HomeMy WebLinkAbout2028.06.24 EEA-DPH Response Letter to Barnstable
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The Commonwealth of Massachusetts
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Maura T. Healey
GOVERNOR
Kimberley Driscoll
LIEUTENANT GOVERNOR
Rebecca L. Tepper
SECRETARY
Tel: (617) 626-1000
Fax: (617) 626-1081
http://www.mass.gov/eea
Mark S. Ells, Barnstable Town Manager
367 Main Street
Hyannis, MA 02601
June 28, 2024
Dear Manager Ells:
On behalf of the Healey-Driscoll Administration, we want to express our gratitude to you and the
citizens of Barnstable for your leadership and partnership in the clean energy transition. The
Cape, Islands, and South Coast communities serve a critical role in Massachusetts’ pursuit of
energy independence. We appreciate your collaborative efforts to ensure our cities and towns are
supported as we navigate this new, uncharted opportunity to provide a clean, affordable future
for us all.
As offshore wind project construction is underway, we are writing to respond to concerns raised
regarding the safety of Barnstable beaches and risks to groundwater supplies and the surrounding
environment. In particular, we would like to address electromagnetic field (EMF) exposure and
contamination risk from the proposed energy infrastructure (i.e., underground cables and
substation).
On behalf of the Massachusetts Executive Office of Energy and Environmental Affairs (EEA),
the Department of Public Health (DPH) and the Energy Facility Siting Board (EFSB), we want
to emphasize that, based on the project review and recent readings, the projects are safe.
In addition, we have also included a review of the measures taken to minimize any risk of
contamination from substations, as well as a discussion of the extensive process undertaken by
the EFSB to ensure the safety of sited projects. Finally, it is worth noting the substantial public
benefits produced by these energy infrastructure projects for the Commonwealth as well as the
Cape, Islands, and South Coast communities.
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Electromagnetic Fields
Transmission, distribution lines, and substations are critical energy infrastructures that are
necessary to power the areas and spaces we occupy daily: our homes, businesses, restaurants,
and other common public indoor areas that use energy. This infrastructure is all around us,
including on telephone poles lining our streets as well as undersea cables connecting the islands
to the regional grid. Electromagnetic fields from transmission lines like those used for offshore
wind generally decrease substantially with distance from the conductors 1 and are similar cables
to ones that are in use and have been buried under beaches along the coast of Massachusetts,
including Cape Cod, Nantucket, and Martha's Vineyard, for decades.
The Martha’s Vineyard cables that are connected to Falmouth by five 23 kV cables are one such
example. One cable was recently replaced due to its age (37 years old), and an additional new
cable was installed. These cables bolster Martha’s Vineyard’s energy capacity and reliability,
meeting the growing needs of the island while simultaneously decreasing its carbon footprint due
to the decommissioning of five diesel generators previously used.
On Nantucket, there are two undersea cables connecting to the Cape at Hyannis and Harwich,
ending the need to use the Nantucket Electric Company’s dirty power plant, which operated on
massive diesel generators, in 1996. An additional undersea cable was installed in 2006 to meet
the island’s increasing energy demands. Both of these cables have operated quietly and without
impacting the health and wellbeing of residents in the communities where they are hosted.
The transmission lines under Covell's Beach and those proposed for Craigville and Dowses
beaches produce low level electromagnetic fields. By comparison, the ordinary use of a vacuum,
an electric shaver, or keeping the television on produces stronger electromagnetic fields than an
electric cable.2 The transmission lines are sufficiently buried at the shoreline to be out of sight
and minimize any potential impacts to the beach. Further, the electromagnetic fields testing of
the transmission lines at Covell's Beach showed readings on the beach were recorded as 1-2
milliGauss ("mG") before increasing to 3-5mG in the parking lot and close to 40mG as the
cables come together and continue under the roadway, an average recorded reading for existing
electric infrastructure under our roads today. These readings match what was modeled as part of
the EFSB’s review and approval of the project 3
In addition to being buried, there is additional protection from a shielding effect of the steel
armoring wire forming the outer portion of the cables, which is estimated to reduce levels by
approximately 50 percent.4 For these and other reasons, it is likely that individuals standing
directly above the cables on the beach will not be exposed to significant levels at any given
moment.5 For reference, typical baseline electromagnetic fields inside residences range from 0.5-
1 Bureau of Ocean Energy Management Environmental Studies: Electromagnetic Fields(EMF) from Offshore
Wind Facilities, December 2023.
2 Park City Wind LLC, EFSB 20-01/D.P.U. 20-56/20-57, at 84 n.67, 89 (2023) (at one feet away, operating
appliances such as a vacuum generate magnetic field levels in the range of 40-300 Milligauss (“mG”) and
shavers, hair dryers, and massagers half a foot away can range from 600-700 mG); Vineyard Wind LLC,
EFSB 17--05/D.P.U. 18-18/18-19, at 76 (2019) (reporting maximum, conservatively modeled magnetic
fields of 3.6 and 21.1 mG between the middle of Covell’s Beach and landward edge of the beach).
3 EFSB 17-05/D.P.U. 18-18/18-19, at 76.
4 EFSB 17-05/D.P.U. 18-18/18-19, at 75.
5 EFSB 17-05/D.P.U. 18-18/18-19, at 76 n. 89.
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5.0 mG. The levels produced by the cables are roughly comparable to or below levels that an
average person might be exposed to at any time throughout the course of a given day.6
The World Health Organization (WHO) concluded that “[magnetic field] exposures below the
limits recommended in the International Commission on Non-Ionizing Radiation Protection
(“ICNIRP”) international guidelines do not appear to have any known consequence on health.7
The ICNIRP recommended exposure limit is 2,000 mG, which is nearly 95 times greater than
that highest modeled value for the Vineyard Wind cables at Covell's Beach.8
Furthermore, there is no evidence to support the suggestion that electromagnetic fields from
offshore wind cables negatively impact marine species or fish populations caught from
commercial and recreational fishing expeditions. DPH has reviewed EEA’s conclusions, which
are consistent with federal guidance on EMF, and has concluded that there is little to no known
risk to public health at these levels. Accordingly, the public should not be fearful of EMF-related
impacts to beach, water or other activities in the Barnstable area from these projects.
Contaminants from Substations
The proposed substations that connect electricity generated from offshore facilities to the grid
have been designed for maximum safety and security. The equipment used in the substations will
contain sulfur hexafluoride (SF6), a non-flammable, non-toxic gas that is needed to operate
circuit breakers, switch gears, and other electrical equipment. In addition, mitigation measures
designed to prevent any SF6 leakage from the substations will be implemented, and the installed
equipment reduces the air impacts to be far lower than the applicable MassDEP regulations.9
There are also several mitigation measures that will be implemented at the substations to prevent
any risk to groundwater supplies and the surrounding environment. These include: an integrated
fluid containment system with capacity capable of capturing at least 110 percent of any
components containing dielectric fluid, plus additional capacity for extreme rainfall events; a
Stormwater Management Plan and Erosion and Sedimentation Plan, including a stormwater
management system in conformance with the Massachusetts Stormwater Management
Standards; and a Spill Prevention, Control, and Countermeasures Plan. Additionally, in the Spill
Prevention Plan, containment kits and other spill control tools will be strategically placed around
the substations and the developers have committed to hiring a spill-response contractor. The
combination of these measures effectively assuages any concerns regarding the potential release
of a pollutant from the substation into the groundwater.10
The substation’s Stormwater Management Plans have been upgraded beyond current standards to
accommodate stormwater from an extreme weather event as defined by the Town’s engineering
6 EFSB 20-01/D.P.U. 20-56/20-57, at 83-84.
7 EFSB 20-01/D.P.U. 20-56/20-57, at 84, 89 (noting that the Project’s range of modeled magnetic fields for
the Offshore Export Cables, at either landfall site, are comparable to values that the EFSB has previously
approved in numerous proceedings, and far below magnetic field safety threshold established by ICNIRP
and referenced by the WHO).
8 International Commission on Non-ionizing Radiation Protection (ICNIRP) ICNIRP Guidelines for limiting exposure
to time-varying electric, magnetic and electromagnetic fields (up to 300 GHz) Health Phys. 1998;74:494–522.
9 EFSB 20-01/D.P.U. 20-56/20-57, at 130 (“The Company stated that it will require its equipment
manufacturer to guarantee a maximum annual leak rate of less than 0.1 percent”).
10 EFSB 20-01/D.P.U. 20-56/20-57, at 127.
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consultants. These plans ensure resiliency during weather events like widespread flooding or
drenching rains that have affected energy infrastructure in past years.
In addition to the protections required by the state and federal entities, Barnstable has negotiated
additional protections for its residents through Host Community Agreements (HCA). These
HCA’s can and do provide a valuable opportunity for municipalities to negotiate additional
protections for their residents’ concerns in ways that best meet the focus of their community.
Barnstable’s agreements not only specify that the construction and operation of the transmission
lines and substations minimize impacts on the environment and public, but that the developer
sufficiently addresses any concerns regarding risks to Nantucket Sound and the Town’s public
drinking water supplies.
EFSB Process
The EFSB employs a consistent and comprehensive standard of review for all proposed facilities,
and offshore wind projects are no different. Massachusetts law requires that the EFSB determine
whether a project would provide a reliable energy supply for the Commonwealth with a
minimum impact on the environment at the lowest possible cost. The EFSB also determines
whether a project is consistent with the current health, environmental protection, and resource
use and development policies adopted throughout the state.11 Both Park City Wind and Vineyard
Wind were subject to EFSB processes that were conducted over multiple years before a final
decision was made. Over the course of the EFSB proceedings for the Vineyard Wind and Park
City Wind projects, designs evolved to address concerns of impacted communities, and
opportunities to avoid and minimize environmental impacts in the area. Offshore wind projects
are also subject to numerous reviews at the federal, state, regional, and local levels.
Benefit to the Public
It is important to remember that these projects will further enhance our shared goals as
established by the Legislature through the Massachusetts Global Warming Solutions Act and the
resulting Clean Energy and Climate Plan. Projects like these provide significant benefits to
Massachusetts residents and businesses. Cape Cod and the Islands are areas that are particularly
vulnerable to the impacts of climate change and projects like this help to lessen those impacts by
accelerating the transition to a clean electric grid.
Moreover, these projects are of tremendous benefit to public health by avoiding harmful
greenhouse gas emissions and associated pollutants that lead to respiratory and other illnesses.
Cape Cod and the Islands have previously been powered by coal, oil, and natural gas generation,
which have significant public health impacts.
Clean reliable electric service is also essential to our economic competitiveness. Hospitals,
businesses, schools, and municipal and state buildings need reliable electricity to work efficiently
and safely. It is also critical to the growth of housing and the development of basic infrastructure,
such as wastewater treatment. Without these projects we risk not only our climate but also our
economic prosperity and future in Massachusetts.
It is paramount that as we transform the way we harness clean energy, that our efforts are led by
facts and science. It is our intention with this correspondence to provide you with the public
11 G.L. c. 164, § 69J.
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health and safety information as they have been researched, studied, and implemented. We stand
ready to assist you in navigating these complex conversations. We urge the public to be wary of
increasing disinformation about common electric infrastructure, which is extensively vetted by
environmental and permitting experts as well as independent academics prior to installation.
Barnstable residents should not be dissuaded from enjoying the beach this summer, but rather
proud of their important role in the fight against climate change, and confident that the electric
transmission lines pose no known threat to public health or safety. Thank you again to the Town
of Barnstable and its leadership for your critical role in making the state’s clean energy transition
a reality.
Sincerely,
Michael Judge Dr. Robbie Goldstein
Undersecretary of Energy Commissioner
Executive Office of Energy & Environmental Affairs Department of Public Health
Cc:
Senator Julian Cyr
Representative Kip A. Diggs
Representative Steven Xiarhos
Felicia Penn, President Barnstable Town Council
Gordon Starr, Barnstable Town Council
Kristin E. Terkelsen, Barnstable Town Council
Betty Ludtke, Barnstable Town Council
Craig A. Tamash, Barnstable Town Council
John R. Crow, Barnstable Town Council
Paul C. Neary, Barnstable Town Council
Seth W. Burdick, Barnstable Town Council
Jeffrey Mendes, Barnstable Town Council
Charles R. Bloom, Barnstable Town Council
Matthew Levesque, Barnstable Town Council
Kris Clark, Barnstable Town Council
Paula K. Schnepp, Barnstable Town Council
Karen Nober, Barnstable Town Attorney