Canal Unit 3 and Canal Community Solar

Transcription

Canal Unit 3 and Canal Community Solar
Expanded Environmental Notification Form/
Phase I Waiver Request
Canal Unit 3
and
Canal Community Solar
Submitted to:
Massachusetts Environmental Policy Act Office
100 Cambridge Street, Suite 900
Boston, Massachusetts 02114
Prepared for:
NRG Canal 3 Development LLC
NRG Renew Canal 1 LLC
9 Freezer Road
Sandwich, Massachusetts 02563
Prepared by:
Tetra Tech, Inc.
238 Littleton Road, Suite 201B
Westford, Massachusetts 01886
July 2015
NRG Canal 3 Development LLC NRG Renew Canal 1 LLC 9 Freezer Road Sandwich, Massachusetts 02563 617.529.3874 July 31, 2015
Matthew Beaton, Secretary
Massachusetts Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Attn: Deirdre Buckley, Director
MEPA Office
Re:
Expanded Environmental Notification Form/Phase 1 Waiver Request
Canal Unit 3 Project and Canal Community Solar Project
Sandwich, Massachusetts
Dear Secretary Beaton:
NRG Canal 3 Development LLC (“NRG Canal 3”) and NRG Renew Canal 1 LLC
(“NRG Renew Canal”), both affiliates of NRG Energy, Inc. (“NRG”), are pleased to submit the
enclosed Expanded Environmental Notification Form (“ENF”) and Phase I Waiver Request
(Expanded ENF).
NRG Canal LLC (“NRG Canal”), also an NRG affiliate, owns approximately 88 acres of
land in the town of Sandwich, at which the existing Canal Generating Station and ancillary
structures and infrastructure currently are located (the Property). The Property is comprised of
two separate areas, the 52-acre Northern Area and the 36-acre Southern Area. These two areas
are not physically contiguous to one another. Rather, the two areas are bisected by a separate
parcel owned by MassDOT and operated as an active railroad right-of-way (ROW) by the Cape
Cod Central Railroad. However, due to the common ownership of the two areas and their close
proximity to one another, the two areas will be treated as one “property” for purposes of
Massachusetts Environmental Policy Act (“MEPA”) review.
NRG Canal 3 seeks to permit, construct, and operate a state-of-the-art, fast-starting, dualfueled simple-cycle electric generating facility (“Canal Unit 3”). NRG Canal 3 is proposing to
utilize a single General Electric (GE) 7HA.02 combustion turbine, or comparable unit, with an
approximate net nominal generating capacity of 330 megawatts (MW) that will operate during
peak times of energy demand, for up to 4,380 hours per year. Natural gas will be the primary
fuel, with a maximum equivalent of 1,440 hours using the backup fuel, ultra-low sulfur distillate
(ULSD), to provide the flexibility and reliability to meet the region’s demonstrated power needs.
Canal Unit 3 will include an approximately 215-foot tall stack.
NRG Renew Canal seeks to permit, construct, and operate an approximately 1.5-MW
state-of-the-art solar photovoltaic community solar array (“Canal Community Solar Project”).
NRG Renew Canal is requesting a Phase I Waiver for the Canal Community Solar Project.
MEPA review of the two projects is precipitated by the location of the two projects in
close proximity to one another and the need for a number of state agency permits and impacts
above certain MEPA thresholds related to the Canal Unit 3 project. Taken on its own, the Canal
Community Solar Project would not require any state permits nor would it exceed any threshold
requiring the mandatory preparation of an Environmental Impact Report (“EIR”). Accordingly,
in conjunction with the Expanded ENF, and in accordance with 301 CMR 11.11(5), we request
that the Canal Community Solar Project be issued a Phase I Waiver in order to allow
development of the Canal Community Solar Project to commence construction and operation
prior to completion of the MEPA review process for the Canal Unit 3 Project. NRG Canal 3 is
fully committed to prepare a comprehensive Draft and a Final EIR in connection with MEPA
review of the Canal Unit 3 project.
Pursuant to 301 CMR 11.11(1) Standards for all Waivers, the Secretary may waive
requirements of provisions of the MEPA regulations if the Secretary finds that strict compliance
with those provisions would:
(a) result in a hardship for the Proponent, unless based on delay in compliance by the
Proponent; and
(b) not serve to avoid or minimize damage to the environment.
In addition, pursuant to 301 CMR 11.11(4) Determination for Phase I Waiver, the
Secretary must find that
(a) the potential environmental impacts of phase one, taken alone are insignificant;
(b) ample and unconstrained infrastructure facilities and services exist to support phase
one;
(c) the Project is severable, such that phase one does not require the implementation of
any other future phase of the Project or restrict the means by which potential
environmental impacts from any other phase of the Project may be avoided,
minimized or mitigated; and
(d) the Agency Action on phase one will contain terms such as a condition or restriction
in a Permit, contract or other relevant document approving or allowing the Agency
Action, or other evidence satisfactory to the Secretary, so as to ensure due compliance
with MEPA and 301 CMR 11.00 prior to commencement of any other phase of the
Project.
As set forth in the Expanded ENF, the Canal Community Solar Project meets all
standards for grant of the Phase I Waiver. The Canal Community Solar project involves minimal
environmental impacts. In contrast, the Canal Community Solar project offers significant
benefits in terms of both making clean, renewable energy available to residents of Massachusetts
and offsetting carbon emissions that would otherwise be generated by older, more polluting
generating units. Further, a Phase I Waiver for the Canal Community Solar Project will enable
the project to take advantage of critical solar Investment Tax Credits (ITC), which are set to
expire at the end of 2016. Absent the ITC, the Canal Community Solar Project is not
2
economically viable and NRG Renew Canal would not construct the project. Accordingly,
without the grant of the Phase I Waiver, the Canal Community Solar Project – and the benefits
resulting from the project – will not occur.
Based on the foregoing, we request that you issue a Phase I Waiver for the Canal
Community Solar Project. Further, we request that you publish notice and availability of the
Expanded ENF for public review in the next edition of The Environmental Monitor. We
appreciate your consideration of the Phase I Waiver Request and look forward to working with
you.
Please contact me anytime at (617)529.3874 or shawn.konary@nrg.com if you have any
questions.
Very truly yours,
Shawn Konary
Senior Director, Environmental – East Region
NRG Energy, Inc.
Copies:
Paul Niedzwiecki,
Thomas Atkins,
Judith Lagano,
Lauren Liss,
Fred Sellars,
File
Executive Director, Cape Cod Commission
NRG
NRG
Rubin and Rudman
TetraTech
3
Commonwealth of Massachusetts
Executive Office of Energy and Environmental Affairs
Massachusetts Environmental Policy Act (MEPA) Office
Environmental Notification Form
For Office Use Only
EEA#:
MEPA Analyst:
The information requested on this form must be completed in order to submit a document
electronically for review under the Massachusetts Environmental Policy Act, 301 CMR 11.00.
Project Name: (1) Canal Unit 3; (2) Canal Community Solar
Street Address: 9 Freezer Road
Municipality: Sandwich
Watershed: Cape Cod
Universal Transverse Mercator Coordinates: Latitude: 41.770688
Zone 19N Easting: 374813.5; Northing: 4625412.7
Longitude: -70.506177
Estimated commencement date: (1) June 2017; Estimated completion date: (1) June 2019;
(2) May 2016
(2) September 2016
Project Type: Energy
Status of project design: 15 % complete
Proponent: (1) NRG Canal 3 Development LLC; (2) NRG Renew Canal 1 LLC
Street Address: 9 Freezer Road
Municipality: Sandwich
State: MA
Zip Code: 02563
Name of Contact Person: Jackie Bruce
Firm/Agency: Tetra Tech, Inc.
Street Address: 238 Littleton Road, Suite 201B
Municipality: Westford
State: MA
Zip Code: 01886
Phone: 978-212-3284
Fax: 978-692-4592
E-mail: jackie.bruce@tetratech.com
Does this project meet or exceed a mandatory EIR threshold (see 301 CMR 11.03)?
Yes
No
If this is an Expanded Environmental Notification Form (ENF) (see 301 CMR 11.05(7)) or a
Notice of Project Change (NPC), are you requesting:
a Single EIR? (see 301 CMR 11.06(8))
a Special Review Procedure? (see 301CMR 11.09)
a Waiver of mandatory EIR? (see 301 CMR 11.11)
a Phase I Waiver? (see 301 CMR 11.11)
Yes
Yes
Yes
Yes
No
No
No
No – See Attachment 2
(Note: Greenhouse Gas Emissions analysis must be included in the Expanded ENF.)
Which MEPA review threshold(s) does the project meet or exceed (see 301 CMR 11.03)?
11.03(3)(b)1.f – Alteration of ½ or more acres of any other wetlands (Land Subject to Coastal Storm Flowage [LSCSF])
11.03(7)(a)1 – New electric generating facility with a capacity of 100 or more MW
11.03(8)(a)2. – Modification of an existing Stationary Source with federal potential emissions that collectively will result,
after construction and the imposition of required controls, of 75,000 tpy of GHGs based on CO2 equivalent
11.03(8)(b)2 – Modification of an existing major stationary source resulting in a "significant net increase" in actual
emissions, provided that the stationary source or facility is major for the pollutant, emission of which is increased by:
15 tpy of PM as PM10; 100 tpy of CO; 40 tpy of SO2; 25 tpy of VOC or NOx; 0.6 tpy of lead
Effective January 2011
1616571_1
Which State Agency Permits will the project require?
 Energy Facilities Siting Board (EFSB) – Approval of Petition to Construct
 Department of Public Utilities (DPU) – Approval of Request for Exemptions from Zoning
 Massachusetts Department of Environmental Protection (MassDEP) New Source Review (NSR)/Air Plan
Approval/Title V Operating Permit Modification
 MassDEP Federal Prevention of Significant Deterioration (PSD) Permit
 MassDEP Determination of Applicability and/or Order of Conditions under Wetlands Protection Act –
associated with Lands Subject to Coastal Storm Flowage
 State Fire Marshall Hazardous Substance Tank Approval
 Massachusetts Department of Transportation (MassDOT) Approval under M.G.L. Ch. 40, Section 54A
 Water Management Act Approval
Identify any financial assistance or land transfer from an Agency of the Commonwealth, including
the Agency name and the amount of funding or land area in acres:
Not Applicable.
Summary of Project Size
& Environmental Impacts
LAND
Existing
Total site acreage
New acres of land altered
Acres of impervious area
Square feet of new bordering vegetated
wetlands alteration
Square feet of new other wetland
alteration (LSCSF)
Acres of new non-water dependent use
of tidelands or waterways
Change
Total
Simple-Cycle
Solar
10.6
4.5
8.2
0.4
0
0
461,736
13,504
0
0
160,000
0
500
45,200
0
0
344,124
0
0
549,324
0
500
100
75
0
0
0
0
100
75
881
16
20.9
STRUCTURES
Gross square footage
Number of housing units
Maximum height (feet)
TRANSPORTATION
Vehicle trips per day
Parking spaces
WASTEWATER
449,3152
125,129
0
Water Use (Gallons per day)
3
518,449,315
125,129
0
Water withdrawal (GPD)
664,0004
2,673
0
Wastewater generation/treatment (GPD)
---Length of water mains (miles)
---Length of sewer mains (miles)
Has this project been filed with MEPA before?
Yes (EEA #
)
No
Has any project on this site been filed with MEPA before?
Yes (EEA # 11703 )
No
1
574,444
518,574,444
666,673
Property is bisected by a railroad corridor owned in fee by MassDOT; 52 acres lie north of the railroad, and 36 acres lie south of the railroad
Consumptive use from existing wells
3
Includes daily non-contact cooling water and well water withdrawal
4
Process and sanitary wastewater; does not include non-contact cooling water
2
-21616571_1
---
GENERAL PROJECT INFORMATION – all proponents must fill out this section
PROJECT DESCRIPTION:
Describe the existing conditions and land uses on the project site:
NRG Canal LLC owns approximately 88 acres of land in the Town of Sandwich at which the existing Canal Generating
Station, ancillary structures and infrastructure are currently located (the Property). As shown on Figure 1, the Property
is comprised of two separate areas. As described further below, the two areas are not physically contiguous to one
another. Rather, the two areas are bisected by a separate parcel owned by MassDOT and operated as an active
railroad right-of-way (ROW) by the Cape Cod Central Railroad. However, due to the common ownership of the two
areas and their close proximity to one another, the two areas will be treated as one “property” for purposes of MEPA
review.
The northern portion of the Property (the Northern Area) comprises approximately 52 acres, approximately 48 acres of
land above water and 4 acres of land under the water, on which in-water work was completed for infrastructure
associated with the existing Canal Generating Station. The Northern Area is bounded by Freezer Road and land owned
by the United States Army Corps of Engineers (USACE) to the east; by Canal Service Road and the Cape Cod Canal to
the north; the Town of Bourne to the west; and Rickey’s Road and the railroad ROW to the south. The existing Canal
Generating Station occupies the western portion of the Northern Area. The Northern Area is located within the
Massachusetts Coastal Zone and a majority of the Northern Area is located within the FEMA-Mapped 100-year flood
zone. The Northern Area is zoned “Industrial Limited.”
The majority of the Northern Area is currently developed to support the existing Canal Generating Station, which
includes two dual-fueled electric generation units totaling approximately 1,120 megawatts (MW), a 498-foot high exhaust
stack, several aboveground oil storage tanks, ammonia storage tanks, and appurtenant structures and infrastructure.
The Canal Generating Station connects to an existing NSTAR Electric Company d/b/a Eversource Energy (Eversource)
switchyard located to the south of the Northern Area across Rickey’s Road and the railroad ROW.
The southern portion of the Property (the Southern Area) comprises approximately 36 acres of land within the Property.
The Southern Area is bounded by the Town of Bourne to the west; Route 6A and Tupper Road to the south; an active
railroad ROW, owned by MassDOT, to the north; and undeveloped property owned by Eversource to the east. The
northern portion of the Southern Area is occupied by two large aboveground oil storage tanks which service the existing
Canal Generating Station, and by several unimproved roadways traversing the property. A 360-foot wide transmission
corridor, held by Eversource under easement, occupies the eastern section of the Southern Area. The Southern Area,
which is separated from the Northern Area by an active railroad corridor, is zoned “Business Limited 1.” The Southern
Area is located within the Massachusetts Coastal Zone, with a portion located within the FEMA-mapped 100-year flood
zone.
Describe the proposed project and its programmatic and physical elements:
NRG Energy, Inc. (NRG Energy) is a Fortune 200 energy company, supporting clean energy resources and
technologies critical to our transition to a sustainable, low-carbon society. NRG’s diverse power generating facilities
have a capacity of over 50,000 MW, capable of supporting nearly 1/3 of the U.S. population. NRG electricity providers
serve nearly 3 million retail customers. NRG Canal 3 Development LLC (NRG Canal 3) is a business affiliate of NRG
Energy’s Wholesale Business division, a separate business unit within NRG Energy focusing on wholesale electricity
generation. NRG Renew Canal 1 LLC (NRG Renew Canal) is a business affiliate of NRG Energy’s Renew division, a
separate business unit within NRG Energy focusing on renewable energy projects.
Canal Unit 3 Project: NRG Canal 3 seeks to permit, construct, and operate a state-of-the-art, fast-starting, dual-fueled
simple-cycle electric generating facility (Canal Unit 3) proposed on the Northern Area. Canal Unit 3 will utilize a single
General Electric (GE) 7HA.02 combustion turbine, or comparable turbine, with an approximate net nominal capacity of
330 MW and will operate during peak times of energy demand, for up to 4,380 hours per year with a maximum of 1,440
-31616571_1
hours on ultra-low sulfur distillate (ULSD) to provide the flexibility and reliability to meet the region’s demonstrated power
needs. Canal Unit 3 will include an approximately 215-foot tall stack.
The proposed Canal Unit 3 will be located on approximately 12 acres on the Northern Area (the Simple-Cycle Site), of
which Canal Unit 3 will permanent occupy 10.6 acres, with natural gas and ULSD interconnections running west-to-east
along existing interconnection corridors. The Simple-Cycle Site is currently occupied by concrete-slab, aluminum-sided
warehouses, two ammonia storage tanks, several temporary trailers, and hard-packed open area used for temporary
parking. An electrical interconnection will connect Canal Unit 3 to the existing electrical grid via the Eversource-owned
switchyard, located to the south from the Northern Area, across Rickey’s Road and the Cape Cod Central Railroad
ROW, owned by MassDOT. Temporary use of land within the Northern Area will occur during construction for parking
and laydown. The proposed in-service date for Canal Unit 3 is June 2019.
Canal Unit 3 will apply Lowest Achievable Emission Rate and Best Available Control Technology, as appropriate and will
demonstrate compliance with all applicable National Ambient Air Quality Standards and Prevention of Significant
Deterioration Increments. As such, there will be no significant adverse impact to air quality. Canal Unit 3 will also
comply with all applicable GHG regulations and policies, including the Global Warming Solutions Act.
Canal Unit 3 will have minimal impact on water resources by utilizing a previously developed, but not currently used,
water supply well that has been demonstrated to provide a safe yield well in excess of demand requirements. Further,
Canal Unit 3 will recycle waste water in a near-zero liquid discharge system, avoiding any discharge to the Cape Cod
Canal.
Canal Unit 3 will not impact wetlands except Land Subject to Coastal Storm Flowage, and no in-water work is proposed,
nor is any work proposed in filled tidelands.
No impact to protected species is anticipated as there are no mapped habitats on the Simple-Cycle Site.
Impacts to traffic would be limited in duration to the construction period, and traffic arrival times and routes will be
coordinated with the Town of Sandwich. No significant noise impacts are anticipated as the new unit will be housed in
an acoustically treated enclosure. Compliance with all applicable state and local noise standards will be demonstrated.
Although located in an historic district, the new unit is proposed on land that has previously been significantly altered.
Therefore, no impact to archaeological resources are anticipated. Further, the new unit will be compatible with the
existing units, minimizing any change in visual character.
Canal Community Solar: NRG Renew Canal seeks to permit, construct, and operate a state-of-the-art solar photovoltaic
array (Canal Community Solar) proposed on the Southern Area. Canal Community Solar will be located on
approximately 10 acres of the 36-acre Southern Area (the Solar Site), of which Canal Community Solar will permanently
occupy 8.2 acres, adjacent to the south of existing oil tanks which serve the existing Canal Generating Station and west
of the Eversource electrical transmission ROW. The Solar Site is currently unoccupied, comprised of a mix of open
fields, scrub/shrub, and wooded vegetation. Access will continue to be from an existing access road from Tupper Road.
Canal Community Solar will utilize approximately 305 watt solar panels, similar or equivalent to the LG305N1C-B3 60
modules, with an approximate net nominal generating capacity of approximately 1.5 MW. With an average height of
between 6 and 8 feet above ground level, the panels will be spaced based on the existing grading and tilted between 20
and 30 degrees. Rainwater that runs off the panels can either enter the seeded ground which lies under the solar array,
or flow into the two vegetated bio-retention stormwater areas, totaling approximately 0.3 acre, which are proposed in the
northeastern part of the Solar Site. A 60-foot wide corridor will be cut/cleared to create a shading clearance along the
southern edge of each of two groupings of solar panels.
The two solar arrays are currently contemplated to connect into the existing Eversource 22.8-kV overhead distribution
circuit which follows Route 6A, south of the Solar Site. A new 22.8-kV three-phase overhead circuit will be constructed
on the Solar Site, abutting Route 6A, with two underground 22.8-kV three-phase circuits trenched along the western and
eastern edges of the Solar Site to connect Arrays 1 and 2, respectively. A padmount 22.8-kV to 480-volt transformer
-41616571_1
and 480 volt main panelboard will connect each array to the underground circuit. The proposed in-service date for
Canal Community Solar is around or about September 30, 2016. Canal Community Solar is described in more detail in
the Expanded ENF/Phase I Waiver Report (Attachment 2).
NOTE: The project description should summarize both the project’s direct and indirect impacts
(including construction period impacts) in terms of their magnitude, geographic extent, duration
and frequency, and reversibility, as applicable. It should also discuss the infrastructure
requirements of the project and the capacity of the municipal and/or regional infrastructure to
sustain these requirements into the future.
Describe the on-site project alternatives (and alternative off-site locations, if applicable),
considered by the proponent, including at least one feasible alternative that is allowed under
current zoning, and the reason(s) that they were not selected as the preferred alternative:
Alternatives to Canal Community Solar are described in the Expanded ENF/Phase I Waiver Request (Attachment 2).
Canal Unit 3 Project alternatives are described below.
The purpose of Canal Unit 3 is to respond to an acknowledged need for additional electrical generating capacity in the
Independent System Operator – New England (ISO-NE) system, especially during periods of peak demand. NRG
Canal 3’s parent indirect corporation/affiliate, NRG Energy, considered a range of off-site and on-site alternative
locations, as well as alternative technologies and sizes for the proposed Canal Unit 3. In selecting the location of the
proposed Canal Unit 3, NRG Energy determined that the addition of capacity to one of its existing power stations,
located in the ISO-NE region, would be preferable to development on a new greenfield site or another previously
developed site not under NRG’s control. Adding capacity to an existing facility has significant technical, cost, and
environmental benefits compared to developing a new power station on a greenfield site not currently in use for electric
generation. In addition, electric generating stations are allowed by zoning at all of NRG Energy’s existing New England
power station locations.
In addition to environmental and market concerns, NRG Energy recognized the importance of siting its facility at a
location: where natural gas, adequate electric transmission and water were available; where there was sufficient space
for a new facility and ancillary structures; and where the development of a new facility was compatible with both zoning
and community needs and concerns. Utilizing one of its existing facilities would allow the proposed peaking generator to
capitalize on existing infrastructure and cause little to no impact on land use.
Technologies Considered
NRG Energy considered alternate technologies, including wind and solar, as well as combined-cycle and simple-cycle
combustion turbine technology. Based on its analyses, NRG Energy determined that the most acute capacity need in
ISO-NE is for meeting peak electrical demand periods. Wind and solar technology are recognized as important
elements in the region’s energy mix, and in fact NRG Renew Canal is proposing an approximately 1.5 MW solar project
on an adjacent site; however, their weather-dependency is not compatible with meeting peak demand capacity needs in
the most reliable manner possible. Combined-cycle units, ideal for base-load applications, are not the most costeffective technology to meet intermittent peak-load capacity needs and not appropriate for a peaking unit, due to longer
start-up and shutdown times. Therefore, NRG Energy selected simple-cycle turbine technology for the proposed Canal
Unit 3.
NRG Energy also considered alternate turbine sizes. Due to the superior efficiency (utilizing the least amount of fuel for
the most electrical output) and associated environmental advantages (generating the least amount of emissions for the
most electrical output) of “H-Class” combustion turbine technology compared to smaller turbines, NRG is currently
configuring to use the General Electric 7HA.02 combustion turbine, or a comparable turbine, for Canal Unit 3.
Off-Site Alternatives
NRG Canal 3 reviewed locations of existing, retired, planned retired, and abandoned power plant and other industrial
-51616571_1
facilities located within ISO-NE’s territory, including those owned by NRG. Since the non-NRG facilities were not under
ownership control of NRG, preference was given to NRG’s properties. NRG Energy, through direct and indirect
subsidiaries, operates seven electric generating stations within ISO-NE’s territory and evaluated each location in terms
of: available space; access to adequate natural gas, electric transmission and water infrastructure; and location within
the electrical grid. The six NRG-owned sites considered by NRG Energy are described below:
 Devon (Milford, CT) – The Devon facility is comprised of four, 50-MW dual-fueled combustion turbines. Since
this facility already has fast-start peaking units it was considered potentially suitable for additional capacity.
However, space limitations at the site precluded its ability to host the class of turbine selected for Canal Unit 3.
 Connecticut Jet Power (Hartford, CT) – The Hartford facility is actually comprised of four remote jet stations –
Cos Cob, Branford, Torrington (Franklin Drive), and Torrington Terminal. NRG Energy expanded the Cos Cob
site in June 2008 by adding two additional 20-MW units increasing capacity to 100 MW of peaking power.
Following the recent improvement projects, insufficient space exists at Connecticut Jet Power to host Canal
Unit 3.
 Middletown, CT – With placement along the Connecticut River, the Middletown site was considered a strong
option. Comprised of three steam units one combustion turbine and four combustion turbines associated with
GenConn Middletown. While a potentially suitable site, this location was deemed to be inferior to the selected
site due to the need to significantly alter existing critical infrastructure to accommodate new units.
 Montville (Uncasville, CT) – The 49-acre Uncasville facility is situated along the Thames River. The 500-MW
peaking station is comprised of four units. As part of NRG Energy’s repowering effort in Connecticut, a project
has already been proposed to repower 40 MW of unit 5 using clean wood biomass from nearby foresters and
sawmills as a fuel source. Since a project has already been contemplated at this facility, NRG Energy
eliminated the Uncasville site from further consideration.
 Martha’s Vineyard, MA – NRG Energy owns and operates two sites on Martha’s Vineyard. These sites have a
combined nominal electrical generating capacity of 13 MW fueled by distillate fuel oil and principally provide
back-up on-island energy. The lack of land, natural gas and electric infrastructure eliminated these sites from
consideration.
 Canal (Sandwich, MA) – The Sandwich site was selected as the most suitable location for a proposed peaking
unit based on the best combination of adequate space, sufficient natural gas supply, availability of water, and
proximity to an electric interconnection location within the ISO-NE sub-region with the greatest need.
On-Site Alternatives
NRG Energy considered alternative locations on the Canal Property and sited the proposed new unit proximate to the
existing units as this location best avoided natural resource encroachment, maximized distance to residences and other
sensitive off-site land uses, and would result in the least visual change from offsite vantage points. Various iterations of
equipment orientation were also considered, with selection of the proposed layout chosen as the most efficient and least
intrusive option.
NOTE: The purpose of the alternatives analysis is to consider what effect changing the parameters
and/or siting of a project, or components thereof, will have on the environment, keeping in mind that
the objective of the MEPA review process is to avoid or minimize damage to the environment to the
greatest extent feasible. Examples of alternative projects include alternative site locations,
alternative site uses, and alternative site configurations.
Summarize the mitigation measures proposed to offset the impacts of the preferred
alternative:
Impacts associated with Canal Unit 3 and Canal Community Solar will be avoided and/or minimized due to their
proposed locations at the existing Canal Generating Station. Utilizing an existing industrial site avoids undisturbed
natural resources and causes minimal to no change in land use.
Canal Unit 3 will be constructed with state-of-the-art emissions controls and will meet all applicable requirements for
Best Available Control Technology and Lowest Achievable Emissions Rate, as appropriate. Water use and discharge
have been minimized by selecting simple-cycle turbine technology with a dry low NOX combustion system and
-61616571_1
incorporation of a near-zero liquid discharge system, avoiding any process water discharge to the Cape Cod Canal or
other surface waterbody. Other design measures will be incorporated to minimize the potential impact of Canal Unit 3 on
surrounding areas, including locating the new unit immediately proximate to the existing units and minimizing stack
height to the greatest extent possible to minimize visual impacts. Canal Unit 3 also has integrated state-of-the-art sound
control measures to minimize noise impacts.
As discussed in the Expanded ENF, Canal Community Solar is not anticipated to require any additional mitigation
measures as its operation will produce no emissions, wastewater or noise. In fact, Canal Community Solar will have a
positive impact on the environment as electricity generated by Canal Community Solar will displace older more polluting
sources.
If the project is proposed to be constructed in phases, please describe each phase:
Phase 1 – Canal Community Solar
Phase 2 – Canal Unit 3
AREAS OF CRITICAL ENVIRONMENTAL CONCERN:
Is the project within or adjacent to an Area of Critical Environmental Concern?
Yes (Specify__________________________________)
No
If yes, does the ACEC have an approved Resource Management Plan? ___ Yes ___ No;
If yes, describe how the project complies with this plan. _______________________________
Will there be stormwater runoff or discharge to the designated ACEC? ___ Yes ___ No;
If yes, describe and assess the potential impacts of such stormwater runoff/discharge to the
designated ACEC.
RARE SPECIES:
Does the project site include Estimated and/or Priority Habitat of State-Listed Rare Species? (see
http://www.mass.gov/dfwele/dfw/nhesp/regulatory_review/priority_habitat/priority_habitat_home.htm)
Yes (Specify__________________________________ )
No
HISTORICAL /ARCHAEOLOGICAL RESOURCES:
Does the project site include any structure, site or district listed in the State Register of Historic Place
or the inventory of Historic and Archaeological Assets of the Commonwealth?
Yes (Old King’s Highway Regional Historic District [5/1/1973] & Canal Electric Company Plant [5/1/1973] )
No
If yes, does the project involve any demolition or destruction of any listed or inventoried historic
or archaeological resources?
Yes (Specify__________________________________)
No
WATER RESOURCES:
Is there an Outstanding Resource Water (ORW) on or within a half-mile radius of the project site?
___Yes _X_ No; if yes, identify the ORW and its location.
______________________________________
(NOTE: Outstanding Resource Waters include Class A public water supplies, their tributaries, and
bordering wetlands; active and inactive reservoirs approved by MassDEP; certain waters within
Areas of Critical Environmental Concern, and certified vernal pools. Outstanding resource waters
are listed in the Surface Water Quality Standards, 314 CMR 4.00.)
Are there any impaired water bodies on or within a half-mile radius of the project site? _X_ Yes __
No; if yes, identify the water body and pollutant(s) causing the impairment: __Cape Cod Canal - fecal
coliform (TMDL complete)________.
-71616571_1
Is the project within a medium or high stress basin, as established by the Massachusetts Water
Resources Commission? ___Yes _X_ No
STORMWATER MANAGEMENT:
Generally describe the project's stormwater impacts and measures that the project will take to comply
with the standards found in MassDEP's Stormwater Management Regulations:
Both projects will be designed in compliance with the MassDEP Stormwater Management Regulations. Practices to
control runoff and manage stormwater during and after construction will be designed and implemented at both the
Simple-Cycle Site and the Solar Site.
MASSACHUSETTS CONTINGENCY PLAN:
Has the project site been, or is it currently being, regulated under M.G.L.c.21E or the Massachusetts
Contingency Plan? _X_ Yes ___ No; if yes, please describe the current status of the site (including
Release Tracking Number (RTN), cleanup phase, and Response Action Outcome classification):
See Attachment 3 for list of Release Tracking Notification Numbers for the Property.
Is there an Activity and Use Limitation (AUL) on any portion of the project site? ___ Yes _X_ No; if yes,
describe which portion of the site and how the project will be consistent with the AUL: _____________.
Are you aware of any Reportable Conditions at the property that have not yet been assigned an RTN?
___ Yes _X_ No; if yes, please describe: _____________________________________.
SOLID AND HAZARDOUS WASTE:
If the project will generate solid waste during demolition or construction, describe alternatives
considered for re-use, recycling, and disposal of, e.g., asphalt, brick, concrete, gypsum, metal,
wood:
Material resulting from demolition of the concrete-slab, aluminum-sided warehouses will be re-used and recycled as
appropriate or disposed of at licensed facilities in accordance with existing sold waste disposal regulations.
(NOTE: Asphalt pavement, brick, concrete and metal are banned from disposal at Massachusetts
landfills and waste combustion facilities and wood is banned from disposal at Massachusetts
landfills. See 310 CMR 19.017 for the complete list of banned materials.)
Will your project disturb asbestos containing materials? ___ Yes _X_ No; if yes, please consult state
asbestos requirements at http://mass.gov/MassDEP/air/asbhom01.htm
Describe anti-idling and other measures to limit emissions from construction equipment:
MGL Chapter 90, Section 16A and the MassDEP idling reduction regulations (310 CMR 7.11(1)(b)) both prohibit
unnecessary vehicle idling and require that engines must be shut down if the vehicle will be stopped for more than five
minutes. This regulation will be included in the contract specifications for site construction contracts.
NOTE: MGL Chapter 90, Section 16A and the Massachusetts Department of Environmental
Protection (DEP) idling reduction regulation (310 CMR 7.11(1)(b)) both prohibit unnecessary vehicle
idling and require that engines must be shut down if the vehicle will be stopped for more than five
minutes. This regulation will be included in the contract specifications for all construction
subcontractors.
-81616571_1
DESIGNATED WILD AND SCENIC RIVER:
Is this project site located wholly or partially within a defined river corridor of a federally designated
Wild and Scenic River or a state designated Scenic River? ___ Yes _X_ No; if yes, specify name of river
and designation:
If yes, does the project have the potential to impact any of the “outstandingly remarkable”
resources of a federally Wild and Scenic River or the stated purpose of a state designated Scenic
River? ___ Yes ___ No; if yes, specify name of river and designation: _____________;
If yes, will the project will result in any impacts to any of the designated “outstandingly remarkable”
resources of the Wild and Scenic River or the stated purposes of a Scenic River. ___ Yes ___ No; if
yes, describe the potential impacts to one or more of the “outstandingly remarkable” resources or
stated purposes and mitigation measures proposed.
ATTACHMENTS:
1.
2.
3.
4.
5.
6.
7.
List of all attachments to this document. – See Attachment 1
U.S.G.S. map (good quality color copy, 8-½ x 11 inches or larger, at a scale of
1:24,000) indicating the project location and boundaries. – See Attachment 4, Figure 1
Plan, at an appropriate scale, of existing conditions on the project site and its
immediate environs, showing all known structures, roadways and parking lots,
railroad rights-of-way, wetlands and water bodies, wooded areas, farmland, steep
slopes, public open spaces, and major utilities. – See Attachment 5, Figures 2 and 3
Plan, at an appropriate scale, depicting environmental constraints on or adjacent to
the project site such as Priority and/or Estimated Habitat of state-listed rare species,
Areas of Critical Environmental Concern, Chapter 91 jurisdictional areas, Article 97
lands, wetland resource area delineations, water supply protection areas, and historic
resources and/or districts. – See Attachment 6, Figures 5 and 6
Plan, at an appropriate scale, of proposed conditions upon completion of project (if
construction of the project is proposed to be phased, there should be a site plan
showing conditions upon the completion of each phase). – See Attachment 7, Figure 4
List of all agencies and persons to whom the proponent circulated the ENF, in
accordance with 301 CMR 11.16(2). – See Attachment 8
List of municipal and federal permits and reviews required by the project, as
applicable. – See Attachment 9
-91616571_1
LAND SECTION – all proponents must fill out this section
I. Thresholds / Permits
A. Does the project meet or exceed any review thresholds related to land (see 301 CMR 11.03(1)
___ Yes _X_ No; if yes, specify each threshold:
II. Impacts and Permits
A. Describe, in acres, the current and proposed character of the project site, as follows:
Northern Area
Footprint of buildings
Internal roadways
Parking and other paved areas
Other altered areas
Undeveloped areas
Total: Project Site Acreage
Existing
___6____
___3____
___6____
___34___
___3____
___52___
Change
___1____
___2____
___0____
___-3___
___0____
___0____
Total
___7___
___5___
___6___
___31__
___3___
___52__
Existing
___0____
___0____
___0____
___17*___
___19____
___36___
Change
___0___
___0___
___0___
__8.2___
__-8.2___
___0___
Total
___0___
___0___
___0___
__25.2__
__10.8__
___36__
Southern Area
Footprint of buildings
Internal roadways
Parking and other paved areas
Other altered areas
Undeveloped areas
Total: Project Site Acreage
*4 acres occupied by oil tanks supporting the existing Canal Generating Station; 13 acres occupied by the
Eversource transmission corridor
B. Has any part of the project site been in active agricultural use in the last five years?
___ Yes _X_ No; if yes, how many acres of land in agricultural use (with prime state or
locally important agricultural soils) will be converted to nonagricultural use?
C. Is any part of the project site currently or proposed to be in active forestry use?
___ Yes _X_ No; if yes, please describe current and proposed forestry activities and
indicate whether any part of the site is the subject of a forest management plan approved by
the Department of Conservation and Recreation:
D. Does any part of the project involve conversion of land held for natural resources purposes in
accordance with Article 97 of the Amendments to the Constitution of the Commonwealth to
any purpose not in accordance with Article 97? ___ Yes _X_ No; if yes, describe:
D. Is any part of the project site currently subject to a conservation restriction, preservation
restriction, agricultural preservation restriction or watershed preservation restriction?
___ Yes _X_ No; if yes, does the project involve the release or modification of such
restriction? ___ Yes ___ No; if yes, describe:
E. Does the project require approval of a new urban redevelopment project or a fundamental
change in an existing urban redevelopment project under M.G.L.c.121A? ___ Yes _X_ No; if
yes, describe:
- 10 1616571_1
F. Does the project require approval of a new urban renewal plan or a major modification of
an existing urban renewal plan under M.G.L.c.121B? ___ Yes _X_ No; if yes, describe:
III. Consistency
A. Identify the current municipal comprehensive land use plan
Title: _The Sandwich Local Comprehensive Plan ___ Date: ____May 2009_____
B. Describe the project’s consistency with that plan with regard to:
1)
Economic Development: The projects involve the development of new electric
generating facilities within property already in use by an electric generating facility. The Northern Area is
zoned for industrial use, while the Southern Area is zoned as Business Limited 1. Although solar energy
generation is not currently a permitted use on land zoned as Business Limited 1, an overlay district has
been proposed which would make solar energy generation a permitted use. The Sustainable
Development Principles of Massachusetts, as adopted by the Town of Sandwich in their 2009
Comprehensive Plan, encourages concentrated development to conserve land and minimize adverse
impacts.
2)
Adequacy of Infrastructure: Transportation, water, and sewer infrastructure, built to
support the existing facility, is located adjacent to the north of the Solar Site and west of the Simple-Cycle
Site. Neither project will result in construction of new water or sewer infrastructure to a previously
unserved area.
3)
Open Space Impacts: Most of Canal Unit 3 is proposed on already disturbed portions
of the Property, which are currently occupied by trailers, tanks, storage warehouses, and temporary
parking. The Property is currently utilized to support the existing station, and development will not
represent a change in land use. Although portions of the Solar Site are undeveloped, vegetated area, as
further described in the Expanded ENF, no significant adverse impacts on open space resources are
anticipated.
4)
Compatibility with Adjacent Land Uses: Canal Unit 3 and Canal Community Solar
will be developed within land zoned for industrial and commercial development, and will be situated
adjacent to an existing steam electric generating station, which has been in operation since 1968. The
existing facility is water-dependent, and was constructed on the Cape Cod Canal to facilitate fuel
deliveries and provide constant access to water for its once-through cooling system. The Project will
utilize some of the infrastructure built to support the existing facility. There will be no new discharges of
wastewater to the Cape Cod Canal as a result of either project, and no in-water work is proposed.
C. Identify the current Regional Policy Plan of the applicable Regional Planning Agency (RPA)
RPA: __Cape Cod Commission__________________
Title: _Cape Cod Regional Policy Plan __ Date: _August 2012 (As Amended) __
D. Describe the project’s consistency with that plan with regard to:
1) Economic Development: Canal Unit 3 involves the development of a new simple-cycle
generating unit on the Northern Area. Canal Community Solar involves the development of a photovoltaic
solar array on the Southern Area. Both projects are proposed on property already developed to support a
steam electric generation station and designated as an Economic Center on the Cape Cod Regional Land
Use Vision Map. (Cape Cod Regional Policy Plan. August 2012. Page 14.) To minimize adverse impacts,
the Cape Cod Regional Policy Plan identifies the need for efficient and collocated land uses, and
emphasizes that towns should adopt policies and regulations that encourage development within
Economic Centers.
- 11 1616571_1
2) Adequacy of Infrastructure: Canal Unit 3 and Canal Community Solar will be constructed
within a property already developed to support a steam electric generating facility. Some of the existing
infrastructure, which currently supports this existing facility, is needed to serve the projects. Additionally,
the Cape Cod Regional Policy Plan identifies the need for adequate capital facilities and infrastructure,
such as a reliable energy source, to meet community and regional needs and support economic growth.
Canal Unit 3 will provide a flexible and reliable energy supply.
3) Open Space Impacts: Since Canal Unit 3 and Canal Community Solar will be contained
within a property already developed as an existing energy generating station, no impacts to any existing
open space areas in the Cape Cod Canal area are anticipated.
- 12 1616571_1
RARE SPECIES SECTION
I. Thresholds / Permits
A. Will the project meet or exceed any review thresholds related to rare species or habitat (see 301
CMR 11.03(2))? ___ Yes _X_ No; if yes, specify, in quantitative terms:
(NOTE: If you are uncertain, it is recommended that you consult with the Natural Heritage and
Endangered Species Program (NHESP) prior to submitting the ENF.)
B. Does the project require any state permits related to rare species or habitat? __Yes _X_ No
C. Does the project site fall within mapped rare species habitat (Priority or Estimated Habitat?) in the
current Massachusetts Natural Heritage Atlas (attach relevant page)? ___ Yes _X_ No.
D. If you answered "No" to all questions A, B and C, proceed to the Wetlands, Waterways, and
Tidelands Section. If you answered "Yes" to either question A or question B, fill out the remainder of
the Rare Species section below.
II. Impacts and Permits
A. Does the project site fall within Priority or Estimated Habitat in the current Massachusetts Natural
Heritage Atlas (attach relevant page)? _ _ Yes ___ No. If yes,
1. Have you consulted with the Division of Fisheries and Wildlife Natural Heritage and
Endangered Species Program (NHESP)? _ _ Yes ___No; if yes, have you received a
determination as to whether the project will result in the “take” of a rare species? ___ Yes
__ No; if yes, attach the letter of determination to this submission.
2. Will the project "take" an endangered, threatened, and/or species of special concern in
accordance with M.G.L. c.131A (see also 321 CMR 10.04)? ___ Yes _ _ No; if yes, provide
a summary of proposed measures to minimize and mitigate rare species impacts
3. Which rare species are known to occur within the Priority or Estimated Habitat?
4. Has the site been surveyed for rare species in accordance with the Massachusetts
Endangered Species Act? ___ Yes _ _ No.
4. If your project is within Estimated Habitat, have you filed a Notice of Intent or received an
Order of Conditions for this project? ___ Yes __ No; if yes, did you send a copy of the
Notice of Intent to the Natural Heritage and Endangered Species Program, in accordance
with the Wetlands Protection Act regulations? __ Yes __ No
B. Will the project "take" an endangered, threatened, and/or species of special concern in
accordance with M.G.L. c.131A (see also 321 CMR 10.04)? _ _ Yes _ _ No; if yes, provide a
summary of proposed measures to minimize and mitigate impacts to significant habitat:
- 13 1616571_1
WETLANDS, WATERWAYS, AND TIDELANDS SECTION
I. Thresholds / Permits
A. Will the project meet or exceed any review thresholds related to wetlands, waterways, and
tidelands (see 301 CMR 11.03(3))? _X_ Yes ___ No; if yes, specify, in quantitative terms:
11.03(3)(b)1.f – Alteration of ½ or more acres of any other wetlands – Canal Unit 3 will result in development
within 12 acres of Land Subject to Coastal Storm Flowage. Canal Community Solar will include a 0.31-acre
vegetated bio-retention area for stormwater management that will also be located with LSCSF.
B. Does the project require any state permits (or a local Order of Conditions) related to
wetlands, waterways, or tidelands? _X_ Yes ___ No; if yes, specify which permit:
MassDEP – Order of Conditions under Wetlands Protection Act associated with Land Subject to Coastal Storm
Flowage and buffer zone.
C. If you answered "No" to both questions A and B, proceed to the Water Supply Section. If
you answered "Yes" to either question A or question B, fill out the remainder of the Wetlands,
Waterways, and Tidelands Section below.
II. Wetlands Impacts and Permits
A. Does the project require a new or amended Order of Conditions under the Wetlands
Protection Act (M.G.L. c.131A)? _X_ Yes ___ No; if yes, has a Notice of Intent been filed? ___
Yes _X_ No; if yes, list the date and MassDEP file number: ______; if yes, has a local Order of
Conditions been issued? ___ Yes ___ No; Was the Order of Conditions appealed? ___ Yes
___ No. Will the project require a Variance from the Wetlands regulations? ___ Yes _X_ No.
B. Describe any proposed permanent or temporary impacts to wetland resource areas
located on the project site:
Construction of Canal Unit 3 will result in alteration of 12 acres within the 100-year floodplain, designated as
Land Subject to Coastal Storm Flowage (LSCSF) and considered a jurisdictional wetland. Of that, 10.6 acres
will be permanently altered for new structures and internal roadways.
No impacts to the Coastal Bank along the Cape Cod Canal edge of the Project Site will result from the
proposed facility. Less than 1,000 square feet of potential impact within the buffer zone of off-site Bordering
Vegetated Wetland is anticipated. No significant adverse impacts to the area’s ability to serve as flood
protection is anticipated.
Construction of Canal Community Solar will include a 0.31-acre vegetated bio-retention area for stormwater
management that will also be located within LSCSF. No adverse impact to this area’s ability to serve as flood
protection is anticipated.
C. Estimate the extent and type of impact that the project will have on wetland resources,
and indicate whether the impacts are temporary or permanent:
Coastal Wetlands
Area (square feet) or
Length (linear feet)
Temporary or
Permanent Impact?
Land Under the Ocean
Designated Port Areas
Coastal Beaches
Coastal Dunes
_______0_________
_______0_________
_______0_________
_______0_________
____________________
____________________
____________________
____________________
- 14 1616571_1
Barrier Beaches
Coastal Banks
Rocky Intertidal Shores
Salt Marshes
Land Under Salt Ponds
Land Containing Shellfish
Fish Runs
Land Subject to Coastal Storm Flowage
_______0_________
_______0_________
_______0_________
_______0_________
_______0_________
_______0_________
_______0_________
_______10.6*______
____________________
____________________
____________________
____________________
____________________
____________________
____________________
_____Permanent_______
* An additional 1.5 acres will be temporarily impacted during construction; however, this temporary use is not expected to
permanently impact any wetland resources. A 0.31-acre bio-retention area is proposed within LSCSF on the Solar Site.
Inland Wetlands
Bank (lf)
Bordering Vegetated Wetlands
Isolated Vegetated Wetlands
Land under Water
Isolated Land Subject to Flooding
Bordering Land Subject to Flooding
Riverfront Area
_______0_________
_______0_________
_______0_________
_______0_________
_______0_________
_______0_________
_______0_________
____________________
____________________
____________________
____________________
____________________
____________________
____________________
D. Is any part of the project:
1. proposed as a limited project? ___ Yes _X_ No; if yes, what is the area (in sf)? ___
2. the construction or alteration of a dam? ___ Yes _X_ No; if yes, describe:
3. fill or structure in a velocity zone or regulatory floodway? ___ Yes _X_ No
4. dredging or disposal of dredged material? ___ Yes _X_ No; if yes, describe the
volume of dredged material and the proposed disposal site:
5. a discharge to an Outstanding Resource Water (ORW) or an Area of Critical
Environmental Concern (ACEC)? ___ Yes _X_ No
6. subject to a wetlands restriction order? __ Yes _X_ No; if yes, identify the area (sf):
7. located in buffer zones? _X_ Yes ___ No; if yes, how much (in sf) _< 1,000__
E. Will the project:
1. be subject to a local wetlands ordinance or bylaw? _X_ Yes ___ No
2. alter any federally-protected wetlands not regulated under state law? ___ Yes _X_ No;
if yes, what is the area (sf)?
III. Waterways and Tidelands Impacts and Permits
A. Does the project site contain waterways or tidelands (including filled former tidelands)
that are subject to the Waterways Act, M.G.L.c.91? ___ Yes _X_ No; if yes, is there a
current Chapter 91 License or Permit affecting the project site? ___ Yes _ _ No; if yes,
list the date and license or permit number and provide a copy of the historic map used to
determine extent of filled tidelands:
Although neither the Simple-Cycle Site nor the Solar Site contains filled tidelands, there are several
Chapter 91 licenses associated with the Property for in-water work which occurred in the Cape Cod Canal
during the construction of the existing Canal Generating Station. The proposed projects do not include
any new in-water work, and will not require a new or modified Chapter 91 license.
B. Does the project require a new or modified license or permit under M.G.L.c.91? __ Yes
_ X_ No; if yes, how many acres of the project site subject to M.G.L.c.91 will be for nonwater-dependent use?
Current ___ Change ___ Total ___
If yes, how many square feet of solid fill or pile-supported structures (in sf)?
- 15 1616571_1
C. For non-water-dependent use projects, indicate the following:
Area of filled tidelands on the site: _____0_______________
Area of filled tidelands covered by buildings: _____0______
For portions of site on filled tidelands, list ground floor uses and area of each use:
___N/A___________
Does the project include new non-water-dependent uses located over flowed
tidelands? ___ Yes _X_ No
Height of building on filled tidelands _____N/A___________
Also show the following on a site plan: Mean High Water, Mean Low Water, Waterdependent Use Zone, location of uses within buildings on tidelands, and interior
and exterior areas and facilities dedicated for public use, and historic high and
historic low water marks.
D. Is the project located on landlocked tidelands? ___ Yes _X_ No; if yes, describe the
project’s impact on the public’s right to access, use and enjoy jurisdictional tidelands and
describe measures the project will implement to avoid, minimize or mitigate any adverse
impact:
E. Is the project located in an area where low groundwater levels have been identified by a
municipality or by a state or federal agency as a threat to building foundations?
___Yes _ X_ No; if yes, describe the project’s impact on groundwater levels and
describe measures the project will implement to avoid, minimize or mitigate any
adverse impact:
F. Is the project non-water-dependent and located on landlocked tidelands or waterways
or tidelands subject to the Waterways Act and subject to a mandatory EIR? __ Yes _X_ No;
(NOTE: If yes, then the project will be subject to Public Benefit Review and
Determination.)
G. Does the project include dredging? ___ Yes _X_ No; if yes, answer the following
questions:
What type of dredging? Improvement ___ Maintenance ___ Both ____
What is the proposed dredge volume, in cubic yards (cys) ________
What is the proposed dredge footprint ____length (ft) ___width (ft)
___depth (ft);
Will dredging impact the following resource areas?
Intertidal ___ Yes ___ No; if yes, _______ sq ft
Outstanding Resource Waters ___ Yes ___ No; if yes, _______ sq ft
Other resource area (i.e. shellfish beds, eel grass beds) ___ Yes ___ No; if
yes ______ sq ft
If yes to any of the above, have you evaluated appropriate and practicable
steps to: 1) avoidance; 2) if avoidance is not possible, minimization; 3) if
either avoidance or minimize is not possible, mitigation?
If no to any of the above, what information or documentation was used to
support this determination?
Provide a comprehensive analysis of practicable alternatives for improvement
dredging in accordance with 314 CMR 9.07(1)(b). Physical and chemical data of
the sediment shall be included in the comprehensive analysis.
- 16 1616571_1
Sediment Characterization
Existing gradation analysis results? ___Yes ___No: if yes, provide results.
Existing chemical results for parameters listed in 314 CMR 9.07(2)(b)6?
___Yes ___ No; if yes, provide results.
Do you have sufficient information to evaluate feasibility of the following
management options for dredged sediment? If yes, check the appropriate option.
Beach Nourishment ___
Unconfined Ocean Disposal ___
Confined Disposal:
Confined Aquatic Disposal (CAD) ___
Confined Disposal Facility (CDF) ___
Landfill Reuse in accordance with COMM-97-001 ___
Shoreline Placement ___
Upland Material Reuse____
In-State landfill disposal____
Out-of-state landfill disposal ____
(NOTE: This information is required for a 401 Water Quality Certification.)
IV. Consistency:
A. Does the project have effects on the coastal resources or uses, and/or is the project
located within the Coastal Zone? _X_ Yes ___ No; if yes, describe these effects and the
projects consistency with the policies of the Office of Coastal Zone Management:
Like all of Cape Cod, the Canal Unit 3 and Canal Community Solar are located in the coastal zone,
but are not expected to have adverse effects on coastal resources areas or uses. See Attachment 10
– CZM Consistency. Further information on Coastal Zone consistency of the Solar Site is discussed in
Attachment 2.
B. Is the project located within an area subject to a Municipal Harbor Plan? ___ Yes _X_ No;
if yes, identify the Municipal Harbor Plan and describe the project's consistency with that
plan:
- 17 1616571_1
WATER SUPPLY SECTION
I. Thresholds / Permits
A. Will the project meet or exceed any review thresholds related to water supply (see 301
CMR 11.03(4))? ___ Yes _ X_ No; if yes, specify, in quantitative terms:
B. Does the project require any state permits related to water supply? _X_ Yes ___ No; if
yes, specify which permit:
Water Management Act Approval
C. If you answered "No" to both questions A and B, proceed to the Wastewater Section. If
you answered "Yes" to either question A or question B, fill out the remainder of the Water
Supply Section below.
II. Impacts and Permits
A. Describe, in gallons per day (gpd), the volume and source of water use for existing and
proposed activities at the project site:
Existing
Change
Total
Municipal or regional water supply
___0_____
___0_____
____0____
Withdrawal from groundwater
_449,315__
_125,129*__
_574,444__
Withdrawal from surface water
518,000,000
___0_____
518,000,000
Interbasin transfer
___0_____
___0_____
____0____
*All withdrawal from groundwater is in support of Canal Unit 3; Canal Community Solar does not
require any water for operation
(NOTE: Interbasin Transfer approval will be required if the basin and community where the
proposed water supply source is located is different from the basin and community where the
wastewater from the source will be discharged.)
B. If the source is a municipal or regional supply, has the municipality or region indicated
that there is adequate capacity in the system to accommodate the project? ___ Yes ___ No
N/A
C. If the project involves a new or expanded withdrawal from a groundwater or surface water
source, has a pumping test been conducted? _X__ Yes ___ No; if yes, attach a map of the
drilling sites and a summary of the alternatives considered and the results.
Well No. 4 was installed and constructed by the R.E. Chapman Company between December 2000 and
February 2001 to a depth of 146 feet below ground surface (bgs). The well was constructed using 12-inch
casing and an 8-inch telescoping screen with 20 to 30 slot openings from 117 to 142 feet bgs. Installation of
this well was based on a pair of 2.5-inch diameter test wells that indicated the presence of moderately
permeable sands between depths of about 120 to 150 feet in the area of Well No. 4. See Attachment 11,
Figure 8 for a map of drilling sites. Well No. 4 was previously developed but not brought online.
There are two existing supply wells, Wells No. 2 and 3, which serve the Canal Generating Station, located
adjacent to the west of the proposed Simple-Cycle Site. Withdrawals from Wells No. 2 and 3 are authorized
under the Canal Generating Station’s existing Water Management Act Registration. When installed, these
wells produced 339 and 425 gpm, respectively. About 100 borings were drilled at the Canal Generating
Station during the design of Unit 1 and 2. Eight additional borings were installed east of Unit 2 in 2001 to
provide additional subsurface data. Therefore, the understanding of the underlying aquifer and lithology of
the glacial sediments in the area is extensive.
- 18 1616571_1
A pumping testing, conducted in April 2001, demonstrated that Well No. 4 would yield 400 gallons per
minute (gpm), with a pumping level (drawdown) of about 35 feet bgs even while pumping nearby wells at
normal rates. The pumping test indicates a stabilized specific capacity of approximately 11
gallons/minute/foot after correction for tidal fluctuation. Therefore, based on well construction details the
withdrawal potential (or safe yield) from this well is most likely significantly higher than 400 gpm.
A set of piezometers, installed to observe the effects of the pumping on nearby wetlands, confirmed that no
adverse impacts were anticipated. Water quality monitoring was recommended to confirm that any resulting
shift in the position of the interface between fresh water and salt water would not degrade water quality in
the supply wells.
Additional withdrawal from Wells No. 2 and 3 was considered, however, withdrawal from previously developed,
but currently unused, Well No. 4 was determined to provide greater reliability to the proposed Canal Unit 3
project.
D. What is the currently permitted withdrawal at the proposed water supply source (in
gallons per day)? 0 gpd
Will the project require an increase in that withdrawal? _X_ Yes
__ No; if yes, then how much of an increase (gpd)? ___125,129 gpd________________
E. Does the project site currently contain a water supply well, a drinking water treatment
facility, water main, or other water supply facility, or will the project involve construction of a
new facility? _X_ Yes ___No. If yes, describe existing and proposed water supply facilities at
the project site:
See Section C, above, regarding the Water Management Act Registration for existing Well No. 2 and 3. Well
No. 4, previously developed but not currently used, is proposed to serve Canal Unit 3 and will be permitted.
Permitted
Flow
Capacity of water supply well(s) (gpd) ___ 0____
Capacity of water treatment plant (gpd) __N/A____
Existing Avg
Daily Flow
___0_____
___N/A___
Project Flow
Total
_125,129__
__ N/A___
_125,129__
__N/A____
F. If the project involves a new interbasin transfer of water, which basins are involved, what
is the direction of the transfer, and is the interbasin transfer existing or proposed?
N/A
G. Does the project involve:
1. new water service by the Massachusetts Water Resources Authority or other
agency of the Commonwealth to a municipality or water district? ___ Yes _X_ No
2. a Watershed Protection Act variance? ___ Yes _X_ No; if yes, how many acres of
alteration?
3. a non-bridged stream crossing 1,000 or less feet upstream of a public surface
drinking water supply for purpose of forest harvesting activities? ___ Yes _X_ No
III. Consistency
Describe the project's consistency with water conservation plans or other plans to enhance
water resources, quality, facilities and services:
NRG Canal 3 proposes to use Well No. 4, a previously developed but not previously permitted or brought on
line, located on the Simple-Cycle Site. As a private well, this water supply will not impact any municipal supply
system. Best available conservation technology has been incorporated into the design of proposed projects
wherever possible.
- 19 1616571_1
WASTEWATER SECTION
I. Thresholds / Permits
A. Will the project meet or exceed any review thresholds related to wastewater (see 301 CMR
11.03(5))? ___ Yes _X_ No; if yes, specify, in quantitative terms:
B. Does the project require any state permits related to wastewater? ___ Yes _X_ No; if yes,
specify which permit:
C. If you answered "No" to both questions A and B, proceed to the Transportation -- Traffic
Generation Section. If you answered "Yes" to either question A or question B, fill out the remainder
of the Wastewater Section below.
II. Impacts and Permits
A. Describe the volume (in gallons per day) and type of disposal of wastewater generation for
existing and proposed activities at the project site (calculate according to 310 CMR 15.00 for septic
systems or 314 CMR 7.00 for sewer systems):
Discharge of sanitary wastewater
Discharge of industrial wastewater
TOTAL
Discharge to groundwater
Discharge to outstanding resource water
Discharge to surface water
Discharge to municipal or regional wastewater
Facility
TOTAL
Existing
Change
Total
________
________
________
________
________
________
________
________
________
Existing
________
________
________
Change
________
________
________
Total
________
________
________
________
________
________
________
________
________
B. Is the existing collection system at or near its capacity? ___ Yes ____ No; if yes, then describe
the measures to be undertaken to accommodate the project’s wastewater flows:
C. Is the existing wastewater disposal facility at or near its permitted capacity? ___ Yes ___ No; if
yes, then describe the measures to be undertaken to accommodate the project’s wastewater flows:
D. Does the project site currently contain a wastewater treatment facility, sewer main, or other
wastewater disposal facility, or will the project involve construction of a new facility? ___ Yes ___
No; if yes, describe as follows:
Wastewater treatment plant capacity
(in gallons per day)
Permitted
Existing Avg
Daily Flow
Project Flow
Total
_______
________
________
________
E. If the project requires an interbasin transfer of wastewater, which basins are involved, what is the
direction of the transfer, and is the interbasin transfer existing or new?
(NOTE: Interbasin Transfer approval may be needed if the basin and community where wastewater
will be discharged is different from the basin and community where the source of water supply is
located.)
- 20 1616571_1
F. Does the project involve new sewer service by the Massachusetts Water Resources Authority
(MWRA) or other Agency of the Commonwealth to a municipality or sewer district? ___ Yes ___ No
G. Is there an existing facility or is a new facility proposed at the project site for the storage,
treatment, processing, combustion or disposal of sewage sludge, sludge ash, grit, screenings,
wastewater reuse (gray water) or other sewage residual materials? __ Yes __ No; if yes, what is the
capacity (tons per day):
Existing
________
________
________
________
________
Storage
Treatment
Processing
Combustion
Disposal
Change
________
________
________
________
________
Total
________
________
________
________
________
H. Describe the water conservation measures to be undertaken by the project, and other
wastewater mitigation, such as infiltration and inflow removal.
III. Consistency
A. Describe measures that the proponent will take to comply with applicable state, regional, and
local plans and policies related to wastewater management:
B. If the project requires a sewer extension permit, is that extension included in a comprehensive
wastewater management plan? ___ Yes ___ No; if yes, indicate the EEA number for the plan
and whether the project site is within a sewer service area recommended or approved in that
plan:
- 21 1616571_1
TRANSPORTATION SECTION (TRAFFIC GENERATION)
I. Thresholds / Permit
A. Will the project meet or exceed any review thresholds related to traffic generation (see 301 CMR
11.03(6))? ___ Yes _X_ No; if yes, specify, in quantitative terms:
B. Does the project require any state permits related to state-controlled roadways? ___ Yes _X_
No; if yes, specify which permit:
C. If you answered "No" to both questions A and B, proceed to the Roadways and Other
Transportation Facilities Section. If you answered "Yes" to either question A or question B, fill out
the remainder of the Traffic Generation Section below.
II. Traffic Impacts and Permits
A. Describe existing and proposed vehicular traffic generated by activities at the project site:
Existing
Change
Total
Number of parking spaces
_______
________
_______
Number of vehicle trips per day
________
________
________
ITE Land Use Code(s):
________
________
________
B. What is the estimated average daily traffic on roadways serving the site?
Roadway
Existing
Change
1. ___________________
________
________
2. ____________________
________
________
3. ____________________
________
________
Total
________
________
________
C. If applicable, describe proposed mitigation measures on state-controlled roadways that the
project proponent will implement:
D. How will the project implement and/or promote the use of transit, pedestrian and bicycle facilities
and services to provide access to and from the project site?
C. Is there a Transportation Management Association (TMA) that provides transportation demand
management (TDM) services in the area of the project site? ____ Yes ____ No; if yes, describe
if and
how will the project will participate in the TMA:
D. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation
facilities? ____ Yes ____ No; if yes, generally describe:
E. If the project will penetrate approach airspace of a nearby airport, has the proponent filed a
Massachusetts Aeronautics Commission Airspace Review Form (780 CMR 111.7) and a Notice
of Proposed Construction or Alteration with the Federal Aviation Administration (FAA) (CFR Title
14 Part 77.13, forms 7460-1 and 7460-2)?
III. Consistency
Describe measures that the proponent will take to comply with municipal, regional, state, and federal
plans and policies related to traffic, transit, pedestrian and bicycle transportation facilities and
services:
- 22 1616571_1
TRANSPORTATION SECTION (ROADWAYS AND OTHER TRANSPORTATION
FACILITIES)
I. Thresholds
A. Will the project meet or exceed any review thresholds related to roadways or other
transportation facilities (see 301 CMR 11.03(6))? ___ Yes _X_ No; if yes, specify, in
quantitative terms:
B. Does the project require any state permits related to roadways or other transportation
facilities? _X_ Yes ___ No; if yes, specify which permit:
MassDOT Approval under M.G.L. Ch. 40, Section 54A
C. If you answered "No" to both questions A and B, proceed to the Energy Section. If you
answered "Yes" to either question A or question B, fill out the remainder of the Roadways
Section below.
II. Transportation Facility Impacts
A. Describe existing and proposed transportation facilities in the immediate vicinity of the
project site:
Existing NRG-owned rail spurs, located on the Simple-Cycle Site, may be considered appurtenant to
railroad right-of-way and require approval by MassDOT under M.G.L. Ch. 40, Section 54A.
B. Will the project involve any:
1. Alteration of bank or terrain (in linear feet)?
2. Cutting of living public shade trees (number)?
3. Elimination of stone wall (in linear feet)?
____No______
____No______
____No______
III. Consistency -- Describe the project's consistency with other federal, state, regional, and local
plans and policies related to traffic, transit, pedestrian and bicycle transportation facilities
and services, including consistency with the applicable regional transportation plan and the
Transportation Improvements Plan (TIP), the State Bicycle Plan, and the State Pedestrian
Plan:
Approval under M.G.L. Ch. 40, Section 54A is sought for private rail spurs located on the Simple-Cycle Site.
The private railroad spurs are owned and operated by NRG Canal and were never owned or operated by any
railroad company or by the Commonwealth. Therefore, project-related activities will not impact the
Transportation Improvements Plan, the State Bicycle Plan or the State Pedestrian Plan.
- 23 1616571_1
ENERGY SECTION
I. Thresholds / Permits
A. Will the project meet or exceed any review thresholds related to energy (see 301 CMR
11.03(7))? _X_ Yes ___ No; if yes, specify, in quantitative terms:
301 CMR 11.03(7)(a)2 – expansion of an existing electric generating facility by 100 or more MW – The Project
has a net nominal generating capacity of 331.5 MW, with Canal Unit 3 generating 330 MW and Canal
Community Solar generating approximately 1.5 MW.
B. Does the project require any state permits related to energy? _X_ Yes ___ No; if yes,
specify which permit:
Energy Facilities Siting Board – Approval of Petition to Construct*
Department of Public Utilities – Grant of Exemption from Zoning Requirements*
*Required for Canal Unit 3, but not for Canal Community Solar
C. If you answered "No" to both questions A and B, proceed to the Air Quality Section. If you
answered "Yes" to either question A or question B, fill out the remainder of the Energy
Section below.
II. Impacts and Permits
A. Describe existing and proposed energy generation and transmission facilities at the
project site:
Existing
Change
Total
Capacity of electric generating facility (megawatts) _1,120__
_331.5*__
_1,451.5_
Length of fuel line (in miles)**
___0___
__0.68___
__0.68__
Length of transmission lines (in miles)***
___0____
__1.05___
__1.05__
Capacity of transmission lines (in kilovolts)
__345___
___0____
__345___
* 330 MW from Canal Unit 3; approximately 1.5 MW from Canal Community Solar
** A 0.64 mile ULSD line and a 0.68 mile natural gas pipeline are proposed for Canal unit 3. Both will be entirely contained
within the Property.
*** Canal Unit 3 will connect to an electrical switchyard owned by Eversource located proximate to the south of the
Property via an approximately 0.8 mile transmission line. Canal Community Solar will include approximately 0.25 mile of
underground circuit and a new 22.8-kV three-phase overhead circuit proposed on the Solar Site, which will connect Canal
Community Solar to the existing Eversource 22.8-kV three-phase overhead distribution circuit along Route 6A, south of the
Solar Site.
B. If the project involves construction or expansion of an electric generating facility, what are:
1. the facility's current and proposed fuel source(s)?
The existing Canal Generating Station includes two steam-electric generating units capable of
running on Number 6 fuel oil or natural gas. The proposed Canal Unit 3 project will be capable of
running on either natural gas or ultra-low sulfur distillate. The proposed Canal Community Solar
project will run on light energy (photons) from the sun.
2. the facility's current and proposed cooling source(s)?
The existing Canal Generating Station utilizes a once-through cooling system which withdraws
water from the Cape Cod Canal. The proposed Canal Unit 3 project, as a simple-cycle facility,
does not require steam condenser cooling. Air-cooled fin fan coolers will be utilized for ancillary
- 24 1616571_1
equipment cooling. Canal Community Solar does not require any cooling source.
C. If the project involves construction of an electrical transmission line, will it be located on a
new, unused, or abandoned right of way? ___Yes _N/A_ No; if yes, please describe:
D. Describe the project's other impacts on energy facilities and services:
Canal Unit 3 will connect to the existing electrical switchyard located adjacent to the south of the Property.
Canal Unit 3 will be served by an existing Algonquin Gas Transmission Company (Algonquin) gas transmission
line, which currently serves the existing station. Due to pressure differences in facility requirements, a separate
piping corridor will extend from the existing Algonquin line across the Property to the Simple-Cycle Site.
III. Consistency
Describe the project's consistency with state, municipal, regional, and federal plans and
policies for enhancing energy facilities and services:
The Cape Cod Commission Regional Policy Plan states that adequate, high-quality infrastructure, including a
reliable energy source, is necessary for economic growth. Canal Unit 3, as a simple-cycle peaking unit, will act
as an efficient, flexible source of electricity for the region. In accordance with this regional plan, the Town of
Sandwich’s Local Comprehensive Plan also indicates a need for regional infrastructure, such as energy supply,
to meet community and regional needs.
In addition, Canal Community Solar is also consistent with the Global Warming Act’s goal of reduced reliance
on carbon-based generation.
- 25 1616571_1
AIR QUALITY SECTION
I. Thresholds
A. Will the project meet or exceed any review thresholds related to air quality (see 301 CMR
11.03(8))? _X_ Yes ___ No; if yes, specify, in quantitative terms:
301 CMR 11.03(8)(a)2. – Modification of an existing Stationary Source with federal potential emissions that
collectively will result, after construction and the imposition of required controls, of 75,000 tpy of GHGs based
on CO2 Equivalent. The collective emissions from Canal Unit 3 will be 1,001,028 tpy of GHGs (as CO2e).
301 CMR 11.03(8)(b)2 - Modification of an existing stationary source resulting in a "significant net increase" in
actual emissions, provided that the stationary source or facility is major for the pollutant, emission of which is
increased by: 15 tpy of PM as PM10; 100 tpy of CO; 40 tpy of SO2; 25 tpy of VOC or NOX; 0.6 tpy of lead – The
proposed Canal Unit 3 project will have potential emissions of 108.4 tons per year of NOX and 98.6 tons per
year of PM. Canal Unit 3 is below the modification thresholds for the other pollutants specified in 301 CMR
11.03(8)(b)2.
B. Does the project require any state permits related to air quality? _X_ Yes ___ No; if yes,
specify which permit:
MassDEP – Air Plan Approval/NSR Review/Title V Operating Permit Modification
MassDEP – Federal PSD Permit
C. If you answered "No" to both questions A and B, proceed to the Solid and Hazardous
Waste Section. If you answered "Yes" to either question A or question B, fill out the
remainder of the Air Quality Section below.
II. Impacts and Permits
A. Does the project involve construction or modification of a major stationary source (see
310 CMR 7.00, Appendix A)? _X_ Yes ___ No; if yes, describe existing and proposed
emissions (in tons per day) of:
Existing
Change1
Total
__2.58__
_130.16_
_142.10_
__0.65__
__36.17__
_0.00130_
__0.31___
_20,964__
Particulate matter
Carbon monoxide
Sulfur dioxide
Volatile organic compounds
Oxides of nitrogen
Lead
Any hazardous air pollutant
Carbon dioxide
1
__1.16__
__0.49__
__0.06__
__0.11___
__0.81___
_0.00003_
__0.01___
__6,760___
__3.74___
_130.65__
_142.16__
__0.76___
__36.98__
_0.00133_
__0.32___
_27,724__
Emissions data are for Canal Unit 3
B. Describe the project's other impacts on air resources and air quality, including noise
impacts:
Canal Unit 3 will incorporate state-of-the-art emission controls and will comply with all regulations and standards
associated with air quality. Noise mitigation will be incorporated in the design of Canal Unit 3 to comply with
applicable standards and prevent significant impact to nearby sensitive receptors.
The beneficial impacts of Canal Community Solar on air quality are discussed in Attachment 2.
- 26 1616571_1
III. Consistency
A. Describe the project's consistency with the State Implementation Plan:
Canal Unit 3 and Canal Community Solar will meet the requirements of all applicable federal and state
regulations. Therefore, both projects will be consistent with the State Implementation Plan.
B. Describe measures that the proponent will take to comply with other federal, state,
regional, and local plans and policies related to air resources and air quality:
Canal Unit 3 will comply with all applicable Best Available Control Technology (BACT) requirements and will meet
the Lowest Achievable Emission Rate (LAER) for NOX by incorporating low NOX combustion technology with
selective catalytic reduction. An oxidation catalyst system will be used to reduce carbon monoxide emissions with
an anticipated co-benefit of a reduction of volatile organic compound emissions.
Canal Unit 3 will comply with the Regional Greenhouse Gas Initiative (RGGI) and obtain CO2 allowances, as
required. Both Canal Unit 3 and Canal Community Solar will also adhere to the Executive Office of Energy and
Environmental Affairs Greenhouse Gas Policy.
- 27 1616571_1
SOLID AND HAZARDOUS WASTE SECTION
I. Thresholds / Permits
A. Will the project meet or exceed any review thresholds related to solid or hazardous waste (see
301 CMR 11.03(9))? ___ Yes _X_ No; if yes, specify, in quantitative terms:
B. Does the project require any state permits related to solid and hazardous waste? __Yes _X_
No; if yes, specify which permit:
C. If you answered "No" to both questions A and B, proceed to the Historical and Archaeological
Resources Section. If you answered "Yes" to either question A or question B, fill out the
remainder of the Solid and Hazardous Waste Section below.
II. Impacts and Permits
A. Is there any current or proposed facility at the project site for the storage, treatment, processing,
combustion or disposal of solid waste? ___ Yes ___ No; if yes, what is the volume (in tons per day)
of the capacity:
Existing
Change
Total
Storage
________
________
________
Treatment, processing ________
________
________
Combustion
________
________
________
Disposal
________
________
________
B. Is there any current or proposed facility at the project site for the storage, recycling, treatment or
disposal of hazardous waste? ___ Yes ___ No; if yes, what is the volume (in tons or gallons per day)
of the capacity:
Storage
Recycling
Treatment
Disposal
Existing
________
________
________
________
Change
________
________
________
________
Total
________
________
________
________
C. If the project will generate solid waste (for example, during demolition or construction), describe
alternatives considered for re-use, recycling, and disposal:
D. If the project involves demolition, do any buildings to be demolished contain asbestos?
___ Yes ___ No
E. Describe the project's other solid and hazardous waste impacts (including indirect impacts):
III. Consistency
Describe measures that the proponent will take to comply with the State Solid Waste Master Plan:
- 28 1616571_1
HISTORICAL AND ARCHAEOLOGICAL RESOURCES SECTION
I. Thresholds / Impacts
A. Have you consulted with the Massachusetts Historical Commission? _X_ Yes ___ No; if
yes, attach correspondence. For project sites involving lands under water, have you
consulted with the Massachusetts Board of Underwater Archaeological Resources? ____Yes
_N/A_ No; if yes, attach correspondence.
See Attachment 13.
B. Is any part of the project site a historic structure, or a structure within a historic district, in
either case listed in the State Register of Historic Places or the Inventory of Historic and
Archaeological Assets of the Commonwealth? _X_ Yes ___ No; if yes, does the project
involve the demolition of all or any exterior part of such historic structure? ___ Yes _X_ No; if
yes, please describe:
The projects are proposed within the property boundaries of the Canal Generating Station, a Historic Site listed
on the Massachusetts State Register of Historic Places (SRHP) and recognized by the Town of Sandwich. The
Property is also within the Old King’s Highway Historic District, a district first listed on the SRHP in 1973 and the
National Register of Historic Places in 1987. As part of this Historic District, all proposed development on the
Property must be reviewed and approved by the town’s Old King’s Highway Historic Commission. Neither
project involves the demolition of any existing historic structures.
C. Is any part of the project site an archaeological site listed in the State Register of Historic
Places or the Inventory of Historic and Archaeological Assets of the Commonwealth? ___ Yes
_X_ No; if yes, does the project involve the destruction of all or any part of such
archaeological site? ___ Yes ___ No; if yes, please describe:
D. If you answered "No" to all parts of both questions A, B and C, proceed to the
Attachments and Certifications Sections. If you answered "Yes" to any part of either
question A or question B, fill out the remainder of the Historical and Archaeological
Resources Section below.
II. Impacts
Describe and assess the project's impacts, direct and indirect, on listed or inventoried
historical and archaeological resources:
The projects are located on the Canal Generating Station, which was designated by the Town of Sandwich as a
Historic Site within the Old King’s Highway Regional Historic District in the 1970s. Proposed structural
development and alterations in this District are subject to review and approval by the Town’s Old King’s
Highway Historic Commission. Canal Unit 3 is consistent with current land use and zoning, and is aligned with
the goals and policies of the Town; however, Canal Community Solar is proposed on property zoned as
Business Limited 1 and under the local zoning regulations, solar energy generation is not a permitted use. An
overlay district has been proposed which would allow solar energy generation on this Property. The projects
are not anticipated to directly or indirectly impact any known historical or archaeological resources.
III. Consistency
Describe measures that the proponent will take to comply with federal, state, regional, and
local plans and policies related to preserving historical and archaeological resources:
The projects are aligned with the goals and policies of the Town, and marks no significant change in land use.
The Cape Cod Commission identifies the Property as within an Economic Center, and encourages
industrial/commercial development. The Town of Sandwich outlines the need for efficient land use, specifically
- 29 1616571_1
emphasizing collocation. As the Property is already occupied by an electric generation facility, and zoned for
industrial and commercial development, the projects are not anticipated to significantly impact any known
historical or archaeological resources.
- 30 1616571_1
Attachment 1: List of All Attachments

Attachment 1: List of All Attachments

Attachment 2: Expanded Environmental Notification Form / Phase I Waiver Request

Attachment 3: List of Release Tracking Notifications

Attachment 4: Project Locus Maps


o
Figure 1 – USGS Locus Map (as required by both MEPA and CCC)
o
Figure 2 – Project Overview Aerial Photograph
o
Figure 3 – Project Site Aerial Photograph
Attachment 5: Constraint Maps
o
Figure 4 – Environmental Constraints
o
Figure 5 – Cultural Constraints
Attachment 6: Site Plan
o

Figure 6 – Existing Conditions Plan (as required by both MEPA and CCC)
Attachment 7: Proposed Development Plans
o
Figure 7 – Proposed Site Plan (as required by both MEPA and CCC)

Attachment 8: ENF Circulation List

Attachment 9: List of Federal, State, and Municipal Agency Permits Potentially Required
by the Canal Unit 3 (as required by both MEPA and CCC)

Attachment 10: CZM Consistency

Attachment 11: Water Supply Section Figure
o
Figure 8 – Map of Drilling Sites for Well No. 4

Attachment 12: Application Cover Sheet (as required by CCC)

Attachment 13: Certified List of Abutting Property Owners for Canal Unit 3 (as required by
CCC)

Attachment 14: MHC Notification Form (as required by CCC)
o

Attachment 15: Certification of Local Filing (as required by CCC)
o

Proof of Receipt of PNF by MHC
Exhibit A: Service List
Attachment 16: Photographs of the Simple-Cycle Site (as required by CCC)
Attachment 2: Expanded Environmental Notification Form / Phase I Waiver Request
Introduction
In accordance with Section 11.05(7) of the Massachusetts Environmental Policy Act (MEPA) regulations at
301 CMR 11.00, NRG Canal 3 Development LLC (NRG Canal 3) and NRG Renew Canal 1 LLC (NRG
Renew Canal) are submitting this Expanded Environmental Notification Form (Expanded ENF) with a
Request for a Phase I Waiver so that Canal Community Solar, as defined below, can proceed in advance
of Canal Unit 3, as defined below.
NRG Energy, Inc. (NRG Energy) is a Fortune 200 energy company, supporting clean energy resources and
technologies critical to our transition to a sustainable, low-carbon society. NRG Energy’s diverse power
generating facilities have a capacity of over 50,000 megawatts (MW), capable of supporting nearly 1/3 of
the U.S. population. NRG Energy electricity providers serve nearly 3 million recurring retail customers.
NRG Canal 3 is a business affiliate of NRG Energy’s Wholesale Business division, a separate business
unit within NRG Energy focusing on wholesale electricity generation. NRG Renew Canal is a business
affiliate of NRG’s Renew division, a separate business unit within NRG Energy focusing on renewable
energy projects.
Canal Unit 3: NRG Canal 3 seeks to permit, construct, and operate a state-of-the-art, fast-starting, dualfueled simple-cycle electric generating facility (Canal Unit 3). Canal Unit 3 will consist of a single
combustion turbine with an approximate net nominal capacity of 330 MW that will operate during peak times
of energy demand, for up to 4,380 hours per year. Natural gas will be the primary fuel, with a maximum
equivalent of 1,440 hours using the backup fuel, ultra-low sulfur distillate (ULSD), to provide the flexibility
and reliability to meet the region’s demonstrated power needs. Canal Unit 3 will include an approximately
215-foot tall stack.
Canal Community Solar: NRG Renew Canal seeks to permit, construct, and operate an approximately 1.5MW state-of-the-art solar photovoltaic community solar garden array (Canal Community Solar). NRG
Renew Canal is requesting a Phase I Waiver for Canal Community Solar, which is the subject of this
Expanded ENF.
Existing Site Conditions
NRG Canal LLC, an affiliate of NRG Energy, owns approximately 88 acres of land in the town of Sandwich,
at which the existing Canal Generating Station and ancillary structures and infrastructure are currently
located (the Property). As shown on Figure 1, the Property is comprised of two separate areas. As
described further below, the two areas are not physically contiguous to one another. Rather, the two areas
are bisected by a separate parcel owned by the Massachusetts Department of Transportation (MassDOT)
and operated as an active railroad right-of-way (ROW) by the Cape Cod Central Railroad. However, due
to the common ownership of the two areas and their close proximity to one another, the two areas will be
treated as one “property” for purposes of MEPA review.
The northern portion of the Property (the Northern Area) comprises approximately 52 acres (approximately
48 acres of land above water and 4 acres of land under the water) on which in-water work was completed
for infrastructure associated with the existing Canal Generating Station. The Northern Area is bounded by
Freezer Road and land owned by the United States Army Corps of Engineers (USACE) to the east; Canal
Service Road and the Cape Cod Canal to the north; the town of Bourne to the west; and Rickey’s Road
and the railroad ROW to the south. Like all of Cape Cod, the Northern Area is located within the
Massachusetts Coastal Zone, and a majority of the Northern Area is located within the FEMA-Mapped 100year flood zone. The Northern Area is zoned “Industrial Limited.”
The majority of the Northern Area is currently developed to support the existing Canal Generating Station,
which includes two dual-fueled electric generation units totaling approximately 1,120 MW, a 498-foot high
exhaust stack, several aboveground oil storage tanks, ammonia storage tanks, and appurtenant structures
1
and infrastructure. The existing Canal Generating Station occupies the western portion of the Northern
Area with some facilities and equipment located across portions of the 12-acre area on which temporary
impact from Canal Unit 3 is proposed (the Simple-Cycle Site). The Canal Generating Station connects to
an existing NSTAR Electric Company d/b/a Eversource Energy (Eversource) switchyard located to the
south of the Northern Area across Rickey’s Road and the railroad ROW.
The southern portion of the property (the Southern Area) is comprised of approximately 36 acres of land.
The Southern Area is bounded by the town of Bourne to the west; Route 6A and Tupper Road to the south;
an active railroad ROW, owned by MassDOT, to the north; and undeveloped property owned by Eversource
to the east. The northern portion of the Southern Area is occupied by two large oil tanks which service the
existing Canal Generating Station, with several unimproved roadways traversing the property. A 360-foot
wide transmission corridor, held by Eversource under easement, occupies the eastern section of the
Southern Area. The Southern Area, which is separated from the Northern Area by an active railroad
corridor, is zoned “Business Limited 1.” The Southern Area is located within the Massachusetts Coastal
Zone, with a portion located within the FEMA-mapped 100-year flood zone.
Canal Community Solar will be located within an approximately 10-acre portion of the Southern Area (Solar
Site), as shown on Figure 2, with 8.2 acres permanently occupied by the proposed solar arrays, access
road, and electrical interconnection equipment. The Solar Site is undeveloped land, comprised of a mix of
open fields, scrub/shrub, and wooded vegetation.
The Solar Site will be accessed off an existing access road off of Tupper Road using an existing curbcut.
Except for a small area of Land Subject to Coastal Storm Flowage, there are no wetland resources or buffer
zones within the Solar Site. The solar arrays themselves will not be located within the FEMA mapped 100year flood plain; however, a vegetated bio-retention area, which will collect stormwater from the Solar Site
and allow it to infiltrate into the ground, will occupy approximately 0.3 acres of floodplain.
As shown on Figure 3, soils on the Solar Site are classified as Carver Loamy Coarse Sand, 3 to 8 percent
slope, according to the United States Department of Agriculture. These soils are classified as “excessively
drained.”
Canal Community Solar Development Program
Canal Community Solar will be an approximately 1.5-MW community solar project, consisting of two
separate arrays, reflecting the two distinct lots that comprise the Solar Site (Map 86, Lots 13 and 15). Array
1 consists of 3,784 305-watt solar panels, with a combined output of approximately 1.15 MW. Array 2
consists of 1,956 305-watt solar panels, with a combined output of approximately 0.6 MW
Canal Community Solar arrays will be configured in a series of smaller portions or rows, as shown on Figure
2. These rows can be allocated to different “off-takes” or customers, where each customer is given a certain
kilowatt (kW) load allotment. For Canal Community Solar, the take-offs/customers could be both residential
and business customers. However, NRG Renew Canal’s community solar strategy is focused around
residential offtakes. For example, the recent 1-MW Freetown, Massachusetts community solar project is
subscribed by 160 homeowners.
The specific kW allotment per customer will be determined based on a 20-year contract between the
customer and NRG. The contract also establishes a monthly rate paid by the customer to NRG. The
customer is then credited on its monthly utility bill for the energy that the customer’s particular portion of the
array produces in that month. No more than two participants may receive net metering credits in excess of
those produced annually by 25-kW of nameplate DC capacity, and the combined share of said participants’
capacity shall not exceed 50% of the total capacity of the Generation Unit.
The community solar garden is particularly helpful for those customers who wish to utilize solar energy but
who cannot install solar panels on their own property for a variety of reasons. For example, residential
customers may not have sufficient space on their property to install solar panels or they may reside in a
2
building (e.g., apartment or condominium) where solar installations are not available. In addition, by
constructing a large 1.5-MW solar array, NRG is able to enjoy economies of scale such as lower
construction and maintenance costs that can be passed on to the customers in terms of lower contract
rates.
Approximately 7.9 acres of the Solar Site will be cleared, graded and seeded with a grass mixture prior to
installation of the arrays. By constructing the arrays on a seeded area, as opposed to a gravel surface or
concrete pads, no significant increase in impervious area will result, except for the gravel access road
connecting to the existing access driveway off of Tupper Road and the footing anchors of the panels
themselves. Stormwater that does not infiltrate from the grassy area will be directed to a vegetated bioretention stormwater collection area, as shown on Figure 2. The 0.3-acre vegetated bio-retention area will
be situated on the northern portion of the Solar Site, within Land Subject to Coastal Storm Flowage. Based
on the existing and planned grade of the Solar Site and the general direction of water flow, this location is
most suitable for this stormwater feature. Water collected in the vegetated bio-retention area will attenuate
into the ground.
As shown on Figure 2, a new 22.8-kV three-phase Eversource overhead circuit will be situated on the
southern portion of the Solar Site, adjacent to Route 6A and the existing Eversource 22.8-kV three-phase
overhead distribution circuit. Two new 22.8-kV three-phase underground circuits will be trenched across
the western and eastern edge of the Solar Site to connect Array 1 and 2, respectively, into the existing
Eversource circuit. A 22.8-kV to 480-volt pad-mount transformer and 480-volt main panel board will be
situated amidst the solar panels and interconnect into the new underground circuits.
Canal Unit 3 Development Program
Canal Unit 3 is being developed by NRG Canal 3, a separate NRG Energy affiliate, and on a longer
schedule than Canal Community Solar. Canal Unit 3 itself constitutes a MEPA Categorical Inclusion
requiring a Draft and Final Environmental Impact Report, in addition to the ENF. As described later, the
two projects are not co-dependent as NRG Renew Canal and NRG Canal 3 are prepared to proceed
completely independently of one another.
Since Canal Unit 3 will be the subject of a comprehensive draft and final Environmental Impact Report, it is
not discussed further in this Expanded ENF.
Required Permits for Phase I Solar Project
There are no state permits required in connection with Canal Community Solar.
Canal Community Solar will be subject to the NPDES General Permit for Construction Activities.
Canal Community Solar will be subject to the jurisdiction of the Cape Cod Commission, and it is anticipated
that Canal Community Solar will be reviewed as a Limited Development of Regional Impact Project,
independent of the Commission’s review of Canal Unit 3.
Canal Community Solar is located within the Town of Sandwich Old King’s Highway Historic District. As
such, it will require a Committee Certificate of Appropriateness.
Finally, Site Plan Approval from the Town of Sandwich Planning Board will also be required. It is noted that
solar arrays currently are not permitted uses in the “Business Limited 1” District. NRG Renew Canal will
seek rezoning of the Solar Site to allow the proposed Canal Community Solar project.
Alternatives Analysis
This section addresses the alternatives analysis conducted by NRG Renew Canal in connection with Canal
Community Solar. This analysis considered on-site alternative configurations as well as off-site alternative
locations for development of Canal Community Solar, as described below.
3
On-site Alternatives
On-site alternatives considered included: (1) locating the solar arrays on the Simple-Cycle Site in a
previously cleared area proximate to the proposed new simple-cycle turbine; (2) locating the solar arrays
on the Simple-Cycle Site in a location between the existing Canal Unit 1 and aboveground oil storage tanks;
(3) constructing a larger solar array on the proposed Solar Site; and (4) constructing the preferred solar
array on the proposed Solar Site.
1. Use of Simple-Cycle Site for Solar Project
Canal Unit 3 will be developed on the easternmost portion of the Northern Area, in a previously cleared
and disturbed area. NRG Renew Canal evaluated the alternative of locating solar arrays adjacent to
the proposed Canal Unit 3. This alternative had the advantages of: being located in the Industrial
zoning district where large scale solar arrays are an allowed use; utilizing an area that had already
been cleared; avoiding any significant loss of vegetation; and, being proximate to the proposed new
units. However, this alternative was rejected for the reasons described below.




The limited space available would have severely restricted the size of the solar array and,
therefore, it’s electric output making the project uneconomical.
The entire Northern Area is located in Land Subject to Coastal Storm Flowage. Accordingly,
locating the solar arrays in this area would increase encroachment on that resource area and
require additional storm protection.
The solar arrays would be visible from areas subject to the jurisdiction of the Old King’s
Highway Regional Historic District, including the pedestrian walkway along the Cape Cod
Canal, as well as from the nearby marina.
The solar arrays would be in the shadow of the existing and proposed new Canal Units,
reducing the arrays’ output.
2. Use of Vacant Space on Northern Area
An existing strip of undeveloped land is located within the Northern Area, west of the existing Canal
Unit 1 and east of the fuel storage tanks. NRG Renew Canal evaluated locating the solar arrays in that
portion of the Property. This alternative has the advantages of: being located in the Industrial zoning
district where large scale solar arrays are an allowed use, and being located proximate to the existing
units but outside of Land Subject to Coastal Storm Flowage. However, this alternative was rejected for
the reasons described below.




The limited space available would have severely restricted the size of the solar array and,
therefore, its electric output, making the project uneconomical.
The solar arrays would be located within the buffer zone of a salt marsh located south of the
railroad ROW.
The solar arrays would be visible from the pedestrian walkway along the Cape Cod Canal.
The available area is entirely wooded and would need to be cleared, offering no advantage
over the proposed location.
3. Increased Build Alternative on the Proposed Solar Site
NRG Renew Canal considered a larger array on the proposed Solar Site. Portions of the Solar Site
that could have accommodated additional arrays include the northern-most portion of the site, west of
the existing oil tanks and the southeastern-most portion of the site, east of the natural gas pipeline
easement and south of the electric easement. Adding additional arrays in these areas would increase
the output of the project. However, this alternative was rejected for the following reasons:
4


The area in the northern portion of the site not slated for solar panels is within the 100-year
floodplain, which is regulated as Land Subject to Coastal Storm Flowage. This area is
proposed to be used for stormwater management for the Solar Site. As shown on Figure 2,
locating solar panels in this areas would require locating the stormwater management areas
further north into the buffer zone of a Bordering Vegetated Wetland.
Solar panels located in the southeastern portion of the site, east of the natural gas pipeline
ROW would be visible from Route 6A, which is also known as Old King’s Highway, part of the
Old King’s Highway Regional Historical District.
4. Proposed Solar Site
The proposed Solar Site maximizes the output of the Solar Project while restricting encroachment on
jurisdictional wetlands to creation of a vegetated bio-retention area for stormwater management. No
solar arrays will be placed in jurisdictional wetland areas. It further represents the alternative with the
least visual impact, being well screened from Route 6A (Old King’s Highway), Tupper Road, and the
Cape Cod Canal. It takes advantage of an underutilized industrial property that currently supports oil
storage for the existing Canal Station, several electrical transmission easements and a natural gas
pipeline ROW.
For the reasons stated above, the on-site alternative locations were deemed to be inferior to the
proposed Solar Site.
Off-site Alternative
NRG Renew Canal evaluated an approximately 44-acre site, consisting of five separate parcels owned by
NRG Canal LLC co-located off of Town Neck Road and Coast Guard Road in Sandwich, Massachusetts
called the Town Neck Site. Due to its size, the Town Neck Site could potentially accommodate solar arrays
totaling approximately 2 MW. The Town Neck Site, shown on Figure 4, is located directly to the south of
the Cape Cod Canal at the mouth of the waterway. The site is bounded by: Cape Cod Bay to the East;
Canal Service Road and the Cape Cod Canal to the North; Town Neck Road to the south; and United
States Coast Guard property and a restaurant to the west. The Town Neck Site is undeveloped and
vegetated; the southern-most lots contain considerable wetlands, including potentially jurisdictional vernal
pools. While this alternative initially had the advantage of greater capacity than the proposed location, it
was rejected for the following reasons.





The Town Neck Site was nearly completely wooded and would need to be cleared, offering no
advantage over the proposed location.
The entire array would be located in Land Subject to Coastal Storm Flowage, encroaching on that
resource area and requiring additional storm protection.
On-site wetland areas were determined to be more extensive than appeared on GIS mapping,
resulting a greatly reduced buildable area and additional wetland impacts.
The Town Neck Site would be visible from Cape Cod Bay beachfront as well as residences to the
south.
The Town Neck Site is considerably farther from the electric transmission system and a new offsite electrical connection would be required.
For the reasons stated above, the off-site alternative location was deemed to be inferior to the proposed
site.
Phase I Solar Project Impacts
This section addresses the potential environmental impacts from the Canal Community Solar project. Canal
Community Solar does not require any state permits and it does not itself exceed any thresholds for an
ENF or mandatory EIR.
5
Land Impacts
The Solar Site will involve clearing of approximately 8.2 acres of land currently characterized by a mix of
field, scrub/shrub, and wooded areas. The areas cleared for the solar panels will be seeded with a grass
mixture prior to the installation of the approximately 1.5-MW of ground-mounted solar arrays. The panels
are not considered “impervious” as rainwater will run off the panels which are tilted at a 20 to 30 degree
angle onto the grassed area. As shown of Figure 2, Canal Community Solar includes a stormwater
management system which conveys the stormwater from the Solar Site to a vegetated bio-retention area
consistent with the Massachusetts Department of Environmental Protection (MassDEP), Cape Cod
Commission, and Town of Sandwich stormwater management best practices and guidelines. Accordingly,
impervious surfaces have been minimized and are limited to the 0.4 acre upland area for the footings of the
proposed solar arrays and for the proposed gravel roadway.
State Listed Species under M.G.L. c. 131A
As shown on Figure 5, Canal Community Solar does not involve the alteration of designated significant
habitat or disturbance of designated priority habitat, as defined in 321 CMR 10.02. Therefore, significant
impacts to state-listed endangered or threatened species or species of special concern are not expected
to occur.
Wetlands, Waterways and Tidelands
As shown on Figure 5, other than Land Subject to Coastal Storm Flowage, the Solar Site does not contain
any wetland resource areas, waterways or tidelands. Accordingly, there will be no impacts to wetlands,
waterways or tidelands associated with Canal Community Solar other than the creation of a vegetated bioretention area for collecting stormwater from the site, which will be allowed to infiltrate into the ground,
consistent with best management practices for stormwater control.
Water Use
There will be no new water use associated with Canal Community Solar. Accordingly, there will be no
water supply impacts associated with the project.
Wastewater
There will be no wastewater generated by Canal Community Solar.
wastewater impacts associated with the project.
Accordingly, there will be no
Transportation
As shown on Figure 2, access to the Solar Site will be provided by constructing a short, gravel roadway to
connect the Solar Site to an existing unpaved roadway with existing access onto Tupper Road.
Construction of Canal Community Solar is expected to take approximately five months. During that time a
maximum of 10 construction workers and delivery trucks would be expected to access the site daily. Site
access during construction would be via an existing access driveway off of Tupper Road. The construction
worker and delivery vehicle trips would have an insignificant impact on traffic on Tupper Road and Route
6A. Once operational there will be no appreciable traffic generated by Canal Community Solar. The site
will be unmanned and accessed via an existing access driveway off of Tupper Road for maintenance
purposes.
Energy
Canal Community Solar will have an electrical generation capacity of approximately 1.5 MW of renewable
energy. Based on the expected capacity factor, this will result in supply of 2,023,000 kW-hours/year of
6
electrical energy to the regional electric supply. Accordingly, the proposed Phase I Canal Community Solar
project will have a positive impact on energy generation.
Air Quality
Canal Community Solar will supply approximately 2,023,000 kW-hours of renewable energy to the regional
electric supply annually. The addition of this clean, renewable energy will displace older, more polluting
generating facilities and is expected to result in a net decrease of emissions of air pollutants, including
924.5 tons per year of CO2 emissions1. Accordingly, the proposed Canal Community Solar project will have
a positive impact on emissions of air pollutants and greenhouse gases.
Solid and Hazardous Waste
There will be no solid or hazardous waste generated by Canal Community Solar. There have been no
known releases or threats of release of hazardous materials at the Solar Site.
Historical and Archaeological Resources
There are no state-listed historical or archaeological resources on the Solar Site. The Solar Site is located
within the Old King’s Highway Regional Historic District. Further, the southernmost portion of the Solar Site
is located in the Route 6A West section of the Old King’s Highway Regional Historic District. The proposed
Canal Community Solar project will undergo review by both the Cape Cod Commission and the Town of
Sandwich Old King’s Highway Historic District. As the solar arrays are low to the ground and completely
obscured by the surrounding vegetation, they will not be visible from Old King’s Highway or the surrounding
area. Therefore, the proposed Canal Community Solar project is not expected to have an adverse effect
on any historic resources.
Areas of Critical Environmental Concern
There are no designated Areas of Critical Environmental Concern located at the Solar Site. Accordingly,
the proposed Canal Community Solar project will have no impact on any such areas.
Environmental Justice Areas
As shown on Figure 6, there are no qualifying Environmental Justice areas within 5 miles of the Solar Site.
Therefore, Canal Community Solar will not adversely impact these areas.
Consistency with Local and Regional Plans
This section describes Canal Community Solar’s consistency with applicable local and regional plans and
policies.
Commonwealth of Massachusetts Policies
Canal Community Solar is consistent with the objectives of recent Commonwealth of Massachusetts
legislative acts and programs, including the Global Warming Solutions Act of 2008 and the Green
Communities Act of 2008. This legislation and implementing programs encourage the reduction of
greenhouse gas emissions (GHG’s), through a number of policies, including the development of solar power
generation. Most recently the Commonwealth’s goal to increase solar power generation has expanded to
a total of 1,600 MW by the year 2020.
1
Based on the ISO-New England marginal emission rate of 914 pounds per megawatt-hour (lb/MW-hour). The
system average emission rate of 730 lb/MW-hour would result in displacement of 738.4 tons per year of CO2.
7
Coastal Zone Management Plan
Canal Community Solar is consistent with the Coastal Zone Management policies as follows:
Energy Policy #1
Summary Statement
For coastally dependent energy facilities, assess siting in alternative coastal locations. For noncoastally dependent energy facilities, assess siting in areas outside of the coastal zone. Weigh the
environmental and safety impacts of locating proposed energy facilities at alternative sites.
Expansion of existing energy facilities located in or affecting the coastal zone may be coastally
dependent if:
• The existing and expanded facility is dependent on existing infrastructure, such as fuel
delivery systems and transmission lines that are currently located in the coastal zone.
• All new facility and ancillary construction (including but not limited to transmission lines,
fuel delivery systems, and traffic systems) are fully described and impacts to the land and
water resources and uses of the Massachusetts coastal zone are fully assessed, avoided,
minimized, and mitigated.
• In keeping with Executive Order (E.O.) 385 Planning for Growth, the effects of the proposed
additional energy capacity on residential and commercial growth are described.
Canal Community Solar is not a coastally dependent energy facility. All of Cape Cod is located in the
coastal zone. Accordingly, there are no on-Cape alternative sites for the Community Solar Project.
Energy Policy #2
Summary Statement
Encourage energy conservation and the use of renewable sources such as solar and wind power
in order to assist in meeting the energy needs of the Commonwealth.
Key Policy Elements
CZM strongly endorses efforts to conserve energy and to develop alternative sources of power. To
this end, CZM will cooperate with EEA, the Department of Energy Resources, Massachusetts
Clean Energy Center, and others in implementing the Commonwealth’s comprehensive energy
conservation program, insofar as it relates to state activities within the coastal zone. In addition,
CZM will support alternative energy source demonstration projects that may be proposed in the
coastal zone, assuming that the proposed projects have minimal impacts on coastal resources and
uses and will assist in locating appropriate sites and evaluating feasibility studies as appropriate.
Canal Community Solar is consistent with this policy as the project is a renewable energy source that will
assist meeting the energy needs of the Commonwealth with minimal impact on coastal resources and uses.
Cape Cod Regional Plan
Goal E-1 of the Cape Cod Regional Plan identifies the following related to Emissions and Energy Use:
To promote a sustainable economic, natural, built, and social environment by reducing greenhouse
gas emissions and energy consumption through design and construction practices that increase
energy conservation, promote energy efficiency, and promote self-sufficiency through the use of
locally distributed renewable energy.
Additionally, the Cape Cod Regional Plan identifies specific actions for both the Cape Cod Commission and
the municipalities to pursue with regard to encouraging solar energy development.
8
Canal Community Solar is consistent with this identified goal as well as the solar energy-related action
items identified in the Regional Plan.
Town of Sandwich Local Comprehensive Plan (2009)
The Town of Sandwich’s Local Comprehensive Plan (LCP) makes many references to promoting the use
of renewable energy, including solar energy, and supporting the Commonwealth’s sustainable energy
policies. Many of the goals, policies and action plans of the LCP encourage the use and development of
solar energy to reduce impacts on the environment and correlate to the Cape Cod Commission’s goals for
air pollution reduction in the region, climate change, energy conservation and development, hazard
mitigation and adaptation, land conservation, and Smart Growth Development.
Town of Sandwich Protective Zoning By-Law
Under Massachusetts General Law 40A Section 3, local zoning may not prohibit the installation of solar
energy facilities.
No zoning ordinance or by-law shall prohibit or unreasonably regulate the installation of solar
energy systems or the building of structures that facilitate the collection of solar energy, except
where necessary to protect the public health, safety or welfare.
Under Section 2200 of the Town of Sandwich Use Regulations of the Protective Zoning By-Law, Solar
Photovoltaic Installations (Large Scale Ground Mounted [greater than 250 kilowatts]) are allowed by right
in the IND (Industrial Limited) district. NRG Canal Renew is pursuing a zoning change for the Solar Site
that would enable Canal Community Solar to move forward.
Assuming the zoning change is approved, Canal Community Solar will be consistent with local zoning
requirements.
Greenhouse Gas Analysis
This section addresses Canal Community Solar’s compliance with the Greenhouse Gas Emission Policy
and Protocol (GHG Policy).
The GHG Policy requires that proponents of projects that require preparation of an environmental impact
report to quantify the greenhouse gas (GHG) emissions from the proposed project and analyze proposed
mitigation measures for those emissions. The GHG Policy further provides that if a project proponent seeks
a Phase I Waiver pursuant to 301 CMR 11.11(4), the EENF should contain the required GHG analysis only
if the Phase I project will result in material GHG emissions itself.
The proposed Canal Community Solar project will not result in any appreciable emissions of GHG. Very
minimal traffic (less than 10 trips per day) is expected during the five-month construction period, and very
infrequent traffic will occur during operation. In fact, Canal Community Solar is expected to offset 924.5
tons per year of CO2 by displacing the operation of GHG-emitting resources. Accordingly, no further GHG
analysis of Canal Community Solar is required under the GHG Policy.
NRG Canal 3 will conduct and submit a comprehensive GHG analysis for Canal Unit 3 as part of its draft
Environmental Impact Report filing.
Phase I Waiver Criteria Requirements
This section addresses the standards for grant of a Request for Phase I Waiver under the MEPA regulations
at 310 CMR 11.11(1) and (4).
9
Pursuant to 301 CMR 11.11(1) Standards for all Waivers, the Secretary may waive requirements of
provisions of the MEPA regulations if the Secretary finds that strict compliance with those provisions would:
(a) result in a hardship for the Proponent, unless based on delay in compliance by the Proponent;
and
(b) not serve to avoid or minimize damage to the environment.
In addition, pursuant to 301 CMR 11.11(4) Determination for Phase I Waiver, the Secretary must find that:
(a) the potential environmental impacts of phase one, taken alone are insignificant;
(b) ample and unconstrained infrastructure facilities and services exist to support phase one;
(c) the Project is severable, such that phase one does not require the implementation of any other
future phase of the Project or restrict the means by which potential environmental impacts from
any other phase of the Project may be avoided, minimized or mitigated; and
(d) the Agency Action on phase one will contain terms such as a condition or restriction in a Permit,
contract or other relevant document approving or allowing the Agency Action, or other evidence
satisfactory to the Secretary, so as to ensure due compliance with MEPA and 301 CMR 11.00
prior to commencement of any other phase of the Project.
As discussed in more detail below, the proposed Canal Community Solar project meets all standards for
grant of a Phase I Waiver.
1. Failure to grant the waiver would result in significant hardship for the Proponent
NRG Renew Canal is requesting a Phase I Waiver so that Canal Community Solar can proceed in
advance of the MEPA review process for Canal Unit 3. This request is due to the fact that, if Canal
Community Solar were subject to the same review requirements/timeframes as the review
requirements/timeframes for Canal Unit 3, the Proponent would not move forward with Canal
Community Solar.
As described in more detail below, NRG Renew Canal needs to take advantage of certain investment
tax credits that are set to expire at the end of 2016. In order to take advantage of these tax credits,
Canal Community Solar must be operational by December 31, 2016. Canal Unit 3 will require the
preparation and review of both Draft and Final Environmental Impact Reports, which will include a
number of complex analyses not relevant to the solar project (e.g., air quality and noise impact
modeling). The anticipated time period to complete this comprehensive MEPA review process for
Canal Unit 3 would not accommodate Canal Community Solar’s need to be operational by December
31, 2016.
The solar Investment Tax Credit (ITC) was designed to support the widespread deployment of solar
energy, and was created as part of the Energy Policy Act of 2005 and extended for eight years in the
Emergency Economic Stabilization Act of 2008. It is the principle federal policy mechanism supporting
the solar industry. Specifically, the ITC allows companies and individuals that install, develop, or
finance solar systems to claim a tax credit in the amount of 30% of the investment cost of the project.
The 30% credit has been instrumental in jump-starting and growing the United States solar industry but
is only in effect until December 31, 2016, at which point the credit will drop to 10% for third-party owned
systems and to 0% for residentially owned systems. To qualify for the 30% credit, projects must be
placed in service prior to December 31, 2016. The economic and growth impacts of the ITC “cliff”
across the solar industry will be significant and widespread; it is a widely held belief that the market will
experience a dramatic slowdown in growth due to infeasibility of project economics.
Projections from leading energy models, including the United States Energy Information Agency,
forecast the coming solar cliff due to the ITC step down will depress solar installations for many years
to come. The 2015 market report by the Solar Energy Industry Association (SEIA)2, one the largest
and well-reputed national non-profit trade associations for solar energy in the U.S., opines the following:
2
http://www.seia.org/research-resources/solar-market-insight-report-2015-q1
10
Businesses across the solar energy industry have begun preparing for the worst while
hoping for the best. In general, solar businesses will try to bring as much capacity online as possible before the scheduled stepdown. Solar development will continue, but
some markets will fare better than others, and resumption of growth after 2017 will look
different from the growth seen over the past eight years. For all market segments, the
total addressable market will shrink post-2016, some states will fall off the solar map
entirely, and resumption of growth at a national level will be due to several states with
strong economics…Overall, installations are expected to drop 57% in 2017.
The reduction in the ITC will increase solar arrays’ corresponding power purchase agreement (PPA)3
rates by 20 to 40% between projects placed in service in 2016 versus the same project placed in service
in 2017. For example, a competitive PPA rate today for the first year of a contract for a 1 MW AC
community solar project in Massachusetts with standard economic assumptions4 might be
approximately $0.15/kWh. As such, this project would be marketable to residential offtakes since that
PPA rate can provide homeowners with a cost savings in comparison with what they would otherwise
be paying on their current electricity bill. The cost savings occur when the offtake buys electricity
generated from the solar project at a lower dollar per kilowatt-hour ($/kWh) PPA rate than the $/kWh
rate at which they buy electricity from the grid via their current electricity supplier.
When modeling that same project going into commercial operation in 2017, the PPA rate would
increase to approximately $0.19/kWh due to the need to compensate for the lost value of the ITC. The
completion of the solar project thus becomes unlikely due to a lack of interest from homeowners who
may not save money on their electricity bill by subscribing as a power offtake. If the solar project were
to maintain that $0.15/kWh rate in a post-ITC environment, it would see a net economic loss over the
project’s 20-year life and, therefore, the project would not move forward.
In summary, without the Phase I Waiver, NRG Renew Canal cannot take advantage of the solar ITC.
If NRG Renew Canal cannot construct Canal Community Solar in time to take advantage of the solar
ITC, Canal Community Solar will not be economically viable and NRG Renew Canal will not pursue
Canal Community Solar. Accordingly, the hardship to NRG Renew Canal is based upon the reality that
without the Phase I Waiver, Canal Community Solar is not economically viable, and simply will not go
forward.
Clearly, the inability of NRG Renew Canal to pursue Canal Community Solar would result in an
economic hardship. If Canal Community Solar does not go forward, NRG Renew Canal would be
forced entirely to forego this otherwise profitable business endeavor.
Moreover, the inability of NRG Renew Canal to pursue Canal Community Solar also results in a
hardship to members of the public who wish to avail themselves of the benefits of the community solar
project. That is, without Canal Community Solar, members of the community would not be able to take
advantage of the environmentally beneficial opportunity to “go solar” or the financially beneficial
opportunity to reduce their electric bills.
As important, and as described in greater detail in Section 2, below, failure to grant the Phase I Waiver
would also result in a significant hardship to the environment because of the recognized environmental
benefits afforded by solar energy.
3
A PPA is a contract between two parties, one who generates electricity (the seller) and one who purchases the electricity (the
buyer).
4
Assumes 1 MW AC ground-mounted fixed-tilt project under a 20-year PPA contract term.
11
2. Failure to Grant the requested Phase I Waiver would not serve to avoid or minimize damage to the
environment.
As described in the foregoing sections and as summarized below, the work associated with Canal
Community Solar will have insignificant adverse impact to the environment. Taken alone, Canal
Community Solar does not trigger any thresholds for an ENF or mandatory EIR, and no independent
state permits are required for Canal Community Solar.
In contrast, Canal Community Solar provides significant benefits to the environment. As stated in the
Greenhouse Gas Analysis section above, Canal Community Solar will result in the displacement of
924.5 tons per year of CO2 emissions that would otherwise occur.
3. The potential environmental impacts of Canal Community Solar, taken alone, are insignificant.
As detailed in this Expanded ENF, Canal Community Solar does not involve any adverse impacts to
any Areas of Critical Environmental Concern, mapped rare species habitat, historic or archaeological
resources, wetlands, water resources, waterways, air quality, or traffic. Although a vegetated, bioretention area will be created within Land Subject to Coast Storm Flowage, no significant long-term
adverse impact to this resource is anticipated.
The only area of potential environmental concern associated with Canal Community Solar is related to
clearing of the Solar Site. Canal Community Solar has minimized impact to land due to the compact
layout of the solar arrays. Further, the arrays will be underlain by grass which is not considered an
impermeable surface.
While construction of Canal Community Solar will involve clearing of vegetation, clearing is limited to
those areas needed to accommodate the arrays. The Solar Site also contains areas that have been
previously disturbed as well as areas that are “burdened” by existing utility easements.
4. Ample and unconstrained infrastructure facilities and services exist to support phase one.
Canal Community Solar does not require additional off-site infrastructure facilities or services. Canal
Community Solar does not require either sewer or water services. Access to the Solar Site will be via
an existing access road off of Tupper Road, utilizing existing curbcuts. Canal Community Solar includes
a new 22.8-kV three-phase overhead circuit and two underground 22.8-kV three-phase circuits, as well
as two pad-mount transformers and two panel boards, one for each solar array. Canal Community
Solar will connect to the existing Eversource 22.8-kV three-phase overhead distribution circuit which
follows Route 6A, located south of the Solar Site.
5. The Project is severable, such that phase one does not require the implementation of any other
future phase of the Project or restrict the means by which potential environmental impacts from any
other phase of the Project may be avoided, minimized or mitigated
Canal Community Solar is completely independent of, and does not depend in any way on, the
development of Canal Unit 3. The two projects have separate and distinct purposes. Canal Community
Solar is intended to provide retail users the ability to enter contracts to purchase solar energy as an
alternative to installing solar arrays on their own. This is particularly important to retail customers for
whom installation of personal solar arrays is not feasible. Canal Unit 3 is intended to provide utilityscale, needed peak-demand generation capacity to a currently constrained load-zone in the ISO-New
England electricity grid.
Implementation of Canal Community Solar will in no way restrict the means by which impacts from
Canal Unit 3 may be avoided, minimized or mitigated. Any environmental impacts of Canal Unit 3 can
be adequately avoided, minimized or mitigated utilizing the Northern Area of the Property and Canal
Unit 3 does not in any way depend on Canal Community Solar. Similarly, Canal Community Solar does
not depend on Canal Unit 3 moving forward.
12
6. The Agency Action on phase one will contain terms such as a condition or restriction in a Permit,
contract or other relevant document approving or allowing the Agency Action, or other evidence
satisfactory to the Secretary, so as to ensure compliance with MEPA and 301 CMR 11.00 prior to
commencement of any other phase of the project.
NRG Canal 3 agrees to prepare and file a comprehensive Draft and Final EIR for review of Canal Unit
3 prior to development of that project, and expects that the Secretary will memorialize this commitment
in any Certificate or Order granting a Phase I Waiver.
13
Figures

Figure 1: Location Map

Figure 2: Solar Site Plan

Figure 3: NRCS Soil Units

Figure 4: Offsite Alternate Solar Site

Figure 5: Environmental Constraints

Figure 6: Environmental Justice Areas
N
NH
H
V
V TT
Legend
N
NY
Y
MA
Canal Property
¯
Project
Location
R
R II
!
C
C TT
Atla nti
c Oc
ea n
0
500 1,000
2,000
Feet
Figure 1
Location Map
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
R:\Projects_2014\Canal_3\maps\Figure1_Canal3_topo.mxd
Figure 2
Solar Site Plan
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
N
NH
H
V
V TT
Legend
Northern Area
N
NY
Y
MA
Southern Area
Project
Location
R
R II
Figure 3
NRCS Soil Units
Soil Unit
259B: Carver loamy coarse sand, 3-8% slopes
380B: Nantucket sandy loam, 3-8% slopes
!
54A: Freetown and Swansea mucks, coastal lowland, 0-1% slopes
C
C TT
O
Atla ntic
n
cea
665: Udipsamments, smoothed
0
100
200
400
Feet
¯
Source: United States Department of Agriculture.
Natural Resource Conservation Service.
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
Date: 5/12/2015
Path: N:\EP\Sandwich Power\Figure 1 Project Locus_Solar.mxd
Project
Locus
1 inch = 2,000 feet
0
1,000
Feet
2,000
Figure 4
Offsite Alternate Solar Site
¹
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
N
NH
H
V
VT
T
Legend
Northern
N
NY
Y
MA
Project
Location
R
R II
Chapter 91 Jurisdictional
Coastal Bank Bluff or Sea Cliff
Simple-Cycle Site
NHESP Priority Habitats of
Rare Species
Salt Marsh
Shallow Marsh Meadow or Fen
Shrub Swamp
Atla nti c
O ce
an
¯
DEP Mapped Wetland Type
Southern
Solar Site
!
C
CT
T
100-year Flood Zone
Wooded Swamp Deciduous
0
125
250
Figure 5
Environmental Constraints
500
Feet
Source: FEMA Flood Zones 2014,
Department of Environmental Protection (DEP)
Wetlands Conservancy Program (WCP) 2014,
NHESP 2014, ESRI Imagery 2013.
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
Note: No NHESP Certified Vernal Pools
in map extent.
R:\Projects_2014\Canal_3\maps\Figure4_Canal3_Environmental_Constraints.mxd
White
Island
Shores
!
Sagamore
!
Wareham
!
Sandwich
Buzzards
Bay
!
!
Wareham
Center
!
East
Sandwich
Onset
!
!
Bourne
!
Monument
Beach
West
Barnstable
!
!
Barnstable
!
Forestdale
Pocasset
!
!
N
NH
H
V
V TT
Legend
N
NY
Y
MA
Project Area
Project
Location
R
R II
5-mile Buffer
!
EJ Criteria, by Block Group
Minority
0
Income
C
C TT
Minority and Income
Atla ntic
O ce
an
0.5
1
2
Miles
¯
Source: MassGIS. 2010 U.S. Census. Environmental
Justice Populations. December 2012.
Figure 6
Environmental Justice Areas
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
R:\Projects_2014\Canal_3\maps\Canal3_EJ_Areas.mxd
Attachment 3: List of Release Tracking Numbers
9 Freezer Road
RTN
4-0010231
4-0010297
4-0010303
4-0010584
Date
1994-01-25
1995-02-25
1994-02-28
1994-06-29
4-0013525
1997-11-19
4-0013791
1998-05-04
4-0013851
4-0013963
4-0014588
1998-05-04
1998-06-17
1999-03-12
4-0014831
4-0015444
4-0018844
4-0021809
4-0022326
4-0024673
4-0024883
4-0024946
1999-07-07
2000-04-26
2005-01-01
2009-02-27
2009-12-03
2013-07-15
2013-11-23
2014-01-04
Description
Release of 200 gallons of #6 fuel oil on soil and gw (cat. 1)
Release of 35 gallons of sodium hydroxide on soil (cat. 2)
Release of 25 gallons of lubricating oil
Release of 3,039 gallons of hypochlorous acid/sodium salt and 10 pounds of
sodium hypochlorite on soil and gw (cat. 1)
Release to soil and gw (cat. 1) of:
- 230 ppb aromatics
- 380 ppm aromatics
- 120 ppb arsenic
- 6.5 ppm benzo(a)anthracene
- 0.2 ppb benzo(a)pyrene
- 5.9 ppm benzo(a)pyrene
- 6.6 ppm benzo(b)fluoranthene
- 64 ppb lead
- 120 ppb nickel
Release of 5,000 ppb of C9 through Aliphatic hydrocarbons and 25,000 ppm
of TPH on soil and gw (cat. 1)
Release of 300 ppm of aromatics on soil and gw (cat. 1)
Release of 10 gallons of transformer oil on soil and gw (cat. 1)
Release of 500 gallons of #2 fuel oil and an unknown amount of magnesium
oxide on soil and gw (cat. 1)
Release of 25 gallons of mineral oil on soil (cat. 3) and gw (cat. 1)
Release of 60 gallons of transformer oil
Release of 5,000 gallons of #6 oil on soil & gw (category 1)
Release of 2,000 gallons of #6 fuel oil on soil and gw (category 1)
Release of 48 mg/kg of chromium on soil and gw (category 1)
Release of 800 gallons of non-pcb transformer oil
Release of 25 gallons of #6 fuel oil on soil (category 1)
Release of 50 gallons of #6 fuel oil on soil (category 1)
RAO Class/Phase
A2
A1
A1
A1
C1 / Phase IV
A2
B1
A2
A2
A1
A1
A2
A2
A2
Phase II
A2
A1
Freezer Road
RTN
4-0011049
4-0012223
Date
1995-01-11
1996-05-29
4-0010221
1994-01-20
Description
RAO Class/Phase
Release of 40 gallons of #2 fuel oil on soil (cat. 3) and gw (cat. 1)
A2
Release of 10 gallons of #6 fuel oil and 16 ppm of 2-Methylnphthalene on soil
A2
and gw (cat. 3)
Release of 25 gallons of diesel fuel off a boat
Not Required
20 Freezer Road
RTN
4-0018469
Date
2004-06-02
4-0021508
2008-09-12
Description
Release of unknown amount of ammonia sulfide on soil (cat. 2) and gw (cat.
1)
Release of 10 gallons of motor oil on soil (cat. 1)
RAO Class/Phase
A1
A1
Source: Massachusetts Department of Environmental Protection. Waste Site/ Reportable Releases LookUp, Version: 1.0.0.2 ~ Built
Date: 5/5/2015. http://public.dep.state.ma.us/SearchableSites2/Search.aspx.
Attachment 4: Project Locus Maps

Figure 1 – USGS Locus Map (as required by both MEPA and CCC)

Figure 2 – Project Overview Aerial Photograph

Figure 3 – Project Site Aerial Photograph
N
NH
H
V
VT
T
Legend
N
NY
Y
MA
Figure 1
USGS Locus Map
Canal Property
Project
Location
R
R II
¯
!
C
CT
T
Atla nti
c Oc
ea n
0
500 1,000
2,000
Feet
NRG Canal 3 Development LLC
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
R:\Projects_2014\Canal_3\maps\Figure1_Canal3_topo.mxd
Sc
us
n Sagamore
Elementary
se
Scusset
Scusset Beach
Beach
State
State Reservation
Reservation
tB
ea
ch
Rd
School
Shawme
Shawme
Park
Park
U
V
6
Shawme
Shawme Crowell
Crowell
State
State Forest
Forest
U
V
130
Camp
Camp Edwards
Edwards
Army
Army Natl
Natl Guard
Guard
£
¤
6
n
Henry T Wing
School
Legend
n
Northern Area
Railroad
Southern Area
Proposed Electrical Interconnection
Simple-Cycle Site
Proposed Natural Gas Interconnection
Solar Site
Proposed Oil Interconnection
School
State Park or Forest
Major Road
Local Park or Recreational Area
Local Road
Military Installation
0
Figure 2
Project Overview
Aerial Photograph
¯
500 1,000
2,000
Feet
NRG Canal 3 Development LLC
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
R:\Projects_2014\Canal_3\maps\Figure2_Canal3_Overview_Aerial.mxd
Ed
Mo
ffi
tt
D
r
Scusset
Scusset Beach
Beach St
St Reservation
Reservation
r
Tuppe
N
NH
H
V
VT
T
Legend
N
NY
Y
MA
Project
Location
R
R II
!
C
CT
T
Atla nti c
O ce
an
Northern Area
Proposed Oil Interconnection
Southern Area
Proposed Natural Gas Interconnection
Simple-Cycle Site
Proposed Electrical Interconnection
Solar Site
State Park or Forest
Railroad
Rd
Figure 3
Project Site Aerial Photograph
¯
0
100
200
400
Feet
NRG Canal 3 Development LLC
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
R:\Projects_2014\Canal_3\maps\Figure3_Canal3_Detail_Aerial.mxd
Attachment 5: Constraint Maps

Figure 4 – Environmental Constraints

Figure 5 – Cultural Constraints
N
NY
Y
MA
¯
Legend
N
NH
H
V
VT
T
Project
Location
R
R II
Northern
100-year Flood Zone
Southern
Chapter 91 Jurisdictional
Coastal Bank Bluff or Sea Cliff
Simple-Cycle Site
NHESP Priority Habitats of
Rare Species
Salt Marsh
Solar Site
!
C
CT
T
DEP Mapped Wetland Type
Shallow Marsh Meadow or Fen
Shrub Swamp
Atla nti c
O ce
an
Wooded Swamp Deciduous
0
125
250
Figure 4
Environmental Constraints
500
Feet
Source: FEMA Flood Zones 2014,
Department of Environmental Protection (DEP)
Wetlands Conservancy Program (WCP) 2014,
NHESP 2014, ESRI Imagery 2013.
Note: No NHESP Certified Vernal Pools
in map extent.
NRG Canal 3 Development LLC
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
R:\Projects_2014\Canal_3\maps\Figure4_Canal3_Environmental_Constraints.mxd
(
!
Scusset Beach State Reservation
Canal Fish
and Freezing
( Company
!
Old King's Highway Regional Historic District
Cape Cod
Canal Access
(
!
Canal
Electric Company
Plant
Cape Cod
Canal Access
Freeman Farm
Town Neck
(
!
(
!
(
!
Route 6A - West Area
Water District Land
Saddle and Pillion
Legend
N
NH
H
V
VT
T
(
!
N
NY
Y
MA
(
!
(
!
Southern Area
(
!
Simple-Cycle Site
(
!
!
(
!
(
!
C
CT
T
O
Atla nti c
(
!
(
!
Solar Site
(
!
¯
Route 6A - West Area
Town Neck
(
!
Protected and Recreational
Open Space
n
cea
Historic Point
(
!
Project
(
!
Location
R
R II
Historic
Northern Area
(
!
Route 6A - West Area
Roberti Dairy Farm !
(
( Burial Ground
!
(
!
(
!
(
( King's !
!
Old
Highway
Regional Historic
District
(
!
Old King's Highway Regional Historic District
(
!
(
!
0
100 200
400
Feet
Source: MassGIS 2014,
ESRI Imagery 2013.
Figure 5
Cultural Constraints
NRG Canal 3 Development
LLC
(
!
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
R:\Projects_2014\Canal_3\maps\Figure5_Canal3_Cultural_Constraints.mxd
(
!
Attachment 6: Site Plan

Figure 6 – Existing Conditions Plan (as required by both MEPA and CCC)
Figure 6
Existing Conditions Plan
NRG Canal 3 Development LLC
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
Attachment 7: Proposed Development Plans

Figure 7 – Proposed Site Plan (as required by both MEPA and CCC)
Figure 7
Proposed Site Plan
NRG Canal 3 Development LLC
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
Attachment 8: ENF Circulation List
Martin Suuberg, Commissioner
MassDEP
One Winter Street
Boston, MA 02108
Kimberly Groff
MassDEP Division of Watershed Management
627 Main Street, 2nd Floor
Worcester, MA 01608
MassDEP Southeast Regional Office
Attn: MEPA Coordinator
20 Riverside Drive
Lakeville, MA 02347
MassDEP Southeast Regional Office
Industrial Wastewater Permit Program
20 Riverside Drive
Lakeville, MA 02347
MassDEP Southeast Regional Office
Division of Air Quality Control
20 Riverside Drive
Lakeville, MA 02347
Massachusetts Department of Transportation
Public/Private Development Unit
10 Park Plaza
Boston, MA 02116
Massachusetts Department of Transportation
District 5 Office
Attn: MEPA Coordinator
1000 County St
Taunton, MA 02780
Massachusetts Historical Commission
220 Morrissey Boulevard
Boston, MA 02125
Department of Energy Resources
Attn: MEPA Coordinator
100 Cambridge Street, 10th Floor
Boston, MA 02114
Coastal Zone Management
Attn: Project Review Coordinator
251 Causeway Street, Suite 800
Boston, MA 02114
Massachusetts Department of Safety
Department of Fire Services
Stephen D. Coan, Fire Marshal
1 State Road
Stow, MA 01775
Division of Marine Fisheries (South Shore)
Attn: Environmental Reviewer
1213 Purchase Street -3rd Floor
New Bedford, MA 02740
Energy Facilities Siting Board
Attn: MEPA Coordinator
One South Station, Fifth Floor
Boston, MA 02110
Cape Cod Commission
3225 Main Street (Route 6A)
Barnstable, MA 02630
Old King’s Highway Historic District Committee
130 Main Street
Sandwich, MA 02563
Sandwich Historical Commission
142 Main Street
Sandwich, MA 02563
Town of Sandwich
George H. Dunham, Town Manager
130 Main Street
Sandwich, MA 02563
Town of Sandwich
Planning Board
130 Main Street
Sandwich, MA 02563
Sandwich Conservation Commission
16 Jan Sebastian Drive
Sandwich, MA 02563
Town of Sandwich
Board of Selectmen
130 Main Street
Sandwich, MA 02563
Sandwich Board of Health
16 Jan Sebastian Drive
Sandwich, MA 02563
Town of Bourne
Board of Selectmen
24 Perry Avenue
Buzzards Bay, MA 02532
Town of Bourne
Conservation Commission
24 Perry Avenue, Room 201
Buzzards Bay, MA 02532
Town of Bourne
Thomas M. Guerino, Town Administrator
24 Perry Avenue, Room 101
Buzzards Bay, MA 02532
Town of Bourne
Board of Health
24 Perry Avenue, Room 201
Buzzards Bay, MA 02532
Town of Bourne
Planning Board
24 Perry Avenue, Room 201
Buzzards Bay, MA 02532
Attachment 9: List of Federal, State, and Municipal Agency Permits Anticipated for
Canal Unit 3
Agency
Permit
Federal Aviation Administration (FAA)
Notice of Construction for Stack
U.S. Environmental Protection Agency
(USEPA)
NPDES Stormwater Permits (construction and
operation)
Energy Facilities Siting Board (EFSB)
EFSB Approval
Massachusetts Department of
Environmental Protection
(MADEP)/Bureau of Waste Prevention –
Air Quality
New Source Review/Air Plan Approval
MADEP/Bureau of Waste Prevention –
Air Quality
Federal Prevention of Significant Deterioration
MADEP/Water Management Act Program
Water Management Act Approval
MADEP/Division of Water Quality
Water Quality Certification (integrated in other
approvals)
MADEP/Sandwich Conservation
Commission
Notice of Intent under Wetlands Protection Act
Massachusetts Department of Public
Safety
Aboveground Storage Tank – Fuel Oil Tank
Approval
Massachusetts State Fire Marshall
Hazardous Substance Tank Approval
Massachusetts Department of
Transportation (MassDOT)
Approval under M.G.L. Ch. 40, Section 54A
Cape Cod Commission
Development of Regional Impact Review
Town of Sandwich Old King’s Highway
Historic District Committee
Certificate of Appropriateness
Note: See Attachment 2: Expanded ENF for list of permits required by Canal Community Solar.
Attachment 10: CZM Consistency
This section outlines Canal Unit 3’s consistency with CZM Policies. Consistency of Canal Community Solar is
discussed in Attachment 2.
1.0
MASSACHUSETTS OFFICE OF COASTAL ZONE MANAGEMENT
The Massachusetts Office of Coastal Zone Management (CZM) is the primary policy and planning agency on
coastal and ocean issues within the Executive Office of Energy and Environmental A ffairs (EOEEA). Policies
established by CZM serve as the foundation for the Massachusetts Coastal Program and provide the framework
for all project review activities. Policies are organized into nine categories:

Coastal Hazards

Energy

Growth Management

Habitat

Ocean Resources

Ports and Harbors

Protect Areas

Public Access

Water Quality
The CZM Program was established to protect and manage the development and use of the coastal zone under
the provisions of the Federal Coastal Zone Management Act of 1972. This goal is accomplished by reviewing
proposed activities within the coastal zone in terms of consistency with the CZM Coastal Policies and
Management Principles. The activities proposed in conjunction with construction and operation of the project
comply with the Massachusetts Coastal Program Policies and will be conducted in a manner consistent with such
policies, as set forth in the following sections.
1.1
Coastal Hazards
Hazardous areas are defined as areas susceptible to storm surge and waves, flooding, erosion, and relative sea
level rise.
1.1.1 Coastal Hazards Policy #1
Preserve, protect, restore, and enhance the beneficial functions of storm damage prevention and flood cont rol
provided by natural coastal landforms, such as dunes, beaches, barrier beaches, coastal bank s, land subject to
coastal storm flowage, salt marshes, and land under the ocean.
The propos ed Project will conform with Coastal Hazard Policy #1. The Project will result in alterations to Land
Subject to Coastal Storm Flowage (LSCSF), but will not result in adverse impacts to the storm damage and flood
control functions. As the Project Site is currently occupied by warehouses, trailers, tanks, and temporary parking,
the Project does not represent a significant change in land use.
All energy generating facilities located within the 100 -year floodplain will be constructed in compliance with
Massachusetts State Building Code requirements for structures within the floodplain. Although the entire Project
is proposed within the 100-year floodplain, construction is not expected to result in redirection of storm waves so
as to affect abutting properties.
Canal Unit 3
Attachment 8: CZM Consistency
The floodplain associated with the Cape Cod Canal is regulated as LS CSF under the Massachusetts Wetlands
Protection Act. Impacts to approximately 10.6 acres of LS CSF will result from construction of the energy
generating facilities and ancillary equipment, including access roadways on the Site.
There will be no alteration to coastal bank or land under the ocean. The site does not contain salt marsh, dunes
or barrier beaches. Construction of the new facilities will be entirely within areas previously disturbed for
construction of the existing Canal Generating Station.
1.1.2 Coastal Hazards Policy #2
Ensure that construction in wat er bodies and contiguous land areas will minimize interference with water
circulation and s ediment transport. Flood or erosion control projects must demonstrate no significant adverse
effects on the project site or adjacent or downcoast areas.
The Project will conform wit h Coastal Hazard Policy #2. The Project does not include construction in the Cape
Cod Canal or other water bodies. Construction activities on the Project Site will not interfere with existing water
circulation and sediment transport patterns within the harbor.
1.1.3 Costal Hazards Policy #3
Ensure that state and federally funded public work s projects proposed for locations within the coastal zone will:

Not exacerbate existing hazards or damage natural buffers or other natural resources.

Be reasonably safe from flood and erosion-related damage.

Not promote growth and development in hazard -prone or buffer areas, especially in velocity zones and
Areas of Critical Environmental Concern.

Not be used on Coastal Barrier Resource Units for new or substantial reconstruction of structures in a
manner inconsistent with the Coastal Barrier Resource/Improvement Acts.
The Project is a private project and not a state or federally funded public works project. As such, Coastal Hazards
Policy #3 does not apply.
1.1.4 Coastal Hazards Policy #4
Prioritize acquisition of hazardous coastal areas that have high conservation and/or recreation values and
relocation of structures out of coastal high-hazard areas giving due consideration to the effects of coastal hazards
at the location to the use and manageability of the area.
The Project is a private project and does not include acquisition of hazardous coastal areas. As such, Coastal
Hazards Policy #4 does not apply.
1.2
Energy
These policies are designed to ensure that the development and maintenance of energy resources are completed
with minimal displacement of water-dependent industry and by the least environmentally damaging means
practicable.
1.2.1 Energy Policy #1
For coastally dependent energy facilities, assess siting in alternative coastal locations. For non -c oastally
dependent energy facilities, assess siting in areas outside of the coastal zone. Weigh the environmental and
safety impacts of location proposed energy facilities at alternative sites.
The Project will conform with Energy Policy #1. The Project is a proposed expansion of an existing coastally
dependent energy facility. Canal Generating Station was built in the 1960s as an electric generation unit
dependent on the Cape Cod Canal for fuel deliveries as well as a continuous source of water for its once -through
2
Canal Unit 3
Attachment 8: CZM Consistency
cooling system. The new unit will utilize some of the existing infrastructure, and interconnect into the same
electrical switchyard, which is located adjacent to the south of the existing units.
In selecting the site for the Project, NRG considered a range of alt ernate site locations. The p urpose of the
Project is to respond to an acknowledged need for additional electric generating capacity in the Independent
System Operator-New England (ISO-NE) system. NRG determined that the addition of capacity to one of its
existing power plants is highly preferable to development on a new greenfield site. Adding capacity to an existing
facility has significant technical, financial, and environmental benefits compared to developing a new power plant
on a greenfield site not currently in use for electric generation.
NRG operates seven electric generating plants in New England and evaluated each location in terms of available
space, access to adequate infrastructure, and location within the grid. The Canal site was selected as the
location that best combined adequate space for a new unit, sufficient natural gas supply, and proximity to a
favorable electrical interconnection location. In addition, the Canal facility is located within an ISO -NE zone with a
growing peak demand capacity need.
1.2.2 Energy Policy #2
Encourage energy conservation and the use of renewable sources such as solar and wind power in order to
assist in meeting the energy needs of the Commonwealth.
The Project is consistent with Energy Policy #2. Canal Unit 3 is comprised of a simple-cycle electric generating
unit capable of producing 330 MW of output. As a quick-start, simple-cycle unit, Canal Unit 3 can immediately
respond to fluctuations in energy demand. This type of electric generating unit is an excellent complement to
intermittent energy resources, such as wind and solar, as it can balance the fluctuating output of those resources.
1.3
Growth Management
The Commonwealth of Massachusetts and the EOEEA have made significant efforts to manage community
growth, particularly the effects of growth on environmental resources. Though most of the land us e and zoning
decisions within the Commonwealth fall under local control, there are several state policies, tools, and incentives
that seek to promote and support sustainable development.
1.3.1 Growth Management Policy #1
Encourage sustainable development that is consistent with state, regional, and local plans and supports the
quality and character of the community.
The Project will conform with Growth Management Policy #1. Th e Project proposes to develop an underutilized
portion of the existing Canal Generating Station property. By locating the new unit wit hin a site properly zoned
for, and currently engaged in, electric generation, the Project is consistent with the current and future land use
plans for the Property.
The Sandwich Local Comprehensive Plan, issued in May 2009, encourages collocation of industrial and
commercial development to conserve land and minimize adverse impacts. The Project will be developed
adjacent to an existing steam electric generating plant, whic h has been in operation since 1968, on land zoned for
industrial and commercial development. Trans port ation, wat er, and electrical transmission infrastructure, built to
support the existing facility, will be utilized to s erve the Project; therefore, no construction of new water
infrastructure to a previously unserved area will be required.
The Cape Cod Regional Policy Plan, issued by the Cape Cod Commission in January 2009, and amended in
August 2012, identifies the need for efficient and collocated land uses to minimize adverse impacts, and
emphasizes that towns should adopt policies and regulations that encourage development within Economic
Cent ers. The Project involves the development of a new simple -cycle power plant within property already
occupied by a steam electric generation plant and designated as an Economic Center on the Cape Cod Regional
3
Canal Unit 3
Attachment 8: CZM Consistency
Land Use Vision Map. Additionally, the Cape Cod Regional Policy Plan identifies the need for adequate capital
facilities and infrastructure, such as a reliable energy source, to meet community and regional needs and support
economic growth.
1.3.2 Growth Management Policy #2
Ensure that state and federally funded infrastructure projects in the coastal zone primarily s erve existing
developed areas, assigning highest priority t o projects that meet the needs of urban and community development
centers.
The proposed facility is a private project and will not rec eive state or federal funding.
Management Policy #2 does not apply.
As such, Growth
1.3.3 Growth Management Policy #3
Encourage the revit alization and enhancement of existing development centers in the coastal zone through
technical assistance and financial support for residential, commercial, and industrial development.
The proposed facility is a private project and is not receiving technical assistance or financial support. As such,
Growth Management Policy #3 does not apply.
1.4
Habitat
CZM attempts to balance the protection of coastal, estuarine, and marine habitats for their important ecosystem
functions and human services with other management interests.
1.4.1 Habitat Policy #1
Protect coastal, estuarine, and marine habitats – including salt marshes, shellfish beds, submerged aquatic
vegetation, dunes, beaches, barrier beaches, banks, salt ponds, eelgrass beds, tidal flats, rock y shores, bays,
sounds, and other ocean habitats – and coastal freshwat er streams, ponds, and wetlands to preserve critical
wildlife habitat and other important functions and services including nutrient and sedim ent attenuation, wave and
storm damage protection, and landform movement and processes.
The proposed facility conforms with Habitat Policy #1. As none of the coastal, estuarine, and marine habitats
listed in Habitat Policy #1 occur on the Site, there will be no impacts to existing nutrient and sediment
attenuations, wave and storm damage protection, and landform movement and processes. There is no critical
wildlife habitat located on the Site.
1.4.2 Habitat Policy #2
Advance the restoration of degraded or former habitats in coastal and marine areas.
The proposed facility conforms with Habitat Policy #2. Th e Site is a developed industrial site and is located
adjacent to the Cape Cod Canal. By avoiding degraded or former marine habitats, the Project does not preclude
restoration of those areas.
1.5
Ocean Resources
Near and offshore wat ers of the Commonwealth are managed to avoid advers e effects and incompatibility in
order to protect the integrity of ocean resources and ecosystem services and to accommodate compatibility and
sustainable use.
1.5.1 Ocean Resources Policy #1
Support the development of sustainable aquaculture, both for commercial and enhancement (public shellfish
stock ing) purposes. Ensure that the review process regulating aquaculture facility sites (and assess routes to
4
Canal Unit 3
Attachment 8: CZM Consistency
those areas) protects significant ecological resources (salt marshes, dunes, beaches, barrier beaches, and salt
ponds) and minimizes adverse effects on the coastal and marine environment and other water-dependent uses.
The Project does not involve an aquaculture facility. As such, Ocean Resources Policy #1 does not apply.
1.5.2 Ocean Resources Policy #2
Except where such activit y is prohibited by the Ocean Sanctuaries Act, the Mass achusetts Ocean Management
Plan, or ot her applicable provision of law, the extraction of oil, natural gas, or marine minerals (other than sand
and gravel) in or affecting the coastal zone must protect marine resources, marine water qualit y, fisheries, and
navigational, recreational, and other uses.
The Project does not involve extraction of oil, natural gas or marine minerals. As such, Ocean Resources Policy
#2 does not apply.
1.5.3 Ocean Resources Policy #3
Accommodate offshore sand and gravel extraction needs in areas and in ways that will not adversely affect
marine resources, navigation, or shoreline areas due to alteration of wave direction and dynamics. Extraction of
sand and gravel, when and where permitted, will be primarily for the purpose of beach nourishment or shoreline
stabilization.
The Project does not involve offshore mining of sand and gravel. As such, Ocean Resource Policy #3 does not
apply.
1.6
Ports and Harbors
Waterways and port resources of the Commonwealth must be maint ained and improved by the least
environmentally damaging practicable alternatives.
1.6.1 Ports and Harbors Policy #1
Ensure t hat dredging and disposal of dredged material minimize adverse effects on water quality, physical
processes, marine productivity, and public health and tak e full advantage of opportunities for beneficial re -use.
The Project does not involve dredging. As such, Ports and Harbors Policy #1 does not apply.
1.6.2 Ports and Harbors Policy #2
Obtain the widest possible public benefit from channel dredging and ensure that designated Port Areas and
developed harbors are given highest priority in the allocation of resources.
The Project does not involve dredging. Moreover, the Project also does not involve public funds or allocation of
public resources. As such, Ports and Harbors Policy #2 does not apply.
1.6.3 Ports and Harbors Policy #3
Preserve and enhance the capacity of Designated Port Areas to accommodate water -dependent industrial uses
and prevent the exclusion of such uses from tidelands and any other DPA lands over which an EOEEA agency
exerts control by virtue of ownership of other legal authority.
The Project is not located within a Designated Port Area. As such, Ports and Harbors Policy #3 does not apply.
1.6.4 Ports and Harbors Policy #4
For development on tidelands and other coastal wat erways, preserve and enhanc e the immediate waterf ront for
vessel-relat ed activities that require sufficient space and suitable facilities along the water’s edge for operational
purposes.
5
Canal Unit 3
Attachment 8: CZM Consistency
Although located proximate to the Cape Cod Canal, the Project is not located on filled or flowed tidelands. The
Property is separat ed from the Cape Cod Canal by an approximately 18-foot wide public walkway. The majority
of activities associated with the P roject will occur on the Project Site, which is more than 350 feet south of this
public walk way; however, the proposed natural gas interconnection will run west-to-east approximat ely 35 feet
south of this path.
All Project work will occur within the Property’s fence line, and will not affect the immediate wat erfront or public
areas closer to the water. As such, the Project is consistent with Ports and Harbors Policy #4.
1.6.5 Ports and Harbors Policy #5
Encourage, through technical and financial assistance, expansion of water -dependent uses in Designated Port
Areas and developed harbors, re-development of urban waterfronts, and expansion of physical and visual access.
The Project is a privat e project, not located in a Designated Port Area, and will not receive direct technical or
financial assistance to expand water-dependent uses, redevelopment of urban waterfronts or expansion of
physical or visual access. As such, Ports and Harbors Policy #5 does not apply.
1.7
Protected Areas
CZM protects recognized complexes of marine resources by ensuring that activities in or affecting such areas
avoid or minimize adverse effects.
1.7.1 Protected Areas Policy #1
Preserve, restore, and enhance coastal Areas of Critical Environmental Conc ern, which are complexes of natural
and cultural resources of regional or statewide significance.
There are no A reas of Critical Environmental Concern on the Project Site or in the surrounding area surrounding.
As such, Protected Areas Policy #1 does not apply.
1.7.2 Protected Areas Policy #2
Protect state designated scenic rivers in the coastal zone.
There are no designated scenic rivers on the Project Site or in the surrounding area surrounding. As such,
Protected Areas Policy #2 does not apply.
1.7.3 Protected Areas Policy #3
Ensure that proposed developments in or near designat ed or registered historic plac es respect the preservation
intent of the designation and that potential adverse effects are minimized.
The Project will conform with Prot ected Areas Policy #3. The Project is propos ed on land adjacent to the Canal
Electric Company Plant, a Historic Structure listed on the Massachusetts State Register of Historic Places
(SRHP) and recognized by the Town of S andwich. The Property is also located in the Old Kings Highway Historic
District, a recognized historic resource on the SRHP and the National Register of Historic Places. Based on this
location, the Project must obtain a Certification of Appropriateness with the Town of Sandwic h Old King’s
Highway Historic District Committee prior to commencement of construction activities.
Development of the Project Site with a state-of-the-art natural gas- and ULSD-fired peak electric generating
facility will not adversely affect the nearby historic resources. The proposed generati on of electricity is a
continuation of the long-standing use of the Property and does not represent a significant inc rease in the intensity
of that use. Heights of Project elements will be lower than the existing buildings and stacks.
6
Canal Unit 3
1.8
Attachment 8: CZM Consistency
Public Access
CZM attempts to promote, maintain, and improve efforts to help the public get to and enjoy the coast and coastal
zone.
1.8.1 Public Access Policy #1
Ensure that development (both wat er-dependent or nonwater-dependent) of coastal sites subject to state
waterways regulation will promote general public use and enjoyment of the water’s edge, to an extent
commensurate with the Commonwealth’s interests in flowed and filled tidelands under the Public Trust Doctrine .
The Project will conform with Public Access Policy #1. There are no filled tidelands located on the Project Site.
The Property does have several associated Chapt er 91 Licenses for in-water work which occurred in the Cape
Cod Canal during construction of the Canal Generating Station. Any work within the Cape Cod Canal would
require a Chapter 91 License; however, no in-wat er work is proposed for the P roject. The new facilities will be
located in uplands, well inland of flowed tidelands.
A public access walkway is located between the northern Property boundary, marked by a fence, and the Cape
Cod Canal. No alteration of this public area is proposed. The proposed simple-cycle unit will be located on the
southeast portion of the Property, closer to the southern P roperty line; therefore, no adverse impacts to the
walkway are anticipated.
1.8.2 Public Access Policy #2
Improve public access to existing coastal recreation facilities and alleviate auto traffic and park ing problems
through improvements in public transportation and trail link s (land- or water-based) to other nearby facilities.
Increase capacity of existing recreation areas by facilitating multiple use and b y improving management,
maintenance, and public support facilities. Ensure that the adverse impacts of developments pr oposed near
existing public access and recreation sites are minimized.
The Project will conform wit h Public Access Policy #2. An existing waterfront walkway, bet ween the northern
Property boundary and the Cape Cod Canal, affords public access along the wat erfront and will not be altered by
the Project. The new simple-cycle unit is proposed on the southeast portio n of the Property, away from the
waterfront, immediately adjacent to the much larger existing power plant units, in an area that is not currently
accessible to the public.
1.8.3 Public Access Policy #3
Expand existing recreation facilities and acquire and develop new public areas for coastal recreational activities,
giving highest priorit y to regions of high need or limited site availability. Provide technical assistance to
developers of both public and private recreation facilities and sites that increase public access to the shoreline to
ensure that both transportation access and the recreation facilities are compatible with social and environmental
characteristics of surrounding communities.
The Project will conform with Public Access Policy #3. A public access walkway is located bet ween the Project
and the Cape Cod Canal. No change to the character of the Property is proposed, and the Project will not
preclude expanded development of the waterfront for coastal recreational activities.
1.9
Water Quality
The Massachusetts coastal management program supports the attainment of state and national water quality
goals for all waters of the coastal zone.
7
Canal Unit 3
Attachment 8: CZM Consistency
1.9.1 Water Quality Policy #1
Ensure t hat point-source discharges and withdrawals in or affecting the coastal zone do not compromise water
quality standards and protect designated uses and other interests.
The Project will conform with Water Quality Policy #1. The Project will not result in the point -source discharge of
process wastewater flows or t he withdrawal of water from t he Cape Cod Canal. The simple-cycle unit does not
require steam condenser cooling; ancillary equipment will be air-cooled through fin fan coolers. The minimal
process wastewater from the proposed unit will be treated in a near-z ero liquid discharge facility or trucked offsite.
Construction stormwat er runoff from t he Site will be managed in accordance with the USEPA’s National P ollutant
Discharge Elimination System (NPDES) Construction General Permit. Operation stormwater management will be
designed to meet the Massachusetts Stormwater Standards prior to discharging into an infiltration pond.
1.9.2 Water Quality Policy #2
Ensure the implementation of nonpoint source pollution cont rols to promote the attainment of water quality
standards and protect designated uses and other interests.
The Project will conform with Water Quality Policy #2. Construction nonpoint source pollution cont rol measures
will be included in the Stormwater Pollution P revention Plan in accordance wit h the USEPA’s NDPES
Construction General P ermit. Post development or operational controls will include the implementation of an
operation and maintenance plan.
1.9.3 Water Quality Policy #3
Ensure that subsurface water discharges conform to applicable standards, including the siting, construction, and
maintenance requirements for on-site wastewater disposal systems, water qualit y standards, established Total
Maximum Daily Load limits, and prohibitions on facilities in high-hazard areas.
There will be no subsurface waste discharges associated with the P roject. As such, Water Quality Policy #3 does
not apply.
8
Attachment 11: Water Supply Section Figure

Figure 8 – Map of Drilling Sites for Well No. 4
Figure 8
Drilling Sites for Well No. 4
NRG Canal 3 Development LLC
NRG Renew Canal 1 LLC
Sandwich, Massachusetts
Attachment 12: Application Cover Sheet
Application Cover Sheet
For Commission Use Only
Date Received:
Fee ($):
Check No:
File No:
Cape Cod Commission
3225 Main Street, PO Box 226
Barnstable, MA 02630
Tel: (508) 362-3828 • Fax: (508) 362-3136
A
Type of Application (check all that apply)
Development of Regional Impact (DRI)
Hardship Exemption
Jurisdictional Determination
DRI Exemption
Limited DRI Review
X
Request for Joint MEPA/DRI Review
B Project Information
NRG Canal 3 Development Project
Project Name: ____________________________________________________________
52.02 acres
Total Site Acreage: __________________________
9 Freezer Road, Sandwich, Barnstable County, MA 02563
Project/Property Location: ___________________________________________________
Industrial
Zoning: ___________________________________
Brief Project Description:
Include total square footage of proposed and existing development, gross floor area, number of lots existing or to be created, specific uses, description of existing conditions, as applicable (attach additional sheets if necessary).
See Attached Sheet.
______________________________________________________________________________________________________________________________________
______________________________________________________________________________________________________________________________________
______________________________________________________________________________________________________________________________________
______________________________________________________________________________________________________________________________________
C Owner(s) of Record
List the following information for all involved parcels. Provide copies of each Deed and Purchase and Sale Agreement and/or evidence of leasehold interest, if applicable, for all involved parcels. Proof of ownership/legal rights for Applicant(s) to proceed with the proposed development must
be documented prior to the Commission deeming any application complete (attach additional sheets if necessary).
Map/Parcel
Owner’s Name
Lot & Plan
Land Court Certificate of Title #
Registry of Deeds Book/Page #
Map 91 Lot 3
NRG Canal LLC*
Lot 7 Plan 14716-D
Ctf. No. 151549
______________________________________________________________________________________________________________________________________
Map 92 Lot 2
NRG Canal LLC*
Plan 33200A
Ctf. No. 151549
______________________________________________________________________________________________________________________________________
*Southern Energy Canal LLC has changed its name to NRG Canal LLC
______________________________________________________________________________________________________________________________________
There ARE/ARE NOT (circle one) court claims, pending or completed, involving this property (if yes, please attach relevant information).
D Certification
BILLABLE
ENTITY
PROPERTY
OWNER
CONTACT
CO-APPLICANT
APPLICANT
I hereby certify that all information provided on this application form and in the required attachments is true and accurate to the best of my
knowledge. I agree to notify the Cape Cod Commission of any changes on the information provided in this application, in writing, as soon
as is practicable. I understand failure to provide the required information and any fees may result in a procedural denial of my project.
NOTE: For wireless communication facilities, a licensed carrier should be either an applicant or a co-applicant.
(617) 529-3874
NRG Canal 3 Development LLC
Applicant(s) Name: ______________________________________
Tel: _______________________
Fax: _________________________
9 Freezer Road, Sandwich, Barnstable County, MA 02563
Address: __________________________________________________________________________________________________________
Signature: ______________________________________________
7/30/2015
Date: ___________________________
Co-Applicant(s) Name: ___________________________________ Tel: _______________________ Fax: __________________________
Address: __________________________________________________________________________________________________________
Signature: ______________________________________________
Date: ___________________________
Shawn Konary
(617) 529-3874
Contact: _______________________________________________
Tel: _______________________
Fax: _________________________
9 Freezer Road, Sandwich, Barnstable County, MA 02563
Address: __________________________________________________________________________________________________________
Signature: ______________________________________________
7/30/2015
Date: ___________________________
(617) 529-3874
NRG Canal LLC*
Property Owner: ________________________________________
Tel: _______________________
Fax: _________________________
9 Freezer Road, Sandwich, Barnstable County, MA 02563
Address: __________________________________________________________________________________________________________
Signature: ______________________________________________
7/30/2015
Date: __________________
*Southern Energy Canal LLC has changed its name to NRG Canal LLC
(617) 529-3874
NRG Canal 3 Development LLC
Name: _________________________________________________
Tel: _______________________
Fax: _________________________
9 Freezer Road, Sandwich, Barnstable County, MA 02563
Address: __________________________________________________________________________________________________________
Page 1 of 2
Cape Cod Commission - Application Cover Sheet
(Continuation Page 1a)
Brief Project Description:
NRG Canal LLC owns approximately 88 acres of land in the Town of Sandwich at which the existing
Canal Generating Station and ancillary structures and infrastructure currently are located (the “Property”).
As shown on Attachment 3, Figure 1, the Property is comprised of two separate areas. The two areas are
bisected by a separate parcel owned by MassDOT and operated as an active railroad right-of-way (ROW)
by the Cape Cod Central Railroad.
The northern portion of the Property (the “Northern Area”) comprises approximately 52 acres
(approximately 48 acres of land above water and 4 acres of land under the water) on which in-water work
was completed for infrastructure associated with the existing Canal Generating Station. The Northern
Area is bounded by Freezer Road and land owned by the US Army Corps of Engineers (Corps) to the
east; by Canal Service Road and the Cape Cod Canal to the north; the Town of Bourne to the west; and
Rickey’s Road and railroad ROW to the south. The majority of the Northern Area is currently developed
to support the existing Canal Generating Station, which includes two dual-fueled electric generation units
totaling approximately 1,120 MW, a 498-foot high exhaust stack, several aboveground oil storage tanks,
ammonia storage tanks, and appurtenant structures and infrastructure. The Northern Area is located
within the Massachusetts Coastal Zone and a majority of the Northern Area is located within the FEMAMapped 100 year flood zone. The Northern Area is zoned “Industrial Limited.”
NRG Canal 3 Development LLC (“NRG Canal 3”), a business affiliate of NRG Energy, Inc.’s Wholesale
Business division, seeks to permit, construct, and operate a state-of-the-art, fast-starting, dual-fueled
simple-cycle electric generating facility (“Canal Unit 3”) proposed on the Northern Area. Canal Unit 3
will utilize a single General Electric (GE) 7HA.02 combustion turbine with an approximate net nominal
capacity of 320 MW and will operate during peak times of energy demand, for up to 4,380 hours per year
with a maximum of 1,440 hours on ultra-low sulfur distillate (ULSD) to provide the flexibility and
reliability to meet the region’s demonstrated power needs. Canal Unit 3 will include an approximately
213-foot tall stack.
Canal Unit 3 is proposed on approximately 12 acres on the Northern Area (the “Simple-Cycle Site”), of
which Canal Unit 3 will permanently occupy 10.6 acres, with natural gas and ULSD interconnections
running west-to-east along existing interconnection corridors. The Simple-Cycle Site is currently
occupied by concrete-slab, aluminum-sided warehouses, two ammonia storage tanks, several temporary
trailers, and hard-packed open area used for temporary parking. An electrical interconnection will
connect the simple-cycle unit to the existing electrical grid via the Eversource-owned switchyard, located
to the south from the Northern Area, across Rickey’s Road and the Cape Cod Central Railroad ROW,
owned by Massachusetts Department of Transportation (MassDOT). Temporary use of land within the
Northern Area will occur during construction for parking and laydown. The proposed in-service date for
Canal Unit 3 is June 2019.
REQUIRED FILING MATERIALS
The following must be attached to the Application Form at the time of its filing:

X
Certified List of Abutters (required for all application types except Attachment 5, Jurisdictional
Determination). A list of abutting property owners within 300 feet of the boundaries of the development site and their addresses. Include both local and off-Cape addresses when applicable.

X
X

N/A 
N/A 

X

X

X
This list must be formatted in three columns consistent with the Standard Label Format
designed to print on Avery Labels #5160.
List must be certified by the Town Assessor’s office. Note: Assessor’s offices may take up to
10 days to certify an abutter’s list.
If there are more than 50 abutters, applicants must provide three sets of the certified list on
self-adhesive labels.
Required Filing Fee. Please calculate according to the Schedule of Fees (see Enabling Regulations, Section 14). Please make check payable to BARNSTABLE COUNTY TREASURER.
An 8 1/2”x 11” copy of the U.S.G.S. quadrangle map of the area, containing sufficient information
for the Commission to locate the site of the proposed development.
See Attachment 2, Figure 1.
Development Plans. File as required for each application type you are making. See list of
Attachment(s) below for specific instructions.
See Attachment 5, Figure 7.
Permits or Actions. List of local, state, or federal agencies or boards from which a permit or other
actions have, will, or may need to be sought. Include agency/board name, type of permit, date
filed, and file number. If one of the listed permits or actions requires the filing of an Environmental
Notification Form under the Massachusetts Environmental Policy Act (MEPA), please contact the
Commission’s Chief Regulatory Officer to discuss the potential for joint Commission and MEPA
review. For information on MEPA regulations contact the Executive Office of Energy and Environmental Affairs, MEPA Unit, at (617) 626-1020. Please attach all relevant MEPA documents and
describe the status of the MEPA filing.
See Attachment 7.
Applicants must also submit the necessary attachment(s) based on the type of application(s) being made:
Attachment 1: Attachment 2: Attachment 3: Attachment 4: Attachment 5: Attachment 6: DRI Application Filing Procedures & Requirements
DRI Exemption Application Filing Procedures & Requirements
Hardship Exemption Application Filing Procedures & Requirements
Limited DRI Review Application Filing Procedures & Requirements
Jurisdictional Determination Application Filing Procedures & Requirements
Joint MEPA/DRI Review Application
Page 2 of 2
SECTION II. REQUIRED SUBMITTALS:
X

1. Application Cover Sheet and its Required Filing Materials.
The Application should include a statement that if an EIR is required, the EIR will cover issues
of concern to, and within the jurisdiction of, both MEPA and the Commission.
X

2. A completed Environmental Notification Form (ENF), as required by t h e
Massachusetts Executive Office of Environmental Affairs – MEPA Unit.
X

3. Massachusetts Historical Commission (MHC) Notification Form. Applicant must
complete and submit a Project Notification Form (PNF) to the MHC (PNF may be obtained
from
Commission
staff
or
from
MHC’s
web
site
(http://www.sec.state.ma.us/mhc/mhcform/formidx.htm).
See Attachment 10.
See Attachment 12.
a.  If the proposed project involves demolition or alteration of a historic structure,
current photographs of the historic structure and elevation drawings showing all
proposed building facades should be included with the PNF. (This will allow MHC t o
provide comments on the PNF more quickly.) Copies of all submitted materials must
be provided to the Commission.
X Submit proof of receipt of PNF by the MHC.
b. 
X

4. Certification of Local Filing. Provide certification of filing copies of this completed
application with all relevant municipal agencies, including any local board before which a
permit is pending or action is required for this proposed project. It is the ongoing
responsibility of the Applicant to continue to provide these municipal agencies and boards with
all materials provided to the Commission throughout the Joint Review process.
See Attachment 13.
X 5.

Development Plans & Supporting Studies.
Applications for Joint Review that are initiated at the ENF filing stage should include the
information required in sections A, B and C below. Applications for Joint Review that are initiated
at the EIR filing stage (or any EIR prepared for a Joint Review) should include the information
required in sections D and E below.
*** FOR JOINT REVIEW INITIATED AT ENF FILING ***
A.
X

Plan Size Requirements. For each plan submitted, provide each of the following:
Copy of plan(s) reduced to fit sheet size 11" x 17"
See Attachment 5, Figure 7.
B.
Existing Conditions Plans.
Submit Existing Conditions Plan including gross square footage calculations of existing
building(s) on the project site (following Plan Size Requirements listed in 5(A) above), as
well as photographs and/or any other pertinent information illustrating the most recent
use(s) of the site.
See Attachment 3, Figure 4, and Attachment 14.
C.
Proposed Development Plans.
Plans should illustrate the proposed project clearly, although the design does not
need to be fully developed at the ENF stage.
X All plans should be drawn at an appropriate scale that provides sufficient detail t o

understand the project.
N/A  If the plan requires more than one sheet, a cover sheet showing the entire property
must be included.
X
 Include a locus map with the outline of the entire property clearly shown.
See Attachment 2, Figure 1.
Attachment 6 (5/2/05)
Page 3 of 4
*** FOR JOINT REVIEW INITIATED AT EIR FILING and INFORMATION TO BE
INCLUDED IN ALL JOINT REVIEW EIRS ***
D.
Required Plans.
Plans submitted for Joint Review at EIR stage should include all information necessary for
DRI review as listed in Section II (4), Attachment 1: DRI Application Filing Procedures &
Requirements, that may be obtained from Commission staff or the Commission’s web site
(www.capecodcommission.org).
E.
Supporting Studies, Reports, or Information.
Supporting Studies, Reports, or Information needed for DRI review should be included at the
EIR stage of the Joint Review and should include all information listed in Section II (5),
Attachment 1: DRI Application Filing Procedures & Requirements, that may be obtained
from Commission staff or the Commission’s web site (www.capecodcommission.org).
SECTION III. IMPORTANT NOTES AND POLICIES:
If you have any questions or require assistance in completing this application form, please contact
a member of the Commission’s regulatory staff at (508) 362-3828. A copy of the current
Regional Policy Plan and Commission Regulations are available at the Commission office or on the
web at www.capecodcommission.org.
Applicant’s Responsibility to Pay Costs of Legal Notices and Other Fees
The Applicant is responsible to pay for the actual costs of publishing and mailing legal notices
throughout the Joint Review process. Please see the Schedule of Fees (within the Enabling
Regulations) for these and other charges that are the responsibility of the Applicant. All publishing
and mailing notices for the DRI review shall also be the responsibility of the Applicant.
Attachment 6 (5/2/05)
Page 4 of 4
Attachment 13: Certified Abutters List for Canal Unit 3
Attachment 14: MHC Project Notification Form

MHC Notification Form

Proof of Receipt of PNF by MHC
950 CMR: OFFICE OF THE SECRETARY OF THE COMMONWEALTH
APPENDIX A
MASSACHUSETTS HISTORICAL COMMISSION
220 MORRISSEY BOULEVARD
BOSTON, MASS. 02125
617-727-8470, FAX: 617-727-5128
PROJECT NOTIFICATION FORM
(1) Canal Unit 3; (2) Canal Community Solar
Project Name: ________________________________________________________________________________
9 Freezer Road
Location / Address: ___________________________________________________________________________
Sandwich
City / Town: ________________________________________________________________________________
Project Proponent
(1) NRG Canal 3 Development LLC; (2) NRG Renew Canal 1 LLC
Name: ______________________________________________________________________________________
9 Freezer Road
Address: ____________________________________________________________________________________
Sandwich, Barnstable County, MA, 02563, (508) 833-5363
City/Town/Zip/Telephone: _____________________________________________________________________
Agency license or funding for the project (list all licenses, permits, approvals, grants or other entitlements being
sought from state and federal agencies).
Agency Name
Type of License or funding (specify)
See attached Continuation Page 1a.
Project Description (narrative):
See attached Continuation Page 1b.
Does the project include demolition? If so, specify nature of demolition and describe the building(s) which
are proposed for demolition.
The Project will include demolition of several slab-based, aluminum-sided warehouse structures which currently occupy
the Simple­Cycle Site (Photograph 3). Several trailers and two ammonia storage tanks will also be relocated within the
Property (Photograph 4). No structural demolition is required at the Solar Site, however, clearing of wooded vegetation
and scrub/shrub will occur. A vegetated buffer will be left around the solar array to minimize visual impact.
Does the project include rehabilitation of any existing buildings? If so, specify nature of rehabilitation
and describe the building(s) which are proposed for rehabilitation.
The Project does not include rehabilitation of any existing buildings.
Does the project include new construction? If so, describe (attach plans and elevations if necessary).
Construction of Canal Unit 3 will include a GE 7HA.02 generating unit, or equivalent, an approximatly 213­foot tall exhaust
stack, several interconnections, and associated ancillary equipment. Canal Solar will include installation of two solar arrays
comprised of 305­Watt LG photovolatic modules. All elements will be no taller than existing structures, and contained within
the 88­acre Property. Plot Plans for Canal Unit 3 and Canal Solar are attached.
5/31/96 (Effective 7/1/93) - corrected
950 CMR - 275
MHC Project Notification Form
(Continuation Page 1a)
List of Agency Permits Potentially Required
Agency Name
Type of License
Comments
Federal Aviation Administration
(FAA)
Notice of Construction for Stack
Existing structures will be taller than
proposed Project elements
U.S. Army Corps of Engineers
(USACE)
Programmatic General Permit
Not anticipated, as wetlands can
likely be avoided
U.S. Environmental Protection
Agency (USEPA)
NPDES Stormwater Discharge
Permits (construction and operation)
Energy Facilities Siting Board
(EFSB)
EFSB Approval
Massachusetts Department of
Environmental Protection
(MADEP)/Bureau of Waste
Prevention – Air Quality
PSD/NSR/Air Plan Approval/Title V
Operating Permit Modification
MADEP/Division of Water Quality
Industrial Discharge Permit
MADEP/Division of Water Quality
Water Quality Certification
MADEP/Division of Waterway
Chapter 91 License
Not anticipated, as no in-water work
is proposed
MADEP/Sandwich Conservation
Commission
Request for Determination of
Applicability and/or Notice of Intent
under Wetlands Protection Act
Associated with Land Subject to
Coast Storm Flowage
Massachusetts State Fire Marshall
Hazardous Substance Tank Approval
Massachusetts Department of
Transportation (MassDOT)
Approval under M.G.L. Ch. 40,
Section 54A
Coastal Zone Management (CZM)
Federal Consistency Concurrence
Cape Cod Commission
Development of Regional Impact
Review
Joint review with MEPA
Town of Sandwich Old King’s
Highway Historic District
Committee
Certificate of Appropriateness
Proposed work is consistent with
goals and policies of the Town.
MCH Project Notification Form
(Continuation Page 1b)
Proposed Description (narrative):
NRG Canal 3 Development LLC seeks to permit, construct, and operate a dual-fueled simple cycle
electric peaking unit (Canal Unit 3) and NRG Renew Canal 1 LLC seeks to permit, construct, and operate
a photovoltaic solar array (Canal Solar). Both projects are proposed to be located within the existing
Canal Generating Station property in Sandwich, Barnstable County, Massachusetts. The Property is
bisected by an existing railroad right-of-way, with the 52-acre Northern Area proposed for Canal Unit 3
and the 36-acre Southern Area proposed for Canal Solar.
Although the two proposed projects will only occupy a fraction of the Canal Generating Station property,
review of the entire 88-acre Property (see Figure 1) is requested, as project-related interconnections and
relocation of existing facilities may occur in selected locations. The Property is bounded by Freezer Road
to the East; by Canal Service Road to the North; the Town of Bourne to the west; and Tupper Road and
Route 6A to the south. The existing Canal Generating Station occupies the entire northwestern portion of
the Property. To the North, beyond Canal Service Road, is the Cape Cod Canal; East Boat Basin, a
recreational and commercial marina, lies east of the Property, on the eastern side of Freezer Road. The
entire Property is located within the Massachusetts Coastal Zone, with a majority of the Property located
within the 100-year flood zone as delineated by Federal Emergency Management Agency (FEMA).
Much of the Northern Area is currently developed to support the existing Canal Generating Station, a
1,200-megawatt dual-fueled steam electric generating plant, located adjacent to the proposed SimpleCycle Site (Photographs 1 – 4). Two large aboveground storage tanks are located on the northern portion
of the Southern Area, adjacent to the proposed Solar Site (Photographs 5 – 8). A switchyard and
associated high-voltage transmission lines, owned by Eversource (formerly known as NSTAR) and
located on Rickey’s Road south of the existing units, connect the generating units to the New England
power grid.
950 CMR: OFFICE OF THE SECRETARY OF THE COMMONWEALTH
APPENDIX A (continued)
To the best of your knowledge, are any historic or archaeological properties known to exist within the
project’s area of potential impact? If so, specify. The Canal Generating Station is designated by the Town
of Sandwich as a Historic Site within the Old King's Highway Regional Historic District. Proposed structural
development and alterations in this District are subject to review and approval by the Town's Old King's Highway
Historic Commission. The proposed Project is consistent with the goals and policies of the Town; therefore, the
Project is not anticipated to significantly affect any known historical or archaeological resources.
What is the total acreage of the project area?
Woodland ______________
acres
2.2
Wetland________________
acres
5.5
Floodplain______________
acres
57.3
Open space______________
acres
9.8
Developed ______________
acres
49.7
Productive Resources:
Agriculture _________________
acres
0
Forestry ___________________
acres
0
Mining/Extraction ___________
acres
0
Total Project Acreage_________
acres
88
What is the acreage of the proposed new construction? _________________
acres
22
What is the present land use of the project area? Much of the Property is developed to support the existing
Canal Generating Station, a 1,200-megawatt steam electric generating plant which includes two dual-fueled
electricity generating units, a 498-foot high exhaust stack, several oil tanks, ammonia storage tanks, and appurtenant
facilities. A switchyard and associated high-voltage transmission lines, located on Rickey's Road, connect the station
to the power grid. The Nothern Area, on which the existing generaiton station is located and Canal Unit 3 is proposed,
is zoned “Industrial,” and the Southern Area, on which Canal Solar is proposed, is zoned “Business Limited.”
Please attach a copy of the section of the USGS quadrangle map which clearly marks the project location.
See Figure 1.
This Project Notification Form has been submitted to the MHC in compliance with 950 CMR 71.00.
Signature of Person submitting this form: _________________________________Date: ____________________
Bruce
Name:Jackie
______________________________________________________________________________________
Littleton Road, Suite 201-B
Address: 238
____________________________________________________________________________________
MA, 01886
City/Town/Zip: Westford,
______________________________________________________________________________
212-3284
Telephone: (978)
__________________________________________________________________________________
REGULATORY AUTHORITY
950 CMR 71.00: M.G.L. c. 9, §§ 26-27C as amended by St. 1988, c. 254.
7/1/93
950 CMR - 276
N
NH
H
V
V TT
Legend
N
NY
Y
MA
USGS Topographic Map
Canal Property
Project
Location
R
R II
¯
!
C
C TT
Atla nti
c Oc
ea n
0
500 1,000
2,000
Feet
NRG Renew Canal 1 LLC
NRG Canal 3 Development LLC
Sandwich, Massachusetts
Photograph 4
Photograph 3
LEGEND
Northern Area
Simple­Cycle Site
Overview of Photograph Locations for Canal Unit 3
Photographs 1 & 2
Photograph 1. The Project Site
(view toward the southwest)
Photograph 2. The Project Site
(view toward the northwest)
Photograph 3. Warehouses to be demolished
(view toward the northwest)
Photograph 4. Ammonia tanks & trailers to be relocated
(view toward the northwest)
Photograph 5. View of Solar Site
(view toward the northeast)
Photograph 6. View of Solar Site
(view toward the north)
Photograph 5. View of Solar Site
(view toward the northwest)
Photograph 5. View of Solar Site
(view toward the south)
LEGEND
001 GAS TURBINE GE 7HA.02
002 GENERATOR
003 SCR/CO2 CATALYST
004 TEMPERING/PURGE FANS
005 STACK
N
H
006 EMERGENCY DIESEL GENERATOR
007 LUBE OIL SKID
008 CEMS
009 COMPRESSED AIR SYSTEM
010 COOLING FAN MODULE
011 EXISTING WELL NO.4
012 SERVICE WATER/FIRE PROTECTION PUMP HOUSE
013 DEMINERALIZED WATER SYSTEM
014 WATER TREATMENT PLANT
015 HYDROGEN STORAGE AREA
016 EXISTING TRAINING BLDG. / NEW CONTROL RM.
017 EXISTING AMMONIA STORAGE AREA
018 GAS COMPRESSOR
019 GAS PRE-HEATER AREA
020 NEW GAS LINE
021 NEW FUEL OIL LINE
022 GSU TRANSFORMER
023 PDC
024 TRANSMISSION LINES
025 SLUDGE ROLL-OFF BIN
026 OIL WATER SEPARATOR
G
027 DELETED
028 EVAP0RATOR COOLER BLOWDOWN COLLECTION TANK
029 SERVICE WATER/FIRE WATER TANK
030 DEMINERALIZED WATER TANK
031 CO2 STORAGE AREA
032 FUEL OIL PUMP HOUSE
F
E
D
C
NOTES:
1. ROAD MAY NEED TO BE ADJUSTED AFTER SURVEY LOCATION OF RAILWAY TRACKS.
2. ELEVATIONS MAY NEED SOME ADJUSTMENT AS MORE INFORMATION BECOMES AVAILABLE.
B
3. THE LOCATION OF THE STACK IS BASED ON THE MASSACHUSETTS STATE PLANE SYSTEM,
(NAD27, DATUM) FOR THE HORIZONTAL COORDINATES. THE GRID PRESENTED WAS
CREATED FROM IMAGE FILES RECEIVED FROM NRG, COORDINATE LOCATION REQUIRES
RECHECK WHEN SURVEY DATA IS OBTAINED. MORE DETAILED DESIGN OF THE SITE
ARRANGEMENT INCLUDING FACILITY PLACEMENT, GRADING AND DRAINAGE WILL
REQUIRE TOPOGRAPHIC SURVEY WITH TIES TO THE PROPERTY AND EASEMENTS.
REVISION APPROVAL RECORD
DISCIPLINE
BY
DATE
DISCIPLINE
REV
NO
REV
BY
DATE
DATE
ISSUED FOR ENF PERMITTING
RLR
MD
REVISED GRADING
RLR
MD
ADDED FUEL OIL PUMPHOUSE; DELETED FUTURE ITEMS
TJK
RLR
B
5/18/15
BUILDING SERVICES
PIPING
C
6/9/15
ELECTRICAL
QA / QC
ENVIRON.
STRUCTURAL
CHKR
5/14/15
MECHANICAL
PROCESS
BY
A
ARCH.
CIVIL
REVISIONS
PROJECT NO.:
DRAWING STATUS
ISSUED
REV
DATE
SDE
PEM
DRAWN:
PRELIMINARY
C
6/9/15
510 CARNEGIE CTR.
31380
(609) 720-2000
DATE:
RLR
PKS
PRINCETON, NJ 08540
CHECKED:
MD
4/23/15
CANAL GENERATING PLANT
5/14/15
SIMPLE CYCLE PROJECT STACK WEST
PLOT PLAN
APPROVED FOR
CONSTRUCTION
GEN. ARRANG.
NOT APPROVED FOR CONSTRUCTION UNLESS SIGNED
I & C
AND DATED. DESTROY ALL PRINTS BEARING
EARLIER DATE AND/OR REV.NO.
8
7
6
5
4
3
A
URS ENERGY & CONSTRUCTION, Inc.
DATE:
SCALE:
DWG. NO.
REV
31380-B024-16-11-220-WEST
1" = 60’-0"
2
1
C
Bruce, Jackie
From:
Sent:
To:
Subject:
trackingupdates@fedex.com
Wednesday, July 29, 2015 8:59 AM
Bruce, Jackie
FedEx Shipment 774150650731 Delivered
Your package has been delivered
Tracking # 774150650731
Ship date:
Delivery date:
Tue, 7/28/15
Wed, 7/29/15 8:55 am
Jacqueline Bruce
Massachusetts Historical
Westford, MA 01886
Commission
US
Delivered
220 Morrissey Boulevard
BOSTON, MA 02125
US
Shipment Facts
Our records indicate that the following package has been delivered.
Tracking number:
774150650731
Status:
Delivered: 07/29/2015 08:55
AM Signed for By:
D.DESHWAN
Reference:
194-5285.14.01
Signed for by:
D.DESHWAN
Delivery location:
BOSTON, MA
Delivered to:
Receptionist/Front Desk
Service type:
FedEx Priority Overnight
Packaging type:
FedEx Envelope
Number of pieces:
1
Weight:
0.50 lb.
Special handling/Services:
Deliver Weekday
1
Please do not respond to this message. This email was sent from an unattended mailbox. This report was generated at
approximately 7:59 AM CDT on 07/29/2015.
To learn more about FedEx Express, please go to fedex.com.
All weights are estimated.
To track the latest status of your shipment, click on the tracking number above, or go to fedex.com.
This tracking update has been sent to you by FedEx at your request. FedEx does not validate the authenticity of the requestor
and does not validate, guarantee or warrant the authenticity of the request, the requestor's message, or the accuracy of this
tracking update. For tracking results and terms of use, go to fedex.com.
Thank you for your business.
2
Attachment 15: CCC Certificate of Service
CERTIFICATE OF LOCAL FILING
I ________________,
hereby certify that on this ______
2015, I caused
July
Fred Sellars
31 day of _______,
a copy of the foregoing Environmental Notification Form and Cape Cod Commission
Application Cover Sheet/Request for Joint MEPA/DRI Review (“Application Cover Sheet”) to
be served upon the Service List attached hereto as Attachment 8 and incorporated herein by
reference in accordance with the requirements of Section II.4. of Attachment 6 to the Application
Cover Sheet.
____________________________________
Attachment 16: Photographs of the Simple -Cycle Site
Photograph 1 – View of Simple-Cycle Site looking northeast
Photograph 2 – View of Simple-Cycle Site looking north
Photograph 3 – View of Simple-Cycle Site looking northeast
Photograph 4 – View of Simple-Cycle Site looking north
Photograph 5 – View of Simple-Cycle Site looking northwest
Photograph 1 – View looking northeast
Photograph 6 – View of Simple-Cycle Site looking north-northwest