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FIBER OPTIC SUBMARINE CABLE SYSTEM EXPANDED ENF ERM One Beacon Street,5th Floor [Telephone: +1 617 646 7800 Boston,MA 02108 Fax: +1 617 267 6447 www.erm.com RECEIVED JUN 1"01019 17 June 2019 CITY OF SALEM Ms. Deirdre Buckley, Director BOARD OF HEALTH Massachusetts Environmental Policy Act Office ERM 100 Cambridge Street, Suite 900 Boston, MA 02114 Reference: 0497639 Subject: Amitie Fiber Optic Submarine Cable System Expanded Environmental Notification Form Dear Ms. Buckley, Environmental Resources Management(ERM) is pleased to provide the attached Expanded Environmental Notification Form (EENF)for the proposed Amitie Fiber Optic Submarine Cable System (Project or Amitie). This EENF is prepared in accordance with the Massachusetts Environmental Policy Act(MEPA)for publication on June 26, 2019 in the Environmental Monitor. Amitie is a proposed subsea cable system in the Atlantic Ocean that will link the countries of the United States, France, and United Kingdom. The Project will install approximately 29.4 continuous miles of up to 1.5-inch diameter fiber optic cable in Massachusetts state waters across eight municipal boundaries. These municipalities are Rockport, Gloucester, Manchester-by-the-Sea, Beverly, Salem, Marblehead, Swampscott, and Lynn. A small temporary workspace is also proposed on-shore in Nahant. The Project will utilize existing conduit and infrastructure to route the cable from 0.8 miles offshore to an existing on-shore data center located in Lynn, MA. The existing conduit was installed in the early 2000s specifically for the purpose of future cable installation such as Amitie. Subject to receipt of required approvals and permits, Project construction is scheduled to commence in fall 2020. The Project is anticipated to be in operation by the end of the first quarter of 2021. Once operational, the Amitie submarine cable will deliver enhanced bandwidth and reliability to telecommunications services and content-based services between North America and Europe. The temporary impacts of cable installation would be confined to a narrow corridor along the proposed cable route in Massachusetts waters. The cable installation within Land Under the Ocean is anticipated to temporarily disturb greater than 10 acres cumulatively, thereby exceeding the MEPA threshold pursuant to 301 CMR 11.03 (3) (a) 1.b. No other MEPA review thresholds identified in 301 CMR 11.03 are known to be exceeded by this Project. Upon review of this EENF, if the Secretary of Energy and Environmental Affairs requires an Environmental Impact Report(EIR)for this Project, we respectfully request that the Secretary allow a single EIR be prepared in accordance with 301 CMR 11.06(8) due to the minor and temporary nature of the proposed environmental impacts. Additionally, we respect that the Secretary consider this Project to qualify for the de minimis exemption from the MEPA Greenhouse Gas Emissions Policy and Protocol. Page 1 of 2 ERM 17 June 2019 Reference:0497639 Page 2 of 2 ERM looks forward to coordinating with you on this Project. Should you have any questions or concerns, please contact Christina Hoffman at 978-857-9334 or email at christina.hoffman@erm.com. Sincerely, Christina C. Hoffman Principal Consultant Enclosures: Expanded Environmental Notification Form Appendix A: Expanded Environmental Notification Project Narrative Appendix B: Figures Appendix C: Permit Table Appendix D: ENF Circulation List Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs Massachusetts Environmental Policy Act (MEPA) Office Environmental Notification Form For Office Use Only EEA#: MEPA Analyst: The information requested on this form must be completed in order to submit a document electronically for review under the Massachusetts Environmental Policy Act, 301 CMR 11.00. Project Name: Amitie Submarine Cable System Street Address: 91 Commercial St.; Lynnway Roundabout; and Atlantic Ocean Municipality: Lynn, Nahant, Swampscott, Watershed: Charles (HUC 8 01090001) Marblehead, Salem, Beverly, Manchester, Gloucester, Rockport, MA Universal Transverse Mercator Coordinates: Latitude: N 42.457073 UTM Zone 19 T Longitude: W -70.936601 340765m E, 4702343 M N Estimated commencement date: Fall 2020 Estimated completion date: Fall 2020 Project Type: Utility Status of project design: 75% Proponent: Edge Cable Holdings USA, LLC Street Address: 1601 Willow Road Municipality: Menlo Park State: CA I Zip Code: 94025_-14_52 Name of Contact Person: Christina Hoffman Firm/Agency: ERM Street Address: 1 Beacon Street, 5th Fir. Municipality: Boston State: MA I Zip Code: 02108 Phone: 978 857 9334 1 Fax: E-mail: Christina.Hoffman@erm.com Does this project meet or exceed a mandatory EIR threshold (see 301 CMR 11.03)? ®Yes ❑No If this is an Expanded Environmental Notification Form (ENF) (see 301 CMR 11.05(7)) or a Notice of Project Change (NPC), are you requesting: a Single EIR? (see 301 CMR 11.06(8)) ®Yes ❑No a Special Review Procedure? (see 301CMR 11.09) ❑Yes ®No a Waiver of mandatory EIR? (see 301 CMR 11.11) ❑Yes ®No a Phase I Waiver? (see 301 CMR 11.11) ❑Yes ®No (Note: Greenhouse Gas Emissions analysis must be included in the Expanded ENF.) Which MEPA review threshold(s) does the project meet or exceed (see 301 CMR 11.03)? 301 CMR 11.03 (3)(a)(1)(b) and (3)(b)(3) Which State Agency Permits will the project require? 401 Water Quality Certification, Chapter 91 License, Chapter 91 Permit, Coastal Zone Consistency Review, Special Use Permit (BUAR) Identify any financial assistance or land transfertrom an Agency of the Commonwealth, including the Agency name and the amount of funding or land area in acres: NIA Effective January 2011 Summary of Project Size Existing Change Total & Environmental Impacts 1 Total site acreage 1.11 onshore,and the Atlantic Ocean New acres of land altered 0.01 (onshore) Acres of impervious area 0 0 a Square feet of new bordering 0 vegetated wetlands alteration Square feet of new other wetland 41.3 acres(offshore) alteration (1,800,000 sq ft) temporary Acres of new non-water dependent use of tidelands or waterways ° Gross s q uare footage NIA NiA NIA 9 Number of housing units NIA N/A N/A Maximum height (feet) NIA N/A N/A TRANSPORTATION Vehicle trips per day NIA NIA NSA Parking spaces NIA N/A N/A WASTEWATER Water Use (Gallons per day) WA N/A NIA Water withdrawal (GPD) NIA N/A N/A Wastewater generation/treatment NIA N/A N/A (GPD) Length of water mains (miles) NIA N/A N/A Length of sewer mains (miles) N/A N/A NIA Has this project been filed with MEPA before? ❑ Yes (EEA# ) ®No Has any project on this site been filed with MEPA before? ® Yes (EEA# 12026 ) ❑No -2- GENERAL PROJECT INFORMATION — all Proponents must fill out this section Environmental Resources Management (ERM) submits this Expanded Environmental Notification Form (EENF) for the Amitie Submarine Cable System (Project). The system includes a subsea cable that will extend from Bude, Cornwall, United Kingdom and Bordeaux, France, to the City of Lynn, Massachusetts (Figure 1). The cable landing in Massachusetts will utilize an existing conduit that extends approximately 0.8 miles from the shore, with the remaining 28.6 miles of cable in Massachusetts waters proposed to be installed using a marine plow towed by an installation vessel resulting in only temporary impacts to Land Under the Ocean. On land, the cable will be routed through existing conduits in the City of Lynn to an existing data center located at 91 Commercial Street. AREAS OF CRITICAL ENVIRONMENTAL CONCERN: Is the project within or adjacent to an Area of Critical Environmental Concern? []Yes (Specify) ®No if yes, does the ACEC have an approved Resource Management Plan? If yes, describe how the project complies with this plan. Will there be stormwater runoff or discharge to the designated ACEC? ❑ Yes ® No; If yes, describe and assess the potential impacts of such stormwater runoff/discharge to the designated ACEC. RARE SPECIES: Does the project site include Estimated and/or Priority Habitat of State-Listed Rare Species? (see http://www.mass.gov/dfwele/dfw/nhesp/regulatory_review/priority_habitat/priority_habitat home.htm) ®Yes(Crossings EH1081 and PH1519) ❑No HISTORICAL/ARCHAEOLOGICAL RESOURCES: Does the project site include any structure, site or district listed in the State Register of Historic Place or the inventory of Historic and Archaeological Assets of the Commonwealth? ®Yes (Specify) ❑No If yes, does the project involve any demolition or destruction of any listed or inventoried historic or archaeological resources? ❑Yes (Specify) ®No WATER RESOURCES: Is there an Outstanding Resource Water(ORW)on or within a half-mile radius of the project site? ❑Yes® No; if yes, identify the ORW and its location. (NOTE: Outstanding Resource Waters include Class A public water supplies, their tributaries, and bordering wetlands, active and inactive reservoirs approved by MassDEP,certain waters within Areas of Critical Environmental Concern, and certified vernal pools. Outstanding resource waters are listed in the Surface Water Quality Standards, 314 CMR 4.00.) Are there any impaired water bodies on or within a half-mile radius of the project site? ® Yes ❑ No; if yes, identify the water body and pollutant(s)causing the impairment: Nahant Bay(MA93-24) Coliform category 4A Fecal Is the project within a medium or high stress basin, as established by the Massachusetts Water Resources Commission? ❑Yes ® No STORMWATER MANAGEMENT: Generally describe the project's stormwater impacts and measures that the project will take to comply with the standards found in MassDEP's Stormwater Management Regulations: The project is primarily located under the ocean, with no potential for stormwater impacts. The small portion of work proposed on land consists of placing a winch truck over an existing manhole to pull the -3- cable through an existing conduit as well as the installation of grounding rods within an existing disturbed industrial facility. No new impervious surface will be created. MASSACHUSETTS CONTINGENCY PLAN: Has the project site been, or is it currently being, regulated under M.G.L.c.21 E or the Massachusetts Contingency Plan? ❑Yes ® No; if yes, please describe the current status of the site (including Release Tracking Number (RTN), cleanup phase, and Response Action Outcome classification):_ Is there an Activity and Use Limitation (AUL)on any portion of the project site? ❑Yes ® No; if yes, describe which portion of the site and how the project will be consistent with the AUL: Are you aware of any Reportable Conditions at the property that have not yet been assigned an RTN? ❑Yes ® No; if yes, please describe:_ SOLID AND HAZARDOUS WASTE: If the project will generate solid waste during demolition or construction, describe alternatives considered for re-use, recycling, and disposal of, e.g., asphalt, brick, concrete, gypsum, metal, wood: No substantial solid waste will be generated by the project. (NOTE:Asphalt pavement, brick, concrete and metal are banned from disposal at Massachusetts landfills and waste combustion facilities and wood is banned from disposal at Massachusetts landfills. See 310 CMR 19.017 for the complete list of banned materials.) Will your project disturb asbestos containing materials? ❑Yes ® No; if yes, please consult state asbestos requirements at htt ://mass. ov/MassDEP/air/asbhom01.htm Describe anti-idling and other measures to limit emissions from construction equipment: Construction will mostly utilize a marine vessel that will be moving at a slow speed. Limited construction equipment will be needed to pull the cable through the existing conduits. DESIGNATED WILD AND SCENIC RIVER: Is this project site located wholly or partially within a defined river corridor of a federally designated Wild and Scenic River or a state designated Scenic River? ❑Yes ® No; if yes, specify name of river and designation: If yes, does the project have the potential to impact any of the`outstandingly remarkable" resources of a federally Wild and Scenic River or the stated purpose of a state designated Scenic River? ❑Yes ❑ No; if yes, specify name of river and designation: if yes,will the project will result in any impacts to any of the designated "outstandingly remarkable" resources of the Wild and Scenic River or the stated purposes of a Scenic River. El Yes ❑ No; if yes, describe the potential impacts to one or more of the`outstandingly remarkable" resources or stated purposes and mitigation measures proposed. -4- ATTACHMENTS: 1. List of all attachments to this document. Appendix A—Project Narrative Appendix B—Figures Appendix C—Permit Table Appendix D—ENF Circulation List 2. U.S.G.S. map (good quality color copy, 8-%2 x 11 inches or larger, at a scale of 1: 24,000) indicating the project location and boundaries. See Appendix B 3. Plan, at an appropriate scale, of existing conditions on the project site and its immediate environs, showing all known structures, roadways and parking lots, railroad rights-of-way, wetlands and water bodies, wooded areas, farmland, steep slopes, public open spaces, and major utilities. See Appendix B 4. Plan, at an appropriate scale, depicting environmental constraints on or adjacent to the project site such as Priority and/or Estimated Habitat of state-listed rare species, Areas of Critical Environmental Concern, Chapter 91 jurisdictional areas, Article 97 lands, wetland resource area delineations, water supply protection areas, and historic resources and/or districts. See Appendix B 5. Plan, at an appropriate scale, of proposed conditions upon completion of project(if construction of the project is proposed to be phased, there should be a site plan showing conditions upon the completion of each phase). Due to the temporary nature of the work, and the expectation that the new fiber optic cable will be buried, post-construction conditions are intended to be similar to pre- construction conditions. 6. List of all agencies and persons to whom the proponent circulated the ENF, in accordance with 301 CMR 11.16(2). See Appendix D 7. List of municipal and federal permits and reviews required by the project, as applicable. See Appendix B -s- LAND SECTION - all proponents must fill out this section I. Thresholds/Permits A. Does the project meet or exceed any review thresholds related to land (see 301 CMR 11.03(1) ❑Yes ® No; if yes, specify each threshold: ll. Impacts and Permits A. Describe, in acres, the current and proposed character of the project site, as follows: Existinq Chancre Total Footprint of buildings 0 0 0 Internal roadways 0 0 0 Parking and other paved areas 0 0 0 Other altered areas 0.01 0 0.01 Undeveloped areas Atlantic Ocean 0 0 Total: Project Site Acreage 0.01 0 0.01 B. Has any part of the project site been in active agricultural use in the last five years? ❑ Yes ® No; if yes, how many acres of land in agricultural use (with prime state or locally important agricultural soils)will be converted to nonagricultural use? C. Is any part of the project site currently or proposed to be in active forestry use? ❑ Yes ® No; if yes, please describe current and proposed forestry activities and indicate whether any part of the site is the subject of a forest management plan approved by the Department of Conservation and Recreation: D. Does any part of the project involve conversion of land held for natural resources purposes in accordance with Article 97 of the Amendments to the Constitution of the Commonwealth to any purpose not in accordance with Article 97? ❑Yes ® No; if yes, describe: The cable-pulling zone is located around an existing manhole,within the roundabout located at the intersection of Lynnway(State Route 1A)and Lynn Shore Drive. The Roundabout is located within Massachusetts Department of Conservation and Recreation Land. Prior to construction, a Construction Access Permit will be obtained, if necessary. No conversion of the land is proposed since the infrastructure necessary to house the cable is existing. E. Is any part of the project site currently subject to a conservation restriction, preservation restriction, agricultural preservation restriction or watershed preservation restriction ❑ Yes ® No; if yes, does the project involve the release or modification of such restriction? ❑ Yes ® No; if yes, describe: F. Does the project require approval of a new urban redevelopment project or a fundamental change in an existing urban redevelopment project under M.G.L.c.121A? ❑ Yes ® No; if yes, describe: G. Does the project require approval of a new urban renewal plan or a major modification of an existing urban renewal plan under M.G.L.c.121 B? ❑Yes ® No; if yes, describe: III. Consistency A. Identify the current municipal comprehensive land use plan Title: Lynn Open Space and Recreation Plan Date: June 2016 -6- Title: Nahant Open Space and Recreation Master Plan Date: November 2016 B. Describe the project's consistency with that plan with regard to: 1)economic development 2)adequacy of infrastructure 3)open space impacts 4)compatibility with adjacent land uses The Lynn Open Space and Recreation Plan(Plan)was published in June 2016 by the City of Lynn Office of Economic and Community Development. The document outlines the current state of open land and recreational areas, identifies issues,and establishes goals on open space. Lynn is largely urbanized. As a result, the Plan emphasizes the need to protect open space and recreational areas. The Project is consistent with these goals since the Project will have no impact to open space and recreational areas. The Project is also not anticipated to conflict with the Nahant Open Space and Recreation Master Plan (November 2016). The Nahant Plan inventories the current areas of open space within the town and provides recommendations to maximize public access.A portion of the roundabout median is located in Nahant.Only during cable installation will temporary construction fencing and vehicle parking be required. C. Identify the current Regional Policy Plan of the applicable Regional Planning Agency(RPA) RPA: RPA: Metropolitan Area Planning Council Title: Metro Future: Making a Greater Boston Region Date: May 2008 D. Describe the project's consistency with that plan with regard to: 1) economic development 2) adequacy of infrastructure 3) open space impacts The MetroFuture Plan identifies six areas that are integral to growth and development of the region. These areas include sustainable growth patterns, housing choices, community vitality,prosperity,getting around,and energy,air,water and wildlife.The Project will deliver enhanced bandwidth availability for telecommunications services and content-based services between North America and Europe, enhancing the Greater Boston areas position as a technology hub for the United States. -7- RARE SPECIES SECTION I. Thresholds/ Permits A. Will the project meet or exceed any review thresholds related to rare species or habitat(see 301 CMR 11.03(2))? ❑ Yes ® No; if yes, specify, in quantitative terms: (NOTE:If you are uncertain, it is recommended that you consult with the Natural Heritage and Endangered Species Program (NHESP)prior to submitting the ENF.) B. Does the project require any state permits related to rare species or habitat? ❑Yes ® No C. Does the project site fall within mapped rare species habitat(Priority or Estimated Habitat?) in the current Massachusetts Natural Heritage Atlas (attach relevant page)? ® Yes ❑ No D. If you answered "No"to all questions A, B and C, proceed to the Wetlands,Waterways, and Tidelands Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Rare Species section below. II. Impacts and Permits A. Does the project site fall within Priority or Estimated Habitat in the current Massachusetts Natural Heritage Atlas (attach relevant page)? ® Yes ❑ No If yes, 1. Have you consulted with the Division of Fisheries and Wildlife Natural Heritage and Endangered Species Program (NHESP)? ® Yes ❑ No; if yes, have you received a determination as to whether the project will result in the"take"of a rare species? ❑ Yes® No; if yes, attach the letter of determination to this submission. 2. Will the project"take" an endangered, threatened, and/or species of special concern in accordance with M.G.L. c.131A(see also 321 CMR 10.04)? ❑ Yes ® No; if yes, provide a summary of proposed measures to minimize and mitigate rare species impacts 3. Which rare species are known to occur within the Priority or Estimated Habitat? EH1081 and PH1519 4. Has the site been surveyed for rare species in accordance with the Massachusetts Endangered Species Act? ❑ Yes ® No 5. If your project is within Estimated Habitat, have you filed a Notice of Intent or received an Order of Conditions for this project? ❑ Yes ® No; if yes, did you send a copy of the Notice of Intent to the Natural Heritage and Endangered Species Program, in accordance with the Wetlands Protection Act regulations? ❑ Yes ® No A copy of the NOI will be provided to the Natural Heritage and Endangered Species Program. B. Will the project"take"an endangered, threatened, and/or species of special concern in accordance with M.G.L. c.131A(see also 321 CMR 10.04)? ❑ Yes ® No; if yes, provide a summary of proposed measures to minimize and mitigate impacts to significant habitat: -8- WETLANDS WATERWAYS AND TIDELANDS SECTION I. Thresholds/Permits A. Will the project meet or exceed any review thresholds related to wetlands, waterways, and tidelands (see 301 CMR 11.03(3))? ® Yes ❑ No; if yes, specify, in quantitative terms: The Project will result in the use of a plow to bury approximately 28.6 miles of fiber optic cable in Massachusetts state waters,with an approximate temporary disturbance of 41.3 acres. B. Does the project require any state permits (or a local Order of Conditions) related to wetlands, waterways, or tidelands? ®Yes ❑ No; if yes, specify which permit: 401 Water Quality Certification, Chapter 91 License, Chapter 91 Permit, Coastal Zone Consistency Review C. If you answered "No"to both questions A and B, proceed to the Water Supply Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Wetlands, Waterways, and Tidelands Section below. II.Wetlands Impacts and Permits A. Does the project require a new or amended Order of Conditions under the Wetlands Protection Act (M.G.L. c.131A)? ® Yes ❑ No; if yes, has a Notice of Intent been filed? ❑ Yes ® No; if yes, list the date and MassDEP file number: ; if yes, has a local Order of Conditions been issued? ❑ Yes ® No; Was the Order of Conditions appealed? ❑Yes ® No. Will the project require a Variance from the Wetlands regulations? ❑ Yes ® No B. Describe any proposed permanent or temporary impacts to wetland resource areas located on the project site: No permanent impacts to wetland resource areas are proposed. Land under the Ocean is the only resource area to be temporarily impacted by the burying of a 1.5-inch wide cable in a trench created by a barge towing a plow. The target burial depth for the cable is approximately 4 to 6 feet; therefore, no permanent changes to the seabed are expected. C. Estimate the extent and type of impact that the project will have on wetland resources, and indicate whether the impacts are temporary or permanent: Coastal Wetlands Area (square feet)or Temporary or Length (linear feet) Permanent Impact? Land Under the Ocean 151,008 ft 128.6 miles) Temporary Designated Port Areas Coastal Beaches Coastal Dunes Barrier Beaches Coastal Banks Rocky Intertidal Shores Salt Marshes Land Under Salt Ponds Land Containing Shellfish Fish Runs _ Land Subject to Coastal Storm Flowage Staging equipment only (0 sq ft)Temporary Inland Wetlands Bank(If) Bordering Vegetated Wetlands Isolated Vegetated Wetlands Land under Water Isolated Land Subject to Flooding Bordering Land Subject to Flooding Riverfront Area D. Is any part of the project: -9- 1. proposed as a limited project? ® Yes ❑ No; if yes, what is the area (in sf) Entire 1,800,000 square feet 2. the construction or alteration of a dam? ❑ Yes ® No; if yes, describe: 3. fill or structure in a velocity zone or regulatory floodway? ❑Yes ® No 4. dredging or disposal of dredged material? ® Yes ❑ No; if yes, describe the volume of dredged material and the proposed disposal site: 23,500 cy backfilled in same location 5. a discharge to an Outstanding Resource Water(ORW) or an Area of Critical Environmental Concern (ACEC)? ❑Yes ® No 6. subject to a wetlands restriction order? ❑ Yes ® No; if yes, identify the area (in sf): 7. located in buffer zones? ❑ Yes ® No; if yes, how much (in sf). E. Will the project: 1. be subject to a local wetlands ordinance or bylaw? ® Yes ❑ No 2. alter any federally-protected wetlands not regulated under state law? ❑ Yes ® No; if yes,what is the area (sf)? III.Waterways and Tidelands Impacts and Permits A. Does the project site contain waterways or tidelands (including filled former tidelands)that are subject to the Waterways Act, M.G.L.c.91? ® Yes ❑ No; if yes, is there a current Chapter 91 License or Permit affecting the project site? ® Yes ❑ No; if yes, list the date and license or permit number and provide a copy of the historic map used to determine extent of filled tidelands: License No. 8458 B. Does the project require a new or modified license or permit under M.G.L.c.91? ®Yes ❑ No; if yes, how many acres of the project site subject to M.G.L.c.91 will be for non-water-dependent use? Current 0 Change 0 Total 0 If yes, how many square feet of solid fill or pile-supported structures (in sf)? No fill or pile-supported structures are proposed. The fiber optic cable will be buried under the seafloor. C. For non-water-dependent use projects, indicate the following: Area of filled tidelands on the site: NIA Area of filled tidelands covered by buildings: NIA For portions of site on filled tidelands, list ground floor uses and area of each use: NIA Does the project include new non-water-dependent uses located over flowed tidelands? ❑Yes ® No Height of building on filled tidelands NIA Also show the following on a site plan: Mean High Water, Mean Low Water, Water- dependent Use Zone, location of uses within buildings on tidelands, and interior and exterior areas and facilities dedicated for public use, and historic high and historic low water marks. D. Is the project located on landlocked tidelands? ❑ Yes ® No; if yes, describe the project's impact on the public's right to access, use and enjoy jurisdictional tidelands and describe measures the project will implement to avoid, minimize or mitigate any adverse impact: E. Is the project located in an area where low groundwater levels have been identified by a municipality or by a state or federal agency as a threat to building foundations? ❑ Yes ® No; if yes, describe the project's impact on groundwater levels and describe measures the project will implement to avoid, minimize or mitigate any adverse impact: F. Is the project anon-water-dependent and located on landlocked tidelands or waterways or - 10- tidelands subject to the Waterways Act and subject to a mandatory EIR? ❑ Yes ® No; (NOTE:If yes, then the project will be subject to Public Benefit Review and Determination.) G. Does the project include dredging? ® Yes ❑ No; if yes, answer the following questions: What type of dredging? Improvement_Maintenance_Temporary trenching for 1.5-inch cable installation with immediate backfill in same location What is the proposed dredge volume, in cubic yards (cys) 23.500 What is the proposed dredge footprint 151.008_length (ft)0.7 width (ft)6 depth (ft); Will dredging impact the following resource areas? Intertidal ❑Yes ® No; if yes, sq ft Outstanding Resource Waters ❑ Yes ® No; if yes,_sq ft Other resource area (i.e. shellfish beds, eel grass beds)❑Yes® No; if yes sq ft If yes to any of the above, have you evaluated appropriate and practicable steps to: 1)avoidance; 2) if avoidance is not possible, minimization; 3) if either avoidance or minimize is not possible, mitigation? If no to any of the above, what information or documentation was used to support this determination? Provide a comprehensive analysis of practicable alternatives for improvement dredging in accordance with 314 CMR 9.07(1)(b). Physical and chemical data of the sediment shall be included in the comprehensive analysis. The Sampling and analysis plan was approved by MassDEP on May 3, 2019. Sediment Characterization Existing gradation analysis results? ❑ Yes ® No: if yes, provide results. Existing chemical results for parameters listed in 314 CMR 9.07(2)(b)6? ❑ Yes ® No; if yes, provide results. Do you have sufficient information to evaluate feasibility of the following management options for dredged sediment? If yes, check the appropriate option. Beach Nourishment Unconfined Ocean Disposal Confined Disposal: Confined Aquatic Disposal (CAD) Confined Disposal Facility(CDF) Landfill Reuse in accordance with COMM-97-001 _ Shoreline Placement Upland Material Reuse In-State landfill disposal Out-of-state landfill disposal (NOTE: This information is required for a 401 Water Quality Certification.) IV. Consistency: A. Does the project have effects on the coastal resources or uses, and/or is the project located within the Coastal Zone? ® Yes ❑ No; if yes, describe these effects and the projects consistency with the policies of the Office of Coastal Zone Management: The Project will utilize an existing manhole and subsurface conduit to avoid impacts to near- shore coastal resources. B. Is the project located within an area subject to a Municipal Harbor Plan? ❑ Yes ® No; if yes, identify the Municipal Harbor Plan and describe the project's consistency with that plan: The Lynn Municipal Harbor Plan does not cover the Project Area. - 11 - WATER SUPPLY SECTION I. Thresholds/ Permits A. Will the project meet or exceed any review thresholds related to water supply (see 301 CMR 11.03(4))? ❑ Yes ® No; if yes, specify, in quantitative terms: B. Does the project require any state permits related to water supply? ❑Yes ® No; if yes, specify which permit: C. If you answered "No"to both questions A and B, proceed to the Wastewater Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Water Supply Section below. II. Impacts and Permits A. Describe, in gallons per day(gpd), the volume and source of water use for existing and proposed activities at the project site: Existing Change Total Municipal or regional water supply Withdrawal from groundwater Withdrawal from surface water Interbasin transfer (NOTE:lnterbasin Transfer approval will be required if the basin and community where the proposed water supply source is located is different from the basin and community where the wastewater from the source will be discharged.) B. If the source is a municipal or regional supply, has the municipality or region indicated that there is adequate capacity in the system to accommodate the project? ❑Yes ❑ No C. If the project involves a new or expanded withdrawal from a groundwater or surface water source, has a pumping test been conducted? ❑Yes ❑ No; if yes, attach a map of the drilling sites and a summary of the alternatives considered and the results. D. What is the currently permitted withdrawal at the proposed water supply source (in gallons per day)?Will the project require an increase in that withdrawal? ❑ Yes ❑ No; if yes, then how much of an increase (gpd)? E. Does the project site currently contain a water supply well, a drinking water treatment facility, water main, or other water supply facility, or will the project involve construction of a new facility? ❑Yes ❑ No. If yes, describe existing and proposed water supply facilities at the project site: Permitted Existing Avg Project Flow Total Flow Daily Flow Capacity of water supply well(s) (gpd) Capacity of water treatment plant(gpd) F. If the project involves a new interbasin transfer of water,which basins are involved, what is the direction of the transfer, and is the interbasin transfer existing or proposed? G. Does the project involve: 1. new water service by the Massachusetts Water Resources Authority or other agency of the Commonwealth to a municipality or water district? ❑ Yes ❑ No 2. a Watershed Protection Act variance? ❑ Yes ❑ No; if yes, how many acres of alteration? - 12- 3. a non-bridged stream crossing 1,000 or less feet upstream of a public surface drinking water supply for purpose of forest harvesting activities? ❑ Yes ❑ No III. Consistency Describe the project's consistency with water conservation plans or other plans to enhance water resources, quality, facilities and services: - ]3- WASTEWATER SECTION I. Thresholds/Permits A. Will the project meet or exceed any review thresholds related to wastewater(see 301 CMR 11.03(5))? ❑ Yes ® No; if yes, specify, in quantitative terms: B. Does the project require any state permits related to wastewater? ❑ Yes ® No; if yes, specify which permit: C. If you answered "No"to both questions A and B, proceed to the Transportation --Traffic Generation Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Wastewater Section below. II. Impacts and Permits A. Describe the volume(in gallons per day)and type of disposal of wastewater generation for existing and proposed activities at the project site (calculate according to 310 CMR 15.00 for septic systems or 314 CMR 7.00 for sewer systems): Existing Change Total Discharge of sanitary wastewater Discharge of industrial wastewater TOTAL Existing Change Total Discharge to groundwater Discharge to outstanding resource water Discharge to surface water Discharge to municipal or regional wastewater facility TOTAL B. Is the existing collection system at or near its capacity? ❑ Yes ❑ No; if yes, then describe the measures to be undertaken to accommodate the project's wastewater flows: C. Is the existing wastewater disposal facility at or near its permitted capacity? ❑Yes ❑ No; if yes, then describe the measures to be undertaken to accommodate the project's wastewater flows: D. Does the project site currently contain a wastewater treatment facility, sewer main, or other wastewater disposal facility, or will the project involve construction of a new facility? ❑ Yes ❑ No; if yes, describe as follows: Permitted Existing Avg Protect Flow Total Daily Flow Wastewater treatment plant capacity (in gallons per day) E. If the project requires an interbasin transfer of wastewater, which basins are involved,what is the direction of the transfer, and is the interbasin transfer existing or new? (NOTE: lnterbasin Transfer approval may be needed if the basin and community where wastewater will be discharged is different from the basin and community where the source of water supply is located.) - 14- F. Does the project involve new sewer service by the Massachusetts Water Resources Authority (MWRA)or other Agency of the Commonwealth to a municipality or sewer district? ❑ Yes ❑ No G. Is there an existing facility, or is a new facility proposed at the project site for the storage, treatment, processing, combustion or disposal of sewage sludge, sludge ash, grit, screenings, wastewater reuse (gray water)or other sewage residual materials? ❑ Yes ❑ No; if yes, what is the capacity(tons per day): Existing Change Total Storage Treatment Processing Combustion _ Disposal H. Describe the water conservation measures to be undertaken by the project, and other wastewater mitigation, such as infiltration and inflow removal. III. Consistency A. Describe measures that the proponent will take to comply with applicable state, regional, and local plans and policies related to wastewater management: B. If the project requires a sewer extension permit, is that extension included in a comprehensive wastewater management plan? ❑ Yes ❑ No; if yes, indicate the EEA number for the plan and whether the project site is within a sewer service area recommended or approved in that plan: - 15- TRANSPORTATION SECTION TRAFFIC GENERATION I. Thresholds/Permit A. Will the project meet or exceed any review thresholds related to traffic generation (see 301 CMR 11.03(6))? ❑Yes ® No; if yes, specify, in quantitative terms: B. Does the project require any state permits related to state-controlled roadways? ❑Yes ® No; if yes, specify which permit: Work onshore will be conducted through existing conduit and manholes.The median is surrounded by state roads. Permits required for accessing manholes to reach the data center will be obtained. C. If you answered "No"to both questions A and B, proceed to the Roadways and Other Transportation Facilities Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Traffic Generation Section below. II.Traffic Impacts and Permits A. Describe existing and proposed vehicular traffic generated by activities at the project site: Existing Change Total Number of parking spaces Number of vehicle trips per day ITE Land Use Code(s): B. What is the estimated average daily traffic on roadways serving the site? Roadway Existing Change Total 1. 2. 3. C. If applicable, describe proposed mitigation measures on state-controlled roadways that the project proponent will implement: D. How will the project implement and/or promote the use of transit, pedestrian and bicycle facilities and services to provide access to and from the project site? C. Is there a Transportation Management Association (TMA)that provides transportation demand management(TDM)services in the area of the project site? ❑ Yes ❑ No; if yes, describe if and how will the project will participate in the TMA: D. Will the project use(or occur in the immediate vicinity of)water, rail, or air transportation facilities? ❑Yes ❑ No; if yes, generally describe: E. If the project will penetrate approach airspace of a nearby airport, has the proponent filed a Massachusetts Aeronautics Commission Airspace Review Form (780 CMR 111.7)and a Notice of Proposed Construction or Alteration with the Federal Aviation Administration (FAA) (CFR Title 14 Part 77.13, forms 7460-1 and 7460-2)? III. Consistency Describe measures that the proponent will take to comply with municipal, regional, state, and federal plans and policies related to traffic, transit, pedestrian and bicycle transportation facilities and services: - 16- TRANSPORTATION SECTION (ROADWAYS AND OTHER TRANSPORTATION FACILITIES) I. Thresholds A. Will the project meet or exceed any review thresholds related to roadways or other transportation facilities (see 301 CMR 11.03(6))? ❑ Yes ® No; if yes, specify, in quantitative terms: B. Does the project require any state permits related to roadways or other transportation facilities? ❑ Yes ® No; if yes, specify which permit: C. If you answered "No"to both questions A and B, proceed to the Energy Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Roadways Section below. II. Transportation Facility Impacts A. Describe existing and proposed transportation facilities in the immediate vicinity of the project site: B. Will the project involve any 1. Alteration of bank or terrain (in linear feet)? 2. Cutting of living public shade trees (number)? 3. Elimination of stone wall (in linear feet)? III. Consistency -- Describe the project's consistency with other federal, state, regional, and local plans and policies related to traffic, transit, pedestrian and bicycle transportation facilities and services, including consistency with the applicable regional transportation plan and the Transportation Improvements Plan (TIP), the State Bicycle Plan, and the State Pedestrian Plan: - 17- ENERGY SECTION I. Thresholds/Permits A. Will the project meet or exceed any review thresholds related to energy (see 301 CMR 11.03(7))? ❑Yes ® No; if yes, specify, in quantitative terms: B. Does the project require any state permits related to energy? ❑ Yes ® No; if yes, specify which permit: C. If you answered "No"to both questions A and B, proceed to the Air Quality Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Energy Section below. II. Impacts and Permits A. Describe existing and proposed energy generation and transmission facilities at the project site: Existin Change Total Capacity of electric generating facility(megawatts) Length of fuel line (in miles) Length of transmission lines (in miles) Capacity of transmission lines (in kilovolts) B. If the project involves construction or expansion of an electric generating facility, what are: 1. the facility's current and proposed fuel source(s)? NIA 2. the facility's current and proposed cooling source(s)? NIA C. If the project involves construction of an electrical transmission line, will it be located on a new, unused, or abandoned right of way? ❑ Yes ❑ No; if yes, please describe: D. Describe the project's other impacts on energy facilities and services: III. Consistency Describe the project's consistency with state, municipal, regional, and federal plans and policies for enhancing energy facilities and services: N/A - 18- AIR QUALITY SECTION I. Thresholds A. Will the project meet or exceed any review thresholds related to air quality (see 301 CMR 11.03(8))? ❑ Yes ® No; if yes, specify, in quantitative terms: B. Does the project require any state permits related to air quality? ❑ Yes ® No; if yes, specify which permit: C. If you answered "No"to both questions A and B, proceed to the Solid and Hazardous Waste Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Air Quality Section below. II. Impacts and Permits A. Does the project involve construction or modification of a major stationary source (see 310 CMR 7.00, Appendix A)? ❑ Yes ❑ No; if yes, describe existing and proposed emissions (in tons per day)of: Existing Change Total Particulate matter Carbon monoxide Sulfur dioxide Volatile organic compounds Oxides of nitrogen Lead Any hazardous air pollutant Carbon dioxide B. Describe the project's other impacts on air resources and air quality, including noise impacts: III. Consistency A. Describe the project's consistency with the State Implementation Plan: B. Describe measures that the proponent will take to comply with other federal, state, regional, and local plans and policies related to air resources and air quality: 19 SOLID AND HAZARDOUS WASTE SECTION I. Thresholds I Permits A. Will the project meet or exceed any review thresholds related to solid or hazardous waste (see 301 CMR 11.03(9))? ❑ Yes ® No; if yes, specify, in quantitative terms: B. Does the project require any state permits related to solid and hazardous waste? ❑Yes ® No; if yes, specify which permit: C. If you answered "No"to both questions A and B, proceed to the Historical and Archaeological Resources Section. If you answered "Yes"to either question A or question B, fill out the remainder of the Solid and Hazardous Waste Section below. II. Impacts and Permits A. Is there any current or proposed facility at the project site for the storage, treatment, processing, combustion or disposal of solid waste? ❑ Yes ❑ No; if yes, what is the volume (in tons per day)of the capacity: Existing Change Total Storage Treatment, processing Combustion Disposal B. Is there any current or proposed facility at the project site for the storage, recycling, treatment or disposal of hazardous waste?_Yes_No; if yes, what is the volume (in tons or gallons per day) of the capacity: Existing Change Total Storage Recycling Treatment Disposal C. If the project will generate solid waste (for example, during demolition or construction), describe alternatives considered for re-use, recycling, and disposal: D. If the project involves demolition, do any buildings to be demolished contain asbestos? ❑ Yes ❑ No E. Describe the project's other solid and hazardous waste impacts(including indirect impacts): III. Consistency Describe measures that the proponent will take to comply with the State Solid Waste Master Plan: N/A 20 HISTORICAL AND ARCHAEOLOGICAL RESOURCES SECTION I. Thresholds/Impacts A. Have you consulted with the Massachusetts Historical Commission? ❑Yes ® No; if yes, attach correspondence. For project sites involving lands under water, have you consulted with the Massachusetts Board of Underwater Archaeological Resources? ®Yes ❑ No; if yes, attach correspondence. Consultation with Massachusetts Historical Commission is ongoing. B. Is any part of the project site a historic structure, or a structure within a historic district, in either case listed in the State Register of Historic Places or the Inventory of Historic and Archaeological Assets of the Commonwealth? ®Yes ❑ No; if yes, does the project involve the demolition of all or any exterior part of such historic structure? ❑ Yes ® No; if yes, please describe: C. Is any part of the project site an archaeological site listed in the State Register of Historic Places or the Inventory of Historic and Archaeological Assets of the Commonwealth? ® Yes ❑ No; if yes, does the project involve the destruction of all or any part of such archaeological site? ❑ Yes ®No; if yes, please describe: D. If you answered "No"to all parts of both questions A, B and C, proceed to the Attachments and Certifications Sections. If you answered "Yes"to any part of either question A or question B, fill out the remainder of the Historical and Archaeological Resources Section below. II. Impacts Describe and assess the project's impacts, direct and indirect, on listed or inventoried historical and archaeological resources: The geophysical survey data will be reviewed,analyzed, and interpreted to identify cultural resources such as shipwrecks and submerged pre-contact Native American archaeological sites. If any marine cultural resources are identified, appropriate measures to avoid, minimize, or mitigate potential Project impacts will be addressed as part of the MEPA and National Historic Preservation Act(NHPA)Section 106 review.Any proposed avoidance, minimization, and/or mitigation measures will be developed in consultation with the relevant authorities and consulting parties including, but not limited to, the BOAR, MHC, and Native American Tribes. Once the BUAR, MHC, and U.S.Army Corps of Engineers have reviewed and accepted the marine cultural resources remote sensing report, ERM will work with these regulatory stakeholders to identify the resulting requirements to complete the MEPA and NHPA Section 106 reviews. Based on initial review of shipwreck data, there are three shipwrecks located within 750 feet of the Project alignment, and all of them are greater than 500 feet from the preliminary cable alignment(Appendix B, Figures). III. Consistency Describe measures that the proponent will take to comply with federal, state, regional, and local plans and policies related to preserving historical and archaeological resources: As no inventoried architectural properties are located within the Project's direct area of impact and no new above ground facilities are proposed, the Project is not expected to have any adverse effects on historic architectural properties. 21 CERTIFICATIONS: 1 The Public Notice of Environmental Review has been/will be published in the following newspapers in accordance with 301 CMR 11.15(1): Beverly: The Salem News Salem: The Salem News Gloucester: Gloucester Daily Times Lynn/Nahant: Daily Evening Item Marblehead: Marblehead Reporter Rockport: Gloucester Daily Times Manchester:Wicked Local Manchester Swampscott: The Daily Item 22 2. This form has been circulated to Agencies and .Persons in accordance with 301 CMR 11.16(2), Signatures; 6/14/2019 v/� 6�I Z /120 r t� 1 Date Signature of Responsible Officer Date Signature of person *abo ) 1 � or Proponent ENF(if different from Kevin Salvadori Christina Hoffman Name (print or type) Name(print or type) Edge Cable Holdings USA,LLC ERM Firm/Agency Firm/Agency 1601 Willow Road 1 Beacon Street, 5th Floor Street Street Menlo.Park CA 94025-1452 Boston. MA. 02108 Municipality/State/Zip Municipality/State/Zip (650)8224885 (974).857 9334 Phone Phone 23 �� 1 '.� �'1 n I n � �, n n A n n n n n n n n n n r7 r' � .-� � 1 '�� -,1 �~� _� '�f 1 r-� } i 1 ' } [ ] I a l } it 1 _� `5 L� 1 � 1 1 I l ti 1 ti iL I� .I is I�1 lu k 1 ti I� 1 I� l� Ij Appendix A PROJECT NARRATIVE www.erm.com Version:1.0 Project No.:0497639 17 June 2019 i 1 Ii i I I 3 �� .� , { ;4 tip,� _:� ��_ ..�-�`�_�� _ � + r � ��1 r� �F f r � r� *�f��•'�" � y �i� �-� `�• - - ��f r y � �7 � � � �r �r �r Y r� s i rr ■ � � � � �� "� .JAR."' � � � r �•. mom ow Awww Expanded Environmental Notification Form FiberOptic Submarine Cable Submitted to: • Policy Submitted by: ERM 17 June 1 • • - No.: 0497639 rfunnuu The ofouff \4 ff fff.A. f1 f�`fluff business i• Document details The details entered below are automatically shown on the cover and the main page footer. PLEASE NOTE:This table must NOT be removed from this document. Document title Expanded Environmental Notification Form Document subtitle Amitie Fiber Optic Submarine Cable System Project No. 0497639 Date 117 June 2019 Version 11.0 Author ERM Consulting and Engineering, Inc. Document history ERM approval to issue Version Revision Author Reviewed by Name Date Comments Final 01 Kyle Purdy Christina Ingeborg 13 June 2019 Hoffman McNicoll I www.erm.com Version:1.0 Project No.:0497639 17 June 2019 EXPANDED ENVIRONMENTAL NOTIFICATION FORM CONTENTS Amitie Fiber Optic Submarine Cable System Expanded Environmental Notification Form r Appendix A: Project Narrative CONTENTS 1. INTRODUCTION .......1 1.1 Project Objective and Benefits..............................................................................................................1 1.2 Regulatory Overview............................................................................................................................2 1.2.1 Massachusetts Ocean Management Plan ...........................................................................2 2. PROJECT DESCRIPTION.................................................................................................................3 2.1 Construction Methodology....................................................................................................................4 2.1.1 Establishment of Controls and Preparation for Cable Installation........................................4 2.1.2 Landward Construction........................................................................................................5 2.1.3 Seaward Construction..........................................................................................................6 2.2 Cable and Pipeline Crossings...............................................................................................................9 2.3 Cable Operation, Maintenance,and Repairs(Post-Installation).........................................................10 3. PROJECT SCHEDULE....................................................................................................................11 4. PROJECT IMPACTS AND MITIGATION.........................................................................................11 4.1 Wetlands,Waterways and Tldelands..................................................................................................11 4.1.1 Existing Environment.........................................................................................................11 4.1.2 Project Impacts..................................................................................................................12 4.1.3 Mitigation Measures...........................................................................................................14 4.2 Protected Species...............................................................................................................................14 4.2.2 Existing Environment.........................................................................................................14 4.2.3 Project Impacts..................................................................................................................15 4.2.4 Mitigation Measures...........................................................................................................15 4.3 Historic and Archaeological Resources..............................................................................................16 4.3.1 Existing Environment.........................................................................................................16 4.3.2 Project Impacts..................................................................................................................17 4.3.3 Mitigation Measures...........................................................................................................17 4.4 Ocean Management Plan...................................................................................................................17 4.4.1 SSUs..................................................................................................................................18 4.5 Other Impacts.....................................................................................................................................18 4.5.1 Land...................................................................................................................................18 4.5.2 Transportation....................................................................................................................19 4.5.3 Wastewater........................................................................................................................19 4.5.4 Energy...............................................................................................................................19 4.5.5 Air..............................................................................•.......................................................19 4.5.6 Solid and Hazardous Waste..............................................................................................19 4.5.7 Noise..................................................................................................................................19 5. ALTERNATIVES ANALYSIS...........................................................................................................20 5.1 System Alternatives............................................................................................................................20 5.2 No-Build Alternative............................................................................................................................20 5.3 Routing Alternatives............................................................................................................................20 5.3.1 Shorter Straight Route.......................................................................................................20 5.3.2 Northern Connection..........................................................................................................21 5.3.3 Preferred Route.................................................................................................................21 www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page iii EXPANDED ENVIRONMENTAL NOTIFICATION FORM CONI I W S Amitie Fiber Optic Submarine Cable System APPENDIX B F C UI .t APPENDIX C PERWT TABLE APPENDIX D ENI C lk'C`.ULATION LIST List of Tables Table 1: Impacts to Land Under the Ocean from Installation of the Amitie Fiber Optic Submarine Cable System within Massachusetts State Waters...............................................................................................13 Lisi of Figures Figure 1: Project Overview Map Figure 2: State Waters and Municipalities Map Figure 3: Special, Sensitive, or Unique Resources Figure 4: Landing Area Figure 5: Coastal Resource Areas and Buffer Zones Figure 6: Environmental Constraints Figure 7: Shipwrecks Identified within the Project Area List of Exhibits Exhibit1: Double-Armor Cable......................................................................................................................4 Exhibit 2: Grapnel Configuration...................................................................................................................5 Exhibit 3: Existing Manhole Located within the Median of the Lynn Roundabout........................................6 Exhibit 4:Typical Installation Vessel.............................................................................................................7 Exhibit 5: Cable Burial Plow to be Deployed off the Stern of the Installation Vessel ...................................7 Exhibit 6: Plan View of Cable Burial Plow Showing the Dimensions of the Ski Tracks and the 0.7-Foot (0.2-Meter)Trench Plow...............................................................................................................8 Exhibit 7: Conceptual Representation of the Cable-Laying Process............................................................9 Exhibit 8: Plan View of a Section of Cable Burial Plow Impacts to Seafloor Sediment..............................13 www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page iv EXPANDED ENVIRONMENTAL NOTIFICATION FORM CONTENTS Amiti6 Fiber Optic Submarine Cable System Acronyms and Abbreviations BUAR Massachusetts Board of Underwater Archaeology CMR Code of Massachusetts Regulations EFH Essential Fish Habitat EIR Environmental Impact Report ERM ERM Consulting & Engineering, Inc. ET Eastern Time FEMA Federal Emergency Management Agency LSCSF Land Subject to Coastal Storm Flowage LUO Land Under the Ocean M.G.L. Massachusetts General Laws MEPA Massachusetts Environmental Policy Act MHC Massachusetts Historical Commission MOMP Massachusetts Ocean Management Plan NHESP Massachusetts Natural Heritage and Endangered Species Program NHPA National Historic Preservation Act NMFS National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration PLGR Pre-Lay Grapnel Run Project Amiti6 Submarine Cable System RC Route Clearance ROV Remotely Operated Vehicle SSB State Seaward Boundary SSU special, sensitive and unique resources Territorial Sea Extending 12 nautical miles from the low water line of the Massachusetts seashore UK United Kingdom USA United States of America USACE United States Army Corps of Engineers WPA Massachusetts Wetlands Protection Act www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page v i i �� i ' �ti i � � .ti �� ,� i ,r t .� .� 4� EXPANDED ENVIRONMENTAL NOTIFICATION FORM INTRODUCTION Amitie Fiber Optic Submarine Cable System 1. INTRODUCTION The Amitie Submarine Cable System (the Project or Amitie) is a planned subsea cable system in the Atlantic Ocean linking the United States, France, and the United Kingdom. Alcatel Submarine Networks would be responsible for the manufacture and installation of the cable, which will land in Bude (United Kingdom), Bordeaux(France), and Lynn, Massachusetts (Figure 1 in Appendix B). The length of the cable proposed in the United States is approximately 200 miles (322 kilometers), which includes approximately 29.4 miles (47.3 kilometers)of cable proposed in Massachusetts state waters. As depicted on Figure 2 of Appendix B, the proposed cable route crosses the municipalities of Rockport, Gloucester, Manchester-by-the-Sea, Beverly, Salem, Marblehead, Swampscott, and Lynn, with a small workspace proposed onshore in Nahant. The cable route presented in this document is considered preliminary as geotechnical and geophysical data continues to be reviewed to refine the cable route. The Project is subject to review under the Massachusetts Environmental Policy Act(MEPA) because the cable installation within Land Under the Ocean (LUO) is anticipated to temporarily disturb more than 10 acres. The temporary disturbance is spread across a very narrow corridor in Massachusetts waters, thereby exceeding the MEPA threshold pursuant to Title 301 of the Code of Massachusetts Regulations (CMR) 11.03 (3) (a) 1.b. No other MEPA review thresholds identified at 301 CMR 11.03 are anticipated at this time to be exceeded by this Project. The cable installation may also be subject to the Massachusetts Ocean Management Plan (MOMP), depending on the level of MEPA review required. Telecommunication cables are a permitted use in the Ocean Management Planning Area and a MOMP review will be triggered if an environmental impact report(EIR) is required by the Secretary of Energy and Environmental Affairs. For the landing in Lynn, the Project will use an existing conduit and infrastructure that starts 0.8 miles(1.3 kilometers)offshore and continues onshore to an existing data center. The conduit was installed in the early 2000s. The Hibernia cable project was reviewed by the Secretary of the Executive Office of Energy and Environmental Affairs and was determined not to require an EIR due to the minor and temporary nature of the impacts of cable burial (EEA File no. 12026). As part of the Hibernia cable installation, additional conduit was installed for the specific purpose of housing an additional telecommunications cable landing in Lynn. The conduits were ultimately installed to avoid impacts to sensitive resources along the near-shore and beach areas of Lynn. Therefore, the Project does not propose any seabed or upland ground disturbance between the connection points within an existing roadway median in Lynn out to a distance of approximately 0.8 miles (1.3 kilometers)offshore. The Amitie cable will result in less environmental impact than the original proposed Hibernia cable project since existing infrastructure will be used and more advanced installation technology that minimizes disturbance to the seafloor is available and will be used. Upon review of this Environmental Notification Form, if the Secretary of Energy and Environmental Affairs requires an EIR for this Project, we respectfully request that the Secretary allow a single EIR be prepared in accordance with 301 CMR 11.06(8) due to the minor and temporary nature of the proposed environmental impacts. The following sections provide a detailed description of the Project, a discussion of project objective and benefits, an evaluation of Project alternatives, and an assessment of potential impacts to environmental resources. 1.1 Project Objective and Benefits The objective of the Project is to install a subsea fiber optic system across the Atlantic Ocean. The new system will increase telecommunication reliability and diversity between the continents and increase data www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 1 EXPANDED ENVIRONMENTAL NOTIFICATION FORM INTRODUCTION Amitie Fiber Optic Submarine Cable System transmission capacity and speeds, helping to satisfy the growing demand for transmission capacity in Europe and the United States. Regulatory Overview The construction, operation, and maintenance of the Project will require multiple permits and regulatory approvals from federal, state and local agencies. The applicable permits, consultations, and approvals are summarized in Appendix C. 1.2.1 Massachusetts Ocean Management Plan Amended in 2015, the MOMP created a framework for managing uses and activities within Massachusetts's ocean waters, including submerged cable projects. Any project within the Massachusetts Ocean Management Planning Area that requires an EIR pursuant to MEPA is subject to the MOMP siting and performance standards. Those projects filing an Environmental Notification Form must document any potential impacts to special, sensitive, and unique (SSU) resources and/or concentrations of water-dependent uses to allow agencies and the public to inform the Secretary whether additional review in a discretionary EIR is warranted. The MOMP has jurisdiction from the seaward limit of state waters to a nearshore boundary that lies 0.3 miles (0.5 kilometers) seaward from the mean high water line. The Project crosses through the Ocean Management Planning Area; therefore, a discussion of the performance standards and siting criteria is provided in Section 4.4 below. As stipulated in the Oceans Act of 2008 and Chapter 1 of the MOMP, execution is through existing state review procedures with all permits required to be consistent to the maximum extent practicable with the MOMP. The MOMP includes mapping and the evaluating natural resources which may be sensitive to projects such as submarine cables. The MOMP acknowledges the need for new telecommunication or other cables, and identifies the following SSU resources that must be addressed for submarine cable projects: 1. Core habitat of the North Atlantic right, fin, and humpback whales 2. Hard/complex seafloor 3. Eelgrass 4. Intertidal flats As described in the MOMP, allowed activities in the Multi-Use Area are managed based on an approach that directs new development away from critical marine ecosystem components, SSU resources, and areas important for water-dependent uses that were identified and mapped in the planning process. Figure 3 (in Appendix B) illustrates the survey route relative to the SSU resources delineated in the MOMP for cable projects. Geophysical and geotechnical data continues to be evaluated along the preliminary cable route to confirm the locations of the SSUs, in particular the hard/complex seafloor. The preliminary cable route avoids delineated North Atlantic right whale core habitat, fin whale core habitat, hard/complex sea floor, eelgrass, and intertidal flats. The cable route traverses approximately 1.2 miles (1.9 kilometers) of humpback whale core habitat east of Cape Ann and north of Stellwagen Bank National Marine Sanctuary. Avoiding the humpback whale core habitat SSU would result in passing through Stellwagen Bank National Marine Sanctuary or crossing adjacent hard/complex sea floor. Therefore, the Project will aim to avoid impacts to humpback whales based on a commitment to provide a marine mammal observer on the vessel during cable installation, maintain a low vessel speed, and work with the National Oceanic and Atmospheric Administration (NOAA) Fisheries and Massachusetts Division of Marine Fisheries to identify other measures that could be implemented to avoid and minimize impacts. www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 2 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT DESCRIPTION Amitie Fiber Optic Submarine Cable System The preliminary cable route through Massachusetts waters is based on an extensive analysis of existing seafloor mapping, as well as an understanding of known locations of existing critical infrastructure (e.g., cables and pipelines) in the waters off the City of Lynn and Cape Ann. As described in more detail below, the alternatives analysis identified the current route with the primary goal of avoiding SSU resources to the maximum extent practicable. The Project is consistent with MOMP siting and performance standards for cables. 2, PROJECT DESCRIPTION This ENF addresses the cable segment located within the Massachusetts State Seaward Boundary (SSB). To provide additional context, details are provided throughout this narrative regarding the cable installation outside of the Massachusetts SSB. In total, approximately 29.4 miles (47.3 kilometers)of cable are proposed between the Massachusetts SSB off Rockport and the landing site in a roadway median in Lynn. Upon entering the SSB from the east, the preliminary cable route extends southwest, paralleling the coastline and crossing through eight municipalities. Along this stretch, the preliminary cable route has been designed to avoid or cross existing cables and pipelines existing on the seafloor where possible. On the final approach to land, the cable will be routed through an existing stainless steel conduit that starts 0.8 miles (1.3 kilometers)offshore and terminates at an existing manhole within the median/roundabout at the intersection of Nahant Road and Lynn Shore Drive (Figure 4 in Appendix B). From the manhole in the median, the cable will be routed approximately 1.8 miles (2.9 kilometers) through existing underground utility conduits under existing roadways to reach an existing data center at 91 Commercial Street in the City of Lynn. As with the offshore conduit, the onshore conduits also have sufficient capacity to receive the Amitie cable. At the data center, several grounding rods would be inserted underground from the surface within a small footprint of the existing facility's developed footprint. As the Project will use existing conduits in the portions of the marine cable installation that are closest to shore and within the landward installation to the data center, the Project will result in very little ground disturbance The cable type to be used is Alcatel Submarine Networks' OALC-4 which is a resilient cable type designed specifically for repeated systems (Exhibit 1). At the heart of the cable the optical fibers are set in a steel tube and are protected by a jelly from water penetration and hydrogen. The cable is insulated; the insulation also provides abrasion resistance. In waters less than 3,000 feet(0.9 kilometers)deep, the fiber unit and insulation sheath are protected by galvanized steel wires and layers of black polypropylene yarn for additional protection against external threats. The cable is approximately 1 to 1.5 inches (2.5 to 3.8 centimeters) in diameter, depending on the level of cable armoring. www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 3 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT DESCRIPTION Amitie Fiber Optic Submarine Cable System �r d Exhibit 1: Double-Armor Cable The marine portion of the cable installation is anticipated to take approximately 5 days within Massachusetts waters; the land installation is anticipated to take another 5 days. Planning, installation, and maintenance will be performed according to approved and certified International Organization for Standardization quality systems. The planning of the route has been performed in accordance with industry-recognized standards and codes, including the International Telecommunications Union. !,:.I Constructit-)a Construction will consist of two distinct methodologies: one for installing the cable underneath the seabed, and the other for installing the cable on land. The main stretch of cable in the seabed will be laid in one continuous length from an installation vessel equipped with a towed plow. The plow will bury the cable to a depth to be determined by the seafloor conditions; however, the target burial depth is 4 to 6 feet(1.2 to 1.8 meters). The results of a marine survey confirming the bottom type are anticipated to be available in June 2019 and are anticipated to provide additional data to refine the route design, including the feasible burial depth. This depth of cover will protect the cable from damage or fouling by anchors, fishing gear, and other marine operations. Data available for the Hibernia cable installation, which occurred along a similar route to the proposed Amitie route, indicates that it was able to be buried along the entire length within Massachusetts waters; therefore, it is assumed at this time that the entire marine cable route will be buried within Massachusetts boundaries. 2.1.1 Establishment of Controls and Preparation for Cable Installation Prior to the cable installation, route clearance (RC)and/or Pre-Lay Grapnel Run (PLGR)will be conducted over the length of the preliminary cable route for burial, to minimize the risk of later damage to the burial equipment and maximize efficiency during installation (Exhibit 2). PLGR is designed to remove any surface debris that would be an obstruction to the simultaneous cable lay and burial process(e.g., abandoned fishing nets,wire rope, or other significant debris on the seabed surface) along the planned route where burial of 4 to 6 feet(1.2 to 1.8 meters) is planned. RC would remove any out-of-service cables identified as crossing or otherwise obstructing the preliminary cable route. www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 4 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT DESCRIPTION Amitie Fiber Optic Submarine Cable System The Speamaim may be replaced a........ a Flatfish C�WwlAf r Exhibit 2: Grapnel Configuration The PLGR would be conducted by the installation vessel towing a grapnel along the final cable route before the cable installation, using a grapnel fluke penetrating between 0.7 and 3.3 feet(0.2 and 1.0 meter) into the seabed (subject to seabed conditions). The RC would be conducted using a specialized grapnel with longer flukes penetrating up to 6.6 feet(2 meters) and a section of the out-of-service cable would be cut/removed to allow the installation and burial process to continue. All debris recovered from the seabed will be stored onboard the installation vessel and disposed of at an appropriate approved land facility once the vessel docks. RC/PLGR operations are intended to be carried out along the sections of the cable where burial will take place and will last for up to 4 days at a target rate of 15.5 miles per day(24.9 kilometers per day). The actual areas covered will likely be reduced and restricted subject to the detailed findings of marine route survey (e.g., detailing rocky outcrops/cable crossings,which may prevent PLGR). 2.1.2 Landward Construction Landward construction starting at the existing manhole on the median in Lynn is proposed to be conducted through the existing conduit and accessed via existing manholes (Exhibit 3). Within the Lynn roundabout median, next to the existing manhole, a winch will be secured to a large piece of machinery (e.g., a large excavator) parked next to the manhole. The winch will connect to the messenger line rope threaded through the conduit that extends offshore. Once connected to the messenger line, the cable will be pulled through the manhole and secured using a winch. A temporary workspace will be used for parking, and temporary fencing will be erected to isolate a portion of the median to conduct the winching and connection work on the median. No ground disturbance is anticipated to occur on the median.Any rutting of the maintained lawn by heavy equipment will be repaired once the cable has been installed. The connection between the manhole on the median and the terminal station on Commercial Street will be made via existing underground conduits that can be accessed via existing manholes and manhole covers. Once the cable is landed and pulled through the existing manhole from both directions, the cable will be tested to ensure the cable is working. The manhole on the median is the point of transition between submarine cable and land cable. www.erm.com Version:1.0 Project No.:D497639 17 June 2019 Page 5 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT DESCRIPTION Amitie Fiber Optic Submarine Cable System I Exhibit 3: Existing Manhole Located within the Median of the Lynn Roundabout 2.1.3 Seaward Construction On the seaward side of the manhole on the median, the cable is proposed to be installed within the existing conduit previously installed during the Hibernia cable installation. Divers will inspect the structural integrity of the conduit prior to construction. At the time of construction, the cable will be run through the existing conduit out to a marine installation vessel. The installation vessel will be a purpose-built cable ship fully equipped with all the necessary equipment, tools, and facilities to safely handle and install,joint, test, and power the submerged equipment, including simultaneous lay and plow burial (Exhibit 4). The vessel will have sufficient power and dynamic positioning capability to carry out the installation in the expected weather and current conditions. The vessel is specifically designed and used for cable installations across the globe and uses the most current features, including dynamic positioning. The dynamic positioning greatly reduces the impact to the seafloor as compared to older models of cable installation vessels that used anchors to stabilize and position the vessels while burying cables under the seafloor. The installation ship will approach the landing in the City of Lynn, the cable will be released from the ship, and divers will guide the cable into the conduit. www.erm.com Version:1.' Project No.:0497639 17 June 2019 Page 6 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT DESCRIPTION Amiti6 Fiber Optic Submarine Cable System Exhibit 4: Typical Installation Vessel The lay operation of the cable will normally take place during daytime hours. Once confirmation is received that the cable has been secured at the existing manhole, the installation vessel will move away from the City of Lynn, installing the remainder of the cable in Massachusetts and United States waters using a plow that is deployed off the stern off the ship (Exhibit 5). ■ �J s a 1 Exhibit 5: Cable Burial Plow to be Deployed off the Stern of the Installation Vessel www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 7 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT DESCRIPTION Amiti(§Fiber Optic Submarine Cable System MakaiLay is the onboard cable engineering software that will be used to install the cable along the final route with high positional accuracy and control of the cable tension in combination with the ship's navigational systems. Various industry standard burial tools will be used to bury the cable (including plowing and a remotely operated vehicle(ROV)equipped with jetting tools)to approximately 4 to 6 feet(1.2 to 1.8 meters) below the seabed. The cable itself will occupy approximately 1.5 inches (3.8 centimeters) of the seabed. The footprint of the submarine cable plow is limited to where the four plow skies are in contact with the seabed surface and the plow share, which is approximately less than 1 foot (0.3 meters)wide (Exhibit 6). The plow is designed to backfill the cable burial trench at the time of installation and is intended to be used to a depth of 3,000 feet(0.9 kilometers). In water depths greater than 3,000 feet(0.9 kilometers)(outside of Massachusetts)the cable will be surface laid. The seabed will be reinstated to near baseline conditions after plowing as the plow backfills the trench with sediment displaced from the trench as it moves along the seabed. Only temporary track marks from skies and the plow share will remain visible just after installation, but will shortly disappear due to seabed currents and wave action. _ 27.2ft 39ft 8.9 r— u; v �i 01 o � o I Exhibit 6: Plan View of Cable Burial Plow Showing the Dimensions of the Ski Tracks and the 0.7-Foot (0.2-Meter) Trench Plow. The plowing process is a well-proven industry standard cable burial process which will keep the environmental disturbance to an absolute minimum compared to other burial techniques available for cable protection, like water jetting, airlifting, sediment dredging, rock cutting, and rock dumping. Seabed type, up, down, and side slopes will determine where plowing can be safely performed. Maximum continuous tow force is normally limited to 80 tons for an "Ile de Class"vessel. The tow force is a function of following three factors: f5 Seabed material/hardness www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 8 EXPANDED ENVIRONMENTAL NOTIFICATION FORMA PROJECT DESCRIPTION Amitie Fiber Optic Submarine Cable System ■ Tow speed Burial depth If the tow tension is too high, the vessel will temporarily reduce speed. If seabed hardness seems to continue for a longer stretch, the burial depth will be reduced in steps of 0.3 feet(9 centimeters). This stepping process will continue until the normal plow speed of approximately 0.6 miles per hour(0.9 kilometers per hour)can be maintained. The plow will be towed in a nearly straight line behind the vessel, except when altering course. The plow position behind the vessel will be calculated based on: Acoustic positioning—slant range accuracy is better than 1 percent under normal conditions, assuming constant sound velocity in the water column; and Tow wire length deployed and water depth. Typical plowing operations runs with the plow two to three times the water depth behind the vessel (Exhibit 7). Dreet7an of lay Surface Umbilirn! IIi Ir i i i 1 Tow wire Cable Submarine cabfe plough Seabed The cable burial plow is being towed behind the vessel. During the laying operation the tension of the cable will be monitored from the bridge of the vessel. Exhibit 7: Conceptual Representation of the Cable-Laying Process During the laying operation,the cable tension will be monitored from the vessel bridge through the readings of the saddle back; the lay angle will be always monitored by a dedicated person who will be near to the saddle back/stern chute and will have continues communication with the vessel bridge. 2.2 Cable and Pipeline Crossings The preliminary Amitie marine cable route has been designed to avoid cable and pipeline crossings, where possible. However, it is anticipated the Amitie cable will cross two in-service telecommunication cables and three pipelines, pending further confirmation following a review of the marine survey results. www.erm.com Version:1.0 Project No.:D497639 17 June 2019 Page 9 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT DESCRIPTION Amiti6 Fiber Optic Submarine Cable System All cable owners will be notified in accordance with International Cable Protection Committee guidelines and, where possible, all crossings will have a favorable crossing angle of close to 90 degrees. Where other in-service-cables are crossed in planned buried areas, the plow will be recovered and redeployed at a suitable and safe distance on either side of the crossing point. The cable will then be protected by post-lay burial operations, subject to suitable conditions for jetting. Post-lay burial is where the cable has been surface laid over a crossing, so as not to damage the existing cable. The plow will be raised approximately 1,640 feet(469 meters) before the crossing point and lowered again 1,640 feet(469 meters)after, leaving 3,280 feet(1,000 meters)of surface-laid cable over the crossing. An ROV equipped with jetting tools will be used to post-lay bury the Amitie cable to the target up to 6-foot(1.8 meters) burial depth. Where the Amitie cable crosses out-of-service cables, these cables will be cut and cleared away from the cable route as mentioned in the route clearance description above. 2.3 Cable Operation, Maintenance, and Repairs (Post-Installation) Following installation, the cable is expected to operate for at least 25 years. During operation, maintenance work, such as cable repair at fault locations due to unexpected damage can be expected. For land-based repairs, the equipment and methods will be the same as for the landward cable installation works and landward burial. For inshore and submarine cable repairs, equipment and methods would again be similar to those outlined in Section 2.1.3, but smaller scale and not along the full alignment, with the potential to use smaller equipment such as ROVs equipped with injector tool and divers with hand-held tools. The repair work process for the landward portion of the cable and the marine portion of the cable is outlined below: ■ Terminal Testing: Testing from cable station terminal, to try and determine fault location as precisely as possible using optical or electrical characteristics of the submarine cable. ■ Initial Inspection: Cable and seabed will be inspected using Side Scan Sonar, ROV, or divers where appropriate to determine the precise fault location and nature if unknown. If the cable is buried, tracking equipment will be used. ■ Cut faulty cable, buoy off, and recover to vessel: If necessary to cut the cable at the fault area, either an ROV or grapnels will be used, or divers, if feasible. Divers will use hand jetting and ROV will use a jetting technique to uncover buried cable. Grapnels will penetrate the seabed without jetting to pick up the cable. The cable ends will be recovered to the vessel, using divers, ROV, or gripper grapnels. While one cable end is repaired on the vessel, the other cable end will be attached to a rope that is lowered to seabed and this rope will be attached to a buoy to mark its location. ■ Cable Splice and Repair: Damaged cable section will be cut out. First one end will be spliced to the spare repair cable section and electrical and optical testing will be conducted to ensure the integrity of the splice and cables. Then the second cable end will be picked up and spliced back to the repair cable section. Upon completion, the cable integrity will be confirmed through end-to-end electrical and optical testing. ■ Replacement of Repaired Cable: Once the cable has been fully repaired and connected, it will be lowered onto the seabed, along the"as-laid" cable route. Once the repaired cable is in the"as-laid" cable route alignment, a diver or ROV will perform an inspection of the repair area, including determining the beginning and end of unburied cable. www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 10 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT SCHEDULE Amiti6 Fiber Optic Submarine Cable System ■ Post-Lay Inspection and Burial: Should burial at the repair area be necessary, it will be carried out to best endeavors or pre-determined target depth, using divers or ROV jetting. If burial is not possible, other means of protection may be considered such as articulated piping, URADUCTO, or other means such as rock dumping. One final diver or ROV inspection will be carried out before repair works are completed. 3. PROJECT SCHEDULE Agency discussions related to the Project commenced in March 2019. Federal, state, and local consultations and permitting were initiated in May 2019 and are anticipated to be complete by summer 2020. The seaward portion of the cable installation will take approximately five days within Massachusetts state waters. Pulling the cable through the existing conduits on land and installing the grounding equipment is anticipated to take five additional days; however, the landward and seaward installations may occur simultaneously. Initial outreach to federal and state commercial fisheries is planned to begin in summer 2020 in anticipation of construction in fall 2020. Typical daily construction hours will extend from 6 AM to 5 PM Eastern Time (ET; UTC -5:00), Monday through Friday. When needed, extended construction hours will be coordinated with local municipalities. 4. PROJECT IMPACTS AND MITIGATION 4.1 Wetlands, Waterways and Tidelands The Project will involve construction within wetland resource areas regulated by the Massachusetts Wetlands Protection Act(WPA) Massachusetts General Laws (M.G.L.) Chapter 131, §40 and its implementing regulations at 310 CMR 10.00; the Public Waterfront Act M.G.L. Chapter 91A, § 18 and implementing regulations at 310 CMR 9.00; §27 of the Massachusetts Clean Waters Act, M.G.L. chapter 21, §§26 through 53 and implementing regulations found at 314 CMR 9.00. Additional federal requirements apply since a majority of the Project crosses through traditionally navigable waters considered to be Waters of the United States. 4.1.1 Existing Environment The cable is proposed to be installed underneath the seafloor bed, through an existing conduit to the roadway median in Lynn, and through existing conduits underneath roadways to the existing data center. As shown in Figure 5 (of Appendix B), the proposed workspaces will cross the following resource areas and buffer zones: 1. Land under the ocean: As articulated in 310 CMR 10.25 (2), LUO is defined as `land extending from the mean low water line seaward to the boundary of the municipality's jurisdiction and includes land under estuaries." 2. Land subject to coastal storm flowage(LSCSF): As listed in 310 CMR 10.02(1)(d), LSCSF is defined in 310 CMR 10.04 Definitions as"land subject to any inundation caused by coastal storms up to and including that caused by the 100-year storm, surge of record or storm of record,whichever is greater." 3. Buffer zone to coastal beach: As defined in 310 CMR 10.27(2), coastal beach means "unconsolidated sediment subject to wave, tidal and coastal storm action which forms the gently sloping shore of a body of salt water and includes tidal flats. Coastal beaches extend from the mean low water line landward to the dune line, coastal bankline or the seaward edge of existing human- www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 11 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT IMPACTS AND MITIGATION Amiti&Fiber Optic Submarine Cable System made structures, when these structures replace one of the above lines, whichever is closest to the ocean."The buffer zone to coastal beach extends 100 feet(30 meters) inland. The preliminary cable route is also within waters and areas under the jurisdiction of the Massachusetts Department of Environmental Protection Chapter 91 law and implementing regulations (Figure 6 of Appendix B). The installation of the cable is also considered the installation of a structure within waters of the United States,jurisdictional under Section 404 of the federal Clean Water Act. The Project crosses three different floodplain areas mapped by Federal Emergency Management Agency (FEMA). Zone VE, which is a coastal area with a 1 percent or greater chance of flooding and an additional hazard associated with storm waves is located within a portion of the roadway median where work will occur over the existing manhole. The second floodplain area is Zone AO,which is an area with 1 percent or greater chance of shallow flooding each year, usually in the form of sheet flow,with an average depth ranging from 1 to 3 feet. FEMA has this Zone AO area mapped as 3 feet of sheet flow. 4.1.2 project Impacts Project impacts to the seafloor(LUO) are limited to where tools and machinery will temporarily shift the sediment and/or impact benthic organisms underneath the stabilizing skis adjacent to the plow. The following impacts discussion pertains to work within the Massachusetts SSB and a summary of potential impacts is provided in Table 1 below. During pre-construction preparation of the underwater workspace, the RC and/or PLGR will impact the seafloor for 28.6 miles (46 kilometers)within the SSB, creating an impact footprint approximately 4.6 feet (1.4 meters)wide. At the time of installation, the burial plow will temporarily create track marks from skies and the plow itself will also impact the seabed. Each ski will leave a 5.6-foot-wide (1.7-meter-wide)temporary track mark that will return over time to natural conditions due to natural water currents and movement. The trench created and immediately backfilled by the plow will be approximately 0.7 feet(0.2 meter)wide (Exhibit 8)and approximately 4 to 6 feet(1.2 to 1.8 meters)deep. In areas of pipeline or cable crossings, the ROV water jet will be used and it is anticipated to create an impact footprint of approximately 1.4 feet(0.4 meter)for each ski and 1.1 feet (0.3 meter)for the water jet. Since the length of cable where the ROV jet will be used for installation is not yet known, total impact calculations have not been determined. Table 1 below assumes the larger equipment would be used for the length of marine installation. The total impact to LUO is calculated by adding the impact area for the plow and the skis. Since the RC/PLGR will run within the same corridor as the burial plow and skis, that impact area is not additive to the total impact to LUO; however, it is acknowledged that the area will be impacted twice in the same location within a short period of time. Based on review of the as-built survey of the Hibernia/GTT cable, it does appear that the full burial along the preliminary cable route is feasible. Due to the intent to bury the narrow cable along the entire length within Massachusetts waters, no permanent impacts to LUO are anticipated. If, following review of 2019 marine survey results, portions of the cable cannot be buried due to the characteristics of the seafloor, a plan for cable protection will be developed for those discrete areas, and permanent impacts to the seafloor will be calculated. www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 12 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT IMPACTS AND MITIGATION Amitie Fiber Optic Submarine Cable System 5.7 feet feet 5.7 feet Legend �*f%ftCAftA An..TM XA Pfo.Su Farb Rohs searmt 0 3 6ANrn The plow trench is backfilled immediately and the plow ski track marks are temporary. Exhibit 8: Plan View of a Section of Cable Burial Plow Impacts to Seafloor Sediment Table 1: Impacts to Land Under the Ocean from Installation of the Amitie Fiber Optic Submarine Cable System within Massachusetts State Waters Description of Impact Impacts Total length of seaward cable alignment(miles) 29.4 Total length of seaward existing conduit(miles) 0.8 Total length of new cable burying activity(miles) 28.6 Volume of temporary sediment re-positioned(nearest 500 yards3) 23,500 Route clearance and/or pre-lay grapnel run impacts(acres) 15.9 Disturbance from ski track marks(acres) 38.8 Total acres of impact of skis plus plow on LUO(acres) 42.0 Ground disturbance onshore is limited to the installation of the grounding rods at the data center. No wetlands, waterbodies, or tidelands are located on the data center parcel; therefore, no ground disturbance is proposed. Activities associated with construction in LSCSF will be limited parking vehicles, staging of equipment and vehicles over and near the existing manhole to make the connection between the offshore and onshore portions of the cable installation. A temporary fence will also be installed to surround the workspace needed on the median. Accordingly, the Project will not alter or disrupt the flood storage capacity of the mimerm.com Version:1.0 Project No.:0497639 17 June 2019 Page 13 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT IMPACTS AND MITIGATION Amitie Fiber Optic Submarine Cable System floodplain areas or LSCSF. Confirmation with the Nahant Conservation Commission will occur as to whether a filing under the WPA is required or not for the temporary parking within town boundaries, and a Notice of Intent will be filed with the Lynn Conservation Commission for the project, including the temporary use of equipment in LSCSF on the roadway median. Impacts to water quality from the pre-installation RC/PLGR as well as the use of the plow to create the trench and immediately backfill after simultaneous cable installation. The marine installation within Massachusetts is anticipated to take approximately 5 days and the impact on water quality is not anticipated to be significant. The seafloor in this region of Massachusetts undergoes heavy interaction with commercial fishing equipment on a regular basis and as such is regularly disturbed. 4.1.3 Mitigation Measures The Project has been specifically designed to reduce impacts to wetlands (i.e. Land Under the Ocean), waterways, and tidelands. The proposed landing site in Lynn was selected due to the existing infrastructure that will accept the cable due to thoughtful planning in the early 2000s when additional capacity was installed for both the offshore and onshore conduits. Using the existing conduit avoids impacts associated with burying the cable underneath the near-shore areas, including intertidal areas, coastal beach, and coastal bank. The installation vessel that will be used is capable of dynamic positioning, which eliminates the need for anchors to be used on the seafloor during cable installation. Anchoring effects in some locations around the globe, depending on water currents and local conditions, can substantially increase impacts to the seafloor; therefore, eliminating anchors has resulted in a great reduction of impacts to LUO in Massachusetts waters. Since the cable is such a small diameter, its burial under the seafloor will result in no permanent impact to LUO and the Project will have no effect or increase in storm damage or erosion of coastal beaches, coastal banks, coastal dunes, or salt marshes. ,12 s-pac] As described in 301 CMR 11.03(2), review thresholds identify categories of Projects or aspects thereof of a nature, size, or location that are likely, directly or indirectly, to cause damage to the environment. Review thresholds for State-listed species under M.G.L c. 131A include: 1. Alteration of designated significant habitat. 2. Greater than 2 acres of disturbance of designated priority habitat, as defined in 321 CMR 10.02, that results in a take of a state-listed endangered or threatened species or species of special concern. As defined in M.G.L c. 131A, to alter a habitat area is"to change the physical or biological condition of a habitat in any way that detrimentally affects the capacity of the habitat to support a population of endangered or threatened species". Habitat areas, also known as priority habitat, are areas identified where there is potential that a take of any Endangered, Threatened, or Special Concern species may occur as a result of an activity. In addition to state-protected species, additional review and assessment is required for species protected under various federal laws and implementing regulations as further described below. - 1.2 ,existing Environrnenr Communication with the Massachusetts Natural Heritage and Endangered Species Program (NHESP) has been initiated regarding the proposed Project and potential impacts to rare and endangered species pursuant to the Massachusetts Endangered Species Act(M.G.L. c. 131A)and its implementing regulations(321 CMR 10.00). A review has also been conducted of NHESP's most recent Priority Habitat www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 14 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT IMPACTS AND MITIGATION Amitie Fiber Optic Submarine Cable System of Rare Species and Estimated Habitats of Rare Species using MassGIS's online mapping application OLIVER. The existing conduit installed in the early 2000s extends offshore from the manhole within the roadway median and crosses underneath Priority Habitat(PH 1519)and Estimated Habitat for State- Protected Rare Species(EH 1081), as indicated in the Massachusetts Natural Heritage Atlas, 14th Edition (October 2017). Initial project coordination with the United States Fish and Wildlife Service and National Marine Fisheries Service (NMFS) has identified 12 marine mammal species protected under the Marine Mammals Protection Act that could occur in the Project area; two of these species are also listed under the Endangered Species Act. In total, there are 14 species listed under the Endangered Species Act that could occur in the Project area. Twenty-seven essential fish habitat(EFH)species/management units and one habitat area of particular concern of may occur in the Project area. The United States Army Corps of Engineers(USACE), as lead Federal agency for the Project, will be responsible for completing Section 7 consultation for species listed under the Endangered Species Act in the Project area, and for completing consultation for EFH and habitats of particular concern that may be affected by Project activities. Coordination with NMFS for potential impacts on marine mammals protected under the Marine Mammals Protection Act is also on-going. The proposed Project is in the "Multi-Use Area"of the MOMP planning area. Multi-Use Areas are open to all uses, activities, and facilities allowed under the Ocean Sanctuaries Act, including cables. For additional discussion regarding SSU resources related to protected whale habitats as identified in the MOMP, refer to Section 1.2.1. 4.2.3 Project Impacts Approximately 665 feet(203 meters)of cable will be routed through an existing conduit underneath Priority Habitat and Estimated Habitat for State-Protected Rare Species indicated in the Massachusetts Natural Heritage Atlas, 14th Edition (October 2017). Because the cable will be pulled to shore through the existing conduit, no ground disturbance is proposed within any areas of Priority or Estimated Habitat, and alteration of significant habitat will be avoided. However, because a portion of the route crosses under Priority and Estimated Habitat, a copy of the Notice of Intent submitted to the Lynn Conservation Commission will be forwarded to the NHESP for review and comment, pursuant to the Massachusetts WPA Regulations(310 CMR 10.37). Potential offshore temporary impacts, including use of the plow and the ROV jet plow, will be limited to the footprint of that equipment during installation of the cable. Existing organisms and habitat in this area are adapted to disturbance associated with active sediment transport and resuspension due to strong tidal currents and frequent fixed and mobile fishing gear use. Consultation with NMFS to assess potential impacts on EFH and marine mammals under the Magnuson-Stevens Fishery Conservation and Management Act(last amended May 2007)and Marine Mammals Protection Act(last amended 1994) is ongoing. 4.2.4 Mitigation Measures The only activity proposed within NHESP priority habitat is pulling the cable through an existing underground conduit that has been in place since the Hibernia cable was built in the early 2000s. Therefore, impacts on Priority Habitat and Estimated Habitat for State-Protected Rare Species will be avoided. A vessel with dynamic positioning will be used to avoid the need for anchoring along the cable route, thereby substantially reducing potential impacts to the seafloor and associated marine resources. Continued consultations with NMFS will define the most appropriate mitigation measures to protect marine mammals and EFH during cable burial. These mitigation measures may include time-of-year www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 15 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT IMPACTS AND MITIGATION AmitiC-Fiber Optic Submarine Cable System restrictions, passive acoustic monitoring, protected species observers, visual observers, or other recommended mitigation measures. Consultation is expected to continue through 2019. Historic and Archaeological Resources Geophysical data gathered along the preliminary cable route corridor is intended to satisfy the National Historic Preservation Act(NHPA) Section 106 requirements to identify and assess potential Project impacts to cultural resources. The Project's cultural resource specialists have communicated with and will work with the Massachusetts Board of Underwater Archaeology (BUAR)as well as the Massachusetts Historical Commission (MHC)and the USACE. 4.3.1 Existing Environment Marine cultural resources as well as onshore resources will be identified and addressed as part of the NHPA Section 106 review. ERM Consulting & Engineering, Inc. (ERM) is currently conducting a review of existing resources to identify known cultural resources within the Project workspace. ERM completed a preliminary desktop review of The Massachusetts Cultural Resource Information System; this preliminary review indicated four National Register of Historic Places inventory points within the median of the Lynn roundabout, including: The Aliferis, Don John Monument(LYN.998); Nahant Beach Boulevard—Lynnway Rotary(NAH.927); Nahant Beach Boulevard—Lynnway Rotary(LYN.996); and Lynn Spanish American War Monument(LYN.997). In addition, NOAA Office of Coast Survey data indicate that many shipwrecks are present along the north shore of Massachusetts(Figure 7 of Appendix B). The closest shipwreck mapped on the nautical charts is approximately 555 feet(169 meters)south of the preliminary cable route. The five shipwrecks near the preliminary cable route include: L&W.B.C. CO. 1, submerged wreck, non-dangerous, approximately 555 feet(169 meters) south of the preliminary cable route; Gloucester Queen, submerged wreck, dangerous to surface navigation, approximately 585 feet(178 meters) north of the preliminary cable route; Submerged wreck, dangerous, approximately 645 feet(197 meters) north of the preliminary cable route; Submerged wreck, dangerous, approximately 1,315 feet(400 meters) north of the preliminary cable route; and Submerged unknown wrecks, dangerous, approximately 1,325 feet(404 meters) north of the preliminary cable route. The following actions will be taken in 2019 to further the understanding of potential cultural resources present in the Project area: * Conduct a desktop study and BUAR database and records search of previously conducted marine surveys and recorded submerged cultural resources in alignment with the BUAR's reporting standards and requirements; Perform marine survey data review, analysis, and interpretation of the side-scan sonar, sub-bottom profiler, multi-beam echo sounder, and magnetometer data; www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 16 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT IMPACTS AND MITIGATION Amitie Fiber Optic Submarine Cable System Prepare a report summarizing the results of the marine remote sensing survey in accordance with the BUAR reporting guidelines; Submit the marine cultural resources remote sensing report to the BUAR, MHC, and the USACE; Respond to BUAR, MHC, and USACE comments on the report and provide a final marine cultural resources remote sensing report The geophysical survey data will be reviewed, analyzed, and interpreted to identify cultural resources such as shipwrecks and submerged pre-contact Native American archaeological sites. Once the BUAR, MHC, and USACE have reviewed and accepted the marine cultural resources remote sensing report, ERM will work with these regulatory stakeholders to identify the resulting requirements to complete the NHPA Section 106 reviews. 4.3.2 Project Impacts The current preliminary cable route avoids the shipwrecks identified above; however, cable installation activities could result in damage to unknown and unrecorded historic cultural resources such as shipwrecks and associated debris fields. The plow operating along the sea floor could potentially disturb previously unrecorded buried archaeological sites created by Paleoindian and Archaic period Native American groups that occupied the continental shelf when it was sub-aerially exposed during the last Ice Age. Project activities in the near-shore environment could potentially impact coastal Native American archaeological sites formed during the later Archaic and Woodland Periods when sea levels reached their current levels. Although the existing conduit connection is located 0.8 miles (1.3 kilometers) offshore the Project trenching activities are still considered nearshore. Project impacts will be further evaluated upon completion of the geophysical survey report and comparison to the cable route. 4.3.3 Mitigation Mesn r The preliminary cable route specifically avoids the shipwrecks identified in the NOAA charts. If additional marine cultural resources are identified in the marine survey results, appropriate measures to avoid, minimize, or mitigate potential Project impacts will be addressed as part of the NHPA Section 106 review. Once the BUAR, MHC, and USACE have reviewed and accepted the marine cultural resources remote sensing report, ERM will work with these regulatory stakeholders to identify the resulting requirements to complete the NHPA Section 106 reviews. Additional measures to avoid, minimize, or mitigate impacts to cultural resources will be developed upon completion of the proposed marine geophysical surveys and in consultation with the BUAR, MHC, USACE, and other cultural resource stakeholders, including Native American Tribes. AA Ocean Management Plan As stipulated in the Oceans Act of 2008 and Chapter 1 of the MOMP, execution is through existing state review procedures with all permits required to be consistent to the maximum extent practicable with the MOMP. The MOMP includes mapping and the evaluation of natural resources which may be sensitive to projects such as submarine cables. Page 2-33 of the MOMP states"For both cables and pipeline, the intent of the ocean plan is to minimize the cumulative impact of future development by requiring that linear infrastructure be co-located within common or adjacent corridors to the maximum extent practicable,with allowances for sufficient space between projects for necessary operations and maintenance generally according to industry standards." As noted throughout this narrative, the Project proposes to locate the Amitie submarine cable with the existing Hibernia/GTT cable installed in the early 2000s at the same landing point in Lynn. By using the existing infrastructure specifically installed with capacity for a future cable, and following a similar offshore www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 17 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT IMPACTS AND MITIGATION Amitie Fiber Optic Submarine Cable System route through Massachusetts waters, the Project minimized cumulative impacts to sensitive resources. While the management standards for cables do not include concentrations of water-dependent uses, the Project commits to working with local fishermen to avoid potential conflicts during cable installation. Specific notification protocols to fishermen that hold federal or state licenses will be notified in advance of the cable installation process. With the goal of burying the entire length of offshore cable in . Massachusetts waters, long-term adverse effects should be avoided on the substantial recreational and commercial fishing effort that contributes high value in this region. 4.4.1 SSUs The MOMP acknowledges the need for new telecommunication or other cables, and identifies the following SSU resources that must be addressed for submarine cable projects: 1. Core habitat of the North Atlantic right, fin, and humpback whales 2. Hard/complex seafloor 3. Eelgrass 4. Intertidal flats As described in the MOMP, allowed activities in the Multi-Use Area are managed based on an approach that directs new development away from critical marine ecosystem components, SSU resources, and areas important for water-dependent uses that were identified and mapped in the planning process. Figure 3 (Appendix B) illustrates the survey route relative to the SSU resources delineated in the MOMP for cable projects. Geophysical and geotechnical data continue to be evaluated along the preliminary cable route to confirm the locations of the SSUs, in particular the hard/complex seafloor. The preliminary cable route avoids delineated North Atlantic right whale core habitat, fin whale core habitat, hard/complex sea floor, eelgrass, and intertidal flats. The cable route traverses approximately 1.2 miles (1.9 kilometers) of humpback whale core habitat east of Cape Ann and north of Stellwagen Bank National Marine Sanctuary. Avoiding the humpback whale core habitat SSU would result in passing through Stellwagen Bank National Marine Sanctuary or crossing adjacent hard/complex sea floor. Therefore, the Project will aim to avoid impacts to humpback whales by committing to providing a marine mammal observer on the vessel during cable installation, maintaining a low vessel speed, and working with the National Oceanic and Atmospheric Administration (NOAA) Fisheries and Massachusetts Division of Marine Fisheries to identify other measures that could be implemented to avoid and minimize impacts. The preliminary cable route through Massachusetts waters is based on an extensive analysis of existing seafloor mapping, as well as an understanding of known locations of existing critical infrastructure (e.g., cables and pipelines) in the waters off the City of Lynn and Cape Ann. The preliminary cable route balances the potential impacts to SSUs and other environmental impacts and represents the alternative with the least environmental impact. With appropriate mitigation, including potential time of year preclusions for the crossing of the humpback whale core habitat SSU, the expectation is that this Project can be consistent with MOMP siting and performance standards for cables. 4.a Other Impacts 4.5.1 Land The Project will not construct impervious surfaces, nor will the Project result in the conversion of land or release from an interest in land held for conservation. In addition,the Project will not have aboveground structures or dwellings. Less than 0.01 acre (40 square meters) of land is anticipated to be disturbed onshore for the installation of the grounding rods. As a result, this Project does not meet the thresholds outlined in 301 CMR 11.03(1) (a)or(b). www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 18 EXPANDED ENVIRONMENTAL NOTIFICATION FORM PROJECT IMPACTS AND MITIGATION Amiti6 Fiber Optic Submarine Cable System 4.5.2 Transportation The Project does not consist of a new roadway or modification of transportation infrastructure. The Project does not meet the thresholds outlined in 301 CMR 11.03(6). The terminus of the Project is in the roundabout at the intersection of Lynnway, Lynn Shore Drive, and Nahant Road. The roundabout is heavily travelled, with Nahant Road being the only access to the Town of Nahant. The roads also provide access to recreational areas, businesses, and residences. Massachusetts Department of Transportation data indicate that Lynn Shore Drive had an annual average daily traffic volume of 28,927 in 2018.1 The cable will be pulled through the existing conduit below the road, resulting in no disruption to traffic. It is not anticipated that work will be conducted within the roadway as the existing manhole is approximately 80 feet inside the roundabout. The Project could cause minor traffic disruption as a result of work vehicles or equipment entering and exiting the median, but a traffic management plan will be created describing procedures for equipment and laborers entering the roundabout. 4.5.3 Wastewater The Project will not construct facilities pertaining to wastewater or result in the generation of sewage or storm water. The Project does not meet the thresholds outlined in 301 CMR 11.03(5). 4.5.4 Energy During operation, the fiber optic cable will be used to transmit data and will include an electrified line that will support the repeater system as data is transferred across great lengths; however,the Project will not construct facilities for electricity generation, transmission, or the transportation of fuel. As a result, the Project does not meet the thresholds outlined in 301 CMR 11.03(5). 4.5.5 Air No modifications to an existing stationary source or construction of a new stationary source are proposed. No air permits are anticipated to be required during construction or operation of the Project. In addition, the United States Environmental Protection Agency has indicated that the proposed vessels to perform the seaward construction do not require an air permit. The Project does not meet the thresholds outlined in 301 CMR 11.03(8). Due to the minor nature of the work, the expected construction period to last approximately five days for the offshore segment and five days for the onshore segment, resulting in limited opportunity for significant emissions, we respectfully request that the Secretary consider this Project to qualify for the de minimis exemption from the MEPA Greenhouse Gas Emissions Policy and Protocol. 4.5.6 Solid and Hazardous Waste The Project does not propose to store, treat, process, combust, or dispose of waste and does not meet the thresholds outlined in 301 CMR 11.03(9). 4.5.7 Noise During the construction phase, the Project will likely contribute some temporary noise impacts. Construction noise could be associated with ground disturbance at the existing data center to install grounding rods and to install the cable through existing conduits. Project noise will be temporary in nature and will occur during typical daily construction hours from 6 AM to 5 PM ET, Monday through Friday. The Lynn Public Schools Early Childhood center is located across the street to the data center, Mass DOT.2018.Transportation Management System.Available online at tittos://mhd.ms2soft.com/tcds/tsearch.aso?Ic .Accessed April 2019. www.enn.com Version:1.0 Project No.:D497639 17 June 2019 Page 19 EXPANDED ENVIRONMENTAL NOTIFICATION FORM ALTERNATIVES ANALYSIS Amitie Fiber Optic Submarine Cable System with additional abutting residences. However, due to the small area of excavation anticipated at the data center, and the brief construction period at all aboveground locations, noise impacts are anticipated to be minor in nature and will cease upon completion of the construction phase. When needed, extended construction hours will be coordinated with the City of Lynn and Town of Nahant, depending on the location of the need. Noise impacts during operation of the Project are not anticipated. Vessels involved with installation of the cable are anticipated to produce noise. These noise impacts will be limited to offshore environments and are not anticipated to impact shoreline communities. The noise generated by the vessel is expected to be in line with other vessels in the region. 5. ALTERNATIVES ANALYSIS An extensive alternatives analysis was conducted prior to selecting a cross-Atlantic cable landing in the City of Lynn, as described below. System Alternative It is difficult to evaluate a system alternative, as other means of transporting data signals cannot be performed at the strength of a hard line. Satellite technology is not an equivalent based on the performance, speed, bandwidth and reliability of a physical cable connection. The"no-build"alternative is a hypothetical scenario sometimes considered as a basis for comparing the development alternatives under consideration. Within the context of the Project, the 'do-nothing' scenario would mean that the Project would not be implemented and the Amiti6 Subsea Cable System would not be installed between Europe and North America. Given the demand for high-speed telecommunications links, capacity, reliability and diversity in North America, it is likely that another cable system would be proposed in the near future to address this demand. The details of such a proposed project are not known at this time but can be assumed to be similar in scope, and therefore involve similar impacts as those addressed in this document. Routing Alternatives Marine cable routes are developed through an iterative review of desktop and survey information, and incremental changes are made during this process. Several alternative cable routes are discussed below. 5.3.1 Shorter Straight Route To achieve a shorter length of offshore cable installation, a shorter straighter route from federal waters through Massachusetts to the same City of Lynn landing point was investigated. Such a route entering Massachusetts SSB approximately east of Lynn would reduce the total length of offshore cable by over 10 miles (16.1 kilometers). However, a straight route into Lynn would require the cable to cross Stellwagen Bank National Marine Sanctuary located just outside the SSB. Seabed disturbance in the Sanctuary is prohibited and, during pre-application agency meetings, NOAA indicated that obtaining a permit to cross the sanctuary may not be feasible. In addition, a straight route into Lynn would require crossing a substantial portion of hard bottom, which is an SSU to be avoided by cable projects to the maximum extent practicable to comply with the MOMP. Crossing hard bottom would preclude burying of the cable. Crossing hard bottom in waters less than 49.2 feet (15 meters) in depth could require the use of articulated pipe installed by divers and additional armoring of the cable. In waters deeper than 49.2 feet(15 meters), no articulated pipe would likely be used; however, additional armoring of the cable to protect the cable from harm may be required for the surface lay over the hard bottom. This route would www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 20 EXPANDED ENVIRONMENTAL NOTIFICATION FORM ALTERNATIVES ANALYSIS Amitie Fiber Optic Submarine Cable System also cross the humpback whale core habitat SSU and could possibly also cross the finback whale core habitat SSU. So while this route would result in a shorter section of offshore cable installation, the increased complexity of the protection of the cable to be laid on the surface of hard bottom, potentially with a higher risk of interaction with fishing gear, combined with the crossing of two whale core habitats results in this alternative being less preferred. 5.3.2 Northern Connection A landing point was investigated in either Rockport or Gloucester(Northern Connection), with a land route southward to the data center. Much of the Massachusetts coastline is home to sensitive dune systems, both unprotected and protected (especially near Rockport and Gloucester). To disturb/drill a new conduit underneath these features would pose both an environmental risk and create new permanent impacts at the receiving point/manhole that would be required to be installed along the coast. Additional temporary workspaces would be needed along the coast for either burying the cable or to use a horizontal direction drill (or similar)entry/exit point on the shore. While a northern connection could reduce the length of the marine cable installation by more than 20 miles (32 kilometers), it would greatly increase the landward route. In addition to the landing, significant trenching would be required onshore to connect the cable from Cape Ann down to the data center in Lynn, including the installation of new conduits. So while this route would result in a shorter section of offshore cable installation, the environmental impacts are deemed to be greater and this alternative is not preferred. 5.3.3 Preferred Route Based on desktop review, the preliminary cable route through Massachusetts incorporates avoidance of key features in the Project area, including SSUs and the Stellwagen Bank National Marine Sanctuary just east of the Massachusetts SSB. Route survey data will allow minor route adjustments to increase burial feasibility along the planned route. This preferred route also maximizes use of existing infrastructure both in the offshore conduit as well as the onshore conduits at the existing Lynn landing site. These infrastructure elements were specifically authorized by state agency actions in the early 2000s to support the addition of a second future cable; there the preliminary cable route identified and evaluated through this document is considered the preferred route. www.erm.com Version:1.0 Project No.:0497639 17 June 2019 Page 21 ti I i I I I I .I .l I-C I L ti l t� �1 n n n � B n �-, • � --•, _,5 �.� ,-7 r ,� _� _7 �� -.� ,y ' } f } -- I r s IJ tij Appendix B FIGURES Figure 1: Project Overview Map Figure 2: State Waters and Municipalities Map Figure 3: Special, Sensitive, or Unique Resources Figure 4: Landing Area Figure 5: Coastal Resource Areas and Buffer Zones Figure 6: Environmental Constraints Figure 7: Shipwrecks Identified within the Project Area www.erm.com Version:1.0 Project No.:D497639 17 June 2019 i 4 l l •� - C SEE± . 2 e © 3 2 � t5 v E' . k ° 2 Reco ® I $ t \ c $ - @ .� a. � .uj / / {) - > » 2 2 ^ © \ « U a Al K 'S ƒ 2 ] - � ] -\' , • @ _ c \ IL \ `3 Ra �• \ In 0 f « ® -OK s k } } - � c : § ) � k � a � � k . ) » # � \ � k � ` \ � . \ �- � A ! c � k - - k ® >- k e § i i i t t r 0m m � mN o cw ) a 3fo 3^ Q 'au a w W - 1 bq a' d i p p p OW C m c Y y y m c p N LL dml dl LL .�. lL (� E m LL N a)Il W y V T li ON1 N . C i O fC 'p a y a v D v yC L v °° c, N j V1 U = N = tc6 W m A aND Y Ia��i O O^ yvy .Vii N y O 111u�1 c r+ •Gi �C C G o> 1 �m ma �. J 1 Q N �r f _ t I I I � 1 ,! 1 t I ;t 1 t k ti l L 1 �J ra c N d a itl q ti m U A £ � fi m ro uw o m � 3 ❑ d >, > v ° v d � o� te1 oil3mI 0 t z s � A 91T b y v 3 � u b q m v xU y m n ax Hd v A 9 @ tea+L 3x � �CD 3 x wU dO \ 0 y t? ¢® e� p c a — y D 6 a b t a' x s m a CIO On v aQtl,HHH7H3I � a - �: t C a ; ti a A s z - j } F � i i �� i �+ �{ i �� , t � �t �y. �ti �� 1� i L� 0 U t J C y P �J O r 3 C N G o y �� c m U y - w 0 W 0 Q W j X J cn a e u % I j 00 / s K ,f - �..� • 1 e ;,•: .;,fir� .� � '., _ I` 1 I 1 1 �1 ti I� 1 1 II S I Il I} I IL Ij I� 11� 4 7� IL IL1 ------------------ 1 Legend = Existing Data Center Location t - _ - — Data Center Route Amitie Cable Alignment Existing Conduit S me=200 feet f ` ► ``` � 100-foot Buffer Zone to Coastal Beach (Approximate) ,' - ,� . Coastal Beach ! �► . Barrier Beaches Temporary Parking/Staging Area ----y '' Town Boundaries Offshore - - , r �; M. ,• - � ��I FEMA Flood Zone Designations ioft }.. AE: 1%Annual Chance of Flooding,with BFE . .,.-`� r• s �_T ti , AO: 1%Annual Chance of 1-3ft Sheet Flow Flooding,with Depth _ - r — ■-t ; 1 .R VE: High Risk Coastal Area(Land Subject to � i Coastal Storm Flowage) N .! .,. ► H r`�r .._.Y �. + --l► - �;s '� NOTES: 1.Aerial Imagery:ESRI World Imagery Reproduced under license in ArcGIS 10.5 _.' �� rr♦ _ �� r.� . a s • r .rr— rr - II • -,� 1 t �' Land Under •r �- — i `' I� r - • Ocean 0 250 500 1,000 1,500 - �- ------ : - -- � I Feet Figure 5. Coastal Resource Areas and ' i �,• Buffer Zones%If E x'- Amitie Submarine Cable —+ System _ Lynn, MA June 2019 ERM c r t t i t �. l t. t t t t �. � ' � ' f 3 v a d N w G tv ' m Z G o m a v v = a to `! c l �i i0 N M n y e N al U OI d IL W u s C A 0 0 p0 a W O Q W Z Z F �JJ a+ a 1 a i �.uojsawvms i - i i F `• F i �, i i �� } I o a y Its li � m y tL y d � L cl _� «. m m S✓1 U ,fir a o 3 Z � D•d -1 ^3 rn R C rn m U rn m o '14 '••. E C �' V J VI m E x m 9 a Q W 6, ♦—o ,�, ,� i~ 'w E N t t a,ss. • y F CO ,n i 4 7 , �' t 1 T I • 1 ! ( J 1 t 1 i JY. NIP 1 , ` f I e , ' ' � i • 1 f = ♦, r R 1 _ • ' ilu it- it ' _ . _ :.� .. • 1 NOW �� -" 1' "•cam. I = - . . � °��° 9R'• •1 � t4 , y itlf � 1 f ,y_. �•s.7� � �� r• �ba• } 9��ti .rjit' .k:ffQ T , �, 1'�`,~ �<'' •••a ! Z, t.•.1/ � r �fi ~q't°j� �rl`i 4'P •I• x m � ` �� "�fi��I I} f �. •.; ei 1,1 � a�';��=$i{, d` Rom`. •O . ll�! J mlp [ N r, co co Y i ' .� �t �� ., �� .� ��, .� �� Fl n n n r� n n C �-�, ry .-.f r^� " 1 .-_} `-1 ` 1 :-y � l � � : � f � , y { � ; 1 tit �} ti A C ..t. Li U Lj r, r r-. Appendix C PERMIT TABLE www.erm.com Version:1.0 Project No.:0497639 17 June 2019 � � �+ l 1 4 t �� s L ;� �� _ �� ,� �� 4 ,� ,� ,� r�r• �� {�� 1-r EXPANDED ENVIRONMENTAL NOTIFICATION FORM APPENDIX C r Amitie Fiber Optic Submarine Cable System Environmental Consultations and Permits for Project Agency/Regulatory Authority Permit/Approval Federal r•. ■ U.S.Army Corps of Engineers Individual Permit under Section 404 Clean Water Act and Section 10 of the Rivers and Harbors Act ■ U.S. Fish and Wildlife Service Endangered Species Act Section 7 Consultation m U.S. Fish and Wildlife Service Region 5 Migratory Bald and Golden Eagle Protection Act(Not Anticipated),- Bird Permit Office Migratory Bird Treaty Act(Not Anticipated) Endangered Species Act Section 7 Consultation and y NOAA National Marine Fisheries Service,Protected Resource Division Marine Mammal Protection Act Incidental Harassment Authorization NOAA National Marine Fisheries Service Habitat Magnuson-Stevens Fishery Conservation Management Conservation Division Act Consultation State e Executive Office of Energy and Environmental Expanded Environmental Notification Form and Single Affairs—Massachusetts Environmental Policy Act Environmental Impact Report Certificates Massachusetts Department of Environmental Individual 401 Water Quality Certification, Chapter 91 Protection—Northeast Regional Office Waterways License and Permit Massachusetts Historical Commission and Section 106 of the National Historic Preservation Act Massachusetts Board of Underwater Archaeological Resources Consultation Massachusetts Office of Coastal Zone Management Federal Coastal Zone Consistency Review Massachusetts Department of Conservation and Construction Access Permits Recreation Special Use Permit for the Marine Underwater Massachusetts Board of Underwater Archaeology Survey, and a Determination of No Adverse Archaeological Resources(MBUAR) Effect Local ■ Beverly Conservation Commission Order of Conditions and Local Ordinance Authorization ■ Gloucester Conservation Commission Order of Conditions and Local Ordinance Authorization ■ Lynn Conservation Commission Order of Conditions ■ Manchester-by-the-Sea Conservation Commission Order of Conditions and Local Bylaw Authorization ■ Marblehead Conservation Commission Order of Conditions and Local Bylaw Authorization * Salem Conservation Commission Order of Conditions and Local Ordinance Authorization a Swampscott Conservation Commission Order of Conditions ■ Nahant Conservation Commission Negative Determination .a. Rockport Conservation Commission Order of Conditions and Local Bylaw Authorization l i ti IL .4 I L ,t t L � ' r1 �1 r� r`1 r-� _. '-1 `-1 �'} .-, __,� r•, 1 ` �I -, D ..� . ., . �� 4 r r j . 1 i ti .t 4 t t � i �� ,� ��. �� t� �ls� '�+ � � �� r � �1 �� i i �� } �, �z: .� �l �i �� i �' `��_ +\ V-• `.. Appendix D ENF CIRCULATION LIST www.erm.com Version:1.0 Project No.:0497639 17 June 2019 i 5 i+ ii it 1 i .� J u if � � { i i� 4 i ii .� ii �� ii i ti { � � 1 l EXPANDED ENVIRONMENTAL NOTIFICATION FORM APPENDIX D Amitie Fiber Optic Submarine Cable System ENF Circulation List Kathleen A. Theoharides, Secretary Attn: MEPA Coordinator Executive Office of Energy Massachusetts Department of Conservation and and Environmental Affairs Recreation Attn: MEPA Office 251 Causeway Street, Suite 600 100 Cambridge Street, Suite 900 Boston, MA 02114 Boston, MA 02114 (2 copies) Attn: Project Review Coordinator Coastal Zone Management Massachusetts Department of Transportation 251 Causeway Street, Suite 800 Public/Private Development Unit Boston, MA 02114 10 Park Plaza, Suite 4150 Boston, MA 02116 Massachusetts Department of Environmental Protection -Waterways Regulation Program Massachusetts Historical Commission One Winter Street, 5`h floor The MA Archives Building Boston, MA 02108 220 Morrissey Boulevard Boston, MA 02125 Massachusetts Department of Environmental Protection—Division of Wetlands and Waterways Metropolitan Area Planning Council One Winter Street 60 Temple Place, 611 floor Boston, MA 02108 Boston, MA 02111 Beverly City Council Board of Selectman Massachusetts Division of Fisheries&Wildlife City Hall Natural Heritage and Endangered Species 191 Cabot Street Program Beverly, MA 01915 1 Rabbit Hill Road Westborough, MA 01581 Beverly Planning Board/Department City Hall Division of Marine Fisheries 191 Cabot Street Division of Marine Fisheries(North Shore) Beverly, MA 01915 30 Emerson Avenue Gloucester, MA 01930 Beverly Conservation Commission City Hall Attn: MEPA Coordinator 191 Cabot Street Massachusetts Department of Environmental Beverly, MA 01915 Protection Northeast Regional Office Beverly Board of Health 205B Lowell Street 90 Colon Street Wilmington, MA 01887 Beverly, MA 01915 Attn: MEPA Coordinator Beverly Public Library Massachusetts Department of Environmental 32 Essex Street Protection Beverly, MA 01915 One Winter Street Boston, MA 02108 Gloucester City Council 9 Dale Road Attn: MEPA Coordinator Gloucester, MA 01930 Massachusetts DOT District 4 Office 519 Appleton Street Gloucester Planning Board Arlington, MA 02476 9 Dale Road Gloucester, MA 01930 EXPANDED ENVIRONMENTAL NOTIFICATION FORM APPENDIX D Amiti6 Fiber Optic Submarine Cable System Gloucester Conservation Commission Marblehead Selectmen's Office 9 Dale Road 188 Washington Street Gloucester, MA 01930 Marblehead, MA 01945 Gloucester Department of Health Marblehead Planning Board 9 Dale Road 188 Washington Street Gloucester, MA 01930 Marblehead, MA 01945 Sawyer Free Library Marblehead Conservation Commission 2 Dale Avenue 7 Widger Road Gloucester, MA 01930 Marblehead, MA 01945 Lynn City Council Marblehead Health Department 3 City Hall Square 7 Widger Road Room 408 Marblehead, MA 01945 Lynn, MA 01901 Abbot Public Library Lynn Planning Board 235 Pleasant Street 3 City Hall Square Marblehead, MA 01945 Lynn, MA 01901 Salem City Council Lynn Conservation Commission 93 Washington Street Room 401, City Hall Salem, MA 01970 3 City Hall Square Lynn, MA 01901 Salem Planning Board 93 Washington Street Lynn Public Health Division Salem, MA 01970 3 City Hall Square Lynn, MA 01901 Salem Conservation Commission 98 Washington Street, 2nd Floor Lynn Public Library Salem, MA 01970 5 N Common Street Lynn, MA 01902 Salem Health Department 98 Washington Street, 2nd Floor Manchester-by-the-Sea Board of Selectmen Salem, MA 01970 10 Central Street Manchester-by-the-Sea, MA 01944 Salem Public Library 370 Essex Street Manchester-by-the-Sea Town Planner Salem, MA 01970 10 Central Street Manchester-by-the-Sea, MA 01944 Swampscott Board of Selectmen 22 Monument Avenue Manchester-by-the-Sea Conservation Swampscott, MA 01907 Commission 10 Central Street Swampscott Planning Board Manchester-by-the-Sea, MA 01944 22 Monument Avenue Swampscott, MA 01907 Manchester-by-the-Sea Board of Health 10 Central Street Swampscott Conservation Commission Manchester-by-the-Sea, MA 01944 22 Monument Avenue Swampscott, MA 01907 Manchester-by-the-Sea Public Library 15 Union Street Swampscott Board of Health Manchester, MA 01944 22 Monument Avenue Swampscott, MA 01907 EXPANDED ENVIRONMENTAL NOTIFICATION FORM APPENDIX D Amitie Fiber Optic Submarine Cable System Swampscott Public Library Massachusetts Lobstermen's Association 61 Burrill Street 8 Otis Place Swampscott, MA 01907 Scituate, MA 02066 Nahant Board of Selectmen's Office Phil Colarusso Nahant Town Hall U.S. Environmental Protection Agency 334 Nahant Road Region 1 Nahant, MA 01908 5 Post Office Square, Suite 100 Boston, MA 02109 Nahant Conservation Commission Nahant Town Hall Christine Jacek 334 Nahant Road U.S.Army Corps of Engineers, New England Nahant, MA 01908 District Office 696 Virginia Road Nahant Planning Board Concord, MA 07142 Nahant Town Hall 334 Nahant Road Nahant, MA 01908 Nahant Board of Health Nahant Town Hall 334 Nahant Road Nahant, MA 01908 Nahant Public Library 15 Pleasant Street Nahant, MA 01908 Rockport Board of Selectman Town Hall 34 Broadway Rockport, MA 01966 Rockport Planning Board Town Hall Annex 26 Broadway Rockport, MA 01966 Rockport Conservation Commission Town Hall Annex 26 Broadway Rockport, MA 01966 Rockport Board of Health Town Hall Annex 26 Broadway Rockport, MA 01966 Rockport Public Library 17 School Street Rockport, MA 01966 I y I I I� I � II ,i L �{ I I - I I II I I 1 I i I I 1• ��I �I I� I I �i I� lu