all cases will be at least three feet, although if required in some
instances (e.g., at certain utility crossings) the minimum cover will be 2.5 feet.
In locations where splicing is necessary, which is likely to occur in only one or two locations within
Barnstable Conservation Commission jurisdiction (see duct bank engineering plans in Attachment
E), the excavated area will be approximately 20 feet wide by 50 feet long to accommodate a splice
vault, which is typically 8 feet wide by 34 feet long and up to 9 feet deep (internal dimensions).
Splice vaults will be installed as two-piece preformed concrete chambers and will be located
approximately every 1,500 to 2,500 feet along the onshore route. Where the onshore route is
particularly straight, the distance between splice vaults may be as great as 3,000 feet (the
approximate length of export cable that can be effectively transported by truck and pulled
through conduit within the manufacturer’s tension specifications). These splice vaults will
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accommodate cable splicing and cross-bonding of cable metallic sheaths. A splice vault will be
required for each circuit, resulting in pairs of splice vaults being installed along the onshore route;
due to their size, the positions of the two splice vaults will be staggered (see the duct bank
engineering plans provided in Attachment E).
Onshore construction is expected to proceed at an average rate of approximately 80 to 200 feet
per day depending on several factors including existing utility density.
Proposed trenching within Conservation Commission jurisdiction will occur within the paved
parking lot and the existing roadway layout of Craigville Beach Road, where the work will take
place within LSCSF, a narrow strip of Coastal Dune separating the paved parking lot from the
paved roadway, and RFA and buffer zone to Salt Marsh associated with the Centerville River. The
Proponent will restore the short strip of Coastal Dune to preconstruction conditions. A second
area of Conservation Commission jurisdiction occurs along Shootflying Hill Road in the vicinity of
Wequaquet Lake where work will be required within the buffer zone of Bordering Vegetated
Wetlands, Land Under a Water Body, Inland Bank, and Beach. For the temporary impacts to
Coastal Dune just north of the parking lot, the Proponent will restore the area as shown in the
Dune Restoration Plan provided in Attachment I.
The trench will be backfilled with a combination of Flowable Thermal Backfill (FTB), native
material (typically sand and gravel), or road base under roadway areas to original grade. FTB, a
thermally approved concrete mix, will be placed above the thermal concrete-encased duct bank
if final cable engineering determines it necessary; FTB is an inert mix of stone, sand, and cement
that is designed to dissipate heat generated by underground electric transmission
cables. Compared with the thermal concrete used to encase the duct bank, FTB is a lower-
strength material; as such, FTB is “excavatable,” whereas the thermal concrete around the ducts
is more solid. During installation, FTB will flow to fill trench voids and bond with the trench
sidewalls. Once hardened, FTB will support loads from vehicular traffic above, and eliminate
possibility of future settlement. The final backfill in roadway areas will be town- and/or state-
required road sub-base graded material upon which base course and finish course pavements will
be placed. In landscaped areas, the final backfill above the FTB will typically be a sandy loam,
which can be seeded.
During construction, traffic will be managed in accordance with TMPs developed in consultation
with Town of Barnstable officials.
The typical duct bank construction sequence will include the following steps:
1. Survey and mark splice vault and duct bank locations.
2. Set up erosion and siltation controls, including silt sacks or similar protection for existing
storm drains.
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3. Set up traffic management measures in coordination with local police and public works
officials.
4. Pipe will be delivered on flatbed trucks, stockpiled in a local staging area or along the road
if space is available, and advanced ahead of the trench.
5. Trench excavation should advance at a rate of 80 to 200 feet per day.
6. Excavated material will be hauled away in trucks daily and recycled or disposed of in
accordance with state regulations.
7. At the landfall site, fusing or joining of continuous PVC or HDPE pipe is planned to be
completed in advance of the trench excavation, and will be waiting for assembly into a
duct bank array (above ground).
8. Duct pipe is proposed to be assembled into the duct bank array in advance, with required
spacers (above ground) then lowered into the trench with slings via heavy equipment.
9. After the duct bank array is secure, concrete trucks will backfill the array in place.
10. Trench areas that are not backfilled by day’s end will be secured with steel plates set in
place to cover and protect the trench overnight. Openings in the shoulder will be
protected and barricaded to ensure traffic and pedestrian safety.
11. While new trench excavation advances, backfill will be placed above new concrete-
encased sections from the prior day’s work. Backfill will be brought to required grade,
and the trench will be secured with steel plates again overnight.
12. Subject to local permit conditions, temporary pavement will be placed at completed
trench sections as soon as there is enough work to occupy a paving crew for a full day’s
work. Final restoration will be performed in accordance with requirements of the HCA.
13. Clean up work area and remove erosion controls.
All work will conform to MassDOT and Town specifications for new road construction. Roadways
will be restored to “like new” condition or an alternative mutually agreed upon with the Town
and consistent with Town policies and procedures.
4.2.2.2 Centerville River Crossing
The onshore transmission system will be installed beneath the Centerville River and adjacent
areas of Salt Marsh via microtunnel, a trenchless crossing technique that will avoid any direct
impacts to these resource areas. The microtunnel operation will require staging and building
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demolition/site preparation within the buffer zone of Salt Marsh. Upon completion of the
installation, the area of buffer zone disturbed by construction staging will be restored to pre-
existing or better conditions.
Microtunnel Methodology
Microtunnel is a pipe jacking operation that utilizes a microtunnel boring machine (MTBM)
pushed into the earth by hydraulic jacks in preparation for insertion of a concrete casing (as
opposed to HDD, which drills a curved trajectory through which a conduit is subsequently
installed). A concrete casing pipe is lowered into the shaft and inserted between the jacking frame
and the MTBM or previously jacked pipe. Slurry lines and power and control cable connections
are made, and the pipe and MTBM are advanced along the planned alignment. This process is
repeated until the MTBM reaches the reception shaft. Upon completion of the tunnel, the
equipment is removed, the carrier pipeline/conduits are pulled through the concrete casing pipe
utilizing rollers or an alternative method, and the annular space is grouted.
To accomplish the Centerville River crossing, a single approximately 430-foot (130-m) long
microtunnel drive would be used to install a 48-inch-diameter reinforced concrete pipe under the
river. The reinforced concrete pipe would house eight 8-inch flexible polyvinyl chloride (FPVC)
power conduits and three 2-inch HDPE conduits for communication and ground cables, as well as
a number of grout lines. The annular space would be grouted using thermal cellular grout to
dissipate heat.
An approximately 30-foot-diameter (inside diameter) jacking shaft and staging area would be
located within the buffer zone to salt marsh on the southwest side of the Centerville River Bridge,
on property identified as 2 Short Beach Road, to align with the staging area for microtunnel and
to minimize impacts on the traveling public on Craigville Beach Road (see Figure 9 as well as the
engineering plans provided in Attachment H). The Proponent has an exclusive option to purchase
the 2 Short Beach Road property. A minimum depth of 10 feet (3 m) of cover between the top of
the casing and the bottom of the Centerville River is needed to complete the microtunnel drive
and maintain tunnel face stability.
A receiving shaft to recover the MTBM will be located north of the river, entirely within the Town
of Barnstable roadway layout and outside of any wetland resource areas or associated buffer
zones. The final location of the receiving shaft will be coordinated with the Town of Barnstable
to avoid any conflicts with proposed components of the future sewer projects planned for this
area. An auger bore or open cut excavation could be used to transition the cable at depth up to
the duct bank depending on geotechnical and hydrogeological conditions, duct bank connection
locations, and the available staging area. The use of auger boring is shown on the engineering
plans in Attachment H. While using an auger bore is a more technically complex approach, it
minimizes dewatering requirements and footprint in the roadway compared with open-cut
excavation. If permitted, open-cut excavation is a likely more cost-effective approach for
constructing the two transition sections.
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
All activities would be outside the river and riverbanks themselves, but equipment set-up and
staging would temporarily affect approximately 9,400 square feet of the 200-foot Riverfront Area
and barrier beach (both previously disturbed); microtunnel would have no permanent impacts to
either resource area. The work would also be located within Land Subject to Coastal Storm
Flowage and within the regulatory buffer zone to salt marsh and land under the ocean, but again
the activity would have no permanent impacts. This trenchless construction method will avoid
impacts to other wetland resource areas located adjacent to the Centerville River including Salt
Marsh, Land Under the Ocean, Land Containing Shellfish, and Coastal Bank.
Microtunnel would have a smaller construction footprint compared to HDD because it avoids the
need to have a pipe string laydown area; however, construction could be somewhat longer in
duration than HDD. An existing four-inch gas main on the west side of the bridge may conflict
with the proposed microtunnel installation operation. In the event that the microtunnel
alignment cannot be designed to be installed safely beneath the existing main, it would be
relocated prior to the execution of the microtunnel. If this is the case, the Proponent will work
with the relevant utility to minimize or eliminate service interruptions to gas customers.
Management of Soil Cuttings
Microtunneling was selected as the preferred methodology with the intention of preventing
accidental release of drilling slurry or soil cuttings to the Centerville River or to the ground surface
when not under the river. While there are several types of trenchless technologies that could
achieve the river crossing installation, in this instance it is important to select the most applicable
trenchless method for maintaining a low depth of cover while crossing under the river.
Microtunneling uses technology to limit the amount of soil and groundwater coming into the
tunnel to establish a successful installation. In addition, the pressure used to perform the
excavation only requires the counterbalance of the active earth pressure and hydrostatic pressure
along the microtunnel drive. A safe operating pressure exists and will be used to prevent
accidental release of soil cuttings or drilling slurry.
Microtunneling counteracts the earth and hydrostatic pressure and creates an equalized pressure
at the face of the tunnel, where the cutterhead is located. The cutterhead rotates to excavate
the soil while maintaining sufficient face stability by limiting the size of the openings on the
microtunnel tunnel boring machine cutterhead. Pressure is monitored real-time by the
microtunnel boring machine (MTBM) operator and can be recorded throughout the length of the
microtunnel drive.
A continuous loop slurry system transports the excavated material such as soil cutting and drilling
slurry back to the launch shaft where the slurry is separated from the solid soil particles and
reused. A slurry separation plant is used to remove soil from the drilling slurry, and the spoils are
then transported offsite and disposed of at an approved landfill. The contractor will be required
to test the spoils prior to disposal to confirm the appropriate landfill is used.
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Drilling slurry engineering parameters will be managed by the contractor. The MTBM will be
monitored using a datalogger to record operating pressures and ensure the operating pressures
at the bore face are within the acceptable operating range to prevent accidental release of soil
cuttings or drilling slurry. The contractor will also be required to develop an appropriate slurry
mix/drilling mud based on anticipated ground conditions. Although drilling fluid release is not
anticipated and the contractor will be required to develop acceptable operation face pressures
and adhere to those during construction, the contractor will also be required to develop a
contingency plan to address accidental release of drilling fluid.
4.2.3 Anticipated Impacts to Coastal Resource Areas from Onshore Construction
By using HDD to extend approximately 1,000 feet offshore from the Craigville Public Beach parking
lot, the Project will avoid impacts to Coastal Beach and minimize impacts to Land Under the
Ocean. The HDD staging area within the parking lot will temporarily occupy approximately one
acre of LSCSF (see Figures 7, 8, and 10), though Project activities will not permanently alter the
elevation or topography of the site.
In addition, the duct bank will pass beneath approximately 0.2 miles (1,100 linear feet) of a barrier
beach system, where installation will occur almost entirely within the paved surfaces of Craigville
Beach Road and the parking lot. Assuming an 11-foot-wide trench for duct bank installation, this
activity will temporarily affect approximately 0.3 acres (12,100 square feet).
As described in Section 3.1.1, the duct bank route will also cross approximately 0.4 miles (2,000
linear feet) of previously altered LSCSF in the vicinity of the landfall site. Again assuming an 11-
foot-wide trench for duct bank installation, this activity will temporarily affect approximately 0.5
acres (22,000 square feet). The Project will have no permanent impacts to this resource since the
underground duct bank will not alter existing topography or flood storage capacity.
Approximately 0.1 miles (730 linear feet) of RFA will be crossed in the vicinity of the Centerville
River, resulting in a temporary impact of approximately 0.2 acres (8,000 square feet). The
microtunnel operation will also require staging, building demolition/site preparation, and
excavation of an entry pit within the buffer zone of Salt Marsh, but there will be no direct impacts
to the salt marsh itself (see Section 5.3.4). In addition, approximately 0.2 miles (1,460 linear feet)
of buffer zone associated with Wequaquet Lake and associated Bordering Vegetated Wetlands
will be temporarily disturbed within the layout of Shootflying Hill Road. Assuming a trench width
of 11 feet, this temporary disturbance will affect approximately 0.4 acres (16,000 square feet).
As described above in Section 4.2.2, the proposed duct bank will also be installed beneath a short
stretch of a narrow linear Coastal Dune located between the paved Craigville Beach parking lot
and Craigville Beach Road (see Figure 7). In this location, a 30-foot-wide construction corridor will
be needed to accommodate the approximately 11-foot-wide trench and associated construction
equipment. This activity will temporarily impact approximately 585 square feet of the Coastal
Dune. Following installation of the duct bank, the Proponent will restore this area of Coastal Dune
as shown in the Dune Restoration Plan provided in Attachment I.
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5.0 Regulatory Compliance
Project work will be located in the following coastal wetland resource areas subject to protection
under the Massachusetts WPA and associated regulations (310 CMR 10.00), and the Barnstable
Wetlands Protection Bylaw and Regulations 16:
i Land Subject to Coastal Storm Flowage (LSCSF);
i Riverfront Area (RFA);
i Land Under the Ocean;
i Coastal Dune/Barrier Beach;
i Land Containing Shellfish; and
i Salt Marsh.
Since HDD will be used for the first approximately 1,000 to 1,200 feet (300-365 meters) of offshore
export cable installation from the landfall site, the Project will avoid impacts to the following
coastal wetland resource areas:
i Coastal Beach; and
i Estimated Habitats of Rare Wildlife (Piping Plover nesting habitat).
Pursuant to the Massachusetts WPA, the Proponent is submitting this NOI to the Barnstable
Conservation Commission for the portion of the Project within the Commission’s jurisdiction (i.e.,
for impacts to wetland resource areas within Barnstable’s municipal boundaries). It is not
anticipated that the Project will have any significant permanent impacts to protected resource
areas or their presumed interests. Project construction will have some limited and unavoidable
impacts to certain resource areas, but these will be temporary and minimized with appropriate
construction methods and mitigation measures.
As shown on Figure 5, the entire route of the OECC in Barnstable waters passes through Natural
Heritage and Endangered Species Program (NHESP) Priority Habitats for State-Protected Rare
Species and Estimated Habitats for Rare Wildlife; these habitats are identified for foraging
seabirds. Accordingly, the Proponent will submit a copy of this NOI to the NHESP pursuant to the
Massachusetts WPA Regulations (310 CMR 10.37).
Potential coastal wetlands impacts related to installation of the offshore export cables, and the
mitigation measures intended to avoid or minimize such impacts, are discussed below for each of
the above-referenced resource areas.
16 A portion of the duct bank installation along Craigville Beach Road is also within the 100-foot buffer zone of the
Coastal Dune located at the northwest corner of the Covell’s Beach parking lot.
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5.1 Water-Dependent Projects
The Massachusetts Waterways Regulations (310 CMR 9.00) state that facilities ancillary to an
offshore wind farm should be characterized as water-dependent, which acknowledges that such
projects are unable to be located away from the water. The specific section of those Regulations
(310 CMR 9.12(2)(e) is excerpted below:
(e) In the case of a facility generating electricity from wind power (wind turbine facility), or
any ancillary facility thereto, for which an EIR is submitted, the Department shall presume such
facility to be water-dependent if the Secretary has determined that such facility requires direct
access to or location in tidal waters and cannot reasonably be located or operated away from
tidal or inland waters, based on a comprehensive analysis of alternatives and other
information analyzing measures that can be taken to avoid or minimize adverse impacts on
the environment, in accordance with M.G.L. c. 30, §§ 61 through 62I.
The Project is water-dependent because to accomplish the purpose of establishing electric
transmission facilities linking the offshore wind farm and onshore electric grid, the proposed
offshore export cables must unavoidably cross waterways. During environmental review of the
very similar Vineyard Wind Connector project, the EEA Secretary concluded in the February 1,
2019 FEIR Certificate: “Consistent with 310 CMR 9.12(2)(e), I have determined that the project is
water-dependent because the facility requires location in tidal waters and cannot reasonably be
located or operated away from tidal waters.”
For further clarity, the WPA Regulations provide a definition of “water-dependent uses,” which is
excerpted here from 310 CMR 10.04.
Water-dependent Uses mean those uses and facilities which require direct access to, or
location in, marine, tidal or inland waters and which therefore cannot be located away from
said waters, including but not limited to: marinas, public recreational uses, navigational and
commercial fishing and boating facilities, water-based recreational uses, navigation aids,
basins and channels, industrial uses dependent upon waterborne transportation or requiring
large volumes of cooling or processing water which cannot reasonably be located or operated
at an upland site, crossings over or under water bodies or waterways (but limited to railroad
and public roadway bridges, tunnels, culverts, as well as railroad tracks and public roadways
connecting thereto which are generally perpendicular to the water body or waterway), and
any other uses and facilities as may further hereafter be defined as water-dependent in 310
CMR 9.00” (emphasis added).
A finding of water dependency is relevant for certain aspects of this filing.
5.2 Limited Project Status
Under the Massachusetts WPA, certain activities are afforded Limited Project status (310 CMR
10.04), which allows permitting authorities to allow projects that are inherently unable to meet
wetland performance standards. The Proponent believes the Project does meet the wetland
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performance standards, but nonetheless requests a determination that the Project is afforded
Limited Project Status. Specific activities that qualify for Limited Project status are listed in the
Massachusetts WPA Regulations at 310 CMR 10.04 and 310 CMR 10.53. Water-dependent
projects such as the NE Wind 1 Connector are one such category of Limited Projects in this section
of the Regulations:
310 CMR 10.53(3) Limited Projects.
(l) The construction, reconstruction, operation or maintenance of water dependent uses;
provided, however that: 1. any portion of such work which alters a bordering vegetated
wetland shall remain subject to the provisions of 310 CMR 10.55, 2. such work in any other
resource area(s) found to be significant to flood control or prevention of storm damage shall
meet the performance standards for that interest(s), and 3. adverse impacts from such work
in any other resource area(s) shall be minimized regarding the other statutory interests for
which that resource area(s) is found to be significant.
Accordingly, the Project should be regarded as a “Limited Project” under the Massachusetts WPA
Regulations. Regardless, the Proponent believes the Project does meet the wetland performance
standards.
5.3 Wetland Resource Areas and Performance Standards
Portions of the proposed work in Barnstable that will be located within LSCSF, RFA, Salt Marsh,
Coastal Dune/Barrier Beach, Land Containing Shellfish, or Land Under the Ocean fall under the
jurisdiction of the Barnstable Conservation Commission under the Massachusetts WPA and
associated regulations (310 CMR 10.00) as well as the Barnstable Wetland Protection Bylaw, Ch.
237 and related Wetland Protection Regulations. The entire OECC in Barnstable waters will also
pass through NHESP-mapped Priority Habitat for State-Protected Rare Species and Estimated
Habitat for Rare Wildlife (see Figure 5). Accordingly, the Proponent will submit a copy of this NOI
to the NHESP pursuant to the Massachusetts WPA Regulations (310 CMR 10.37).
Cable installation will have some unavoidable and temporary impacts to these resource areas, but
these impacts will be minimized with appropriate construction methods and mitigation measures
and meet the applicable state performance standards, as well as the criteria in the Barnstable
Wetlands Protection Bylaw and related Regulations. Specific Project-related impacts to Land
Under the Ocean related to installation of the offshore export cables are quantified in Table 4-1.
In addition, as described in Section 4.2, the Project’s onshore activities within the Commission’s
jurisdictional area will include: (1) approximately 0.5 acres (22,000 square feet) of temporary
alteration to LSCSF due to duct bank installation within Craigville Beach Road and the Craigville
Public Beach parking lot; (2) approximately 0.3 acres (12,100 square feet) of temporary alteration
of a barrier beach system due to duct bank installation within Craigville Beach Road and the
Craigville Public parking lot; (3) approximately 0.2 acres (8,000 square feet) of temporary
alteration of RFA in the vicinity of the Centerville River; (4) approximately 200 square feet of
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temporary alteration to Coastal Dune due to duct bank installation in the narrow area between
the parking lot and Craigville Beach Road; and (5) approximately 1 acre of temporary occupation
of LSCSF within the paved Craigville Public Beach parking lot for HDD staging. In addition, any
proposed work within the buffer zones of inland resource areas that are located along Shootflying
Hill road in the vicinity of Wequaquet Lake is also subject to the jurisdiction of the Barnstable
Conservation Commission.
The relevant performance standards for RFA, Land Under the Ocean, Coastal Dune/Barrier Beach,
Land Containing Shellfish, and Salt Marsh are discussed below. There are no performance
standards established for LSCSF, although it is worth noting that Project activities will not result
in any permanent alteration of elevation or topography, will not increase impermeable surface,
and will not affect storm damage prevention or flood control.
5.3.1 Riverfront Area
The Massachusetts WPA Regulations define RFA as the area of land located within a specified
distance, usually 200 feet, of the banks of perennial rivers and streams. RFA may include overlap
with other resource areas and their buffer zones, but the RFA itself has no buffer zone. For the
Centerville River crossing, the RFA within the layout of Craigville Beach Road extends roughly from
200 feet south of the south bridge abutment to 200 feet north of the north bridge abutment.
Some projects have been granted exemptions from the performance standards that would
otherwise apply to certain activities located in RFA. Included in the list of exempted activities are
those that are necessary to construct a project that is required to obtain a Chapter 91 license (see
310 CMR 10.58(6)(i)). The Project will require a Chapter 91 license for the proposed crossing of
the Centerville River, and is therefore not subject to the performance standards applicable to RFA.
Regardless the Project will satisfy the performance standards for the other resource areas present
at the Centerville River crossing, including Land under the Ocean and Salt Marsh.
5.3.2 Land Under the Ocean
The Massachusetts WPA Regulations require that projects located within Land Under the Ocean
satisfy certain general performance standards when the resource is found to be significant to the
protection of marine fisheries, protection of wildlife habitat, storm damage prevention, or flood
control (310 CMR 10.25 (3) through (7)). Of relevance to this Project, 310 CMR 10.25(5) states:
(5) Projects not included in 310 CMR 10.25(3) or (4) [relating to dredging projects for
navigational purposes] which affect nearshore areas of land under the ocean shall not
cause adverse effects by altering the bottom topography so as to increase storm damage
or erosion of coastal beaches, coastal banks, coastal dunes, or salt marshes.
Use of HDD will avoid offshore cable installation activities within approximately 1,000 to 1,200
feet of the shoreline, thus avoiding nearshore impacts. Installation of the offshore export cables
will require the temporary disturbance of two narrow strips of seafloor to achieve sufficient burial
depth (see Section 4.1 for a more detailed discussion of offshore export cable installation). Cable
5526.10/New England Wind 1 Connector 49 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
burial will temporarily displace some sediments that do not immediately re-settle back into the
fluidized trench, but these displaced sediments will return to the seafloor in the wake of the cable
installation tool generally within a few meters of the furrow created by cable installation. Particle
sediment monitoring studies completed for the Block Island Wind Farm’s offshore cable
installation found that displaced sediments were an average distance from the trench centerline
of 12.5 feet (3.8 meters) at a thickness 2.8 inches (7 cm).17 Such a minor alteration to the bottom
topography would not alter water circulation or sediment transport patterns, and would not
increase erosion of coastal beaches, coastal banks, coastal dunes, or salt marshes.
Discontinuous sand wave dredging may be required in areas where currents have created large,
mobile sand waves. These sand waves are located along the southernmost stretch of the OECC
in Barnstable waters, in an area just east of Wreck Shoal and almost 3 miles from the nearest
coastal beach, coastal bank, coastal dune, or salt marsh. Where the offshore cable installation
must cross a sand wave, it will be necessary to provide additional burial depth to achieve sufficient
coverage beneath the stable seabed surface and prevent the cable from being exposed as the
sand wave advances across the seafloor. Where large sand waves are encountered, it may be
necessary to carve a notch into the sand waves of sufficient width and depth so the cable
installation tool can proceed through it, installing the cables beneath the stable seabed. The
Project’s dredging methods and related impacts are discussed and quantified in Section 4.1.
Any dredging required for offshore cable installation through sand waves will occur within narrow
corridors in areas relatively far from shore (greater than 1 mile); therefore, regardless of the
dredge method selected through sand waves, installation of the offshore export cables is not
expected to increase the risk of erosion in coastal areas. The impacts will be modest and in
compliance with performance standards.
Also potentially relevant to this Project, 310 CMR 10.25(6) states:
(6) Projects not included in 310 CMR 10.25(3) which affect land under the ocean shall if
water-dependent be designed and constructed, using best available measures, so as to
minimize adverse effects, and if non-water-dependent, have no adverse effects, on marine
fisheries habitat or wildlife habitat caused by:
(a) alterations in water circulation;
(b) destruction of eelgrass (Zostera marina) or widgeon grass (Rupia maritina) beds;
(c) alterations in the distribution of sediment grain size;
17 James Elliott, K. Smith, D.R. Gallien, and A. Khan. 2017. Observing Cable Laying and Particle Settlement During the
Construction of the Block Island Wind Farm. Final Report to the U.S. Department of the Interior, Bureau of Ocean Energy
Management, Office of Renewable Energy Programs. OCS Study BOEM 2017-027. 225 pp.
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
(d) changes in water quality, including, but not limited to, other than natural
fluctuations in the level of dissolved oxygen, temperature or turbidity, or the addition
of pollutants; or
(e) alterations of shallow submerged lands with high densities of polychaetes, mollusks
or macrophytic algae.
The Project is water-dependent as defined in the Massachusetts Waterways Regulations at 310
CMR 9.12(2)(b)10, which includes infrastructure facilities used to deliver electricity to the public
from an offshore facility located outside the Commonwealth. As a water-dependent use, the
Project must be designed and constructed using best available measures to minimize adverse
effects. The Project’s water-dependency is discussed in Section 5.1.
As described in Section 4.0 of this NOI as well as in the MEPA documents incorporated by
reference, the proposed cable installation methods are well documented as environmentally
conscious operations with minimal temporary impacts to the seafloor and water quality.
Installation of the export cables will require some displacement of marine sediments to achieve
desired cable burial, but in most areas the method of installation will result in minimal alteration
to seafloor topography. More alteration will be required in high-energy areas where large sand
waves are encountered, but these high-energy areas are characterized by constantly changing
bathymetry, and any alteration due to the Project is expected to be temporary. None of the
affected areas will be altered to the extent that any significant changes occur to water circulation
or sediment grain size distribution.
The OECC has been sited to avoid areas of eelgrass or widgeon grass, and the installation
methodologies will minimize impacts to benthic organisms.
In addition, under 310 CMR 10.25(7), projects with certain adverse effects are presumed
impermissible:
(7) Notwithstanding the provisions of 310 CMR 10.25(3) through (6), no project may be
permitted which will have any adverse effect on specified habitat sites of rare vertebrate
or invertebrate species, as identified by procedures established under 310 CMR 10.37.
The NHESP has mapped all of Nantucket Sound as priority habitat of state-listed rare species
(Massachusetts Natural Heritage Atlas, 15th Edition, 2021). As a result, the OECC will necessarily
cross priority habitat within Barnstable waters (see Figure 5). The Proponent has been consulting
with NHESP in accordance with the Massachusetts Endangered Species Act (MESA, 321 CMR
10.14) to ensure that impacts to offshore rare species are avoided or minimized to greatest extent
practicable. The Proponent has completed a MESA checklist pursuant to 321 CMR 10.18 with
regard to priority habitat within state waters, and the checklist was submitted to NHESP for review
in March 2022. The Piping Plover Protection Plan was attached to the Checklist (see also
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Attachment G). On April 1, 2022, the NHESP issued a MESA Determination that with compliance
with the Piping Plover Protection Plan, the Project will avoid a Take (see Attachment L). Pursuant
to 310 CMR 10.37, the Proponent will submit a copy of this NOI to the NHESP.
5.3.2 Coastal Dune/Barrier Beach
The performance standards for Coastal Dune and Barrier Beach state that any alteration of a
coastal dune or within 100 feet of a coastal dune must not have an adverse effect on the dune.
In other words, to satisfy the performance standard the Project must not result in a greater than
negligible change in the dune that diminishes its ability to perform specified functions (i.e. provide
storm damage prevention, flood control, or protection of wildlife habitat).
These performance standards for projects affecting coastal dunes and adjacent lands are found
at 310 CMR 10.28(3) through (6) and are excerpted below:
(3) Any alteration of, or structure on, a coastal dune or within 100 feet of a coastal dune
shall not have an adverse effect on the coastal dune by:
(a) affecting the ability of waves to remove sand from the dune;
(b) disturbing the vegetative cover so as to destabilize the dune;
(c) causing any modification of the dune form that would increase the potential for
storm or flood damage;
(d) interfering with the landward or lateral movement of the dune;
(e) causing removal of sand from the dune artificially; or
(f) interfering with mapped or otherwise identified bird nesting habitat.
HDD activities will be staged from the paved Craigville Public Beach parking lot, some of which is
located within 100 feet of a Coastal Dune. However, HDD activities will in no way impair dune
functions. Approximately 585 square feet of the Coastal Dune will be disturbed during installation
of the proposed duct bank between the paved parking lot and Craigville Beach Road. Although
construction will temporarily alter the grade of the dune, the impact will be temporary and the
dune will be restored according to the dune restoration plan provided as Attachment I. It should
be noted that while the Coastal Dune that will be disturbed is not functioning as a coastal dune in
that it is physically disconnected from the beach and sits in between a paved parking lot and a
paved town road, the Proponent will provide restoration measures that treat the area as if it were
a functioning coastal dune.
(4) Notwithstanding the provisions of 310 CMR 10.28(3), when a building already exists
upon a coastal dune, a project accessory to the existing building may be permitted,
provided that such work, using the best commercially available measures, minimizes the
5526.10/New England Wind 1 Connector 52 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
adverse effect on the coastal dune caused by the impacts listed in 310 CMR 10.28(3)(b)
through (e). Such an accessory project may include, but is not limited to, a small shed or a
small parking area for residences. It shall not include coastal engineering structures.
There is no existing structure on the dune, and the Project does not propose any accessory
projects.
(5) The following projects may be permitted, provided that they adhere to the provisions
of 310 CMR 10.28(3):
(a) pedestrian walkways, designed to minimize the disturbance to the vegetative
cover and traditional bird nesting habitat;
(b) fencing and other devices designed to increase dune development; and
(c) plantings compatible with the natural vegetative cover.
The area of Coastal Dune that will be temporarily disturbed by duct bank installation will be
restored with compatible sand and planted with American beach grass and other native plants
appropriate for landscape to promote dune development.
(6) Notwithstanding the provisions of 310 CMR 10.28(3) through (5), no project may be
permitted which will have any adverse effect on specified habitat sites of Rare Species, as
identified by procedures established under 310 CMR 10.37.
The Project is located within specified Priority Habitat of rare wetlands wildlife. The Proponent
has consulted with the NHESP and will continue to comply with all time-of-year restrictions and
other conditions deemed necessary by the NHESP for the installation and maintenance of the
Project.
5.3.3 Land Containing Shellfish
Offshore export cable installation may result in some localized impact to shellfish and other
organisms in the direct path of the installation tool, and within the water column from water
withdrawals. Soon after disturbance, recolonization and recovery to pre-construction species
assemblages is expected given the similarity of nearby habitats and species, the limited area of
disturbance, and the mobility of the organisms in some or all life stages. Nearby, unaffected areas
will likely act as refuge areas and supply a brood stock of species, which will begin recolonizing
5526.10/New England Wind 1 Connector 53 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
disturbed areas post-construction. A post-construction marine survey conducted in 2015 within
six weeks of installation of a submarine cable from Falmouth to Tisbury on Martha’s Vineyard
found that benthic disturbances only occurred along some parts of the cable route.18
As described in Section 4.1.2.2, anchoring may be required along the entire OECC to enable the
use of installation tools capable of achieving the target burial depth. Anchors would disturb the
substrate and leave a temporary irregularity in the seafloor resulting in some localized mortality
of infauna. In addition, portions of the seafloor would be swept by an anchor cable as the
installation equipment moves along the cable. The Proponent will implement a monitoring plan
to document disturbance and recovery of marine habitat along the cable installation corridor. A
monitoring program focusing on benthic habitat and communities will be performed to measure
potential impacts and the recovery of these resources comparable to controls outside the area of
construction.
The Massachusetts WPA Regulations require that projects located in resource areas that are
determined to be significant to the protection of land containing shellfish and therefore marine
fisheries shall satisfy certain general performance standards (310 CMR 10.34 (4) through (6) and
(8)). These performance standards are excerpted below:
(4) Except as provided in 310 CMR 10.34(5), any project on land containing shellfish shall
not adversely affect such land or marine fisheries by a change in the productivity of such
land caused by:
(a) alterations of water circulation;
(b) alterations in relief elevation;
(c) the compacting of sediment by vehicular traffic;
(d) alterations in the distribution of sediment grain size;
(e) alterations in natural drainage from adjacent land; or
(f) changes in water quality, including, but not limited to, other than natural fluctuations
in the levels of salinity, dissolved oxygen, nutrients, temperature or turbidity, or the
addition of pollutants.
The Project is not anticipated to result in any permanent alterations to water circulation, relief
elevation, or distribution of sediment grain size. There will be no change to natural drainage from
adjacent land, and no compacting of sediments from vehicular traffic or installation gear.
Offshore export cable installation will result in some temporary impacts to shellfish in the area
18 Epsilon Associates, Inc. and CR Environmental, Inc. 2015. Martha’s Vineyard Hybrid Submarine Cable Post-
Construction Marine Survey Report. Prepared for Comcast and NSTAR Electric Company.
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
immediately along the installation path, but these impacts are regarded as negligible given that
the area of potential affect is incrementally small in comparison to the wide area of habitat
present in the Project vicinity.
(5) Notwithstanding the provisions of 310 CMR 10.34(4), projects which temporarily have
an adverse effect on shellfish productivity but which do not permanently destroy the
habitat may be permitted if the land containing shellfish can and will be returned
substantially to its former productivity in less than one year from the commencement of
work, unless an extension of the Order of Conditions is granted, in which case such
restoration shall be completed within one year of such extension.
The Proponent has assembled a benthic habitat monitoring framework and remains in active
consultations with state and federal agencies (including the Massachusetts Office of Coastal Zone
Management [CZM], Division of Marine Fisheries [DMF], Massachusetts Department of
Environmental Protection [MassDEP], Bureau of Ocean Energy Management [BOEM], and the
National Marine Fisheries Service [NMFS]) to develop a Benthic Habitat Monitoring Plan (BHMP)
out of that framework. The BHMP will document habitat and benthic community disturbance and
recovery as a result of construction and installation. The Proponent expects the BHMP will be
memorialized in the Water Quality Certification (WQC) that will be issued by MassDEP.
(6) In the case of land containing shellfish defined as significant in 310 CMR 10.34(3)(b)
(i.e., those areas identified on the basis of maps and designations of the Shellfish
Constable), except in Areas of Critical Environmental Concern, the issuing authority may,
after consultation with the Shellfish Constable, permit the shellfish to be moved from such
area under the guidelines of, and to a suitable location approved by, the Division of Marine
Fisheries, in order to permit a proposed project on such land. Any such project shall not be
commenced until after the moving and replanting of the shellfish have been commenced.
The Proponent will work with the DMF and the shellfish constable for the Town of Barnstable to
minimize impacts to shellfish habitat but is not proposing to relocate shellfish prior to cable
installation.
(8) Notwithstanding the provisions of 310 CMR 10.34(4) through (7), no project may be
permitted which will have any adverse effect on specified habitat of rare vertebrate or
invertebrate species, as identified by procedures established under 310 CMR 10.37.
The Massachusetts NHESP has mapped all state waters within Nantucket Sound and Muskeget
Channel as priority habitat of state-listed rare species (Massachusetts Natural Heritage Atlas, 15th
Edition, 2021). As a result, the OECC will necessarily cross priority habitat within Barnstable
waters. The Proponent is consulting with the NHESP in accordance with the MESA (321 CMR
10.14) to ensure that impacts to offshore rare species are avoided or minimized to greatest extent
practicable. The Proponent has completed a MESA checklist pursuant to 321 CMR 10.18 with
regard to priority habitat within state waters, and the checklist was submitted to NHESP for review
5526.10/New England Wind 1 Connector 55 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
in March 2022. On April 1, 2022, the NHESP issued a MESA Determination that with compliance
with the Piping Plover Protection Plan, the Project will avoid a Take (see Attachment L). Pursuant
to 310 CMR 10.37, the Proponent will submit a copy of this NOI to the NHESP.
5.3.4 Salt Marsh
The onshore transmission system will be installed beneath the Centerville River and adjacent
areas of Salt Marsh via microtunnel, a trenchless crossing technique that will avoid any direct
impacts to these resource areas. The microtunnel operation will require staging, building
demolition/site preparation, and excavation of an entry pit within the buffer zone of Salt Marsh.
For the entry pit, a caisson or similar water-tight shaft construction methodology will minimize
the required dewatering during shaft construction and microtunnel operation. Upon completion
of the installation, the area of buffer zone disturbed by construction staging will be restored to
pre-existing or better conditions.
Construction methods for microtunneling are described in detail in Section 4.2.2.2, including drill
slurry management methods.
Performance standards for Salt Marsh are found in the Massachusetts Wetlands Protection Act
Regulations at 310 CMR 10.32 (3) through (6), which is excerpted below.
(3) A proposed project in a salt marsh, on lands within 100 feet of a salt marsh, or in a body of
water adjacent to a salt marsh shall not destroy any portion of the salt marsh and shall not have
an adverse effect on the productivity of the salt marsh. Alterations in growth, distribution and
composition of salt marsh vegetation shall be considered in evaluating adverse effects on
productivity. 310 CMR 10.32(3) shall not be construed to prohibit the harvesting of salt hay.
The Project will have no direct impacts to salt marsh. Temporary staging will minimize ground
disturbance and erosion and sediment controls will also allow for any separation of dewatering
from the salt marsh.
(4) Notwithstanding the provisions of 310 CMR 10.32(3), a small project within a salt marsh, such
as an elevated walkway or other structure which has no adverse effects other than blocking
sunlight from the underlying vegetation for a portion of each day, may be permitted if such a
project complies with all other applicable requirements of 310 CMR 10.21 through 10.37.
This standard is not applicable, as the Project does not to propose introducing any elevated
walkway or other structure that might block sunlight from underlying vegetation.
(5) Notwithstanding the provisions of 310 CMR 10.32(3), a project which will restore or rehabilitate
a salt marsh, or create a salt marsh, may be permitted in accordance with 310 CMR 10.11 through
10.14, 10.24(8), and/or 10.53(4).
This standard is not applicable, as the Project does not propose restoration, rehabilitation, or
creation of a salt marsh.
5526.10/New England Wind 1 Connector 56 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
(6) Notwithstanding the provisions of 310 CMR 10.32(3) through (5), no project may be permitted
which will have any adverse effect on specified habitat sites of Rare Species, as identified by
procedures established under 310 CMR 10.37.
This standard is not applicable, as the Centerville River crossing is not located within any specified
habitat of Rare Species.
5.4 Interests Protected under Barnstable Wetlands Protection Bylaw
The Project and associated activities contribute to the protection of wetland functions and values
identified in the WPA and The Town of Barnstable Wetlands By-Law, Chapter 237. The bylaw
specifically addresses fourteen values, as discussed below.
1. Protection of public and private water supply: Construction activities proposed in or
within 100 feet of wetland resource areas will not affect public or private water supplies.
The cables and duct bank will not contain any fluids or hazardous materials. A Stormwater
Pollution Prevention Plan will be prepared in accordance with the U.S. EPA’s general
permit for construction activities and will be implemented during construction to properly
manage construction activities. The Proponent’s objective is to minimize the potential
for erosion and sedimentation impact during Project construction by managing
stormwater and effectively restoring any disturbed areas. The Proponent will meet these
objectives by implementing various erosion and sediment control measures that will:
o Minimize the quantity and duration of soil exposure;
o Protect areas of critical concern during construction by redirecting and reducing the
velocity of runoff; and
o Establish vegetation where required as soon as possible following final grading.
Temporary erosion control barriers will be installed prior to initial disturbance of soil and
will be inspected on a daily basis in areas of active construction or equipment operation
and on a weekly basis in areas with no construction or equipment operation. These
temporary erosion control barriers will be maintained as necessary to contain soil and
sediment within the permitted work limits.
Any silt fence used as a construction-period control will be installed as directed by the
manufacturer and applicable permit conditions. Accumulated sediment will be removed
and the fence inspected to ensure it remains embedded in the soil as directed. Sufficient
silt fence will be stockpiled onsite for emergency use and maintenance. Hay/straw bales
used for stormwater management will be anchored in place with at least two wooden
stakes and will be replaced or damaged or allowing water to flow underneath; properly
placed and staked straw wattles or fiber rolls may be used in lieu of hay bales in certain
circumstances.
5526.10/New England Wind 1 Connector 57 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
Nearly all vehicle fueling and all major equipment maintenance will be performed off-site
at commercial service stations or a contractor’s yard. A few pieces of large, less mobile
equipment (e.g., excavators, paving equipment) will be refueled as necessary on-site. Any
such field refueling will not be performed within 100 feet of wetlands waterways, or
within 100 feet of known private or community potable wells, or within any Town water
supply Zone I area.
2. Protection of groundwater supply: The Project will protect groundwater supply through
the implementation of a Stormwater Pollution Prevention Plan during construction to
properly manage construction activities.
3. Flood control: The Project will not permanently change existing grades, and therefore will
not affect existing flood storage capacity (see Section 5.3).
4. Storm damage prevention: The Project will not affect resources that protect properties
from storm damage. Following the temporary disturbance of a narrow strip of Coastal
Dune located between the paved Craigville Public Beach parking lot and Craigville Beach
Road, the Proponent will restore this area of Coastal Dune as shown in the Dune
Restoration Plan provided as Attachment I.
5. Prevention of pollution: The Project will prevent pollution through the implementation of
a Stormwater Pollution Prevention Plan during construction to properly manage
construction activities, and by otherwise using appropriate construction techniques
discussed in Section 4.2. There will be no fluids in the cable or vaults.
6. Protection of land containing shellfish: As discussed in Section 3.1.2 and shown on Figure
4, the Project’s OECC and preliminary cable alignments almost entirely avoid shellfish
suitability areas in Barnstable waters. The transition from offshore cable burial to the
HDD will occur close to the boundary for mapped suitable habitat for Surf Clam (Spisula
solidissima) located in the nearshore area of Centerville Harbor. The use of HDD will avoid
almost all impacts to the mapped suitable habitat; it is estimated that typical cable
installation may occur through less than approximately 200 linear feet of that habitat.
7. Protection of shellfish and fisheries: As discussed in Section 4.1.2, direct trenching impacts
for the two offshore export cables will be limited to two narrow, approximately 3.3-foot
(1-meter) wide, strips of seabed. Given the narrow width of disturbance, and since
immediately adjacent habitats will remain unaffected, it is anticipated that the affected
area will recover quickly, as observed for other cable projects in Nantucket Sound (e.g.,
the Martha’s Vineyard Hybrid Cable Project between Falmouth and Tisbury in 2015). The
Proponent will continue to consult with the relevant federal and state agencies to refine
the Project construction schedule to avoid and minimize impacts to marine species.
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8. Protection of wildlife habitat: As discussed in Section 3.1.3, the Project will avoid
disturbance of the priority habitat associated with Craigville Public Beach by installing the
cable using HDD and by initiating the HDD activities prior to April 1 or after August 31
(later per HCA). Furthermore, since the onshore route utilizes existing corridors (e.g.,
roadway layouts and existing utility ROWs), it will not adversely affect wildlife habitat.
9. Erosion and sedimentation control: The Project will control erosion through the
implementation of a Stormwater Pollution Prevention Plan.
10. Recreation: The Project will have a minimal impact on recreational activities, and all
construction activities at the landfall site and in public roadways will be completed
outside of the busy summer season. In addition, the Proponent will maintain public
access to parking lot at the landfall site during the construction period. Finally, the
Proponent will repave the parking lot upon completion of construction.
11. Aesthetics: Within the jurisdiction of the Barnstable Conservation Commission, the
Project will have no visual impacts outside of the construction period since the offshore
export cables and the onshore duct bank will be entirely underground.
12. Effects on agriculture: The Project will not affect any areas of existing agriculture.
13. Effects on aquaculture: The Project will not affect any areas of existing aquaculture.
14. Effects on historic interests: No direct impacts to terrestrial historic resources are
anticipated. Avoidance, minimization, and mitigation measures for submarine historical
and archaeological resources within the Project area will be determined in consultation
with the Massachusetts Historical Commission (MHC) and Massachusetts Board of
Underwater Archaeological Resources (MBUAR) through the NEPA process.
6.0 Mitigation Measures
The Project will result in unavoidable temporary impacts to offshore wetland resource areas (Land
Under the Ocean) as discussed and quantified in Sections 3 and 4. These impacts have been
avoided and minimized through thoughtful selection of route and installation methods, and
mitigation for impacts will be provided as appropriate. Perhaps most importantly, the alignment
of the OECC is the product of an extensive consideration of alternatives and is itself intended to
avoid and minimize potential impacts to sensitive resources, including SSU areas (i.e., eelgrass,
hard bottom, complex bottom, and core habitat of the North Atlantic Right Whale). Wherever
possible, the Project will avoid sensitive habitats, and where impacts cannot be avoided, the
Project will attempt to minimize their extent through cable installation methodology and
scheduling.
The Proponent, through consultations with state and federal agencies, has considered the timing
of export cable installation and potential TOY restrictions, there are two critical schedule
considerations for the Project:
5526.10/New England Wind 1 Connector 59 Attachment A – Project Narrative
Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
1. Safe operating conditions for cable-laying vessels. Cable-laying vessels can only safely
operate in certain wave conditions. To ensure the welfare of the vessel and its crew, the
Proponent can only conduct cable-laying if there is a greater than 50% probability of
obtaining the required weather conditions during the installation activity. An extensive
analysis of historic weather conditions indicates it is statistically likely to obtain safe
weather conditions for cable-laying during the period of approximately April to
September. Scheduling work within safe weather conditions is critical for the Project
because, if weather conditions exceed the limiting operational conditions for the cable
and safe working limits for the vessel, then the crew may have to undertake a controlled
abandonment of the cable, whereby the cable will be cut and placed on the seabed so the
vessel can seek refuge. In this instance, the cable would then have to be spliced. Such a
repair joint would take approximately six days to complete, which would then seriously
compromise the progress of the operation since it would require a favourable weather
window both for the repair joint and the remaining cable-laying activity.
2. Sequencing the Project to begin to deliver power by 2026. Offshore export cable
installation is currently anticipated in 2025-2026, so that the process of WTG
commissioning (which is partially dependent on having power from the offshore export
cable(s) can start and some power can be delivered 2026.
Therefore, the definition of TOY restrictions for export cable installation arises from consideration
of the safe operational conditions for cable-laying vessels and the need to provide power on
schedule in addition to environmental considerations. Extensive discussions with federal and
state agencies, including but not limited to NMFS and DMF, regarding TOY restrictions occurred
for Vineyard Wind/Vineyard Wind Connector. The outcome of those discussions resulted in a set
of TOY restrictions that are also reasonable to apply to Park City Wind/NE Wind 1 Connector given
the similarities between the projects.
Final determination of TOY restrictions for the NE Wind 1 Connector is not complete and the
Proponent will continue to consult with regulatory agencies regarding relevant TOY restrictions
for all aspects of Project construction. At this time, the Proponent is proposing the following TOY
restrictions based on Vineyard Wind Connector and ongoing consultations with permitting and
resource agencies:
i HDD activities at the landfall site will begin in advance of April 1, or will not begin until
August 31, to avoid and minimize noise impacts to Piping Plover during the breeding
season per the Massachusetts Endangered Species Act (MESA) Determination issued by
NHESP on April 1, 2022 (see Attachment G for the Piping Plover Protection Plan [PPPP]).
i Activities at the landfall site where offshore cables will transition from offshore to
onshore cables will not be performed from May 15 through September 15 unless
authorized by the Town of Barnstable or otherwise defined in the HCA.
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Notice of Intent – Barnstable, MA Epsilon Associates, Inc.
i Cable installation of the sections of cable that pass through the portion of Nantucket
Sound with an active squid fishery (specifically, from the landfall site to a distance of
approximately 24-27 km offshore) will occur between July and March, but will avoid April
through June. This installation schedule will avoid cable installation during the spring
months in Nantucket Sound and avoid and minimize impacts to the squid fishery.
i Finally, to comply with federal protections for the Northern long-eared bat, the
Proponent does not plan to perform tree removal activities from June 1 through July 31.
As with Vineyard Wind Connector, the Proponent expects these TOY restrictions will be
memorialized during permitting. The Proponent expects that the final TOY restrictions in state
waters will be incorporated into the Project’s 401 Water Quality Certification (WQC).
In addition, the Proponent has selected installation techniques that will minimize the amount of
seafloor disturbance during installation of the offshore export cables (see Section 4.1). Based on
post-installation monitoring of a similar submarine cable project in Nantucket Sound, cable burial
is expected to have no long-term impact on the benthic habitat, and the affected area of the
seafloor is expected to be fully restored within a relatively short time. As an example, a post-
construction marine survey conducted in 2015 within six weeks of installation of the Martha’s
Vineyard Hybrid Cable Project from Falmouth to Tisbury on Martha’s Vineyard found that benthic
disturbances visible only along portions of the cable route.
Mitigation for unavoidable impacts to marine resources will be provided in accordance with
provisions established under the Massachusetts OMP and its implementing regulations (301 CMR
28.00). Those regulations specify that projects subject to the OMP are required to pay an Ocean
Development Mitigation Fee intended to compensate the Commonwealth for unavoidable
impacts on public interests and rights in the Planning Area and to support planning, management,
restoration, or enhancement of marine resources and uses. A fee proposal was included in the
Proponent’s FEIR, and the Secretary’s Certificate on the FEIR contained the final fee
determination.
For onshore construction, the Project avoids and minimizes potential impacts to wetlands by
following existing roadway layouts. This means the temporary impacts to LSCSF, RFA, and Barrier
Beach will be entirely within paved areas or previously disturbed areas (i.e., roadway shoulder or,
in the case of RFA, a previously developed residential parcel). Furthermore, the use of
microtunnel to achieve the Centerville River crossing will avoid any direct impacts to the river
itself or to salt marsh.