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Home My WebLink AboutSubject File OFFICE LOCATION•Town Hall Annex fin.� ��"" AILING ADDRESS: "��" P.O. Box 1179 54375 State Route 25 � Southold, NY 11971 (cor. Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.southoldtow-imy.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD April 19, 2023 Mr. Philip Denara 25 Monroe Street, Suite 300 Albany, NY 12210 Re: Suspension of Review Key Capture Battery Energy Storage Facility 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 Dear Mr. Denara: I am writing to inform you that the Southold Planning Board has suspended the review of your site plan and subdivision applications for the proposed Battery Energy Storage System (BESS) located at 10750 Oregon Road, Cutchogue (SCTM#1000-83.-3-6.1). This is a result of the moratorium recently enacted by the Town of Southold to address the need to codify the parameters of BESS facilities locally. We appreciate your understanding. Once the moratorium is lifted and new regulations are in place, we will promptly resume the review of your applications in compliance with the updated guidelines. Please do not hesitate to contact the undersigned if you have any questions or have need of further clarification. Respectfully, Heather Lanza, AICP Town Planning Director cc. John Anzalone HARRIS BEACH ATTORNEYS AT LAW December 5, 2022 THE OMNI 333 EARLE OVINGTON BLVD,SUITE 901 UNIONDALE,NEWYORK 11553 516.880.8484 VIA Hand Delivery JOHN J.ANZALONE Donald Wilcenski, Chairman MEMBER Town of Southold DIRECT: 516.880.8108 FAX: 5 16.880.8483 Planning Board JANZALONEga HARRISBEACH.COM Town Hall Annex 54375 Main Road Southold,NY 11971 R E C E7IVRE: Site Plan Application of KCE NY 26 LLC FEB 0 10750 Oregon Road, Cutchogue,NY L_ Dist. 1000, Sec. 83, Blk. 3, Lot 006.001 southal[TTown Planning Board Dear Chairman Wilcenski and Members of the Planning Board: In connection with the above-referenced Application, please find the following exhibits for the December 5, 2022 Planning Board hearing: 1. One (1) copy of Southold Town Board Resolution Number 2019-829 memorializing the Town's adoption of the Climate Smart Communities Pledge on September 24, 2019; 2. One (1) copy of the Long Island Fossil Peaker Replacement Study prepared by Strategen for NY-BEST, dated October 28, 2020; 3. One (1) copy of the Town of Southold Zoning Map for Cutchogue,NY; 4. One (1) copy of the Aerial Photograph of the portion of Cutchogue, NY bounded by Depot Lane, Cox Lane, Middle Road and Oregon Road; 5. One (1) copy of the recent photographs of the subject property and abutting parcels located along Oregon Road; and 6. One (1) copy of the professional resume of Robert Joel Richardson, P.E. Should you have any questions, please do not hesitate to contact our office. Thank you for your time and attention to this matter. Very truly yours, HARRIS BEACH PLLC JoW n J. nzalone Encls. 317808\4856-8477-8817\A `�"�` RESOLUTION 2019-829 4 ADOPTED DOC ID: 15593 THIS IS TO CERTIFY THAT THE FOLLOWING RESOLUTION NO. 2019-829 WAS ADOPTED AT THE REGULAR MEETING OF THE SOUTHOLD TOWN BOARD ON SEPTEMBER 24,2019: WHEREAS the Town Board of the Town of Southold(hereinafter"Local Government") believes that climate change poses a real and increasing threat to our local and global environments and is primarily due to the burning of fossil fuels; and WHEREAS the effects of climate change will endanger our infrastructure, economy and livelihoods; harm our farms, orchards, and ecological communities, including native fish and wildlife populations; spread invasive species and exotic disease;reduce drinking water supplies and recreational opportunities; and pose health threats to our citizens; and WHEREAS we believe that our response to climate change provides us with an unprecedented opportunity to save money, and to build livable, energy-independent and secure communities, vibrant innovation economies,healthy and safe schools, and resilient infrastructures; and WHEREAS we believe the scale of greenhouse gas(GHG) emissions reductions required for climate stabilization will require sustained and substantial efforts; and WHEREAS we believe that even if emissions were dramatically reduced today, communities would still be required to adapt to the effects of climate change for decades to come, now therefor be it RESOLVED that the Town Board of the Town of Southold, in order to reduce greenhouse gas emissions and adapt to a changing climate, does hereby adopt the New York State Climate Smart Communities pledge, which comprises the following ten elements: 1. Build a climate-smart community 2. Inventory emissions, set goals, and plan for climate action 3. Decrease energy use 4. Shift to clean, renewable energy 5. Use climate-smart materials management 6. Implement climate-smart land use 7. Enhance community resilience to climate change 8. Support a green innovation economy 9. Inform and inspire the public 10. Engage in an evolving process of climate action Elizabeth A.Neville Resolution 2019-829 Board Meeting of September 24,2019 Southold Town Clerk RESULT: ADOPTED [UNANIMOUS] MOVER: Jill Doherty, Councilwoman SECONDER:William P. Ruland, Councilman AYES: Dinizio Jr, Ruland, Doherty,Evans, Russell ABSENT: Robert Ghosio Updated: 9/25/2019 11:58 AM by Elizabeth A.Neville Page 2 LONG ISLAND FOSSIL PEAKER REPLACEMENT STUDY ii, A,w 1 sr' 4 . K 41 ` 1 - - �` PREPARED FOR NY-BEST STRATEGENOCTOBER 289 2020 YOUR PARTNER IN THE ENERGY TRANSITION Long Island Fossil Peaker Replacement Study Prepared for: Prepared by: CAMDYORKAA1 ORA �,JSTRATEGEN ANA ENE116Y STOAA6ETELNIOl06Y 601EORTIIIN New York Battery and Energy Storage Strategen Consulting, LLC Technology Consortium (NY-BEST) 2150 Allston Way, Suite 210 Berkeley, California 94704 www.ny-best.org www.strategen.com Edward Burgess Erin Childs Eliasid Animas Jennifer Gorman Melanie Davidson Disclaimers Client Disclaimer This report does not necessarily represent the views of NY-BEST or its employees. NY-BEST, its employees, contractors, and subcontractors make no warranty, express or implied, and assume no legal liability for the information in this report; nor does any party represent that the uses of this information will not infringe upon privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by NY-BEST. Stakeholders and subject-matter experts consulted during this study did not necessarily review the final report before its publication.Their acknowledgment does not indicate endorsement or agreement with the report's content or conclusions. Strategen Disclaimer Strategen Consulting LLC developed this report based on information received by NY-BEST.The information and findings contained herein are provided as-is, without regard to the applicability of the information and findings for a particular purpose. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise .does not necessarily constitute or imply its endorsement, recommendation, or favoring by Strategen Consulting LLC. Long Island Fossil Peaker Replacement Study 0 2020 by Strategen Table of Contents ExecutiveSummary............................................................................................•--- .......................... 1. Background................................................................... ......-.....................................................................5 1.1 Overview of Long Island Peaker Fleet...........................................................................................5 1.1.1 Peaker Fleet Costs.........................................................................................................................7 1.1.2 Peaker Fleet Environmental Impacts.......................................................................................8 1.1.3 Peaker Fleet Location & Local Reliability.............................................................................10 1.2 Relevant Policies and Long-Term Planning Issues...................................................................11 1.2.1 Climate Leadership and Community Protection Act..........................................................11 1.2.2 Air Quality and NOx Regulation.......:...........................................................:.........................12 1.2.3 Energy Storage Roadmap and Deployment Plans........................................__...............13 1.2.4 LIPA Contracts and Procurement....................................................____............................13 1.2.5 LIPA PSA Early Termination Options.....................................................................................14 1.3 Clean Energy Replacement Options............................:................................................................14 1.3.1 Energy Storage..............................................................................................................................14 1.3.2 Role of Solar and Off-Shore Wind....................................................................... .............15 2. Peaker Replacement Feasibility Analysis............:............................................................................15 2.1 Methodology for Identifying Replacement Candidates..........................................................16 2.1.1 Operating Profiles...........................................................................•............................................16 2.1.2 Peaker Groupings by Contract Expiration and NOx Compliance Dates...................16 2.2 Use of 901h Percentile Criterion.............................................................................. --...................18 2.2.1 Peaker Unit Dispatch versus Available Zone Level Capacity.......................................18 2.2.2 Peaker Unit Dispatch versus Plant Level Capacity.........................................................19 2.2.3 Peaker Unit Dispatch for Localized, Non-Peaking Needs............................................21 2.2.4 Inconsistent Levels of Output During Longer Run-Times...........................................22 2.2.5 Unit Operational Constraints................................................................................................ 23 2.2.6 Conclusions on Use of 90' Percentile for Evaluating Peaker Start Duration.......24 2.3 Start Duration Analysis....................................................................................................................25 2.3.1 Candidate Portfolio Based on Start Durations.................................................................26 2.3 Load Pocket Analysis and Local Reliability Issues................................................................29 2.3.1 Review of NYISO Reliability Studies....................................................................................29 2.3.4 Uneconomic Peaker Operation for Local Reliability .....................................................33 2.4 Impact of Solar, Energy Efficiency and Off-Shore Wind on Net Load Profiles............. 36 2.5 Peaker Retirement Phases........................................................... ...............................................39 3. Peaker Retirement & Replacement Economic Analysis..............................................................43 3.1 Methodology and Assumptions.....................................................................................................44 3.1.1 Net Cost Comparison ................ .............................................................. ..............44 Long Island Fossil Peaker Replacement Study 14 ©2020 by Strategen 3.1.2 Peaker Costs and Benefits........................................... ................. ........................................44 3.1.3 Storage Costs and Benefits....................................................................................................45 3.1.4 LIPA Total Annual Portfolio Savings Potential ................................... 45 3.2 Cost Effectiveness Relative to Existing Peakers....................................................................46 3.3 Storage Benefits not Included in Cost-Benefit Analysis......................................................49 3.3.1 Benefits of Battery Storage for the Grid.............................................................................49 3.3.2 Health and Environmental Costs of Peaker Emissions................... ::.........:.........49 4. Recommended Replacement Pathway...........................................................................................50 4.1 Near Term (2020-2023)....................................................................................................................51 4.2 Medium Term (2024-2030)........................ .. ----..................................---.----------.............51 4.3 Long Term (2031-2040)....................................................................................................................51 p Long Island Fossil Peaker Replacement Study ©2020 by Strategen Tables and Figures Table1. LIPA Fleet Summary..................... ....... .........................................................................................5 Table 2. Annual CO2, NOx, SO2 Emissions by LIPA Peaker Plant...................................................8 Table 3. LIPA Peaker Fleet Contract Expiration Date and NOx Compliance.............................17 Table4. Peaker Group 1 ............................................................................................................------..._...._.26 Table5. Peaker Group 2...........................................................................................................----------...._..27 Table6. Peaker Group 3........................ ..................................................................................................28 Table7. Peaker Group 4.............................:..............................------------..............,....------.......------.............29 Table 8. Groups 1 & 2 Excluded Peaker Plants in East End.............................. ................. 32 Table 9. Peaker Retirement Phase 1...................................................................................................... 39 Table 10. Peaker Retirement Phase 2.............................................................................. ....................40 Table 11. Peaker Retirement Phase 3 ...... ..................................... .........................................................41 Table 12. Annual Economic Impact of Peaker Emissions...............................................................50 Table 13. Detail of Peaker Selection by Generating Unit................................................................ 53 Figure 1. Phased Replacement of LIPA Peaker Capacity...................................................................2 Figure 2. Peaker Plants in Long Island ....................................................................................................3 Figure 3. Age of Peaker Fleet and Typical Retirement Dates .........................................................7 Figure 4. Peaker Proximity to Potential Environmental Justice Areas.........................................10 Figure 5. Peaker Power Plants and Load Pockets in Long Island................................................10 Figure 6. Policy and Planning Outlook Through 2040............................... .....-................................11 Figure 7. Peaker Hourly Dispatch in Long Island Zone K, 2016-2018.........................................19 Figure 8. Comparison of Unit Level and Plant Level Run-Time for Shoreham Peaking.......20 Figure 9. Shoreham Peaking GT3 Dispatch Duration, 2018............................................................21 Figure 10. Illustration of E.F. Barrett Jet 09 hourly output.............................................................. 23 Figure 11.I1lustration of typical dispatch at Northport steam and gas turbine units................. 24 Figure 12.I1lustration of dispatch duration at each of 10 units at the Holtsville plant during peaksummer load hours in 2018............................................,........................................................--... 24 Figure 13. Peaker Start Duration Analysis............................................................................................25 Figure 14. E.F. Barrett Jet 04 Dispatch Duration Frequency, 2018..............................................25 Figure 15. Consistency of 9011 Percentile Peaker Dispatch Duration, 2016-2018...................26 Figure 16. Long Island Load Pockets and Interfaces........................................................................30 Figure 17. Barrett Load Pocket Duration Curve....................................................................................31 Figure 18. South Western Suffolk Load Duration Curve....................................................................31 Figure 19. East End Load Cycle Deficiency, 2028............................................................................32 Figure 20. Partial Replacement of East End Load with Storage, 2025.......................................33 Figure 21. Uneconomic Peaker Unit Commitments, 2019........__.................................................. 35 Figure 22. Demonstration of Voltage Control Provided by a Large-Scale PV Plant............. 36 Figure 23. Long Island Cumulative Energy Efficiency Forecasts..................................................37 Figure 24. Baseline NYCA Energy Demand, 2020-2040...............................................................37 Figure 25. Planned and Forecast Offshore Wind Contracts in NY.............................. ..........._38 Figure 26. Forecast of 2030 Long Island Net Load: Average August and January Days...39 Figure 27. Average August Energy Available from Energy Efficiency, Offshore Wind & Rooftop Solar in 2030............ ...... .............................................................................................42 Figure 28. Energy Storage Balances Excess Generation and Peak Demand.........................43 Figure 29. Annual Savings from Peaker Replacement. ..................................................................46 Figure30. PSA Net Cost 2020 to-2030.............................................................................................47 Figure 31. Energy Storage Net Cost in 2020.......................................................................................48 Figure 32. Energy Storage Net Cost in 2030,_....................................................................................48 Figure 33. Peaker Retirement Pathway..................................................................................................51 Long Island Fossil Peaker Replacement Study 13 ©2020 by Stra[egen Executive Summary Long Island, New York is an expansive, densely populated island stretching east from New York City into the Atlantic Ocean, home to nearly 3 million residents in Nassau and Suffolk County. Long Islanders are increasingly vulnerable to the effects of climate change such as recurring hurricanes and rising seas. As part of New York State's commitment to halting climate change, it has mandated a carbon-free grid by 2040. Long Island has a leadership role to play in New York's clean energy transformation. This study examines the cost- effectiveness of retiring an aging and inefficient fleet of fossil-fueled peaking power plants and replacing them with energy storage, a "low-hanging fruit" in the island's energy transition. The analysis shows that replacing the aged, polluting peaker fleet will reduce energy costs, create jobs, build a more resilient power system, reduce air pollution in Potential Environmental Justice Areas and lower greenhouse gas emissions- a "no regrets" solution for all Long Islanders. Over the next decade, deploying energy storage to replace fossil-fueled pecker plants could save LIPA customers as much as $393 million Long Island is host to 26 fossil-fueled power plants, composed of 74 individual generation units,that seldom operate yet impose significant costs on Long Island Power Authority(LIPA) customers. Of LIPA's portfolio of 5,667 MW of emitting generators, 4,357 MW are "pecker plants"that operate at an annual capacity of 15%or less (i.e. roughly 15%of the time or less)'. To maintain these peckers, LIPA customers pay an estimated $473 million annually in capacity costs, almost three times the market rate for capacity resources cleared through NYISO's competitive markets.2 This report presents analysis demonstrating that it is feasible and cost-effective to replace over 2,300 MW of Long Island's fossil-fueled peaker plants with energy storage over the next decade.Approximately half of these resources,1,116 MW,could be retired and replaced with energy storage by 2023. The remaining 1,209 MW could be replaced with energy storage by 2030, using the storage to supplement the state's planned deployments of increased solar, energy efficiency, and offshore wind, which will also help enable fossil fuel retirements in Long Island's transmission constrained East End load pocket. Of the initial 4,357 MW peaker selection, 69 units with about 3,053 MW of capacity operated at 10%or less of the time while a subset of 36 units accounting for 1,249 MW ran less than 1%of the time in 2019. 2 Based on net cost of contracted capacity(after estimated energy and AS revenues)through Power Supply Agreement between Lipa and National Grid and Strip Auction market prices in Zone K(averaged for the last 5 years). See section 1.1.1 Pecker Fleet Costs. Long Island Fossil Peaker Replacement Study 1 ©2020 by Strategen 5,000 Near-Term Retirements: 1,116 MW 4,500 4,000 Mid-Term Retirements: 1,209 MW 3,500 C1 3,000 Energy CLCPA Zero 1,116 MW of U Carbon Target 2,500Q R�ejnruernentls EnatbIllied By. 117p -n 0-f) 2,000 MW "' ' OffshoreRemaining Retirements: .NFn 1,500 "GWh of 2,032 MW O ••Solar 1,000350+MW of Energy Storage 500 Cumulative Storage Additions: 334 334 1,116 1,116 1,206 1,206 1,206 1,206 1,206 1,556 ■ 0 _ _ _ Ln CO � 0o � O N M Ln CO r- W O O N M V Ln O n 00 61 O N N N N N N N N N N N M M M M M M M M M M V 0 't O O O O O O O O O O O O 0 O O O 0 O O O O O O O O O N O Figure 1. Phased Replacement of LIPA Pecker Capacity This trajectory of fossil-fuel retirement and replacement with storage would put Long Island on trajectory to comply with the state's Climate Law and Community Protection Act(CLCPA), which requires a carbon-free grid by 2040. Moreover, it would provide much needed new flexible capacity into the Long Island transmission zone while preparing Long Island to integrate expected and forecast renewable capacity. NYISO reliability studies show that peaking needs could become an issue in the future if replacement generation is not added, particularly in localized areas with transmission constraints.3 Given that New York has established emissions reduction goals limiting replacement generation to clean energy options, energy storage represents a technologically feasible, commercially available, cost- effective, policy-compliant solution to help ease out aging fossil-fueled plants. In addition to the carbon reduction imperatives established by the CLCPA, New York City and Long Island have established rules to help encourage the retirement of many of these plants that run on fuel oil. Fuel oil is known to be one of the highest polluting fossil fuel sources.' As a result, although they operate infrequently, when they do operate, they are major contributors to ozone pollution and local air quality problems. However,these shorter duration operations mean that these peaking assets are excellent candidates for replacement with energy storage. In fact, 17 of LIPA's 26 plants are subject to recent rules established by the Department of Environmental Control (DEC) to reduce local NOx emissions from oil-fired power plants. Of these 17 plants, only 8 of the plants already comply with the emissions control requirements established by the DEC, while another 6 are planning to install costly emissions control mechanisms—costs paid by LIPA customers that could be avoided altogether if these plants were simply retired. The remaining 3 are planning to either retire or be kept as black start only generators. 3 NYISO,2019-2028 Comprehensive Reliability Plan. https://www.nyiso.co m/doc u me nts/20142/6001938/04%202019-2028%2OCRP%20 Re port%20D raft.pdf 4 EPA,Emissions Factors for Greenhouse Gas Inventories. https://www.epa.gov/sites/production/files/2015- 07/documents/emission-factors-2014.pdf Long Island Fossil Peaker Replacement Study 2 0 2020 by Strategen a sewha�He C.—V.. Northport Port 140,1eWlfaM e ftp E Hampton Pt-- P J H. m4 SM eeam �Savm o. G Wpd CHolt,Jlle Bran-w .Edgewood e CT®efpag;Pooeta_PowerO Peakers .W-tBabyl— Gas fueled w12 "I ■ Oil fueled r ® Capacity Figure 2. Pecker Plants in Long Island Retiring and replacing these aging assets has the potential to create $10.5 million of savings per year in 2021, growing to $150 million per year in 2030. Over the next decade, fossil peaker replacements could save LIPA customers as much as $393 million, net present values, representing savings of around $360 per household across LIPA's 1.1 million customers. On top of the value that these retirements and replacements could create in structured energy markets, they provide additional social and environmental benefits in the form of emissions reduction. The pecker fleet considered in this analysis annually emits 2.65 million metric tons of CO2, 1,910 tons of NOx, and 639 tons of SO2. The estimated societal cost of these annual emissions is over $160 million.6 Moreover, these pollutants disproportionately impact Potential Environmental Justice Areas, many of whom are already exposed to some of the highest levels of pollution in the state. Exposure to ozone above background levels causes New Yorkers to suffer annually from about 400 premature deaths, more than 800 asthma related hospital visits, and over 4,500 asthma related emergency room visits. A reduction in ozone levels by just 10% could prevent 180 premature deaths, 180 hospital admissions and 970 emergency department visits annually.' 5 Assumes a discount rate of 7% based on industry standards. 6 Annual emission cost estimates are based on the social cost of CO2 and the morbidity and mortality of NOx and SOx as precursors to PM 2.5. New York City Department of Health and Mental Hygiene,Air Pollution and the Health of New Yorkers. https://wwvd.nyc.gov/assets/doh/d own loads/pdf/eode/eode-air-qu a I ity-i m pact.pdf Long Island Fossil Peaker Replacement Study 3 0 2020 by Strategen Key results of this Long Island Fossil Peaker Replacement Study show: • It is feasible and cost-effective to replace 1,116 MW of Long Island's fossil-fueled peaker plants with energy storage by 2023 and over 2,300 MW by 2030. • Potential savings of up to $393 million of savings can be achieved for LIPA customers over the next decade by retiring and replacing aging fossil assets. • Replacing peckers with storage will eliminate 2.65 million metric tons of CO2, 1,910 tons of NOx, and 639 tons of SO2 of emissions annually, resulting in societal benefits of$163 million annually. • Of the 2,300 MW of fossil peaker plant replacements, 334 MW could be retired and replaced immediately, and another 782 MW could be phased out by 2023, coinciding with the implementation of local emission control regulations and the expiration of existing LIPA long-term contracts. • In the East End of Long Island there is a near-term opportunity for up to 90 MW of fossil peakers to be displaced with energy storage, and additional opportunities over time as local constraints are addressed. As New York establishes its leadership position in the fight against climate change,the state will need all generation plant owners and operators to think strategically and expansively about how to transition their fleets. Replacing Long Island's oldest, least efficient, and most polluting fossil-fueled peaker plants today with lower cost, emission-free energy storage is a no-regrets solution for LIPA, its customers, the environment, and the state of New York. Long Island Fossil Peaker Replacement Study 4 C-3 ©2020 by Strategen 1. Background 1.1 Overview of Long Island Peaker Fleet Long Island's electricity system has a fleet of 74 peaking power generation units at 26 plant locations accounting for 4,357 MW of fossil fueled generation capacity.$ The average age of the fleet is 43 years old, with some units running since the 1940's. All these plants operate infrequently and, when they do, many run for only a few hours every time - of the portfolio of 74 units, 26 of those units, representing 1,116 MW of capacity have typical dispatch durations of 8 hours or less.' Plants listed below are identified based on their resource designation in the NYISO market, though many are in the same geographic location. Table 1. LIPA Fleet Summary CapacityNumbe,r of Total Peaking Units at Plani Bethpage Calpine Corp. 1 96 Bethpage CT Calpine Corp. 1 60 Brentwood New York Power Authority 1 47 Charles P Keller Village of Rockville Centre 7 31.4 Edgewood J Power 2 100 E.F. Barrett Jet National Grid 11 293.2 East Hampthon National Grid 4 27.3 Freeport GS J Power 1 60 Freeport 1 & 2 Village of Freeport 5 89.7 Glenwood CT National Grid 3 126 Glenwood Landing National Grid 2 106 Greenport Village of Greenport 3 6.8 Hawkeye Energy Hawkeye Energy 1 54 Greenport Greenport Holtsville National Grid 10 567 Jamaica Bay Hull Street Energy 11 60.5 8 Peaker plants were defined in this study as all fossil fueled power plants with capacity factors equal or below 15%for single units or for full plant average, and nameplate capacity equal or greater than 10 MW(one smaller plant was included due to its operational characteristics). 14 Long Island Fossil Peaker Replacement Study 5 ©2020 by Strategen Northport National Grid 4 1,548 Northport CT National Grid 1 16 Pinelawn Power J Power 1 82 Port Jefferson National Grid 2 376 Port Jefferson National Grid 3 122 Peaking Shoreham National Grid 2 71.5 Shoreham Peaking J Power 2 100 Southampton National Grid 1 11.5 Southold National Grid 1 14 Wading River National Grid 3 238.5 West Babylon National Grid 1 52.4 Toto/ 4,356.8 On average,the pecker fleet on Long Island is only used at 8%of its full capability. However, about a third of the units actually run less than 1% of the time. Generally, these are the least efficient plants, and burn either natural gas, light fuel oil or kerosene — some without any pollution controls -- making them some of the most polluting energy assets on the grid on a per megawatt-hour basis. For such reasons, these polluting peckers can be considered the "low-hanging fruit" and ideal candidates for near-term replacement with lower cost and cleaner technologies. Not only would replacing these resources be aligned with the State's clean energy policy goals, but such replacements would also help address local resident environmental justice concerns, and lower electricity costs. The age of the generating units is another factor for consideration. Most of the pecker fleet capacity is more than 40 years old and almost 1,600 MW are past the normal age of retirement for their specific generation technologies'. By 2025, that number will go up to 2,775 MW or about 65% of the total peaker capacity in Long Island. 9 Analysis of S&P Global Market Intelligence on annual retirements in the US at unit-level data. https://www.spglobal.com/marketintelligence/en/news-insights/trending/gfjgeFt8GTPYNK4WX57z9g2 Long Island Fossil Peaker Replacement Study 6 0 2020 by Strategen Age(years) 600 1 I 1 1 1 1 1 80 75 70 65 60 55 150 45 40 35 30 25 20 15 10 5 I I 500 I I y I I 11 I I ! I 400 - 1-�- 1 I l I 300 1 I I I I f I 200 1 i I 100 E I I 0 r uI_■ 1940 1945 1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 Date Online Gas ST cl Gas CC Gas GT 0 Oil CT Average Retirement Age: — — — — — — Figure 3. Age of Pecker Fleet and Typical Retirement Dotes 1.1.1 Pecker Fleet Costs The aging peaker fleet, although rarely used, leads to significant costs for by Long Islanders through their energy bills. Strategen estimates that the identified peaker fleet may be costing Long Island electricity customers approximately $473 million annually just for capacity,and that if the peaking fleet is not replaced,this cost could increase to an estimated $716 million by 2030.10 The bulk of these costs reflect payments for generation capacity to the plants contracted through a Power Service Agreement (PSA) between LIPA and National Grid for 3,634 megawatts (MW), of which 3,284 MW (90%) are for peaking capacity." This represents a significant majority of the Long Island peaker fleet. The PSA was contracted for the period from 2013 to 2028.Although not all the plants were initially contracted to function as peaking capacity, the entry of new and more efficient generation assets into the market have resulted in older generators running much less frequently, thereby increasing the cost per unit of energy delivered for those older units. Strategen estimates that the cost for capacity of this agreement is three times higher than the relative cost of capacity on the Long Island that is cleared through NYISO's competitive capacity markets.,z Moreover, many of the peakers on Long Island are frequently operated uneconomically due to inefficiencies and constraints in how the system is operated, some of which could be 10 Based on estimated 2019 capacity payments of$/kW-year(net of estimated energy&ancillary services) and an annual escalation rate of 2.5%. PSA contract cost as reported in the LIPA/NG PSA-Attachment A. The escalation rate approximates PSA annual cost increase. 11 LIPA,Amended and Restated Power Supply Agreement. https://www.lipower.org/wp- content/uploads/201G/10/A-and-R-PSA-effective-28-May-13.pdf 12 The average cost of capacity in the last 5-years for Long Island was$3.14/kW-month through the strip market while the net cost of capacity in the PSA was estimated to be$9.98/kW-month during 2019. Long Island Fossil Peaker Replacement Study 7 _ � ©2020 by Strategen alleviated through market reforms or through deployment of modern inverter-based resources like battery storage. According to recent reports by the NYISO market monitor, over half of all gas turbine operations on Long Island appear to be uneconomic, meaning that plants are running out of merit order, unnecessarily increasing emissions and customer costs.' This is driven in part by out-of-market dispatch by LIPA to manage low voltage congestion and transient voltage issues, some of which arises from deficiencies in the NYISO market model and lack of real-time coordination between LIPA and the NYISO. 1.1.2 Pecker Fleet Environmental Impacts The forecasted cost noted above also considers the addition of new NOx emissions control equipment for a portion of the peaking assets. Many of the Long Island peakers will need to be retrofitted with new NOx controls in the coming years to comply with environmental regulations 13 recently promulgated by the New York Department of Environmental Conservation. The cost of these retrofits will ultimately be passed on to Long Island electricity customers.These retrofit costs will also be exacerbated by the fact that the state's Climate Leadership and Community Protection Act(CLCPA) phases out all fossil generation by 2040, thus shortening the financial life of the peaker plant assets and any associated pollution control investments. Retirement of pecker plants is a clear way to address harmful pollution issues in New York and yield a significant improvement to public health as peakers contribute as much as 94% percent of the State's NOx emissions on high ozone days despite providing as little as 36% of the gross load.14 Peakers produce a disproportionate amount of emissions, and in part, this is because many of the older peaker plants do not have any form of NOx controls. The emissions of peakers have an adverse impact on New York's air quality and make it near impossible for the State to achieve attainment with NAAQS targets. As displayed in the table below, the LIPA peaker fleet contributes significantly to local CO2, NOx, and SO2 emissions. Based on historic emissions and generation data from 2016-201811 the Long Island peaker fleet produces 2.65 MT of CO2, 1,910 tons of NOx, and 639 tons of SO2 annually.16 Table 2. Annual CO2, NOx, SO2 Emissions by LIPA Pecker Plant • • • S02 Emissions Bethpage Yes 245,849 183 1.01 Bethpage CT No 89,934 5.2 0.42 Brentwood Yes 32,138 2.5 0.14 Charles P Keller No 1,469 2.8 0.1 Edgewood Yes 64,846 125 4.6 13 See section 1.2.2 for more information on New York NOx regulations. 14 New York State Department of Environmental Conservation,Adopted Subpart 227-3 Revised Regulatory Impact Statement. https://www.dec.ny.gov/regulations/116175.html 16 S&P Global Market Intelligence,Annual Unit Emissions. https://platform.mi.spglobal.com/web/client?auth=inherit&overridecdc=l&#powerplant/PowerPlantEmissionsB yproduct?ID=7502 16 For 19 peakers emissions data was directly available from S&P Global Market Intelligence.The emissions of the other 7 peakers(Charles P Keller, Edgewood, Freeport GS, Freeport 1&2, Greenport,Southampton, Southold)were calculated from the available peakers'CO2, NOx, and SO2 average emissions rates (Ib/MMBtu). Long Island Fossil Peaker Replacement Study 8 ©2020 by Strategen E.F. Barrett Jet No 111,631 365 3.8 East Hampthon No 11,106 32..4 0.67 Freeport GS Yes 53,996 101 3.7 Freeport 1 &2 No 29,399 56.5 2.0 Glenwood CT No 3,631 10.7 3.5 Glenwood Landing Yes 79,809 8.7 0.3 Greenport No 21 0.04 0.007 Hawkeye Energy Yes 13,446 2.0 0.08 Greenport Holtsville Yes 38,561 143 41.2 Jamaica Bay Yes 7,533 1.2 0.05 Northport Yes 1,500,648 689 409 Northport CT No 327 2.2 0.02 Pinelawn Power Yes 76,641 4.6 0.55 Port Jefferson Yes 219,980 119 160 Port Jefferson Peaking No 37,906 5.7 0.15 Shoreham No 3,560 12.0 4.2 Shoreham Peaking Yes 5,260 1.4 0.04 Southampton No 2,377 4.5 0.17 Southold No 1,883 3.7 0.13 Wading River Yes 16,179 19.6 0.08 West Babylon No 2,949 9.4 2.61 Total 2,651,077 1,911 639 Further, many of these plants are located in some of the communities that already bear the greatest pollution burdens in New York State, and which have been designated by the State as Potential Environmental Justice Areas." Bases on data from the US Census and EPA, we estimate that about 890,000 people live within a 3-mile radius of a pecker plant, and 32% of them live in Potential Environmental Justice Areas. "New York State Department of Environmental Conservation, Maps&Geospatial Information System (GIS) Tools for Environmental Justice. https://www.dec.ny.gov/public/911.html Long Island Fossil Peaker Replacement Study 9 0 2020 by Stra[egen Sort' r' �,y GreenPo't Northport Port3nPN. '''r5r� Ing E.1Wm.pr4r.011efest mv.nn Nwtn p..... r�pq f$lrore _ m - 5°Gth J ' e .G�r.n.,oea C7 qC Ihrt3eolNr !7M- n ❑ 4 arant`woa �t aw?¢n � Gas fueled a,, eathy c f Oil fueled newer O Peakers Capacity ' rrrt�Qors a .. iamaicar ' r--` DAC Areas t. .Eau.pru Smile radius Figure 4. Pecker Proximity to Potential Environmental Justice Areas 1.1.3 Pecker Fleet Location & Local Reliability For the peaking assets examined in this study, location is a major consideration affecting replacement feasibility.Some of these peaker plants are located in transmission constrained areas, also known as load pockets, that raise reliability concerns under the current state of the system. These concerns are addressed in this study with a special focus on the island's East End, which is one of the most location-constrained areas on Long Island according to NYISO's Comprehensive Reliability Plan 2019-2028. � a Grn.npe., East End ll JI 1 i i Northport Port left w'61 �"^r prrnamA aMmg E Hampton rDI—Ie€m' ron h P.iarra o.. g 5W ham 'Stony Brook 1 aSWt nn 4 -A�+�%cr Hn]lcw [unrwss———— Pttharrl7A A'a A era":rrw6 FCgewooC \ V !• � ��Load Pocket Bethpage N-ea 'dDBau.r,e°4w,a� ,r � 1 South western Gas fueled iweapabylon• Suffolk E Oil fueled■ tt Ched®a P NeICre "\ Q Peakers Bey—mr 1 Er.gauerl / Load Follow lar"ace ; F Barr i Barret ®Capacity Figure 5. Pecker Power Plants and Load Pockets in Long Island Some of the oldest and least utilized assets are smaller generators, accounting for 67.4 MW from 11 units. These units are presumed to be used as back-up generators by local municipalities and are thus excluded from consideration in this analysis. Although these were excluded from the analysis conducted in this study, such units may still be attractive candidates for replacement in the near future. Long Island Fossil Peaker Replacement Study 10 ©2020 by Strategen 1.2 Relevant Policies and Long-Term Planning Issues New York has already established policies to phase out polluting,fossil fuel assets(including peaker plants), and accelerate deployment of clean energy technologies like battery storage, wind and solar. The section below outlines some of the key policies and long-term planning consideration that continue to motivate resource procurements and retirements. 2020 2025 2030 2035 2044 Indian Point CLCPA CLCPA CLCPA CLCPA Deactivate units 2&3 6 GW of distributed 3 GW storage 9 GW offshore wind 100%carbon free by 2020 and solar 70%load from electricity 2021 (2.3 GW) Reduce consumption renewables by 185 Trillion BTU NYC Residual Oil with energy efficiency PSC Order Elimination 3,000 MW of storage Eliminate Fuel Oil#6 Goal Announced by Cuomo RGGI Performance 1,500 MW of storage Reduce CO2 Standards emissions cap by 30% Maximum power plant NYC Residual Oil from 2020&include emissions of 180 Ibs Elimination peakers CO2 per MMBTU Eliminate Fuel Oil#4 (2.95 GW affected) LIPA and NY Accelerated RE& National Grid PSA Community Benefit Peaker Rule Contract expires NOx reduction in 2028 with options Helps accelerated compliance period to ramp down sooner siting of eligible (3.3 GW impacted) renewable projects LIPA and National Grid PSA Contract can be terminated early with 2 years'notice Figure 6. Policy and Planning Outlook Through 2040 1.2.1 Climate Leadership and Community Protection Act On July 18, 2019, New York Governor Andrew M. Cuomo signed into law the Climate Leadership and Community Protection Act(CLCPA). New York State's CLCPA is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and no less than 85 percent by 2050 from 1990 levels. The CLCPA puts New York State on the path towards net zero greenhouse gas (GHG) emissions.18 The CLCPA consists of the most stringent economy-wide carbon target in the US. By 2050,the CLCPA mandates an 85%reduction in GHGs from 1990 levels. Emissions beyond 85%can either be directly reduced or offset through projects that remove GHGs from the atmosphere.Additionally,the CLCPA codifies a number of ambitious electric sector targets, including 100% carbon-free electricity by 2040. To support and enable these broader decarbonization targets,the CLCPA has set resource procurement targets leading up to these decade milestones. The targets include 6 GW of rooftop solar by 2025, 3 GW of energy storage by 2030, and 9 GW of offshore wind by 2035. With clear targets for renewable energy, energy efficiency, and energy storage 'B New York State, Climate Act. https:Hclimate.ny.gov Long Island Fossil Peaker Replacement Study 11 ,� 0 2020 by Strategen coupled with a concrete timeline,the act seeks to drive renewable energy procurement and facilitate the rapid growth of a clean energy economy in New York. CLCPA mandates effectively eliminate the use of all fossil energy resources by 2040, necessitating the retirement of New York's fossil fuel plants in the next 20 years and thus investments in a carbon-free replacement resources will need to occur in parallel. 1.2.2 Air Quality and NOx Regulation In response to New York's nonattainment for the 2008 and 2015 ozone National Ambient Air Quality Standards (NAAQS), the New York Department of Environmental Conservation (DEC) implemented New York Codes, Rules, and Regulations (NYCRR) Subpart 227-3.19 The primary goal of this regulation is to lower allowable NOx emissions during ozone season. The regulation applies to all simple cycle and regenerative combustion turbines (SCCTs) larger than 15 MW and will affect approximately 3,400 MW of SCCT capacity in New York City and Long Island that are older, pre-1986 units. The DEC expects that most impacted facilities will optto replace or shut down non-compliant SCCTs because those installed prior to 1986 are typically not conducive to the addition of retrofit pollution control technology and will face high installation costs for any emissions control solutions. SCCTs built before 1986 contribute up to 94% of NOx emissions on high ozone days while providing only 36% of the gross load, so retirement of these generation resources will address NAAQS nonattainment.20 Based on estimates by DEC, replacing and retiring these older fossil units built prior to 1986 could reduce 1,849 tons of NOx emissions on some of the highest ozone days of the year, and will have the biggest impact on nearby communities, many of which are Potential Environmental Justice Areas. New York DEC has established a phased approach, with a NOx emission limit of 100 parts per million (ppm) going into effect on May 1, 2023. Two years later, the limit will drop to 25 ppm for units using gaseous fuels and 42 ppm for units burning liquid fuels. Further, the new emission rules stipulate that in 2023 peaking units will only be able to average emissions with similar units at the facility or with approved energy storage and renewable energy resources during the ozone season.This is contrast to current regulation, 6 NYCRR Part 227-2, which allows plant owners to average emission rates from across all facilities, including turbines and boilers.21 This means that under the current rules a facility can average its lower emitting, well controlled sources with higher emitting sources and calculate an average value for NOx compliance purposes. Under the new rules,this practice will no longer be allowable in 2023. Compliance options for SCCTs that exceed NOx limits consist of (a) retrofitting, shutting down, or replacing units, (b) ceasing operations during ozone season, or (c) pairing units with energy storage or renewable energy resources. As a part of this process, NYISO is planning to review any planned unit shutdown to ensure grid reliability.22 For example, the 19 New York State Department of Environmental Conservation,Adopted Subpart 227-3 Revised Regulatory Impact Statement. https://www.dec.ny.gov/regulations/l16175.html 2°Ibid. 21 New York State Department of Environmental Conservation,Adopted Subpart 227-2 Reasonably Available Control Technology(PACT)for Major Facilities of Oxides of Nitrogen(NOx)Revised Express Terms. https://www.dec.ny.gov/regulations/117482.html 22 New York State Department of Environmental Conservation,Adopted Subpart227-3 Revised Regulatory Impact Statement, op. cit. Long Island Fossil Peaker Replacement Study 12 0 2020 by Strategen NYISO 2020 RNA included a review for 3 units (Glenwood GT 1, Northport GT, and Port Jefferson GT 01) in preparation for deactivation in compliance with the peaker rule. These NOx compliance rules are expected to impact 3.4 GW of the fossil fueled power plants operating in Long Island, either through shutdown, reduced operation, or retrofits. These impacts are considered and explored later in this report by examining the explicit retirement of plants and as well as considering the cost effectiveness of continued investment in fossil assets as compared to the cost of transitioning to cleaner resources such as energy storage. 1.2.3 Energy Storage Roadmap and Deployment Plans At the end of 2018,the New York Public Service Commission (PSC)issued an energy storage order establishing a goal of 3 GW by 2030.23 It is important to note the goal of 3 GW was established by the PSC as a "no regrets" minimum threshold amount of storage and is not necessary the optimal amount of storage for the state, nor is it indicative of the level of storage deployment needed to achieve the state's goal of carbon-free electricity by 2040. This order built upon Governor Cuomo's nation-leading goal for the State of 1.5 GW of energy storage by 2025. The PSC order was based upon the recommendations of the New York Energy Storage Roadmap, developed by NYSERDA and the New York State Department of Public Service(DPS).24 The roadmap identified deployment opportunities and use cases for energy storage and provided recommendations of policies, regulations, and initiatives that the State could undertake to meet energy storage targets. To accelerate deployment of the mandated 3 GW of energy storage, the PSC order included incentive funds totaling $400 million available through 2025 and a directive to the state's six investor- owned utilities to hold competitive procurements for at least 350 MW of bulk-sited energy storage. 1.2.4 LIPA Contracts and Procurement A significant part of Long Island's pecker fleet is contracted through a PSA between LIPA and National Grid. The contract started in 2013, providing LIPA with 3,634 MW of dispatchable capacity.25 Of this capacity, 2,200 MW comes from eight steam units located at three sites: Northport, Port Jefferson and E.F. Barret. The remainder of the PSA capacity comes from 11 internal combustion power plants that provide additional peaking capacity. In recent years,the entry of new and more efficient assets on the Long Island system have led to substantially diminished output at Northport and Port Jefferson such that they now meet this study's criteria for a peaking facility (i.e. capacity factor less than 15%). The PSA with National Grid provides LIPA with all the capacity provided by the plants, as well as limited energy and ancillary services.26 All additional energy, ancillary services, and expenses are adjusted through monthly variable charges. These additional expenses may za New York Public Service Commission, Case 18-E-0130. http://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefld=%7bFDE2C318-277F-4701-B7D6- C70FCEOC6266%7d 24New York Public Service Commission,New York State Energy Storage Roadmap and Department of Public Service/New York State Energy Research and Development Authority Staff Recommendations. http://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefld=%7b2AlBFBC9-85B4-4DAE-BCAE- 164B21BODC3D%7d 25 LIPA,Amended and Restated Power Supply Agreement, op. cit.,p. C-1. 26 The National Grid PSA allows for offtake of a set amount of energy and ancillary services based on plant operational and performance characteristics.Additional energy and ancillary services are available on a cost to serve basis. Long Island Fossil Peaker Replacement Study 13 0 2020 by Strategen include, for example, those from environmental compliance such as NOx regulation, legal proceedings, Regional Greenhouse Gas Initiative (RGGI) allowances, and additional startups. Other costs included in the agreement are the cost of capital, property taxes, operation and maintenance costs, turbine upgrades, and new emission controls. Since its inception in 2013, the overall cost of the PSA, including the factors listed above, has increased over time with an annual average year-over-year increase of 2.5%. 1.2.5 LIPA PSA Early Termination Options Although the term of LIPA's PSA with National Grid extends through 2028, it does include contractual options to reduce contracted capacity before the end of the PSA term —referred to as a "ramp-down". For steam units, it allows LIPA to reduce contracted capacity of up to one of the steam unit blocks (out of six total across the three steam plants) before the end of the contract, assuming a 2-year advance notice from LIPA. For internal combustion units, the PSA allows for the ramp-down of any or all of the units with a 1-year notice. In the case of a ramp-down, LIPA is required to provide National Grid with a ramp-down payment that is linked to the Net Book Value of the specific asset being ramped down. This ramp-down payment is adjusted using a 37.5% discount factor for a ramp-down occurring after 2020 and 62.5% discount factor for a ramp-down occurring after 2023. Given this discount factor, and the fact that most of the units under the PSA are over 40 years old and thus have significant accumulated depreciation, it is reasonable to expect these ramp-down payments to be minimal in most cases (with the possible exception of newer units constructed in the 2000s). No additional discount factor is provided after 2023, meaning that there would be no potential additional savings for LIPA customers to delay retirements from 2024 to 2028. Furthermore,the entire PSA contract can also be terminated by LIPA as soon as May 2025, with a prior 2-year notice. 1.3 Clean Energy Replacement Options 1.3.1 Energy Storage The diverse asset class known as "energy storage" technologies are a critical enabler for integrating large quantities of renewable energy into power systems. Energy storage facilitates the acceleration of the energy transition because it may be deployed rapidly, scaled easily, located virtually anywhere on the electric grid, and efficiently provide necessary grid reliability services. The energy storage industry is well developed in the United States and energy storage systems are actively supporting grids and replacing fossil fueled peaking capacity in Hawaii, California, Massachusetts, New York, and many other locations. Indeed, New York has several examples of large-scale energy storage systems being developed, from which LIPA can learn and repeat. For example, NYSERDA signed a contract in 2019 with Lincoln Park DG to build a 20 MW storage project located atthe Lincoln Park Grid Support Center. The original proposed project at the site included a natural gas- powered peaking plant, but concerns raised by the community lead to the newly approved plans to install a battery at the site.27 Another approved New York project is at the Ravenswood site in Queens which once contained 16 peckers, of which only two remain in 27 Power Engineering,2019,NYSERDA to Replace Fossil Fuels with 20MW Energy Storage System. https://www.power-eng.com/2019/12/13/nyserda-to-rep lace-fossi I-fuels-with-20-mw-energy-storage- system/#gref Long Island Fossil Peaker Replacement Study 14 el ©2020 by Strategen operation today. The plant's owner has announced plans for the remaining peakers to be removed and replaced with a 318 MW battery.28 As New York's grid becomes increasingly decarbonized and decentralized,the operational flexibility provided by energy storage is especially important to balance supply and demand. In addition to grid flexibility, energy storage offers stacked benefits which include ancillary services, resource adequacy, deferral of transmission and distribution upgrades, increased renewable energy utilization and reduction of curtailment, GHG reductions, and portfolio diversity.Today's energy storage technology can allow the State to meet peak power needs without reliance on older, heavily polluting peakers. As of 2018, in the United States alone over 1,400 MWh of grid-connected battery storage had already been procured and installed.29 By 2030, the energy storage industry has been projected to provide benefits to the State totaling $3 billion, create approximately 30,000 jobs, and avoid over two million metric tons of CO2 emission S.31 1.3.2 Role of Solar and Off-Shore Wind New York's Climate Law mandates deployment of 6 GW of rooftop solar by 2025, 9 GW of offshore wind deployment by 2035, and 70% of electricity from renewable sources by 2030.31 As the state's portfolio of intermittent renewable power grows to provide a more significant portion of New York's net electricity demand, new challenges are created. The addition of new renewable resources, many of which are expected to be sited and interconnected near constrained load pockets with high energy demand, will shift overall energy flow on the grid. This may help to alleviate local reliability constraints but will create additional need for resources that can balance the intermittent generation of renewable resources. With these changes, energy storage will be increasingly necessary to smooth and time-shift renewable generation and minimize curtailment to ensure grid reliability. More specifically, it is anticipated that a large share of New York's ambitious off-shore wind portfolio will interconnect to the NYISO grid through Long Island. This will provide a significant amount of new generation to Zone K, which is location constrained. However, it will also mean there is a greater need for storage on Long Island to help overcome periods of low wind, as well as balance daily fluctuations in output. 2. Peaker Replacement Feasibility Analysis Energy storage is positioned to become one of the primary reliability and flexibility resources for New York State's clean electric grid. Given the combined need to meet both local reliability constraints (e.g. in New York City and Long Island) and New York's commitment to achieve zero emissions by 2040, energy storage will undoubtedly play an increasingly important role in meeting the reliability needs previously supplied by fossil fueled assets. This section explores the ways that fossil fuel peakers have historically operated on Long Island as a means to understand the ways storage may need to perform 28 CleanTechnica,2019, World's Largest Storage Battery-2.5 GWh-to Replace Gas Pecker Plants in Oueens. https://cIeantechnica.com/2019/10/28/worlds-largest-storage-battery-2-5-gwh-to-replace-gas- peaker-plants-in-queens/ 29 US Energy Information Administration,2020,Battery Storage in the United States:An Update on Market Trends. https://www.eia.gov/analysis/studies/electricity/batterystorage/ 30 NYSERDA, Energy Storage. https://www.nyserda.ny.gov/All-Programs/Programs/Energy- Storage#:"':text=Energy%20Storage%20 i n%20New%20York&text=A%20pro posed%2Ota rget%20of%20100,b y%202030%20through%20greater%20efficiency 3' NYSERDA, Climate Act op.. cit. ILLong Island Fossil Peaker Replacement Study 15 I 0 2020 by 5[ra[egen in order to replace these assets while providing comparable reliability services in support of Long Island's clean energy transition. A portion of this discussion focuses on understanding and accurately estimating actual reliability needs on Long Island. Long Island's peaker fleet has historically operated inefficiently and uneconomically, such that direct peaker dispatch is a useful proxy, but not a strict mandate to evaluate reliability needs. This section discusses both the use and limitations of historical peaker dispatch data to understand peaker replacement feasibility and lays out a conservative but informed approach to estimating grid needs. 2.1 Methodology for Identifying Replacement Candidates To assess the opportunity to retire and replace existing peaking assets, peckers were first categorized by their location. The peckers in the East End load pocket are considered in a separate analysis focused on reliability in constrained local areas, and identifying how this area could be transitioned while respecting the reliability concerns identified by NYISO and LIPA in the 2019-2028 Comprehensive Reliability Plan. After excluding the units in the East End load pocket, the remaining fossil fueled peaking fleet (which constitutes the bulk of the Long Island peaker fleet)were then further evaluated based on their historical operations and regulatory and contractual obligations on a unit by unit basis, as described below. 2.1.1 Operating Profiles The Long Island peaker fleet was analyzed on an hourly basis using historic generation profiles as reported to the EPA.32 The hourly profiles of individual units were analyzed for the years 2017, 2018 and 2019. Each unit was then categorized by its dispatch duration to understand the duration of storage that may be needed to replace the energy provided by peckers. Peakers with shorter duration dispatches were considered to be more cost- effective to replace as compared to peckers with longer-duration dispatches, regardless of their overall power capacity. This is due to the fact that the duration of a battery storage resources, as represented by MWh of battery capacity, is the largest driver of battery storage resources costs. Additional details of the peaker dispatch duration analysis and methodology is discussed in greater detail in the subsequent sections. 2.1.2 Pecker Groupings by Contract Expiration and NOx Compliance Dates In addition to historical peaker operations, there are other potential considerations for identifying peaker replacement candidates. Two important factors in this regard are 1) the expiration of existing contracts with off-takers (e.g. LIPA) and 2) compliance with NOx emission standards discussed in the previous section. In the case of contract expiration, many plants have recently expired contracts. Although the PSA block will not expire until 2028, there are key milestones for possible early ramp-down or termination of the contract in the 2025 timeframe. Of LIPA's 26 peaker plants, 17 are subject to recent rules established by the Department of Environmental Control (DEC) to reduce local NOx emissions from simple cycle combustion turbines. Of these 17 plants, only 8 of the plants already comply with the emissions control 32 Through its Continuous Emissions Monitoring System,the EPA collects data on hourly dispatch for all power plant units over 10 MW. 14 Long Island Fossil Peaker Replacement Study 16 ©2020 by Strategen requirements established by the DEC. Another 6 units, representing 1,324 MW are planning to install costly emissions control mechanisms by 2023 or 2025. Notably, these are costs paid by LIPA customers that could be avoided altogether if these plants were simply retired. The remaining 3 are planning to either retire or be kept for black start only generators, representing 16 MW retiring and 32 MW being kept for black start services. Table 3 below shows the NOx regulation compliance status and contract expiration year for all the plants considered in this analysis. It should be noted that the plants with contract expiration dates in 2028 are all part of the National Grid-LIPA PSA, and are subject to the early termination options discussed in the previous section. Toble 3. LIPA Pecker Fleet Contract Expiration Date and NOx Compliance Compliance Plan i. - • rContract • - Expiration Bethpage No N/A 2025 Bethpage CT No N/A N/A Brentwood Yes Selective Catalytic Reduction control N/A (SCR) in place. Comply with rule Charles P Keller No N/A N/A Edgewood Yes SCR & Water Injection (WI) controls in 2023 place. Comply with rule E.F. Barrett Jet Yes Plan to install WI 2028 East Hampthon Yes Plan to install WI 2028 Freeport GS Yes SCR &WI controls in place. Comply 2016 with rule Freeport 1 & 2 Yes Freeport 2 has SCR &WI. Comply N/A with rule Glenwood CT Yes Plan to install WI 2028 Glenwood Landing Yes SCR in units 4&5. Plan to retire unit 1 2028 by 2021 (16MW) Greenport No N/A N/A Hawkeye Energy Yes SCR &WI controls in place. Comply 2018 Greenport with rule Holtsville Yes Needs to "tune WI systems"to meet 2028 rule Jamaica Bay Yes SCR in place. Comply with rule 2020 Northport No(Steam) N/A 2028 Northport CT Yes Plans to go black start only by 2023 2013 Pinelawn Power No N/A 2025 Port Jefferson No (Steam) N/A 2028 Port Jefferson Peaking Yes Units 2&3 have SCR &WI. Unit 1 2028 going black start only(16 MW) Shoreham Yes Plan to install WI 2028 Shoreham Peaking Yes SCR &WI, comply with rule 2017 Southampton No N/A 2028 Southold No N/A 2028 Wading River Yes Needs to "tune WI systems"to meet 2028 rule West Babylon Yes To retire December 2020 2028 Long Island Fossil Peaker Replacement Study 17 �� 0 2020 by Strategen 2.2 Use of 901h Percentile Criterion To date, much of the analysis in New York conducted on the use of storage to replace fossil pecker units has focused on the single longest duration runtime of a pecker unit over a set time period. For example, a 2019 study evaluating the potential to replace peakers with energy storage relied heavily on evaluating the "longest start" of each individual pecker unit and was constrained by the hourly peaker unit dispatch." Under this approach, in order for an energy storage system to be sufficient to replace a fossil pecker unit it must be capable of running at least as long as longest start of the peaker unit. This approach has several shortcomings that may unintentionally bias replacement options towards longer duration storage systems for reasons that are not reflective of true system reliability needs. As such, this study's analysis took a closer examination of the "longest start" approach and developed alternative criteria for determining replacement storage duration needs. We believe these criteria are still relatively conservative, but do not needlessly limit storage replacement options to arbitrarily long durations. In re-evaluating the "longest peaker runtime" approach, there are five key factors to consider, which are discussed in greater depth through the remained of this section: 1. Peaker unit dispatch versus available zone level capacity, 2. Peaker unit dispatch versus plant level capacity, 3. Peaker unit dispatch for localized, non-peaking needs, 4. Inconsistent levels of output during longer run-times, and 5. Unit operational constraints. 2.2.1 Pecker Unit Dispatch versus Available Zone Level Capacity In recent years,the full capacity of the fleet of peakers on Long Island has not been required to meet peaking needs in Zone K. This is clearly illustrated in the chart below, which demonstrates that in 2018, only about 2,800 MW out of 4,350 MW (or about 64%) of total peaking capacity was ever used simultaneously. In 2017 and 2016, maximum fleet usage topped out at 67% and 71% respectively. 33 New York Public Service Commission, The Potential for Energy Storage to Repower or Replace Peaking Units in New York State. http-Hdocuments.dps.ny.gov/public/CommonNiewDoc.aspx?DocRefld=%7B2FOA202D-CAB9-4961-96F3- 56AEA67C6052%7D Long Island Fossil Peaker Replacement Study 18 ©2020 by Strategen 5,000 4,500 --------------------------------------®------ 4,000 3,500 3,000 a 2,500 0 2,000 T 1,500 0 1,000 500 0 _ C T C 5 O) Q U > U co Q m 7 N O N L Q :2 Q cn O Z o 2016 2017 2018 ——— Max Capacity Figure 7. Pecker Hourly Dispatch in Long Island Zone K, 2016-2018 There are several implications from this. First, it indicates that there is substantially more generation on the Long Island system than is typically needed to meet peak load. This conclusion is supported by NYISO's recent analysis as part of the 2019-2028 Comprehensive Reliability Plan, which included a Resource Adequacy study of the Peaker Rule Scenario.34 More specifically, the study demonstrated that the removal of about 1,440 MW of peaker capacity from Long Island would require only 350-500 MW in compensatory replacement generation on Long Island to maintain resource adequacy (i.e. to meet peak load) at the NYCA LOLE reliability criterion of 0.1 days/year. This means that N1,000 MW of generation can likely be removed from Long Island with minimal impact on reliability(from a peaking capacity standpoint), even if no new generation is added. Second, it also means thatthere is a significant amount of idle capacity, or headroom among the existing fleet of peckers that could be available for redispatch during peak load hours. For example, if a single 100 MW pecker unit ("Unit A") had operated for 12 hours during a peak load day in July, the same need could have been met by operating Unit A for only 6 hours, and then re-dispatching to another 100 MW peaker unit ("Unit B"), which had previously been idle, for the remaining 6 hours. Similarly, the peaking need could be met with a 6-hour duration battery storage system replacing Unit A, plus an additional six hours of outputfrom Unit B. In this case,the 12-hour pecker run time is not indicative of the duration of storage needed to replace Unit A since there is additional headroom on the system from undispatched units that can also contribute to peaking needs. The above chart shows around 1,260 MW of headroom between total installed capacity and actual demand. This means that the maximum runtimes for about 1,260 MW of peckers on Long Island could be met by re-dispatching across other peaking units, thus reducing the equivalent duration requirements of replacement options for these peckers by about 50% during peak load hours. 2.2.2 Peaker Unit Dispatch versus Plant Level Capacity Not only is there additional headroom at the Zone K level, but there is often additional headroom among units at a single plant location. The charts below illustrate this point for Shoreham in Long Island, the site hosts two power plants: Shoreham and Shoreham 94 NYISO,2019-2028 Comprehensive Reliability Plan. https://www.nyiso.com/documents/20142/6001938/04%202019- 2028%20CRP%20Report%20Draft.pdf 14 Long Island Fossil Peaker Replacement Study 19 0 2020 by Strategen Peaking. Shoreham Peaking is a 100 MW plant with two units of 50 MW each, while Shoreham has two units of 53 MW and 18.6 MW. In 2019, all units in the site dispatched less than 1% of their capacity. In 2018, one specific unit in the Shoreham plant, Shoreham GT3, dispatched for up to 15 hours, its longest dispatch of the year. However, this does not necessarily mean that a 15-hr duration storage asset is needed to replace Shoreham GT3. As an initial matter it is worth noting that while the run-time in this instance is 15 hours, the actual energy needs over this time period correspond to an 11-hour storage system. This is due to the fact that the output of the unit varies considerably across those 15 hours, meaning that the battery capacity in MWh would need to be sized for less than the full output of the plant over 15 hours. Furthermore, an examination of dispatch at the plant level including all four units, reveals that the duration needs are even less than 11-hours. In fact, a 7-hour duration storage system would suffice as a replacement for the plant's energy needs. This is because of the fact that while the peak output of the plant is about 170 MW, it is not 170 MW for the full 15 hours, or about 2,550 MWh. Instead,the output varies across those 15 hours, it only equals 1,190 MWh, or about 7-hours of duration at 170 MW. Unit Level Plant Level 50 180 45 160 40 140 35 120 30 r 25 v 80 � (6 a 20 15 60 10 40 i 2 0 I 0 - 0 1 2 3 4 5 6 7 8 9 10111213141516 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Hour of operation after initial start Hour of operation after initial start *Shoreham Peak GT3 ■Shoreham Peak GT3 ■Shoreham Peak GT4 .o Shoreham 1 7�Shoreham 2 Figure B. Comparison of Unit Level and Plant Level Run-Time for Shoreham Peaking The reduction from a 15 to a 7 hour start duration requirement corresponds to over a 50% reduction in storage needs versus the unit level maximum start duration approach. When considering the annual dispatch distribution for Shoreham GT3, shown in the below chart, a 7-hour start duration corresponds to the 8811 percentile of unit start-times for Shoreham GT3. Long Island Fossil Peaker Replacement Study 20 13 ©2020 by Strategen 14 90"'percentile 12 V) 10 U CO °_- 8 0 6 a`) z 4 2 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Dispatch Duration(hours) Figure 9. Shoreham Peaking GT3 Dispatch Duration, 2018 Another example of the ability to re-dispatch across the units within an individual plant can be seen in the case of the Northport Power Station. Earlier this year, LIPA analysis of retirement and repowering options for the Northport Power Station found no compelling reason to repower the Northport to maintain its existing capacity, and concluded that retiring, not replacing, one of the four units at the plant in 2022 would be the best option. Retirement of one of the Northport units would reduce customer costs by $300 million without harming system reliability. LIPA's decision to retire the Northport unit without the identifying a need for replacement indicates that there is more flexibility to remove individual peakers units from a plant than would be suggested by only looking at a more limited view of operating profiles.ss 2.2.3 Pecker Unit Dispatch for Localized, Non-Peaking Needs There are a variety of reasons that peakers may be operated on Long Island that are unrelated to resource adequacy (i.e. peaking needs). This is illustrated by the large amount of peaker capacity headroom during peak load hours as described above. If peaker runtimes were primarily driven by a significant peaking need, review of peaker dispatch would show a significant number of longer pecker run times that coincided across the peaking fleet and with and with highest demand hours. However,this dispatch phenomenon is not readily apparent from historic operations, which suggests that several other drivers are likely responsible for some of the longer runtimes observed at many peaking units in Zone K. For example, as further described in section 2.2.4 below, many peaker units are operated to provide local congestion relief on the low- voltage 69 kV system, or to address transient voltage issues. In Long Island's East End load pocket, out-of-merit dispatch (i.e. uneconomic peaker starts) was used to manage transient voltage for 813 hours and 61 days of 2019. Similarly, in the East of Northport load pocket, out-of-merit actions were used to manage constraints on the low voltage (69 kV) system for 754 hours and 48 days of 2019. Assuming that these 754 to 813 hours are allocated similarly across the 48 to 61 days with voltage constraints, this suggests that these out-of-merit 35 LIPA,Pepowering Feasibility Study Northport Power Station. https://www.lipower.org/wp- content/u ploads/2 020/0 5/No rth port-Repoweri ng-Study_2020.05.20-Secured.pdf Long Island Fossil Peaker Replacement Study 21 L+� 0 2020 by Strategen actions would correspond to pecker starts of 13-16 hours on average, which could be significantly higher than the start duration needs for meeting peak load. Moreover, as further explained below, these local voltage related needs could feasibly be addressed through alternative means that do not require sustained energy output associated with long-duration peaker starts. For example, reactive power can be supplied by inverter-based resources even when there is little to no energy output. This would obviate the need to provide a direct one-for-one replacement of pecker energy, and allow for replacement of pecker units with storage significantly shorter duration than the peaker's run time. Furthermore, the NYISO Market Monitor (Potomac Economics), has recommended certain market reforms that could help alleviate the need to manage these issues through out-of- merit action S.36 This could improve the efficiency of pecker dispatch, and perhaps reduce the run times of high heat rate peaker units. Thus, while it is difficult to quantify the impact on pecker run times these market reforms would have, it is reasonable to assume they could meaningfully reduce the duration need of any replacement resources. 2.2.4 Inconsistent Levels of Output During Longer Run-Times A close examination of pecker unit operations on Long Island reveals that the energy duration equivalent of the pecker output is significantly less than the pecker run time in hours. This is caused by inconsistent pecker output throughout each start. This could arise for a variety of reasons, but the most likely explanation is that each pecker run is not started or ended on the exact minute that the hourly interval begins or ends. As such, any start duration that is computed from historical hourly datasets will be systemically and systematically biased towards longer recorded dispatch times periods than actual historical dispatch. For example, when examining hourly generation data, a peaker unit may appear to start at hour beginning 600 at 10% of its maximum output, and then increasing to 100% in hour beginning 700. This could mean that the peaker unit started exactly at 6:00 but only at 10% of its capability. However, it more likely means the peaker unit started at 6:54. Thus when computing the run time, it will appear to be 1 to 2 hours longer than what actually occurred, depending on the timing of the start and the shut-off. This trend is visible at both the beginning and end of many peaker run times in the NYISO hourly generation data. The relevance of this phenomenon is most pronounced for peaking units that are recorded operating below their minimum operating capacity, as shown below. For example, the below chart shows the hourly output from the unit E.F. Barrett Jet 09 over a 32-hour period. During this time, the unit is recorded dispatching for durations of up to 4 hours. However, actual output is well below 25% of max capacity for all of these dispatches, and in some cases is barely 1 MW. 36 Potomac Economics,2019 State of the Market Report for the New York Independent System Operator. https://www.potomaceconomics.com/wp-content/uploads/2020/05/NYISO-2019-SOM-Report_Full- Report_5-19-2020-fi nal.pdf Long Island Fossil Peaker Replacement Study 22 0 2020 by Strategen 45 40 r r r r r r r r w wwrww�rrrrrrrw..�rwrrrrrwwwww wrrrr-rwr 35 30 25 20 15 10 o 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Hour of dispatch E.F Barrett Jet 09 —-- Max Capacity 50%Capacity Figure 10. Illustration of E.F. Barrett Jet 09 hourly output 2.2.5 Unit Operational Constraints Finally, there are inherent technical limitations in thermal power plant dispatch and operations that may lead plants to run longer than what would otherwise be necessary or efficient for the system if those limitations did not exist. These limitations include minimum run times, minimum down time, minimum operating capacity, and cycling costs. While many of the pecker units analyzed in this study are gas turbines with quick start capabilities and relatively short minimum run times, the pecker portfolio contemplated for this report also includes several older steam units that run at relatively low capacity factors. These steam units typically have longer minimum run times. For example,the Northport, Port Jefferson and E.F. Barrett units all have cold start-up times exceeding 24 hours, and even when still hot, will take 8 hours to start up.37 These constraints mean that it is often preferably to leave units running, even when not strictly needed or when not economic, to avoid the forced downtime that results from slow unit start-up times. Additionally, steam units tend to have significant cycling costs.38 This means that a unit that is already online will tend to stay online even if it is uneconomic to operate over the course of several hours. This is because it may be advantageous to temporarily incur losses from uneconomic generation in order to avoid cycling costs. For both of these reasons, when steam units are started,they tend to operate for longer periods of time, even if a truly optimal solution would be for them to run for fewer hours. Moreover, these limitations are not reflective of system reliability needs, but are simply reflective of the characteristics of steam generation and should not be interpreted as a requirement for the duration of a storage alternative. The below chart shows historical operation of the Northport plant where 3 peaking units were ramped down, but not turned off, despite low demand. Notably, the overall energy from these 3 units is less than the max capacity from a single unit. 37 LIPA,Amended and Restated Power Supply Agreement, op. cit.,p. EA 38 NREL,2012,Power Plant Cycling Costs. httos://www.nrel.goo//docs1fo2osti/55433.pdP Long Island Fossil Peaker Replacement Study 23 0 2020 by Strategen 1200 1000 800 600 400 200 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 13 19 Hours of Dispatch Northport1 ■Northport 2 [Northport 3 2Northport 4 ■Northport CT GT Figure 11.111ustrotion of typical dispatch of Northport steam and gas turbine units 2.2.6 Conclusions on Use of 901 Percentile for Evaluating Peoker Start Duration Given the cumulative impact of the five factors described above, use of maximum start duration is an inappropriate and unnecessarily conservative approach to evaluate the feasibility of replacing fossil pecker units with storage. For example, as shown in the figure below, many pecker units operate for very short durations even during the critical summer peak load hours, and some units do not even run at all during those times. However, some consideration must be given to the fact that peak load in Zone K must be met even under high load conditions and that some peaker starts can be a result of the need to meet these high load conditions. As such, this analysis adopts a compromise approach of determining storage duration needs based on the 90' percentile of peaker run times at each unit. 200 3000 2500 �150 2000 v L � U CM 1100 1500 a o LO 1000 50 LL 500 0 -- - - - 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Hour of Dispatch Holtsville 01 Holtsville 02 �Holtsville 03 �Holtsville 04 Holtsville 05 Holtsville 06 ��Holtsville 07 �Holtsville 08 Holtsville 09 Holtsville 10 Peaker Fleet Generation Figure 12.111ustrotion of dispatch duration of each of 10 units of the Holtsville plant during peak summer load hours in 2018 This approach strikes an appropriate balance of ensuring that duration needs are not inappropriately biased towards longer start times while still maintaining a very conservative approach to system reliability. Moreover, given the headroom in terms of overall capacity in Zone K, and the results of the 2019-2028 Comprehensive Reliability Plan analysis on the Long Island Fossil Peaker Replacement Study 24 0 2020 by Strategen Peaker Rule Scenario, there is strong indication that there is little risk involved (from a resource adequacy standpoint) in replacing the first 1000 MW (or more) of peaker units with energy storage as a form of compensatory generation. 2.3 Start Duration Analysis Further reinforcing the analysis in the previous section, assessment of hourly dispatch of the units considered for this study shows that the majority of unit starts are for relatively short durations. In fact, Long Island peaking units were most frequently dispatched for 2 hours or less as illustrated in Figure 8 below. Of all unit starts, over half were recorded to last for 4 hours or less. Over 90% of all recorded unit dispatches were for 13 hours or less. 30% 100% 90% 25% 54% 80% 90% 70% 20% 77% 60% E ° 15% 50% � 40% � 10% 30% in a 5°/ 100/0 20%° 0% ° 0% 1 2 3 4 5 6 7 8 9 10 11 12 13 Start Duration(hours) Figure 13. Pecker Start Duration Analysis This portfolio-wide dispatch pattern was also demonstrated in individual peaking units. For example, E.F. Barrett Jet 04 was called on in 2018 to run for as long as 49 hours, but most frequently it ran for 2 hours or less, and over 90% of its dispatches were for 12 hours or less. 40 35 90t"percentile U ° 30 L U a a 25 ' 0 `0 20 `m 15 E z 10 5 0 1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 Dispatch Duration(hours) Figure 14. E.F. Barrett Jet 04 Dispatch Duration Frequency, 2018 Analysis further demonstrated that these dispatch patterns remain relatively consistent across multiple historical years. Nearly 2,000 MW of fossil fueled capacity on Long Island typically ran for around 12 hours or less over the last 3 years. Long Island Fossil Peaker Replacement Study 25 ©2020 by Strategen 2,500 2,000 1,500 1,000 500 ' o - 0 1-4 hrs 5-8 hrs 9-12 hrs 12-25 hrs 26-100 hrs 101-1000 hrs >1000 hrs Maximum Dispatch Duration ■2018 ■2017 -2016 Figure 15. Consistency of 901' Percentile Pecker Dispatch Duration, 2016-2018 2.3.1 Candidate Portfolio Based on Start Durations To identify feasible replacement candidates, peaker units were categorized into three groups for potential retirement based on their 90th percentile dispatch duration. A fourth group was also included to identify peckers that would be difficult to retire based solely on extensive dispatch duration. The first group included all peckers that were typically dispatching for 4 hours or less during the year. This group included the below 193 MW of installed peaking capacity. Table 4. Pecker Group 1 Installed ��-L--Capacity E.F. Barrett Jet GT01 E.F. Barrett Jet 18 East Hampthon 2 East Hampthon 2 East Hampthon 3 East Hampthon 2 East Hampthon 4 East Hampthon 2 Glenwood GT02 Glenwood CT 55 Holtsville 03 Holtsville 56.7 Northport CT GT Northport CT 16 Port Jefferson Peaking GT1 Port Jefferson Peaking 16 Southampthon 1 Southampton 11.5 Southold 1 Southold 14 Total 193 Long Island Fossil Peaker Replacement Study 26 ©2020 by Strategen The second group included all peckers that were typically dispatching for 8 hours or less across the year and was comprised of the below 927 MW of peaking capacity. Table 5. Peoker Group 2 Installed .. E.F. Barrett Jet 03 E.F. Barrett Jet 18 E.F. Barrett Jet 05 E.F. Barrett Jet 18 E.F. Barrett Jet 06 E.F. Barrett Jet 18 E.F. Barrett Jet 09 E.F. Barrett Jet 41.8 E.F. Barrett Jet 10 E.F. Barrett Jet 41.8 E.F. Barrett Jet GT02 E.F. Barrett Jet 18 Freeport GS CT1 Freeport GS (Equus) 60 Holtsville 01 Holtsville 56.7 Holtsville 02 Holtsville 56.7 Holtsville 04 Holtsville 56.7 Holtsville 05 Holtsville 56.7 Holtsville 06 Holtsville 56.7 Holtsville 07 Holtsville 56.7 Holtsville 08 Holtsville 56.7 Holtsville 09 Holtsville 56.7 Holtsville 10 Holtsville 56.7 Shoreham 1 Shoreham 52.9 Shoreham 2 Shoreham 18.6 Shoreham Peaking GT4 Shoreham Peaking 50 Wading River 2 Wading River 79.5 Total 927 The third group consisted of all peaking units with typical dispatch duration of 12 hours or less, representing 782 MW of installed capacity. Long Island Fossil Peaker Replacement Study 27 ©2020 by Strategen Table 6. Peoker Group 3 211111 —Fn—sta-1 -. .. E.F. Barrett Jet 04 E.F. Barrett Jet 18 E.F. Barrett Jet 08 E.F. Barrett Jet 18 E.F. Barrett Jet 11 E.F. Barrett Jet 41.8 E.F. Barrett Jet 12 E.F. Barrett Jet 41.8 Edgewood GT2 Edgewood 50 Freeport CT2 Freeport 1 & 2 60.5 Glenwood GT01 Glenwood Landing 16 Glenwood GT03 Glenwood CT 55 Glenwood GT05 Glenwood Landing 53 Jamaica Bay GT2 Jamaica Bay 60.5 Port Jefferson Peaking GT2 Port Jefferson Peaking 53 Port Jefferson Peaking GT3 Port Jefferson Peaking 53 Shoreham Peaking GT3 Shoreham Peaking 50 Wading River 1 Wading River 79.5 Wading River 3 Wading River 79.5 West Babylon 4 West Babylon 52.4 Total 782 Finally, the last group included all peckers with typical dispatch greater than 12 hours. Though all of these units operate at less than 10% capacity factor, dispatch durations across this group varied significantly. Some, such as Glenwood Landing and Edgewood, generally dispatched for no more than 13-14 hours. Others, such as the Northport plants, often dispatched for as much as 400 or more hours. This is in part due to the operational constraints of steam units discussed earlier and requires a different analytical approach to retirement and replacement decisions. This final portion of the portfolio represents the largest share of installed capacity, at more than 2,300 MW total. Long Island Fossil Peaker Replacement Study 28 ©2020 by Strategen Toble 7. Pecker Group 4 Installed Capacity' U nit Rame Bethpage 3 Bethpage 96 Bethpage CT GT4 Bethpage CT 60 Brentwood Brentwood 47 East Hampthon GT1 East Hampthon 21.3 Edgewood GT1 Edgewood 50 Glenwood GT04 Glenwood Landing 53 Greenport Hawkeye GT1 Greenport Hawkeye 54 Pinelawn Power 1 Pinelawn Power 82 Northport 1 Northport 387 Northport 2 Northport 387 Northport 3 Northport 387 Northport 4 Northport 387 Port Jefferson 3 Port Jefferson 188 Port Jefferson 4 Port Jefferson 188 Total 2,387 2.3 Load Pocket Analysis and Local Reliability Issues Local reliability constraints may also limit replacement options in certain limited areas of Long Island such as the East End, Barrett, and East of Holbrook locations. However, some amount of replacement is still feasible in near term. According to its Comprehensive Reliability Plan, NYISO and LIPA estimated that there is sufficient headroom for storage to replace pecker capacity in the Barrett and East of Holbrook locations. Meanwhile, about 250 MW of local pecker plant capacity in the East End that cannot be easily replaced by storage due to charging limitations. However, Strategen estimates that at least 90 MW of the 250 MW deficiency could be replaced with storage of 8 hours or less. Additionally, expected deployments of solar, off-shore wind, and energy efficiency could mitigate the remaining need for compensatory generation in the East End load pocket. This section discusses replacement and retirement options in these transmission constrained areas. 2.3.1 Review of NYISO Reliability Studies In 2019, the NYISO completed its 2019-2028 Comprehensive Reliability Plan. The Plan included analysis of a "Pecker Rule Scenario" which the ISO studied (in coordination with LIPA and ConEd)to understand the potential reliability impacts and any necessary mitigation Long Island Fossil Peaker Replacement Study 29 ©2020 by Strategen measures from implementing the DEC's "Pecker Rule.1139 This rule will apply new limits to NOx emissions from peaking generation units, most of which are located in New York City and Long Island. In the Scenario studied, the ISO assumed that by 2025 about 1,445 MW (name plate) of peaking capacity would be removed from Long Island (Zone K) and 1,758 MW would be removed from New York City (Zone J). To meet overall system resource adequacy needs (i.e. peaking needs), about 1,000 MW of "compensatory generation" would need to be added, equally split between Zones J and K, by the year 2028. This need decreases to 700 MW total if expected AC Transmission Projects are completed on time.40 h'ORTf!FO4A / Newbridge Interface Holbrook Interface r EI rSl) f. FASTOF,SORINPORT F ' NORTNEASTNIMA' 1 ] ' F_ISTOFBL'EU. I�Ll'TGR7Y 90RTTOAN it� ,,..1 . ` ► y ti _ s } i 1 4 tl alIL77f FOl7A' 1 art,, —�} F_ISTBROOA'IIAI'E1' r�'� ^ ► �Y�1'-^� k 1 ` 1 IrESTBR00AH1YE.�' s B.�milarrn BABITON SOUR I SIE U y SUFFOLK i - ! 14RRErT SOLTNFAR111.1'GDALE I FAR ROCFO1'AY Figure 16. Long Island Load Pockets and Interfoces41 In addition to NYISO's overall resource adequacy needs, LIPA conducted its own analysis of local transmission security issues under the Peaker Scenario in the 2028 timeframe.42 The results of this analysis showed that thermal overloads on the Long Island transmission system were possible during peak conditions unless 620 MW of local compensatory generation were added. This 620 MW deficiency arises from the combined needs of three critical load pockets -- East End, East of Holbrook and Barrett — each of which has its own unique limitations. Despite the local transmission constraints identified for Holbrook and Barret, these load pockets remain prime candidates for storage. As shown in the two charts below, the overall load profile in these regions provides sufficient headroom for storage charging, with the MWh total of headroom during off-peak hours exceeding the deficiency during the on-peak hours. " NYISO,2019-2028 Comprehensive Reliability Plan. Op.cit.., p.28. 40 AC Transmission projects T027+T019 in service by January 2024. 4' NYISO,2019-2028 Comprehensive Reliability Plan. op. cit., p.19. 42 PSEG Long Island,CRP:Peaker Scenario. https://www,nyiso.com/documents/20142/5552484/LIPA- Sim ple%20Cycle%2ORetirement%2OAssessment%203-03-2019.pdf/3ld43e9f-d9f7-476f-605f-df3lef7d7674 Long Island Fossil Peaker Replacement Study 30 0 2020 by Strategen 200 — 150 Headroom:3653 MWh(18 hours) ]oo sa — — 0 u, 3 P -50 -100 .150 Deflciency:240 MWh(6 hours) — V -200 -250 Load level with no deficency LIPA system load of 4925 MW 300 — -350 _�11I Iw:.i:• " 400 1W 2W 3W 4.00 500 6.00 7DO AW 9.100 10.00 11:00 12:00 190 2:00 3,00 4:00 590 6W 790 890 9:00 10:00 11:00 12:00 AM AM AM AM AM AM AM AM AM AM AM PM PM PM PM PM W PM PM PM PM PM PM AM Figure 17, Barrett Load Pocket Duration Curve 43 /W 600 — Load level with no deficency 500 LIPA system load of 4450 MW 400 300 Headroom:5276 MWh(14 hours) _ 3 200 100 0 if E-100 .200 it -300 Deficiency:2126 MWh(10 hours) -000 i -500 600 -700 — 7W 2W 390 490 590 6W 7W AW 990 10:00 11:00 12:W 11,00 2W 3D0 490 5W 6W 7W AW 990 10.00 11:W 12:00 AM AM AM AM AM AM AM AM AM AM AM PM PM PM PM PM PM PM PM PM PM PM PM AM Figure 18. South Western Suffolk Load Duration Curve 44 Of these three, East End presents the largest challenge for ensuring reliability can be maintained if the compensatory generation comes in the form of energy storage.This is due to the long duration of the deficiency identified and the limited headroom available during off-peak hours for charging energy. In fact, as illustrated in the chart below, the energy required during the deficiency is greater than the charging energy available under the present transmission constraints of the East End load pocket. 43 Ibid., p.22. 44 Ibid., p.21. Long Island Fossil Peaker Replacement Study 31 ©2020 by SVategen East End 2025 Load Cycle Deflcency 300 zsa Loadleve'with no deficencyI 200 East End load of 326 MW 150 Headroom:495 MWh(9 Hours) 2 300 5o 0 .50 -100 Deficiency:2544 MWh(15 hours) -150 -200 100 200 300 4:00 S00 600 700 800 900 10:00 11:00 12:00 100 200 300 400 500 600 700 8:00 900 10:00 11:00 12:00 AM AM AM AM AM AM AM AM AM AM AM PM PM PM PM PM PM PM PM PM PM PM PM AM Figure 19. East End Load Cycle Deficiency, 202845 Due to these challenges, we initially excluded the following peaker plants located in the East End area from the portfolio assessment of potential replacement candidates: Table B. Groups 1& 2 Excluded Pecker Plants in East End U Ultimate Parent East Hampthon 2 East Hampthon National Grid East Hampthon 3 East Hampthon National Grid East Hampthon 4 East Hampthon National Grid Southampthon 1 Southampton National Grid Southold 1 Southold National Grid Shoreham Peaking GT4 Shoreham Peaking Manulife Financial & Electric Power Dev. Shoreham Peaking GT3 Shoreham Peaking Manulife Financial & Electric Power Dev. Shoreham 1 Shoreham National Grid Shoreham 2 Shoreham National Grid Wading River 2 Wading River National Grid However, while a full replacement of these units with storage may not be both feasible and cost-effective in the near term, it is worth noting that 1) a partial replacement may still be feasible and cost-effective, and 2) a full replacement may become feasible and cost- effective in the longer term. Factors that could enable a full replacement include: a) battery costs declines sufficient to allow longer duration storage to become cost effective, b) changes to net load patterns change in the East End load pocket shift due to off-shore wind, 45 Ibid., p.21. Long Island Fossil Peaker Replacement Study 32 0 2020 by Strategen solar PV, and energy efficiency measures that reduce and narrow the peak, and c)additional buildout of transmission facilities that alleviate load pocket constraints. Regarding the partial replacement option described above, the chart below illustrates how at least 90 MW of peaker capacity in the East End could be feasibly replaced with a combination of 3-hour, 6-hour, and 8-hour duration storage, rather than the 15 hour duration requirements suggested by the Comprehensive Reliability Plan.46 300 250 90 MW replacement potential: 30 MW x3 hr. 3� 200 +30 MW x6 hr. 0 \ 2 +30 MW x 8 hr. 495 MWh Discharge \ V 150 E 100 07 50 0 0 ~ °/ 12 \ 2 3 4 5 6 7 •4 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 -50 \ / -100 495 MWh Charge Headroom Base Case With Storage Figure 20. Partial Replacement of East End Load with Storage, 2025 2.3.4 Uneconomic Pecker Operation for Local Reliability One of the most important characteristics about the operation of existing peaker units on Long Island is that they are frequently dispatched uneconomically, or "out of merit" and for reasons other than meeting peak load needs. In fact, according to the 2019 NYISO State of the Market: `[Out of Merit]dispatch was frequently used to manage 69 kV constraints and voltage constraints (i.e., TVR requirement on the East End of Long Island)."47 In other words, Long Island peakers are frequently used to resolve two local reliability issues: 1. Resolve congestion on the low voltage (69 kV) system and, 2. Manage Transient Voltage Recovery(TVR) in the East End. In both cases, the local Transmission Owner (i.e. LIPA) takes actions to manually resolve these issues through uneconomic dispatch of peakers, which ultimately lead to sub-optimal results. These actions are generally not coordinated with NYISO and are not optimized through NYISO's day-ahead and real-time market software. As a result, units are often operated unnecessarily and inefficiently, while also leading to depressed L13MPs that send 46 Ibid., p. 21. 47 Potomac Economics,op. cit, p.40. Long Island Fossil Peaker Replacement Study 33 a� 0 2020 by Strategen inaccurate price signals to potential future investment, and requiring millions of dollars in uplift charges.48 Regarding the 69 kV congestion, NYISO SOM states the following: [W]hen a 69 kV facility is constrained flowing into a load pocket, the local [Transmission Owner]often provides relief by starting a peaking unit in the pocket. However, when this is done on short notice and there is no least-cost economic evaluation of offers, the local TO often runs oil-fired generation with a relatively high heat rate when much lower-cost resources could have been scheduled to relieve the constraint.`9 The proportion of hours where out-of-merit actions were taken to resolve congestion issues (versus times when the market was used to resolve these)were quite significant throughout Long Island and are more pronounced in certain locations. For example, in the Brentwood area, 99% of congested hours in 2019 were managed through out-of-merit actions rather than through the DA and RT markets. Additionally, the NYISO has identified the fact that issues frequently arise due to lack of coordination between the local TO and NYISO regarding the scheduling of Phase Angle Regulators ("PARs")to manage congestion: "If the local TO frequently adjusts a PAR to relieve 69 kV congestion, the NYISO will have difficulty predicting the PAR schedule since it does not model the constraint that the PAR is adjusted to relieve. Consequently, errors in forecasting the schedules of the Pilgrim PAR on Long Island in the day-ahead market and in the RTC model has been a significant contributor to unnecessary operation of oil- fired generation, balancing market congestion residuals, and inefficient scheduling by RTC."so Additional analysis performed by the NYISO market monitor suggests that the majority of gas turbine (i.e. peaker) unit commitments being made in real time were not clearly economic, including for units on Long Island. This is clearly illustrated in the figure below, where the green bars indicate economic unit commitment and the other colored bars represent operation that is inefficient, and units are being started despite the fact that their offer prices (which reflect their operating costs) exceed the prevailing market price, by over 50% in many instances. 48 For example, according to the 2019 NYISO State of the Market Report,the net revenues for a new generator on Long Island could increase by$27/kW-yr if these inefficient practices were addressed (see p A-78). 49 Potomac Economics,op. cit., p.41. so/bid., p.41. Long Island Fossil Peaker Replacement Study 34 0 2020 by Strategen Fi6w•e A-?G:Efficiency-of Gas Turbine Commitment 2019 so ■05er,LBIIP bF EDlibor more 70 a Offer>LBVP b<:r b to S0R o — G 60 OOff#rnLBW bFupto2a!o L y Economic t s0 3 a ;0 Z a 30 i Y m 20 Y 10 — 0 NYCLI ti1'C LI NTC Li 10-36Imote GTs Otdtr 30%lin GTs INM 30min CTs Figure 21. Uneconomic Pecker Unit Commitments, 201951 Taking together the information in these SOM reports, it is apparent that the peakers on Long Island are frequently operating inefficiently and uneconomically and appear to be doing so to meet local voltage and congestion issues that could potentially be alleviated through modest NYISO market reforms and/or better coordination between NYISO and LIPA. If these steps were taken, we believe that long-duration pecker would become much less prevalent. This provides further proof that examining the maximum duration of pecker starts in recent years is not a sound approach for determining the feasibility of replacement via energy storage. For example, many of these longer starts may have been simply have been due to local voltage issues that could have just as been easily resolved through a replacement resource regardless of its duration. For voltage issues in particular, it is worth noting that voltage control can generally be provided by most modern inverter-based resources and that there is no fundamental need to maintain fossil peakers for this service. In fact, recent demonstrations have shown that inverter-based resources can perform just as well if not better than traditional resources for provide ancillary services. As an example, the image below shows the real-world test results of a joint demonstration conducted by the CAISO, NREL and First Solar for a large-scale solar PV plant (which functions as an inverter-based resource similar to battery storage).The results show that the plant was capable of providing accurate voltage control (i.e. reactive power) even under conditions where it did not produce energy: "One woy to increase the optimol utilization of PV power plants is to use their capability to provide VAR support to the grid during times when the solar resource is not ovoiloble. For this purpose, the capability of the grid-tied inverters of the 300- MW PV plant to provide reactive power support during o period of no octive power generation was demonstrated. Due to the limited time window available for this testing, it was not possible to test this capability during dark hours of the day,' 51 Ibid., p.134. Long Island Fossil Peaker Replacement Study 35 0 2020 by Strategen instead, the team decided to demonstrate the VAR support capability of the plant at nearly zero active power generation. The plant's active output was curtailed to nearly zero MW on August 24, 2017 Then the command was sent to the plant controller to ramp the reactive power to produce or absorb 100 MVAR. The results of these tests along with the measured POI voltage are shown in Figure 49. The plant was fully capable of producing or absorbing the commanded MVAR levels during the whole testing time. Note that the conditions of this test are only partially realistic because special control schemes are needed for grid-tied inverters to operate as STA TCOM when a PV array is fully de-energized, and a certain amount of active power needs to be drawn from the grid to compensate for inverter losses. A more realistic test for nighttime VAR mode is planned for the near future."sz 4 Figure 22. Demonstration of Voltage Control Provided by a Large-Scale PV Plont53 The same would be true of a battery storage resources,that should be capable of providing voltage control, even if the battery is not providing energy output. As such, regardless of its duration, a storage resource could serve as a viable replacement for peakers that are primarily operating to address local voltage problems, such as those occurring on the East End. 2.4 Impact of Solar, Energy Efficiency and Off-Shore Wind on Net Load Profiles A final major contributor to Long Island local reliability will be the addition of new clean resources over the next decade. According to forecasts by NYISO, Long Island could see the addition of as much as 262 MW of new behind-the meter distributed solar by 2030, and between 2.3 to 5.2 GWh of new energy efficiency in the same period, which could provide 52 NREL, Demonstration of Essential Reliability Services by a 300-MW Solar Photovoltaic Power Plant https://www.nrel.gov/docs/fyl7osti/67799.pdf 53 Ibid., p.42. Long Island Fossil Peaker Replacement Study 36 ©2020 by Strategen as much as 580 to 1,300 MW of peak capacity.54 The below charts shows NYISO's energy efficiency and rooftop solar forecasts for the Long Island Transmission zone. Both charts show the additional resource contributions that are expected incremental to what is already in place today. For the purposes of this analysis,the low energy efficiency forecast and high rooftop solar forecast were used to estimate net load. T 6,000 350 5,000 a 300 CD Ji U 250 >^ 4,000 m c 200 w L7 3,000 MO 150 C 2,000 E E 100 P P 1,000 U 50 C— 0 0 2020 2022 2024 2026 2028 2030 2020 2022 2024 2026 2028 2030 Energy Efficiency Forecast-High Rooftop Solar Forecast-Low Energy Efficiency Forecast-Low Rooftop Solar Forecast'High Figure 23. Long Island Cumulative Energy Efficiency Forecasts Although New York is expecting to see the addition of incremental electrification of the building and transport sectors in pursuit of overall economy decarbonization, much of this electrification is expected to arrive between 2030 and 2040. Between 2020 and 2030, the energy efficiency shown above is expected to be greater than the incremental demand presented by electrification. In fact, as seen in the below chart,total energy demand in New York declines a small amount in the mid-2020s due to energy efficiency, and only begins to rebound in the latter half of the decade as increased demand from electrification begins to impact total statewide electric demand. 175,000 34,500 170,000 34,000 165,000 3: 33,500 a 160,000 -6 33,000 C m E 155,000 32,500 150,000 >1 32,000 C' 145,000 c 31,500 LU 140,000 31,000 135,000 -- 30,500 O N d' C9 CO O N CO CO O O N CO O N (-O O N N N N N N m m O O O O O O O O O O O O O O O O O O O O O O N N N N N N N N N N N N N N N N N N N N N N Figure 24. Baseline NYCA Energy Demand, 2020-2040 54 NYISO,2020 Load and Capacity Data(Gold Book). https://www.nyiso.com/docu ments/20142/2226333/2020-Gold-Book-Final-Public.pdf/ Long Island Fossil Peaker Replacement Study 37 ILI 0 2020 by Strategen Meanwhile, New York is also making significant progress towards its goal of 9 GW of offshore wind by 2035. The majority of these new wind resources are anticipated to interconnect primarily into Zones J & K. Over 1,800 MW of new offshore wind has already been contract, and is expected to deliver energy into New York by 2024 or sooner. Consistent with this progress and with the 2035 goal of 9 GW of offshore wind, New York could see as much as 6 GW of offshore wind by 2030, with as much as half of that capacity interconnecting into Long Island. 14,000 sEmpire Wind Project =South Fork 12,000 NYC Generic Incremental Sunrise Wind Project 10,000 :CLCPA Generic Incremental �LI Total 8,000 a 6,000 a M v 4,000 2,000 2025 2030 2035 2040 Figure 25. Planned and Forecast Offshore Wind Contracts in NY The addition of these new resources will fundamentally change energy demands (i.e. load net of variable wind and solar) in Long Island by 2030. The below chart shows an example of how these new resources might impact net load on an average August day. August is generally the month with highest energy demand, and often sees the most significant use of peaking resources. Long Island could see a reduction in average annual net load peak by over 670 MW, which represents about 12% of current peak load. This change in net energy demand will be even more pronounced during winter months, when offshore wind production is highest. The below charge shows an average day in January — net load has dropped by close to 2,000 MW to nearly 0 during off-peak hours. These new operating conditions will create extreme ramping and flexibility challenges for the existing fossil fleet but present an excellent opportunity for storage to help absorb excess generation and moderate overall ramping demands, helping to reduce curtailment and improve overall renewable deliverability. Long Island Fossil Peaker Replacement Study 38 ©2020 by Strategen 4,500 Summer Day 4,500 Winter Day 4,000 4,000 3,500 3,500 3: 3,000 3,000 2,500 2,500 - a� 2,000 2,000 ; z 1,500 1,500 1,000 1,000 500 500 0 - - 0 1 3 5 7 9 11 13 15 17 19 21 23 1 3 5 7 9 11 13 15 17 19 21 23 Hour of Day Hour of Day - LI Actual 2018 Load 2030 Net Load Figure 26. Forecast of 2030 Long Island Net Load:Average August and January Days 2.5 Peaker Retirement Phases Taking into consideration all of the factors outlined in this report, a candidate set of Long Island pecker units have been identified for replacement with energy storage. In order to appropriately manage this replacement, we have further categorized these replacements into Phases reflecting their viability along a future time horizon. Factors considered for these phases include contract expiration, NOx emission regulation, dispatch duration, load pocket location, and availability of additional clean resources discussed in the previous section, a final selection of peckers was made that represented a reasonable overall retirement and replacement portfolio. The first phase includes 334 MW of peaking capacity that could reasonably be retired and replaced with storage today. On average, the units in this portfolio are over 40 years old. Over half of them are still reliant on fuel oil for their operation, and three plants (Northport CT, Port Jefferson Peaking, and West Babylon) are already expected to retire due to NOx regulations. Table 9. Pecker Retirement Phase 1 Installed Capacity Retirement Reason E.F. Barrett Jet GT01 E.F. Barrett Jet 18 Dispatch Duration Freeport GS CT1 Freeport GS (Equus) 60 Contract Expiration Glenwood GT02 Glenwood CT 55 Dispatch Duration Holtsville 03 Holtsville 56.7 Dispatch Duration Long Island Fossil Peaker Replacement Study 39 0 2020 by Strategen Jamaica Bay GT2 Jamaica Bay 60.5 Contract Expiration Contract Expiration; NOx Northport CT GT Northport CT 16 Regulation; Dispatch Duration Port Jefferson Port Jefferson 16 NOx Regulation; Dispatch Peaking GT1 Peaking Duration West Babylon 4 West Babylon 52.4 NOx Regulation Total 334 Due to the short duration dispatch cycles that these plants are to perform, the grid services provided by these peaking plants can be effectively replaced by storage resources of 4- hour duration, or by "stacked" 2-hour storage resources.55 Stacked storage resources have the benefit of increased dispatch flexibility and can be run at reduced capacity to provide a 4-hour solution in times of greater duration of need. The second phase includes 782 MW of peaking capacity that could be retired and replaced with storage by 2023, coinciding with the implementation of NOx regulations. These units have an average age of over 43 years, and in 2018 had an average capacity factor of less than 3%. The units that are part of the E.F Barrett Jet and Holtsville plants have both been online since the early to mid-1970s, and the Holtsville and Glenwood units continue to use fuel oil as a secondary fuel option. Table 10. Peoker Retirement Phase 2 Installed Capacity Retirement Reason E.F. Barrett Jet 03 E.F. Barrett Jet 18 Dispatch Duration E.F. Barrett Jet 05 E.F. Barrett Jet 18 Dispatch Duration E.F. Barrett Jet 06 E.F. Barrett Jet 18 Dispatch Duration E.F. Barrett Jet 09 E.F. Barrett Jet 41.8 Dispatch Duration E.F. Barrett Jet 10 E.F. Barrett Jet 41.8 Dispatch Duration E.F. Barrett Jet GT02 E.F. Barrett Jet 18 Dispatch Duration Edgewood GT1 Edgewood 50 Contract Expiration Edgewood GT2 Edgewood 50 Contract Expiration Glenwood GT01 Glenwood Landing 16 NOx Regulations Holtsville 01 Holtsville 56.7 Dispatch Duration ss "Stacked"storage resources have similar overall energy storage capabilities and similar storage battery pack sizes, but are constructed as separate,shorter duration storage resources. Long Island Fossil Peaker Replacement Study 40 ©2020 by Strategen Holtsville 02 Holtsville 56.7 Dispatch Duration Holtsville 04 Holtsville 56.7 Dispatch Duration Holtsville 05 Holtsville 56.7 Dispatch Duration Holtsville 06 Holtsville 56.7 Dispatch Duration Holtsville 07 Holtsville 56.7 Dispatch Duration Holtsville 08 Holtsville 56.7 Dispatch Duration Holtsville 09 Holtsville 56.7 Dispatch Duration Holtsville 10 Holtsville 56.7 Dispatch Duration Total 782 These grid services provided by these peaking plants can be effectively replaced by stacked storage resources of 4-hour duration.As with the stacked storage described above, stacked 4-hour storage can be dispatched on a portfolio basis to meet long-duration dispatch needs, or can be dispatched more flexibly and more economically during more typical grid conditions. Stacked 4-hour storage has been shown to be effective to meet longer dispatch needs, as seen in analysis performed by the California ISO on local capacity needs for the Moorpark Sub-Area." The third phase includesjust over 1,119 MW of peaking capacity that could be brought offline by 2030 in conjunction with the rooftop solar and offshore wind targets established by New York State, and balanced by incremental storage resources. This 1,119 MW represents some of the newest and most frequently used units considered in this analysis — but these units are still, on average, over 33 years old, and used at less than 10% of their full capability. The Northport plant was built in 1967; it is now 53 years old and will be 63 by 2030. Nine of these units, representing nearly 400 MW,typically dispatch for 12 hours or less over a year, and 14 units representing nearly 750 MW typically dispatch for 20 hours or less. By 2030, all existing PSA contracts with LIPA will have expired, making all plants contractually eligible for retirement. Table 11. Pecker Retirement Phase 3 Retirement - • Bethpage 3 Bethpage 96 Contract Expiration; Dispatch Duration Bethpage CT GT4 Bethpage CT 60 Dispatch Duration Brentwood Brentwood 47 Dispatch Duration E.F. Barrett Jet 04 E.F. Barrett Jet 18 Contract Expiration; Dispatch Duration s6 California ISO, 2017,MoorporkSub-Area Local CopocityAltemotive Study. https://www.caiso.com/Documents/Augl6_2017_MoorparkSub-AreaLocalCapacityRequirementStudy- Pu entePowerProj ect_15-AFC-01.pdf Long Island Fossil Peaker Replacement Study 41 ©2020 by Strategen E.F. Barrett Jet 08 E.F. Barrett Jet 18 Contract Expiration; Dispatch Duration E.F. Barrett Jet 11 E.F. Barrett Jet 41.8 Contract Expiration; Dispatch Duration E.F. Barrett Jet 12 E.F. Barrett Jet 41.8 Contract Expiration; Dispatch Duration Freeport CT2 Freeport 1 & 2 60.5 Dispatch Duration Glenwood GT03 Glenwood CT 55 Contract Expiration; Dispatch Duration Glenwood GT04 Glenwood Landing 53 Contract Expiration; Dispatch Duration Glenwood GT05 Glenwood Landing 53 Contract Expiration; Dispatch Duration Northport 1 Northport 387 Contract Expiration Pinelawn Power 1 Pinelawn Power 82 Contract Expiration; Dispatch Duration Port Jefferson Peaking Port Jefferson 53 Contract Expiration; Dispatch GT2 Peaking Duration Port Jefferson Peaking Port Jefferson 53 Contract Expiration; Dispatch GT3 Peaking Duration Total 1,119 Although these resources have historically dispatched at longer durations, by 2030, the addition of offshore wind, rooftop solar, and energy efficiency will displace fossil generation, reduce the overall dispatch duration needed from storage, and will increase charging opportunity for storage. For example,the below chart shows incremental resources that will be available from the addition of new energy efficiency, offshore wind, and rooftop solar on an average day in August. These resources will, on average, add as much as 1000 MW of additional capacity during evening hours of highest demand. Over the course of 2030, they will inject an expected 12,500 GWh of incremental energy availability into the system. 1,400 1,200 1,000 - - 800 - a 600 c Lu 400 200 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Hour of Day 62030 Energy Efficiency a2030 Offshore Wind(MW) N2030 Rooftop Solar-high Figure 27. Average August Energy Available from Energy Efficiency, Offshore Wind& Rooftop Solar in 2030 Long Island Fossil Peaker Replacement Study 42 ©2020 by Strategen These resources have the potential to significantly reduce the dispatch duration of any peaking or flexibility resources. In this context, the role of storage or other peaking fossil assets will be to provide integration during times of low renewable energy. For example, the below chart shows three days in August with low offshore wind production — potentially the three days of the year with highest demand for peaking energy supplied from dispatchable resources. In this instance, the role of storage or any other integrating resources would be to balance the excess generation in the early hours of the morning with peak demand later in the afternoon. Clean Resource vs Fossil Fuel Dispatch 1,400 1,200 1,000 800 600 400 200 1 3 .5 7 ;9. 11 13 15 17 19 2123 1 3 5 7 ,9 11 13 15 17 19 2123 1 3 5 7 9 11 13 15 17 19 2123 7-Aug 8-Aug 9-Aug Energy Efficiency Offshore Wind Rooftop Solar Historic Fossil Dispatch Figure 28. Energy Storage Balances Excess Generation and Peak Demand By 2025,this analysis has proposed the addition of 1,116 MW of storage to meet the regional energy needs of Long Island. Based on analysis of the hourly net load profile for 2030,these potential resource additions could be able to meet a significant portion of the overall flexible resource needs described above. Given the addition of new customer and grid scale resources, much shorter duration storage could be used to replace the capacity of these peakers, despite their longer historic run-times. By 2030, a cumulative storage portfolio of around 350 MW could help to enable the retirement of the full 2,300 MW considered in this analysis. Of course,the full need for grid resources such as storage in 2030 will be heavily dependent on the adoption of customer resources, such as energy efficiency and rooftop solar. Building and transport electrification, which will be cornerstones of New York's clean economy, will also drive overall grid needs. 3. Peaker Retirement & Replacement Economic Analysis This section assesses the potential economic benefits that could accrue to LIPA customers through the retirement and replacement of fossil assets with new storage resources. Although this analysis focuses specifically on the direct economic benefits that LIPA and its customers could realize through established energy markets and value streams,the indirect benefits of storage could go far beyond this, and the final portion of this section provides some additional context on those potential benefits. Long Island Fossil Peaker Replacement Study 43 13 ©2020 by Strategen 3.1 Methodology and Assumptions At the highest level, this methodology evaluates the potential costs net of any revenue streams from NYISO markets that both fossil pecker resources and storage resources would yield for LIPA customers. 3.1.1 Net Cost Comparison By using a net cost approach, this study evaluates the cost-effectiveness of fossil peakers against an equivalent amount of storage capacity. More specifically, the analysis compares the full resource costs and revenue streams for an equivalent NYISO capacity value for each resource.57 Costs included, as applicable, contract costs (for existing peakers), overnight capital costs (for new storage), operations and maintenance, augmentation and warranty for storage, the costs of fuel or charging; while revenues included the market value of energy and ancillary services. 3.1.2 Peaker Costs and Benefits For the purposes of this analysis, it was assumed that the capacity cost of the PSA between LIPA and National Grid is indicative of the bilateral contract market on Long Island. Bilateral contracts account for 87% of the cleared capacity in Long Island and the National Grid PSA accounts for 72% of those contracts, and thus comprises the bulk of Long Island's capacity resources.58 The cost of the PSA going forward was projected based on historical increases in the cost of the contract and on NYISO's projected cost of fuel, based on the natural gas blend for Zone K and adjusted for the use of fuel oil in some.plants.59 The revenues of the peckers are calculated through an energy and ancillary model that assumes a pecker will generally follow the day ahead market on an hourly basis. In short, it runs for all the hours that it is economic to do so based on locational based marginal prices (LBMP) and its cost to dispatch, with some exceptions described later. The revenues from the ancillary services are adjusted to reflect a limited share of the operating reserves market (primarily non-spin) that can be served by the peaker fleet. The costs and revenues of the peaker fleet are then adjusted to reflect actual market performance as reported by the NYISO market monitor, Potomac Economics. According to the NYISO market monitor's most recent State of the Market report, over half of all gas turbine unit commitments on Long Island were not clearly economic, meaning that many peaker plants are running out of merit order, unnecessarily increasing emissions and customer cost60. For the purposes of this analysis, 25% of peaker plant dispatch was assumed to be uneconomic, whereby the unit's energy market revenues were less than its operating costs as determined by the plant's heat rate and cost of fuel.61 The NYISO 2019 market monitor report also indicates that peaker plant dispatch has historically been limited by outages, with an equivalent forced outage rate (EFORd)for older peaker units (which comprise the bulk of the Long Island fleet) of about 13%.62 This means 57 Capacity value based on estimation of NYISO unforced capacity(UCAP) 58 Estimated based on NYISO's monthly reports on Installed Capacity Market(ICAP)for Long Island. https://www.nyiso.com/installed-capacity-market 59 NYISO, 2019. 2019 CARIS Fuel Price Forecast with Proposed Methodology Revision for Natural Gas 60 Potomac Economics,op. cit., p.103. 61 For the old peakers in the fleet,the assumed heat rate is close to 15,000 btu/kWh, based on estimates from the market monitor in 2019.Ibid. p.A-206 61 Ibid. p.A-188. Long Island Fossil Peaker Replacement Study 44 ©2020 by Strategen that on average, the unforced capacity contribution of these peckers is around 87% of installed capacity, and that a perfectly available resource will only need to replace 87% of the fleet's capacity. So, for the purposes of this analysis, fossil fuel capacity contribution was derated to capture the usable capacity of the peaker fleet more accurately when comparing it to an equivalent storage resource. 3.1.3 Energy Storage Costs and Benefits Energy storage costs are based on projections from Lazard's 2019 Levelized Cost of Storage report,63 are levelized for a 20-year lifetime using a 9% weighted average cost of capital (WACC) and include the cost of augmentation to maintain the storage capabilities of the batteries, as well as other O&M and warranty costs. The analysis uses lithium-ion batteries as a reference for storage costs. The analysis further assumes than LIPA would procure the most cost competitive storage solutions available, supporting the use of the lower end of Lazard's cost projections. Finally, storage capital costs projections reflect a 10% cost adder, reflecting the higher costs to develop resources in Long Island, and consistent with recommendations from NREL.64 The net cost of storage was calculated for several battery configurations based on their arbitrage and ancillary services potential using hourly NYISO LBMP prices from 2019. The model assumes that storage is able to complete daily cycles at its specific duration and 85% round-trip efficiency, charging during the contiguous blocks of lowest energy cost and discharging during the highest ones. The study considers the currently limited size of the ancillary services market in Zone K which will be further limited as new storage capacity begins to deliver regulation services. Conservatively, the study assumes that the market, at its present size, will be split among the current and new resources. However, it should be noted that the market for ancillary services may grow as new intermittent renewables are added to the grid in higher amounts. Another consideration is the capacity value of storage. The study assumes a capacity value of 45%for 2-hour duration storage, 90%for 4-hour and 100%for 6-hour and larger durations, consistent with NYISO capacity market rules going into effect May 2021.65 This means that each MW of six-hour or eight-hour duration batteries is generally able to provide capacity equivalent to each MW of unforced capacity (UCAP) from fossil peckers on a one-to-one basis. Meanwhile, each MW of pecker capacity requires about 2.2 MW of 2-hour storage or 1.1 MW of 4-hour storage for an equivalent replacement. 3.1.4 LIPA Total Annual Portfolio Savings Potential Annual savings to LIPA customers from the proposed pecker replacement pathway was estimated by computing the difference between the levelized net cost of new storage additions and the annual net cost of the peaker capacity under the LIPA PSA.These savings were then scaled up to represent the full Long Island peaker fleet capacity, under the assumption that the PSA is generally indicative of the contracted cost of pecker capacity. These avoided costs do not reflect any "ramp-down" costs that may arise as the result of early terminations as described earlier, which were assumed to be de minimis. 63 Lazard,2019. Levelized Cost of Storage V5. https://www.lazard.com/perspective/Icoe2Ol9 64 NREL, 2019. Cost Projections for Utility-Scale Battery Storage&2020 Update. https-Hwww.nrel.gov/docs/fyl9osti/73222.pdf 6s NYISO,2019. Expanding Capacity Eligibility, https-Hwww.nyiso.com/documents/20142/5375692/Expanding%2OCapacity%20EIigibility%20030719.pdf/19c 4ea 0d-4827-2e7e-3c32-cf7e36e6e34a Long Island Fossil Peaker Replacement Study 45 0 2020 by Strategen 3.2 Cost Effectiveness Relative to Existing Peakers Based on the peaker groupings described above in Section 2.5, Strategen analyzed a peaker replacement pathway that would phase 1,116 MW of Long Island peakers by 2023 and another 1,206 MW (around 2,300 total) by the end of the decade. Strategen's recommended portfolio of new standalone energy storage as a replacement for this peaker capacity results in substantial potential savings to LIPA customers.We estimate total savings of$393 million (net present value) by the end of the decade, representing about $350 per household across LIPA's 1.1 million customers. These savings are the result of avoiding the relatively high cost of contracted peaker capacity, which is expected to increase over time (based on historical trends, increasing operating costs such as fuel, and environmental retrofits for NOx emissions) relative to the ever more competitive cost of battery storage,which is only expected to decrease over time and as subsequent tranches of peaker capacity is replaced. It is also worth noting that that for the last phase of energy storage replacements, a smaller share of storage is needed relative to the amount of peaker retirements (approximately 30% of the proposed peaker retirements). This is due to the fact that significant expected additions of renewable energy and energy efficiency over the next decade will partially offset the need for peaking capacity on Long Island. 300 250 200 M" 150 100 9 50 0 • 2020 2021 2022 2023 2024 2025 2025 2.027 2028 2429 2030 -50 -100 -150 G1-PSA Avoided Cost G1-Other Cap Avoided Cost G1-Net Cost of Storage G2-PSA Avoided Cost G2-Other Cap Avoided Cost - – G2-Net Cost of Storage � EE-PSA Avoided Cost EE-Other Cap Avoided Cost e—EE-Net Cost of Storage �G3-PSA Avoided Cost M✓G3-Other Cap Avoided Cost �G3-Net Cost of Storage Annual Savings Figure 29. Annual Savings from Pecker Replocement" 66 G1,G2, and G3 refer to the different groupings of peaker units described in Section 2 (and corresponding storage replacements),while EE refers to the East End location-constrained capacity. Long Island Fossil Peaker Replacement Study 46 0 2020 by Strategen Retiring and replacing aging peaker units has the potential to create $10.5 million of savings per year in 2021, growing to $150 million per year in 2030. The growth in projected savings over the next decade are driven by both the growing differential in peaker and storage costs, as well as the increased scale of savings due to replacing a larger portion of the portfolio (i.e. growing from 324 MW in 2021 to 2,325 MW by 2030). The following graphics demonstrate the underlying estimates of net cost construct for contracted peaker capacity and new energy storage throughout the next decade. 25 PSA Net Cost 2020 PSA Net Cost 2025 PSA Net Cost 2030 5.52 20 4.75 L � 0 15 3.42 14.49 0.(39 -4.76 -0.09 12.81 0.09 12.80 11.32 0.09} -4.76 -0.09 9.98 0 10 -4.76 -009 U 5 0 _ N N in rn ,��, N N in in .�+ +�� a) N N oU o U U o o � c U U o oC U U Uj0) j j 73 � � Z of of Z z C O LL ), LO C o LL T (n C a LL T (\ OO O N C C C U w U w U w O O O z z z Figure 30. PSA Net Cost 2020 to 2030 Long Island Fossil Peaker Replacement Study 47 �' ©2020 by Strategen BES-2hr($/kW-month) BES-4hr($/kW-month) BES-6hr($/kW-month) BES-8hr($/kW-month) @45%Capacity Value @90%Capacity Value 529 25 i 203.51 3.72 i _15.96 c 2.87 14.44 -7.27:0..21 E 15 2.64 2.71 3: 2241 11.14 5,74,03111.46 sn 2.07, 0 10 8.12, 8.02.. -4.73 7.67 . 7.82 V 1.19 4.48 0.49 5 0 - V O OC C U U O O C C U U O O C C V V O O C C U :2 of-FOv Q � :2 0) (1) aa) o ami � �° 2i m w Q) 'Q � C Z 'Q .6 C d' Z '� C d' Z 'a C 0' - Z U (2 U 12) O 21 > o 2) QJ -CQ U Q U Q U � Q v � v t a) a) U c U C U c U C LU w w w Figure 31. Energy Storage Net Cost in 2020 25 BES-2hr($/kW-month) BES-4hr($/kW-month) BES-6hr($/kW-month) BES-8hr($/kW-month) -d45%Capacity Value @90%Capacity Value 20 5.29 C: 15 E 3.51 Y 2,40 0 10 2-64 2.71 1.85 9'08' 7.27-0,21 28 U 00. 144 1.33 7. ' 6.30 -5.740-31 5 -4-73.1.193,64 .4.480- 4.11 1.19 4 4 2 W �r) v 4L a v v in In 4 a a V y 4 v a V O 0 0 w C O O 0 0 C O O 0 0 O O 0 0 O -a �O c Z a �6 c_ Of C� Z a c Z a c Q!! 0� Z U O of >1 U U of >1 LU U 21 >1 U) U 0 ED Lf) M 0)V w U w U c U c LU LU Figure 32. Energy Storage Net Cost in 2030 Long Island Fossil Peaker Replacement Study 48 ©2020 by Strategen 3.3 Energy Storage Benefits Not Included in Cost-Benefit Analysis 3.3.1 Grid Benefits of Storage The addition of storage capacity to the New York grid provides additional benefits which are not quantified in this net cost of storage analysis, which focuses on direct monetizable value streams that can be captured for LIPA customer benefit. As New York procures increasing amounts of renewable energy to reach CLCPA targets, the state will require energy storage to integrate these clean resources to their full advantage. New York's North Country, for example, is already experiencing consistent curtailment of wind resources when supply outpaces demand.67 The region's transmission system is constrained which is limiting the grid's ability to transmit renewable energy. Historically, addressing grid issues such as load growth, rising peak demand, network congestion, and system reliability has been accomplished by building out additional transmission and distribution (T&D) infrastructure which is expensive and time-consuming, but instead, energy storage can play an important role in the balancing act of matching supply and demand and help to create a more flexible and reliable grid system thus deferring the need for costly T&D upgrades while significantly reducing renewable energy curtailment.68 Additionally, battery storage resources can provide voltage control, a valuable ancillary service which would benefit grid reliability. Storage also adds diversityto the electric system, so the grid is less exposure to single points of failure, such as reliance on a single fuel source. 3.3.2 Health and Environmental Benefits from Reduced Emissions Further, the economics in this report do not account for environmental or social benefits such health benefits, greenhouse gas emission reductions from reduced pecker usage, or improved conditions in Potential Environmental Justice Areas. The counties that compose Long Island — Kings, Queens, Nassau, and Suffolk — currently and historically have nonattainment status regarding 8-hour ozone levels set by the National Ambient Air Quality Standard (NAAQS).69 Further, according to the New York State Department of Health and Mental Hygiene, exposure to ozone above background levels causes New Yorkers to suffer annually from about 400 premature deaths, more than 800 asthma related hospital visits, and over 4,500 asthma related emergency room visits.70 Additionally, it has been estimated that a reduction in ozone levels byjust 10% could prevent more than 80 premature deaths, 180 hospital admissions and 950 emergency department visits annually.71 Beyond health impacts, emissions from peaker plants are also harmful for New York's economy. Peaker emissions cost the state an estimated $163 million annually based on 67 NYISO, Unbottling Wind:How We Can Expand Clean Energy. https://www.nyiso.com/view-blog/- /asset_publisher/5397gTlac7HE/content/u nbottling-wind-how-we-ca n-expand-clean-energy 68 California Energy Storage Alliance, Why Storage. https://www.storagealliance.org/about/why-storage 69 EPA,New York Nonattainmen07Mointenance Status for Each County by Year for All Criteria Pollutants https://www3.epa.gov/airquality/greenbook/anayo—ny.html 70 New York City Department of Health and Mental Hygiene, op. cit. p.4. 71 Ibid., p.4. Long Island Fossil Peaker Replacement Study 49 0 2020 by Strategen average annual peaker emissions between 2016-2018, the morbidity and mortality of NOx and SOx as precursors to PM 2.5,72 and the social cost of carbon.73 Table 12. Annual Economic Impact of Pecker Emissions Criteria Economic LIPA Peaker Emissions, 2018 Annual Economic ImpactPollutant Value (to n s) CO2 42 2,650,000 111 NO, 12,000 1,910 2.3 SOx 78,000 639 50 Total 163.3 4. Recommended Replacement Pathway Collectively, the peaker retirements proposed in this report represent a reduction of just over 2,300 MW of fossil fuel capacity on Long Island, and an addition of over 1,540 MW of new energy storage resources. If this pathway is followed, LIPA has the opportunity to halve the fossil fuel power plants operating in Long Island over the course of the next decade. As shown below, these reductions would put LIPA on a "glide path" towards meeting the CLCPA mandate of carbon neutral electricity generation by 2040, and also represents a significant step forward for Long Island's clean energy future. The deployment of storage (and other clean energy resources), can be appropriately staged to ensure that 1) all reliability needs can be identified and addressed in a timely manner, 2) near-term deployments are able to address "low hanging fruit" opportunities to deliver immediate cost savings to LIPA customers, while scaling the market for energy storage, 3) medium and long-term deployments benefit from market maturity and declines in energy storage technology costs. By using a staged approach, we recommend that different targets be applied for replacing LIPA's peaker portfolio over the Near Term, Medium Term, and Long Term. 72 EPA, Estimating the Benefit per Ton of Reducing PM2.5 Precursors from 17 Sectors. https://www.epa.gov/ben map/esti mati ng-benefit-ton-red uci ng-pm25-precu rsors-17-sectors 73 EPA, The Social Cost ofCorbon. https://19january20l7snapshot.epa.gov/climatechange/social-cost- carbon_html Long Island Fossil Peaker Replacement Study 50 ©2020 by strategen 5,000 Near-Term Retirements: 1,116 MW 4,500 4,000 Mid-Term Retirements: 1,209 MW 3,500 - - - • -• U 3,000 CLCPA Zero 1,116 MW of Energy SLorage v Carbon Target 2,500 2030 FZeUramant!5.Enabled Pr. `O 2,000 MW of Offshore Wind 0- '�� Remaining Retirements: N 1,500 2,3002,032 MW 0 325 MW of Rooftop Solar LL 1,000350+MW of Energy Storage 500 Cumulative Storage Additions: 334 334 1,116 1,116 1,206 1,206 1,206 1,206 1,206 1,556 t 0 _ _ _ LO LO 00 M0 N M T LO CO r 00 6) O N M � Ln CO n 00 O O N N N N N N N N N N N M M M M M M M M M M 'IT0 � O O N N 0 0 CN 0 0 0 0 0 0 0 0 0 0 (N 0 0 0 0 0 0 0 0 0 � O Figure 33. Pecker Retirement Pathway 4.1 Near Term (2020 — 2023) There is a significant amount of peaking generation capacity (about 334 MW) that is "low hanging fruit" and could be feasibly and cost effectively replaced immediately. In addition to that initial set, over the next 3 years, LIPA could retire just over 1,100 MW of fossil fuel capacity and replace it with a portfolio of storage with similar capacity. While much of this near-term portfolio would consist of relatively short duration (i.e. <4 hours) storage resources, some portion may need to meet longer dispatch needs in the 6- to 8-hour duration range. On average,we estimate that the near-term storage portfolio duration would be around 5.5 hours, or about 4,700 MWh of storage capability. 4.2 Medium Term (2024-2030) In the second half of the decade, LIPA has an opportunity to retire additional 1,200 MW of fossil fuel resources. As replacement resources are considered, energy storage is poised to play a key role. Retirement of fossil peakers could be enabled by the addition of offshore wind, distributed solar, and energy efficiency, and the addition of energy storage for a cumulative total of 1,556 MW or more. Moreover, this storage will play a critical role in supporting the integration of these new, clean resources through the provision of time shifting capabilities, operating reserves, and improving the deliverability of large-scale off- shore wind. 4.3 Long Term (2031-2040) In the decade beginning in 2031, LIPA will need to retire just over 2 GW of existing fossil fuel capacity to be compliant with the electric sector zero carbon targets of the CLCPA. These remaining 2 GW represent the peckers understood to be the most "challenging" from the standpoint of having typically longer start durations. However, they will still need to be Long Island Fossil Peaker Replacement Study 51 _$ ©2020 by Strategen addressed as part of the transition towards CLCPA goals. To enable this transition, LIPA will need to continue on a trajectory of developing clean, integrating resources to balance renewable generation and meet net peak demand. While some of these resources could theoretically be retired sooner, we believe the plan laid out in this report presents a reasonable "glide path"for meeting the CLCPA goals, while still giving sufficient time to plan and procure the appropriate portfolio of replacement resources, including energy storage. Meanwhile, LIPA will be able to gain critical experience operating storage resources as a means to better understand their performance and contribution to system reliability. Long Island Fossil Peaker Replacement Study 52 0 2020 by Strategen Appendix A Table 13. Detail of Pecker Selection by Generating Unit Nameplate Unit Capacity Age 2019 Replacement Duration Unit Ultimate • Fuel Net Peaker Rule @90% Parent - ars) Phase E.F.00rreUJet National Island Park 18 GT 2.47% Yes 50 NG/ GT01 Grid FO2 3.9 (T020-2023) Non-Compliant N/A Freeport GS J Power Freeport 60 GT 7.59% 16 NG/ 39.9 Phase 1 Compliant 8 CT1 FO2 (2020-2023) Glenwood CT National Phase 1 GT02 Grid Glenwood 55 GT 0.06% Yes 48 FO2 0.3 (2020-2023) Non-Compliant 8.4 Holtsville 03 National Holtsville 56.7 JE 0.34% Yes 46 FO2 1.7 Phase 1 Non-Compliant 3.9 Grid (2020-2023) Jamaica Bay Hullo GT2 Street Jamaica Bay 60.5 JE 1.60/ 17 FO2 8'5 (2020-2023) Compliant 11 Energy Northport CT National Phase 1 Non-Compliant GT Grid Northport 16 GT 0.00% Yes 53 FO2 0.0 (2020-2023) (Black-start) 3"9 Port Jefferson National Port Jefferson 16 GT 0.07% Yes 54 FO2 0.1 Phase 1 Non-Compliant 3.6 Peaking GT1 Grid (2020-2023) (Black-start) West Babylon National West Babylon 52.4 GT 0.65% Yes 49 FO2 3.0 Phase 1 Non-Compliant 8.4 4 Grid (2020-2023) (Retiring) E.F.Barrett Jet National NG/ Phase 2 03 Grid Island Park 18 GT 1.78% Yes 50 FO2 2'8 (2020-2023) Non-Compliant 8 E-F.Barrett Jet National Island Park 18 GT 1.65% Yes 50 NG/ 2.6 Phase 2 Non-Compliant 8 05 Grid FO2 (2020-2023) E.F.Barrett Jet National Island Park 18 GT 1.59% Yes 50 NG/ 2.5 Phase 2 Non-Compliant 6 06 Grid FO2 (2020-2023) E.F.Barrett Jet National Island Park 41.8 JE 3.55% Yes 49 NG/ 13.0 Phase 2 Non-Compliant 8 09 Grid FO2 (2020-2023) E.F.Barrett Jet National Island Park 41.8 JE 3.09% Yes 49 NG/ 11.3 Phase 2 Non-Compliant 7 10 Grid FO2 (2020-2023) E.F.Barrett Jet National Island Park 18 GT 1.59% Yes 50 NG/ 2.5 Phase 2 Non-Compliant 7 GT02 Grid FO2 (2020-2023) Edgewood J Power Brentwood 50 GT 7.35% 18 NG 32.2 Phase 2 Compliant 14 GT1 (2020-2023) Edgewood J Power Brentwood 50 GT 6.48% 18 NG 28,4 Phase 2 Compliant 12 GT2 (2020-2023) Glenwood National Glenwood 16 GT 0.07% Yes 53 FO2 0.1 Phase Non-Compliant 39 Landing GT01 Grid (2020-2023) (Retiring) Holtsville 01 National Holtsville 56.7 JE 0.26% Yes 46 FO2 1.3 Phase 2 Non-Compliant 5 Grid (2020-2023) Holtsville 02 National Holtsville 56.7 JE 0.12% Yes 46 FO2 0.6 Phase 2 Non-Compliant 4,6 Grid (2020-2023) Holtsville 04 National Holtsville 56.7 JE 0.40% Yes 46 FO2 2.0 Phase 2 Non-Compliant 5.2 Grid (2020-2023) Holtsville 05 National Holtsville 56.7 JE 0.26% Yes 46 FO2 1.3 Phase 2 Non-Compliant 5 Grid (2020-2023) Holtsville 06 National Holtsville 56.7 JE 0.44% Yes 45 FO2 2.2 Phase 2 Non-Compliant 8 Grid (2020-2023) Holtsville 07 National Holtsville 56.7 JE 0.58% Yes 45 FO2 2.9 Phase 2 Non-Compliant 8 Grid (2020-2023) Holtsville 08 National Holtsville 56.7 JE 0.70% Yes 45 FO2 3.5 Phase 2 Non-Compliant 6 Grid (2020-2023) Holtsville 09 National Holtsville 56.7 JE 0.42% Yes 45 FO2 2.1 Phase 2 Non-Compliant 6.6 Grid (2020-2023) Holtsville 10 National Holtsville 56.7 JE 0.40% Yes 45 FO2 2.0 Phase 2 Non-Compliant 7 Grid (2020-2023) Calpine Phase 3 Bethpage 3 Corp(Volt Hicksville 96 CC 13.21% 15 NG 111.1 (2024-2030) N/A 20.2 Parent) Bethpage CT CalpCorpne(Volt Hicksville 60 GT 8.62% 18 NG 45.3 Phase 3 N/A 16 GT4 Parent) (2024-2030) New York Phase 3 Brentwood Power Brentwood 47 GT 13.04% 19 NG 53.7 (2024-2030) Compliant 13 Authority E.F.Barrett Jet National NG/ Phase 3 04 Grid Bland Park 18 GT 2.98% Yes 50 FO2 4J (2024-2030) Non-Compliant 9 E,F.Barrett Jet National NG/ Phase 3 08 Grid Island Park 18 GT 1.20% Yes 50 FO2 1'9 (2024-2030) Non-Compliant 9.5 E.F.Barrett Jet National Island Park 41.8 JE 6.53% Yes 49 NG/ 23 9 Phase 3 Non-Compliant 9 11 Grid FO2 (2024-2030) E.F.Barrett Jet National Island Park 41.8 JE 4.78% Yes 49 NG/ 17.5 Phase 3 Non-Compliant 9 12 Grid FO2 (2024-2030) 14 Long Island Fossil Peaker Replacement Study 53 0 2020 by Strategen Freeport CT2 Village of Freeport 60.5 GT 249% 16 NG/ 13.2 Phase 3 Compliant 12 Freeport KER (2024-2030) Glenwood CT National Glenwood 55 GT 0.04% Yes 48 F02 0.2 Phase 3 Non-Compliant 10 GT03 Grid (2024-2030) Glenwood National Glenwood 53 GT 8.42% 18 NG/ 391 Phase 3 Compliant 13 Landing GT04 Grid F02 (2024-2030) Glenwood National Glenwood 53 GT 8.81% 18 NG/ 409 Phase Compliant 12 Landing GT05 Grid F02 (2024-2030) Northport 1 National Northport 387 ST 9.86% Yes 53 NG/ 334.2 Phase 3 N/A 171.8 Grid F06 (2024-2030) Pinelawn J Power Babylon 82 CC 9.58% 15 NG/ 68.8 Phase 3 N/A 17 Power 1 KER (2024-2030) Port Jefferson National Port Jefferson 53 GT 4.85% 18 NG/ 225 Phase Compliant 10 Peaking GT2 Grid F02 (2024-2030) Port Jefferson National Port Jefferson 53 GT 4.63% 18 NG/ 215 Phase Compliant 10 Peaking GT3 Grid F02 (2024-2030) East National East 2 IC 4.00% Yes 58 F02 0.7 East End Non-Compliant N/A Hampthon 2 Grid Hampthon East National East 2 IC 5.14% Yes 58 F02 0.9 East End Non-Compliant N/A Hampthon 3 Grid Hampthon East National East 2 IC 5.14% Yes 58 F02 0.9 East End Non-Compliant N/A Hampthon 4 Grid Hampthon East National East Hampthon Grid Hampthon 21.3 JE 6.43% Yes 50 F02 12,0 East End Non-Compliant 16 GT1 Greenport Hawkeye Hawkeye GT1 Energy Greenport 54 JE 6.45% 17 F02 30.5 East End Compliant 14 Greenport Shoreham 1 National Shoreham 52.9 GT 0.15% Yes 49 F02 0.7 East End Non-Compliant 5.4 Grid Shoreham 2 National Shoreham 186 JE 0.18% Yes 36 F02 0.3 East End Non-Compliant 4.5 Grid Shoreham J Power Shoreham 50 GT 0.55% 18 F02 2.4 East End Compliant 9 Peaking GT3 Peak Shoreham T4 J Power Shoreham 50 GT 0.53°% 18 F02 2.3 East End Compliant 6 Southampthon National Southampthon 11.5 GT 2.08% Yes 57 F02 2.1 East End N/A N/A 1 Grid Southold 1 National Southold 14 GT 1.39% Yes 56 F02 1,7 East End N/A N/A Grid Wading River 1 National Shoreham 79.5 GT 0.55% Yes 31 F02 3.8 East End Non-Compliant 11 Grid Wading River National Shoreham 79.5 GT 0.43% Yes 31 F02 3.0 East End Non-Compliant 7.2 2 Grid Wading River National Shoreham 79.5 GT 0.57% Yes 31 F02 4.0 East End Non-Compliant 11 3 Grid Northport 2 National Northport 387 ST 15.37% Yes 52 NG/ 521,1 Long N/A 405 Grid F06 Duration Northport3 National Northport 387 ST 16.00% Yes 48 NG/ 542.3 Long N/A 727.4 Grid F06 Duration Northport 4 National Northport 387 ST 18.63% Yes 43 NG/ 631.6 Long N/A 509 Grid F06 Duration Port Jefferson National Port Jefferson 188 ST 6.62% Yes 62 NG/ 109,1 Long N/A 257.2 3 Grid F06 Duration Port Jefferson National Port Jefferson 188 ST 10.01% Yes 60 NG/ 164.8 Long N/A 246.2 Duration Charles P Village of Rockville F02/ Back-up Keller 10 Rockville Centre 3.5 IC 0.00% 66 NG 0.0 Generator N/A N/A Centre Charles P Village of Rockville F02/ Back-up Keller 11 Rockville Centre 5.2 Ic 0.00% 58 NG 0.0 Generator N/A N/A Centre Charles P Village of Rockville F02/ Back-up Keller 12 Rockville Centre 5.5 9C 0.00% 53 NG 0'0 Generator N/A N/A Centre Charles P Village of Rockville F02/ Back-up Keller 13 Rockville Centre 5.5 1C 0.00% 46 NG 0`0 Generator N/A N/A Centre Charles P Village of Rockville F02/ Back-up Keller 14 Rockville Centre 6.2 Ic 1.47% 26 NG 0'8 Generator N/A N/A Centre Charles P Village of Rockville Back-up N/A Keller 7 Rockville Centre 2 IC 0.00% 78 F02 0.0 Generator N/A Centre Charles P Village of Rockville Back-up N/A Centre 3.5 IC 0.00% 66 F02 0.0 Generator N/A Keller 9 Rockville Centre Back-up Compliant Freeport 1-2 Freeport Freeport Freeport 2,9 C 0.00% 71 F02 0.0 Generator N/A Village of Back-up Compliant Freeport 1-3 Freeport Freeport 3.1 [C 0.00% 66 F02 0.0 Generator N/A Villae Back-up Compliant Freeport 1-4 Freeportf Freeport 5.1 IC 0.00% 56 F02 0.0 Generator N/A Long Island Fossil Peaker Replacement Study 54 0 2020 by Strategen Freeport 2-3 Village of Freeport 18.1 GT 0.13% 47 KER 02 Back-up Compliant N/A Freeport Generator Greenport IC4 Village of Greenport 1.2 IC 0.00% 63 FO2 0.0 Back-up N/A N/A Greenport Generator Greenport IC5 Village of Greenport 1.8 IC 0.00% 55 FO2 0.0 Back-up N/A N/A Greenport Generator Greenport IC6 Village of Greenport 3.8 1C 0.00% 49 FO2 0.0 Back-up N/A N/A Greenport Generator Long Island Fossil Peaker Replacement Study 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ROBERT JOEL RICHARDSON 122 La Rue Drive Huntington,NY 11743 (512) 567-6267 r oelr@gmail.com Education B.S. in Civil Engineering, University of Texas at Austin May 2003 Professional Certification Professional Engineer, State of New York, License No. 099970 August 2018 Professional Engineer, State of Texas, License No. 104776 December 2009 Professional Experience H2M architects + en 'veers Melville New York Senior Associate, Department Manager - Civil Engineering August 2014 - present • Manager of Civil Engineering Department concentrating on Land Development projects and associated entitlement procurements, growing and leading a team of Professional Engineers and EITs working on a variety of projects across Long Island,NY. • Project manager and civil engineer for site development projects throughout Long Island, responsible for site civil design of roadways, site grading and stormwater management systems, sanitary collection and disposal systems, erosion/sedimentation control, traffic control plans, and construction administration. • Responsible for project entitlements from conceptual design and zoning grants through permitting,construction and project close out. Vigil &Associates Austin Texas Project Manager/Design Engineer/Staff Engineer October 1997-July 2014 • Project manager and civil engineer for residential subdivision and commercial site development projects, responsible for civil design of stormwater management and water quality controls, roadways, water distribution and wastewater collection systems, lift stations and on-site sewerage facilities, site grading, erosion/sedimentation control and traffic control plans. • Prepared cost estimates, construction specifications and contract documents, oversaw construction contract bidding,negotiation,and administration. Additional Skills • AutoCAD (Civil3D, Land Development Desktop, Civil), HEC-RAS, SewerGEMS, TR-20, StormCAD,HY-8,Microsoft Office Suite. • Extensive surveying experience using levels, Sokia Total Station and GPS surveying equipment. ROBERT JOEL RICHARDSON Site Development Project Experience • Ronkonkoma Hub, Phase 1 &Phase 2, Ronkonkoma,NY: Project Civil Engineer and Manager for Phases 1 and 2 of the Ronkonkoma Hub, Transit Oriented Development (TOD) adjacent to the LIRR Ronkonkoma Station. The first two phases of this project include site design and engineering for 866 new residential units and over 95,000 sf of commercial space, the reconstruction of public roadways within the 53-acre TOD area, gravity sewer collection system to serve the overall TOD, and coordination with the MTA. Services include permitting through the Town of Brookhaven, SCDHS and SCDPW, and coordination with the various utility providers serving the development. Phase 1 construction was completed in 2019. Phase 2 construction is set to begin during the second quarter of 2021. • Engel Burman at Mount Sinai,Mount Sinai, NY: Project Civil Engineer and Manager for the development of a 24.31-acre site, including a new 120-unit assisted living residence and 225 new senior independent residential units. Responsible for site layout, design of internal roadways, grading and drainage, and sanitary sewer collection system. Construction was completed in 2020. • Brightview Port Jefferson Station,Brookhaven, NY: Project Civil Engineer and Manager for the 170-unit senior living residence. This project includes site design and engineering for an on-site sewage treatment plant (STP) and collection system, and construction of an entrance turn lane on the adjacent State highway. Permitting included Town of Brookhaven Change of Zone, Board of Zoning Appeals, Site Plan approval, Highway Work Permit and SWPPP, SCDHS approval for the site plan and STP, and NYSDOT permitting for the access driveway and turn lane. Construction began in the Fall of 2020. • Key Capture Energy, Four Sites Throughout Suffolk County,NY: Project Civil Engineer and Manager for due diligence investigations and site feasibility analyses of four prospective project sites for utility scale Battery Energy Storage System (BESS) developments throughout Suffolk County. Services have included preparation of Critical Issue Analysis reports, Phase 1 Environmental Site Assessments and Property Surveys to determine if potential development sites are suitable for the BESS projects. • Chuck E Cheese/Oak Terrace Office Condominiums,Austin, TX: A phased,multi-use site development including a 15,000 sf Chuck E Cheese restaurant,26,000 sf of professional office space and site for future development. The conceptual planning and design for this project required great care for the preservation of several Heritage Trees in coordination with the property developer (our client) and the primary commercial tenant, Chuck E Cheese. Construction was completed in July of 2013. Representative selection of additional Site Development Projects • Brightview Sayville: 154-unit senior living residence,Islip,NY • Bristal at Garden City: 150-bed assisted living residence, Garden City,NY • Stony Brook University Medical Center-East Campus Parking,Stony Brook, NY • Vista Office Plaza: 67,600 sf of medical office space,San Marcos,TX • Plaza East:29,000 sf of retail space,Kyle,TX G ROBERT JOEL RICHARDSON Residential Subdivision Project Experience Park at Willow Creek/Park Court: San Marcos,TX: A phased residential development that includes 41 townhouse lots, 26 single family residential lots and 4 commercial lots on a 27-acre site along Stagecoach Trail in San Marcos Texas. The second phase of this project utilized Low Impact Development (LID) design techniques and controls, and when completed this project will be the first development in the City of San Marcos to incorporate LID practices. Construction of the second phase of this project began in July of 2013. Representative selection of additional Residential Subdivision Projects • Rose Glen:21 lot infill subdivision on a 2.8-acre site,Austin,TX • Blarwood Forest:14 lot infill subdivision on a 2.0-acre site,Austin,TX • Highland Ranch: 87 lot residential subdivision on a 101-acre site,Caldwell County,TX BOARD MEMBERS " � Town Hall Annex Leslie Kanes Weisman,Chairperson m 53095 Route 25,Main Road Patricia Acampora P.O.Box 1179 Eric Dantes � Southold,NY 11971 Robert Lennert,Jr. Telephone(631)765-1809 Nicholas Planamento � h-ftp://southoldtownny.gov ZONING BOARD OF APPEALS TOWN OF SOUTHOLD C 2 7 2022 outhoRd T `° MEMORANDUM Planning Board To: Brian Cummings, Planner Heather Lanza, Planning Director Southold Town Planning Board From: Zoning Board of Appeals ' Leslie Kanes Weisman, Chairperso , Date: December 27, 2022 RE: KCE NY 26 LLC: Battery Energy Stora e Coordinated Review and Comments Requested Pursuant to Section 280-131C of the Southold Town Code and SEQR Lead Agency Request 10750 Oregon Road, Cutchogue, NY. SCTM No. 1000-83-3-6.1. Thank you for the opportunity make comments relating to the above referenced Action by the applicant seeking approval for a special exception, subdivision, area variances and site plan to construct and operate Battery Energy Storage upon lands located at 10750 Oregon Road, Cutchogue, more particularly known as SCTM No. 1000-83-3-6.1. We have no objection to the Town of Southold Planning Board assuming Lead Agency for the above action. Based upon our review of the project and testimony received during the December 1, 2022 Public Hearing of the ZBA, we offer the following comments and concerns: 1. Although located on lands zoned Light Industrial (LI), the subject property is surrounded by agricultural and residential properties. There is an uncertainty as to how aging lithium ion batteries will affect agricultural soils or may increase toxicity to potable water. 2. During the presentation at the public hearing, the applicant's representatives discussed using water or a dielectric cooling fluid to surround the battery cells as a cooling agent. More information is needed regarding this fluid, how this fluid is disposed of, and whether there may be adverse impacts associated with a possible leakage of both the batteries and the fluid. 3. Local Fire Departments are unfamiliar with and unequipped to take measures to contain potential fire hazards or prevent an explosion caused by lithium ion battery BES systems. Many such disasters are known to have occurred throughout the country with this method of energy storage. SEQRA Comments KCE NY 26, LLC December 27, 2022 Page 2 There is genuine concern for the safety of our first responders and the residents living in proximity to BESS installations. Furthermore, based upon these potential occurrences, will the community need to develop an evacuation plan? 4. Unknown level of noise and whether the noise levels would have adverse impacts on nearby residents. 5. It is unclear whether this facility will have a direct benefit to the East End community; i.e., Southold residents. 6. Visibility: There are concerns by residents of Southold Town that the project, would disrupt their valued agricultural vista on Oregon Road, particularly the proposed 55 feet high utility poles. What visual impacts would they create and what measures can be undertaken to assure that the view would not be adversely disturbed. Lastly, because this technology is relatively new and the safety of operations has not yet been assured, we suggest that the Town Board further investigate the value and feasibility of permitting lithium ion BES Systems in Southold Town, until there is greater confidence that the technology is safe and nontoxic to our first responders, the community and the environment. C:\Users\kimf\Documents\2 SEQRA\SEQRA-KCE NY 26-Memo to B Cummings,Lead Agency and comments LKW Final 2.doc SCOTT A. RUSSELL 6, MICHAEL M. COLLINS, P.E. SUPERVISOR ° "' �� : TOWN ENGINEER w TOWN HALL - 53095 MAIN ROAD .,� �; TOWN OF SOUTHOLD,NEW YORK 11971 Tel. (63 1)-765—1560 Fax (631)-765-9015 po tart n � E.9 OFFICE OF THE ENGINEER TOWN OF SOUTHOLD 'O'U0101J' yard Plannr ng Bo Brian Cummings December 19, 2022 Planner Southold Town Planning Department 54375 Main Road Southold, New York 11971 Re: Key Capture Battery Energy Storage System SCTM #: 1000 — 83. — 03 — 6.1 Dear Mr. Cummings: As per a request from your office, I have reviewed the Site Plan for the Key Capture Energy, LLC Battery Energy Storage Facility prepared by Robert Joel Richardson, P.E., dated June 6, 2022. Please have the applicant submit revised plans that address the following: 1. The apron connecting the site to Oregon Road must be constructed of asphalt for a minimum of 5' from the existing edge of the asphalt pavement. Show the asphalt apron on the plans and provide details for the construction of the asphalt apron. 2. Revise the Site Plan notes and details as necessary to state that if Recycled Concrete Aggregate (RCA) is to be utilized it must be NYSDOT Specification RCA. 3. The final plans must show the location of and details for the concrete washout areas and soil stockpile areas as part of the erosion and sediment control plan. If you have any questions regarding this review, please contact my office, Sincerely, �44j" � Michael M. Collins, P.E. Town Engineer OFFICE LOCATION• MAILING ADDRESS: Town Hall Annex ` P.O. Box 1179 54375 State Route 25 . Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) �� Telephone: 631 765-1938 Southold, NY www.southoldtownny.gov o .. �CouC PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Leslie Weisman, ZBA Chairperson Members of the Zoning Board of Appeals Cc: John Burke, Deputy Town Attorney From: Donald J. Wilcenski, Planning Board Chairman Members of the Planning Board Date: December 20, 2022 Re: Key Capture Energy Battery Storage Request for Comments SCTM# 1000-83-3-6.1 The Planning Board is retracting our memorandum of support dated November 28, 2022 due to significant concerns raised about battery energy storage facilities during the public hearing on December 5, 2022. These concerns highlighted the volatile nature of lithium-ion batteries, and the potential dangers should the facility catch fire. At this time, we cannot support the proposed variances because we lack adequate information about the safety of these types of facilities, including the technology and equipment necessary for local fire districts to be able to suppress a fire should one occur, the potential for toxic gases to be emitted during a fire, the effects of fire suppression chemicals on groundwater, and the potential threat to the health, safety and welfare to the public. If you have any further questions, please do not hesitate to contact the Planning Office. From: Baylinson, Lester Sent: Thursday, December 15, 2022 2:41 PM To: Cummings, Brian A. Cc: Michaelis,Jessica Subject: Site Plan for 10750 Oregon Rd, Cutchogue TM#83.-3-6.1 Good Afternoon, No open violations past or present Ok to proceed. LB L RLLE __. _1 mD outrioli Goin Planning Board i OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex P.O. Box 1179 54375 State Route 25 + Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 v^ w.southoldtownny.gov COUNTI PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Lester Baylinson, Ordinance Inspector a K Mike Verity, Acting Fire Marshal From: Brian Cummings, Planne" Date: December 13, 2022 Re; Site Plan for Key Capture Battery Energy Storage System 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 The Planning Board refers this application to you for your information, comments, review, and any violations on record, if applicable. This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. Thank you for your cooperation. (In Laserfiche: Planning, Applications, Site Plans, Pending, 1000-83.-3-6.1) OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex � P.O. Box 1179 54375 State Route 25 Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.southoldtownuy.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Elizabeth Thompson, Chairperson Southold Town Architectural Review Committee From: Brian Cummings, Planne� Date: December 13, 2022 Re, Site Plan for Key Capture Battery Energy Storage System Located at 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 The Planning Board refers this Site Plan Application to your committee for review and comments. This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial Zoning District, Cutchogue. Thank you. Encls.: Site Plan Application and Site Plan Elevations OFFICE LOCATION: MAILING ADDRESS: Town Hall Annexes P.O.Box 1179 54375 State Route 25 �' Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.southoldtownny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Michael J. Verity, Chief Building Inspector Amanda Nunemaker, Building Permits Examiner From: Brian Cummings, Planner& Date: December 13, 2022 Re: Site Plan for Key Capture Battery Energy Storage System 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 The Planning Board refers this application to you for your information, comments, review, and certification, if applicable. This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial Zoning District, Cutchogue. Thank you for your cooperation. Encls: Site Plan Application Site Plan OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex � � � P.O.Box 1179 54375 State Route 25 Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY d Telephone: 631 765-1938 www.southoldtownny.gov ev PLANNING BOARD OFFICE TOWN OF SOUTHOLD December 13, 2022 Mr. Matthew Martin c/o Cutchogue Fire District 260 New Suffolk Road Cutchogue, NY 11935 Re: Request for Review - Proposed Site Plan for Key Capture Battery Energy Storage System 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 Dear Mr. Martin: The Site Plan Application described below is being referred to you for your comment on matters of interest to the fire department, including fire department equipment access, emergency services, and any other issue that may be of concern or relevance to this application. This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial Zoning District, Cutchogue. Thank you for your cooperation. Sincerely, �v S Brian Cummings Planner Encls: Site Plan Application, Site Plan OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex P.O.Box 1179 54375 State Route 25 �� Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.s outholdtownny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Michael Collins, Town Engineer From: Brian Cummings, Planne� Date: December 13, 2022 Re: Site Plan for Key Capture Battery Energy Storage System Application Name: Key Capture Battery Energy Storage System Tax Map Number: 1000-83.-3-6.1 Location: 10750 Oregon Road, Cutchogue Type of Application: Sketch Subdivision Map (Dated: Preliminary Subdivision Map (Dated: Final Subdivision Map (Dated: Road Profiles (Dated: 1 Grading and Drainage Plans (Dated: Other (Dated; Site Plan (Dated: to PB 9/29/22) Revised/Amended Site Plan (Dated: Grading and Drainage Plans (Dated: Other (AS BUILT) (Dated: Pro"ect Description: This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. Thank you for your cooperation. OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex � �1� P.O. Box 1179 54375 State Route 25 � p Southold, NY 11971 (cor. Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.southoldtownny.gov eou PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Lester Baylinson, Ordinance Inspector Mike Verity, Acting Fire Marshal From: Brian Cummings, Planne" Date: December 13, 2022 Re: Site Plan for Key Capture Battery Energy Storage System 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 The Planning Board refers this application to you for your information, comments, review, and any violations on record, if applicable. This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. Thank you for your cooperation. (In Laserfiche: Planning, Applications, Site Plans, Pending, 1000-83.-3-6.1) OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex � � P.O.Box 1179 54375 State Route 25 Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.southoldtownny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Mark Terry, LWRP Coordinator From: Brian Cummings, Planna Date: December 13, 2022 Re: Site Plan for Key Capture Battery Energy Storage System 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 The Planning Board refers this application to you for your information, comments, review, and certification, if applicable. The file is available at your convenience. This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. Thank you for your cooperation. OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex P.O. Box 1179 54375 State Route 25 Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.southoldtownny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Suffolk County Planning Commission From: Brian Cummings, Planne-----\ Date: December 13, 2022 Re. Site Plan Application Review: • Request for Comments pursuant to Section A14-24, Suffolk County Administrative Code • Request for Comments pursuant to General Municipal Law §239 (as a referral) and Southold Town Code §280-131 • SEQR Lead Agency Request The purpose of this request is to seek comments from your agency, and also to determine lead agency and coordinate review under Article 8 (State Environmental Quality Review Act- SEQRA) of the Environmental Conservation Law and 6 NYCRR Part 617. Please provide the following, as applicable: 1. Comments or requirements from the Suffolk County Planning Commission that the Southold Planning Board should take into consideration while reviewing the proposed project; 2. Issues of concern you believe should be evaluated; 3. Your interest in assuming the responsibilities of lead agency under SEQR. The lead agency will determine the need for an Environmental Impact Statement (EIS) on this project. Within thirty (30) days of the date of this letter, please respond in writing whether or not you have an interest in being lead agency. The following page contains information pertaining to the project under review. For further information, please feel free to contact this office. Southold Referral & SEQR Coordination Planning Board Position: (x) This agency wishes to assume lead agency status for this action. Comments: Project Name: Key Capture Battery Energy Storage System Address: 10750 Oregon Road, Cutchogue Tax Map #: 1000-83.-3-6.1 Requested Action: This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. SEQRA Classification: (X) Type I ( ) Type II ( ) Unlisted Contact Person: Brian Cummings Planner Southold Town Planning Board (631) 765-1938 Enclosures: • Environmental Assessment Form • Site Plan Application Form • Site Plan(s) • SCPC Referral Submission Cover Sheet 2 Appendix A- County Referral For Appendix A—Suffolk County Planning Commission Guidebook Suffolk • • Commission Submission Cover Form For Planning and Zoning Referrals Municipality: SgUlbgld Town Hamlet: Cutchoaue Local Case Number: District: 1000 Section: 83 Block:�3 Lot: 6.1 Local Meeting Date: Application/Action Name: Public Hearing: CE) No Referring enc . Type of Referral: SE RA Actior �ol, New EAF Draft EIS Positive Declaration and orornmisFinal EIS Negative Declaration Ex ansion Lead A encS�sar�of A ea1 ,"�► P Agency Findings Town Board/Village Board of Modification Draft Scope Trustees Brief description of application or proposed action This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutcho ue. Type of Action Please check appropriate box below if action is located within the Suffolk County Pine Barrens Zone, within one mile of a nuclear power plant or airport or within 500 feet of: • A municipal boundary; • The boundary of any existing or proposed county, state,or federal park or other recreation area; • The right-of-way of any existing or proposed county or state road; • An existing or proposed county drainage channel line; ' The Atlantic Ocean, Long Island Sound, any bay in Suffolk County or estuary of any of the foregoing bodies of water, • The boundary of county,state,or federally owned land held or to be held for governmental use; • The boundary of a farm located in an agricultural district. Comprehensive Plan (Adoption or Amendment) Subdivision Zoning Ordinance or Map(Adoption or Amendment) Use Variance Code Amendment Area Variance Official Map Special Use Permit/Exception/Conditional Use Moratorium Site Plan� Note:The above represents a summary of the required actions subject to referral to the Suffolk County Planning Commission. The provisions of GML and Laws of Suffolk County must be used to verify which actions are subject to referral and the related procedural requirements. Additional Application Information • Action Previously Referred to Suffolk County Planning Commission Yes No 4(If yes,Date ) • Adjacent Municipality Notified (see NYS GML 239 nn) Yes No N/A • Located Within Long Island Pine Barrens Zone Yes No • Workforce/Affordable Housing Yes No N/A • Energy Efficiency Yes No N/A • Zoning Board of Appeals Approval Yes No N/A • Suffolk County Department of Health Approval/Comments Yes No N/A • New York State Dept.of Environmental Conservation Approval/Comments Yes No N/A • New York State/Suffolk County Dept.of Public Works Approval/Comments Yes No N/A • Suffolk County Sanitary Code Article 6,Groundwater Management Zone- 1 11 III IV V VI VII VIII Contact Information Municipality Town of Southold Contact Name: Department/Agency: Planning De a m nt Brian Cummings Phone Number: 631-7'65-1'936 Email Address:brian.cum i s ownsouthald.n-.us Applicant: Key Capture/KCE NY 26,LLC Contact:Philip Denara Address: 25 Monroe Street Albany,NY t5161279.2655 OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex P.O. Box 1179 54375 State Route 25 � . Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) " Southold, NY Telephone: 631 765-1938 www.southoldtow-nny.gov co-� cou PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Zoning Board of Appeals (ZBA) Leslie Weisman, Chairperson From: Brian Cummings, Plann Date: December 13, 2022 Re: Site Plan Application Review: • Request for Comments pursuant to §280-131(C) of the Southold Town Code • SEQR Lead Agency Request The purpose of this request is to seek comments from your agency, and also to determine lead agency and coordinate review under Article 8 (State Environmental Quality Review Act- SEQRA) of the Environmental Conservation Law and 6 NYCRR Part 617. Please provide the following, as applicable: 1. Comments or requirements from the Zoning Board of Appeals that the Southold Planning Board should take into consideration while reviewing the proposed project; 2. Issues of concern you believe should be evaluated; 3. Your interest in assuming the responsibilities of lead agency under SEQR. The lead agency will determine the need for an Environmental Impact Statement (EIS) on this project. Within thirty (30) days of the date of this letter, please respond in writing whether or not you have an interest in being lead agency. The following page contains information pertaining to the project under review. For further information, please feel free to contact this office. Southold Referral & SEQR Coordination Planning Board Position: (x) This agency wishes to assume lead agency status for this action, Comments: Project Name: Key Capture Battery Energy Storage System Address: 10750 Oregon Road, Cutchogue Tax Map #: 1000-83.-3-6.1 Requested Action: This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. SEQRA Classification: (X) Type I ( ) Type II ( ) Unlisted Contact Person: Brian Cummings Planner Southold Town Planning Board (631) 765-1938 Enclosures: 0 Environmental Assessment Form • Site Plan Application Form Site Plan(s) 2 OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex :� P.O. Box 1179 54375 State Route 25 Southold, NY 11971 (cor. Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.southoldtownny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Scott A. Russell, Supervisor Members of the Town Board Denis Noncarrow, Town Clerk cc: Town Attorney From: Brian Cummings, Planne Date: December 13, 2022 Re. Site Plan for Key Capture Battery Energy Storage System 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 The Planning Board refers this application to you for your information, comments, review, and a determination of jurisdiction, if applicable. This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. Thank you for your cooperation. (In Laserfiche: Planning, Applications, Site Plans, Pending, 1000-83.-3-6.1) OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex P.O.Box 1179 54375 State Route 25 , Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Southold, NY Telephone: 631765-1938 www.southoldtowuny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD December 6, 2022 Mr. Philip Denara 25 Monroe Street, Suite 300 Albany, NY 12210 Re: Public Hearing - Key Capture Battery Energy Storage Facility 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 Dear Mr. Denara: A Public Hearing was held by the Southold Town Planning Board on Monday, December 5, 2022 regarding the above-referenced application. The Public Hearing was adjourned without a date. The Planning Board requires additional time to gather more information about battery energy storage facilities, which are new to Southold Town. If you have any questions regarding the above, please contact this office. Respectfully, -'r�6ao LJQ.QL Donald J. Wilcenski Chairman North Fork Environmental Council 12700 Main Road -, PO Box 799 North Fork Mattituck, NY 11952 En�vironmefftal Council Phone: 631.298.8880 Fax: 631.298.4649 µ Web: www.NFEC1.org December 5, 2022 D. C 0 5 1022 Mr. Donald Wilcenski .. _��'whof ,.._'own Chairperson Planning Board Southold Town Planning Board Re: Key Capture Energy Battery Storage Dear Mr. Wilcenski, I am writing to you on behalf of the North Fork Environmental Council, a fifty-year-old grassroots North Fork environmental organization. I strongly urge the Southold Town Planning Board to consider the fol- lowing information while reviewing the application of KCE NY 26, LLC (Key Capture Energy Battery Storage) to site a 60-megawatt lithium-ion battery storage facility at 10750 Oregon Road in Cutchogue. The New York State Energy Development Agency (NYSERDA) has developed a guidebook (see attach- ment) along with best practices and training for local governments in order to ensure responsible battery development. It recommends that municipalities form a task force of local stakeholders to develop local laws to ensure the orderly development of these projects. Southold Town has not planned for, nor has it developed, any laws governing the placement of these fa- cilities. The NFEC supports battery storage facilities but only if the town has a well-considered plan in place for them. The town owes it to the public to ensure that battery storage facilities have environmental standards and safety reviews. Due to this very lack of planning, the Southold Zoning Board of Appeals approved a battery storage fa- cility in a completely inappropriate location in Greenport adjacent to wetlands and preserved open space. There was simply no battery storage law, or plan, in place to prevent it. The Planning Board should ensure that the zoning consultant includes battery storage plans in the current zoning review, and it should recommend that the town board have a plan, and a local law, to safely site such facilities. We believe it is unwise and unfair to the taxpayers to have another battery storage project underway in Southold without a proper town wide-plan in place. Sincerely, n T NFEC President r LARK& FOLTS Attorneys at Law 28785 MAIN ROAD PO BOX 973 CUTCHOGUE,NEW YORK 11935 Tele.No.(631)734-6807 RICHARD F.LARK Fax No. (631)734-5651 MARY LOU FOLTS E-mail: Attys@larkandfolts.com December 1, 2022 'RECEIVED PlanBoard F_ Town nofgSoutholdDEC' 0 1 2022 54375 Main Road - P.O. Box 1179 Southold, NY 11971 out of Town Planning Board RE: KCE NY 26, LLC Key Capture Battery Energy Storage Site Plan 10750 Oregon Road, New York Dear Sirs: On behalf of KCE NY 26, LLC, I am enclosing an Affidavit of Posting for the Hearing on December 5, 2022 . It is my under- Standing you have already received its Affidavit of mailing of Notices. Very truly yours, 1.01 101 ?Mary L Fo is MLF/m Enclosure AFFIDAVIT OF POSTING This is to serve notice that I personally posted the property known as 10750 Oregon Road, Cutchogue, New York by placing the Town's official poster notice(s) within 10 feet of the front property line facing the street(s) where it can be easily seen, and that I have checked to be sure the poster has remained in place for at least seven days prior to the date of the public hearing on December 1ftW6xK0txtCd0qMhy>o-eVb " maw James M. McBride Your Name (print) 1� e.2::�,& �v 1 &4C Signature 6580 Oregon Road, Cutchogue, New York Address December 1, 2022 Date Not Pyglic MARY LOU FOLTS N^tary Public,State of New York No.01F01000858 0,ollfled in Suffok County Gv, w„ d�,&Pire.!March 30,20A3 PLEASE RETURN THIS AFFIDAVIT, CERTIFIED MAIL RECEIPTS & GREEN RETURN RECEIPT CARDS BY. 12:00 noon Fri. 12/2/22 Re: Key Capture Battery Energy Storacle Site Plan SCTM#: 1000-83-3-6.1 Date of Public Hearing: Monday, December 5 2022 6:01 P.M. 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F �fa `,;:Y.. 4 '��;" S• f i_ ... .. - f i � � r�.�•a 3 _- i�' ,r ff v` �R� .fir ��+ � .k r Y �• ��f f i." Y. � '� �� ,w .. r .j 1 "� - AK " ,F fir•"5 - �or �. -,`fir 3 f w - f -f• i..= E � f �! -i f ,�.�w � - '� �,1 i _ _ � '• ,fit ,. ek ' k .. 1. OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex P.O.Box 1179 54375 State Route 25 �� Southold,NY 11971 (cor. Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.s outholdt ownny.gov 400, PLANNING BOARD OFFICE TOWN OF SOUTHOLD November 9, 2022 Mr. Philip Denara 25 Monroe Street, Suite 300 Albany, NY 12210 Re: SEAR Classification & Set Hearing Key Capture Battery Energy Storage Facility 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 Dear Mr. Denara: The following resolutions were adopted at a meeting of the Southold Town Planning Board on Monday, November 7, 2022: WHEREAS, this site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue; and WHEREAS, the Southold Town Planning Board, pursuant to State Environmental Quality Review Act (SEQRA) 6 NYCRR, Part 617, has determined that the proposed action is a Type I action pursuant to 617.4(b)(8) "any Unlisted action that includes a nonagricultural use occurring wholly or partially within an agricultural district [...]"; be it therefore RESOLVED, that the Southold Town Planning Board has determined that this proposed action is an Type I Action under SEQRA as described above; and be it further Key Capture Battery Energy Storage Page 2 November g 2022 RESOLVED, that the Southold Town Planning Board sets Monday, December 5, 2022 at 6:01 p.m. for a Public Hearing regarding the Site Plan entitled ""`Key Capture Energy KCE NY 26" prepared by Robert Joel Richardson, P. E., dated June 6, 2022. The public hearing packet regarding the Town's notification procedure and the sign & post will need to be picked up at the Planning Board Office at the Southold Town Annex when you are contacted to do so. Please return the Affidavit of Posting/Mailing, included in the packet, aloo with the certified mailing,,receipts AND the signed green return receipt cards before 12:00 noon on Friday, December 2 2022. The sign and the post need to be returned to the Planning Board Office after the Dublic hearing is closed. If you have any questions regarding the information contained in this resolution, please contact the Planning Board Office. Respectfully, -L-640 Donald J. Wilcenski Chairman Encls. Southold Town Planning Board Work Session -- November 7 202'2 Pa e 2 Project Name. Key Capture Energy Battery Storag Site Plan .. ,.. ��.�.w .... _.._..... w 'U Description. This sit °n Road Cutcho ue ion m. ..... 10750 wOrean is for the construction of a 60MW Loca . " siteplan Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial tonin district, ggt!qho ue p Status: Actions w ,... eyiew for Corn letrtes __. .......... .._._.. _ Attachments Staff Report Project Names H_.. - axed Use _� Southold M�ww SCTM# 1000 61 4 1 - ca Hard Corner o Southold �-DescrLoi tion This site plan is �� - � _ 3530 Route Description: for the proposed mixed use construction of a 2-story 4,983 sq. ft. building fronting NYS Route 25 with retail on the first floor and three Affordable Housing apartments on the second floor and 25 parking stalls; and four 1,597 sq. ft. 55 and older rental units along Wells Avenue, all on 2.28 acres in the Hamlet Business Zoning.District. w Pending �... . Status - Action: _sed Site Plan Review Revs -,�..... Attachments: Staff Repoort. rner Heart of Love Lane SCTM#: 1000-141-4-2, 141-4-33, Prosect Name. -��Hard Co , _ _ Amended 141-4-6.1 Location _ ,,_24 Plan le Streetro o ck _ Description. This ame ded Site is for the proposed alteration and conversion of an existing ±16,500 gross sq. ft. commercial office building (with basement) to contain a 56 seat restaurant and two retail spaces on the first floor and two commercial spaces and an accessory apartment on the second floor, all on 0.784 acres in the HB Zoning District. Status: New A plication .� _ ..m.. ._...._ _. ...m.-...__ Review for Completeness Action: - p ess_�.....__.. Attachm ents: Staff Report ..�.�-_,w .m-�.�. . ....-m. ..�� .. m.......�, Southold Planning Department Staff Report Site Plan Application Work Session — Completeness Date November 7, 2022 Prepared By: Brian Cummings I. Application Information Project Title: Key Capture Battery Energy Storage System (BESS) Applicant: KCE NY 26, LLC (Owner: F. McBride & Sons LLC) Date of Submission: June 10, 2022 Tax Map Number: 83.-3-6.1 (to be subdivided) Project Location: 10750 Oregon Road Hamlet: Cutchogue Zoning District: LI — Light Industrial II. Description of Project Type of Site Plan: Commercial Acreage of Project Site: 27 acres Building size 11 acre area of disturbance, see below for details Site Plan packet Table of Contents: C-000 COVER SHEET C-120 EROSION&SEDIMENT CONTROLS TOPOGRAPHIC/BOUNDARY SURVEY CL-100 LANDSCAPE SITE PLAN CD-100 SITE DEMOLITION PLAN C-500 SITE DETAILS CS-100 DIMENSIONAL SITE PLAN C-510 BESS CONTAINER&PCS ELEVATION CS-110 TRANSMISSION LINE PLAN L-100 LIGHTING PLAN C-100 GRADING AND DRAINAGE PLAN L-101 PHOTOMETRIC PLAN C-110 DRAINAGE CALCS&STRUCTURES L-102 ELECTRICAL LIGHTING DETAILS Description: This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System (BESS) and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. Ill. Zoning Compliance and Staff update: Building Department: Notice of Disapproval received by Planning on June 10, 2022 notes the following: - Proposed Use and Subdivision of lot require site plan approval 1 - The proposed subdivision, as presented, is not permitted pursuant to Article XXII 280-109 A (1-2) which requires that all lots have direct access to a public street o The site plan is showing the proposed "POI" Lot to be an interior lot Staff: to be clarified by applicant if an access easement is proposed (in lieu of creating a flag lot, typ.) to provide legal access to the created lot. - Additionally, the proposed construction on this (proposed) 1,067,051 sq. ft. parcel and 110,872 sq. ft. parcel in the LI District is not permitted under "Permitted Uses" o A battery energy storage facility is not a permitted use in the LI zoning district Staff: the Building Department has noted that the proposed BESS facility is not specifically listed/Permitted in the LI Zone uses. As identified in the Expanded Environmental Assessment, this facility is proposed as a "Public Utility" which under the LI Zoning District code would require Special Exception approval from the ZBA. The Building Department has determined the applicant may apply to the ZBA to present the application as a "Public Utility" for Special Exception I" . Proposed Action: According to the project description, the proposed action includes the following;: 1. Construct and operate an approximately 60-megawatt Lithium-Ion BESS Facility on 27 acres in the LI zoning district, proposed an 11 acre area of disturbance a) Construct project substation, Point of Interconnection (POI) substation on the subdivided portion of the site and enter into an easement with the Town to permit access to a 100 feet wide by 1,150 long area on an adjacent parcel (SCTM#96.-1-2) where an overhead transmission line would be sited and travel in a southeasterly direction to connect at County Route 48; Approximately 13 utility poles are planned for installation through the easement at a span of±150-180 feet, expected at heights consistent with LIPA's existing transmission infrastructure there (±50'-70' high) b) Minimal realignment of driveway location to Oregon Road and construct/upgrade 20' wide driveway surface to compacted RCA pavement. The driveway extends to connection with created internal roads until it splits for access to BESS Facility, POI Lot or project substation; 2 c) BESS Facility to consist of the following:. i) 272 — battery modules (168sf ea.) within containerized enclosures at 30.7' long, 5.6' wide and 8.6' tall; ii) 34 — medium voltage transformer and inverter units (160sf ea.) located within their own containers to mitigate sound and visual impacts at 19.9' long, 8' wide and 9.5' tall iii) 392sf substation control building iv) Installation of a 12' high visual and sound barrier wall (elevations/details not provided) surrounding the BESS Facility on its north, west and southern sides, chain link (barbed wire) fencing around the perimeter of the BESS installations, project substation and POI substation; v) Landscaping: fourteen (14) planting block patterns are proposed to border the 12' high barrier wall and BESS Facility, each including deciduous plantings at 2 Y2" — 3" caliper, evergreen trees at 6'-7' high, shrubs and seeding. Irrigation numbers are unknown (if proposed) vi) Exterior Lighting: twenty-three (23) light poles at 30' high. Photometric plans have been provided for each of the subject parcels but there are areas of overlap that are not included on the plans. During full review, a revised (and comprehensive) photometric plan will be required. d) 2.54-acre Point of Interconnection (POI) lot (after subdivision): i) 55' tall lightning masts connecting to off-site utility poles ii) 1,OOOsf equipment enclosure iii) POI Substation e) Two phase proposed construction: i) Phase 1: 8 — 12 months, Transmission easement work, POI substation, curb cuts/driveway upgrades along Oregon Road and LIPA's road easement to POI substation will be constructed first ii) Phase 2: 6 — 9 months, construction of BESS Facility f) This action will require outside approvals from at least: SCDHS (subdivision), SCWA (proposed water usage), NYSDEC (SWPPP), SCDPW for interconnection to CR 48, Southold Town Board easement, Interconnection 3 Agreement determination from the New York Independent System Operator (NYISO) and the Long Island Power Authority (LIPA) V: Expanded Environmental Assessment provides the following: a) Introduction with project description, intro to KCE (applicant), project purpose and need, site setting, construction schedule, operations and maintenance, decommissioning, permits and approvals. b) Existing Conditions and Potential Impacts Assessment: a. Natural Resources i. Wetlands and Water Resources ii. Threatened and Endangered Species iii. Critical Environmental Areas and Sensitive Habitats b. Noise c. Visual Resources i. Existing Conditions ii. Potential Impacts of the Proposed Action Note: Clarify exact locations of the photo-simulations— one of the photos appears to be closer than indicated in the key map provided. c) LWRP d) Storm water e) Cultural Resources VI. Planning Board follow up letter dated July 29 2022: The site plan application was determined incomplete based on the following: 1. Provide at least nine (9) prints of a revised Site Plan to include the seal, stamp and signature of the NYS licensed professional preparing the plan, with the following: a. Provide LIPA easement details to provide access to the proposed landlocked parcel; Submitted: Yes; the proposed LIPA easement, which varies in width, is provided on Sheet CS100 — Dimensional Site Plan. 4 Staff: the proposed access easement appears to take a longer route (and separate driveway) to the west and south of the energy storage facility. It is unclear why this route would be the preferred access easement route as opposed to routing the driveway to the east and north of the energy storage area. i. Provide exterior lighting details and any other construction details proposed on the 2.54acre parcel associated with the subject application; Submitted: yes; a lighting plan has been provided but a comprehensive photometric plan will be required during full review that includes both parcels on one plan. b. Provide boring sample details and test hole location(s); Submitted: yes; soil boring locations have been added to Sheet C100 — Grading and Drainage Plan. The soil boring logs have been added to sheet C110 — Drainage Calculations and Structure Schedule c. Provide elevations and details for the proposed 12' high wall and surrounding fencing. A clear elevation or rendering of the proposed site at a larger scale would be beneficial for the Board to review the action including wall materials/colors/elevations, dimensions, overall site elevation with lightning masts and lighting poles included; Submitted: yes; updated renderings of the facility have been provided as well as details for the proposed visual/sound barrier wall provided as detail 14 on Sheet C500 — Site Details. Staff: the 12' high wall proposed on three sides of the energy storage facility requires a variance from the ZBA, which was not specified on the Notice of Disapproval. 2. Submit a Special Exception application to Zoning Board of Appeals (ZBA) for a "Public Utility" as proposed to the Planning Board, listed within documentation, and referenced in the Notice of Disapproval. Submitted: yes; Staff: applicant should confirm that all recently revised plans and current information submitted to the Planning Board are consistent with plans on file with the ZBA. 5 VIII: Planning Board items to consider: Accept the above referenced site plan application as complete for review and consider the items below to commence the review process: 1. Classify SEQRA a) If the property is still in the Ag District: Standards for Type I Classification Minimum Project Proposed triggering Type I 25% of 10 acres of land being converted 2.5 acres >11 acres to non-agricultural use: b) If not in the Ag District Pursuant State Environmental Quality Review Act (SEQRA) 6 NYCRR, Part 617, classify the proposed action is an Unlisted Action as it does not meet any of the thresholds of a Type I Action, nor does it meet any of the criteria on the Type II list of actions. Staff will begin the SEQRA review process. 2. Set the Public Hearing for December 5, 2022; 3. Distribute referrals of the application to all involved and interested agencies for comment; 4. Provide comments to the ZBA for their upcoming public hearing for the proposed project. 6 OFFICE LOCATION: " �w�� MAILING ADDRESS: Town Hall Annex P.O. Box 1179 54375 State Route 25 Southold, NY 11971 (cor.Main Rd. &Youngs Ave.) Telephone: 631765-1938 Southold, NY 11971 LOCAL WATERFRONT REVITALIZATION PROGRAM . L (YrT TOWN OF SOUTHOLD RECEIVED MEMORANDUM OF 19 2022 To: Donald Wilcenski, Chair Planning Board Town of Southold Planning Board From: Mark Terry, AICP Assistant Town Planning Director LWRP Coordinator Date: October 14, 2022 Re: Key Capture Energy Battery Storage Site Plan SCTM#: 1000-83-3-6.1 Zoning District—LI This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. The proposed action has been reviewed to Chapter 268, Waterfront Consistency Review of the Town of Southold Town Code and the Local Waterfront Revitalization Program (LWRP) Policy Standards. Based upon the information provided on the LWRP Consistency Assessment Form submitted to this department, the proposed action is CONSISTENT with the LWRP. Pursuant to Chapter 268, the Board shall consider this recommendation in preparing its written determination regarding the consistency of the proposed action. Cc: Mara Cerezo, Planner architects - engineers 538 Broad Hollow Road,411 Floor East Melville,NY 11747 i tet 631.756.8000 AL I September 19, 2022 JRE ��' Mr. Brian Cummings- Planner SEP 2 9 7-022 Planning Board Office So— u_tat �a .`Towrias.' Town of Southold Planning Board 54375 State Route 25 Southold, New York 11971 Re: KCE NY 26—Site Plan Application—Completeness Review Response 10750 Oregon Road, Cutchogue SCTM: 1000-083-03-6.1 H2M Project No: KCEG 2101 Dear Mr. Cummings: We have received the Town's completeness review comment letter regarding the Site Plan Application for the above referenced project. We have reviewed the letter and revised Sheets CS 100, C 100, C 110 and C 500 to address the comments. We have also included a new plan sheet to show the proposed lighting and photometrics within the proposed POI substation portion of the development. In addition to these revisions, the project no longer proposes to share a driveway with the neighbor to the north (Tax Lot 100- 83-03-5.2) but will now have its own direct driveway connection to Oregon Road. Below please find our written response to the comment letter. For your convenience, we have listed the original comments in bold italic text, with our responses following. Also enclosed are nine copies of the revised plans and new sheet, and supporting visualization documents: 1. Provide at least nine (9)prints of a revised Site Plan to include the seal, stamp and signature of the NYS licensed professional preparing the plan, with the following: a. Provide LIPA easement details to provide access to the proposed landlocked parcel, Response:The proposed LI PA easement,which varies in width, has been added to Sheet CS100 — Dimensional Site Plan. L Provide exterior lighting details and any other construction details proposed on the 2.54 acres parcel associated with the subject application; Response: A Lighting Plan for the Project and POI Substations, prepared by Reynolds Architecture Engineering, is included with this submission. Said plan details the lighting and photometric calculations for the proposed 2.54-acre POI Substation parcel associated with the application. b. Provide boring sample details and test hole location(s); Response: Soil boring locations have been added to Sheet C100—Grading and Drainage Plan. The soil boring logs have been added to Sheet C110 — Drainage Calculations and Structure Schedule. C. Provide elevations and details for the proposed 12'high wall and surrounding fencing.A clear elevation or rendering of the proposed site at a larger scale would be beneficial to the Board to review the action including wall materials/colors/elevations, dimensions, overall site elevation with lighting masts and lighting poles included; H2M Architects, Engineers, Land Surveying and Landscape Architecture, DPC (NY)offers its services in NY only H2M Architects & Engineers, Inc. (NJ)offers its services in NJ, CT, MA, PA, VA only H21V1 Associates, Inc. (NJ)offers its engineering, land surveying, landscape architecture services in NJ only h2rn.com Town of Southold ill' September 19, 2022 Page 2 of 2 Response:A detail of the Visual and Sound Barrier has been added as Detail 14 on Sheet C500 —Site Details. The detail includes a note proposing the wall color to be green. However, the wall color can be modified to meet the Board's preference. Fencing details are included as Detail 1 and Detail 2 on Sheet C500—Site Details. The"Proposed Action Visual Simulation Location 2(View from Oregon Road Looking Southeast) has been updated to show the light poles within the battery energy storage system portion of the site. A closer visual simulation from this vantage has been created and included in this submission for the Board's use. 2. Submit a Special Exception application to Zoning Board of Appeals (ZBA) for a "Public Utility"as proposed to the Planning Board, listed within documentation, and reference in the Notice of Disapproval. Response:A Special Exception Application was delivered to the Town of Southold Zoning Board of Appeals office on June 10th, 2022. Should you have questions or require further information, please feel free to contact our office at (631) 756-8000 extension 1715. Very truly yours, H2M architects + en uineeirs ichardson, P.E. Department Manager—Civil Engineering cc: Phil Denara—Key Capture Energy, LLC John Anzalone— Harris Beach, PLLC XAKCEG (Key Capture Energy)\KCEG 2101 (NY 26 Cutchogue)\02-Permitting\ToS\Site Plan\22-0919 Completeness Review Resubmission\22-0919 Completeness Review Comment Response Letter.docx OFFICE LOCATION: MAILING ADDRESS: Town Hall Annex P.O. Box 1179 54375 State Route 25 Southold NY 11971 (cor. Main Rd. &Youngs Ave.) Southold, NY Telephone: 631 765-1938 www.southoldtownny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD July 29, 2022 Mr. Philip Denara 25 Monroe Street, Suite 300 Albany, NY 12210 Re: Proposed Site Plan for Key Capture Battery Energy Storage Facility 10750 Oregon Road, Cutchogue SCTM#1000-83.-3-6.1 Dear Mr. Denara: I am writing as a follow-up to the Work Session held on July 25, 2022 where the Planning Board determined that the above-referenced Site Plan Application is incomplete for review. Before the Board can commence its full review, it is necessary to complete the application by submitting the following directly to this department: 1. Provide at least nine (9) prints of a revised Site Plan to include the seal, stamp and signature of the NYS licensed professional preparing the plan, with the following: Note: a draft electronic site plan (PDF) including the items listed below is encouraged to be submitted to this Department prior to printing multiple copies of the site plan for review efficiency. a. Provide LIPA easement details to provide access to the proposed landlocked parcel; i. Provide exterior lighting details and any other construction details proposed on the 2.54acre parcel associated with the subject application; b. Provide boring sample details and test hole location(s); Key Capture BESS Faciiit Pa e 2 Jul 29 2022 c. Provide elevations and details for the proposed 12' high wall and surrounding fencing. A clear elevation or rendering of the proposed site at a larger scale would be beneficial for the Board to review the action including wall materials/colors/elevations, dimensions, overall site elevation with lightning masts and lighting poles included; 2, Submit a Special Exception application to Zoning Board of Appeals (ZBA) for a "Public Utility" as proposed to the Planning Board, listed within documentation, and referenced in the Notice of Disapproval. If you have any questions regarding this Site Plan or its process, please do not hesitate to contact this office. Respectfully, Brian Cummingsh4. Planner Southold Town Planning Board Work Session — July 25 2022— Page 3 . .......... _ Project Name. KeyCapture Energy Battery Storage SCTM#: 1 1000-83-3-6.1 Site PlanV .............. .�...... 1111... m... .. 1111 ._1111......._ . Location 110750Oregon Road, Cutchogue m Description: This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is +27 acres in the Light Industrial zonrng di,ct'c , Cutchogue _. __ Status: I New Application Review for Completeness Action............ . ... .... ........ rv. .._. Attachments: .Staff Repo-----. ........— _......1111............ __ .. rrAPLJame SPorts East Recreational Fa cilty SCTM# 1000771151-1,-,6 Location-, 1080 Carroll venue econic Description: This site plan is for the proposed construction of a 2-story 45,500 sq. ft. Public Indoor Recreational Facility building and associated parking. This proposal requires a subdivision of the parcel, and a change of zoning 4district from A-C to RFZ (Recreational Floating Zone) on 5.3 acres in Peconic. ..._._ Status: New Application A,ction 1111.. _ Review for Com.. . tete Hess Attachments: Staff Report .. ... _ . , I Prosect Nam. l Carroll _.._. Cottages._ y 80 Car SCTM# 1000-75-1-6 7 Name: . .� Avenue Avenue,Location: 4 10 conic Description_. This site plan is for the pro. ............... n........ , ......... i posed construction of 24 workforce rental housing units. Each unit is a separate 2-bedroom cottage of 600 sq. ft.. This proposal requires a subdivision of the parcel and a change of zoning district from A-C to AHD (Affordable Housing District), and is in Peconic. ................._ ........m located on 4 8 acres. ............. _. ..n.n _.. ...._ Status_ New Application .....rCompleteness Action Review for .. ....... �......... ��... . .. . .. � Staff Report .... .... . Attachments .S.�. ..... 1111 _ .. ........... . Southold Planning Department Staff Report Site Plan Application Work Session — Completeness Date July 25, 2022 Prepared By: Brian Cummings I. Application Information Project Title: Key Capture Battery Energy Storage System (BESS) Applicant: KCE NY 26, LLC (Owner: F. McBride & Sons LLC) Date of Submission: June 10, 2022 Tax Map Number: 83.-3-6.1 (to be subdivided) Project Location: 10750 Oregon Road Hamlet: Cutchogue Zoning District: LI — Light Industrial II. Description of Project Type of Site Plan: Commercial Acreage of Project Site: 27 acres Building size 11 acre area of disturbance, see below for details Site Plan packet Table of Contents:. C-000 COVER SHEET C-120 EROSION&SEDIMENT CONTROLS TOPOGRAPHIC/BOUNDARY SURVEY CL-100 LANDSCAPE SITE PLAN CD-100 SITE DEMOLITION PLAN C-500 SITE DETAILS CS-100 DIMENSIONAL SITE PLAN C-510 BESS CONTAINER&PCS ELEVATION CS-110 TRANSMISSION LINE PLAN L-100 LIGHTING PLAN C-100 GRADING AND DRAINAGE PLAN L-101 PHOTOMETRIC PLAN C-110 DRAINAGE CALCS&STRUCTURES L-102 ELECTRICAL LIGHTING DETAILS Description: This site plan is for the construction of a 60MW Lithium-Ion Battery Energy Storage System (BESS) and a new LIPA substation. The battery storage facility is comprised of 272 battery energy storage container units, 34 power conversion system units, a 1,000 sq. ft. point of interconnection building. The LIPA substation will require a 2.54-acre parcel to be created for LIPA ownership, and will contain a 392 sq. ft. LIPA substation building, lightning masts and ±13 utility poles connecting to CR 48 by way of an access easement over Town of Southold land. The parcel is ±27 acres in the Light Industrial zoning district, Cutchogue. III. Zoning Compliance and Staff update. Building Department: Notice of Disapproval received by Planning on June 10, 2022 notes the following: - Proposed Use and Subdivision of lot require site plan approval 1 The proposed subdivision, as presented, is not permitted pursuant to Article XXII 280-109 A (1-2) which requires that all lots have direct access to a public street o The site plan is showing the proposed "POI" Lot to be an interior lot Staff: to be clarified by applicant if an access easement is proposed (in lieu of creating a flag lot, typ.) to provide legal access to the created lot. Additionally, the proposed construction on this (proposed) 1,067,051 sq. ft. parcel and 110,872 sq. ft. parcel in the LI District is not permitted under "Permitted Uses" o A battery energy storage facility is not a permitted use in the LID district Staff: the Building Department has noted that the proposed BESS facility is not specifically listed/Permitted in the LI Zone uses. As identified in the Expanded Environmental Assessment, this facility is proposed as a "Public Utility" which under the LI Zoning District code would require Special Exception approval from the ZBA. The Building Department has determined the applicant may apply to the ZBA to present the application as a "Public Utility" for Special Exception I" , Proposed Action: According to the project description, the proposed action includes the following: 1. Construct and operate an approximately 60-megawatt Lithium-Ion BESS Facility on 27 acres in the LI zoning district, proposed an 11 acre area of disturbance a) Construct project substation, Point of Interconnection (POI) substation on the subdivided portion of the site and enter into an easement with the Town to permit access to a 100 feet wide by 1,150 long area on an adjacent parcel (SCTM#96.-1-2) where an overhead transmission line would be sited and travel in a southeasterly direction to connect at County Route 48; Approximately 13 utility poles are planned for installation through the easement at a span of±150-180 feet, expected at heights consistent with LIPA's existing transmission infrastructure there (±50'-70' high) b) Minimal realignment of driveway location to Oregon Road and construct/upgrade 20' wide driveway surface to compacted RCA pavement. The driveway extends to connection with created internal roads until it splits for access to BESS Facility, POI Lot or project substation; 2 c) BESS Facility to consist of: i) 272 — battery modules (168sf ea.) within containerized enclosures at 30.7' long, 5.6' wide and 8.6' tall; ii) 34 — medium voltage transformer and inverter units (160sf ea.) located within their own containers to mitigate sound and visual impacts at 19.9' long, 8' wide and 9.5' tall iii) 392sf substation control building iv) Installation of a 12' high visual and sound barrier wall (elevations/details not provided) surrounding the BESS Facility on its north, west and southern sides, chain link (barbed wire) fencing around the perimeter of the BESS installations, project substation and POI substation; v) Landscaping: fourteen (14) planting block patterns are proposed to border the 12' high barrier wall and BESS Facility, each including deciduous plantings at 2 Y2" — 3" caliper, evergreen trees at 6'-7' high, shrubs and seeding. Irrigation numbers are unknown (if proposed) vi) Exterior Li htin twenty-three (23) light poles at 30' high. A photometric plan has been provided but the plans note that the POI Lot will have "lighting by others" —this information is required for the proposed action. d) 2.54acre subdivided Point of Interconnection (POI) lot: i) 55' tall lightning masts (height/ area variance required?) connecting to off- site utility poles ii) 1,OOOsf equipment enclosure iii) POI Substation iv) Lighting "by other" — unknown details as referenced and required above e) Two phase proposed construction: i) Phase 1: 8 — 12 months, Transmission easement work, POI substation, curb cuts/driveway upgrades along Oregon Road and LIPA's road easement to POI substation will be constructed first and will take approximately ii) Phase 2: 6 — 9 months, construction of BESS Facility 3 f) This action will require outside approvals from at least: SCDHS (subdivision), SCWA (proposed water usage), NYSDEC (SWPPP), SCDPW for interconnection to CR 48, Southold Town Board easement, Interconnection Agreement determination from the New York Independent System Operator (NYISO) and the Long Island Power Authority (LIPA) V: Expanded Environmental Assessment provides the following: a) Introduction with project description, intro to KCE (applicant), project purpose and need, site setting, construction schedule, operations and maintenance, decommissioning, permits and approvals. b) Existing Conditions and Potential Impacts Assessment: a. Natural Resources i. Wetlands and Water Resources ii. Threatened and Endangered Species iii. Critical Environmental Areas and Sensitive Habitats b. Noise c. Visual Resources i. Existing Conditions ii. Potential Impacts of the Proposed Action c) LWRP d) Storm water e) Cultural Resources VI: Planning Board items to consider: Find the above referenced site plan application as incomplete for review and require the items detailed above to be submitted before it is processed any further: A minimum of nine (9) revised Site Plans are required including the seal stamp and signature of the NYS licensed professional preparing the plan. Note: a draft electronic site plan (PDF) including the items listed below is encouraged to be submitted to this Department prior to printing multiple copies of the site plan for review efficiency. 4 1. Provide LIPA easement details to provide access over the proposed landlocked parcel; 2. Provide exterior lighting details and any other construction details proposed on the 2.54ac parcel associated with the subject application; 3. Provide boring sample details and test hole location(s); 4. Provide elevations and details for the proposed 12' high wall and surrounding fencing. A clear elevation or rendering of the proposed site at a larger scale would be beneficial for the Board to review the action including Wall Materials/colors/elevations, dimensions, overall site elevation with lightning masts and lighting poles included; 5. Submit application to Zoning Board of Appeals for a "Public Utility" as proposed within documentation and referenced in the Notice of Disapproval 5 Southold Planning Department Checklist for Site Plan Application Completeness - Section 280-133 Project Name: Key Capture Battery Energy Storage System (BESS) Completed by: Brian Cummings Date: July 25, 2022 Received Comment A. Submission of a complete site plan application shall consist of: (1) A completed site plan application form. �l (2) The site plan review fee, as specified in Subsection B $19,289.60 below. Editor's Note: See now § 280-138, Fee schedule for submitted site plan applications. (3) A completed environmental assessment form. FEAF submitted w/ expanded environmental assessment narrative -to be reviewed for adequacy (4) Nine copies of the site plan. (5) Four copies of a property survey, certified by a licensed land surveyor. �l B. Standards. Site plan design shall include the following items: (1) Technical data: (a) The lot, block and section number of the property, taken from the latest tax records. �l (b) The name and address of the landowner on record: �l [1] The names and addresses of adjoining landowners. [2] The name and address of the applicant, if not the same as the landowner. (c) The name and address of the person, firm or organization preparing the map, sealed with the �l applicable New York State license seal and signature. (d) Date, graphic scale and North point, whether true or magnetic; if magnetic, show the date of reading. �l (e) A survey prepared by a licensed surveyor or civil engineer. The site plan may reference a land surveyor's map or base reference map. All distances shall be in feet and hundredths of a foot. All angles shall be given �l to the nearest 10 seconds or closer. The error of closure shall not exceed one in 10,000. (f) The locations, names and widths of all rights-of-way within 500 feet of property lines. If none exist within 500 �l feet of the subject property, indicate the distance to the nearest intersection with a public street. (g) A separate key map showing location and owners of all 1 Checklist for Site Plan Application Completeness Southold Planning Department adjoining lands within 500 feet, as shown on the latest �l tax records, at a scale of one inch equals 100 feet. (h) The location, width and purpose of all existing and proposed easements, setbacks, reservations and areas �l dedicated to public use within or adjoining the property. (i) A complete outline of other existing easements, deed �l restrictions or covenants applying to the property. Q) Existing zoning, including zone lines and dimensions. �l (k) Site plans drawn at the scale of one inch equals 20 feet. If all required information cannot be shown clearly on �l one plan, the information should be separated as follows: [1] Alignment and schedule plan. [2] Grading and drainage. [3] Landscaping. [4] Other, e.g., site utilities. (2) Natural features: Received Comment (a) Existing contours with intervals of two feet or less, referred to mean sea level as per United States �l Geological Survey datum. (b) Boundaries of any areas subject to flooding or stormwater overflows, tidal bays, saltwater marshes, beaches and all freshwater bodies, including wetlands N/A and intermittent streams, perimeter boundaries of shoreline bluffs, dunes and beaches. (c) The location of existing natural features, including but 35 Existing trees not limited to natural drainage swales, watercourses, noted to be wooded areas and wetlands, as defined by the New removed York State Department of Environmental Conservation and the Board of Trustees of Southold Town, marshes, ponds, dunes, bluffs, beaches, kettleholes, escarpments, wildlife habitats, flood hazard areas, erosion-prone areas and trees of six inches in diameter at a point three feet above the trunk base. (d) The location of any existing cultural and historical features within 500 feet of the property boundaries. N/A (3) Existing building structures and utilities: (a) The locations, dimensions and outlines of all buildings, as defined in § 280-4 of this chapter, and all uses of the �l site. (b) Paved areas, including parking areas, sidewalks and vehicular access between the site and public streets. �l (c) The locations, dimensions, grades and flow directions of any existing culverts, waterlines or sewage disposal systems, as well as other underground and �l aboveground utility poles and utility lines within and 2 Checklist for Site Plan Application Completeness Southold Planning Department adjacent to the property. (d) The location and use of all buildings and structures, Not provided including curbcuts, within 200 feet of the boundary of the X subject property. (4) Proposed construction: Received Comment (a) The location of proposed buildings or structural improvements, indicating setbacks from all property �l lines and horizontal distances from existing structures. (b) The location and design of all uses not requiring structures, such as off-street parking and loading areas and pedestrian circulation. (c) The location, direction, power level and time of use for Incomplete for any proposed outdoor lighting or public address X new parcel systems. (d) The location and plans for any outdoor signs must be in None provided accordance with applicable sign regulations. X (e) The location and details of aprons, curbs, sidewalks, Incomplete; test fencing (type and location), and grading, including hole/depth to existing and proposed topography with two-foot groundwater not contours (on site and 200 feet beyond the property line) X provided) and spot elevations for buildings and all structures, drainage calculations, details of drainage structures and watershed areas, where applicable. (f) Grading and drainage plans shall be based upon site Provided but stormwater retention, in conformance with Chapter 161, incomplete; Highway Specifications. SWPPP required (g) The location and listing of landscaping, buffering and street tree plans, including type, material, size, quantity �l and location. (h) The location of water and sewer mains, electrical service, cablevision and telephone installations, ground transformers, fire wells and fire hydrants and/or any �l alternate means of water supply and sewage disposal and treatment. (i) Building elevations for all facades and floor plans ,I Incomplete: wall showing the proposed use of floor area. Materials/colors/ele vations,dimensions, overall site elevation with lightning masts and lighting poles included Notes: N/A = Not Applicable 3 Checklist for Site Plan Application Completeness architects + engineers EC ,/ { ' 538 Broad Hollow Road,41h Floor East EI �/ E® {r0 Melville,NY 11747 1 tel 631.756.8000 JUN 10 2022 June 8, 2022 Sou tiioid Town Planning Board Ms. Heather Lanza, AICP Town Planning Director Southold Town Planning 53095 Route 25 Southold, New York 11971 Re: KCE NY 26—Site Plan Application SCTM; 1000-083-03-6.1 1-12M Project No: KCEG 2101 Dear Ms. Lanza: On behalf of Key Capture Energy (KCE), H2M architects + engineers (1-12M) present this letter along with the enclosed Site Plan Application for KCE NY 26(the"Project"). KCE is proposing to construct and operate an approximately 60-megawatt battery energy storage system (BESS)on the referenced parcel. As stated in the Notice of Disapproval issued by the Town of Southold Building Department, dated April 13, 2022,the proposed use and subdivision of the lot require site plan approval from the Southold Town Planning Board. In connection with this application, enclosed please find the following: 1. Site Plan Application Form appended with Transactional Disclosure Forms, Authorization Affidavit and Applicant's Affidavit(1 original and 8 copies) 2. Application Fee Check No. 8647 in the amount of$19,289.60 3. Notice of Disapproval from the Building Department, dated April 13, 2022 (9 copies) 4. Expanded Environmental Assessment appended with FEAF Part I, LWRP Consistency Assessment Form and Noise Study, prepared by H2M, dated May 2022 (1 copy) 5. Proof of Lot Recognition— 1960 Deed—L 4820 P 362 (9 copies) 6. Survey prepared by H2M, dated May 12, 2021 (4 copies) 7. Site Development Plan Package including Grading & Drainage Plans, Landscape Plan, and Lighting Plan prepared by H2M, dated June 6, 2022 (9 copies) 8. Elevations Drawings of the BESS containers obtained from the Manufacturer and Substation General Arrangement Plans and Elevations prepared by Reynolds Architecture Engineering last revised January 27, 2022 (2 copies) 9. Site Photographs from Adjacent Properties and Roads (2 copies) Should you have questions or require further information, please feel free to contact our office at (631) 756-8000 extension 1715. Very truly yours, 1-12M r-c-hi cts + engineers Ichardson, P.E. Department Manager—Civil Engineering cc: Phil Denara—Key Capture Energy, LLC John Anzalone—Harris Beach, PLLC \\h2m.com\shares\Projects\KCEG(Key Capture Energy)\KCEG 2001 (NY 21)\02-Permitting\TOH\ZBA\22-0603 Submission\22-0603 Cover Letter.docx 1-12M Architects, Engineers, Land Surveying and Landscape Architecture, DPC(NY)offers its services in NY only 1-12M Architects &Engineers, Inc. (NJ)offers its services in NJ, CT, MA, PA,VA only 1-12M Associates, Inc. (NJ)offers its engineering, land surveying, landscape architecture services in NJ only h2m.com SOUTHOLD PLANNING BOARD RECEIVED SITE PLAN APPLICATION FORM JUN 10 2022 Site Plan Name and Location Southold Town Planning Board Site Plan Name: KCE NY 26 Application Date: Q'S Suffolk County Tax Map#1000- 083.00 _ 03.00 006.001 Other SCTM#s Street Address: 10750 Oregon Road Hamlet: cutchogue Distance to nearest intersection: 790 feet(Dignans Road to the east) Type of Site Plan: X New Amended Residential Zoning District LI Owners/Agent Contact Information Please list name, mailing address, and hone number for the people belotiv: Property Owner F. Mcbrides & Sons LLC Street 10415 Oregon Road City Cutchogue State NY Zip 11935 Home Telephone (631)-734-6807 Other Applicant KCE NY 26, LLC Street 25 Monroe St, Suite 300 City Albany State NY Zip 12210 Home Telephone N/A Other Office - (516)-279-2955 Applicant's Agent or Representative: Contact Person(s)" Philip Denara Street 25 Monroe St, Suite 300 City Albany State NY Zip 12210 Office Telephone (516)-279-2955 Other "Unless otherwise requested, correspondence will be sent only to the contact person noted here. Site Plan Application Form 2118/2010 Site Data Proposed construction type: X New Modification of Existing Structure Agricultural Change of use Property total acreage or square footage: 27.04 Ac. ac./sq. ft. Site Plan build-out acreage or square footage: 11.0 Ac, ac./sq. ft. Is there an existing or proposed Sale of Development Rights on the property? Yes No If yes, explain: Does the parcel(s) meet the Lot Recognition standard in Town Code §280-9 Lot Recognition? Y X N * If"yes", explain (and attach any necessary documentation—title report, subdivision approval, etc.) * Note: Site will be subdivided pursuant to an application being filed for Subdivision approval concurrently herewith. Building Department Notice of Disapproval Date: 04 / 06 / 2022 ; revised 04/13/2022 Is an application to the Southold Town Zoning Board of Appeals required? Yes X No If yes, have you submitted an application to the ZBA? Yes X No If yes, attach a copy of the application packet. Show all uses proposed and existing. Indicate which building will have which use. If more then one use is proposed per building, indicate square footage of floor area per use. List all existing property uses: agricultural land/.farming List all proposed property uses: Battery Energy Storage System, project substation and LIPA substation. Other accessory uses: Existing lot coverage: ° % Proposed lot coverage: 4.49 % Gross floor area of existing structure(s): 0 sq. ft. Gross floor area of proposed structure(s): 52,896 sf Parlung Space Data: #of existing spaces: 0 #of proposed spaces: 0 Loading Berth: Yes No Landscaping Details: Existing landscape coverage: 0* % Proposed landscape coverage: 16.5* *For the purposes of the Landscape Details calculations above,areas of agricultural use have not been included in the landscape covera es. Wetlands: Is this property within 500' of a wetland area? Yes No X Maybe I, the undersigned, certify that all the abo e information is true. 71 Signature ofPreparer. Date: 2 Site Plan Application Fora 2/18/2010 Southold Planning Department Applicant Transactional Disclosure Form The Town of Southold's Code of Ethics prohibits conflicts of interest on the part of town officers and employees. The purpose of this form is to provide information which can alert the town of possible conflicts of interest and allow it to take whatever action is necessary to avoid same. Your Name: ()Z(\01f Last,First,middle initial unless you are applying in the name of someone else or other entity, such as a company. If so, indicate the other person's or company's name. Nature of Application: (Check all that apply) / Subdivision or Re-subdivision Site Plan J Other(Please name other activity) Do you personally(or through your company,spouse,sibling,parent or child)have a relationship with any officer or employee of the Town of Southold? "Relationship includes by blood,marriage or business interest. "Business interest"means a business, including a partnership,in which the town officer or employee has even a partial ownership of(or employment by)a corporation in which the town officer or employee owns more than 5%of the shares. Yes NOY If you answered"Yes"complete the balance of this form and date and sign where indicated. Name of the person employed by the Town of Southold Title or position of that person Describe the relationship between yourself(the applicant)and the town officer or employee. Either check the appropriate line A through D and/or describe in the space provided. The town officer or employee or his or her souse,sibling,parent or child is(check all that apply): A.the owner of greater than 5%of the shares of the corporate stock of the applicant(when the applicant is a corporation); B. the legal or beneficial owner of any interest in a noncorporate entity(when the applicant is not a corporation); C. an officer,director,partner or employee of the applicant;or D.the actual applicant Description of Relationship: Submitted this I 1 day of 01.'j Signature Print Name I ` 1 l ) OOn�r�l Disclosure Form .l cM Southold Planning Department Applicant Transactional Disclosure Form The Town of Southold's Code of Ethics prohibits conflicts of interest on the part of town officers and employees. The purpose of this form is to provide information which can alert the town of possible conflicts of interest and allow it to take whatever action is necessary to avoid same. Your Name: F. McBride & Sons, LLC Last,First,middle initial unless you are applying in the name of someone else or other entity, such as a company. If so, indicate the other person's or company's name. Nature of Application: (Check all that apply) Subdivision or Re-subdivision V Site Plan V Other(Please name other activity) Do you personally(or through your company,spouse,sibling,parent or child)have a relationship with any officer or employee of the Town of Southold? "Relationship includes by blood,marriage or business interest. "Business interest"means a business,including a partnership,in which the town officer or employee has even a partial ownership of(or employment by)a corporation in which the town officer or employee owns more than 5%of the shares. Yes No X If you answered"Yes"complete the balance of this form and date and sign where indicated. Name of the person employed by the Town of Southold Title or position of that person Describe the relationship between yourself(the applicant)and the town officer or employee. Either check the appropriate line A through D and/or describe in the space provided. The town officer or employee or his or her souse,sibling,parent or child is(check all that apply): A.the owner of greater than 5%of the shares of the corporate stock of the applicant(when the applicant is a corporation); B.the legal or beneficial owner of any interest in a noncorporate entity(when the applicant is not a corporation); C.an officer,director,partner or employee of the applicant;or D.the actual applicant Description of Relationship: th April Submitted this 25 day of 2022 �j r Signature�l'''Y'e-e� Print Name James M. McBride Disclosure Form .i Authorization Affidavit I,James M. McBride/Manager of F. McBride &Sons LLC,owner of the property identified as SCTM# 1000-083.00-03.00-006.001 in Cutchogue, NY, hereby authorize Philip Denara, acting on behalf of KCE NY 26, LLC,to apply for a subdivision and site plan on our property and hire any agents necessary to complete the work involved in the subdivision and site plan application process with the Southold Planning Board. {� r Signature ` `' /�,/ /�/ Sworn before me this 25th day of April 20 22 &iat4- [Notary Stamp] BARBARA DIACHUN Notary Public, State of New York No 01 D14635190-Suffolk County Commission Expires Oct.31,20'?-")- APPLICANT'S AFFIDAVIT APPLICANT'S AFFIDAVIT STATE OF NEW YORK COUNTY OF SUFFOLK . Pki 110 ORr\of c being duly sworn, deposes and says that he resides at Monf 0e. A-_ J Ae— 20o AL6, in the State of New York, and that he is the owner of property located at ��'cp` 10�o Ofiz ion P0CA , SCTM#O$3.M - d3.00 - , or that he is the Atjk) (&-aa k caQA-� of the (y\C('�V49- T <')0y\:S �_L c , (Title) (Specify whether Partnership or Corp.) and said Corporation is the owner of the above property, which is hereby making a Site Plan application; that there are not existing structures or improvements on the land which are not shown on the Site Plan; that the title to the entire parcel, including all rights-of-way,has been clearly established and is shown on said Plan; that no part of the Plan infringes upon any duly filed plan which has not been abandoned both as to lots and as to roads; that he has examined all rules and regulations adopted by the Planning Board for the filing of Site Plans and will comply with same; that the plans submitted, as approved, will not be alter or changed in any manner without the approval of the Planning Board; and that the actual physical improvements-will be installed in strict accordance with the plan as approved by the Planning Board. Signed Owner Signed (Pa er or C(rporate Officer and Title) Sworn to me this EGN'otaryELLI LYNNE RAMIID#132322day of , LQ�� y Commission ExJanuary 21,202'] Notary Public FORM NO.3 RECEIVED TOWN OF SOUTHOLD JUN 10 822 BUILDING DEPARTMENT South old Town SOUTHOLD,N.Y. Pl8nning Board NOTICE OF DISAPPROVAL DATE: April 6, 2022 REVISED: April 13, 2022 TO: Phil Denara,KCE NY 26 LLC (F. McBride& Sons LLQ 25 Monroe Street, Suite 300 Albany,NY 12210 Please take notice that your application dated December 17, 2021: For permit to: Construct a",new Battery Energy Storage Facility.and:to's'ukill,vhd_e__.,.'ffie"_ existinparcel at: Location of property: ---!'-07-5-0OregonRoad..,',iC-.uie-hoaue.,"-N,Y,.' County Tax Map No. 1000—Section 83 Block 3., Lot 6.1,; Is returned herewith and disapproved on the following grounds: Pursuant to.Article-MU Section 28'0127;the proposed use and subdivision of lob.: require site plan approval from the Southold Town Planning Board. 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Main Rd.&Youngs Ave.) , t ; ;i Telephone: 631-765-1938 Southold,NY ,V www.southoldtownny.gov PLANNING BOARD OFFICE TOWN OF SOUTHOLD MEMORANDUM To: Accounting From: Planning Department Date: June 13, 2022 Re: Check Please deposit the attached check into B691: Deferred Revenue. Fee is for a Site Plan Application not yet accepted by the Planning Board. Applicant/Project Name & Type Tax Map # Amount Check Date/No. Key Capture Energy Battery Storage 83-3-6.1 $19,289.60 5/18/22 - #8647 Site Plan Key Capture Energy 1 �. Bank,ofAmerica. 8647 ".., - KEY/CAPTURE Key Capture Energy, Inc. ACHR/r111000025 ®' EN E'RGY 25 Monroe St.,3rd Floor 35-2/1130 Albany,.NY 12210 5/18/2022 0 PAYE THE, Town of Southold ORDER oF. **19,289.60 ° Nin6teen Thousand Two•Huhdred Eighty-Nine and 60/100********.******'*********************************************** • DOLLARS -Town of Southold` MEMO ,� KCe NY 26 Site Plan Appllcatlon SIMIg..RI�E. 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