Clean Path NY

New York State Energy Research and
Development Authority (NYSERDA)
Purchase of New York

Tier 4 Eligible Renewable
Energy Certificates (RECs)
RFP No. T4RFP21-1 • May 2021
Clean Path NY | Step Two Proposal | TOC
Table of contents
Cover letter Section 9. Energy storage operation plan 152
Acronyms and abbreviations Section 10. Business entity and

financing plan 156
Section 1. Executive summary 1
Section 11. Permitting plan 170
Section 2. Impacts of COVID-19 on proposer
and project development 23 Section 12. Environmental mitigation plan 199
Section 3. Proposer experience 27 Section 13. Project schedule 221
Section 4. Resource description and Section 14.O

perational flexibility and
site control 69 peak coincidence 231
Section 5. Delivery plan 119 Section 15. Communities engagement plan 240
Section 6. Baseline verification plan 142 Section 16. Incremental economic

benefits plan 271
Section 7. Interconnection plan 143
Section 8. Energy resource assessment 150

Appendices Appendix 18. Mott MacDonald Field Investigation Plan
Appendix 1. NYPA asset maps Appendix 19. Mott MacDonald Contracting Strategies
and Execution Overview Plan
Appendix 2. Key personnel resumes
Appendix 20. Project Schedule
Appendix 3. Invenergy Resources control status summary
Appendix 21. P(50) 8760 schedule
Appendix 4. Third-party developer support letters
Appendix 22. Communities and demographic data
Appendix 5. Tier 4 REC Standard Form Purchase and around generation
Sale Agreement memorandum
Appendix 23. Communities and demographic data
Appendix 6. New Transmission route mapbook around transmission
Appendix 7. PowerGEM Reliability and Market Analysis report Appendix 24. Clean Path New York Benefit Cost Assessment
Appendix 8. Class Year 2017 Facilities Study Appendix 25. NYS Building and Construction Trade Council
PLA Letter
Appendix 9. Class Year 2019 Facilities Study
Appendix 26. Fraser Converter Station Site Control
Appendix 10. Verona Solar feasibility studies
Appendix 11. P(50) 12x24 energy resources
Appendix 12. NYPA audited financial statements (3 years) Separately submitted files
Appendix 13. Invenergy audited financial statements (3 years) Appendix F-1. Master Offers Form
Appendix 14. Permitting Plan figures and maps Appendix F-2. Offer Data Form
Appendix 15. National Historic Landmarks and NRHP-Listed Sites Appendix H. Proposal Certification Form
Appendix 16. AKRF Air Quality and Benefits Distribution to

Disadvantaged Communities report
Appendix 17. Appleseed Economics and Community Benefits report

Acronyms and abbreviations
Acronym/ Acronym/
abbreviation Meaning abbreviation Meaning
AA Blacks/African Americans CLCPA Climate Leadership and Community Protection Act
AC Alternating current COD Commercial Operation Date
ACOE Army Corps of Engineers COO Chief Operations Officer
ACORD Association for Cooperative Operations Research and Development COPD Chronic obstructive pulmonary disease
ACSR cable Aluminium conductor steel-reinforced cable CORE CCCG Overseas Real Estate
ACSS cable Aluminum conductor steel supported cable CRIS Capacity Resource Interconnection Service
ADA Americans with Disabilities Act CRIS cultural Cultural Resources Information System
AIS substation Air insulated substation CSC Convertible static compensator
AKRF Allee King Rosen and Fleming, Inc. CTE Career and Technical high schools
BG Blenheim-Gilboa CY Class year
BRS Bull Run Solar DAC Disadvantaged communities
CAISO California Independent System Operator DBM Design Basis Manual
CAPEX Capital expenditure DC Direct current
CDC Centers for Disease Control and Prevention DEC Department of Environmental Conservation
CDO Chief Data Officer DFWMR Division of Fish, Wildlife and Marine Resources
CEB Clean Energy Business DOS Department of State
CDT Contract delivery term DPS Department of Publice Services
CECONY Consolidated Edison Company of New York, Inc. EA Environmental assessments
CEII Critical Electric Infrastructure Information EB ID Economic Benefit ID
CEO Chief Executive Officer ECI Early contractor involvement
CEP Communities Engagement Plan ECL Environmental Conservation Law
CFO Chief Financial Officer EDP Energía del Pacífico
CFR Code of Federal Regulations EDR Environmental Design and Research
cfs Cubic feet per second EH&S Environment, health, and safety
CHW Community Health Worker EIS Environmental impact statements
CIP Critical Infrastructure Protection EJ Environmental justice
Acronym/ Acronym/
EM&CP Environmental Management and Construction Plan HVDC High voltage direct current
EMF Electro-magnetic field IDA Industrial Development Agency
EMS Emergency Management Services IEBP Incremental Economic Benefits Plan
EPA Environmental Protection Agency IEDP Innovative Energy Demonstration Program
EPC Engineering, procurement and construction IFB Issue for Bid
EPMC Engineering, procurement, and construction IFC Issue for Construction
ERCOT Electric Reliability Council of Texas IFR Issue for Review
ERIS Energy Resource Interconnection Service IGBT Insulated gate bipolar transistors
ERP Emergency Response Plan IMPLAN Impact analysis for planning
ESNA Energy Storage North America IPaC Information, Planning, and Consultation
EVP Executive Vice President IPFC Interline Power Flow Controller
FAA-DNH Federal Aviation Agency Determination of No Hazard ISO Independent System Operator
FACTS Flexible AC transmission system ISO-NE Independent System Operator New England
FAST manholes Fault Annunciating Self-inspecting Transmission manholes IT Information technology
FAT Factory acceptance test ITC Investment Tax Credit
FEMA Federal Emergency Management Agency JSA Job safety analysis
FERC Federal Energy Regulatory Commission JV Joint venture
FSRU Floating storage regasification unit kcmil Thousand Circular Mil
FTE Fiull-time equivalent kV Kilovolt
FWS Fish and Wildlife Service kWh Kilowatt hour
GAAP Generally Accepted Accounting Principles LA California Los Angeles
GDP Gross Domestic Product LCR Locational Minimum Installed Capacity Requirement
GHG Greenhouse gases LEED Leadership in Energy and Environmental Design
GIA Generator Interconnection Agreement LEM Lifecycle Extension Modernization
GIS Geographic information system LIDAR Light intensity distance and ranging
GIS substation Gas insulated substation LNG Liquefied natural gas
GNSS Global Navigation Satellite System LOD Limits of disturbance
GP General Permit LWRP Local Waterfront Revitalization Program
GTO thyristor Gate turn-off thyristor M&A Mergers and acquisitions
GW Gigawatt MET Meteorological evaluation towers
HDD Horizontal directional drill MISO Midcontinent Independent System Operator
HIPPA Health Insurance Portability and Accountability Act MLLW Mean Lower Low Water
HUC Hydrologic Unit Code MOA Memorandum of Agreement
HVAC High voltage alternating current MOC Management of Change
Acronym/ Acronym/
MP Milepost NYSDPS New York State Department of Public Service
MSG Mineral Soil Group NYSE New York Stock Exchange
MTA Metropolitan Transportation Authority NYSEG New York State Electric and Gas Corporation
MVA Mega volt amps NYSERDA New York State Energy Research and Development Authority
MW Megawatt O&M Operations and maintenance
MWBE Minority/Women-owned Business Enterprise O&R Orange and Rockland Utilities, Inc.
MWh Megawatt hour OATT Open access transmission tariff
NAESB North American Energy Standards Board ODF Offer Data Form
NEPA National Environmental Policy Act OEM Original equipment manufacturer
NERC North American Electric Reliability Corporation OGS Office of General Services
NGO Non-governmental organization OMB Office of Management and Budget
NGVD National Geodetic Vertical Datum OPRHP Office of Parks, Recreation, and Historic Preservation
NHD National Hydrography Dataset ORES Office of Renewable Energy Siting
NOAA National Oceanic and Atmospheric Administration P&ID Piping and instrumentation diagram
NOI Notice of Intent PEJA Potential Economic Justice Areas
NPCC New York City Panel on Climate Change PEP Project Execution Plan
NPDES National Pollutant Discharge Elimination System PFD Process flow diagram
NPV Net present value PHA Process hazard analysis
NRHP National Register of Historic Places PILOT Payment in lieu of taxes
NTAC NYPA Transmission Adjustment Charge PIP Public Involvement Program
NWI National Wetlands Inventory PJM PJM Interconnection LLC
NYC New York City PM Particulate matter
NYCA New York Control Area PO Purchase orders
NYCDEP New York City Department of Environmental Protection POI injection Point of injection
NYCDOT New York City Department of Transportation POI interconnection Point of interconnection
NYCRR New York Codes, Rules and Regulations POW Protection of Waters
NYGATS New York Generation Attribute Tracking System PPA Power Purchase Agreement
NYISO New York Independent System Operator, Inc. PPE Personal protective equipment
NYPA New York Power Authority PSA Professional Service Agreement
NYS New York State PSC Public Service Commission
NYSDAM New York State Department of Agriculture and Markets PTC Production Tax Credit
NYSDEC New York State Department of Environmental Conservation PTP Point-to-point
NYSDOS New York State Department of State pu Power unit
NYSDOT New York State Department of Transportation PV Photovoltaic
Acronym/ Acronym/
QA/QC Quality assurance/quality control UPNY Upstate New York
REC Renewable Energy Certificate US United States
RFP Request for proposal USACE United States Army Corps of Engineers
ROW Right of way USCG United States Coast Guard
RT&E species Rare, Threatened, and Endangered species USFWS United States Fish and Wildlife Services
RTO Regional tranmission operator USGS United States Geological Survey
SBS Small Business Services VOC Volatile organic compounds
SCFWH Significant Coastal Fish and Wildlife Habitats VOSB Veteran-Owned Small Business
SDVOSB Service Disabled Veteran Owned Small Business VP Vice President
SENY Southeastern New York VSC Voltage source converter
SEQRA State Environmental Quality Review Act WBS Work Breakdown Structure
SERC State Electricity Regulatory Commission WECC Western Electricity Coordinating Council
SHPO State Historic Preservation Office XLPE Cross-linked polyethylene
SIEPAC Central American Interconnection System
SPDES State Pollutant Discharge Elimination System
SPP Southwest Power Pool
SRIS System Reliability Impact Study
SSSC Static Synchronous Series Compensator
STATCOM Static Synchronous Compensator
STEM Science, technology, engineering, and mathematics
STL St Lawrence FDR Power Project
SUNY State University of New York
SVP Senior Vice President
SWPPP Stormwater Pollution Prevention Plan
T&C Terms and conditions
TBD To be determined
TO Transmission Owners
TTC Transmission transfer capability
TVA Tennessee Valley Authority
TWh Terawatt hour
U.S.C. United States Code
UCAP Unforced capacity
UDR Unforced delivery rights
UPFC Unified Power Flow Controller
Section 1
Executive summary
Clean Path New York | Step Two Proposal | 1
1 Executive summary
1.1. Introduction
New York’s Climate Leadership and Community Protection Act
(CLCPA) of 2019 provides the roadmap for a green energy future and
sets our state on an ambitious course to lead the nation in fighting
climate change. We must achieve the aggressive goals laid out by
the CLCPA for two very simple reasons: they provide what may be
the single greatest economic opportunity for the people of New
York and, equally important, they represent a moral imperative in the
effort to preserve our planet. New York stands uniquely positioned to
strengthen its international leadership in the shift from the fossil-fuel
Figure 1-1. Clean Path New York represents an "All Renewable, All New York" energy vision.
past to an all-renewable, completely clean electricity system of the
future. This green vision will power a rebirth of our State’s economy By delivering renewable power directly to Zone J (New York City)
in the wake of the COVID-19 pandemic and provide a sorely needed and alleviating the bottleneck preventing upstate-generated clean
rebalancing of equity—with respect to both economic opportunity energy from reaching downstate, Clean Path New York solves one of
and public health. New York’s most vexing challenges, the so-called “Tale of Two Grids.”
At the same time, Clean Path New York will remake the engine of
The New York Power Authority (NYPA) and Forward
opportunity that powers our great state and deliver a transformative
Power (a joint venture of Invenergy and energyRe) economic and environmental justice victory for New York.
are proud to present Clean Path New York, a bold
and transformative “All Renewable, All New York”
energy vision.
Representing over $11 billion of investment and over 7,900,000
megawatt hours1 (MWh) of new emissions-free energy each
year, Clean Path New York joins together clean energy – generated
across New York State, by New York workers – with new
state-of-the-art transmission demonstrating the power of public-
private partnerships to deliver transformative change for the State.
1
Including NYPA's Blenheim-Gilboa pumped storage facility. Figure 1-2. Current New York State energy profile.
Here is how we do it. As a buried line using existing rights- of-way, Clean Path New York
will expedite permitting, mitigate potential community concerns, and
Clean Path New York is centered on the principle of “All Renewable, All be more resilient than above-ground alternatives in the face of severe
New York” for all aspects of the project, which encompass $7.5 billion weather and security threats.
of new generation and $3.5 billion of new transmission
infrastructure, with delivery beginning in June of 2026
at a competitive strike price inclusive of transmission of
1.3 GW state-of-the-art HVDC link over
$ per MWh. The value drivers differentiating Clean Path New
York as a uniquely compelling offering are summarized below.
175 miles between Zone E and Zone J
An “All Renewable, All New York” Resource Portfolio

Clean Path New York’s portfolio of 100% in-state, advanced
development-stage renewable projects is the most technologically and
geographically diverse available. It comprises over 2,000 MW of
new wind and 1,800 MW of new solar assets, with almost 60%
of this generation being developed directly by Clean Path New York
and the balance by third parties. The scale and quality of this portfolio
are further enhanced by the New York Power Authority’s existing 1,160
MW Blenheim-Gilboa pumped storage facility in Schoharie County,
which will provide over 375,000 MWh of firming services to maximize
the availability and reliability of renewable power delivered via the
transmission line.
An Upstate-to-NYC Underground
Transmission Connection
Clean Path New York’s new 175-mile, 1,300 MW HVDC transmission
link will create a direct connection from Upstate to New York City,
interconnecting in Zone E, which is north and west of the main source
of system congestion at the Total East interface, and delivering
into Zone J. To enhance project viability, it will be located entirely
underground and underwater and primarily in the existing rights-of-way
of the New York Power Authority’s Marcy South 345 kV transmission
corridor (105 of 175 miles). Figure 1-2. Delivery of renewable energy to New York City is projected to begin in June 2026.
Economic, Climate and Equity Benefits that Keep and other criteria pollutants—(NOx , SO2, and Particulate Matter (PM))—
CLCPA’s Promise Clean Path New York will result in over $6.25 billion in
Clean Path New York offers the State an opportunity to reimagine avoided social and public health costs over 25 years, with
and reinvigorate our economy with clean, affordable energy, while over 50% of these benefits in New York City and 40%
realizing the climate and equity benefits promised by CLCPA. accruing to disadvantaged communities across the state.
Clean Path New York will create over 10,500 person years of
Clean Path New York will deliver $12 billion of cost in-state jobs over the first three years of the contract delivery
term – all paying prevailing wage. Clean Path New York generates
savings to ratepayers across the State in its first
over $4.3 billion Category 1 and 2 incremental economic
25-years of operation.
benefits, 36.3% of which flow to disadvantaged
These will be driven in large part by $5.6 billion communities. In addition, Clean Path New York will invest $270
of congestion cost savings that emerge from the million in Category 3 workforce development, public health, and
project’s resolution of the “Tale of Two Grids” as its community programs to provide a pathway for members of our most
converter station location in Zone E dramatically vulnerable populations to emerge as a vibrant new green workforce
reduces congestion across the Total East and UPNY- that will continue to build New York’s future while also enhancing
SYNY interfaces. the overall quality of life in these communities. This brings the
project’s total investment in disadvantaged communities
to 40% overall – in line with goals of the CLCPA.
Importantly, the Clean Path New York transmission line will have a
lifespan that lasts—and delivers savings—well beyond 25 years.
It will be an enduring lifetime asset for New York, with operations likely
to continue for 70 years and more.
Clean Path New York will help the State achieve the CLCPA goals
while delivering huge social and health benefits to disadvantaged
communities. By delivering clean energy into New York City, Clean
Path New York will reduce the output of oil- and gas-fueled generation
sources by an average of 4.6 TWh per year statewide and
2.56 TWh per year in Zone J, reductions of 8% and 16%,
respectively. Clean Path New York will reduce carbon
emissions by 39 million tons in its first 25 years.
In 2030 the project delivers a 22% reduction in carbon emissions for
the statewide electric system and in 2035 it delivers a reduction of
23%. When accounting for all emissions reductions, including carbon
Figure 1-3. Clean Path New York will deliver huge social and health benefits
to disadvantaged communities.
Unrivaled Value and Benefits At A Competitive Price This resale market will create a non-ratepayer funded income stream
Clean Path New York is a project that benefits all New Yorkers and that the State can use to further advance our new clean energy economy.
more than pays for itself in the process. To the extent a 30% Federal Investment Tax Credit for transmission
projects is enacted, Clean Path New York would pass along 75% of the
net effective benefit of the tax credit to NYSERDA.
The project delivers a direct net benefit
of over $800 million to ratepayers, the An Experienced Team of New York Partners
ultimate funders of the project. Ready to Execute
The New York Power Authority and Forward Power (a joint venture
of Invenergy and energyRe) each bring unique skills, assets, and
experience to Clean Path New York that ensure its success. The project’s
Clean Path New York delivers ratepayer developers are trusted leaders in New York’s energy industry with
savings in excess of the value of distinguished histories of achievement. We are excited to work together
NYSERDA's REC payments to the leveraging the best-in-class capabilities of each organization to ensure
project. that, while other states may speak of demonstrating leadership, New
York State will continue its history of actually leading the way forward for
the rest of the world by building projects no one else thought possible.
In all aspects of Clean Path New York, the project team views our work
The net present value (NPV) of direct cost savings to ratepayers as a partnership with the local communities we operate in and serve.
resulting from the project over the same 25-year term is $7.02
billion – $828 million more than the NPV of the REC payments.
When we add in the value of $6.25 billion in avoided social and Clean Path New York Team
public health costs due to emissions reductions across the state,
the billions of dollars invested in state economic development
through job creation, and tax and payment in lieu of taxes (PILOT)
revenues, the NPV of the project benefits outweighs the expense
by a margin of 2:1.2
Beyond that, NYSERDA will be able to establish a resale market for

Tier 4 RECs to New York City building owners who need to comply
with Local Law 97’s carbon reduction mandate. The marginal cost
Forward Power
of excess emissions penalties faced by non-compliant buildings is
well in excess of Clean Path New York’s strike price, meaning that
NYSERDA will be able to sell Tier 4 RECs to building owners
at a profit.
2
See Appendix 24 for cost benefit analysis
1.2. Fulfillment of PSC Evaluation Criteria

2.
The extent to which the selected project or projects
will enable reduced reliance on fossil-fuel fired
The Public Service Commission's analysis of whether the procurement
generation located in Zone J.
of Tier 4 RECs from a particular project or portfolio of projects
advances the public interest will incorporate criteria articulated in the A
verage of 2.56 TWh/YR of reduced thermal generation
Commission's BCA Framework Order 60. Clean Path New York is a in Zone J
compelling project when measured against these criteria. A
verage thermal generation reduction of 16% per year
in Zone J
A brief overview as to how Clean Path New York performs strongly
in this context follows, with project attributes listed under each R
educe NYISO locational capacity requirement (LCR) over
criterion: time by adding 1,300 MW of controllable resources into
Zone J, decreasing the need for thermal assets for resource
Whether the agreement is a cost-effective means of
1.
adequacy
progressing toward the CLCPA’s 2030 and 2040 Targets
3.
in light of the unique challenges of reducing fossil fuel The degree to which the selected project or projects
use in Zone J. complement the foreseeable deployment of offshore
R
educed load payment savings to ratepayers by $12 billion wind within Zone J.
over 25 years O
ur modeling indicates Clean Path New York will experience
Interconnection at Fraser Substation in Zone E, which is the 0 hours of curtailment even with 9,000 MW of offshore wind
closest interconnection location to Zone J, while still solving (OSW) connected to Zones J and K in 2035, depending on
congestion across the crucial Total East interface. This will result the New York Independent System Operator rules to dispatch
in congestion savings of $5.6 billion over 25 years (a subset of the the line to Zone J for both economic and environmental
$12 billion above) benefits
R
educed fossil fuel electric generation by average of 4.6 TWh/YR T
he converter station at Fraser in Zone E enables the export
statewide of OSW beyond the Total East Interface in periods of excess
wind supply needed to serve Zone J
– Reduced carbon emissions by 39 million tons over 25 years
– Reduced carbon emissions from the statewide electric system
by 22% in 2030 and 23% in 2035
Clean Path New York will experience
N
PV of ratepayer cost savings is $828 million greater than NPV
of NYSERDA’s total REC investment over 25 years 0 hours of curtailment even with 9,000
MW of offshore wind connected to NYC
O
verall benefit/cost ratio of 2:1 when including all benefits
and costs
and Long Island
4. Impacts to disadvantaged communities.

4
0% of the incremental economic benefits of the project accrue to
5. Project viability.
1 00% of transmission resource to be buried underground
disadvantaged communities or under water in the Hudson and Harlem Rivers.
– This constitutes an investment of $1.8 billion in project-specific U
se of the Power Authority’s Marcy- South right-of-way
expenditures
– No green-field transmission corridor development needed
9% of the benefit avoided social and public health costs due
4 – 60% of transmission route controlled by single owner
to emissions reduction from decreased use of oil- and gas- fired
generation accrue to disadvantaged communities C
lean Path New York directly developing and owning 60% of
the 3,800 MW new wind and solar generation portfolio
– This constitutes an avoided cost value of over $3 billion to
disadvantaged communities – 624 MW of directly owned generation assets already
contracted under Tier 1 REC program
$270 million in Category 3 community benefits agreement
938 MW of third party-owned generation holding executed
– $100 million investment to expand workforce development and
term sheets with Clean Path New York already contracted
job creation programs targeting disadvantaged communities
under Tier 1 REC program
– $50 million investment in economic development programs
targeting disadvantaged communities se of 1,160 MW Blenheim- Gilboa facility in Schoharie
U
County to firm renewables
– $50 million investment in enhancements to public health in
disadvantaged communities C
ontrol of upstate converter station site location
– $70 million investment in environmental justice programs E
xisting site control in Zone J for converter
station site location
$6.25 billion in avoided social and public

health costs
Over 50% of this benefit occurs

in New York City
Figure 1-4. The project includes an agreement on $270 million in community benefits.
6. Economic benefits to the state.

O
ver $11 billion investment in New York State infrastructure
Job creation
– Creates over 10,500 person years of in-state construction jobs
Tax revenue
– Approximately $1.6 billion in tax revenue, PILOTs and host
community payments for local communities over 25 years
– This tax revenue comes without increased demand on
community services
Investment in 70-year transmission resource to reduce congestion
and lower energy costs long after initial 25-year contract expires
Increased New York State energy independence and
competitiveness by not investing in any single foreign sources
of energy
Creates 10,618 person years of in-state jobs

through 1st three years of contract term
Generates $1.6 billion in tax revenue,

PILOTs and host community payments
over 25-year contract term
Figure 1-5. New Yorkers will benefit from approximately 233 long-term jobs in the state.
1.3. Transmission: Siting & Routing - In all, 105 miles of the 175-mile transmission project (60%) is located
within NYPA’s Marcy-South 345kV transmission corridor. Clean Path
Minimizing Environmental and New York conductors will generally be buried five feet below grade.
Community Impacts Much of the Marcy- South corridor is characterized by loose rocky soil
at grade, obviating the need for destructive installation methods such
as blasting. Use of existing rights-of-way reduces local impacts to the
community and environment, which results in less complex permitting
and increases project timeliness and feasibility.
The Marcy-South corridor to be used for Clean Path New York

terminates at Rock Tavern, at which point the underground
transmission resource continues south and east, primarily in New York
State Department of Transportation (DOT)-controlled rights-of-way
along Route 207, Route 300, and Route 69, until transitioning into the
Hudson River at what is currently an industrial site in the Town of New
Windsor. Clean Path New York is working with DOT to ensure close
collaboration on the potential need for any routing alternatives to
deliver a positive outcome with minimal impacts to local communities
Figure 1-7. The transmission line runs for six miles in the Harlem River before
reaching the South Bronx.
The transmission route represents the optimal balance of increasing

connectivity across key constraints while maintaining cost
effectiveness for ratepayers. The entirety of the new transmission
resource developed under Clean Path New York will be buried
underground or underneath the Hudson River. This is consistent with
policy direction promoted by the PSC and the Cuomo administration
as the project enhances system reliability through storm hardening
Figure 1-6. The new transmission line will run beneath the Hudson River from New Windsor
and minimizes visual impact to communities. to New York City.
along the route. Once in the Hudson River, the transmission line will Forward Power will develop and own 60% of the supply portfolio on
be installed in the riverbed, where it travels 16.2 miles south, making a MW basis. For the balance of the supply Clean Path New York has
landfall again on the east side of the river in the Village of Buchanan secured term sheet agreements with third party developers RWE,
(Westchester County) to avoid environmentally sensitive areas in Northland Power, Apex, Terra-Gen, and Boralex. Clean Path New York
the Hudson around Haverstraw Bay. Once in Buchanan, the line is will enter into long-term REC purchase agreements with these third-
again buried underground in DOT rights-of-way, including Route 9 party suppliers to supply the project.
and Route 9A, as it travels south to Ossining, where it re-enters the
Hudson River and travels south for another 20.1 miles. All of the supply assets either already hold or will pursue Tier 1 REC
contracts with NYSERDA so that, in the event the transmission resource
At this point, the line enters the Harlem River between Manhattan and does not require additional capacity for full utilization, the suppliers can
the Bronx. The line is in the Harlem River for four miles before making receive Tier 1 compensation for their generation in place of Tier 4 RECs.
landfall in the Bronx Terminal Market, the proposed Zone J converter
site location. The project is then interconnected to the Rainey
Substation via an AC generator lead line coming off the converter
station and running along East 151st Street and East 138th Street to
make a landfall at the East River, in the South Bronx.
The line then travels via submarine cables across the East River to
make another landfall at Astoria, Queens. The transmission line will
continue in public road ROWs for 3.8 miles in the streets of Queens to
terminate at the Rainey Substation.
1.4. Supply Plan

Clean Path New York’s supply portfolio comprises new on-shore
wind and solar resources as well as NYPA’s Blenheim-Gilboa
pumped storage facility to serve as a firming resource to smooth
the utilization of the intermittent wind and solar assets. Clean
Path New York’s portfolio is ideally suited to maximize utilization
of the new transmission line. Our portfolio is both geographically
and technologically diverse. It is also cost effective, with a robust
production tax credit (PTC) and investment tax credit (ITC) qualification
strategy across all assets, and includes many advanced stage
projects, with 1,562 MW already contracted under NYSERDA’s
Tier 1 REC program.
Figure 1-7. The transmission line runs for six miles in the Harlem River before reaching
the South Bronx.
The table below depicts the Clean Path New York supply portfolio, including
information on ownership, capacity, construction start date, and COD.
Project Developer Capacity Location Technology Tier-1 Contract COD

Alle-Catt Wind Invenergy 340 MW Wyoming, Cattaraugus, Allegany Counties Wind ✓ Q3 2024
Horseshoe Solar Invenergy 180 MW Livingston County Solar PV
✓ Q4 2023
Number Three Wind Invenergy 104 MW Lewis County Wind
✓ Q3 2022
Canisteo Wind Invenergy 250 MW Steuben County Wind Q2 2023
Bull Run Wind Invenergy 449 MW Clinton County Wind Q3 2024
Verona Solar Invenergy 350 MW Oneida County Solar PV Q4 2024
Twinleaf Solar Invenergy 75 MW Lewis County Solar PV Q4 2024
Taproot Solar Invenergy 205 MW Montgomery County Solar PV Q4 2025
Wintergreen Solar Invenergy 75 MW Montgomery County Solar PV Q3 2025
Orangeville Solar Invenergy 75 MW Wyoming County Solar PV Q3 2025
Seventy Seven Solar Invenergy 100 MW Wyoming County Solar PV Q4 2024
Bull Run Solar Invenergy 170 MW Clinton County Solar PV Q3 2025
Ball Hill Wind Northland 107.2 MW Chautauqua County Wind
✓ Q4 2022
Bluestone Wind Northland 111.8 MW Broome County Wind
✓ Q4 2022
High Bridge Wind Northland 103.2 MW Chenango County Wind
✓ Q3 2023
Bald Mountain Solar Boralex 20 MW Washington County Solar PV
✓ Q4 2022
West River Solar Boralex 20 MW Saratoga County Solar PV
✓ Q2 2024
Sandy Creek Solar Boralex 20 MW Jefferson County Solar PV
✓ Q4 2023
Greens Corners Solar Boralex 120 MW Jefferson County Solar PV
✓ Q4 2023
Sky High Solar Boralex 20 MW Onondaga County Solar PV
✓ Q1 2023
Baron Winds Phase I RWE 121.8 MW Steuben County Wind
✓ Q4 2022
Heritage Wind Apex 198 MW Orleans County Wind
✓ Q4 2021
Prattsburgh Wind Terra-gen 147 MW Steuben County Wind
✓ Q4 2023
1.5. Utilization of Blenheim-Gilboa

In 1973 NYPA developed the Blenheim-Gilboa pumped storage
facility. It offers the State’s power system 1,168 MW of pumped storage
capacity. Despite its large capacity, the facility is underutilized; in 2019
Blenheim-Gilboa generated 406.8 GWh of energy (per NYISO Gold
Book 2019), which equates to approximately 3.5 hours of daily use at
full load output. Clean Path New York will optimize use of Blenheim-
Gilboa, adding over 375,000 MWh per year to its output.
The incorporation of the Blenheim-Gilboa facility in the Clean

Figure 1-8. The Blenheim-Gilboa facility will store excess renewable energy so it
Path New York project enables excess renewable energy to be can be delivered when needed.
stored when generation from wind and solar resources is high, and
subsequently delivered to Zone J at times when generation from wind
and solar resources is low. This increases utilization of the HVDC line Bull Run Wind
Bull Run Solar
and generation of Tier 4 RECs. It is expected that the charging energy
will be provided by the buildout of the additional eligible generating
resources, with hourly matching to ensure Tier 4 eligibility.
We offer an alternative (reduced) strike price of $ Twinleaf Solar

Greens Corners Solar
if including Blenheim-Gilboa in the project.
Number Three Wind
Sandy Creek Solar
West River Solar
Contracting Blenheim-Gilboa Heritage Wind
pumped storage to balance Horseshoe Solar

Verona Solar I & II
Bald Mountain
intermittent Resources and Orangeville Solar
Wintergreen Solar
Solar
Seventy-Seven Solar
maximize utilization of the Prattsburgh
Wind
Sky High Solar High Bridge
Taproot Solar
New Transmission Baron Winds

Wind
Phase I
Ball Hill Wind Blenheim-Gilboa
Canisteo Wind Bluestone Wind

1.6. Solving the Tale of Two Grids: transmission line as short as possible, Clean Path New York reduces
project costs to the greatest extent possible while doing the most
Delivering Cost Effective, Viable to remediate upstate/downstate congestion. By interconnecting
Reduction in Fossil Fuel Generation at the Fraser substation, Clean Path New York’s
transmission line reduces congestion costs over
Remediating the Tale of Two Grids Total East by $250 million, or 57% in 2030.
In order to achieve the CLCPA goals of 70% clean
electricity by 2030 and 100% by 2040 is the remediation Our team studied the congestion effects of being located on
the other side of Total East, in Zone F, in order to confirm whether
of what the New York Independent System Operator
interconnection at Fraser, in Zone E, was optimal from a system
(NYISO) calls the “Tale of Two Grids.” impact perspective. To quantify the value of any Tier 4 transmission
Currently, congestion on the bulk power system prevents mostly project extending north of the Total East interface, Clean Path New
emissions-free power in Zones A-E from being used in the region’s York modeled a 2030 case with a 1,300 MW HVDC line originating
major load center in Zones J and K. This congestion, when coupled at the Leeds substation, in Zone F, rather than the Fraser substation,
with NYISO’s locational capacity requirement (LCR) for Zone J, results in Zone E, and held constant everything else in the model.
in the downstate grid being more than 70% oil- and gas-fired. This The Leeds case showed almost $120 million, or 35%,
imposes significant environmental justice burdens on disadvantaged more congestion than the Fraser case, $96 million of
communities in the South Bronx and Queens, which host these fossil which is tied to the Total East interface. The Leeds case
fuel assets. also had renewables dispatch of 593 GWh less than the Fraser case,
mostly due to increased renewables curtailment.
To rewrite the “Tale of Two Grids,” congestion between Zones A-E
and Zones J and K must be resolved and additional new clean energy
generation must be brought online to offset the use of oil and gas
generators in Zone J.
The most important congestion point on the bulk power system

inhibiting the flow of energy from Zones A-E to Zones J and K is the
Total East interface. Projects that interconnect in Zone F (at the Leeds
or New Scotland substations) do not solve the Tale of Two Grids
problem. Projects that inject power into Zone J from outside the
New York Control Area (those that come from Canada or PJM) do
nothing to solve it either; they simply bypass the problem, while
leaving it unaddressed.
The transmission resource developed by Clean Path New York

interconnects its withdraw-point converter station to the Fraser
Substation in Zone E, the closest feasible location to Zone J while
still being on the other side of Total East congestion. By keeping the Figure 1-9. The project will help relieve environmental justice burdens on disadvantaged
communities in the South Bronx and Queens.
Mature and Cost-Effective Supply Beginning in 2030, the Clean Path New York reductions would be
Clean Path New York includes 1,562 MW of wind and solar generation equivalent to retiring the facilities listed above plus:
(more than 30% of the total project resources) already contracted • East River Generation Station
by NYSERDA under the Tier 1 REC program. The portfolio features • Kennedy International Airport Cogeneration Plant.
a majority of the Tier 1-contracted wind capacity in New York, which
enables Clean path New York to achieve a high utilization of the New
Transmission and maximize the value of the proposal.
Clean Path delivers $12 Billion in load
Reduction in Fossil Fuel Generation and Other Benefits payment savings to New York ratepayers
over its first 25 years of service.
By developing 3,800 MW of clean energy throughout

the state and remediating transmission constraints In 2030, the addition of Clean Path New York generation and
at the Total East interface and across UPNY-SYNY transmission assets reduces statewide load payments by $438 million,
an 11% reduction in the amount New York State ratepayers pay for
to allow that energy to flow into Zone J, Clean Path
their electricity. A little less than half of these savings are in Zone J,
New York will reduce the output of oil and gas- where load payments decline by $204 million, or 13%. These savings
fueled generation sources by 4.6 TWhrs/YR — an 8% are even higher in our 2035 case, with Clean Path New York reducing
reduction statewide and a 16% reduction in Zone J. statewide load payments by $528 million, or 13%, and Zone J load
payments by $247 million, or 16%.
In Clean Path New York’s 2025 modeling case of the electric system Post-Contract Flexibility Benefits New York State
performed by PowerGEM, city-wide reductions resulting from It is important to note that Clean Path New York will
the project would be equivalent to retiring all fossil fuel-fired have a service life that greatly exceeds the 25-year term
equipment at: contemplated under this Tier 4 REC solicitation.
• Ravenswood Generating Station
New York State has an opportunity to make an investment in a
• Arthur Kill Generating Station
transmission resource with a useful life of 70 years. Because Clean
• Riverbay Generation Station Path New York is located entirely within the State and entirely served
• Starrett City Cogeneration Plant by New York State generation resources, we are confident the State
will be able to utilize the investment it makes in Clean Path New York
long after the initial contract term with NYSERDA expires. The same
cannot be said for any project that seeks to connect a single
source of power to Zone J from outside the State under a single
supply agreement. Clean Path New York is a true in-state,
all New York solution.
1.7. Carbon Emissions Goals A project injecting renewable power directly into Zone J from outside
New York may provide similar emissions reductions, but would do so
In addition to its goals of 70% renewable energy by 2030 by bringing out-of-state renewables into the State, not by improving the
and a carbon-free electricity supply by 2040, New York intrastate transmission system to dispatch New York’s existing renewables
State has a goal of reducing carbon emissions to at least more efficiently. Based on our modeling, a fully utilized 1,250 MW
85% below 1990 levels by 2050. transmission line from Canada into Zone J would increase New York’s net
electricity imports by 52% in 2030 and 57% in 2035. While such a project
According to the New York State Department of Environmental would reduce emissions in Zone J, from a system perspective it would do
Conservation, the State emitted 410 million metric tons of CO2 so by injecting foreign renewables into the State, rather than by allowing
equivalent in 1990.3 This implies that the State must reduce its CO2 New York State to more efficiently utilize in-state renewables.
emissions by 349 million metric tons – to 61 metric tons – by 2050.
Based on PowerGEM’s modeling, which assumes the State will meet

its 70% renewable energy by 2030 goal, Clean Path New York in that
year will reduce New York State’s annual CO2 emissions by 2.5 million
tons. This represents a 22% reduction in statewide CO2 emissions
from electric generation in that year. Clean Path New York provides
similar incremental CO2 reductions even when modeled in conjunction
with a similarly sized HVDC line interconnecting into Zone J
from Canada.
Clean Path New York provides the targeted CO2 emissions

reductions that are the driving force behind the Tier 4 program.
Over 57% of these reductions, or 1.5 million tons, are located in

New York City, and 82% of them – 2.1 million tons – are located in
the constrained downstate New York State capacity zones (G-K).
In the 2035 case, with 9 Gigawatts (GW) of offshore

wind interconnecting in Zones J and K, Clean Path
New York reduces statewide carbon emissions by 23%
versus the base case.
3
missions numbers are drawn from the New York State Department of Environmental
E Figure 1-10. Clean Path New York takes advantage of New York State's own renewable
Conservation at https://www.dec.ny.gov/docs/administration_pdf/revexpterms496.pdf. energy resources.
1.8. Complement to Offshore Wind 1.9. NYISO Leadership on Intrastate HVDC

Clean Path New York is a complement to New York State’s The global trend in bulk transmission development is
investment in offshore wind. Our interconnection assumes NYISO toward the use of high voltage DC technology. HVDC offers
will control the dispatch of the line. Therefore, power flow will be the benefit of being able to travel long distances without voltage
based on a security- constrained economic dispatch model (adjusted support, which increases efficiency, while also being controllable.
to account for the economics of the project’s REC revenue). This Several HVDC projects connect into the NYCA from adjacent control
necessarily results in cost optimization for ratepayers. By locating areas. However, there are no fully intrastate deployments of the
a converter station within the New York Control Area (NYCA) at the technology in New York State. Because of this, the NYISO’s Open
Fraser Substation, Clean Path New York is able to convey power in Access Transmission Tariff (OATT) and its operations manual do
either direction – into or out of Zone J. not currently contemplate how an intrastate HVDC asset would be
managed, nor how one would participate in the bulk power market.
Over the next decade, the State is expected to procure 9,000 MW
of offshore wind. Our modeling indicates that Clean Path New York All stakeholders involved in energy policy and planning across
will not be curtailed even after all 9,000 MW of the offshore wind is the state recognize that this is an untenable situation as it allows
interconnected into Zones J and K. If, however, wind output going interstate projects to proceed while inhibiting the market for intrastate
into Zones J and K at some point exceeds downstate load, Clean Path development. Clean Path New York is leading the effort to resolve
New York will be able to serve as an export mechanism for that clean the regulatory gap at the NYISO. On March 25, 2021, we nominated a
energy beyond the Total East interface, delivering it to load centers project to NYISO’s Budget & Priorities Working Group, through which
throughout the State that need it. amendments will be made to the OATT and the operations manual
to provide rules and guidelines for intrastate HVDC projects to serve
the State’s entire transmission development market.
Figure 1-11. Offshore wind will contribute 9,000 MW of clean renewable energy. Figure 1-12. HVDC provides an efficient, reliable source of electricity.
1.10. Benefits to Disadvantaged Clean Path New York will work directly with community stakeholders to
listen to their priorities and needs and then act.
Communities
The COVID-19 pandemic laid bare, through outsized negative health The Clean Path New York project team’s initial focus will be on:
outcomes for racial minorities, the stark consequences of systemic 1. Support workforce development and education programs focused on
inequality woven into our social fabric. Social determinants like increasing minority participation in the green economy ($70 million);
environmental justice burdens in disadvantaged communities are
a large driver of these outcomes. Clean Path New York drives 2. Provide increased funding for existing workforce development, local
significant benefits to disadvantaged communities by greatly apprenticeship, and education programs currently administered by NYPA;
reducing emissions from fossil generation assets located in these 3. Invest in access to medical care and health services in disadvantaged
communities and by creating economic development opportunities communities ($50 million);
for community members.
4. Performing efficiency and electrification retrofits in disadvantaged
Emissions Reduction communities to spur local investment, create good jobs, and reduce the
Dramatically reduced emissions across the State result in avoided environmental burden existing buildings place on local communities
social costs of more than $6.25 billion over the 25-year project term. ($50 million).
Over 50% of these emissions reductions occur in New York City and
49% occur in environmental justice and disadvantaged communities. The fund will be managed by a board of directors representing communities
NOx, SOx, and PM emissions from oil- and gas-fired generation sources and stakeholder groups that serve as hosts to the project. The board will be
in 2030 and 2035 are all reduced by 20%. The air quality benefits constituted after the project secures a funding award from NYSERDA.
reflect the value of improved public health that would result from less
exposure to harmful pollutants – including fewer episodes of illness,
fewer days of school or work missed, less disruption of business, lower
health care costs, and fewer premature deaths.
Economic Development
Clean Path New York directs 40% of its overall incremental economic
over $1.5 billion of investment in job creation from construction and
operation of the project as detailed in our Community Engagement
Plan and the Incremental Economic Benefits Sections of our response,
Clean Path New York will establish a community investment fund
totaling $270 million over 25 years targeting the following core
strategic objectives aimed at reducing economic inequality and
improving education while creating a pathway to green energy jobs,
enhancing public health, and improving the environmental performance
of buildings located in disadvantaged communities.
Figure 1-13. Reducing emissions will improve the health and well-being of urban communities.
1.11. Economic Development by

New York, for New York
Clean Path New York will serve as a powerful engine for Key metrics are included in the tables below. Category 1 benefits
economic development. Clean Path New York’s “All Renewable, include project-specific spending and job creation in New York State.
All New York” commitment ensures that the economic benefits Category 2 benefits include transmission and other infrastructure,
of the project and associated investments stay in the state. New supply chain, and community economic development in New York
York has the opportunity to leverage the new green economy in State. DAC is the acronym used by NYSERDA in the Tier 4 RFP
a way that will lift all regions of the state. It is critical that all worksheets to describe Disadvantaged Communities.
aspects of the project chosen under this RFP are entirely New
York focused. Clean Path New York accomplishes that goal.
Investment in New York State and Disadvantaged Communities ($000)

Generation and Transmission New York State Disadvantaged Communities % to Disadvantaged Communities
Through 3rd Year of Contract $2,060,650 $453,634 22.0%
Remainder of Contract $2,314,549 $1,132,933 48.9%
Full Term $4,375,200 $1,586,566 36.3%
Community and Workforce

Through 3rd Year of Contract $50,000 $50,000 100.0%
Remainder of Contract $220,000 $220,000 100.0%
Full Term $270,000 $270,000 100.0%
Combined
Through 3rd Year of Contract $2,110,650 $503,634 23.9%
Full Term $4,645,200 $1,856,566 40.0%
Figure 1-14.
Labor relations
Clean Path New York joins the New York State Building & Construction
Trades Council in the belief that good-paying union jobs in the
fossil fuel industry can and should transition to good-paying jobs
in the renewable energy industry. For this reason, we will require
our Construction Managers and Prime Contractors to negotiate
and sign a Project Labor Agreement with the Council, which will be
binding on all subcontractors. The agreement will have a form and
substance not materially different from that required pursuant to
the NYSERDA Standard Form Tier 4 Renewable Energy Certificate
Purchase and Sale Agreement, Section 18.11. Clean Path New York
will work collaboratively with the Council to successfully navigate the
geographic and craft jurisdiction of the affiliated councils and trades.4
Figure 1-15. Clean Path New York will work collaboratively with the Council to successfully
navigate the geographic and craft jurisdiction of the affiliated councils and trades.
Job Creation in New York State and Disadvantaged Communities
New York Disadvantaged % to Disadvantaged

State Communities Communities
Through 3rd Year of CDT 10,618 2,016 19.0%
Remainder of CDT 210 26 12.3%
Total 25-Year Term 10,827 2,042 18.9%
Figure 1-16.
See Appendix 25.

4
1.12. Team Experience

and Commercial Structure
The project is overseen by a steering committee composed of the
Senior Executive management personnel of each organization.
This oversight committee is responsible for all aspects of project
development, financing, and commercial structuring, and for all
governance concerns related to the submission of this proposal.
Clean Path New York

Steering Committee:
Gil Quinones, President and CEO, NYPA
Michael Polsky, CEO, Forward Power (Invenergy)
Jeff Blau, Founding Partner, Forward Power (energyRe)
Clean Path New York LLC Clean Path New York New York Power Authority
• Generator Owner/Operator Infrastructure LLC • Transmission Owner/Operator
• Third Party Supply Coordinator • Transmission Owner/Operator • Blenhiem Gilboa Owner/Operator
General Partner: General Partner:
Forward Power Forward Power
Figure 1-17. Management chart for project bid phase

The business model for Clean Path New York is

driven by energy market revenues, transmission
service agreements, and Tier 4 REC revenue. The
commercial structure is depicted below.
NYSERDA NYISO Energy revenue
• Funds REC payments • Energy market,

transmission control Energy sales
NYPA
Monthly
• State authority/public benefit REC
REC
Energy Energy
payments sales revenue
corporation settlement
payments
Capacity
• Owns certain transmission
resources from Fraser to Rock
Tavern and supplies energy Clean Path New York LLC
storage
• Owns Blenheim-Gilboa pumped
• Single ownership of most in-state generation Third-party clean power
payments
suppliers
Attribute
storage asset • 25-year contracts with transmission owners on
Environmental
attributes
a fixed capacity basis • Suppliers of Tier 4-qualified
• Contract with third party suppliers for wind and solar
environmental attributes Members:
Clean Path New York • Settles REC payments via New York Generation Boralex, Northland, RWE, Apex,
and Terra-Gen
Environmental
attributes
Attribute Tracking System
Infrastructure LLC Other renewable generation
• Receives REC payments from NYSERDA
• Owns certain transmission developers under negotiation
Members:
Capacity
payments
resources from Rock Tavern to

Rainey Forward Power
• Provides transmission services to
Clean Path New York LLC
Members: Fee to energy Documentation on
manager energy transactions
Forward Power
Energy manager/service provider

• Contracts with Clean Path New York LLC
• Settles market transactions
Members:
TBD - Third Party provider subject to competitive award
Figure 1-18. Clean Path New York commercial structure.
Clean Path New York is enabled through a series of transactions NYPA will enter into a service agreement with Clean Path New York
by independent business entities tied together through contractual LLC to sell energy storage services to Clean Path New York LLC
relationships. Clean Path New York LLC will be the counterparty to associated with its Blenheim- Gilboa pumped storage facility.
NYSERDA’s Tier 4 REC contract.
Third party-owned, Tier 4-qualified, clean power suppliers of wind and
solar will enter into REC purchase agreements with Clean Path New
This Entity Will: York LLC to sell it environmental attributes associated with that Tier
1. Directly own Tier 4-qualifying wind and solar generation assets; 4-qualifed generation. These generators will sell their power to the
2. Sell the power from those resources to the NYISO; NYISO in exchange for energy revenues.
3. Contract with NYPA’s Blenheim-Gilboa pumped storage facility;
4. Coordinate with NYPA to charge and discharge Blenheim-Gilboa
to balance renewables and increase Tier 4 deliveries on the New
Transmission;
5. Contract with third-party owned Tier 4-qualifying wind and solar
resources to procure those resources’ environmental attributes via
power purchase agreements;
6. Contract with NYPA and Clean Path Infrastructure LLC for
transmission services from the Fraser substation to the
Rainey substation;
7. Contract with an energy manager / ESCO to provide the
following services
– Forecast day ahead and hourly load;
– Document hourly-matching via metered flows in support of
monthly reconciliation with NYSERDA via NYGATS for REC
payments
NYPA and Clean Path New York Infrastructure LLC will develop and
own the northern and southern legs of the new HVDC transmission
resource connecting the Fraser substation to Rainey. These entities
will hold transmission service agreements with Clean Path New York
LLC for these transmission services.
Figure 1-19. Clean Path New York helps lead the way to a sustainable, all-renewable energy future.
Conclusion
By reducing the cost and increasing the reliability of power
delivered to New York’s residential and commercial energy
consumers, Clean Path New York will help to enhance the State’s
attractiveness as a place to live, work, and do business.
During the next few years, Forward Power will be making major new
investments in renewable generating facilities in several regions
within the State that have in the past not had the opportunity to
participate fully in the growth of New York’s economy – for example,
the North Country and the Southern Tier. By making it possible to
cut back on the use of – and eventually shut down entirely – some
of New York City’s worst-polluting power plants, Clean Path New
York will not only help to improve the quality of life in neighborhoods
such as Astoria, Long Island City, and the South Bronx, but also
help stimulate new economic growth in those neighborhoods. By
increasing the State’s capacity to generate clean, carbon-free power,
and to move it downstate, Clean Path New York will help accelerate
the electrification of New York’s economy -- a key element in the
State’s transition to more sustained, and sustainable, economic
growth.
Over time, through public-private partnership, Clean Path New York

can play a central role in the development of a diverse community
of experienced, New York-based contractors and suppliers who can
participate in the ongoing growth of renewable energy industries in
New York State. Clean Path New York presents a historic opportunity
to put New York on the path to achieving the ambitious targets of
the CLCPA while making our State the nation’s leader for renewable
energy innovation.
Figure 1-20. Clean Path New York is an economic engine

that benefits the people of New York State.
Section 2
Impacts of COVID-19
on proposer and
project development
Clean Path NY | Step Two Proposal | 23
2 Impacts of COVID-19 on proposer and

project development
2.1. Impacts of COVID-19 on Clean Path Our collective infrastructure expertise helped us optimize project
design, permitting, construction, and operation while managing risk.
New York’s operations The lessons learned in the process further emphasize the importance
The current global landscape of the COVID-19 pandemic presents a of adapting our infrastructure’s operation and design to better
significant challenge to all organizations. Clean Path New York and withstand uncertainties — such as lockdowns and new disease threats.
our project partners have minimized business and project continuity Just as net-zero carbon and climate resilience have led to industry
risk through our collaborative and digital delivery approach. We follow standards and norms, we seek to build resilience to epidemics/
New York State and Centers for Disease Control and Prevention (CDC) pandemics by adapting and transforming our designs and operational
guidelines for all aspects of our COVID-19 safety response, including practices to address future threats.
health assessments, mandating masks, social distancing, cleaning,
In March 2020, Clean Path New York partners transitioned to a
travel advisory, and field operations.
fully remote working environment for all nonessential staff due to
Over the years, the Clean Path New York partners have invested COVID-19. This transition was nearly seamless, with minimal to no loss
heavily in cloud-based IT infrastructure to enable the majority of of productivity on our major projects.
what we do to be completed remotely. This not only enables us to
effectively collaborate with internal and external stakeholders but Our capabilities are enabled by best-in-class digital infra-
also helps our project delivery partners optimize workflow to meet structure for a modern digital workforce including the following:
project requirements and timelines as well as keep our respective • Robust IT Infrastructure capable of serving critical remote operations
employees safe during this unprecedented pandemic. We have used • High-performing, secure cloud-based platforms such Autodesk
those capabilities to collaborate with our partners and our consultants suite of products, PLS-CADD suite of products, and other specialty
to develop this proposal. technical products
Since the start of the COVID-19 pandemic, our environment, health, • Advanced staff training in remote applications
and safety (EH&S) and emergency preparedness specialists have been • Contemporary, streamlined workflows
implementing mitigation strategies recommended by New York State • Advanced project controls and reporting
and CDC. We regularly review new emerging evidence and guidelines • Advanced financial management
to ensure that our measures and strategies are up-to-date with the latest
understanding of COVID-19. The result is a best-in-industry foundation to Concurrently, Clean Path New York is engaged in comprehensive
guide our teams and partners to make better decisions with confidence planning for return-to-office, and some partners have safely and
about what they need to do as well as what they should avoid. seamlessly returned to the workplace when offices were reopened.
Key partners of Clean Path New York include the owner-operators Implement enhanced field
of essential service facilities in New York. Our success in sustaining operations protocols
facility operations and project delivery results from our focus on the Clean Path New York will require all employees
productivity and well-being of our staff and partner workforce. For and contractors to complete a health
example, at the beginning of 2020, Clean Path New York partner assessment screening survey before entering
NYPA, had a capital project portfolio of approximately $865 million. In project sites. We will also take additional
March 2020, due to COVID-19, many projects were paused following measures for employees traveling out of state
state executive orders. However, with appropriate business process or internationally to protect the workforce
measures already in place, NYPA was able to achieve 78% of its against new variants of the virus.
planned capital project goals ($674 million capital spend in 2020) with
over 202 projects in active construction. Project offices and sites will have signage
to enforce, hygiene, social distancing, mask-
wearing, and occupancy limits in elevators,
2.2. Clean Path project development conference and classrooms, and muster rooms.
process
Clean Path New York anticipates receiving the NYSERDA Award
Notification in the third quarter of 2021. Upon selection, we will use Engage health, safety and
our best-in-class digital infrastructure to continue collaborating with environmental (HSE) professionals
NYSERDA and our project delivery partners to finalize contracts We will deploy EH&S professionals and
and project financing. By mid-2021, we envision that most of our emergency preparedness professionals
workforce will have received a COVID-19 vaccination. Considering that on project sites to control and monitor the
vaccination will not eliminate the virus from our society, we will continue workforce. Routine refresher training will
to be vigilant and regularly reassess the pandemic situation using our be provided to update the workforce with
rigorous management systems. However, planning for a worst-case the latest guidelines and address
scenario, we will enhance our current successful project development corrective measures.
and execution processes, focusing on the following aspects.
Protect staff and workers Perform enhanced project risk

We will continue to update our COVID-19 protocols to assessment and mitigation
align closely with New York State and CDC guidelines. The Clean Path New York project management
We will continue to encourage our staff to follow team will perform frequent project risk
enhanced hygiene protocols, social distancing, mask- assessments, including worker availability and
wearing, and other recommendations or requirements deployment, material delivery, manufacturing,
as outlined by the prevailing state and federal and construction.
guidelines.
Closely monitor the supply chain Clean Path New York will develop, maintain, and keep on each project
and intervene to prevent significant site a comprehensive COVID-19 pandemic project work plan.
disruptions
Clean Path New York Partners have well-
established supply chains, matured over
the years from successfully delivering major PPE utilization ● On-site social distancing
energy projects in New York. We will assign The plan will include ● Hygiene ● Sanitation ● Symptom
procurement specialists to closely monitor the Clean Path New York monitoring ● Incident reporting ● Site
supply chain and intervene when a potential policies regarding decontamination procedures ● COVID-19
disruption is identified. Such interventions these control safety training ● Exposure-response
would include engaging alternative suppliers to measures: procedures ● Post-exposure incident
augment supply capabilities. project-wide recovery plan
Sustain project performance The plan will be updated as the state and federal agencies issue new
through digital technology guidelines. A copy of the plan will be available for inspection by state
Clean Path New York envisions leveraging and local authorities.
our powerful digital technology platforms for
Clean Path New York’s construction site safety practices will include
design development, material procurement,
the following:
permitting, community engagement, project
management, and project financing of the • All workers will be screened at the beginning of their shift by taking
project. their temperature and asking about likely COVID-19 symptoms.
• A daily attendance log of all workers and visitors will be kept in the
site office. The attendance log will enable contact tracing in case a
positive test occurs for a worker on the site.
Implement pandemic-resilent design • Weekly safety training (toolbox talk/tailgate training) will be held for
We will design the project to be pandemic- all workers to explain the site-specific protective measures for all
resilient so that the project components could workers.
be efficiently constructed during COVID-19
• COVID-19 safety requirements will be visibly posted on the sites.
restrictions and operated during future virus
outbreaks. In the initial project development • Workers will be required to keep social distancing of at least 6 feet
phase, Clean Path New York will depend on and minimize interactions when picking up and delivering equipment
virtual site visits with the use of action cameras, or materials. Where social distancing is impractical, additional
drones, and LIDAR. measures such as improved ventilation, shorter shifts, and enhanced
personal protective equipment (PPE) will be considered.
• PPE such as gloves, goggles, face shields, and face masks as

appropriate or required for the activity being performed will be
2.3. Impacts on the content of this
provided to workers. Step Two Proposal
• Masks and gloves will be mandatory for all workers on the site. Clean Path New York has utilized the robust IT infrastructure
• Soap and running water in abundant quantity will be provided explained above, including cloud-based applications to collaborate
for frequent handwashing. Workers will be encouraged to leave on the development of this proposal. Digital solutions were identified
their workstations to wash their hands regularly. Portable washing at the very early stages to optimize the process, improve experience,
stations will be provided when running water is not available. and moderate the development of this proposal.
• High-touch surfaces will be frequently cleaned and disinfected. If The result is a fully developed proposal that has benefited from
feasible, touchless access to the site will be provided. frequent online communication among the partners and their
• If workers develop COVID-19 symptoms, they will be required to consultants. Digital solutions have aided in all aspects of the proposal,
report immediately to their supervisors. Clean Path New York will including all the backup and associated essential activities such as
arrange for testing and evaluation by a healthcare provider. project development, management, and communication, and the
• If a worker is confirmed to have COVID-19 infection, Clean Path New successful completion of the associated technical studies, digital site
York will inform fellow workers of their exposure while maintaining survey, and other necessary activities.
confidentiality as required by the Americans with Disabilities Act
(ADA) and Health Insurance Portability and Accountability Act
(HIPAA).
Section 3
Proposer experience
3 Proposer experience
3.1. Introduction and operate the project. Each member has been successful in
developing projects of similar scale and complexity, working together
Clean Path New York LLC is the bidding entity for the project and and with countless other organizations, to bring projects effectively
will be the counterparty to the NYSERDA Tier 4 REC contract. This to commercial operation in a timely fashion, as described and
new partnership includes the New York Power Authority (NYPA) demonstrated in this section.
and Forward Power LLC (Forward Power), collectively referred to as
the Partners herein. The structure of the Partners is shown in the
organizational chart as Figure 3-1. Forward Power is a joint venture 3.2. Organizational chart
between Invenergy Renewables and energyRe, a company formed
The project, referred to herein and throughout the proposal as Clean
to develop new renewable energy resources in New York State and
Path New York, is overseen by a steering committee composed of
provide energy management and transaction services to Clean Path
the senior executive management of each member organization.
New York.
This oversight committee is responsible for all aspects of project
While Clean Path New York LLC is a development, financing, commercial
new entity incorporated in Delaware structuring, and all governance-related
and wholly owned by Forward Power. Clean Path New York matters around the submission of this
Its members have significant experience Steering Committee:
and management capability to develop Gil Quinones, President and CEO, NYPA
Michael Polsky, CEO, Forward Power (Invenergy)
Jeff Blau, Founding Partner, Forward Power (energyRe)
Figure 3-1. Organizational chart for project bid phase.
Clean Path New York LLC Clean Path New York New York Power Authority
• Generator Owner/Operator Infrastructure LLC • Transmission Owner/Operator
• Third Party Supply Coordinator • Transmission Owner/Operator • Blenhiem Gilboa Owner/Operator
General Partner: General Partner:
Forward Power Forward Power
proposal. See Figure 3-1 below for an illustration of the corporate

structure.
Clean Path New York (https://www.cleanpathny.com/) will function as

an umbrella project for various independent business units to support
both the supply and transmission sides of the project. On the supply
side, the Clean Path New York partners will collaboratively develop,
operate, and/or schedule a sizable portfolio of emissions-free
generation and storage resources to serve the project.
A portion of this supply is composed of new wind and solar generation

assets directly owned by Forward Power, with another portion
owned by and contracted through REC purchase agreements with
third-party owners. Clean Path New York will utilize NYPA’s 1,160 MW
Blenheim-Gilboa pumped storage facility to provide firming supply to
the intermittent renewables that make up the balance of the supply
Figure 3-2. Invenergy's Shoreham solar project on Long Island provides 24.90 MW of power.
portfolio.
All of this activity (ownership of generation and contracting REC underground and under the Hudson and Harlem Rivers between Rock
purchase agreements) will reside within Clean Path New York LLC, Tavern and Rainey.
an entity owned by Forward Power. This entity will be the single
The business model for Clean Path New York LLC is driven by
counterparty to NYSERDA’s Tier 4 REC contract.
energy market revenues, delivery service agreement, and Tier 4 REC
On the transmission side of the project, Clean Path New York revenue. The commercial structure is depicted below in Figure 3-3 on
is supported by two entities: NYPA and Clean Path New York the next page.
Infrastructure LLC. NYPA will develop and own the northern
Clean Path New York has assembled an unparalleled portfolio of more
segment of the transmission system, including the converter
than 3,000 MW of exclusively New York renewable generation to
station and the interconnection facility at the withdrawal point near
support this proposal. The portfolio include more than 1,500 MW wind
Fraser Substation in Delaware County, NY and the balance of the
generation. The wind generation resources offered brings much more
transmission infrastructure located within its Marcy-South corridor and
diverse generating profile compared to other renewables, in addition
corresponding right-of-way, which ends at the Rock Tavern Substation
to a significantly higher net capacity factor, a large quantity of wind is
in Orange County, NY.
considered essential to a cost effective and successful Tier 4 project.
Clean Path New York Infrastructure LLC will be owned by Forward The portfolio also include more than 1,400 MW Solar generation
Power. It will develop and jointly own the southern segment of resources to complement the wind and strengthen the overall
the transmission system, including the converter station and the energy profile of the portfolio. In addition to Invenergy Renewables,
associated interconnection facility at the Rainey Substation in Northland, RWE, Apex, Terra-Gen and Boralex resources are also
Queens, NY and the balance of the transmission infrastructure located included with underlying termsheets with Clean Path New York LLC,
Figure 3-3.
Clean Path New York commercial structure.

NYPA REC
Monthly
Energy Energy
REC
• State authority/public benefit payments
settlement
sales revenue
payments
corporation
Capacity
Tavern and supplies energy
Clean Path New York LLC
storage • Single ownership of most in-state generation Third-party clean power
payments
suppliers
Attribute
• Owns Blenheim-Gilboa pumped • 25-year contracts with transmission owners on a
Environmental
attributes
storage asset fixed capacity basis • Suppliers of Tier 4-qualified
• Contract with third party suppliers for wind and solar
environmental attributes Members:
Clean Path New York • Settles REC payments via New York Generation Boralex, Northland, RWE, Apex,
and Terra-Gen
Environmental
attributes
Infrastructure LLC Other renewable generation
• Receives REC payments from NYSERDA
• Owns certain transmission developers under negotiation
Members:
Capacity
payments

• Provides transmission services
to Clean Path New York LLC
Forward Power

Members:
TBD - Third Party provider subject to competitive
award
those additional experienced developers with track records of being NYPA will enter into a service agreement with Clean Path New York
able to deliver projects also enhance the credibility of the offered to sell energy storage services associated with its Blenheim-Gilboa
portfolio of resources. pumped storage facility.
The project is enabled through a series of discrete transactions by Third-party-owned, Tier 4-qualified, clean power suppliers of wind and
independent business entities tied together through contractual solar will enter into a REC purchase agreement with Clean Path New
relationships as explained earlier. Clean Path New York LLC will be the York LLC to sell the environmental attributes associated with their
counterparty to NYSERDA’s Tier 4 REC contract. This entity will do the Tier 4-qualified generation. These generators will sell their power to
following: NYISO in exchange for energy revenues just as Clean Path New York
LLC would sell the energy from its owned Resources into the NYISO
• Directly own Tier 4-qualifying wind and solar generation assets market.
• Sell the power from those resources to the NYISO
• Potentially contract with NYPA’s Blenheim-Gilboa pumped storage
facility 3.3. Experience of each project participant
• Contract with third-party owned Tier 4-qualifying wind and solar New York Power Authority (NYPA)
resources to procure those resources’ environmental attributes via NYPA is the nation’s largest state-owned public power utility, with 16
REC purchase agreement clean hydroelectric and natural gas-fueled generating plants across
• Contract with NYPA and Clean Path New York Infrastructure LLC New York State and more than 1,400 circuit-miles of high-voltage
for transmission services from the Fraser Substation to the Rainey transmission lines, or approximately one-third of the state’s total.
Substation NYPA's electricity output and power purchases account for up to
• Contract with an energy manager and/or energy service company to one quarter of the state’s electricity. The expanse of NYPA assets is
provide the following services: demonstrated in the asset maps in Appendix 1.
– Forecast day ahead and hourly load
– Document hourly-matching via metered flows to support monthly
reconciliation with NYSERDA via New York Generation Attribute
Tracking System (NYGATS) for REC payments
NYPA and Clean Path New York Infrastructure LLC will develop
40,000+
and own the northern and southern segments of the new HVDC jobs are directly supported by NYPA's low-cost power allocations
transmission system connecting the 345 kV NYSEG owned Fraser statewide, including the ReCharge NY program, introduced by
substation (withdrawal point) to the 345 kV Rainey Substation (delivery Governor Andrew M. Cuomo in 2011. Through the ReCharge NY
point) owned by Consolidated Edison Company of New York, Inc. program, qualifying businesses and nonprofits statewide can
(CECONY). These entities will hold transmission service agreements potentially lower their energy costs by using specially allocated
with Clean Path New York for transmission services. NYPA power.
NYPA’s mission is to power the economic growth and

competitiveness of the state by providing customers with low-cost,
clean, reliable power and the innovative energy infrastructure and
services they value. + + +
NYPA also has full-fledged partnerships with state and local
governments that have made a major difference for improving the Wind Solar Natural gas Storage
energy efficiency of their tax-supported public facilities and reducing 107 projects 44 projects 12 projects 17 projects
their electric bills and associated greenhouse gas emissions. NYPA 17,173 MW 5,261 MW 5,661 MW 410 MW
is well on its way to becoming the first end-to-end digital utility in the
country for optimizing its efficiency and performance and the value Total
that it brings to a wide variety of customers.
= 180 projects
28,505 MW
More information on NYPA can be found on www.nypa.gov.
Figure 3-4. Invenergy's portfolio consists of four core technologies.
NYPA has a long-standing reputation as a “can do” organization more sustainable, flexible, and resilient grid.
developing transmission and generation to suit New York State’s
unique needs. It is in pursuit to become the first digital utility through Figure 3-4 below shows projects operating, under construction,
investments in cutting-edge technologies. or contracted that Invenergy has developed across four core
technologies since its founding in 2001.
Forward Power
As previously described, Forward Power is a newly-formed joint venture Transmission experience
between Invenergy Renewables and energyRe. The capabilities and Because the core of Invenergy’s business model is project development
experience of both of these entities are described separately below. and long-term ownership and operations, the company takes great
care to ensure the longevity, reliability, and cost-effectiveness of its
Invenergy assets, especially the transmission and interconnection infrastructure
Invenergy’s name is synonymous with innovation in an industry for its projects.
undergoing transformation. As the world’s largest privately held Since 2001, Invenergy has built all required transmission and distribution
developer and operator of renewable power, Invenergy works with lines, generator step-up transformers, and substations for its facilities
leading utilities, global brands, and public sector partners to take in CAISO, ERCOT, MISO, NYISO, PJM, WECC, SERC, SPP, Canada, and
energy infrastructure projects from drawing board to reality. in the TVA territory, as well as internationally. Invenergy has developed,
Invenergy’s 1,100 employees are united by a vision to be innovators permitted, and constructed this infrastructure across various terrains,
building a sustainable world. Headquartered in Chicago, the company
has successfully developed over 27 gigawatts of power projects
across the Americas, Europe, and Asia. Invenergy projects enable a
state, and local jurisdictions and in vastly differing environmental and Invenergy has deep technical expertise at every step of the project
regulatory conditions. This experience adds to over 702 miles of high- lifecycle. This is rooted in an engineering culture that recognizes the
voltage transmission lines, over 2,592 miles of distribution lines, 88 critical importance of project aspects like system design, transmission,
substations, 102 generator step-up transformers, and 5,284 pad-mounted and interconnection, which others are often comfortable outsourcing.
transformers, of which several have been built for utilities. End-to-end, fully integrated capabilities allow Invenergy to serve as the
single entity responsible for project development, construction, financing,
Invenergy solutions and operations, with seamless execution from one phase to the next.
Invenergy’s unique combination of full-service solutions, end-to-
Invenergy’s involvement in projects from early development through
operations ultimately benefits customers through higher project
Full range of services and flexible structures efficiency and quality. Invenergy’s operations group constantly reports
• Development-transfers on how the latest equipment and system configurations perform under
• Build-transfers real-life conditions in the field, which immediately shapes procurement
• Engineering, procurement and construction (EPC) and design considerations by Invenergy’s development, engineering,
• Joint Development Agreements and construction groups working on pipeline projects. This keeps
Invenergy at the forefront of project design and construction practices
• Power Purchase Agreements (PPAs)
and methods. Invenergy boasts an impressive portfolio of 180 projects
• Short- and long-term operations, and maintenance and asset totaling 28,505 MW of power.
management
In addition to the services and capabilities it offers, Invenergy
end execution ability, and relationship-driven approach has won it embraces a relationship-driven approach to business, based on the
a reputation for meeting customer’s needs with high-value projects belief that a project can only be considered successful if all parties
delivered on time and on budget. Traditionally, Invenergy’s approach are engaged and satisfied. Customers, EPC contractors, and financial
has been to develop, build, own, and operate projects, but the company institutions who have choices about the power sector companies
provides a full range of services and flexible structures to serve utilities,
corporate buyers, asset owners, and financial institutions. More information on Invenergy can be found on
https://invenergy.com/.
End-to-end, fully integrated capabilities

• Project development • Finance
• Permitting • Project construction
• Engineering • Asset management
• Transmission • Operations and maintenance
• Interconnection
they work with consider Invenergy a preferred partner. That is why The principals of energyRe have developed the following marquee
Invenergy has successfully completed over $35 billion in transactions projects involving interconnection to Con Edison’s transmission
over the past two decades and over 50% of its projects represent infrastructure.
repeat business.
Hudson Yards cogeneration microgrid1. Nearly every Eastern Rail Yard
Invenergy and NYPA personnel have interacted in various roles building at Hudson Yards was planned with the intention of installing
throughout their careers, including one of Invenergy’s in-development cogen to help meet high-level LEED requirements. But the plants
wind projects in New York. would have been small because each building’s individual demand for
hot and chilled water varies greatly over the course of the day or week.
energyRe Commercial buildings peak in the afternoon, residential buildings peak in
energyRe is an independent New York-based company focused on the morning and evening, and the retail and cultural facilities are busiest
solving complex challenges and providing clean energy solutions. over the weekend when the commercial buildings are nearly empty.
Guided by the values of community engagement, government
In response, we consolidated the power and thermal demands of the
partnership, and a demonstrated commitment to sustainability,
buildings, establishing a microgrid and connecting the buildings to
energyRe is working towards a clean energy future for all New Yorkers.
a thermal loop. Related established one larger plant instead of four
The team at energyRe has expertise in infrastructure, engineering, smaller ones, making more than four times as much cogen capacity
and real estate development with leadership that comprises principals economically rational. This single-plant solution capitalizes on the
of Related Companies, the most prominent private real estate firm in mixed-used program of Hudson Yards.
the US with over $60 billion in assets owned or under development.
Just as crucially, Related did not have to build out a costly electrical
These properties include the 28-acre Hudson Yards neighborhood
distribution network to implement the microgrid. Instead, the cogen
on Manhattan’s West Side, The Grand and Related Santa Clara in
plant delivers power directly to the Con Edison grid, and Con Edison
California, as well as luxury condominiums, rentals, and offices.
offsets this power from the Eastern Rail Yard buildings’ electricity
Related started exclusively as an affordable housing developer in bills. In the event that Con Edison’s grid fails, breakers open to isolate
1972 and today is one of the largest developers of affordable and Hudson Yards from the rest of the grid, and cogen power will be
workforce housing in the United States. Named to Fast Company delivered directly to the buildings.
magazine’s list of the 50 Most Innovative Companies in the World,
All told, Related's 13.3-MW cogen plant, thermal loop, and Con Edison
Related is a champion of environmentally conscious real estate and
interconnection cost nearly $200 million. To recoup some of this
continuously advances the design, construction, and operation of its
cost, Hudson Yards sells various forms of power to the Eastern Rail
properties to reduce their environmental footprint. In 2008, Related
Yard buildings and tenants through a subsidiary set up for its power
committed that every building developed in the United States,
business. This setup allows Hudson Yards to cover ongoing operating
regardless of asset class, shall be certified LEED Silver or better.
costs and the facilities’ mortgage payments. It comes with a binding
1
https://www.mckinsey.com/industries/real-estate/our-insights/using-power-and-technology-
to-deliver-resilience-in-hudson-yards
2
https://www.utilivisor.com/news/energy-conservation-at-time-warner.html
commitment that rates will be no higher than they would be if the Enel X, the developer of the battery system that leases the space
microgrid did not exist. from Related, said in a statement, "The system’s design enables a
direct relationship between Enel X’s energy storage resource and
Time Warner Center load management energy conservation2. Time
Con Edison, while simplifying the lease transaction from a real estate
Warner Center is a two-million-square-foot mixed-use skyscraper
perspective by removing the complexities of energy management and
developed by the Related Companies in 2003 and managed by
tenant participation from the structure.”
Related Management thereafter. The facility has foot traffic of
approximately 5,700 people per day for entertainment, luxury The battery generates revenue by delivering capacity to the utility
condominiums, retail shops, and hotel and commercial office space. as part of its Brooklyn-Queens Neighborhood Program, which uses
flexible resources to defer expensive grid upgrades.
Time Warner Center, in partnership with NYSERDA and utiliVisor,
undertook a load management energy conservation project that
optimized chilled-water production for the past two years. Since the 3.4. Proposer's project team and
project has been implemented, approximately 1,407,014 kWh has
been saved. management charts
Gateway Center battery storage project3. Gateway Center, a big-box- Clean Path New York is set up as a framework of both contracted
store mall in Brooklyn's East New York owned by Related, is the site of and underlying established businesses. Each of those businesses
a 5 MW lithium ion battery energy storage project, the largest battery has a team of internal and external resources supporting it. Given
storage project in New York City. The battery connects in front of the the early stage of the project, certain resources are not yet required
meter for dispatch based on Con Edison's signal. to support the teams’ activities. The organizational charts in this
section represent the resources currently engaged in the effort, and
the accompanying narrative seeks to clarify how the project comes
together as well as why certain resources have not yet been engaged
“So far the Gateway Center project has at this stage.
provided the local electricity grid with
more than 100 MWh of electricity from the Clean Path New York LLC
storage system, offering support during Clean Path New York LLC, which develops and owns almost 70% of
periods of higher energy demand.” the supply portfolio of wind and solar, serves as counterparty to the
REC purchase agreements with third-party suppliers and orchestrates
Enel X
supply dispatch. Clean Path New York LLC will have service contracts
with Invenergy Renewables and EnergyReto provide and allocate
resources dedicated to legal, development and finance, government
More information on energyRe can be found here: affairs and communications, construction and procurement, and
https://www.energyre.com/. energy market operations. Those services and resources will be
3
https://www.greentechmedia.com/articles/read/enel-is-back-in-new-york-city-with-a-bigger-
battery
Figure 3-5. Management chart –

Clean Path New York LLC (GenCo) Forward Power
Michael Polsky, Co-CEO
Jeff Blau, Co-CEO
Program management and

financial structuring
Glenn Goldstein, SVP of Development
Shashank Sane, SVP of Development
Legal – internal Development and Government affairs Construction and Energy market
Lead General Counsel finance and communications procurement operations
VP of Development #1 Charles O'Byrne, EVP Emad Lotfalla, EVP Manager #1
VP of Development #2 Beth Conley, VP VP of Procurement Manager #2
VP of Development #3 Senior Project Manager
Development Associate
Development Analyst #1
Legal – external Development Analyst #2 Design engineering –
Couch White, LLP Invenergy internal staff
The Dax Law Firm, P.C. Environmental
Gibson Dunn Electricity markets
engineering –
modeling – PowerGem
Environmental Design
Environmental and Research
engineering – AKRF
Construction manager
Economic development – Invenergy internal
consulting – staff
Appleseed
Permitting –
Financial advisor – Invenergy internal staff
Morgan Stanley
focused on the resources and will coordinate with the Clean Path New complex projects that would typically be served by a traditional EPC
York Infrastructure LLC team with regards to interface and schedule contractor. Trade management is self-performed under this general
coordination of the New Transmission. The management organization contracting role, and subcontractor awards are yet to be made on
chart of Clean Path New York LLC is shown under Figure 3-5 on the projects given their early stage.
next page.
Forward Power will self-perform construction management and
In addition to internal counsel of the entities involved in this project, procurement internally. Using its internal Energy Markets Operations
legal counsel is provided by Couch White, LLP, focusing mostly on team, Forward Power will self-perform energy modeling work to
regulatory aspects, and by The Dax Law Firm P.C., advising on energy inform market exposures, price sensitivity, and curtailment risk of
contracts and FERC-related matters, and Gibson Dunn advising on its portfolio. Forward Power has retained Morgan Stanley to serve
partnership agreements and other contracts as well as bulk power as financial advisor to the supply side of Clean Path New York LLC.
market regulatory counsel. Individual lenders have not yet been designated.
On the technical front, PowerGEM performed electric system production For supply orchestration, dispatch, and execution and settlement of
cost modeling. AKRF examined statewide local emission impacts market transactions with NYISO and NYSERDA, Forward Power will
on criteria pollutants pursuant to the project’s impact on the electric contract with a yet-to-be designated energy manager/energy service
system using PowerGEM’s modeling output. Appleseed performed company to administer these activities. Invenergy Renewables, and
the incremental economic benefits assessment on the supply side of NYPA all have internal business units capable of providing this service
the project. Projects directly owned by Forward Power self-performed to Clean Path New York LLC and such corporate resources will be
generation plant design and used Environmental Design and Research allocated on as needed basis.
(EDR) for Article VII, Article 10, and 94-C permitting support, including As projects move out of development into stabilized operations period,
environmental impact assessment and remediation programs. These Invenergy Renewables will develop an operations strategy that includes
firms are considered the gold standard in their field. adding plant operators and maintenance teams as needed to operate
each additional facility or providing active oversight of those activities.
As projects move into construction, Forward Power, through its
member companies Invenergy and energyRe, has the expertise and Clean Path New York Infrastructure LLC
resources in internal design and construction to serve as its own Clean Path New York Infrastructure LLC will be owned by Forward
owner’s representative and to cover technical aspects related to that Power. The company will develop and own the southern segment of
period of the project. It has internal capabilities in construction and the new HVDC transmission system from Rock Tavern to the Rainey
procurement to self-perform general contracting services on large, Substation. Forward Power will maintain a team of internal resources
dedicated to legal, development and finance, government affairs and
communications, and design and construction management. The

Clean Path New York Infrastructure LLC
(Transmission Operator)
Jeff Blau, CEO, energyRe
Michael Polsky, CEO, Invenergy

Glenn Goldstein, SVP, energyRe
Shashank Sane, SVP, Invenergy
Legal – internal Development and finance Government affairs and Design and construction
Lead General Counsel VP of Development #2 communications Emad Lotfalla, EVP
VP of Development #3 Charles O'Byrne, EVP Project Manager
Development Associate
Legal – external Consulting engineering
Latham & Watkins, LLP and construction
Couch White, LLP Mott MacDonald
Electricity markets
modeling – PowerGem
Environmental
Economic development
consulting – Appleseed
Financial advisor –
Morgan Stanley
CCA Group
management organization chart of Clean Path New York Infrastructure

LLC is shown under Figure 3-6 on the next page. Mott MacDonald’s scope of responsibility for the project
includes the following:
In addition to internal counsel of the entities involved in this project,
legal counsel will be provided by Latham & Watkins who will advise • Electrical engineering and design • Article VII permitting support
on regulatory and commercial agreements, partnership agreements • Routing design and constructability • Construction management
and other contracts and bulk power market regulatory counsel. Couch • Field survey services including • Procurement support
White, LLP will provide land use and environmental legal counsel. geotechnical assessment • Overall project management
Per the description under Clean Path New York LLC, PowerGEM, • Environmental and mitigation review
AKRF, and Appleseed were retained to perform cost modeling,
determine environmental impacts, and assess incremental economic
benefits, respectively. Legal counsel is provided by Van Ness Feldman LLP covering energy
As projects move into construction, Forward Power will allocate contracts and FERC matters, and Norton Rose Fulbright covering
internal resources to manage certain aspects of design and partnership agreements and other contracts. There will be significant
construction. Clean Path New York Infrastructure LLC has retained involvement of NYPA’s internal counsels around the overall project
Mott MacDonald, an experienced engineering and project development.
management firm with a track record of delivering transmission Legal counsel is provided by NYPA’s in-house counsel, led by Justin
projects, to serve as the overall HVDC transmission system technical Driscoll, Executive Vice President and General Counsel, as well as
consultant and engineer for the project. Mott MacDonald will provide the law firms of Van Ness Feldman LLP (energy contracts and FERC
engineering support for both segments of the transmission line. matters) and Norton Rose Fulbright (project finance and structure).
Clean Path New York Infrastructure LLC has retained CCA Group and There will be significant involvement of NYPA’s In-house counsel
Morgan Stanley to serve as financial advisors to the transmission side around the overall project development.
of Clean Path NY. Individual lenders have not been designated. PowerGEM performed electric system production cost modeling.
As the project moves out of development into stabilized operations, AKRF examined statewide local emission impacts on criteria
Forward Power will add a team of transmission operators, converter pollutants, pursuant to the project’s impact on the electric system
station engineers, and maintenance teams as needed to operate the using PowerGEM’s modeling output. Appleseed performed the
facility. incremental economic benefits assessment on the transmission side
of the project.
New York Power Authority
NYPA will develop and own the northern segment of the new HVDC Mott MacDonald will also provide engineering and project
transmission system spanning from the Fraser Substation in Delaware management services to NYPA as part of its role of the New
County, NY to the Rock Tavern Substation in Orange County, NY. Transmission engineering services. Mott MacDonald’s scope of
The largest transmission owner and developer in the state of New responsibility for the project includes:
York, NYPA maintains a team of internal resources dedicated to legal,
• Electrical engineering and design
development and finance, government affairs and communications,
and transmission engineering. The management organization chart of • Routing design and constructability
NYPA is shown under Figure 3-7. • Field survey services including geotechnical assessment

NYPA (Transmission Operator, Bleinheim
Gilboa Operator)
NYPA
Gil Quinones, President and CEO

Phil Toia, SVP
Legal – internal Development and Government affairs and Engineering

Justin Driscoll, General construction communications Vice President
Counsel Girish Behal, VP Justin Driscoll, General Senior Director
Principal Attorney Director of Development Counsel
Legal – external Electricity markets Consulting engineering

Van Ness Feldman LLP modeling – PowerGem and construction
Norton Rose Fulbright Mott MacDonald
Environmental
Economic development
consulting – Appleseed
Financial advisor –
Goldman Sachs
Credit Agricole
• Environmental and mitigation Clean Path New York Steering Committee

review
• Article VII permitting support
• Construction management
• Procurement support
• Overall project management
As projects move into

construction, NYPA has internal
design and construction
expertise to serve as owner’s
representative for the northern Jeff Blau Michael Polsky Gil Quinones
leg of the project. It will retain Jeff Blau is founding partner of With more than 40 years’ Gil Quinones is President
project management support to Forward Power and energyRe experience in the energy and CEO of the New York
manage the project, although and CEO and a partner of industry, Michael Polsky, Power Authority. He is an
that designation has not yet Related Companies. At Related, founder and CEO of Invenergy, internationally recognized
be made given the early stage he has been responsible for is widely recognized as a leader in advancing
of the project. EPC contractor directing and overseeing new pioneer and industry leader sophisticated power generation,
awards have yet to be made on developments worth over $60 in the cogeneration and delivering new technologies
the transmission project, given billion in virtually every sector independent power industry and clean energy sources to
its early stage. of the real estate industry, in North America. Under drive economic growth, create
with a strong emphasis on his leadership, Invenergy jobs, and fight climate change.
NYPA has retained Credit sustainability and environmentally has grown to be the largest He is responsible for developing
Agricole and Goldman Sachs responsible development. privately held renewable energy and implementing the statewide
to serve as financial advisors to As CEO, he is responsible for developer and operator in utility's strategic vision and
the transmission side of Clean the strategic direction of the the world. Before establishing mission and for supervising its
Path NY. Individual lenders have company, overall management Invenergy in 2001, Michael operations, legal, and financial
not yet been designated. of the firm, the pursuit of new founded SkyGen Energy, a matters and relationships with
development opportunities, developer, owner, and operator external stakeholders. Gil’s
As the project moves out of
corporate acquisitions, and of natural gas-fueled generating career of more than 30 years
development into stabilized
financing activities. Under his plants. SkyGen was purchased reflects a singular blend of
operations, NYPA will add a
leadership, Related continuously by Calpine Corporation in 2001, experience in the regulated and
team of transmission operators,
advances the sustainable design, and Michael was appointed competitive utility markets, the
converter station engineers, and
construction, and management as a member of the Board of public and private sectors, and
maintenance teams as needed
of its projects and is pioneering Directors. state and local governments.
to operate the new addition to
urban energy solutions that
its vast portfolio of transmission
address increasing demands
facilities.
on cities.
Clean Path New York program management and financing structuring team
Glenn Goldstein Shashank Sane Phil Toia

As Executive Vice President Shashank Sane leads Phil Toia, President of NYPA
of Development at energyRe Invenergy’s transmission Development, has nearly
and President of Related business, leading the company’s 30 years' experience in the
Retail, Glenn Goldstein has pursuit of high-voltage, long- electric utility industry in
over 25 years' experience in distance transmission projects engineering, system planning,
development and complex from inception to completion. project management, and field
legal matters. He brings Shashank has held multiple work. He is an experienced
expertise to every element roles at Invenergy since operations leader with a
of the development process, he joined in 2013. He led strong emphasis on strategic
including site acquisition and Invenergy’s Edge business, planning, financial performance,
planning approvals, financing, which helped facility and asset and work management,
construction, sustainable fleet owners to lower costs, and employee safety. Prior
design, leasing, and property enhance sustainability, and to joining NYPA, Phil worked
management. He has led the increase resiliency through in engineering, project
development of several large- on-site and market-integrated management, and system
scale projects including Hudson turnkey solutions. Previously, planning roles in the power
Yards, Gateway Center phases he led Invenergy’s Corporate generation, investor-owned
I and II, and the Bronx Terminal Development team where he utility business, and at several
Market. executed on value accretive consulting firms.
M&A transactions and identified
new business opportunities for
the company.
Clean Path New York government affairs and communications team
Beth Conley Justin Driscoll Charles O'Byrne

Beth Conley currently heads As Executive Vice President Charles O’Byrne is Executive
Invenergy’s communications and General Counsel at NYPA, Vice President of Policy at
team as Vice President. Justin Driscoll advises and energyRe and Executive Vice
She leads both internal represents NYPA in all legal President for Policy at Related
communication efforts across matters. He provides strategic Companies. He serves in a
the company and external counsel to the CEO, Board of leadership role on a wide
efforts, such as content Trustees, senior executives, and range of assignments involving
management and media the Governor’s Office regarding government affairs on the
engagement, that support NYPA’s industry-leading role federal, state, and local levels;
Invenergy’s large portfolio of in renewable energy project labor issues; litigation matters;
clean energy projects. Beth development, land-based and and questions of strategy on
joined Invenergy in 2018. offshore transmission, electric multiple projects within the
Prior to serving as VP, she vehicle charging infrastructure, Related portfolio, including
held multiple positions as and energy storage. He leads environmentally conscious
Senior Manager, Strategic wholesale power market and real estate developments
Communications and Director, regulatory efforts, as well as and pioneering urban energy
Communications. NYPA’s FERC hydropower solutions that address
licensing, legislative, and increasing demands on cities.
government relations activity.
Development and Design and 3.5. Key personnel proposed

construction construction The project team we have selected brings together unparalleled
expertise and shares the state’s goal of achieving emissions-free
electricity by 2040. A brief description of each key person listed on
the management charts (Figures 3-5, 3-6, and 3-7) is shown. Further
detailed information regarding these team members’ experience,
credentials, and education can be found on their resumes in
Appendix 2.
In addition to those listed, Clean Path NY has access to a diverse set

of qualified individuals, most of them local to the New York area, with
the technical skills and experience to successfully deliver renewable
Girish Behal Emad Lotfalla energy into New York City.
Girish Behal is Vice President Emad Lotfalla is Executive
of Projects and Business Vice President of Design
Development at NYPA. Girish and Construction for Related
has more than 16 years’ Companies. He is responsible
utility sector experience in for leading all design and
various capacities at different construction efforts for the
organizations. Girish leads Hudson Yards development and
an innovative, solutions- providing strategic advice to the
oriented team that works on senior executive team across
development of high-voltage Related’s global development
onshore transmission, onshore portfolio. Emad brings over 35
and offshore renewables, years’ experience in design
offshore transmission, grid-scale and construction, having
energy storage, and project successfully managed the
licensing supporting the overall construction of over 12 million
renewable goals of New York square feet in all asset classes,
State. including high-rise commercial
office and residential buildings,
hospitals, academic facilities,
aviation and infrastructure, and
high-profile cultural facilities.
Project type, size, Capacity factor (est.) Capacity factor (actual) Availability factor
Project Location and technology COD 2020 2019 2018 2020 2019 2018 2020 2019 2018 Reference
Marcy to New Scotland Transmission Upgrade Project* Marcy to New • Overhead transmission Q4 2023 N/A N/A N/A N/A N/A N/A N/A N/A N/A Patricia Lomardi
(NYPA) Scotland, NY and substation 123 Main Street
• 345kV White Plains, NY
This collaborative project was undertaken by NYPA and LS Power • Bundled ACSS cable 10601
Grid NY to rebuild approximately 100 miles of transmission lines • 93 miles 914.287.3259
across central New York to increase power transfer capabilities. • AIS and GIS substation
The project was competitively awarded by the NYISO public policy work
transmission planning process and is currently in construction, with an
in-service date at the end of 2023.
Moses Adirondack Smart Path Reliability Project (NYPA) Massena to • Overhead transmission Q3 2023 N/A N/A N/A N/A N/A N/A N/A MA1: MA1: Patricia Lomardi
Croghan, NY • 345kV 92.37% 92.37% 123 Main Street
The existing Moses-Adirondack 1 and Moses-Adirondack 2 transmission
• Bundled ACSR cable White Plains, NY
lines, approximately 80 miles of 1,600 H-frame wooden poles,
• 80 miles MA2: MA2: 10601
were NYPA’s first operating asset. The lines, supported by wooden
92.02% 92.02% 914.287.3259
structures, are at the end of their life and will be replaced with steel
monopoles and support future 345kV upgrades to increase renewable
transfer from the North Country to the rest of New York State.
PV-20 Cable Replacement Project* (NYPA) Plattsburgh, • Submarine transmission Dec. 2017 N/A N/A N/A N/A N/A N/A 89.13% 97.48% 93.25% Patricia Lomardi
NY to • 115kV 123 Main Street
PV-20 is a single-circuit 115kV transmission line running from
Vermont • Solid dielectric cable White Plains, NY
Plattsburgh Substation to Cumberland Head Substation,
• 7.5 miles 10601
approximately 7.5 miles. The cables were oil-filled, with gravity-fed
914.287.3259
oil reservoirs at each termination. Based on a completed study that
looked at reducing the environmental risk associated with oil-filled
cables, the remaining useful life of the circuit components and future
circuit loads, the submarine portion of the cable was replaced with
solid dielectric cable.
Flexible AC transmission (FACTS)* (NYPA) Marcy, NY • +/- 200MVAr Phase 1: N/A N/A N/A N/A N/A N/A 88.54% 89.26% 93.28% Dan Herrmann
• GTO thyristor-based 2001 6520 Glass Factory
The Marcy Station convertible static compensator (CSC) project
inverter Rd
was developed to increase the power transfer capability of NYISO’s
Phase 2: Marcy, NY 13403
Central-East and Total-East transmission corridors. This high-power
2004 315.792.8249
voltage source inverter system is the most advanced flexible AC
transmission system (FACTS) device installed to date. It increased
power transfer capability by 200 megawatts.
Next Generation Niagara (NYPA) Niagara, NY • Hydro facility life 2034 N/A N/A N/A N/A N/A N/A N/A N/A N/A Patricia Lomardi
extension and 123 Main Street
The Next Generation Niagara Program is a life extension and
modernization White Plains, NY
modernization program consisting of four major capital projects. The
10601
Integrated Controls Project will provide increased protection in case
914.287.3259
of a cybersecurity breach. The Mechanical and Electrical Upgrade
Project upgrades the 13 generating units and their associated auxiliary
power generating equipment. The RM 630T Gantry Crane will be
replaced, as it is required to perform any major maintenance to the
generating units. The Penstock Platform and Inspections Project will
provide a penstock inspection platform to perform FERC-mandated
inspections of the 13 penstocks.
Table 3-3. The Clean Path NY partners have experience developing similar projects.
Sheldon Wind Energy Center* (Invenergy) Wyoming • Generation March 26.00% 24.50% 24.09% 24.78% 24.50% 23.64% 97.69% 96.39% 95.07% Beth Conley
County, NY • Wind 2009 1 S. Wacker Drive
Sheldon is Invenergy's first operating wind farm in New York. The
• 112.5 MW Suite 1800
project has a capacity of 112.5 MW and utilizes 75 GE 1.5 SLE wind
Chicago, IL 60606
turbines. The wind farm began commercial operation in March 2009
312.429.2529
and produces enough electricity to power more than 23,400 homes.
Orangeville Wind Energy Center (Invenergy) Wyoming • Generation March 34.90% 33.08% 35.05% 34.01% 33.07% 36.07% 91.62% 89.72% 92.33% Beth Conley
County, NY • Wind 2014 1 S. Wacker Drive
Orangeville is a 94 MW wind power generation facility in Wyoming
• 94 MW Suite 1800
County, New York, completed in 2014. The project utilizes 58 GE 1.6-
Chicago, IL 60606
100 wind turbines, producing enough electricity to power more than
312.429.2529
25,900 homes.
Southern Oak Solar Energy Center (Invenergy) Mitchell • Generation May 2020 N/A N/A N/A N/A N/A N/A N/A N/A N/A Beth Conley
County, GA • Solar 1 S. Wacker Drive
Southern Oak is a 160 MW solar energy facility in Camilla, Georgia.
• 160 MW Suite 1800
The project is currently under a 30-year Power Purchase Agreement
Chicago, IL 60606
with Georgia Power Company, and provides power for 30,000
312.429.2529
American homes. The Southern Oak facility features LONGI-brand,
PERC Hi-MO2 bifacial modules combined with NEXTracker single-axis
trackers.
Grand Ridge Energy Center* (Invenergy) LaSalle, IL • Generation 2008 - 27.94% 28.75% 23.34% 27.02% 28.54% 26.18% 97.48% 96.53% 96.49% Beth Conley
• 210 MW wind 2016 1 S. Wacker Drive
Three clean energy technologies are co-located at Grand Ridge
• 20 MW solar Suite 1800
Energy Center, including a 210 MW wind farm, 36 MW of battery
• 36 MW battery storage Chicago, IL 60606
storage, and a 20 MW solar farm, all developed and operated by
312.429.2529
Invenergy. The first project phase began operating in 2008 and the
latest came online in 2016. A battery system helps maintain power
quality and reliability for the PJM electric grid. The project provides
enough power for 54,000 homes.
Energía del Pacífico (EDP)* (Invenergy) Port of • Generation Q1 2022 N/A N/A N/A N/A N/A N/A N/A N/A N/A Beth Conley
Acajulta, El • LNG-to-power 1 S. Wacker Drive
EDP is an LNG-to-power project, currently under construction in El
Salvador • 378 MW Suite 1800
Salvador. The project includes a 378 MW gas-fired power plant that
Chicago, IL 60606
will run on natural gas, a 28 MW common steam turbine generator,
312.429.2529
an offshore liquified natural gas import terminal, and a floating
storage regasification unit that will deliver gas to the power plant via a
natural gas pipeline. It includes a 44-kilometer 230 kV double-circuit
transmission line from Acajutla to Ahuachapán and its associated
substations. EDP is under a 20-year agreement with the Government
of El Salvador.
Time Warner Center* (energyRe) New York, NY • 2.8 million total square 2004 N/A N/A N/A N/A N/A N/A N/A N/A N/A Jon Weinstein
feet 30 Hudson Yards
Time Warner Center changed the face of Manhattan in a dramatic
New York, 10001
way, adding drama to the city’s skyline and serving as an urban
212.801.3902
catalyst that redefines the Columbus Circle neighborhood. Related
worked closely with the City of New York and the MTA on the
development of the soaring 2.8-million-square-foot vertical mixed-use
property
Table 3-3 (continued). The Clean Path NY partners have experience developing similar projects.
Hudson Yards* (energyRe) New York, NY • $28 billion of 2019 N/A N/A N/A N/A N/A N/A N/A N/A N/A Jon Weinstein
investment 30 Hudson Yards
Hudson Yards, Manhattan’s first-ever LEED GOLD Neighborhood
• 28 total acres New York, 10001
Development, is at the center of New York City’s rapidly changing
• 14 acres of open spaces 212.801.3902
West Side. The largest private real estate development in New York
• 18.1 million total square
since Rockefeller Center, Hudson Yards is codeveloped by Related
feet
Companies and Oxford Properties Group.
The Grand LA* (energyRe) Los Angeles, • 3.2 total acres Est. 2022 N/A N/A N/A N/A N/A N/A N/A N/A N/A Jon Weinstein
CA • 1.56 million total square 30 Hudson Yards
The Grand LA is a multiphase master-planned development to
feet New York, 10001
reenvision and redevelop underutilized government-owned parcels
212.801.3902
adjacent to the Civic Center and key cultural institutions such as the
Music Center, Walt Disney Concert Hall, The Colburn School of Music,
and the Museum of Contemporary Art. The result will be a dynamic
mixed-use district fitting for the cultural center of Los Angeles.
Table 3-3 (continued). The Clean Path NY partners have experience developing similar projects.
The Marcy to New Scotland Transmission

Line Upgrade Project, managed jointly
by LS Power Grid New York and the New
York Power Authority, puts New York on
track to meet its goals under the Climate
Leadership and Community Protection Act,
which includes a zero-emissions electricity
sector by 2040.
Project description
Marcy to New Scotland Transmission Line NYPA and LS Power Grid NY are collaborating to rebuild transmission
Upgrade (AC Transmission Segment A) lines across central New York to increase power transfer capabilities.
Partner New York Power Authority The Marcy to New Scotland Transmission Line Upgrade Project was
Location Marcy to New Scotland, NY competitively awarded by the NYISO public policy transmission
Project type Transmission planning process and is currently in construction, with an in-service
date at the end of 2023.
Project size 93-miles and multiple substations, 345kV
Project technology AC transmission This project upgrades 93 miles of transmission lines and includes
COD Q4 2023 the construction of two new substations between NYPA’s central
Estimated and Year Estimated Actual transmission hub in Marcy (Oneida County) and New Scotland (Albany
actual capacity 2020 N/A N/A County). The project uses existing electric transmission corridors
factor (past three 2019 N/A N/A and replaces aging and outdated transmission towers with the latest
years) 2018 N/A N/A technologies to increase energy efficiency.
Availability factor Year Availability factor
(past three years) 2020 N/A
2019 N/A
2018 N/A
Reference Patricia Lombardi
123 Main Street, White Plains, NY 10601
914.287.3259
Marcy to New Scotland Transmission Line Upgrade (AC Transmission Segment A) (continued)
Benefits
The project is designed to increase transmission capacity and help
deliver more renewable energy to higher-demand areas across the
state. It will stimulate the local and regional economies by creating
“A clean and reliable transmission
and supporting hundreds of clean energy construction jobs. infrastructure is critical to combating climate
On February 25, 2021, Governor Cuomo said, “A clean and reliable change and achieving New York’s nation-
leading clean energy goals. The start of
transmission infrastructure is critical to combating climate change and
construction on this important project marks
achieving New York’s nation-leading clean energy goals. The start
a major milestone in our efforts to construct
of construction on this important project marks a major milestone in a new energy superhighway to move energy
our efforts to construct a new energy superhighway to move energy across the state more efficiently, while also
across the state more efficiently, while also creating new jobs and creating new jobs and opportunities for New
opportunities for New Yorkers that will help to reinvigorate our local Yorkers that will help to reinvigorate our local
and statewide economies.” and statewide economies.”
The project, managed jointly by LS Power Grid New York and the New Andrew Cuomo, Governor of New York
York Power Authority, puts New York on track to meet its goals under
the Climate Leadership and Community Protection Act, which includes
a zero-emissions electricity sector by 2040, 70% renewable energy
generation by 2030, and economy-wide carbon neutrality.
A single-circuit transmission line originally

installed in 1958 with oil-filled cables
and reservoirs was successfully replaced
with new dielectric cables. Challenges
included large-scale directional drilling
and the need to protect the environment
of Lake Champlain and an underwater
archeological site.
Project description
PV-20 Cable Replacement PV-20 is a single-circuit 115kV transmission line, approximately 7.5
miles long, running from the Plattsburgh substation to the Cumberland
Partner New York Power Authority
Head substation. The submarine cable portion consisted of four 500
Location Plattsburgh, NY to Vermont
kcmil cables installed in 1958 (one spare). The cables were oil-filled,
Project type Submarine cable with gravity-fed oil reservoirs at each termination.
Project size 7.5 miles transmission and substations
One of the original 500 kcmil cables failed in 1970 and was not
Project technology AC transmission
replaced. Three additional 1000 kcmil cables were installed the
COD December 2017 same year.
Estimated and Year Estimated Actual
actual capacity 2020 N/A N/A A study looked at reducing the environmental risk associated with
factor (past three 2019 N/A N/A oil-filled cables, the remaining useful life of the circuit components,
years) 2018 N/A N/A and future circuit loads. Based on the results, it was determined
Availability factor Year Availability factor that the submarine portion of the cable should be replaced with
(past three years) 2020 89.13% solid dielectric cable. It was important to protect Lake Champlain,
2019 97.48% a recreational and navigable waterway with ferry routes in close
proximity to the work zone.
2018 93.25%
Reference Patricia Lombardi
123 Main Street, White Plains, NY 10601
914.287.3259
PV-20 Cable Replacement (continued)
The project, carried out jointly by NYPA and the Vermont Electric Benefits
Power Company, required interagency communications and
New dielectric cables with spare and new transition stations were
collaboration with New York State and Vermont regulatory agencies
successfully installed without adverse effects on the environment
as well as the US Army Corps of Engineers. The project required
of Lake Champlain or the underwater archeological site. The
a lake survey which discovered an underground archeological site
replacement of the cables mitigated environmental risk and improved
associated with the Lake Champlain Maritime Museum on the lake
the overall reliability of the circuit. The project was energized in
bed very close to the existing lines.
December 2017.
The cables were manufactured overseas, requiring shipping
coordination to a US port and additional logistics to deliver the cables
to Lake Champlain. Large-scale directional drilling was required to
install conduits from each of the transition station locations some
100 yards into the lake. The cables were then jet-plowed into the soil
approximately four feet to meet permit conditions. Where this was not
feasible, concrete mattresses were placed on top of the cables.
Divers with cameras were utilized to monitor conduit, cable, and

mattress placement. While removing the existing oil-filled conductors,
divers were again used to monitor the maritime museum. Spill
response plans were utilized with vessels prepared on site. The
shoreline was also monitored and protected.
A convertible static compensator (CSC) was

designed and installed at NYPA’s Marcy
Station. This high-power voltage source
inverter system is the most advanced
flexible AC transmission system (FACTS)
device installed to date. It increased power
transfer capability by 200 megawatts.
Project description
Marcy Station Convertible To increase power transfer capability on NYISO’s Central-East and Total-
Static Compensator East transmission corridors, a convertible static compensator (CSC)
was designed and installed at NYPA’s Marcy Station near Utica, NY.
Partner New York Power Authority
Location Marcy 345 kV station, Marcy, NY The project team developed a power circuit with two inverters, each
Project type FACTS: Flexible AC transmission rated 100 MVA, that could perform the functions specified for the CSC.
These functions required independent control of the output voltage for
Project size +/- 200 MWAr
the two inverters, as well as transfer of real power between the
Project technology GTO thyristor-based inverter
two inverters.
COD 2004
Estimated and Year Estimated Actual The system had to operate in a variety of configurations, each with
actual capacity 2020 N/A N/A multiple control modes and functions. The design had to take into
factor (past three 2019 N/A N/A account the physical layout of the switchyard and existing equipment. To
years) 2018 N/A N/A protect the inverters from damaging overcurrents that may arise during
Availability factor Year Availability factor line faults, a thyristor bypass switch was developed to protect series
(past three years) 2020 88.54% connected inverters during severe transmission line disturbances.
2019 89.26%
2018 93.28%
Reference Dan Herrmann
6520 Glass Factory Road, Marcy, NY 13403
315.792.8249
Marcy Station Convertible Static Compensator (continued)
200 MW
The project was the first of its kind, with the ability to operate in 11
different configurations using four distinct operating modes:
• STATCOM (Static Synchronous Compensator)

• SSSC (Static Synchronous Series Compensator) of increased power transfer capability
• UPFC (Unified Power Flow Controller)
• IPFC (Interline Power Flow Controller)
1st 11 4
Benefits
This high-power voltage source inverter system is the most advanced
flexible AC transmission system (FACTS) device installed to date.
of its kind different distinct operating
It provides precise and continuous control of power transmission
configurations modes
parameters. The project increased power transfer capability by 200
megawatts.
The Sheldon Wind Farm, Invenergy’s first

operating wind energy center in New York,
is located in Wyoming County. The project
has a capacity of 112.5 MW and utilizes 75
GE 1.5 SLE wind turbines. The wind farm
began commercial operation in March
2009 and produces enough electricity to
power more than 23,400 homes.
Project description
Sheldon Wind Energy Center The Sheldon Wind Farm is Invenergy’s first renewable facility to reach
operations in New York. Invenergy developed, constructed, and
Partner Invenergy
operates the project.
Location Wyoming County, NY
Project type Generation The project is located in Sheldon, New York, on approximately 21,300
Project size 112.5 MW acres of land leased from approximately 85 landowners. The site
is located atop two ridgelines and rolling hills along the tops of the
Project technology Wind
ridges. The surrounding land is predominantly agricultural usage
COD March 2009 (cropland and pasture).
actual capacity 2020 26.00% 24.78% In 2011, Invenergy entered into a ten-year agreement to sell Renewable
factor (past three 2019 24.50% 24.50% Energy Credits (RECs) from the wind farm to the New York State
years) 2018 24.09% 23.64% Energy Research and Development Authority. Sheldon interconnects
Availability factor Year Availability factor to the NYISO transmission system via the Sheldon substation, which
(past three years) 2020 97.69% was constructed adjacent to NYSEG’s 230 kV Stoelle Road–Meyer
2019 96.39% transmission line.
2018 95.07%
Reference Beth Conley
1 S. Wacker Drive, Suite 1800, Chicago, IL 60606
312.429.2529
Sheldon Wind Energy Center (continued)
Sheldon substation Benefits

The Sheldon substation, developed by Invenergy to interconnect The Sheldon Wind Farm produces enough electricity to power more
the Sheldon Wind Farm, is a 230kV substation in a 3-breaker ring than 23,400 American homes. Its emissions reductions are equivalent
bus configuration. The in-service date was in 2008 and the facility is to removing 30,700 cars from the road.
currently in operation. Ownership was transferred to NYSEG, which
currently operates the facility. The project employed more than 1,000 workers during peak
construction and employs nine full-time operations and maintenance
staff. The project invests more than $2.9 million annually in wages,
benefits, local taxes, and landowner payments.
Grand Ridge Energy Center is the world’s

largest co-located wind, solar, and
energy storage facility, totaling 266 MW.
It maintains power quality and reliability
for the PJM electric grid and serves as
an innovation and research center for
Invenergy.
Project description
Grand Ridge Energy Center Grand Ridge Energy Center is located in LaSalle County, Illinois, 80
miles southwest of Chicago. Three clean energy technologies are co-
Partner Invenergy
located, including a 210 MW wind farm, 36 MW of battery storage, and
Location LaSalle County, IL
a 20 MW solar farm, all developed and operated by Invenergy.
Project type Generation
Project size 210 MW wind, 20 MW solar, 36 MW battery storage The first phase of the project began operating in 2008 and the
latest came online in 2016. Renewable energy from Grand Ridge
Project technology Wind, solar, storage
helps consumers meet sustainability goals, while its battery system
COD 2008 - 2016 helps maintain power quality and reliability for the PJM electric grid.
Estimated and Year Estimated Actual The project serves the PJM power market, which stretches from
actual capacity 2020 27.94% 27.02% northeastern Illinois all the way to the Eastern seaboard.
factor (past three 2019 28.75% 28.54%
years) 2018 23.24% 26.18%
Availability factor Year Availability factor A center of innovation
(past three years) 2020 97.48% Grand Ridge is the site of Invenergy’s first solar project and its first
2019 96.53% storage project. The Brookfield solar test bed facility is located on site.
2018 96.49% Here, engineers and operators are able to evaluate and compare the
Reference Beth Conley performance of various system configurations and equipment types as
1 S. Wacker Drive, Suite 1800, Chicago, IL 60606 well as test new operations strategies and techniques.
312.429.2529
Grand Ridge Energy Center (continued)
The experience of developing, owning, and operating these projects Benefits

has given Invenergy confidence in development, battery chemistry,
The project produces enough renewable energy to power 54,000 US
deployment, and operations, paving the way for its large solar and
homes. It provides fast-response regulation service to the PJM market.
storage portfolio today.
Emissions reductions from the project are equivalent to removing
Invenergy is also funding the collection of data from five telemetry 68,000 cars annually from the road.
units that are attached to bald eagles to better understand their
The project generates $4.88 million annually in wages, benefits, local
behavior and interaction with the landscape and operational wind
taxes, and landowner payments. Three hundred thirty jobs were
facilities. This research is being conducted in partnership with the US
created during construction, and the project employs six full-time
Fish and Wildlife Service in Illinois.
operations and maintenance staff.
Honors
The site has won both Power Engineering and Renewable Energy
World Magazine’s Project of the Year Award as well as Energy Storage
North America’s (ESNA) Innovation Award.
Energía del Pacífico, Ltda. de C.V. (EDP) is

an LNG-to-power project currently under
construction at the Port of Acajutla, El
Salvador. This $1 billion project, the largest
private investment to date in El Salvador,
will meet about one third of El Salvador’s
total electricity needs while significantly
reducing the amount of carbon and sulfur
pollution in the air.
Project description
Energía del Pacifico, Ltda. De C.V. (EDP) In 2013, the Government of El Salvador issued a call for electricity supply
aimed at securing a 20-year supply of new electric power generation
Partner Invenergy
from sources other than heavy fuel. EDP secured the winning bid.
Location Port of Acajutla, El Salvador
Project type Generation EDP consists of the following:
Project size 378 MW • 378 MW power plant that will run on natural gas, with one 28 MW
Project technology Liquefied natural gas to power project common steam turbine generator
COD February 2022 • Offshore liquified natural gas (LNG) import terminal, including a
Estimated and Year Estimated Actual dedicated, permanently moored, floating storage regasification unit
actual capacity 2020 N/A N/A (FSRU)
factor (past three 2019 N/A N/A • Approximately 1.8 km natural gas pipeline delivering gas to the
years) 2018 N/A N/A power plant
Availability factor Year Availability factor • 44-kilometer 230 kV double circuit transmission line from Acajutla to
Ahuachapán and its associated substations
2019 N/A
2018 N/A EDP’s development, construction, and operations are led by Invenergy
Reference Beth Conley and supported by El Salvador-based partners Grupo Calleja, VC
1 S. Wacker Drive, Suite 1800, Chicago, IL 60606 Energy de Centroamérica, and Quantum Energy. EDP includes El
312.429.2529
Salvador’s first LNG-fueled power plant and the region’s first FRSU.
Energia del Pacifico, Ltda. De C.V. (continued)
Challenges EDP’s ground-breaking development and project financing has been

recognized by multiple awards, including Latin Finance’s Infrastructure
Laying the groundwork for this project had its challenges, including
Financing of the Year Award and Latin Lawyer’s Project Finance
regulatory approvals for offshore gas storage and transmission, the
(Energy) Award. EDP’s successful financing demonstrates Invenergy’s
complex scope of the transmission network, designing novel physical
ability to proficiently structure project financing and to maintain and
components, and minimizing environmental and visual impacts.
develop successful relationships with a wide range of partners.
As project lead, Invenergy is leveraging decades of development,
engineering, finance, construction and operating experience to
execute this complex project alongside its partners. Complex transmission infrastructure
For the project, Invenergy is building a 44-kilometer (27.3-mile)
transmission line and three substations. The line will run from
Investing in El Salvador
the coastal port town of Acajutla through mountainous terrain to
EDP completed project financing for the LNG-to-power project in Ahuachapan. It will connect to and strengthen the Central American
December 2019. The project brings approximately $1 billion in foreign Interconnection System (SIEPAC), supplying electricity to six Central
direct investment, making it the largest private investment ever in American nations. The transmission is a showcase of Invenergy’s
El Salvador. Leading global financial institutions — Overseas Private execution abilities as the ROW negotiations had to be finalized before
Investment Corporation (succeeded by the United States International power plant construction could begin.
Development Finance Corporation), International Finance Corporation,
IDB Invest, Finnish Export Credit Ltd., and KfW IPEX-Bank — are Benefits
lenders to the project.
EDP will provide cleaner, more reliable energy for El Salvador,
diversifying the energy mix and meeting more than 30% of the
country’s energy demand. Reliable power generation will drive
economic growth and contribute to the stability of the region. The
project will create 1,000 jobs during construction and more than 60
permanent jobs.
Invenergy is heavily invested in the social and economic advancement

of the municipality of Acajutla. Invenergy is providing more than
$500,000 of projects and initiatives each year that will improve the
quality of life for local communities through improvements in basic
infrastructure and social services. These include a street reworking
project and a wastewater treatment plant in Acajutla, and donations of
masks and hand sanitizer to the communities of Acajutla, Ahuachapán,
Sonsonate, and Santo Domingo de Guzman.
Related worked closely with the City

of New York and the Metropolitan
Transportation Authority (MTA) on the
development of Time Warner Center.
Sitting atop the third busiest subway station
in the New York City transit system, Time
Warner Center proves that thoughtful urban
design with a complementary mixture of
uses and transportation improvements
creates a whole project that is greater than
the sum of its parts. Time Warner Center
Time Warner Center addressed the City’s concerns to develop
Partner energyRe
a positive neighborhood catalyst, while
Location New York, NY
Project type Mixed use development simultaneously meeting MTA’s need to
Project size 2.8 million square feet
maximize the value of its site.
Project technology N/A
COD 2004
Estimated and Year Estimated Actual Project description
actual capacity 2020 N/A N/A
factor (past three Time Warner Center changed the face of Manhattan in a dramatic way,
2019 N/A N/A
years) 2018 N/A N/A
adding drama to the city’s skyline and serving as an urban catalyst
Year Availability factor that redefines the Columbus Circle neighborhood.
Availability factor
(past three years) 2020 N/A Related worked closely with the City of New York and the MTA on the
2019 N/A
development of the soaring 2.8-million-square-foot vertical mixed-use
2018 N/A
property.
Reference Jon Weinstein
30 Hudson Yards, New York, NY 10001
212.801.3902
Time Warner Center (continued)
Active nearly 24 hours a day, the 80-story building reflects the pace Benefits
and cadence of the City around it. It includes the following features:
Completed in 2004, Time Warner Center quickly became a mixed-
• Bustling commercial office center, soon to be home to Deutsche use destination like New York City had never seen before. Today, its
Bank shops attract more than 16 million visitors annually and have helped
establish the neighboring entrance to Central Park as the most
• 338,000-square-foot retail and dining complex featuring world-
popular entry to Manhattan’s most beloved green space.
renowned chefs Thomas Keller, Masa Takayama, and Michael
Lomonaco Acting as a bridge between the mature neighborhoods of Midtown
• 5-star Mandarin Oriental Hotel with 198 rooms and 46 suites Manhattan and the Upper West Side, Time Warner Center created a
• 40,000-square-foot Equinox® Fitness Club new center of gravity for the Columbus Circle neighborhood due to
• 122-seat Jazz at Lincoln Center its scale, diversity of offerings, and sensitive architectural and urban
design.
• 199 luxury residences
Hudson Yards, Manhattan’s first-ever

LEED GOLD Neighborhood Development,
constructed over the Eastern Rail Yard of the
Long Island Rail Road, is at the center of New
York City’s rapidly changing West Side. At the
nexus of Chelsea and Hell’s Kitchen, Hudson
Yards is the largest private real estate
development in New York since Rockefeller
Center and co-developed by Related
Companies and Oxford Properties Group.
Hudson Yards Project description

Partner energyRe Hudson Yards is far more than a collection of towers and open spaces.
Location New York, NY It is a model for the 21st-century urban experience; an unprecedented
integration of buildings, streets, parks, utilities, and public spaces
Project type Mixed-use development
that forms a connected, responsive, clean, reliable, and efficient
Project size 18.1 million square feet
neighborhood. The development is part of New York City’s goal to
Project technology N/A transform the broader 42-block Hudson Yards District from a largely
COD March 2019 vacant, underdeveloped area into a vibrant mixed-use neighborhood
Estimated and Year Estimated Actual of workers, residents and visitors is also being achieved ahead of
actual capacity 2020 N/A N/A projections, with over 30 million square feet of new development
factor (past three 2019 N/A N/A completed or in construction since the rezoning in 2005.
years) 2018 N/A N/A
Availability factor Year Availability factor Building an entire new neighborhood in the heart of Manhattan from
(past three years) 2020 N/A the ground up afforded us the opportunity to recalibrate every aspect
2019 N/A of a 21st-century, urban mixed-use neighborhood. When Hudson Yards
2018 N/A is completed, an estimated 125,000 people daily are expected to live,
Reference Jon Weinstein work, dine, shop, study, stroll, or sightsee at the neighborhood.
212.801.3902
Hudson Yards (continued)
Since opening in March 2019, Hudson Yards has become a thriving Resilience
destination for foodies, fashionistas, art lovers, park goers and
Whatever the potential disruption — superstorm, brownout — Hudson
tourists—not to mention home the world’s most innovative businesses
Yards has the onsite power-generation capacity to keep basic building
and trendiest urban dwellers. Hudson Yards is home to dozens of
services, residences, and restaurant refrigerators running. Because it
restaurants and one-of-a-kind shopping experiences; The Shed, a
is built above a rail yard, the first level of Hudson Yards is well above
unique cultural center; the first Equinox Hotel®, world-class medical
the flood plain.
facilities and lush gardens; Edge, the Western Hemisphere’s highest
outdoor observation deck, and Vessel, New York’s newest landmark; A unique electrical interconnection will allow the cogeneration plant
a climbable, interactive public monument unlike any in the world. All of to disconnect from the utility during grid outages and restore power to
this is in addition to state-of-the-art office space, and the finest in luxury tenants.
residences and affordable rental apartments. When Hudson Yards is
completed, an estimated 125,000 people daily are expected to live, The 895-foot-tall tower features a 1.2 MW cogeneration plant that
work, dine, shop, study, stroll or sightsee at this 28-acre neighborhood, generates power, hot water, and chilled water with twice the efficiency
which will include 18 million square feet of commercial and residential of standard systems. It remains operational in the event of a power
space, 14 acres of public open space, and a public school. outage. A stormwater retention tank replenishes cooling towers and
irrigate terrace landscaping, and an Operation and Energy Control
To build the first half of Hudson Yards, a “platform” was constructed Center coordinates security, building performance, and visitor
over the Eastern Rail Yard of the Long Island Rail Road. Completed experience throughout Hudson Yards.
in 2016, the 10-acre platform bridges 30 working tracks, three
subsurface tunnels used by Amtrak and New Jersey Transit, and the
Gateway Tunnel, which is not yet in service.
The platform, which weighs more than 35,000 tons, is supported
by 300 caissons — ranging from four to five feet in diameter and 20
to 80 feet in depth — that were drilled into the bedrock between
existing tracks. In total, 25,000 tons of steel and 14,000 cubic yards of
concrete were used in its construction. Throughout construction, all
train lines remained operational.
Supported by an advanced technology platform, operations managers
monitor and react to power demands and temperature changes in
order to enhance the employee, resident, and visitor experience.
Communications are supported by a fiber loop, designed to optimize
data speed and service continuity for rooftop communications, as well
as mobile, cellular and two-way radio communications.
Hudson Yards (continued)
Economic benefits Environmental benefits

Hudson Yards is a new economic engine for New York City. The Hudson Yards is Manhattan’s
project contributed more than $10 billion to the City’s GDP during first-ever project to receive the
construction and serves as a significant source of revenue to the MTA. LEED GOLD Neighborhood
Hudson Yards is well known as the largest private sector project in Development designation.
US history and an enormous source of jobs through construction and
associated industries. The first wave of construction at Hudson Yards, A 13.3MW cogeneration
comprising nearly 7.5 million square feet, was built predominantly with facility will provide over 50%
union labor. of the electrical and thermal
demand of the Eastern Yards,
From 2012 through 2025, hard- and soft-cost spending on the avoiding 25,000 million tons
development of Hudson Yards will have directly supported an average of greenhouse gas emissions
of nearly 4,600 jobs each year, including an average of 3,116 jobs each each year (equal to the annual
year in construction, and 1,476 jobs in associated industries. Total emissions of 5,000 cars).
wages and salaries paid to these workers will average $579.7 million
each year, an average of about $126,000 per job. Nearly 10 million gallons of
stormwater will be collected
Related created the “Hudson Yards Hiring Network” in 2018 to help each year from building roofs
assure that as many of the operational jobs being created by our and public plazas, then filtered
new Hudson Yards development would be made available to city and reused in mechanical
residents who might have additional barriers to employment. The and irrigation systems to
Hiring Network coordinates the efforts of multiple city agencies and conserve potable water for
at least ten community nonprofits that service the needs of those who drinking and reducing stress
are justice-involved, have physical and mental health disabilities, live on New York’s sewer system.
in public housing, or are veterans or homeless. Captured rainwater is used to
irrigate the over 200 mature
After the second half of the project is built between 11th and 12th trees and 28,000 plants in the
Avenues, Hudson Yards is expected to contribute nearly $19 billion public park.
annually to New York City’s GDP. This is just one piece of the overall
economic impact the redevelopment of the Hudson Yards district will
have on the city, state, and region.
The Grand LA is a visionary project to

revitalize downtown LA’s cultural and
civic core with a mix of commercial, retail,
cultural, and residential units stitched
together with great public spaces and
world-class architecture.
Project description
The Grand LA The Grand LA is a multiphase master-planned development to
reenvision and redevelop underutilized government-owned parcels
Partner energyRe
directly adjacent to the Civic Center and key cultural institutions such
Location Los Angeles, CA
as the Music Center, Walt Disney Concert Hall, The Colburn School of
Project type Mixed use development Music, and the Museum of Contemporary Art. The Grand is designed
Project size 1.56 million square feet to become a 24-7 destination for shopping, dining, entertainment and
Project technology N/A hospitality, as well as a paradigm-shifting place to live. The result will
COD Est. 2022 be a dynamic mixed-use district fitting for the cultural center of Los
Angeles.
actual capacity 2020 N/A N/A Part of The Grand Avenue Project is a visionary public-private
factor (past three 2019 N/A N/A partnership with the Los Angeles Grand Avenue Authority to revitalize
years) 2018 N/A N/A downtown LA's cultural and civic core with a mix of commercial, retail,
Availability factor Year Availability factor
cultural and residential uses stitched together with great public spaces
and world-class architecture. This multi-phased master planned
2019 N/A
development is re-envisioning and re-developing underutilized
2018 N/A
government-owned parcels directly adjacent to the Civic Center and
Reference Jon Weinstein
key cultural institutions..
212.801.3902
The Grand LA (continued)
The Grand will include 176,000 square feet of retail space anchored Designed by Frank Gehry, The Grand will include a dynamic mix
by chef-driven restaurants and a collection of shops; more than 400 of hotel, dining, nightlife and residential anchored by a central
residences of which 20% will be affordable housing units; a luxury public plaza above subterranean parking. This $1 billion mixed-use
hotel and more. The development will also include a large, vibrant development is being developed by Related Companies and its
public plaza with a series of landscaped, open terraces. Key project partner CORE USA, a joint venture of China Harbour Engineering
components funded by Related include these: Company and CCCG Overseas Real Estate (CORE). Destination
restaurants and shopping will be spread among a series of
• Grand Park (12-acre public park, 3 million visitors yearly, completed landscaped open terraces along with a 39-story residential tower,
2012) 20% of which will be affordable-rate units.
• The Emerson residential tower (271 residences, 5,000 square feet of
retail/restaurant, completed 2014) As part of Related’s longtime commitment to the larger Grand Avenue
Project, Related also developed Grand Park.
• The Broad contemporary art museum (completed 2015)
• The Grand (3.2 acres, 436 residences, 309 hotel rooms, 1,036-space
parking garage, 175,000 square feet retail/restaurant/entertainment,
1.56 million total square feet, estimated completion 2022)
The Grand LA (continued)
Benefits
The Grand will generate broad community benefits including an
estimated 10,000+ new jobs, including 8,310 construction jobs and
3,280 permanent jobs during operations. The Grand is working
with local labor advocates and human service agencies to create
construction and permanent employment opportunities for formerly
incarcerated individuals, nonnative English speakers, those without
a high school diploma, and other populations that face employment
barriers
The project will provide much-needed affordable housing, $1.3 billion

in one-time total economic output for Los Angeles County, $397
million in revenues to the City of Los Angeles, and $68 million in
revenues to the County of Los Angeles over the next 25 years.
The destination will attract thousands of visitors from across the

nation and around the world, along with downtown residents and
visitors from other communities throughout the region.
The Grand exceeds energy efficiency requirements through high-

efficiency heating, cooling, and hot water systems, LED lighting,
ENERGY STAR equipment and appliances, and smart controls. Use
of the city’s potable water supply is reduced through significant
rainwater collection and reuse for irrigation systems and water
efficient fixtures.
The Grand offers residents and visitors access to sustainable and

unique amenities including EV charging stations, on-demand electric
vehicle car sharing, and over 150 bicycle parking spaces. The Grand’s
site design enhances the neighborhood fabric with mixed uses and a
pedestrian-friendly streetscape.
3.6. Listing of projects developed or under • Implementing dynamic protocols for generation bidding into the
NYISO energy, ancillary, and capacity markets
construction • Forecasting generation, market prices, and emissions on a range of
Table 3-3 on the next page provides a listing of projects that the Clean time scales
Path NY members have successfully developed or are currently under • Developing and implementing short- and long-term fuel supply
construction. Further details on projects marked with an asterisk are planning and risk mitigation strategies to support the cost-effective
provided in this section. and reliable operation of NYPA's generating facilities
• Developing and implementing management strategies for hedging
3.7. NYISO market experience energy transactions to provide price and revenue stability.
As a transmission owner, NYPA operates more than 1,400 circuit miles

NYPA NYISO market experience
of transmission lines, primarily from its Clark Energy Center in Marcy,
NYPA has extensive experience operating in the NYISO market in a
NY. NYPA recoups costs associated with its transmission lines through
variety of roles, including as a generation owner, as a transmission
both the NYPA Transmission Adjustment Charge and NYISO Tariff.
owner, and as a load serving entity. NYPA has been a market
NYPA operates its transmission assets in compliance with NYISO and
participant since before the inception of the NYISO in the year 2000.
FERC regulations, ensuring reliability and open access. NYPA has
As a generation owner, NYPA offers output from its diverse fleet of extensive experience coordinating with the NYISO and developers on
16 generating facilities into the NYISO energy, capacity, and ancillary interconnections of new generators to NYPA’s transmission assets.
serves markets. NYPA generates approximately 25 TWh annually,
NYPA is an active stakeholder at the NYISO, representing and
providing nearly 20% of New York State’s electricity. NYPA operates
advocating for New York’s interests in the various NYISO working
a modernized trading facility at its offices in White Plains, NY and has
groups and guiding the development of NYISO policies and market
a 24x7 trading desk, ensuring seamless interaction with the NYISO.
rules.
NYPA’s trading group offers approximately 6,000 MW of hydropower
and natural gas generation into the NYISO markets on a daily basis.
NYPA optimizes its participation in the NYISO markets in these ways:
Invenergy development experience
Invenergy is an experienced developer and operator in NYISO, with
approximately 900 MW in operation or contracted, including the
following operating renewable facilities:
• High Sheldon Wind Farm, 112.5 MW, in Town of Sheldon, Wyoming

County, NY
• Orangeville Wind Farm, 94 MW, in Town of Orangeville, Wyoming
County, NY
• Marsh Hill Wind Farm, 16.2 MW, in Town of Jasper, Steuben County, Invenergy Services operates its renewable fleet from the Invenergy
NY Control Center in Invenergy’s Chicago headquarters office. The
• Shoreham Solar Commons, 24.9 MW, in Town of Brookhaven, Invenergy Control Center employs control room operators and power
Suffolk County, NY schedulers staffed around the clock 365 days a year. The control room
staff is responsible for monitoring and maintaining the availability of
Invenergy’s development and environmental permitting staff have all wind, solar, and energy storage facilities that Invenergy Services
conducted the permitting efforts on all these projects. Invenergy operates in North America. This facility serves as the critical hub
has broad experience with New York State permitting agencies and for the fleet. All communications between the sites, transmission
process, under SEQRA, Article 10 and Article VII, and has long- operators, balancing authorities, markets and outside counterparties
standing working relationships with the agencies whose jurisdiction run through its network.
these projects fall under.
As the main liaison to generation facilities, the Invenergy Control
Invenergy market experience Center manages all market-related functions, including availability
Invenergy operates over 11,000 MW of renewable and natural gas submissions and energy offers into the various markets throughout
facilities through its operations group, Invenergy Services. Invenergy the NYISO. The Power Trading and Settlements groups are located
Services provides asset management and operations for Invenergy- within the control room to work side by side with the Power
owned projects. It has steadily grown assets under management Scheduling group.
since expanding to serve third-party owners at the beginning of 2019.
The Invenergy Control Center ensures that all applicable contractual,
With 223 MW operated by the company, Invenergy has extensive
market and NERC compliance related requirements are complied
experience navigating and dispatching renewable power into the
with for all generation facilities. The Invenergy Control Center and
NYISO market.
Backup Control Center located in the west suburbs of Chicago are
both compliant with all NERC Critical Infrastructure Protection (“CIP”)
requirements.
Section 4
Resource description
and site control
4 Resource description and site control
4.1. Introduction effective and successful Tier 4 project.
The proposed renewable energy resources (referred to in the proposal

as either “Resources” or “portfolio of Resources”) are primarily new
3,400+ Wind projects are also in much shorter
supply in New York, considering that
MW
NYSERDA has contracted nearly 5 GW
onshore wind and solar PV projects. Figure 4-1 on the next page of solar compared to only about 1.5 GW
provides a graphical summary of all the proposed Resources that meet of Tier 4-eligible wind. Clean Path New
the eligibility requirements of “Renewable Energy System” as defined of exclusively New York has therefore focused its efforts
by the Climate Leadership and Community Protection Act. Table 4-1 York renewable on wind, securing more than 1,900 MW
provides general details for these Resources. Attached to this proposal generation in the Clean and 5 TWh/year of wind generation.
is Appendix 3 presenting a summary description of control status by Path New York portfolio Furthermore, Clean Path New York’s
parcel for each resources to provide evidence of site control. All of portfolio is mature and ready to perform.
the resources that were awarded Tier 1 RECs through NYSERDA’s More than 45% of Clean Path’s portfolio (by capacity) currently holds a
Renewable Energy Standards solicitation have already demonstrated NYSERDA Tier 1 REC contract and more than 30% holds a Certificate
site control to NYSERDA. Those remain available to NYSERDA upon of Environmental Compatibility and Public Need pursuant to Article
request. 10. In addition to Invenergy, the Clean Path portfolio includes projects
Clean Path New York has assembled an unparalleled portfolio of more from Northland Power, RWE, Apex, Terra-Gen, and Boralex, all of whom
than 3,400 MW of exclusively New York renewable generation to are experienced developers with track records of being able to deliver
support this proposal. Clean Path New York is confident this portfolio projects. These developers have all signed letters of support with Clean
represents the largest volume of in-state renewables of any project Path New York, which are provided as Appendix 4. Finally, the portfolio
and highest utilization of any intrastate transmission line, resulting in is zonally diversified, with no more than 30% of capacity in any one
optimum project economics while also maximizing in-state economic zone. This will help to reduce overall basis risk to Clean Path and will
benefits. The advantages of this large portfolio are further amplified also provide resource diversity to the portfolio.
by leveraging the state’s largest storage resource, Blenheim-Gilboa,
as described in detail in Section 9. Because wind has a much more
diverse generating profile than solar, in addition to a significantly
higher net capacity factor, a large quantity of wind is essential to a cost
1
Clean Path New York notes that NYSERDA’s response to Question #61 in its circulation of questions and answers posted on May 7, 2021, added a requirement for maps of MSG classifications. While it
is not practical to produce this mapping in the remaining timeframe, Clean Path New York can provide such mapping post-bid submittal, if requested by NYSERDA.
Bull Run Wind
Clean Path New York is proposing a portfolio of diverse resources. Bull Run Solar
Figure 4-1. Clean Path New York’s Resources are located

exclusively in New York State.
Twinleaf Solar
Greens Corners Solar
Number Three Wind
Sandy Creek Solar
West River Solar
Heritage Wind
Verona Solar I & II

Horseshoe Solar Bald Mountain
Orangeville Solar Solar
Wintergreen Solar
Seventy-Seven Solar
Prattsburgh Taproot Solar
Wind High Bridge
Sky High Solar
Wind
Baron Winds
Phase I
Ball Hill Wind Blenheim-Gilboa
Canisteo Wind Bluestone Wind
Clean Path New York is bidding a projected annual quantity of

7,496,113 MWh with the potential to add an additional 374,753 MWh
(for a total of 7,870,865 MWh) if selected for award inclusive of storage
utilizing NYPA’s pumped storage facility at Blenheim-Gilboa. Between
projects owned by Invenergy and projects retained through executed
indicative term sheets with third-party generators, Clean Path New
York holds 3,354 MW of generation (1,924 MW of wind, 1,430 MW
of solar 1). This portfolio represents 87% of the expected generation
capacity (MW) and 92% of the expected generation (MWh). Clean
Path New York is confident that, if selected, it will be able to round
out the portfolio necessary to meet the projected annual quantity, as
evidenced by list of additional resources listed in Section 4.25.
Project Developer Capacity Location Technology Tier-1 Contract COD

Alle-Catt Wind Invenergy 340 MW Wyoming, Cattaraugus, Allegany Counties Wind
✓ Q3 2024
Horseshoe Solar Invenergy 180 MW Livingston County Solar PV
✓ Q4 2023
Number Three Wind Invenergy 104 MW Lewis County Wind

✓ Q3 2022
Canisteo Wind Invenergy 250 MW Steuben County Wind Q2 2023
Bull Run Wind Invenergy 449 MW Clinton County Wind Q3 2024
Verona Solar Invenergy 350 MW Oneida County Solar PV Q4 2024
Twinleaf Solar Invenergy 75 MW Lewis County Solar PV Q4 2024
Taproot Solar Invenergy 205 MW Montgomery County Solar PV Q4 2025
Wintergreen Solar Invenergy 75 MW Montgomery County Solar PV Q3 2025
Orangeville Solar Invenergy 75 MW Wyoming County Solar PV Q3 2025
Seventy Seven Solar Invenergy 100 MW Wyoming County Solar PV Q4 2024
Bull Run Solar Invenergy 170 MW Clinton County Solar PV Q3 2025
Ball Hill Wind Northland 107 MW Chautauqua County Wind

✓ Q4 2022
Bluestone Wind Northland 111 MW Broome County Wind

✓ Q4 2022
High Bridge Wind Northland 103 MW Chenango County Wind

✓ Q3 2023
Bald Mountain Solar Boralex 20 MW Washington County Solar PV

✓ Q4 2022
West River Solar Boralex 20 MW Saratoga County Solar PV

✓ Q2 2024
Sandy Creek Solar Boralex 20 MW Jefferson County Solar PV

✓ Q4 2023
Greens Corners Solar Boralex 120 MW Jefferson County Solar PV

✓ Q4 2023
Sky High Solar Boralex 20 MW Onondaga County Solar PV

✓ Q1 2023
Baron Winds Phase I RWE 121 MW Steuben County Wind

✓ Q4 2022
Heritage Wind Apex 198 MW Orleans County Wind

✓ Q4 2021
Prattsburgh Wind Terra-Gen 147 MW Steuben County Wind

✓ Q4 2023
Table 4-1. Clean Path New York’s Resources summary.

4.2. Alle-Catt Wind

Resource site plan and proposed route to the injection point
Alle-Catt Wind N
Legend
Developer Invenergy Wind turbine
Transmission proposed route
Location Wyoming, Cattaraugus,
and Allegany Counties, Site boundary
NY
Installed 340 MW
capacity
Status Development stage

(expected COD: Q3
2024)
Technology 116 onshore wind

turbines in four wind
turbine models
Land use 45% agricultural land

and 45% forested land
Land control Secured, through lease

or option, 37,000 acres
across 300 parcels
Interconnection NYISO Queue position

0569; completed SRIS
and Class Year 2019
Table 4-2. Alle-Catt Wind resource summary Figure 4-2. Alle-Catt Wind project site plan.
matrix.
Development status Site ownership or lease

Alle-Catt Wind is a 340 MW wind project in the development stage. Alle-Catt Wind has secured, through lease and option, all land
Construction is expected to commence in Q4 2022 with a proposed required to develop and operate the full 340 MW project over the
commercial operation date of Q3 2024. Alle-Catt Wind received its entire contract tenor. Almost 37,000 acres have been signed across
Certificate of Environmental Compatibility and Public Need pursuant 300 parcels.
to Article 10 of the Public Service Law (Case 17-F-0282) in June 2020
and has submitted its Article VII Application in February 2021 (Case Injection point and generator lead line right of way
21-T-0059). Alle-Catt Wind filed an interconnection request with Alle-Catt Wind has secured, through lease or option, approximately
NYISO in January 2017. Its queue position is number 0596. Its system 95% of the lands to host transmission infrastructure including an
reliability impact study is complete, and it participated in Class Year interconnection point switchyard and a 10-mile transmission line. It
2019 and accepted its cost allocation. is targeting to complete late-stage negotiations with the remaining
parcels by Q2 2021. The proposed injection point switchyard (Lime
Technology and equipment Lake Switchyard) will be located on land to be owned by Alle-Catt
Alle-Catt Wind has permitted 116 onshore wind turbine locations. It Wind and transferred to National Grid following construction. The
is currently considering at least four wind turbine models and will transmission facility’s sole purpose is to operate as a generator lead
likely settle on a combination of models to meet siting and project (or interconnection line) to deliver electricity produced by the project
goals. The transmission facility consists of a new 10-mile overhead to the National Grid transmission system.
345 kV electric transmission line connecting the project’s 34.5/345
kV collector substation to a newly built three-breaker ring bus 345
kV switchyard substation. This is the point of interconnection, also
referred to as Lime Lake Switchyard. The switchyard will connect to
the existing 345 kV overhead line between the Stolle Road and Five
Mile Road Substations owned by National Grid.
Local zoning and existing land use

The existing land use for the facility site and the surrounding area
is primarily zoned as Agricultural/Rural, with smaller areas zoned
Residential, Industrial, and Land Conservation. The facility site is
classified as approximately 45% agricultural land and 45% forested
land, with the remaining 10% comprised of shrub/scrub, open water,
and developed (residential or commercial) areas. The setting is rural,
and the site has primarily been used for agriculture. Two existing wind
farms are in vicinity of the site.
4.3. Horseshoe Solar

Horseshoe Solar N
Legend
Developer Invenergy Preliminary panel area
Location Livingston County, NY Site boundary
Capacity 180 MW

(expected COD: Q4
2023)
Technology Bifacial panels on

single-axis trackers


of option, 4,600 acres
across 25 parcels

and entered Class Year
2021
MSG Total panel area of 1,305

classification acres with 715 acres
located within MSG
Groups 1-4
Table 4-3. Horseshoe Solar resource summary matrix. Figure 4-3. Horseshoe Solar project site plan.
Development status Ownership or lease

Horseshoe Solar is a 180 MW solar project in the development stage. Horseshoe Solar has secured, through lease, easement, or option, all
Construction is expected to commence in Q2 2022, with a proposed lands proposed to host all required solar facilities and construction
commercial operation date of Q4 2023. Horseshoe Solar submitted areas to develop and operate a 180 MW solar project over the entire
its Article 10 Application in July 2020 (Case 18-F-0633), which contract tenor. Approximately 4,600 acres have been signed across
also includes the transmission line and associated facilities, and is 25 parcels.
anticipating a completeness determination in Q2 2021. Horseshoe
filed an interconnection request with NYISO in May 2018. Its queue Generator lead line right of way
position is number 0710. Its system reliability study is complete, and it Horseshoe Solar has secured, through option agreements, all lands
has entered Class Year 2021. required to host transmission infrastructure. The ~400 ft transmission
line will cross a public road and Horseshoe Solar has purchase
Technology and equipment options for the property on each side. The proposed injection point
Horseshoe Solar is currently proposing to use bifacial solar panels is National Grid’s existing 115 kV Golah Substation. Horseshoe Solar
mounted on single-axis trackers. The transmission facility consists has a purchase option for the adjacent parcel to provide for the
of a very short (~400 ft) overhead 115 kV electric transmission line expansion of Golah Substation to construct a new breaker position for
connecting the project’s 34.5/115 kV collector substation to National its interconnection.
Grid’s existing 115 kV Golah Substation.
Mineral Soil Group (MSG) classification
Local zoning and existing land use The total panel area is approximately 1,305 acres, and 715 acres is
The facility site and surrounding area is primarily zoned agriculture/ located within MSG Groups 1-4. Horseshoe Solar’s Tier 1 contract
rural residence and residential, with smaller areas zoned industrial, pre-dates NYSERDA’s requirement for solar projects constructed on
land conservation, and commercial. The facility site is classified as MSG Groups 1-4 to make an agricultural mitigation payment. However,
approximately 77% agricultural land and 20% forested land, with the Horseshoe Solar intends to implement co-utilization in the form of
remainder comprised of shrub/scrub, open water and developed. The solar grazing for vegetation maintenance.
setting is rural, and the site has primarily been used for agriculture.
Several stone quarries and one community solar project are near
the site.
4.4. Number Three Wind

Number Three Wind N

Legend
Transmission proposed route
Location Lewis County, NY
Site boundary
Capacity 104 MW
Status Construction stage

(expected COD: Q3
2022)
Technology 27 on shore wind

turbines [22 Vestas
(V150-4.2) and 5 GE (GE
2.3-116)]


across 160 parcels

and participated in Class
Year 2019 and accepted
its cost allocation
Table 4-4. Number Three Wind resource summary Figure 4-4. Number Three Wind project site plan.
matrix.
Development status Local zoning and existing land use

Number Three Wind is a 104 MW wind project in the construction The Project Area is primarily zoned Agricultural, Residential, and
stage. Tree clearing commenced in March 2021 and full civil Vacant land. The land cover classification is approximately 62%
construction is anticipated to begin in July 2021, with an anticipated agricultural land, 27% forested land, with the remaining 11% consisting
commercial operation date as of Q3 2022. Number Three Wind of scrub/shrub, grasslands, and developed areas. The setting is rural,
received its Certificate of Environmental Compatibility and Public and the site has primarily been used for agriculture. Two existing wind
Need pursuant to Article 10 of the Public Service Law (Case 16-F- farms border the site on the west and north.
0328) in November 2020, which also included the transmission line
and associated facilities. Number Three Wind filed an interconnection Ownership or lease
request with NYISO in January 2016. Its queue position is number Number Three Wind has secured, through lease or option, all land
0531. Its system reliability study is complete, and it participated in required to develop and operate the full 104 MW wind project over
Class Year 2019 and accepted its cost allocation. the entire contract tenor. More than 10,000 acres have been signed
across 160 parcels.
Technology and equipment
Number Three Wind has permitted 31 onshore wind turbine locations. Generator lead line right of way
It has selected a combination of turbines (27 total) as its final build, Number Three Wind has secured, through option or agreement, all
with 22 turbines being Vestas wind turbines (V150-4.2) and the lands to host transmission infrastructure, including the interconnection
remaining 5 being GE wind turbines (GE 2.3-116). The transmission switchyard and a 3.7-mile transmission line. The proposed injection
facility consists of a new 3.7-mile 115 kV electric transmission line out point switchyard (Waters Road Station) will be located on land to
of which around 1.2 miles is underground connecting the project’s be owned by Number Three Wind and transferred to National Grid
34.5/115 kV collector substation to a newly built 5-breaker ring bus following construction. The transmission facility’s sole purpose is
115 kV switchyard substation. This is the point of interconnection, also to operate as a generator lead (or interconnection line) to deliver
referred to as the Waters Road Station. The switchyard will connect to electricity produced by the project to the National Grid transmission
the existing 115 kV overhead lines running between the Taylorville and system.
Boonville Substations owned by National Grid.
4.5. Canisteo Wind

Canisteo Wind Legend N
Location Steuben County, NY Transmission proposed route
Site boundary
Capacity 250 MW

(expected COD: Q2
2023)

turbines with five turbine
models


or option, 95% of lands
to host transmission
infrastructure

Year 2019 and accepted
its cost allocation
Table 4-5. Canisteo Wind resource summary matrix.
Figure 4-5. Canisteo Wind project site plan.


Canisteo Wind is a 250 MW wind project in the development stage. Canisteo Wind has secured, through lease or option, all land required
Construction is expected to commence in Q1 2022, with a proposed to develop and operate the full 290.7 MW wind project over the
commercial operation date of Q2 2023. Canisteo Wind received its entire Contract Tenor. Over 38,000 acres have been signed across
Certificate of Environmental Compatibility and Public Need pursuant approximately 480 parcels.
to Article 10 of the Public Service Law (Case 16-0772) in March 2020
and had its Article VII Application (Case 19-T-0041) deemed compliant Generator lead line right of way
November 2019. Canisteo Wind filed an interconnection request with Canisteo Wind has secured, through option or agreement,
NYISO in October 2015. Its queue position is number 0519. Its System approximately 95% of the lands to host transmission infrastructure,
Reliability Impact Study (SRIS) is complete, and it participated in Class including a 14.6-mile transmission line. It is targeting to complete
Year 2019 and accepted its cost allocation. late-stage negotiations with the remaining parcels by Q2 2021. The
proposed injection point switchyard (Bennett Substation) is owned
Technology and equipment by NYSEG. The transmission facility’s sole purpose is to operate as a
Canisteo Wind has permitted 117 onshore wind turbine locations. It generator lead (or interconnection line) to deliver electricity produced
is currently considering at least 5 wind turbine models and will likely by the project to the transmission system.
settle on a combination of models to meet siting and project goals.
The transmission facility consists of a new 14.6 mile overhead 115 kV
transmission line connected to the project’s 34.5 /115 kV collector
substation to the existing Bennett Substation owned by NYSEG.

The facility site and surrounding area is primarily zoned residential,
agricultural, and vacant. The land cover classification is approximately
48% open land (crop, pasture, successional fields) and 42% forested
land, with the remainder consisting of scrub/shrub and developed
areas. The setting is rural and the site has primarily been used for
agriculture. Three existing wind projects are within the vicinity of the
site, including Invenergy’s own Marsh Hill wind project operates within
the site footprint.
4.6. Bull Run Wind

Bull Run Wind N

Legend
Location Clinton County, NY Transmission proposed route
Site boundary
Capacity 449 MW

(expected COD: Q3
2024)

turbines with models
ranging from 2.3-5.6
MW
Land use 65% forested land and

19% agricultural land

across 240 parcels

0497 and 0521;
completed SRIS and
participated for both
queue positions and it
has entered 0521 into
Class Year 2021
Table 4-6. Bull Run Wind resource summary matrix. Figure 4-6. Bull Run Wind project site plan.

Bull Run Wind Energy is a 449 MW wind project in the development Bull Run Wind Energy has secured, through lease or option, nearly all
stage. Construction is expected to commence in Q4 2022, with land required to develop and operate the full 449 MW wind project.
a proposed commercial operation date of Q3 2024. Bull Run Almost 33,000 acres have been signed across approximately 240
Wind submitted its application for a Certificate of Environmental parcels.
Compatibility and Public Need pursuant to Article 10 of the Public
Service Law (Case 15-F-0377) in August 2019. Bull Run Wind filed two Generator lead line right of way
interconnection requests with NYISO in April 2015 and December Bull Run Wind Energy has secured, through option or agreement, all
2015. Its queue position numbers are 0497 and 0521. Its system lands to host transmission infrastructure, including an interconnection
reliability studies are complete for both queue positions and it has point switchyard and a 3.3-mile transmission line. The Proposed
entered 0521 (for the full 449 MW) into Class Year 2021. injection point switchyard will be located on land to be owned by
Bull Run Wind and transferred to NYPA following construction. The
Technology and equipment transmission facility’s sole purpose is to operate as a generator lead
Bull Run Wind Energy is applying to permit up to 139 onshore wind (or interconnection line) to delivery electricity produced by the Project
turbine locations and is considering turbine models ranging from to the transmission system.
2.3-5.6 MW to meet siting and project goals. The transmission
facility consists of a 3.3 mile overhead 230 kV electric transmission
line connecting the project’s 34.5/230 kV collector substation to a
newly built switching station, which will connect to the existing NYPA
Patnode-Duley 230 kV and Ryan-Plattsburgh 230kV lines.

The facility site and surrounding area is primarily zoned residential,
agricultural, and vacant. The land cover classification is approximately
65% forested land and 19% agricultural land, with the remaining 16%
consisting of wetlands, scrub/shrub, grasslands, and developed
areas. The setting is rural, and the site has primarily been used for
agriculture, logging, and recreational purposes. Six existing wind
projects are within 10 miles of the site, while one directly borders the
project to the west. There are also two existing community scale solar
projects within the vicinity of the site.
4.7. Verona Solar

Verona Solar
Developer Invenergy
Location Oneida County, NY
Capacity 350 MW

(expected COD: Q4
2024)

Land use 56% agricultural land,

22% forested land, and
16% wetlands
Land control

0871 and 0873; its
feasibility study is
complete, and it expects
to enter Class Year 2022
MSG 50% (~740 acres) of the

classification preliminary panel area
is classified within MSG
soil groups 1-4
Table 4-7. Verona Solar resource summary matrix. Figure 4-7. Verona Solar project site plan.

Verona Solar is a 350 MW solar project in the development stage.
Construction is expected to commence in Q2 2023, with a proposed
commercial operation date of Q4 2024. Verona Solar submitted its
Public Involvement Program Plan Q1 2020 pursuant to Article 10 of
the Public Service Law (Case 19-F-0777) and continues to consult with Generator lead line right of way
Project stakeholders. Verona Solar anticipates transitioning into the
new 94c process and submitting a Project Application in late 2021.
Verona
Solar filed two interconnection requests with NYISO in June 2019. Its
queue positions are numbers 0871 and 0873. Its feasibility study is
complete, and it expects to enter Class Year 2022. Mineral Soil Group (MSG) classification
Approximately 50% (~740 acres) of the preliminary panel area is
Technology and equipment classified within MSG soil groups 1-4. Verona Solar is currently in
Verona Solar will likely propose bifacial panels on single-axis trackers, early development stages and anticipates panel areas may change
but this may change depending on PV technology available at later as development progresses. Verona Solar will continue considering
stages of development. Verona Solar is planning to connect to NYPA’s mineral soil groups and agricultural districts when designing and
existing Edic to Clay 345 kV line via a newly built switchyard. The selecting final locations for Project facilities.
34.5/345 kV collector substation is expected to be adjacent to the
point of interconnection, resulting in a very short transmission line.

The Project Area is primarily zoned as rural development. The Project
Area’s land cover classification consists primarily of agricultural land
(56%), forested areas (22%), and wetlands (16%). The remaining 6%
consists of scrub/shrub, grasslands, and developed areas. Verona
Solar is at a relatively early development stage and may refine the
Project Area as development progresses. The setting is rural, and the
site has primarily been used for agriculture.
4.8. Twinleaf Solar

Twinleaf Solar
Developer Invenergy
Location Lewis County, NY
Capacity 75 MW
Status Early development stage

(expected COD: Q4
2024)

Land use 59% forested land, 24%

agricultural land, and 8%
wetlands
Land control

1141 filed in March 2021

soil groups 1-4
Table 4-8. Twinleaf Solar resource summary matrix. Figure 4-8. Twinleaf Solar project site plan.

Twinleaf Solar is a 75 MW solar project in the early development
stages and is undertaking studies to prepare for the submission of an
Application under the 94c process in 2022. Construction is expected
to commence in Q4 2023 with a proposed commercial operations Generator lead line right of way
date of Q4 2024. Twinleaf filed an interconnection request with NYISO
in March 2021. Its queue position is number 1141.

Twinleaf Solar will likely propose bifacial panels on single-axis
trackers, but this may change depending on PV and racking
technology available at later stages of development. Twinleaf Solar is Mineral Soil Group (MSG) classification
planning to connect to National Grid’s Coffeen St. - Taylorville 115 kV Twinleaf Solar is currently in early development stages and anticipates
line via a newly built switchyard. The 34.5/115 kV collector substation panel areas may change as development progresses. Twinleaf Solar
is expected to be adjacent to the point of interconnection, resulting in will continue considering mineral soil groups and agricultural districts
a very short transmission line. when designing and selecting final locations for Project facilities.
Approximately 40% (~115 acres) of the preliminary panel area is
Local zoning and existing land use classified within MSG soil groups 1-4.
The Project Area is not zoned. The Project Area’s land cover
classification consists primarily of forested areas (59%), agricultural
land (24%), and wetlands (8%). The remaining 9% consists of scrub/
shrub, grasslands, open water, and developed areas. Twinleaf Solar
is at a relatively early development stage and may refine the Project
Area as development progresses. The setting is rural, and the site has
primarily been used for agriculture.
4.9. Taproot Solar

Taproot Solar
Developer Invenergy
Location Montgomery County, NY
Capacity 205 MW
Status Early development

stage (expected COD:
Q4 2025)


8% wetlands
Land control

1140 filed in March 2021

soil groups 1-4
Table 4-9. Taproot Solar resource summary matrix.
Figure 4-9. Taproot Solar project site plan.


Taproot Solar is a 205 MW solar project in the early development
to commence in Q2 2024 with a commercial operations date of Q4 Generator lead line right of way
2025. Taproot filed an interconnection request with NYISO in March
2021. Its queue position is number 1140.

Taproot will likely propose bifacial panels on single-axis trackers,
but this may change depending on PV technology available at later
stages of development. Taproot Solar is proposing to interconnect to
National Grid’s existing Edic - New Scotland 345 kV line via a newly Mineral Soil Group (MSG) classification
built switchyard. The 34.5/345 kV collector substation is expected to Taproot is currently in early development stages and anticipates
be adjacent to the point of interconnection, resulting in a very short panel areas may change as development progresses. Taproot will
transmission line. continue considering mineral soil groups and agricultural districts
when designing and selecting final locations for Project facilities.
Local zoning and existing land use Approximately 12% (~180 acres) of the preliminary panel area is
The Project Area is primarily zoned as agricultural/rural residential. classified within MSG soil groups 1-4.
The Project Area’s land cover classification consists primarily of
agricultural land (61%), forested areas (25%), and wetlands (8%). The
remaining 6% consists of scrub/shrub, grasslands, and developed
areas. Taproot is at a relatively early development stage and will refine
the Project Area as development progresses. The setting is rural,
and the site has primarily been used for agriculture. One other solar
project is near the Project Area.
4.10. Wintergreen Solar

Wintergreen Solar
Developer Invenergy
Location Montgomery County, NY
Capacity 75 MW

(expected COD: Q3
2025)


9% wetlands
Land control

1138 filed in February
2021

soil groups 1-4
Table 4-10. Wintergreen Solar resource summary Figure 4-10. Wintergreen Solar project site plan.
matrix.

Wintergreen Solar is a 75 MW solar project in the early development
Application under the 94c process in 2022. Construction is expected .
to commence in Q4 2024 with a commercial operations date of Q3
2025. Wintergreen filed an interconnection request with NYISO in Generator lead line right of way
February 2021. Its queue position is number 1138.

Wintergreen Solar will likely propose bifacial panels on single-axis
trackers, but this may change depending on PV technology available
at later stages of development. Wintergreen Solar is currently
considering the existing Marshville 115 kV substation as the point of
interconnection. The 34.5/115 kV collector substation is expected to Mineral Soil Group (MSG) classification
be adjacent to the point of interconnection, resulting in a very short Wintergreen is currently in early development stages and anticipates
transmission line. panel areas may change as development progresses. Wintergreen
will continue considering mineral soil groups and agricultural districts
Local zoning and existing land use when designing and selecting final locations for Project facilities.
The Project Area is primarily zoned as rural residential. The Project Approximately 17% (~140 acres) of the preliminary panel area is
Area’s land cover classification consists primarily of agricultural land classified within MSG soil groups 1-4.
(60%), forested areas (25%), and wetlands (9%). The remaining 5%
consists of scrub/shrub and developed areas. Wintergreen is at a
relatively early development stage and may refine the Project Area
as development progresses. The setting is rural, and the site has
been primarily used for agriculture. One other solar project is near the
Project Area.
4.11. Orangeville Solar

Orangeville Solar
Developer Invenergy
Capacity 75 MW

(expected COD: Q3
2025)


5% developed
Land control

2021

soil groups 1-4
Table 4-11. Orangeville Solar resource summary matrix. Figure 4-11. Orangeville Solar project site plan.

Orangeville Solar is a 75 MW solar project is in the early development
to commence in Q3 2024 with a commercial operations date of Q3
2025. Orangeville filed an interconnection request with NYISO in Generator lead line right of way
February 2021. Its queue position is number 1137.

Orangeville Solar will likely propose bifacial panels on single-
axis trackers, but this may change depending on PV technology
available at later stages of development. Orangeville Solar is
currently considering the Orangeville 230 kV substation and the
Wethersfield 230 kV substation as potential points of interconnection. Mineral Soil Group (MSG) classification
The 34.5/230 kV collector substation is expected to be adjacent Orangeville Solar is currently in early development stages and
to the selected point of interconnection, resulting in a very short anticipates panel areas may change as development progresses.
transmission line. Orangeville solar will continue considering mineral soil groups and
agricultural districts when designing and selecting final locations for
Local zoning and existing land use Project facilities. Approximately 47% (~470 acres) of the preliminary
The Project Area is primarily zoned as agricultural. The Project Area’s panel area is classified within MSG soil groups 1-4.
land cover classification consists primarily of agricultural land (58%),
forested areas (32%), and developed areas (5%). The remaining
5% consists of wetlands and shrub/scrub. Orangeville Solar is at a
relatively early development stage and may refine the Project Area
as development progresses. Invenergy’s Orangeville Wind project is
within the vicinity of the Orangeville Solar Project.
4.12. Seventy Seven Solar

Seventy Seven Solar

Developer Invenergy
Capacity 100 MW

(expected COD: Q4
2024)


26.5% forested land,
and 5% developed
Land control

2021

soil groups 1-4
Table 4-12. Seventy Seven Solar resource summary Figure 4-12. Seventy Seven Solar project site plan.
matrix.
Development status Generator lead line right of way

Seventy Seven Solar is a 100 MW solar project in the early
development stages, and is undertaking studies to prepare for
the submission of an Application under the 94c process Q4 2021.
Construction is expected to commence in Q3 2023 with a commercial
operations date of Q4 2024. Seventy Seven filed an interconnection
request with NYISO in February 2021. Its queue position is
number 1139.
Technology and equipment Seventy Seven Solar is currently in early development stages, and
Seventy Seven Solar will likely propose bifacial panels on single-axis anticipates panel areas may change as development progresses. 77
trackers, but this may change depending on PV technology available Solar will continue considering mineral soil groups and agricultural
at later stages of development. Seventy Seven Solar is proposing the districts when designing and selecting final locations for Project
Stony Creek 230 kV substation as the point of interconnection. The facilities. Approximately 32% (~430 acres) of the preliminary panel
34.5/230 kV collector substation is expected to be adjacent to the area is classified within MSG soil groups 1-4.
point of interconnection, resulting in a very short transmission line.

The Project Area is primarily zoned as agricultural. The Project Area’s
land cover classification consists primarily of agricultural land (66%),
forested areas (26.5%), and developed areas (5%). The remaining 2.5%
consists of wetlands and shrub/scrub. Seventy Seven Solar is at a
relatively early development stage and may refine the Project Area as
development progresses. Invenergy’s Sheldon Wind project is within
the vicinity of the proposed Seventy Seven Solar project.
Ownership or lease
4.13. Bull Run Solar

Bull Run Solar

Developer Invenergy
Location Clinton County, NY
Capacity 170 MW

(expected COD: Q3
2025)


14% wetlands
Land control

0686 filed in January
2018 and have
completed the SRIS and
currently undertaking
the Facilities Study

soil groups 1-4
Table 4-13. Bull Run Solar resource summary matrix. Figure 4-13. Bull Run Solar project site plan.

Bull Run Solar is an up to 170 MW solar project in the development
stage, although its capacity may be reduced to 75 MW depending
on final turbine selection and design of Bull Run Wind. Construction .
is expected to commence in Q4 2024, with a proposed commercial
operation date of Q3 2025. Bull Run Solar submitted its Public Generator lead line right of way
Involvement Program Plan in May 2018 pursuant to Article 10 (Case
18-F-0189) and continues to consult with Project stakeholders. Bull
Run Solar anticipates submitting a Project Application under the 94c
process in 2022. Bull Run Solar filed an interconnection request with
NYISO in January 2018. Its queue position is number 0686.

Bull Run Solar will likely propose bifacial panels on single-axis Mineral Soil Group (MSG) classification
trackers, but this may change depending on PV technology available Bull Run Solar is currently in early development stages and anticipates
at later stages of development. Bull Run Solar is proposing NYPA’s panel areas may change as development progresses. Bull Run Solar
Patnode – Duley 230 kV line as the point of interconnection. This will continue considering mineral soil groups and agricultural districts
is part of the point of interconnection that is proposed for Bull Run when designing and selecting final locations for Project facilities.
Wind and it is anticipated that Bull Run Solar would tie into the same Approximately 52% (~290 acres) of the preliminary panel area is
switchyard. classified within MSG soil groups 1-4.

The Project Area is primarily zoned residential, agricultural, and
vacant. The Project Area’s land cover classification consists primarily
of agricultural land (44%), forested areas (38%), and wetlands (14%).
Bull Run Solar is at an early development stage and may refine the
Project Area as development progresses. The setting is rural, and the
site has primarily been used for agriculture, logging and recreational
purposes. Six existing wind projects and two community scaled solar
projects are within 10 miles of the site.
4.14. Ball Hill Wind

Ball Hill Wind Legend N

Developer Northland Power Wind turbine
Site boundary
Location Chautauqua County, NY
Capacity 107 MW

(expected COD: Q4
2022)

turbines [22 Vestas
(V150-4.3) and 3 Vestas
(V136-4.2)]
Land use 41% agricultural, 56%

forested

and easement, 6,000
acres across 170 parcels

Year 2017
Table 4-14. Ball Hill Wind resource summary matrix.
Figure 4-14. Ball Hill Wind project site plan.


Ball Hill Wind is a 107 MW wind project in development and will be The existing land use for the Ball Hill Wind is primarily zoned as
entering the construction stage this year. Tree Clearing activities Agricultural (41%), Forested (56%), and Vacant land (3%). The setting is
commenced in February 2021 and full civil construction is anticipated rural, and the site has primarily been used for agriculture.
to begin in June 2021, with an anticipated commercial operation date
in the fourth quarter of 2022. Ball Hill Wind has obtained its special Ownership or lease
use permit (SUP) and New York State Environmental Quality Review Ball Hill has secured through lease and easement all land required
Act (SEQRA) permits from the Towns of Villenova and Hanover. to develop and operate the 107.2 MW wind project over the entire
Ball Hill filed an interconnection request with NYISO in June 2015. contract tenor. More than 6,000 acres have been signed across 170
Its queue position number is 0505. Its system reliability study is parcels.
complete, and it participated in Class Year 2017 and accepted its cost
allocation. Generator lead line right of way
Ball Hill Wind has secured, through easement or agreement, all lands
Technology and equipment to host transmission infrastructure, including the interconnection
Ball Hill Wind has permitted 29 onshore wind turbine locations. It switchyard and a 25.6-mile transmission line. The proposed injection
has selected a combination of 25 turbines as its final build, with point switchyard will be located on land to be owned by Ball Hill
22x Vestas V150-4.3 and 3 Vestas V136-4.3 MW turbines. The Wind and transferred to National Grid following construction. The
transmission facility consists of a new 25.6-mile 34.5 kV, mostly transmission facility’s sole purpose is to operate as a generator lead
underground electric transmission line connected to the project’s (or interconnection line) to deliver electricity produced by the project
34.5/230 kV collector substation to connect to National Grid’s 230 kV to the National Grid transmission system.
system between Dunkirk and Gardenville via three-breaker ring bus
arrangement.
4.15. Bluestone Wind

Bluestone Wind
Legend N
Developer Northland Power
Wind turbine
Location Broome County, NY Site boundary
Capacity 111 MW

(expected COD: Q4
2022)

turbines [Vestas (V150-
4.3)]

residential, and 33%
vacant land

and easement, 8,000

Year 2017
Table 4-15. Bluestone Wind resource summary matrix.
Figure 4-15. Bluestone Wind project site plan.


Bluestone Wind is a 111 MW wind project in development and will The existing land use for the Project Area is primarily zoned
be entering the construction stage this year. Tree Clearing activities Residential (63%), Vacant (33%), and Agricultural (2%) land. The setting
commenced in January 2021 and full civil construction is anticipated is rural, and the site has primarily been used for agriculture.
to begin in May 2021, with an anticipated commercial operation date
in the fourth quarter of 2022. Bluestone Wind Received its Certificate Ownership or lease
of Environmental Compatibility and Public Need pursuant to Article Bluestone has secured through lease and easement all land required
10 of the Public Service Law (Case 16-F-0559) in December of 2019 to develop and operate the 111.8 MW wind project over the entire
which also included the transmission lines and associated facilities. contract tenor. More than 8,000 acres have been signed across 200
Bluestone filed and interconnection request with the NYISO in parcels.
September 2016. Its Queue position is 0579. Its system reliability
study is complete, and it participated in Class Year 2017 and accepted Generator lead line right of way
its cost allocation. Bluestone Wind has secured, through option or agreement, all lands
to host transmission infrastructure, including the interconnection
Technology and equipment switchyard, a collection system substation and overhead transmission
Bluestone Wind has permitted 27 onshore wind turbine locations. lines to the interconnection. The proposed injection point switchyard
It has selected 26 turbines as its final build all being a single model will be located on land to be owned by Bluestone Wind and
of Vestas V150-4.3 MW turbines. A 34.5/115 kV collector substation transferred to NYSEG following construction.
will be connected to a second substation adjacent to the point of
interconnection using 200 feet of overhead 115 kV transmission
line. The second substation will connect to NYSEG’s 115 kV system
between Afton - Stilesville 115kV via three-breaker ring bus
arrangement.
4.16. High Bridge Wind

High Bridge Wind N

Legend
Developer Northland Power Wind turbine
Location Chenango County, NY Site boundary
Capacity 103 MW
Status Late development stage

(expected COD: Q3
2023)

turbines [Vestas (V150-
4.3)]

forested, 21% residential
land, and 34% vacant
land

and easement, 5,000

Year 2017
Table 4-16. High Bridge Wind resource summary matrix.
Figure 4-16. High Bridge Wind project site plan.


High Bridge Wind is a 103 MW wind project in late development High Bridge Wind has secured, through option or agreement, all lands
stage. Tree clearing is expected to begin in Q1 2022 with full civil to develop the project and host transmission infrastructure, including
construction is anticipated to begin in Q2 2022, with an anticipated the interconnection switchyard, a collection system substation and
commercial operation date of Q3 2023. High Bridge Wind received its overhead transmission lines to the interconnection. Over 5,000
Certificate of Environmental Compatibility and Public Need pursuant acres have already been signed across approximately 45 parcels.
to Article 10 of the Public Service Law (Case 18-F-0262) in March The proposed injection point switchyard will be located on land to
of 2021 which also included the transmission lines and associated be owned by High Bridge Wind and transferred to NYSEG following
facilities. High Bridge filed and interconnection request with the construction.
NYISO in April 2018. Its Queue position is 0706. Its system reliability
study is complete and participated in Class Year 2017 and accepted its Generator lead line right of way
cost allocation. High Bridge Wind filed an interconnection request with NYISO for
100.8 MW in April 2018. Its queue position number is 0706. The
Technology and equipment System Impact Study and Facilities Studies are complete. High Bridge
High Bridge Wind has permitted 25 onshore wind turbine locations. Wind participated in Class Year 2017 and accepted its cost allocation
It has selected 24 turbines as its final build all being a single model of $10,726,500 to obtain ERIS and CRIS. This cost includes its direct
Vestas V150-4.3 MW turbines. A 34.5/115 kV collector substation interconnect facilities (Collector substation and transformer). No other
will be co-located with a 10 MW lithium-ion battery storage system. System Upgrade Facilities are required.
A point of interconnect substation will be constructed adjacent to
NYSEG’s existing Jennison to East Norwich 115 kV transmission line.

The existing land use for the Project Area is primarily zoned Vacant
(34%), Forested (26%), Residential (21%), and Agricultural (10%)
land. The setting is rural, and the site has primarily been used for
agriculture.
4.17. Bald Mountain Solar

Bald Mountain Solar Legend N

Developer Boralex Preliminary panel area
Location Washington County, NY Site boundary
Capacity 20 MW

(expected COD: Q4
2022)
Land use 100% active agricultural

fields
Land control Negotiating land

agreements, secured
249 acres across 9
parcels

0855 filed in May 2019
and have completed the
SRIS and the Facilities
Study
MSG Most portions of the

are classified within
MSG soil groups 1-4
Table 4-17. Bald Mountain Solar resource summary

matrix.
Figure 4-17. Bald Mountain Solar project site plan.


Bald Mountain Solar is a 20 MW solar project in the development Bald Mountain Solar has secured, through lease or option, all lands
stage. Construction is expected to commence in Q4 2022 with proposed to host all required solar facilities and construction areas to
a commercial operation date of Q4 2022. Bald Mountain filed an develop and operate a 20 MW solar project over the entire contract
interconnection request with NYISO in May 2019. Its queue position is tenor. Approximately 249 acres have been signed across 9 parcels.
number 0855. A system reliability study was completed in April 2020,
and the facilities study was completed in October 2020. Generator lead line right of way
Bald Mountain Solar has secured, through option agreements, all
Technology and equipment lands required to host transmission infrastructure. The Developer
Bald Mountain Solar is currently proposing to use bifacial solar panels has site control of the point of interconnection via a binding option
mounted on single-axis trackers. The connecting substation will be to lease. Land Rights have been secured for the project and point of
located directly adjacent to the injection point. Less than 200 feet of interconnection.
interconnection line will be constructed to connect the substation to
the existing transmission line. Mineral Soil Group (MSG) classification
Bald Mountain Solar is in Fulton County Agricultural District 1 and
Local zoning and existing land use portions of the Project are underlain by MSG Groups 1-4.
The parcels hosting the project are currently active agricultural fields.
The parcels surrounding the project are a mix of active agricultural
fields, mixed-use residential, and forested areas.
4.18. West River Solar

West River Solar Legend N
Site boundary
Location Saratoga County, NY
Capacity 20 MW

(expected COD: Q2
2024)


fields
Land control Negotiating land

agreements, secured 831
Interconnection No active Queue

position with NYISO.
Expected to be filed in
May 2021.
MSG Most portions of the

are classified within
MSG soil groups 1-4
Table 4-18. West River Solar resource summary matrix.
Figure 4-18. West River Solar project site plan.


West River Solar is a 20 MW solar farm in the early development West River Solar has secured, through lease or option, all lands
stages. Construction is expected to commence in the first quarter of proposed to host all required solar facilities and construction areas to
2023 with a commercial operation date within the second quarter of develop and operate a 20 MW solar project over the entire contract
2024. West River Solar expects to file an interconnection request with tenor. Approximately 831 acres have been signed across 9 parcels.
NYISO in May 2021. It does not currently have a queue assigned.
Generator lead line right of way
Technology and equipment West River Solar has secured, through option agreements, all lands
West River Solar is currently proposing to use bifacial solar required to host transmission infrastructure. The Developer has
panels mounted on single-axis trackers. West River Solar will be site control of the point of interconnection via a binding option to
interconnected to the NYISO controlled grid. The injection point and lease. Land Rights have been secured for the project and point of
point of interconnection have not yet been determined. interconnection.
Local zoning and existing land use Mineral Soil Group (MSG) classification
The parcels hosting the project are currently active agricultural fields West River Solar is in Fulton County Agricultural District 1 and portions
and tree nurseries. The parcels surrounding the Project are a mix of of the project are underlain by MSG Groups 1-4.
active agricultural fields, mixed-use residential, and forested areas.
4.19. Sandy Creek Solar

Sandy Creek Solar Legend N
Site boundary
Location Jefferson County, NY
Capacity 20 MW

(expected COD: Q4
2023)


fields

or option, 667 acres
across 7 parcels

0843 filed in May
2019 and is currently
undertaking the SRIS
MSG 0.26% of the preliminary

classification panel area is classified
within MSG soil group 1;
33% is classified within
MSG soil group 2; and
35% is classified within
MSG soil group 3
Table 4-19. Sandy Creek Solar resource summary

matrix.
Figure 4-19. Sandy Creek Solar project site plan.


Sandy Creek Solar is a 20 MW solar farm in the development stage. Sandy Creek Solar has secured, through lease or option, all lands
Construction is expected to commence within the fourth quarter of proposed to host all required solar facilities and construction areas to
2022 with a COD expected to be within the third quarter of 2023. develop and operate a 20 MW solar project over the entire contract
Sandy Creek filed an interconnection request with NYISO in May 2019. tenor. Approximately 667 acres have been signed across 7 parcels.
Its queue position is number 0843. A System Impact Study is currently
in progress for the project and is expected to be completed in April Generator lead line right of way
2021. Sandy Creek Solar has secured, through option agreements, all
lands required to host transmission infrastructure. The Developer
Technology and equipment has site control of the point of interconnection via a binding option
Sandy Creek Solar is currently proposing to use bifacial solar to lease. Land Rights have been secured for the project and point of
panels mounted on single-axis trackers. Sandy Creek Solar will interconnection.
be interconnected to the NYISO controlled grid. The connecting
substation will be located adjacent to the injection point. Less than Mineral Soil Group (MSG) classification
200 feet of interconnection line will be constructed to connect the Portions of the project are underlain by MSG Groups 1 (0.26%), 2
substation to the existing transmission line. (33%), and 3 (35%).

The parcels hosting the project are currently active agricultural fields.
The parcels surrounding the project are a mix of active agricultural
fields, mixed-use residential, and forested areas.
4.20. Greens Corners Solar

Greens Corners Solar Legend N
Site boundary
Location Jefferson County, NY
Capacity 120 MW

(expected COD: Q4
2023)

Land use 100% agricultural

residential land

across 26 parcels

SRIS and entered Class
Year 2021.
MSG The project area

classification overlaps with MSG
Groups 1-4. Boralex is in
process to complete the
feasibility assessment.
Table 4-20. Greens Corners Solar resource summary

matrix.
Figure 4-20. Greens Corners Solar project site plan.


Greens Corners Solar is a 120 MW solar farm in the development Greens Corners Solar has secured, through lease or option, all lands
stage. Construction is expected to commence within the fourth proposed to host all required solar facilities and construction areas to
quarter of 2022, with a proposed commercial operation date develop and operate a 120 MW solar project over the entire contract
within the fourth quarter of 2023. Greens Corners Solar filed an tenor. Approximately 2,373 acres have been signed across 26
interconnection request with NYISO in May 2019. Its queue position parcels. Please see land control summary table and documentation
number is 0864. Its system reliability study is complete, and it has demonstrating site control via binding option to lease.
entered Class Year 2021.
Technology and equipment Greens Corners Solar has secured, through option agreements, all
Greens Corners Solar is currently proposing to use bifacial solar lands required to host transmission infrastructure. The Developer
panels mounted on single-axis trackers. The project will connect to has site control of the point of interconnection via a binding option to
the existing National Grid 115kV transmission line Coffeen – West lease. Land Rights have been secured for the project.
Adams Line #2, which intersects the project area.
Local zoning and existing land use The project area overlaps with MSG Groups 1-4. Boralex is working
Greens Corners Solar is located in the Town of Hounsfield and the with an agronomist to complete a feasibility assessment of various
Town of Watertown, Jefferson County in a rural area used primarily for agricultural co-utilization practices being considered for the site. An
agricultural purposes and recreation. Within the Town of Hounsfield agricultural co-use plan will be submitted with the 94-c application.
the project is in the Agricultural and Residential, Industrial, and
Multi-Use zoning districts. Within the Town of Watertown the project
is in the R-1 Residential zoning district. Greens Corners Solar is a
permitted use within these zones in each Town. The project area
and surrounding land uses include a mix of industrial, agricultural
production, rural residential development, and sparsely forested
areas. The area is characterized by rolling topography, with gently
sloped areas transected by small streams and/or wetlands in the low-
lying areas between elevated landforms.
4.21. Sky High Solar

Sky High Solar Legend N

Location Onondaga County, NY Site boundary
Capacity 20 MW

(expected COD: Q1 2023)



or option, 655 acres
across 3 parcels

SRIS and the Facilities
Study
MSG <0.2% (<1.5 acres) of the

soil groups 1-4
Table 4-21. Sky High Solar resource summary matrix.
Figure 4-21. Sky High Solar project site plan.


Sky High Solar is a 20 MW solar farm in the development stage. Sky High Solar has secured, through lease or option, all lands
Construction is expected to commence within the second quarter of proposed to host all required solar facilities and construction areas
2021, with a proposed commercial operation date of within the first to develop and operate a 20 MW solar project over the entire
quarter of 2023. Sky High Solar filed an interconnection request with contract tenor. Approximately 655 acres have been signed across 3
NYISO in May 2016. Its queue position is number 0545. Its system parcels. Please see land control summary table and documentation
reliability study and facilities study are complete, and it has entered demonstrating site control via binding option to lease.
Class Year 2021.
Technology and equipment Sky High Solar has secured, through option agreements, all lands
Sky High Solar is currently proposing to use bifacial solar panels required to host transmission infrastructure. The Developer has site
mounted on single-axis trackers. The connecting substation will be control of the point of interconnection via a binding option to lease.
located directly adjacent to the injection point. Approximately 600 Land Rights have been secured for the project.
ft of interconnection line will be constructed to connect the project
substation to the existing transmission. Mineral Soil Group (MSG) classification
A review of the New York State Agriculture and Markets (NYSDAM)
Local zoning and existing land use database confirmed that the Study Area is not within a mapped
The project site consists of agricultural fields, hunting food plots, an Agricultural District. After a preliminary investigation, there is a small
overgrown tree farm, and forested areas. The Sky High facility site area (less than approximately 1.5 acres) at the southern project
is classified as approximately 49% agricultural land and 51% forested boundary that is underlain by MSG Groups 1-4. However, the specific
land. The project site is surrounded by agricultural fields, tree farm, location and extent of these soils, and the final project footprint, will
ponds, rural residential areas, and forested areas. be confirmed through additional evaluation.
4.22. Baron Winds Phase I

Baron Winds Phase I

Legend N
Developer RWE
Wind turbine
Location Steuben County, NY Site boundary
Capacity 121 MW
Status Late development stage

(expected COD: Q4
2022)

turbines [24 Vestas
(V150-4.2) and 8 SGRE
(SGRE114-2.625)]

20% residential land,
and 12% vacant land

across 307 parcels for
Phase I

2487; participated
in Class Year 2017
and accepted its cost
allocation
Table 4-22. Baron Winds Phase I resource summary

matrix.
Figure 4-22. Baron Winds Phase I project site plan.


Baron Winds Phase I is a 121 MW wind project in the late development The facility site and the surrounding area is primarily used for
stage. Construction is expected to commence within the third quarter agriculture (63%), residential (20%), and vacant (12%) lands. There is an
of 2021, with a proposed commercial operation date within the fourth existing wind farm to the east of the proposed Baron Winds Project.
quarter of 2022. Baron Winds received its Certificate of Environmental
Compatibility and Public Need pursuant to Article 10 of the Public Ownership or lease
Service Law in September 2019. It has a signed Interconnection Baron Winds Phase 1 has secured, through lease and option, all land
Agreement with NYSEG and NYISO as of February 2020, and which required to develop and operate the 121.8 MW project over the entire
was amended in February 2021. Its queue position is number 2487. It contact tenor. Over 6,800 acres have been signed across 307 parcels
participated in Class Year 2017 and accepted its cost allocation. for Phase I.
Technology and equipment Generator lead line right of way

Baron Winds Phase I is planning to construct 32 onshore wind turbine Baron Winds has secured, through lease and option, 100% of the
locations, consisting of 24 Vestas wind turbines (V150-120mHH- lands to host the transmission infrastructure. Baron Winds will design
4.2MW) and 8 SGRE safe harbor turbines (SGRE114-93mHH-2.625MW) and construct the facilities needed for the point of interconnection in
for a total capacity of 121 MW. The transmission facility consists the Canandaigua Substation, using a NYSEG-approved contractor,
of a new 700-foot underground 230 kV electric transmission line and then transfer those facilities to NYSEG per the project’s
connecting the project’s 34.5/230 kV collector substation to an Interconnection Agreement.
existing but expanded four-breaker ring bus Canandaigua Substation
owned and operated by NYSEG.
4.23. Heritage Wind

Heritage Wind
Legend N
Developer Apex
Wind turbine
Site boundary
Location Orleans County, NY
Capacity 198 MW

(expected COD: Q4
2023)
Technology Onshore wind turbines

[Vestas (V162-5.6),
Nordex (N149-4.8), and
GE (GE158-5.5)]

20% residential land,
and 3% vacant land
Land control Secured 10,760

acres across 130 land
agreements

0571; participated in
Class Year 2021 and
accepted its cost
allocation
Table 4-23. Heritage Wind resource summary matrix.
Figure 4-23. Heritage Wind project site plan.


Heritage Wind is a 198 MW wind project in the development stage Heritage Wind has secured, through lease, all land required to
with an anticipated commercial operation date of Q4 2023. Heritage develop and operate the 198 MW project over the entire contract
Wind is currently seeking a Section 94-c Siting Permit, which is tenor. More than 10,760 acres of land have been signed across 130
expected in January 2022, with 90-day appeal period to follow. land agreements.
Heritage received a draft permit in March 2021. Heritage Wind
expects the Federal Aviation Agency Determination of No Hazard Generator lead line right of way
(FAA-DNH) in Q2 2021. Heritage Wind filed an interconnection A 200.1 MW queue position has been filed for interconnection into
request with NYISO. Its queue position is number 0571. Heritage Wind Niagara Mohawk’s Lockport-Mortimer 115 kV Lines #113 and #114.
participated in Class Year 2021 and has accepted its cost allocation of Heritage Wind entered Class Year 2021 in March 2021. Generator
$3.7 Million. Interconnection Agreement (GIA) execution is expected in Q2 2023
with anticipated COD in Q4 2023. Congestion in this area is relatively
Technology and equipment low and is not impacted by other regional markets. An on-site parcel
Heritage Wind is currently being permitted as a 184.8 MW project and for the necessary substation has been acquired under a purchase
will be uprated to a 198 MW project at a later date. While a specific option and is directly adjacent to the point of interconnection.
turbine has not yet been selected for Heritage Wind, the following
models are being considered: Vestas 162-5.6, Nordex N149-4.8, and
GE 158-5.5.

The existing land use for the facility site and the surrounding area is
primarily zoned as Agricultural with smaller areas zoned residential
and vacant. Heritage Wind site is classified as approximately 77%
agricultural land and 20% residential land, with the remaining 3%
comprised of vacant land.
4.24. Prattsburgh Wind

Prattsburgh Wind
Legend N
Developer Terra-Gen
Wind turbine
Site boundary
Location Steuben County, NY
Capacity 147 MW

(expected COD: Q4
2023)

turbines with models
ranging from 2 to 6.8
MW
Land use 75% agricultural

land and 25% forest,
recreational, and other
land
Land control Secured 14,820 acres

across 109 parcels

0801; entered in Class
Year 2021
Table 4-24. Prattsburgh Wind resource summary matrix.
Figure 4-24. Prattsburgh Wind project site plan.


Prattsburgh Wind is a 147 MW wind project in the development stage, Prattsburgh Wind has secured approximately 90% of the land required
permitting and design, with an expected commercial operation date to develop and operate the 147 MW project over the entire contract
of Q4 2023. Prattsburgh Wind is seeking a Section 94-c permit. tenor. More than 14,820 acres of land have been signed across 109
Prattsburgh Wind filed an interconnection request with NYISO. Its parcels.
queue position is number 0801 and it has entered Class Year 2021.
Technology and equipment Prattsburgh Wind has full site control of the collector substation parcel
Prattsburgh Wind will permit approximately 40 wind turbine locations. and has optional parcels for an additional collector substation
It will use a mix of turbines ranging between 2 MW and 6.8 MW. if needed.
Prattsburgh Wind will interconnect into the Meyer – Avoca 230 kV
transmission line and will build a new point of interconnection.

The existing land use for the facility site and the surrounding areas is
primarily zoned agricultural and recreational. The Prattsburgh Wind
site is classified as approximately 75% agricultural land and 25%
forested, recreational and other land. The setting is rural and there are
wind farms close to the area.
4.25. Additional projects Boralex

Capacity Commercial
While not included in the proposed list of project Resources, Clean Partner Location (MW) Operation Date
Path New York has engaged in preliminary discussions with several Chalk Solar Fulton County, NY 20 December 2023
project developers regarding participation of additional Tier 4-eligible
projects. If awarded a Tier 4 REC contract, Clean Path New York Easton Solar Washington County, NY 30 December 2023
would work with these developers to secure the participation of these Fort Edward Washington County, NY 100 December 2024
projects to maximize the offered Resources and ensure a reliable and Solar Farm
resilient generation portfolio. These projects include those listed in
NY38B Solar Jefferson County, NY 45 December 2024
Tables 4-25 and 4-26 below.
NY48 Diamond Herkimer County, NY 60 December 2025
Solar Solar
NY115 Solar Oneida County, NY 130 December 2025
Northland Power
Capacity Commercial
Partner Location (MW) Operation Date NY125 A & B Franklin County, NY 375 December 2025
Solar
Alfred Oak Solar Allegany County, NY 100 December 2024
NY128 Solar Fulton County, NY 50 December 2025
Christmiller Livingston County, NY 20 December 2023
Table 4-26. Additional Boralex solar projects.
Cowens Corner Cattaraugus County, NY 20 December 2023
Solar
Pennsylvania Hill Steuben County, NY 100 December 2024
Hydroelectric
Boralex
Scotch Jefferson County, NY 100 December 2024
Boralex has independently submitted data regarding Supplier Energy
Settlement
and Supplier GHG baselines and received baseline determinations
Sunwine Solar Chautauqua County, NY 75 December 2024
back from NYSERDA. Any participation by these projects in Clean
Path New York will conform with these baseline determinations to
Vineyard Volts Chautauqua County, NY 20 December 2023 ensure the Tier 4 eligibility of any generation from these projects
Solar
(listed in Table 4-27 below).
West River Allegany County, NY 100 December 2024 Capacity
Partner Location (MW)
Table 4-25. Additional Northland Power solar projects.
Hudson Falls South Glens Falls, NY 44
Fourth Branch Waterford, NY 3
South Glens Falls South Glens Falls, NY 15
Middle Falls Middle Falls, NY 2
Table 4-27. Additional Boralex hydroelectric projects.

Section 5
Delivery plan
5 Delivery plan
5.1. Capability to deliver energy and Tier 4 high-voltage AC lines (HVAC) to a converter station adjacent and
connecting to the 345kV Fraser Substation in Zone E. There it will be
RECs to Zone J withdrawn from the high-voltage AC transmission system, transmitted
Clean Path New York will deliver energy and Tier 4 renewable energy across the HVDC line to a second converter station to be located in
credits to the New York Control Area (NYCA) Zone J via a new 1,300 the South Bronx and directly connected via high-voltage AC lines to
MW transmission line utilizing high-voltage direct current (HVDC) the 345kV Rainey Substation to inject the energy into NYCA Zone J.
technology, referred to in this proposal as "New Transmission"). Energy A detailed description of the proposed New Transmission line and the
from a portfolio of renewable resources located throughout Upstate proposed route is provided under Section 5.10, "Information regarding
New York will be delivered across the NYISO system via existing the New Transmission", below.
Clean Path New York will coordinate delivery of renewable Resources

from Upstate New York to Zone J through an independent entity.
This entity, Clean Path New York LLC (see the organizational charts
Converter station in Section 3 for more details on the structure), will own a significant
Fraser 345 kV DC portion of the generation assets and will contract with third-party
Withdrawal Point generation assets to ensure a cost-effective, robust, and reliable
AC
generation mix. In operation, Clean Path New York LLC will obtain
RECs from resources owned by third parties via index REC purchase
The Clean Path to NY contracts which settle at the zonal hub for each resource. These
contracts are consistent with existing Tier 1 index REC structures.
5.2. Firmness of delivery path, contract

Rock Tavern
arrangement, and transmission rights
Clean Path New York is offering more than 3,400 MW of exclusively
Figure 5-1. Clean Path New Converter station
York will deliver renewable New York renewable generation to support this proposal. Clean Path
DC New York LLC will:
energy from Fraser Substation Rainey 345 kV
to Rainey Substation located
in Zone J.
Withdrawal Point AC
• Directly own Tier 4-qualifying wind and solar generation assets
• Potentially contract with NYPA’s Blenheim-Gilboa pumped storage

facility
5.3. Hourly energy matching
The fundamental means by which Clean Path New York will verify
• Contract with third-party owned Tier 4-qualifying wind and solar
deliveries and effectuate contract settlement with NYSERDA will be
resources to procure those resources’ environmental attributes via
hourly matching of each Resource’s actual production metered at its
REC purchase agreement
Injection Point with deliveries over the New Transmission line metered
• Contract with an energy manager and/or energy service company to at its Delivery Point. If the production from Resources exceeds the
provide the following services: deliveries over the New Transmission line in a given hour, Clean Path
– Forecast day ahead and hourly load New York will determine which resources’ production will be matched
– Document hourly matching via metered flows to support monthly to the delivery to qualify for Tier 4. Excess RECs not matched for
reconciliation with NYSERDA via New York Generation Attribute Tier 4 delivery will be either sold to NYSERDA separately under the
Tracking System (NYGATS) for REC payments resource’s Tier 1 REC contract, if that resource holds such a contract,
otherwise energy will be sold on a merchant basis. For each monthly
Clean Path New York LLC will hold Transmission Services Agreements settlement period with NYSERDA, Clean Path New York will provide a
with NYPA and Clean Path New York Infrastructure LLC to provide table listing, for each hour of the month, the number of MWh delivered
for transmission of energy and RECs from Fraser Substation to to Zone J at the Delivery Point, the number of MWh injected by each
Rainey Substation and injection into Zone J. These contracts will resource at its Injection Point, and the number of MWhs matched from
be structured as capacity agreements, providing NYPA and Clean each resource to equal the delivered quantity. A simplified example is
Path New York Infrastructure LLC with the secure stream of revenue provided in Table 5-1 below.
required to construct and maintain the New Transmission line at a
guaranteed availability level.
New
Transmission Project 1 Project 1 Project 2 Project 2 Tier 4 Total
Day Hour Ending Line Delivery Injection (a) Match (b) Injection (c) Match (d) (b + d)
01 01:00 1300 MWh 600 MWh 600 MWh 550 MWh 550 MWh 1150 MWh
Table 5-1. An example table that will be provided for each monthly settlement period with NYSERDA.
This hourly matching procedure complies with the requirements of Similarly, the NYISO market has provisions for bilateral energy
the Tier 4 Order, Section 7.6.5 of the RFP, and Section 3.01 of the transactions. However, these transactions are also purely financial
standard form Tier 4 REC contract.1 Clean Path New York believes and are typically between generation and load. Bilateral energy
this is the most appropriate method to verify deliveries and effectuate transactions have been used to facilitate REC sales from NYISO to
contract settlement. While we have considered additional contractual ISO-NE, but this is because energy must be scheduled across the
arrangements and NYISO tariff mechanisms to provide additional RTO interface, and energy marketers charge generators a significant
evidence or firmness of delivery, we believe such structures would premium on the transaction. Such an arrangement should not be
add cost and/or complexity to the process without providing any real necessary to deliver RECs internally in the NYISO.
benefit to NYSERDA or the state.
To accommodate the complexities of operating the NYISO’s first
For example, the NYISO tariff contains a mechanism for firm point-to- intrastate HVDC transmission line while ensuring the most economic
point (PTP) transmission. While securing firm PTP mechanism might outcome for ratepayers across New York State, control of the Clean
superficially appear to provide greater certainty than energy from a Path New York New Transmission line will rest with the NYISO. The
given resource bring delivered to the Withdrawal Point of the New NYISO will adhere to security-constrained economic dispatch of the
Transmission line, firm PTP transmission rights are a purely financial New Transmission line. As outlined in Sections 5.4 and 5.7 in more
instrument. The NYISO market has no mechanism for physically detail, Clean Path New York is leading an effort at the NYISO Budget
scheduling energy. Furthermore, firm PTP transmission can only & Priorities Working Group for the NYISO to prioritize resources to
be purchased around the clock and would therefore not be useful develop and implement new market rules for operation of the New
during hours when intermittent resources are not generating, adding Transmission line that will ensure high utilization of the line with
significant cost without benefit. Clean Path New York notes based renewable assets.
on its own analysis that NYISO control of the new transmission will
by definition be best for rate payers in New York, this is based on Clean Path New York is proposing to leverage NYPA’s Blenheim-
integrating the New Transmission asset as a controllable transmission Gilboa pumped storage facility to provide storage of renewable
line into its economic dispatch to optimize generation and energy energy and RECs. Blenheim-Gilboa provides a unique opportunity
flows, the benefits of such integration is evident in the material to balance intermittent renewable generation to maximize utilization
reduction in transmission congestion and GHG remission. of the New Transmission, in alignment with NYSERDA’s goals to
increase market opportunities for storage to serve as a transmission
Such an approach will require Clean Path New York to cede asset while at the same time increasing the utilization and value to
operational control of the New Transmission line to the NYISO NYPA and the NYISO system of a very large existing storage asset.
resulting in a utilization risk of the New Transmission that cannot be It is important to note that Blenheim-Gilboa is already an important
mitigated by Clean Path New York and hence risk allocation resulting capacity and storage resource for NYISO, and any operation of
from the operational decisions of the NYISO need to be managed to the facility for that purpose will take first precedent. We note that
ensure success of the Tier-4 program as well as structure financeable NYISO recently updated its energy storage market rules, and this
projects to enable such success. proposal assumes that the implementation of those new rules does
1
Based on Clean Path New York’s understanding of the provisions outlined in Section 7.6.5 of the RFP, and Section 3.01 of the standard form Tier 4 REC contract, the Delivery Verification Plan does
not contemplate losses upstream of the Delivery Point and as such, any losses upstream of the Delivery Point have not been incorporated into this bid.
not unreasonably prohibit the ability of Blenheim Gilboa to operate Clean Path New York will actively work with NYPA to coordinate the
outside of NYISO-designated capacity events. Currently, Blenheim- scheduling of Blenheim-Gilboa in order to maximize the utilization
Gilboa’s capacity and storage related market obligations comprise of the New Transmission line with the Resources under Clean Path
a very small percentage of annual hours, leaving a significant New York control. NYPA will complete scheduling of dispatchable
opportunity for Clean Path to increase the utilization of the facility. resources, along with monitoring and settling of energy flows across
the New Transmission line as illustrated in Figure 5-2.
Figure 5-2. Scheduling of dispatchable resources.
+
Solar Wind
Yes >1300 MW? No
BG Pumped BG Pumped
Yes Storage Capacity No Storage Capacity
Available? Available?
Yes
B F
E
A B C
Charge to Inject to Discharge

Blenheim- Generator from Blenheim-
Gilboa Zone Gilboa
Day ahead Real time

Our approach to the day ahead scheduling will be as follows: During real time dispatch and performance, the following steps will be
considered:
1. Clean Path New York will receive expected hourly generation
schedules from the intermittent resources included in Clean Path 1. Clean Path New York will receive updated day-of generation
New York’s generation portfolio. schedules from the intermittent resources included in Clean Path
2. Clean Path New York will receive the hourly energy dispatch to New York’s generation portfolio, along with updated day-of New
Zone J on the New Transmission line as determined by NYISO. Transmission line scheduled energy dispatch to Zone J from the
NYISO.
3. Clean Path New York will reconcile expected intermittent
generation with New Transmission line energy dispatch to Zone J 2. Clean Path New York will reconcile expected intermittent
and Blenheim-Gilboa in the following manner: generation with New Transmission line availability and request that
NYPA modify dispatch commands to Blenheim-Gilboa consistent
– If, in any hour, the scheduled renewable generation is less than
with the methodology outlined above to account for any deviations
the projected New Transmission line energy dispatch to Zone J,
between day-ahead schedules and real-time performance.
Clean Path New York will request that NYPA schedule discharge
from the pumped storage facility in Blenheim-Gilboa, subject As illustrated in Figure 5-3 on the next page, this active energy
to available storage volumes and discharge capacity, up to the management approach, coupled with numerous resources and
availability of the New Transmission line. Maximum utilization of flexibility, would result in substantially increased utilization of the New
the New Transmission line will be the objective. Our proposed Transmission line that will ensure delivery of renewable resources to
portfolio of Resources provides sufficient energy availability to Zone J at the lowest cost.
maximize the utilization.
– If, in any hour, the scheduled renewable generation is more than
the projected New Transmission line energy dispatch to Zone
J, Clean Path New York will request that NYPA schedule charge
to the pumped storage facility in Blenheim-Gilboa, subject to
available storage volumes and charge capacity. If charging
to Blenheim-Gilboa is insufficient to utilize all of the excess
generation, any remaining generation from Resources would
“spill” onto each generation’s local zone. For resources holding
Tier 1 agreements with NYSERDA for the same generation asset,
the RECs associated with this excess generation would be
compensated under the terms of that agreement.
1400
1200
1000
800
600
400
200
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
-200
BG Charge BG Discharge Solar Wind Clean Path Transmission
Figure 5-3. Example of hourly energy dispatch and line utilization.
5.4. Risk mitigation of unavailability, Availability

Physical availability
curtailment, and underutilization of New The New Transmission has been designed to achieve very high
Transmission availability. Weather, including lighting, wind, falling trees, ice,
The project will deploy several layered tactics to mitigate the impact or extreme temperatures, is by far the leading cause of New
of any risks that would limit the potential of the New Transmission Transmission outages. Animals or vehicular accidents can also cause
line to deliver renewable energy to Zone J. Next we discuss the risk outages. Because the entire HVDC line will be underground, these
mitigation of unavailability, curtailment, and underutilization. outage risks are virtually eliminated. Additionally, HVDC converter
station technology is highly reliable and achieves very high operating
availability. Clean Path New York will secure availability guarantees
from the converter station suppliers to mitigate the risk of outages of
those systems.
Furthermore, the involvement of experienced transmission owners Generation mix

and operators from NYPA and Invenergy will help ensure the physical Clean Path New York has assembled an unparalleled portfolio of
availability of the New Transmission line. NYPA has used its deep more than 3,400 MW of exclusively New York renewable generation
design and operating expertise to develop the New Transmission line to support this proposal. Clean Path New York is confident this
with reliability in mind from the start. Each party has the experience portfolio represents the largest volume of in-state renewables of
to identify and plan for contingencies that could risk the continuity any project and highest utilization of any intrastate transmission line,
of reliable operations. Furthermore, performance guarantees related resulting in optimum project economics while also maximizing in-
to availability and losses embedded in the Transmission Services state economic benefits. The advantages of this large portfolio are
Agreement will ensure that incentives are aligned between NYPA, further amplified by leveraging the state’s largest storage resource,
Clean Path New York Infrastructure LLC, and Clean Path New York Blenheim-Gilboa, as described in detail in Section 9. Because wind
LLC to maximize the New Transmission line performance. has a much more diverse generating profile than solar, in addition to
a significantly higher net capacity factor, a large quantity of wind is
Economic availability essential to a cost effective and successful Tier 4 project. Selecting
At present, NYISO market rules do not contemplate the operation generation resources with sufficient capacity, zonally diversified,
of an HVDC transmission line that both sources from and sinks into with no more than 30% of capacity in any one zone. This will help to
the NYCA. Clean Path New York was the first participant among the reduce overall basis risk to Clean Path New York and will also provide
NYISO working group members to identify a gap in the NYISO's tariff resource diversity to the portfolio. This will naturally lead to a high
regarding the treatment of an intrastate HVDC transmission asset. utilization factor and lower delivered cost. Through its development
Clean Path New York led efforts to encourage the NYISO to develop process, Clean Path New York simulated thousands of different
the needed market rules by proposing to the Budget & Priorities generation portfolios to bracket the optimal mix and has assembled
Working Group on March 24, 2021 that the NYISO staff prioritize those a collection of resources that closely aligns with that solution set.
rules by the NYISO’s Budget & Priorities Working Group to prioritize Furthermore, Clean Path New York will secure, via acquisition or
the development of such market rules in calendar year 2022. Amongst contract, additional generation resources that can be called upon in
the rules to be developed, Clean Path New York is proposing that the the event of nonperformance by one or more selected generation
New Transmission line be dispatched into Zone J in a manner that resources. Additionally, Clean Path New York will prioritize selection
accounts for the value of Tier 4 RECs via a price signal that would of generation resources with executed Tier 1 REC agreements with
help ensure that the line is dispatched by the NYISO in harmony with aggregate capacity of 2,000 MW, as these projects will be able to
the goals of the Tier 4 program. This measure is in accordance and monetize the environmental attributes that cannot deliver directly
consistent with existing treatment of renewable resources and the to Zone J or storage assets, as well as Tier 1 contracted assets are
principles of economic dispatch while providing a level of certainty likely to have lower costs due to a lower risk of losing production
regarding energy flows across the line into Zone J. tax credit monetization. While the portfolio is expected to produce a
minimal amount of generation in excess of the project’s capacity, the
Utilization
preferential selection of Tier 1 assets will facilitate the participation of
Ensuring utilization of the New Transmission line is among the highest
generation resources and reduce the levelized cost of generation. A
priorities for the project. Tactics to increase line utilization include
summary of the Tier-1 contracted assets is provided in Table 5-2 on
these:
the next page.
Tier-1 Storage
Project Developer Capacity Technology contract The pumped storage facility at Blenheim-Gilboa will offer the project
a significant degree of flexibility with respect to dispatch of the New
Alle-Catt Wind Invenergy 340 MW Wind
✓ Transmission line. With a charge/discharge capacity of 1,160 MW
and a storage capacity of up to 12,000 MWh, Blenheim-Gilboa will
Horseshoe
Solar
Invenergy 180 MW Solar PV
✓ retain the value of intermittent, in-state renewables while improving
the utilization of the New Transmission line. More information about
Number Three
Wind
Invenergy 104 MW Wind
✓ Blenheim-Gilboa is provided in Section 9, Energy Storage Operation
Plan.
Ball Hill Wind Northland 107 MW Wind
✓
Curtailment
Bluestone
Wind
Northland 111.8 MW Wind
✓ In the event of curtailment of the New Transmission line, the facility at
Blenheim-Gilboa can provide long-duration storage of the intermittent
High Bridge
Wind
Northland 103.2 MW Wind
✓ resources that would otherwise be injected directly into New York
City. This flexibility offers the project another tool to reduce risks
Bald Mountain
Solar
Boralex 20 MW Solar PV
✓ which would otherwise limit its capacity.
West River
Solar
✓ 5.5. Assumptions related to unmitigated
Sandy Creek
Solar
✓ risk of unavailability, curtailment, and
Greens Boralex 120 MW Solar PV
✓ underutilization
Corners Solar
Our bid price includes operational risks considered and related to
Sky High Solar Boralex 20 MW Solar PV
✓ unavailability, curtailment, or underutilization of the New Transmission
line. In commercial operation, Clean Path New York will assume the
Baron Winds
Phase I
RWE 121.8 MW Wind
✓ risks outlined in Table 5-3 on the next page.
Heritage Wind Apex 198 MW Wind

✓ Additionally, Clean Path New York will be required to cede operational
control of the New Transmission line to the NYISO, which does not
Prattsburgh
Wind
Terra-Gen 147 MW Wind
✓ currently have market rules governing the operation of internal
controllable lines. This arrangement results in a risk that cannot be
Table 5-2. Tier-1 contracted assets. mitigated, is out of the control of Clean Path New York, and has not
been factored into the bid price. Clean Path New York may need
Energy management to discuss risk allocation with regards to New Transmission line
An active energy management strategy executed by a manned control unavailability resulting from the operational decisions of the NYISO.
center can correct for deviations from the planned dispatch in real Clean Path New York believes accepting this risk would make any
time and ensure that resources are effectively and efficiently utilized. intrastate (and perhaps even out of state) Tier 4 project unfinanceable.
Risk Description 5.6. Assumptions regarding compensation

Unavailability Inability of the New Transmission line to meet
(physical)
under Tier 1 for undeliverable RECs
its technical capacity due to outage or derating
resulting from physical factors associated with the Clean Path New York will prioritize the selection of generation resources
New Transmission line or either converter station with executed Tier 1 REC agreements as these projects will be able to
(e.g., outage due to preventative maintenance at a monetize the environmental attributes that cannot be delivered directly
converter station, New Transmission line outage due to New York City or storage assets (i.e., RECs associated with spilled
to damage) power). For Tier 1 resources, where RECs cannot be delivered to New
York City and cannot be used to charge Blenheim-Gilboa, the RECs
Curtailment Reduction of generation resource output as directed
associated with this excess generation would be compensated under
by the New York Independent System Operator
the terms of their existing Tier 1 agreements with NYSERDA.
(e.g., NYISO directs a wind farm operating at 200
MW to reduce output to 150 MW to maintain system
reliability) 5.7. Demonstrating delivery by providing
Under-
utilization
Inability of the generation Resources to meet the full
availability of the New Transmission line (e.g., the
capacity to Zone J and New Transmission
sum of all generation Resources is 743 MW and New UDRs
Transmission line availability is 1,300 MW) Clean Path New York does not believe it is possible for an intrastate
Table 5-3. Assumptions related to risk of unavailability, curtailment, and underutilization. HVDC project to commit to demonstrating delivery by providing capacity
into Zone J over New Transmission due to the lack of necessary market
rules and structures. Below we provide a description and background
Any reduction in the full technical availability of New Transmission on the existing regulatory structure followed by a discussion of the
capacity of the line to inject power into Zone J is wholly subject to need for market rules for controllable lines internal to NYCA.
the discretion of the NYISO and outside the control of Clean Path
New York. Clean Path New York is engaging NYISO stakeholders to Unforced Capacity Deliverability Rights (UDRs) are rights associated with
contemplate revision of the market rules for internal controllable lines a specific controllable and schedulable transmission facility (hereinafter, a
to remove the challenges such projects would otherwise confront. “controllable transmission facility or project”) with a terminus in a NYISO
If selected for award, Clean Path New York will continue to work Locality. External UDRs are associated with controllable transmission
with NYSERDA to develop an alternative structure through which to facilities connecting the NYCA to an External Control Area. Internal
address this risk. This proposed structure, which would be narrowly UDRs are associated with controllable transmission facilities connecting
defined to address the issue of New Transmission line unavailability a non-constrained region in the NYCA with a NYISO Locality.
resulting from the operational decisions of the NYISO outside of Clean
External UDRs allow capacity external to a NYISO Locality to be treated
Path New York's control, is outlined in detail in Appendix 5, Tier 4 REC
as if it were physically located in that NYISO Locality, thereby facilitating
Standard Form Purchase and Sale Agreement memorandum.
the delivery of capacity into that NYISO Locality. Indeed, several currently
operating controllable transmission projects, including the Cross Sound
Cable and Linden VFT transmission projects, have been awarded external
UDRs that enable the delivery of capacity physically located outside of Service (CRIS) rights. However, the absence of NYISO market rules
the NYCA over their transmission facilities into a NYISO Locality. governing treatment of an intra-NYCA controllable transmission facility
leaves open the question of whether or not such a transmission facility
However, while the construct of internal UDRs exists within the NYISO could secure local UDRs. Without UDRs, such a transmission facility
open access transmission tariff (OATT), the NYISO market rules that are would be ineligible for CRIS rights, which are awarded through a Class
necessary for the implementation of these internal UDRs do not exist. Year Deliverability Study.
Moreover, the NYISO market rules necessary to contemplate operation
of an intra-NYCA controllable transmission facility do not currently exist. At present, the interconnection request for Clean Path New
York is based on pursuing Attachment P for NYISO OATT. The
Clean Path New York is taking a leadership role with the NYISO interconnection process under Attachment P is nominally followed for
to enhance the market rules that will enable accommodating the all intra-NYCA transmission projects subject to the operational control
complexities of operating the NYISO’s first intrastate HVDC transmission of the NYISO. It does not contemplate project participation in a Class
line while ensuring the most economic outcome for ratepayers across Year Deliverability Study, the request for UDRs, or the award of CRIS
New York State. This mainly entails that the control of the project’s rights.
New Transmission will rest with the NYISO. Clean Path New York has
initiated conversations with the Interconnection, Market Design, and Following the development and implementation of NYISO new market
Market Operations teams at the NYISO to discuss the path forward for rules governing intra-NYCA controllable transmission facilities, and
development and implementation of new market rules associated with prior to execution of an interconnection agreement, Clean Path New
intra-NYCA controllable transmission facilities. Clean Path New York is York could elect to withdraw from Attachment P and proceed under
also leading an effort currently before the NYISO Budget & Priorities Attachment X to the NYISO OATT in order to request CRIS . The
Working Group for the NYISO to prioritize resources to develop and interconnection process under Attachment X contemplates project
implement new market rules for operation of the New Transmission participation in a Class Year Deliverability Study and award of CRIS
line that will ensure high utilization of the line with renewable assets. rights. This, together with new market rules, could allow Clean Path
New York to request UDRs and offer UCAP.
These rules are necessary not only for Clean Path New York, but for
any intra-NYCA controllable transmission facility, including any other
intra-NYCA New Transmission facilities being offered in response to 5.8. Explanation of production profile and
NYSERDA’s Tier 4 RFP solicitation. These intra-NYCA controllable delivery match profile
transmission facilities will be vital to unlocking the potential of upstate
renewable generation resources to serve downstate loads, which is See Section 5.3, “Hourly energy matching”, above for more details.
why Clean Path New York has taken the lead in working with NYISO to
develop a framework for its operation. 5.9. For dispatchable resources, factors
Certainty about the market treatment of an intra-NYCA controllable that will determine the dispatch and
transmission facility will influence the New Transmission
interconnection approach under the NYISO OATT taken by Clean
delivery of energy to Zone J
Path New York. In order to achieve Unforced Capacity (UCAP), and See Section 5.3, “Hourly energy matching”, above for more details.
thus offer capacity deliverable in Zone J, any controllable transmission Our proposal currently assumes no UDRs given the market rules. If
line must secure both UDRs and Capacity Resource Interconnection circumstances change, Clean Path New York will share the net benefit
with NYSERDA through as an offset against the RECs.
5.10. Information regarding the New

Transmission
New Transmission overview
The New Transmission system spans approximately 175 miles. It
connects Fraser Substation in Delaware County, Zone E as the
withdrawal point to Rainey Substation, Queens County in Zone J as
the delivery point. The route runs overland within existing rights-of-
way and public streets and underwater within the Hudson River and
Harlem River. Table 5-4 provides a summary of the New Transmission.
Fraser Substation to Rainey Substation

Facility name Clean Path New York
Entity responsible Clean Path New York Infrastructure LLC
Withdrawal point 345kV Fraser Substation in Zone E
Delivery point 345kV Rainey Substation in Zone J
Development stage Development ready
MW capability 1,300 MW
Commercial June 30, 2026
Operation Date
Table 5-4. Details of the New Transmission. Figure 5-4. Proposed route overview map.
New Transmission technology The HVDC link will be configured as a symmetrical monopole. In this
The New Transmission line will utilize state-of-the-art technology configuration a single transformer secondary feeds a single pole, the
based on an HVDC voltage source converter (VSC) with the capability center of the DC bus of each converter station is usually grounded,
of delivering a capacity of 1,300 MW. A +/- 400 kV operating voltage and the converter stations are connected to two transmission links
was selected as the optimal voltage to maximize capacity. See Section at equal and opposite potentials: the positive pole and the negative
14 for more details with regards to the added flexibility using an pole. A schematic of the New Transmission line is shown in Figure 5-5
HVDC line. on the next page.
Converter
transformer
+ + 400 kV pole DC underground cable + Converter
transformer
Zone E Zone J
DC AC
Fraser 345 kV Rainey 345 kV
substation substation
AC DC
1,300 MW - 400 kV pole DC underground cable 1,300 MW

sending receiving
end converter end converter
Figure 5-5. Transmission line schematic. station station
The proposed technology deploys insulated gate bipolar transistors based on an extensive and thorough iterative process that involved
to switch the DC voltage. This commutates the DC voltage to the assessing publicly available GIS data, USGS topographic information,
expected AC voltage of the grid to which it is delivering power. The land use information, geologic data, property tax map parcel
transistors operate based on information provided by the control information, existing utility/infrastructure data, and other pertinent
systems, increasing the control of real and reactive power with data. This process included hosting numerous workshops and
reactive compensation capabilities. consultations with internal and external project stakeholders to solicit
feedback and refine the primary proposed route.
The project will include two VSC HVDC stations located at each end
of the transmission link: Fraser in Zone E and the Bronx in Zone J. At Alternatives/back-up routes were also identified during this process
the withdrawal point, the New Transmission line will use the NYSEG to proactively plan for challenges that could be encountered along
Fraser 345 kV yard by installing a new breaker in a spare bay position the primary route for several high-risk areas. Clean Path New York will
in the existing breaker-and-a-half substation. At the delivery point, it continue this process as additional data is gathered during future field
is planned to connect to the CECONY Rainey Substation by installing investigations and detailed engineering. The proposed route, assessment
two new breakers and expanding the existing ring bus to meet the process, and primary alternatives are further described below.
CECONY operations procedures and reliability standards.
Clean Path New York’s proposed New Transmission route originates at
The symmetrical monopole link will include a buried section of two 2,500 the existing Fraser Substation in Delaware County, NY and continues
mm2 underground cross-linked polyethylene (XLPE) HVDC cables. A south within the existing New York Power Authority (NYPA) right-
fiber optic communication link will connect both converter stations, of-way (ROW) for approximately 105 miles underground. This ROW
with submarine portions of single-core 2500 mm2 armored copper segment offers a competitive, cost effective, and low risk approach
XLPE cable in the Hudson, Harlem, and East Rivers, to Zone J. XLPE to create the energy highway needed to deliver the Tier-4 RECs into
cabling provides better performance at high and low temperatures. New York City. At the end of the NYPA ROW, the proposed route
will enter public roads in Orange County, after which the route will
Our proposed route transition into the Hudson River through the Harlem River to connect
A key strategy for defining our proposed primary route was to utilize to the receiving-end converter station in the Bronx. High-voltage AC
existing public ROW and utility corridors to minimize community cables will then be routed through public street ROWs and East River
impacts and disruptions and to also streamline the permitting and to connect from Zone J converter station to the Rainey Substation.
regulatory process. Additionally, our proposed route was selected
A map book for the proposed route is attached as Appendix 6 to the Below are the key criteria and guiding principles that were used to
proposal. develop the proposed route.
The proposed route is composed of the following major construction Utilizing existing utility corridors/right-of-way
components: A key consideration for developing a proposed route was utilizing
existing utility corridors/ROW. Benefits of siting the proposed routes
• Underground segments with focus on the following sub-segments:
within existing utility corridors/ROW include the following:
– Existing transmission ROW
– Public road ROW in Orange County • Reduced/eliminated ROW acquisition costs for permanent
– Public road ROW in Westchester County easements.
– Public road ROW in the Bronx • Reduced impacts to previously disturbed land and potential utility
interference conflicts.
– Public road ROW in Queens
• Minimization of landowner negotiations for private properties.
• Submarine segments with focus on the following sub-segments:
• Preferred siting by regulatory agencies, resulting in improved
– Hudson River
permitting certainty.
– Harlem River
• Improved constructability and production rates: Using existing utility
– East River corridors and public ROWs should limit environmental and other
• Total number of onshore horizontal directional drills (HDDs) impacts.
• Total number of landfall approaches • Reduced restoration costs: Existing utility
DYED PRECAST MARKERS
• Steep slope and bedrock along the route WITH MAGNET TAPE corridors are typically vegetated areas with
limited hardscape/pavement, resulting in
reduced restoration costs compared to
road installations.
All the underground cable will consist of

duct bank with two eight-inch conduits for
EXCAVATION PAY
LIMIT ENVELOPE
the 400 kV DC cables and one four-inch
conduit for the fiber optic cable, as shown
conceptually in Figure 5-6. Segments that
are in the public ROW will have concrete-
4" HDPE CONDUIT encased duct banks while segments within
FIBER OPTIC CABLE
the NYPA Marcy South transmission line
ROW will have sand-encased duct banks.
8" HDPE CONDUIT This approach will help secure the DC cables
SAND BEDDING 400KV DC CABLE while meeting the permitting requirements.
Figure 5-6.
Preliminary duct 8" HDPE CONDUIT
bank vault details. 400KV DC CABLE
Minimizing public/project stakeholder impacts

A key component of the route selection is minimizing impacts to the
public and project stakeholders, including businesses, public emergency
services, public transportation, recreational areas, and utilities. The density
of the population/development along the project route corridor varies
from rural to highly developed/urban areas. Clean Path New York has also
conducted meetings with agencies such as NYISO, NYSDOT, NYSDEC,
OGS, and USFWS which were key to understanding key requirements,
schedule drivers and the impact of key permitting requirements in
developing a realistic and achievable target commercial operation
date. Outcomes from conversations with the agencies were weaved
Figure 5-7. Impacts to the environment, such as the endangered shortnose sturgeon found in
into the development and have informed key development decisions. the Hudson River, will be considered and minimized.
Minimizing street work

Street work should be avoided to reduce impacts on pedestrian At this conceptual stage of the design, not all field conditions are
and vehicle traffic and to enhance safety during construction to the known. It is inevitable that site constraints and issues will be identified
extent feasible. Other benefits of avoiding street work include faster as field surveys are completed during the detailed design. By routing
production rates, wider construction corridors, and lower project in wider ROW corridors, constraints not currently known may be
costs. Avoiding existing utilities and minimizing street work are related mitigated during detailed design with minor modifications to the route
concepts. Township and county roadways typically contain gas, sewer, alignment and/or construction workspace. If the space is not available,
water, stormwater, telecommunications, and electric utilities. the minor modifications become more challenging to implement.
Minimizing environmental/cultural/endangered species impacts Trenchless and HDD consideration

A key consideration in routing is minimizing impacts to wetlands, Trenchless crossings are required across the route. These were
waterbodies, cultural/historical areas, endangered species, and other evaluated to minimize impact while addressing site-specific risks. Our
environmental resources. Avoiding these areas will improve the review identified the high-risk trenchless crossings to support the
overall project, including lower construction costs and mitigation fees, selection of the proposed route.
improved constructability, improved public perception, and potentially Submarine routing evaluation
improved permit certainty and timelines. Similar projects were The proposed route includes submarine routing through sections of the
required to adjust their proposed route alignment due to the presence Hudson, Harlem, and East Rivers. At the time of submitting this proposal,
of shortnose sturgeon within the Hudson River. Avoiding the breeding the proposed route for these in-water sections was developed through
area of this endangered species was an important consideration for a desktop-level mapping assessment using publicly available data such
determining the proposed route. as National Oceanic and Atmospheric Administration (NOAA) navigation
Maximizing space charts, New York State Department of Environmental Conservation
Maximizing space is accomplished by locating the route within (NYSDEC) Hudson River estuary data and maps, historical aerials, and
wider ROW corridors. Wide corridors are typically needed to allow US Army Corps of Engineers historical bathymetry surveys. Additionally,
for adequate construction workspace and access to the site for we have met with a variety of state and local agencies for initial routing
installation of the project. feedback and have adjusted the route as a result of those conversations.
or barges and support equipment will likely be utilized in segments

Legend
with physical constraints such as shallow water less than 30 feet deep
Proposed route
at Mean Lower Low Water and narrow and/or low bridges.
Detailed in-situ data collection efforts, including geophysical and

bathymetric surveys, are planned along the proposed route to
support route refinement efforts. These surveys will further identify
riverbed conditions, strata, and uncharted obstructions. This new
data will also be used to inform additional studies such as a riverbed
mobility assessment, navigation hazard assessment, and a Cable
Burial Risk Assessment, which will refine the proposed alignment. The
Cable Burial Risk Assessment will involve a detailed analysis of the
anthropogenic and natural conditions along the proposed alignment
and will be used to quantify risks and aid in the selection of the
proposed cable burial depths within each waterway.
Subsea landfall evaluation

The upland, shoreline, and nearshore physical conditions of the
Figure 5-8. NOAA proposed landfalls between each section of in-water routing were
navigation chart.
based on publicly available information such as historical aerials and
The mapping assessment evaluated physical conditions such as water NOAA navigation charts.
depths, riverbed slopes, substrate data (where available), NOAA-
Within each landfall region, multiple sites were evaluated for both
charted obstructions, navigation aids and channels, existing cables
trenchless and trenched construction methods. Each site was
and pipelines, anchorage areas, and relic structures. Where possible,
assessed against criteria that evaluated physical conditions such as
given the available data reviewed, the proposed alignment avoids
available upland workspace, proximity to residential areas, access for
areas of high risk and challenging physical conditions.
construction equipment, presence and type of shoreline stabilization
The cable is proposed to be installed within a trench below the structures, interference with vessel navigation, nearshore obstructions,
riverbed, using burial tools such as a cable plow, self-propelled and distance to deep water. Impacts to the overall cable alignment
trencher, or similar. Additional cable protection such as marine length and upland routing requirements were also considered.
mattresses or riprap armor may be required where a sufficient burial
The alternative landfall sites were narrowed down to locations that
depth is not achievable (i.e., in areas with bedrock) and/or where the
are anticipated to simplify construction and reduce overall project
cable must cross existing buried utility lines (cables and pipelines).
risk as best as possible at this level of assessment. Additional data
Typical cable-laying vessels and equipment can likely be utilized in the collection efforts and coordination with agencies and landowners will
deeper sections of the rivers, which are usually greater than 30 feet be conducted for each proposed landfall site, to aid in refining the
deep at Mean Lower Low Water. Specialty shallow-draft vessels and/ landfall alignments.
REDACTED - COMMERCIALLY SENSITIVE INFORMATION






ROW acquisition status and site control Status of transmission service agreement, operating
The proposed ROW for the New Transmission requires minimal to no agreement between Clean Path New York LLC, and
acquisitions. As explained above, the proposed route will largely utilize Clean Path New York Infrastructure LLC
existing NYPA transmission Marcy South ROW between the withdrawal Clean Path New York LLC will execute a Transmission Services
point at Fraser and Rock Tavern. From Rock Tavern to the Bronx, where Agreement with NYPA and Clean Path New York Infrastructure LLC to
the converter station will be located, and into Rainey Substation, the define the commercial terms and conditions under which Clean Path
path will utilize public ROW including existing utility corridors. New York will utilize the New Transmission line and compensate
the transmission owners. These agreements will include standard
Clean Path New York have secured 40 acres through an option commercial terms, as well as standards of performance regarding
agreement between NYPA and the Linda S. Brodeur Revocable Trust availability and efficiency to ensure full utilization of the New
to develop and operate the northern converter station located in at Transmission line.
the withdrawal point near Fraser, a copy of the Option Agreement for
Purchase of Real Property is provided under Appendix 26. The option Scheduling coordinator entity and operating
is for an adjacent lot near the 345 kV Fraser substation. A copy of the agreement terms
agreement can be made available at NYSERDA’s request. Clean Path As noted above, any intra-NYCA controllable transmission facility
New York has site control for the Zone J converter station location in must be operated by the NYISO in order to ensure system reliability
the Bronx on Exterior Street, evidence of site control can be provided and economic dispatch. While Clean Path New York is advocating
upon request. the adoption of market rules that could change this arrangement, at
For the Zone J converter station, Clean Path New York has adopted present operational control would remain with the NYISO. However,
an innovative design for land-based HVDC compact design converter as outlined above, Clean Path New York LLC will contract for
station that leverages emerging technology currently used in offshore energy management services necessary to coordinate scheduling
wind applications like the BorWin2 project in Germany. This approach of dispatchable resources, along with monitoring and settling of
consolidates all station components into a modular compact and multi- energy flows across the New Transmission line to ensure consistent
level footprint that will fit well within the one-acre site secured by Clean utilization. This contract would be negotiated as a simple fee-for-
Path New York in the Bronx. Discussions with an HVDC converter service arrangement with an energy management provider such as
OEM have confirmed that such configuration is commercially available Invenergy Services or another energy provider.
and technical viable. This configuration optimizes the use of space
and efficiently addresses the challenge of building in dense urban NYISO market participant entity for Resources
settings. Similar to its alternative routing analyses, Clean Path New York Clean Path New York LLC or a subsidiary will be the NYISO market
is currently in active negotiations with representatives for alternate participant with respect to the project Resources. Clean Path New
converter sites that offer the potential to reduce installed cost and drive York LLC will utilize an Index REC structure comparable to the one
further project optimization. devised by NYSERDA for the contracts signed with project Resources,
which offers generators better price certainty and lower energy costs.
The generator contracts will be settled at each resource's zonal hub,
leaving generators as the market participants to clear energy capacity
payments and Clean Path New York to pay the net REC cost to
generators to secure the environmental attributes.
Capacity utilization plan 5.11. Rights to capability of the New

As explained above, the operational control exercised by NYISO
will adhere to a security-constrained, economic dispatch of the New Transmission
Transmission line consistent with standard practice. While the sum As the NYISO will exercise operational control of the line, Clean Path
of the Resources may at times be less than the capacity of the New New York will not have exclusive rights to the capability of the New
Transmission line, it is highly likely that the NYISO will utilize the Transmission line. Clean Path New York will coordinate the utilization
full capacity of the line to reduce congestion costs across the bulk and allocation. Additionally, Clean Path New York is currently
transmission system. In fact, PowerGEM has estimated that in 2030, engaging NYISO stakeholders to contemplate revision of the market
the project will reduce congestion costs by $5.6 billion for ratepayers rules.
in New York. A PowerGEM detailed report is provided under
Appendix 7.
5.12. Conditionality of acceptance of other
proposal(s)
$5.6 billion The proposal is not conditional upon acceptance by NYSERDA of
other proposal(s) proposing to utilize the same New Transmission.
reduction in congestion costs for
ratepayers in New York
New Transmission capacity allocation among

Resources and managing Resources excess capacity
When the energy manager reconciles the energy flows across the
New Transmission line, priority of allocation will follow ascending
generator strike price, comparable to a nominal generation stack.
The lowest-cost generator, in any hour, will receive an allocation up
to its generation capacity in that hour, followed by the next highest
cost generator. The energy manager will follow this approach
whether the energy production from the Resources exceeds or falls
short of the New Transmission in any hour. In the event that energy
production exceeds the capacity of the New Transmission line, the
energy manager will direct charging to the pumped storage facility at
Blenheim-Gilboa, subject to storage availability and pumping capacity.
See Section 5.3, "Hourly energy matching", above for more details on
managing the excess capacity.
Section 6
Baseline verification
plan
6 Baseline verification plan
No hydroelectric power is being offered; therefore, this section is not applicable.

Section 7
Interconnection plan
7 Interconnection plan
7.1. Resource interconnection application Alle-Catt Wind

Alle-Catt Wind filed an interconnection request with NYISO
status, queue position and information in January 2017. Its queue position is number 0596. Its
regarding interconnection request, studies System Reliability Impact Study and Facilities Study are
complete. Alle-Catt participated in Class Year 2019 and
340 MW
undertaken and estimates of system accepted its cost allocation of $60,946,010 to obtain ERIS
upgrade costs and CRIS. This cost includes its direct interconnect facilities (the Lime
Lake Switchyard) and associated remote end upgrades, as well as a
The resources included in the Clean Path New York portfolio provided phase angle regulator at the 230 kV Hillside Substation to maintain
in this proposal have all filed interconnection requests with NYISO, with transfer capability between PJM and NYISO. The upgrade cost
the exception of one 20 MW resource that will file its request soon. estimate for Alle-Catt Wind is provided in the 2019 Class Year study.
Alle-Catt's Facilities Study contains detailed cost estimates and CEII
For each resource in the portfolio, the subsections below provide material. It can be provided to NYSERDA if requested, and with proper
information related to the NYISO interconnection application for its confidentiality provisions in place as required by NYISO.
injection point, including queue position, studies undertaken, and
cost estimate for system upgrades where applicable. Horseshoe Solar
Horseshoe Solar filed an interconnection request with
NYISO in May 2018. Its queue position is number 0710. Its
Under Appendix 8 we have included the Class Year 2017 Facilities System Reliability Impact Study is complete. Horseshoe
Study and under Appendix 9 the Class Year 2019 Facilities Study, 180 MW Solar has entered Class Year 2021 to obtain ERIS and CRIS.
which includes cost estimates for the resources that participated in the Horseshoe Solar's System Reliability Impact Study includes
2017 and 2019 class years. Other resources participating in the 2021 a good-faith cost estimate for its interconnection of $6,350,000,
class year have good-faith cost estimates derived from their System but also contains CEII material. It can be provided to NYSERDA if
Reliability Impact Studies. requested, and with proper confidentiality provisions in place as
required by NYISO.
Supporting information and completed NYISO and interconnection
studies for the below resources are classified as critical energy/electric
infrastructure information and are not included in this bid. Those are
available for NYSERDA upon request.
Number Three Wind Verona Solar

Number Three Wind filed an interconnection request with Verona Solar filed two interconnection requests with
NYISO in January 2016. Its queue position is number 0531. NYISO in June 2019. Its queue position numbers are 0871
Its System Reliability Impact Study and Facilities Study are and 0873. Its feasibility studies are complete, and the
104 MW complete. Number Three Wind participated in Class Year 350 MW System Reliability Impact Studies for both positions are
2019 and accepted its cost allocation of $19,951,600 to obtain underway and are expected to be complete in Q3 2021.
ERIS and CRIS. This cost includes its direct interconnect facilities (the Verona expects to enter Class Year 2022 to obtain ERIS and CRIS.
Waters Road Station) and associated remote end upgrades. No other Verona Solar's feasibility studies for queue positions 0871 and 0873
system upgrade facilities are required. The upgrade cost estimate for are attached under Appendix 10, which includes a preliminary cost
Number Three Wind is provided in the 2019 Class Year study. Number estimate of $23,000,000 for its interconnection facility upgrades.
Three Wind facilities study contains detailed cost estimates but also CEII Note that the cost estimates are for the same interconnection facility
material. It can be provided to NYSERDA if requested, and with proper and are not additive. Only one POI switchyard would be built for the
confidentiality provisions in place as required by NYISO. two queue positions.
Canisteo Wind Twinleaf Solar

Canisteo Wind filed an interconnection request with NYISO Twinleaf Solar filed an interconnection request with NYISO
in October 2015. Its queue position is number 0519. Its in March 2021. Its queue position is number 1141. Because
System Reliability Impact Study and Facilities Study are it has sufficient site control, Twinleaf Solar has elected
290 MW complete. Canisteo Wind participated in Class Year 2019 and 75 MW to skip the feasibility study and move directly into the
accepted its cost allocation of $1,730,109 to obtain ERIS and System Reliability Impact Study. The scoping meeting has
CRIS. This cost includes its direct interconnect facilities (the Bennett been held and the study is expected to commence shortly. Twinleaf
Station) and elective System Upgrade Facilities. The upgrade cost expects to enter Class Year 2022 to obtain ERIS and CRIS. Based on
estimate for Canisteo Wind is provided in the 2019 Class Year study. cost estimates for similar facilities, Twinleaf Solar estimates that its
Canisteo Wind facilities study contains detailed cost estimates but also interconnection upgrades will cost approximately $12,000,000.
CEII material. It can be provided to NYSERDA if requested, and with
proper confidentiality provisions in place as required by NYISO. Taproot Solar
Taproot Solar filed an interconnection request with NYISO
Bull Run Wind in March 2021. Its queue position is number 1140. Because
Bull Run Wind filed two interconnection requests with it has sufficient site control, Taproot Solar has elected to
NYISO: one in April 2015 for up to 303.6 MW under queue 205 MW skip the feasibility study and move directly into the System
position 0497 and the other in December 2015 for an Reliability Impact Study. The scoping meeting has been
449 MW additional 145.4 MW under queue position 0521, totaling a held and the study is expected to commence shortly. Taproot Solar
combined 449 MW. The System Reliability Impact Studies for plans to enter Class Year 2022 to obtain ERIS and CRIS. Based on
both queue positions are complete. Bull Run Wind has entered queue cost estimates for similar facilities, Taproot Solar estimates that its
position 0521 into Class Year 2021 to obtain ERIS and CRIS. Bull Run interconnection upgrades will cost approximately $23,000,000.
Wind system reliability impact studies include a good-faith cost estimate
for its interconnection of $9,643,000, but also contains CEII material.
Wintergreen Solar Bull Run Solar

Wintergreen Solar filed an interconnection request with Bull Run Solar filed an interconnection request with NYISO
NYISO in February 2021. Its queue position is number 1138. in January 2018. Its queue position is number 0686. Its
The scoping meeting has been held and the feasibility System Reliability Impact Study is complete. Bull Run Solar
75 MW
study is expected to commence shortly. Wintergreen 170 MW
plans to enter Class Year 2022 to obtain ERIS and CRIS.
Solar plans to enter Class Year 2023 to obtain ERIS and Bull Run Solar's system reliability impact studies include a
CRIS. Based on cost estimates for similar facilities, Wintergreen Solar good-faith cost estimate for its interconnection of $5,000,000.
estimates that its interconnection upgrades will cost approximately
$6,000,000. Ball Hill Wind
Ball Hill Wind filed an interconnection request with NYISO in
Orangeville Solar June 2015. Its queue position number is 0505. The System
Orangeville Solar filed an interconnection request with Reliability Impact Study and Facilities Study are complete.
NYISO in February 2021. Its queue position is number 1137. 107 MW Ball Hill Wind participated in Class Year 2017 and accepted
The scoping meeting has been held and the feasibility its cost allocation of $15,975,700 to obtain ERIS and CRIS.
75 MW study is expected to commence shortly. Orangeville This cost includes its direct interconnect facilities (collector substation
expects to enter Class Year 2023 to obtain ERIS and and transformer). No other system upgrade facilities are required.
CRIS. Based on cost estimates for similar facilities, Orangeville Solar
estimates that its interconnection upgrades will cost approximately Bluestone Wind
$2,000,000. Bluestone Wind filed an interconnection request with NYISO
for 124.5 MW in September 2016. Its queue position number
Seventy Seven Solar is 0579. The System Reliability Impact Study and Facilities
Seventy Seven Solar filed an interconnection request with 111 MW Study are complete. Bluestone Wind participated in Class
NYISO in February 2021. Its queue position is number 1139. Year 2017 and accepted its cost allocation of $12,524,882
Because it has sufficient site control, Seventy Seven has to obtain ERIS and CRIS. This cost includes its direct interconnect
100 MW elected to skip the feasibility study and move directly into facilities (collector substation and transformer). No other system
the System Reliability Impact Study. The scoping meeting upgrade facilities are required.
has been held and the study is expected to commence shortly.
Seventy Seven Solar expects to enter Class Year 2022 to obtain High Bridge Wind
ERIS and CRIS. Based on cost estimates for similar facilities, Seventy High Bridge Wind filed an interconnection request with
Seven Solar estimates that its interconnection upgrades will cost NYISO for 100.8 MW in April 2018. Its queue position number
approximately $2,000,000. is 0706. The System Reliability Impact Study and Facilities
103 MW Study are complete. High Bridge Wind participated in Class
Year 2017 and accepted its cost allocation of $10,726,500
to obtain ERIS and CRIS. This cost includes its direct interconnect
facilities (collector substation and transformer). No other system
upgrade facilities are required.
Bald Mountain Solar West River Solar

Bald Mountain Solar filed an interconnection request
with NYISO for 20 MW in May 2019. Its queue position Interconnection request Expected to be submitted in May
2021
number is 0855 and is subject to the small generator
20 MW interconnection procedures. Its System Reliability Impact System Reliability Impact Study Expected January 2022
Study is complete. Bald Mountain Solar is currently
participating in the Expedited Deliverability Study-2 to secure CRIS
Facilities Study Expected July 2022
and will secure ERIS via the completion of the Facility Study process.
Bald Mountain Solar planned key milestones include those listed in
Table 7-1 below. Interconnection Agreement Expected October 2022
Bald Mountain Solar Interconnection engineering/ Start date January 2023

construction
Interconnection Agreement Expected August 2021
Interconnection in-service date Expected May 2024
Interconnection engineering/ Expected April 2022
construction Generator Commercial Expected June 2024
Interconnection In-Service Date Expected November 2022 Operation Date
Table 7-2. West River Solar planned key milestones.

Table 7-1. Bald Mountain Solar planned key milestones.
West River Solar Sandy Creek Solar

West River Solar is preparing to submit a new Sandy Creek Solar filed an interconnection request with
interconnection request and does not currently have a NYISO for 20 MW in May 2019. Its queue position number
queue number assigned. West River Solar capacity will is 0843. It is subject to the small generator interconnection
20 MW
be 20 MW and will be subject to the small generator 20 MW
procedures and is currently in the process of completing
interconnection procedures. It plans to secure ERIS via the the System Reliability Impact Study. Sandy Creek Solar
completion of the Facility Study process. West River Solar planned key will secure ERIS via the completion of the Facility Study process. It
milestones include those listed in Table 7-2. also expects to participate in the Expedited Deliverability Study-4 in
late 2021 to secure CRIS. Sandy Creek Solar planned key milestones
include those listed in Table 7-3 on the next page.
Sandy Creek Solar Sky High Solar

Sky High Solar filed an interconnection request with NYISO
System Reliability Impact Study Expected to be completed May for 20 MW in October 2016. Its queue position number is
2021
0545. Sky High Solar will secure ERIS via the completion
Facilities Study Expected to be completed of the Facility Study process and is expected to participate
20 MW
October 2021 in the Expedited Deliverability Study-3 in late 2021 to
Interconnection Agreement Expected to be executed secure CRIS. Sky High Solar has also executed the Interconnection
January 2022 Agreement. The detailed engineering work is scheduled to start in the
next four to six weeks as of submitting this proposal. Sky High Solar’s
Interconnection engineering/ Start date expected April 2022
construction in-service date is expected to be in December 2022.
Interconnection in-service date Expected March 2023 Baron Winds Phase I

Baron Wind filed an interconnection request with NYISO
Table 7-3. Sandy Creek Solar planned key milestones. in November 2012. Its queue position number is 0396.
Baron Winds has an executed Interconnection Agreement in
121 MW place, No. 2487, with NYISO and NYSEG, dated February 24,
Greens Corners Solar 2021. Baron Winds participated in Class Year 2017 and has
Greens Corners Solar filed an interconnection request accepted its cost allocation of $2,922,144, and has the same amount
with NYISO for 120 MW in May 2019. Its queue position posted as security with NYSEG for its proposed connection facilities.
number is 0864. Greens Corners has completed its System
120 MW
Reliability Impact Study. Greens Corners has entered Class Heritage Wind
Year 2021 to obtain ERIS and CRIS. Greens Corners Solar Heritage Wind filed an interconnection request with
planned key milestones include those listed in Table 7-4. NYISO. Its queue position number is 0571. Heritage
Wind completed its System Reliability Impact Study and
147 MW Facility Study. Heritage Wind participated in Class Year
Greens Corners Solar 2021 and has accepted its cost allocation of $3.7 Million.
Interconnection Agreement Expected to be executed July Heritage is expected to post a $16.8 million security in Q3 2022, this
2022 security will be fully refunded by COD. Its expected interconnection
Interconnection engineering/ Expected October 2022 costs are $10.5M to self-build the switchyard and $3.7M for network
construction upgrades. The Generator Interconnection Agreement (GIA) execution
is expected in Q2 2023 with an anticipated commercial operation date
Interconnection in-service date Expected August 2023 in Q4 2023.
Generator Commercial Expected September 2023

Operation Date
Table 7-4. Greens Corners Solar planned key milestones.

Prattsburgh Wind While no studies by NYISO have been completed at this stage,
Prattsburgh Wind filed an interconnection request with as discussed in Section 7.4, Clean Path New York has engaged
NYISO. Its queue position number is 0801. Prattsburgh PowerGEM to complete reliability studies according to applicable
Wind participated in Class Year 2021. NYISO interconnection standards. The full results of PowerGEM’s
147 MW
analyses can be found in Appendix 7.
7.3. New transmission quantity of UDRs

7.2. New transmission interconnection
expected
application status There are currently no rules in the NYISO tariff regarding the
Clean Path New York has filed an interconnection request with the participation of internal HVDC lines within the NYISO market
NYISO for a connection between the 345 kV Fraser substation construct, and no rules for providing capacity delivery rights for
as the withdrawal point and the 345 kV Rainey substation as the internal HVDC lines via internal UDRs. Clean Path New York does not
delivery point. The scoping meeting will be held in the near future. currently expect to deliver any unforced capacity (UCAP) into Zone
Pending NYISO Operating Committee approval of the SIS scope, J. Moreover, Clean Path New York does not believe that any internal
the study is likely to commence this summer, and is anticipated to HVDC line can reasonably expect to be awarded UDRs and to be able
be completed later this year, followed by the Facilities Study which to offer UCAP under the current NYISO market rules.
would be expected to be completed in 2022. Clean Path New York
elected to seek interconnection under Attachment P, largely to allow As discussed in more detail in Section 5 of this proposal, Clean Path
its Facilities Study to be completed expeditiously and outside of New York has taken a lead role at the NYISO Budget & Priorities
the Class Year process. If any upgrades are contingent on the final Working Group in advocating for a priority project for the development
settlement results of the currently ongoing Class Year, those upgrades of the necessary additions and modifications to the NYISO tariff,
and contingencies will be identified in Clean Path New York’s Facilities manuals, and models to support the participation of internal HVDC
Study. By contrast, under Attachment X, projects are unable to enter lines in the NYISO market construct. Clean Path New York will continue
a Class Year until their System Reliability Impact Study is complete, to work to get the project prioritized for 2022. Assuming the project
which would add significant delay and risk. is prioritized, during the stakeholder process to develop these rules,
Clean Path New York will vigorously advocate for market rules that will
Clean Path New York has identified Mott Haven as an alternative enable the project to be awarded UDRs and deliver UCAP to Zone J.
delivery point as illustrated in Section 05 and submitted an
interconnection request with the NYISO in 2021. Clean Path New When NYISO approves and implements those market rules, Clean
York’s strategy is to obtain an alternative delivery point to provide Path New York will pursue CRIS rights, as long as doing so does not
flexibility and allow for reasonable management of the risks and substantially impact the project’s overall schedule and cost. In the
potential costs of interconnecting within New York City. Similar to event that Clean Path New York is awarded UDRs at any point during
Rainey and as explained in Section 7.4 below, Mott Haven is not its project life, Clean Path New York will promptly notify NYSERDA. If,
expected to induce any system reinforcement requirements. at any point during the term of the NYSERDA Tier 4 REC PSA, Clean
Path New York receives Zone J capacity market revenues, the $/MWh
equivalent would be deducted from the strike price as set forth in the
Tier 4 REC PSA.
7.4. Transmission system upgrades needed

to interconnect the new transmission at the
withdrawal point and delivery point
Clean Path New York has completed a steady-state analysis in
accordance with standard NYISO reliability analysis practice and
guidelines. An analysis report prepared by PowerGEM is provided
under Appendix 7. In the reliability part of the study, monitored
elements within the study area were checked for thermal overloads
against their Rate A (pre-contingency conditions) or Rate B (post-
contingency conditions). Voltage limits were assessed, pre-
contingency and post-contingency, in accordance with established
NYISO criteria. In general, voltages at buses rated 230 kV and above
were checked against an acceptable range of 0.95 pu to 1.05 pu,
whereas bus voltages for the 115 kV and 138 kV portion of the system
were checked against an acceptable range of 0.90 pu to 1.05 pu.
The results indicate that the addition of the new transmission line has
no adverse impact on steady-state system performance under N-1
contingency conditions (over 750 contingencies considered) and no
system reinforcements are needed. Additionally, the N-1-1 analytical
results (considered over 350 single-element first level outages) show
that the new transmission line does not have an adverse impact on
steady-state system performance. Thermal transfer limit analysis
shows that the addition of the new transmission line increases the
general ability of the system to transfer power from north to south.
Section 8
Energy resource
assessment
8 Energy resource assessment
8.1. Available energy resource data for each 8.2. Projection of net annual energy
resource production and a 12 x 24 P(50) energy
As illustrated in Section 4 and reiterated in Section 5, the vast majority generation at the resources' injection point
of project resources identified by Clean Path New York reflect mature
Projection of net annual energy production and the 12 x 24 P(50)
projects that have been in development for years and have already
energy generation for each resource is provided under Appendix 11.
been awarded contracts through NYSERDA’s Renewable Energy
Standards solicitation for Tier 1 RECs. Accordingly, these projects have
robust and reliable estimates of energy production that support the
aggregate delivery profiles provided here.
8.3. Schedule of planned maintenance
outages for each resource
Clean Path New York energy resource data was developed for each
technology as follows: Clean Path New York has elected to work only with developers that
have deep experience in the development of utility-scale renewable
For wind resources, where energy production estimates projects. These developers understand the importance of proper
are particularly sensitive to the details of geography, design to ensuring reliable operation, diligent practices for startup and
we developed estimates by analyzing data from on-site commissioning to ensure a smooth transition to commercial operation,
meteorological towers gathered over a period of three to and assiduous monitoring and maintenance procedures to ensure that
five years. We then coupled this data with the power curve performance issues are identified and corrected promptly. Adherence
data obtained from wind turbine OEMs for the specific resources to to these protocols will minimize the need for maintenance outages to
arrive at the energy production estimate. correct deficiencies in operation.
For solar resources, we developed estimates either through

site-specific solar irradiance forecasts or by analyzing data
from on-site solar irradiance sensor deployed for a period
of one year. This data was then coupled with the panel
yield and loss data from solar array OEMs for the specific resources to
arrive at the energy production estimate.
Key among these practices is execution of a preventative Planned maintenance outages will occur at least once per year and
maintenance plan for each project. By technology, these plans include last approximately four hours per inverter per outage. (Outages may
the following: not impact site output depending on site overbuild and time of day.)
The outages will be conducted on the panels and associated system
Wind turbines to minimize overall downtime and optimize the resource availability.
Each wind turbine will undergo semiannual and annual maintenance
outages for preventative maintenance. Maintenance items will include, Outages for planned maintenance have already been incorporated
but are not limited to, the following: into the projections for resource production outlined in Offer Data
Form Table III-1. Thus scheduled maintenance of generation will not
• Cleaning and inspection of mechanical components including the affect the expected monthly quantities of Tier 4 deliveries into Zone
gearbox, shaft coupling, bearings, seals, frames, and bolts J. Degradation of solar PV array production is projected at 0.4%
• Cleaning and inspection of electrical components including the per annum and will lead to a slight reduction in expected monthly
generators, cables, converters, circuit breakers, and control cabinets quantities of Tier 4 deliveries into Zone J over the Contract Delivery
• Lubrication of gearboxes and bearings Term, from 7,496,113 MWh in Year 1 of commercial operation to
7,166,022 MWh in Year 25 of commercial operation.
• Infrared testing of electrical components
• Testing of electrical insulation, generator winding resistance, rotor
AC drop voltage (as needed)
Planned maintenance outages will occur twice per year and last
7,496,113 7,166,022
approximately 8 to 10 hours per turbine per outage. The outages MWh of monthly quantities MWh of monthly quantities
will be staggered and managed to minimize overall downtime and of Tier 4 deliveries into of Tier 4 deliveries into Zone
optimize the resource availability. Zone J (Year 1 of commercial J (Year 25 of commercial
operation) operation)
Solar photovoltaic arrays
Each solar photovoltaic (PV) array will undergo semiannual and annual 8.4. Assumed level of curtailment and any
maintenance outages for preventative maintenance. Maintenance
items will include, but are not limited to, the following: projected impacts
Clean Path New York retained PowerGEM to conduct power system
• Visual inspection of general site conditions including fences,
analysis and production cost modeling necessary to accurate the
shading, vegetation, animal damage, or erosion
impact of generation and transmission resources over the course of
• Cleaning of arrays (condition-based) the project. The modeling indicates that wind resource production
• Visual inspection of electrical connections and ground connections will be curtailed by an average of 4.6% in 2030, and solar resource
• Inverter preventative maintenance per manufacturer’s operating production will be curtailed by an average of 8.6%. These curtailment
guidelines estimates are incorporated into the projections for resource
• Tracker verification and preventive maintenance per manufacturer’s production outlined in Offer Data Form Table III-1. A copy of the
operating guidelines PowerGEM report is provided under Appendix 7.
Section 9
Energy storage
operation plan
9 Energy storage operation plan
9.1. Assumptions used in preparing the New York proposes an innovative structure to integrate this facility
with its renewable portfolio and store excess renewable generation.
energy profile and deployment strategy This would result in a dramatic increase in the utilization of Blenheim-
As New York’s grid transitions toward 70% renewables by 2030 and Gilboa, unlocking its potential to facilitate the high renewable
zero emissions by 2040, energy storage will play a critical role. While penetration required to meet New York’s goals, while at the same time
battery storage technology has received much of the focus, studies increasing the production of Tier 4 RECs from the Project.
show that high renewables integration will require longer duration
In coordination with NYPA, Clean Path New York will use the
storage,1 and pumped storage has been described as ‘the heavy
Blenheim-Gilboa pumped storage facility to both maximize the
artillery’2 that will be needed for renewable penetration. Fortunately
contribution of wind and solar generation and to improve the new
for New York State, NYPA owns and operates Blenheim-Gilboa, one
transmission line utilization. Sited approximately 30 miles northeast of
of the largest pumped storage facilities in the country. Clean Path
the Fraser Substation, the Blenheim-Gilboa pumped storage facility
can generate 1,160 MW from four pump-turbine sets that draw on a
reservoir that can store up to 12,000 MWh. Blenheim-Gilboa provides
a unique opportunity to balance intermittent renewable generation
to maximize utilization of the new transmission, in alignment with
NYSERDA’s goals to increase market opportunities for storage to
serve as a transmission asset while at the same time increasing the
utilization and value to NYPA and the NYISO system of a very large
existing storage asset.
Clean Path New York will actively work with NYPA to coordinate
the scheduling of Blenheim-Gilboa to maximize the utilization of the
transmission line with the Resources under Clean Path New York
control. NYPA will complete scheduling of dispatchable resources,
Figure 9-1. The Blenheim-Gilboa project is located on Schoharie Creek.
1
National Renewable Energy Laboratory, 2021. “The Four Phases of Storage Deployment: A Framework for the Expanding Role of Storage in the U.S. Power System.” Golden, CO. NREL/TP-
6A20-77480. Available at: https://www.nrel.gov/docs/fy21osti/77480.pdf.
2
Utility Dive, Oct 13, 2020. “To batteries and beyond: In a high-renewables world, pumped hydro storage could be 'the heavy artillery'” Available at: https://www.utilitydive.com/news/to-batteries-
and-beyond-in-a-high-renewables-world-pumped-hydro-storage-c/584958/
along with monitoring and settling of energy flows across the The pumped storage facility at Blenheim-Gilboa also gives Clean Path
transmission line as illustrated in Figure 9-2. During scheduling and New York and the NYISO another degree of flexibility in determining
dispatch of project resources, if generation is expected to exceed system dispatch. If, any time period, the NYISO determines that
available capacity of the transmission line, Clean Path New York will the transmission line is not fully dispatching energy into Zone J,
request that NYPA charge Blenheim-Gilboa, subject to the available Blenheim-Gilboa can be used to store any generation that would have
storage volume and charging capacity. Conversely, if generation is otherwise been delivered into Zone J. As the NYISO conducts system
expected to fall short of the available capacity, Clean Path New York planning over the coming years and determines how to accommodate
will request that NYPA discharge from Blenheim-Gilboa, subject to the increasing penetration of renewable resources, this flexibility will
available storage volume and discharging capacity. become increasingly important.
9.2. Energy discharge eligible for Tier 4 RECs

The robust metering regime deployed at the Blenheim-Gilboa pumped
storage facility, monitored by the energy manager, will account for any
excess generation transmitted to or from the project along the 345 kV
HVAC line connecting the Fraser and Blenheim-Gilboa Substations.
Figure 9-2.
+
Scheduling of dispatchable resources. NYPA will be responsible for testing and verification of the storage
facility’s full-cycle efficiency, which will be used to derate the energy
charged to the facility and maintain an accurate account of the stored
energy eligible for Tier 4 RECs.
Solar Wind
Yes >1300 MW? No
BG Pumped BG Pumped
Yes Storage Capacity No Storage Capacity
Available? Available?
Yes
B F
E
A B C
Charge to Inject to Discharge

Blenheim- Generator from Blenheim-
Gilboa Zone Gilboa
9.3. System facility operating parameters

and specifications
The Blenheim-Gilboa Project is located on Schoharie Creek within
the towns of Blenheim and Gilboa, approximately two river miles
downstream from the New York Department of Environmental
Conservation’s Gilboa Dam (Figures 9-3 and 9-4).
The project consists of the following:
1. Earth and rock fill embankment dike 2.25 miles long and 30 feet
wide, maximum height 110 feet, constructed at Brown Mountain and
forming the 399-acre upper reservoir (operating at the maximum
and extreme minimum elevations of 2,003 feet and 1,955 feet
National Geodetic Vertical Datum of 1929 [NGVD 29], respectively)
with 15,085 acre-feet of usable storage and dead storage of 3,706
acre-feet below elevation 1,955 feet NGVD 29
2. Emergency spillway 655 feet long with asphaltic concrete crest
25 feet wide at elevation 2,005 feet NGVD 29 and a capacity of
10,200 cubic feet per second (cfs)
3. Intake system that includes (i) hexagonal intake cover 125 feet
wide, supported by six vertical concrete piers, and trash racks
attached to the outside of the piers with a clear spacing of 5.25
inches, (ii) concrete-lined vertical shaft 1,042 feet long and 28 feet
in diameter, in the bottom of the upper reservoir, (iii) horizontal,
concrete-lined rock tunnel 906 feet long, and (iv) concrete-lined
manifold 460 feet long that distributes flow to four 12-foot-diameter
steel-lined penstocks, each with a maximum length of about 1,960
feet, to four pump-turbines located at the powerhouse
4. Multilevel powerhouse 526 feet long, 172 feet wide, and 132 feet
high located along the east bank of the lower reservoir at the base
of Brown Mountain, containing four reversible pump turbines that
each produce approximately 290 MW in generation mode and
have a total maximum discharge of 12,800 cfs during generation
and 10,200 cfs during pumping
Figure 1. Blenheim-Gilboa
Figure 9-3. Project
Blenheim-Gilboa project boundary,
boundary, Schoharie
Schoharie County,
County, New York. New York
2
Figure 9-4. Aerial view of Blenheim-Gilboa project facilities.
5. Powerhouse trash racks, including a bottom

trash rack with a clear spacing of 5.625
inches and four upper trash racks with a
clear spacing of 5.25 inches
6. Central-core, rock-filled lower dam 1,800
feet long with a maximum height of 100 feet
that impounds Schoharie Creek to form the
413-acre lower reservoir (operating at the
maximum and minimum elevations of 900
feet and 860 feet NGVD 29, respectively)
with 12,422 acre-feet of usable storage and
dead storage of 3,745 acre-feet below 860
feet NGVD 29
7. Three Taintor gates 38 feet wide by 45.5
feet high at the west end of the lower dam
8. Concrete spillway structure 425 feet long
and 134 feet wide with a crest elevation of
855 feet NGVD 29
9. Concrete stilling basin 238 feet long and
68.5 feet deep Figure 3. Aerial view of Blenheim-Gilboa Project facilities
10. Low-level outlet with four discharge valves 9.4. Intended deployment and dispatch of
of 4-, 6-, 8-, and 10-inch diameters for release of 5 to 25 cfs, and
two 36-inch-diameter Howell-Bunger valves to release a combined the storage system
4
flow of 25 to 700 cfs A description of the intended deployment and dispatch of the storage
11. Switchyard on the eastern bank of Schoharie Creek adjacent to the system over the contract term, as well as how the deployment
powerhouse provides operating flexibility and/or peak coincidence benefits, is
12. Appurtenant facilities addressed in Section 9.1 above. Blenheim-Gilboa will give Clean
Path New York and the NYISO another degree of flexibility in
A Lifecycle Extension Modernization (LEM) program completed in 2010, determining system dispatch specifically managing the line utilization
combined with a regular preventative maintenance and equipment in conjunction with the level of resources generation available.
inspection program, will ensure reliable and consistent production from This added flexibility will enable NYISO a better management of
the Blenheim-Gilboa pumped storage facility for years to come. intermittent generation and maintaining system reliability.
Section 10
Business entity and
financing plan
10 Business entity and financing plan
10.1. Financeability of project and long-term 10.2. Business entity structure and
contract implications information on shareholders supporting the
The 25-years Tier-4 REC purchase agreement awarded through this project
RFP process will provide a level of certainty for a long term revenue
NYPA and Forward Power (a 50/50 joint venture between energyRe1
stream and will be considered one of the key underwriting agreements
and Invenergy Renewables), the “Partners,” have entered into a
to enable the financing of generation projects not currently contracted
partnership to develop Clean Path New York. The Partners have
under Tier 1 and the New Transmission. The majority of the cost
structured the project through the creation of multiple entities to both
associated with Clean Path New York is upfront capital cost. As such
develop and manage the New Transmission, the Resources and enter
Clean Path New York will require a known ongoing revenue stream
into a Tier 4 purchase agreement with NYSERDA. Figure 10-1 below
over a long period to recoup the substantial upfront capital required
illustrates the structure and provides an organization chart showing
for the project. Without a long-term contract from NYSERDA, the
the relationship among project participants.
project would need to sell into the market on a merchant basis,
which would introduce significant volatility into the revenue stream The financial strength of the Partners is described in greater detail in
for the project. Additionally, NYSERDA is the only buyer at scale for the following responses.
renewable energy delivered into Zone J, which is a key attribute of the
project. The contract with NYSERDA therefore both monetizes a key
Clean Path New York
value associated with the project and ensures long term certainty of
revenue, both of which are critical to the ability to finance the various
energyRe
components of the project. Forward Power
New York Power
Authority (NYPA)
Invenergy
Renewables
Clean Path New

Clean Path New
York Infrastructure
York LLC
LLC
Southern segment Northern segment

of the New of the New
Transmission and Transmission and
1
energyRe is an independent company founded by the principals of related. Figure 10-1. Organizational structure converter in NYC northern converter
of project participants.
Clean Path New York LLC is a newly formed limited liability company • Directly own Tier 4-qualifying wind and solar generation assets
owned by Forward Power. Clean Path New York LLC will own and • Sell the power from those resources to the NYISO
manage the majority of the offered Resources, is the bidding entity for
• Contract with NYPA’s Blenheim-Gilboa pumped storage facility
Clean Path New York, and will be the counter-party of the NYSERDA
Tier 4 REC purchase agreement. While Clean Path New York LLC is a • Contract with third-party-owned Tier 4-qualifying wind and solar
new entity, its members have significant experience and management resources to procure those resources’ environmental attributes via
capability to develop and operate the project. Each member has REC purchase agreement
successfully developed projects of similar scale and complexity from • Contract with NYPA and Clean Path New York Infrastructure LLC
early stages through to commercial operation, as described in this for transmission services from the Fraser Substation to the Rainey
section. Substation
• Contract with an energy manager and/or energy service company to
On the transmission side of the project, Clean Path New York provide the following services:
is supported by two entities: NYPA and Clean Path New York
– Forecast day ahead and hourly load
Infrastructure LLC. NYPA will develop and/or own the northern
segment of the transmission system, including the converter – Document hourly matching via metered flows to support monthly
station and the interconnection facility at the withdrawal point near reconciliation with NYSERDA via New York Generation Attribute
Fraser Substation in Delaware County, NY and the balance of the Tracking System (NYGATS) for REC payments
transmission infrastructure located within its Marcy-South corridor and
NYPA and Clean Path New York Infrastructure LLC will develop
corresponding right-of-way, which ends at the Rock Tavern Substation
and own the northern and southern segments of the new HVDC
in Orange County, NY.
transmission system connecting the 345 kV NYSEG-owned Fraser
Clean Path New York Infrastructure LLC will be owned by Forward substation (withdrawal point) to the 345 kV Rainey Substation (delivery
Power. It will develop and own the southern segment of the point) owned by Consolidated Edison Company of New York, Inc.
transmission system, including the converter station and the (CECONY). These entities will hold transmission service agreements
associated interconnection facility at the Rainey Substation in with Clean Path New York LLC.
Queens, NY and the balance of the transmission infrastructure located
NYPA intends to enter into a service agreement with Clean Path New
underground and under the Hudson and Harlem Rivers between Rock
York LLC to sell energy storage services associated with its Blenheim-
Tavern and Rainey.
Gilboa pumped storage facility.
The business model for Clean Path New York LLC is driven by energy
Clean Path New York LLC will enter into REC purchase agreements
market revenues, a delivery service agreement, and Tier 4 REC
with third-party owned Tier 4-qualified, clean power suppliers of wind
revenue. The commercial structure is illustrated in Figure 10-2.
and solar will enter into REC purchase agreements with Clean Path
Clean Path New York is enabled through a series of discrete New York LLC to sell the environmental attributes associated with
transactions by independent business entities tied together through their Tier 4-qualified generation. These generators will sell their power
contractual relationships. As previously stated, Clean Path New York to NYISO in exchange for energy revenues.
LLC will be the counter-party to NYSERDA’s Tier 4 REC contract. This
entity will do the following:
Figure 10-2.
Clean Path New York commercial structure.

NYPA
• State authority/public benefit REC
Monthly
Energy Energy
REC
corporation payments
settlement
sales revenue
payments
Capacity
Tavern and supplies energy
storage Clean Path New York LLC
• Single ownership of most in-state generation
• Owns Blenheim-Gilboa pumped Third-party clean power
payments
Attribute
storage asset • 25-year contracts with transmission owners on a
suppliers
Environmental
attributes
fixed capacity basis
• Suppliers of Tier 4-qualified
• Contract with third party suppliers for
wind and solar
environmental attributes
Members:
Clean Path New York • Settles REC payments via New York Generation
Boralex, Northland, RWE, Apex
Environmental
attributes
Infrastructure LLC and Terra-Gen
• Receives REC payments from NYSERDA Other renewable generation
Member: developers under negotiation
Capacity
payments

• Provides transmission services
to Clean Path New York LLC
Forward Power

Members:
TBD - Third Party provider subject to competitive
award
Regulatory considerations Nevertheless, Clean Path New York is aware of the requirements the
Clean Path New York is aware of the Public Service Commission’s Commission has imposed in other proceedings where it has upheld
Vertical Market Power Guidelines and their potential application to this the rebuttable presumption. In the event the Commission disagrees
Project. In its Order Granting Certificate of Public Convenience and with Clean Path New York’s position, Clean Path New York is prepared
Necessity in Case 18-E-0765, Petition of NextEra Energy Transmission to take steps consistent with Commission precedent to allay any
New York, Inc. for an Order Granting Certificate of Public Convenience vertical market power concerns.
and Necessity Pursuant to Section 68 of the Public Service Law on
February 11, 2021, the Commission determined that the rebuttable
presumption of vertical market power can be overcome where (i) there 10.3. JV owners and interests and
is a low risk to ratepayers of the improper exercise of market power, (ii) proposer's right to submit a proposal
the risks can be reduced via mitigation measures, and (iii) the project
The Partners have entered into a Joint Bidding Agreement to
will have significant benefits.
document the agreement to jointly bid into this solicitation. This Joint
Clean Path New York believes that this Project satisfies these Bidding Agreement outlines roles and responsibilities of the Parties as
requirements for similar reasons as set forth in that matter. First, the well as confirms the agreement to bid. Upon award, the Partners will
transmission line will be operationally controlled and dispatched by enter into definitive documentation to confirm the contractual details
the NYISO, and the generation owned or controlled by Clean Path of each of the independent relationships. Additionally, Clean Path
New York is intermittent with relatively low capacity factors. Both New York LLC has entered into term sheets with the majority of third
the Public Service Commission and the Federal Energy Regulatory party Resources confirming certain economic terms, as well as their
Commission will have oversight over Clean Path new York and the approval to be included in this proposal. Such documentation can be
New Transmission line. For these reasons, Clean Path New York made available to NYSERDA upon request.
would not have the ability to exercise market power. Second, Clean
Path New York is willing to develop a code of conduct to separate
its transmission and generation operations, file annual reports with 10.4. Financing plan
the Commission on affiliate transactions and line outages, notify Financing mechanism
the Commission of changes to the code of conduct, maintain the
transmission line in accordance with god utility practice, and file
periodic reports on future supply side projects in New York. Third,
the significant public benefits that justify the transmission line were
established in the Commission’s adoption of Tier 4. See Case 15-
E-0302, Proceeding on Motion of the Commission to Implement a
Large-Scale Renewable Program and Clean Energy Standard, Order
Adopting Modifications to the Clean Energy Standard (issued October
15, 2020) at 77-103.
Existing financial structure and projected financial

structure
Expected sources of debt and equity financing

Agreements entered with respect to equity

ownership/any other financing arrangement
$11 billion
The total construction costs for Clean Path New York are
expected to be approximately $8.5 billion for directly developed
generation Resources and New Transmission, with the balance
coming from third-party developers of new wind and solar
resources.
10.5. Project financing experience

The Partners have significant experience in financing projects having Projected capital structure
raised capital for complex generation and transmission projects in the
past.
Forward Power will lead the financing efforts for both the Resources
and the southern segment of the New Transmission. Through its
parent companies, namely Invenergy Renewables, Forward Power has
Figure 10-3. Projected capital structure for Clean Path New York, LLC.
extensive experience in project financing. Invenergy Renewables will
leverage these existing relationships to fund construction and project
debt. Invenergy Renewables has successfully worked with various
financial institutions including those listed in Figure 10-4.
Table 10-1 on the next page provides a sample of Invenergy's

successfully financed projects.
Figure 10-4. Invenergy has successfully worked with numerous financial institutions.
Date of construction Form of debt and equity Status of the

Project name Location Type and size and financing financing project
AEP North Central Oklahoma Traverse: December 2020 Traverse and
Wind Energy 999 MW Wind (Sundance & Maverick) Maverick: under
Facilities: Traverse, construction
Maverick: March 2021 (Traverse)
Maverick, and Sundance:
287 MW Wind
Sundance operating
Sundance:
199 MW Wind
Lackawanna Jessup, PA 1,485 MW Natural December 2016 Operating
Energy Center gas combined cycle
Energia del El Salvador 378 MW “LNG- November 2019 (thermal Under

Pacifico to-power" natural plant) construction
gas-fired power February 2021 (FSRU)
plant / offshore
floating storage and
regasification unit
High Sheldon Wyoming 112.5 MW Wind December 2008 Operating

Wind County, NY
Orangeville Wind Wyoming 94 MW Wind June 2013 Operating

County, NY
Marsh Hill Wind Steuben 16 MW Wind June 2014 Operating

County, NY
Shoreham Solar Brookhaven, 25 MW Solar July 2017 Operating

Commons NY
Table 10-1. Projects successfully financed by Invenergy.

NYPA will arrange for financing its portion of Clean Path New York
$1.1 billion
associated with the northern segment of the New Transmission.
NYPA has a long history of developing, constructing and operating
a broad spectrum of low-carbon energy infrastructure assets. On
April 27, 1931, New York Governor Franklin D. Roosevelt signed the in bonds issued by NYPA in 2020
Power Authority Act creating the New York Power Authority calling
for a “self-supporting organization devoted to public purpose.” To
undertake such investments, NYPA utilizes its own cash equity built
steadily through the responsible operations of its assets in addition
to raising capital in the municipal debt markets, traditionally through
the issuance of long-dated revenue bonds. It is important to note that
NYPA operates and makes all of these investments without reliance
on tax-payer funding, and in a manner that is financially sustainable
in addition to fulfilling its purpose and Mission. A prime example of
NYPA’s sustainable finance in practice was its 2020 debt issuance. In
April 2020, NYPA issued $1.1 billion in bonds, including $800 million in
certified green bonds. Through this issuance, the company was able
to lock-in one of the lowest financing rates in its history in order to
fund a number of strategic, mission critical investments in low-carbon
infrastructure related to its core transmission business.
The 2020 debt issuance included more that $625 million in

proceeds that will go toward major transmission projects across
New York State to overhaul and upgrade the existing backbone
transmission network owned by NYPA, to construct new
transmission lines to address congestion, and to extend the life
of and modernize existing infrastructure. This will help to assure
reliability, improve asset management, and lower the lifecycle
operating costs.
Examples of these projects include:

• Moses-Adirondack Transmission Line Upgrade (the Smart Path
Reliability Project)
• Marcy-to-New Scotland Transmission Line
• Niagara Transmission Life-extension & Modernization program
Figure 10-5. NYPA's Smart Path Project.
10.6. Evidence of financial resources

Evidence of financial resources are summarized below. More details
can be found in the associated appendices.
NYPA energyRe
NYPA is the largest public power company in the U.S. and has an AA/ The principals of energRe have substantial resources and a successful
Aa2 credit rating. NYPA generates $2.4 billion in annual revenue on track record investing and raising capital for large scale development
average. The company benefits from the essentiality of the services and infrastructure projects. A core strength of energyRe is its ability
it provides for key governmental customers across the state, flexible to creatively and efficiently finance projects in order to maximize the
regulatory construct and strong contractual framework unpinning value to all stakeholders. Its financing approaches have historically
revenues, low operating risk, and a diversified asset portfolio. In included a variety of different sources including the following: general
April 2021 NYPA celebrated its 90th anniversary of being a financial and limited partner equity, conventional construction and permanent
independent company serving NYS’s energy needs. NYPA's audited debt, taxable and tax-exempt bonds, tax credits, preferred equity
financial statements and rating agency reports exemplify the strength and multiple other sources. energyRe have an extensive network of
of their financial resources. debt and equity relationships that include many of the world’s largest
banks, insurance companies, pension funds, sovereign wealth funds
Invenergy and other financial institutions. We have historically sourced between
Over nearly two decades, Invenergy has completed more than $5 and $10 billion of debt and equity capital per year and have done
$42 billion in transactions, and the its deep bench of financiers is so at scale across economic cycles. Additional details regarding
unparalleled in the renewable energy development sector. Invenergy energRe’s financial resources and capabilities can be made available
proficiently structures project financing and maintains strong upon request.
relationships with a wide range of partners including international
and domestic banks, multilateral development banks, export credit
agencies and pension funds. In the fourth quarter of 2019 alone,
Invenergy closed more than $3 billion in project financing; and
Invenergy has been recognized with Power Finance & Risk Borrower
of the Year or Deal of the Year awards in 2017, 2016, 2013 and 2012.
10.7. Role of Federal Production Tax Credit 10.8. Audited financial statements and
or Investment Tax Credit annual reports
Three years audited financial statements for the partners are provided
as follows:
NYPA. 2018, 2019, and 2020 Financial Statements are provided under
Appendix 12.
Invenergy. 2018, 2019, and 2020 Financial Statements are provided

under Appendix 13.
energyRe. energyRe has no published audited financial statements at

this stage. Additional details regarding energRe’s financial resources,
its parent companies and capabilities can be made available upon
request.
10.9. Credit ratings from Standard & Poor's

and Moody's
Credit ratings for each of the Partners are listed in Table 10-2 below.
Partner Credit rating

NYPA AA (by Fitch Ratings), AA (by S&P), and Aa2 (by
Moody’s).
Invenergy As a privately-owned company, Invenergy does not

Wind projects Solar projects have a credit rating.
60% Federal 26% Federal
energyRe As a privately-owned company, energyRe does not
Production Tax Investment Tax
have a credit rating.
Credit Credit
Table 10-2. Credit ratings of each Partner.
10.10. Partners' board of directors, officers,

and trustees for the past three years
Invenergy
Invenergy's core senior executive team includes the following:
NYPA
Michael Polsky (Founder and CEO) ● Jim Murphy (President and
NYPA Trustees are as follows: John R. Koelmel (Chair) ● Eugene L. CEO) ● Jim Shield (EVP and CCO) ● Bryan Schueler (EVP and
Nicandri (Vice Chair) ● Tracy B. McKibben ● Anthony Picente, Jr. CDO) ● Bill Bradley (EVP and General Counsel)
● Michael Balboni ● Dennis Trainor
Current NYPA officers include: Gil C. Quinones (President and

CEO) ● Joseph Kessler (EVP and COO) ● Kristine Pizzo (EVP and
energyRe
Chief Human Resources and Administration Officer) ● Justin E.
Driscoll (EVP and General Counsel) ● Adam Barsky (EVP and The energyRe officers are as follows: Stephen M. Ross (Chairman)
CFO) ● Sarah Orban Salati (EVP and CCO) ● Robert Piascik (SVP ● Jeff T. Blau (President) ● Bruce A. Beal, Jr. (Executive Vice
and Chief Information and Technology Officer) ● Yves Noel (SVP President) ● David Zussman (Executive Vice President) ● Richard
and Chief Strategy Officer) ● Daniella Piper (Chief Transformation L. O'Toole (Executive Vice President) ● Glenn A. Goldstein (Vice
Officer and Regional Manager, Western New York) ● Phil Toia President) ● Charles O'Byrne (Vice President) ● David Zussman
(President, NYPA Development (Treasurer) ● Richard L. O'Toole (Assistant Secretary).
10.11. Ability and plan to provide the

required security
As demonstrated in the sections above, the Partners have the
financial strength and the required facilities to provide the required
securities. Typically, for projects under long-term power sale contracts
like this one, the Clean Path New York Partners will provide credit
support to backstop their obligations. The typical credit support
structure is based upon providing cash, a performance bond, or
an irrevocable standby letter of credit from an issuer with a senior
unsecured debt rating equivalent to A- (S&P) or A3 (Moody’s) or
better. To address these needs, the Partners maintain credit facilities
with a number of investment grade financial institutions. For previous
agreements, the Partners have posted sufficient security to NYSERDA.
10.12. Credit issues and credit rating • Alle-Catt Wind Energy LLC v. Town of Farmersville, et al, U.S. District
Court, Western District of New York, Case No.: 1:20-cv-01785-GWC.
downgrade events Declaratory judgment action challenging Town’s effort to terminate
NYPA. In October of 2020 Moody's downgraded NYPA's revenue MET tower permit
bonds to Aa2 from Aa1 with a stable outlook. energyRe. None, however the parent company has an expansive
Invenergy. None. enterprise of affiliate businesses that are engaged in typical volume
of commercial litigation that is commensurate with typical business of
energyRe. None. this size.
10.13. Pending litigation or disputes 10.14. Expected operating life of the

NYPA. None.
proposed project and depreciation period
Invenergy. The following ongoing litigations are related to a few of the
offered Resources owned by Invenergy Renewables:
for all substantial physical aspects
The GAAP depreciable life is assumed to be 30 years for the majority
• Orangeville: Rohauer v. Invenergy LLC, Supreme Court of New York of the wind and solar equipment & facilities. The New Transmission
No. 46066; Slowinski v. Invenergy LLC, Supreme Court of New would be depreciated over a range of 40 to 60 years depending on
York No. 46911; Andre et al v. Invenergy LLC, Supreme Court of the sub-asset classes within the overall line and converter stations.
New York No. 46912. Three related actions asserting claims arising
from the Orangeville Wind project. Claims include typical wind farm The operating life of the assets is expected to be as follows:
“nuisance” claims – noise and vibrations, shadow flicker, property
40 years
values. Rohauer and Andre were removed to federal court and
consolidated for purposes of discovery. Slowinski is still pending in
Wyoming County Supreme Court.
• Alle-Catt: Coalition of Concerned Citizens, et al, and Town of Solar design life
Farmersville v. New York State Board on Electric Generation Siting,
35 years
et al, New York Supreme Court, Appellate Division, 4th Department,
No. OP 20-01406. Consolidated Article 78 proceedings appealing
the issuance of the project’s state Article 10 permit.
• Alle-Catt Wind Energy LLC v. Town of Farmersville, et al, New Wind design life
York Supreme Cattaraugus County, Civil No. 89872. Article 78
40 years
and declaratory judgment action challenging the Town’s effort to
terminate a project road use agreement.
New Transmission design life

10.15. Listing of proposer's affiliated entities • Invenergy Clean Power and its subsidiaries build, own and operate
natural gas power generation and co-generation assets that serve
and JVs transacting business in energy as flexible, high-efficiency resources for power grids and industrial
energy users. Invenergy Clean Power has operating or late-stage
sector development assets in Canada, El Salvador, Mexico, and the United
NYPA. NYPA does not have any affiliated entities. States.
Invenergy. Invenergy Renewables LLC and its subsidiaries develop, • Invenergy Transmission and its subsidiaries develop transmission
own, and operate large-scale sustainable energy generation and infrastructure to bring clean energy to market. Invenergy
storage facilities in the Americas, Europe, and Asia. A high-level Transmission is currently advancing development of a transmission
organization chart is provided in Figure 10-6 below. project in Uruguay, a transmission line across the Midwest U.S. and
several other early-stage development projects across the United
States.
Invenergy Renewables LLC
• Invenergy Solutions and its subsidiaries help customers develop
tailored solutions to achieve their energy goals through multi-
technology on-site energy infrastructure, offsite renewable supply
and the sophisticated software to manage those systems.
Invenergy Solar Project Invenergy Wind • Invenergy Clean Water and its subsidiaries are tackling the next
Development North Development North sustainability challenge with an emerging water infrastructure and
America LLC America LLC
desalination business. Invenergy Clean Water is currently advancing
development opportunities in the United States and Mexico.
Invenergy Solar Project Invenergy Wind
energyRe. energyRe does not have any affiliated entities.
Development LLC and Development LLC and
Specific Project Entity Specific Project Entity
Figure 10-6. Invenergy Renewables LLC and its subsidiaries. 10.16. Litigation, disputes, claims,
Other Invenergy entities include the following:
complaints, or failure to satisfy contract
• Invenergy LLC and its subsidiaries serve as holding companies
obligations related to the purchase or sale
which retain nearly all of the personnel which support Invenergy’s of energy, capacity, or RECs
development, ownership and operation of large-scale sustainable NYPA. None.
energy generation, transmission and storage facilities in the
Americas, Europe, and Asia. Invenergy. None.
energyRe. None.
10.17. Confirm that proposer/agents

of proposer are not currently under
investigation and have not in the last four
years been convicted or found liable for
any act prohibited by State or Federal law
in any jurisdiction involving conspiracy,
collusion or other impropriety with respect
to offering on any contract, or have been
the subject of any debarment action
NYPA. None.
Invenergy. None.
energyRe. None.
Section 11
Permitting plan
11 Permitting plan
The New Transmission component of Clean Path New York is the main
driver for the schedule and for achieving the targeted Commercial
11.1. Introduction to New Transmission
Operation Date explained in Section 13. More specifically, the critical permitting plan
path for this component includes the NYSDPS Article VII permitting Clean Path New York has prepared a Preliminary Permitting Plan in
and construction phase. The Resources offered within the portfolio of support of the proposed Clean Path New York project. In general,
Resources are expected to achieve commercial operation date one to the purpose of this plan is to describe the environmental review
four years before the completion of the New Transmission. Hence we program, identify environmental and land use conditions in the vicinity
have focused on a diligent assessment of its permitting requirement. of the proposed project, and identify potential environmental review,
permitting, and mitigation (refer to Section 12) considerations that will
In the subsections herein we provide a detailed explanation of the
likely need to be addressed during the development and construction of
New Transmission permitting plan. Toward the end of the section we
the project.
provide a status update of the Resources Portfolio permitting plan and
progress. The portfolio of Resources offered by Clean Path New York
reflects mature projects that have been in development for years and Specific to the RFP requirements, this plan identifies:
have already been awarded contracts through NYSERDA’s Renewable
1
Energy Standards solicitation for Tier 1 RECs. Accordingly, these
projects have already made significant progress in obtaining some of A comprehensive list of permits anticipated for the project
the major permits.
2 Applicable environmental assessment or impact documents

that may be required to support the project
3 Government agencies responsible for permits, consultations, or

approvals
4 The current status of all agency consultations to date
5 The anticipated timelines for said permits, consultations, and

approvals
These items are summarized in Tables 11-1 and 11-2. However,

additional detail and discussion is provided throughout the plan,
11.4. New Transmission listing of
which has been provided as Section 11.7. governmental agencies responsible for
permits
11.2. New Transmission comprehensive Please refer to Tables 11-1 and 11-2 below. Specific details regarding
government agencies responsible for permits, consultations, or
listing of permits approvals are found within Section 11.7 below.
Please refer to Tables 11-1 and 11-2 below. Specific details regarding
permits, consultations, and approvals are found within Section 11.7
below. 11.5. New Transmission status of permit
applications
11.3. New Transmission listing of Please refer to Tables 11-1 and 11-2 below.
environmental assessment or impact

statements 11.6. New Transmission anticipated
Please refer to Tables 11-1 and 11-2 below. Specific details regarding timelines for permits, licenses, EA/EIS
permits, consultations, and approvals are found within Section 11.7 Please refer to Tables 11-1 and 11-2 below.
below.
State and federal permitting

Agency(s) and contact Anticipated Status of permit
Permit, approval, or consultation (11.2/11.3) information (11.4) Approval process timelines (11.6) applications (11.5) Notes/thresholds/status
State approvals/consultations
New York State Public Service Law, Article New York State Department of Public Article VII applies to the siting of major utility transmission Estimated 20 Consultation Section 401 delegates authority to
VII, §120 et seq., 16 NYCRR Parts 85-88 Service, Public Service Commission facilities (submarine and onshore cable connection), lines months for initiated in Q1 NYSDEC to issue a 401 Water Quality
Certificate of Environmental Compatibility (PSC or DPS) 125 kV and overextending a distance of one mile or more. application phase 2021; estimated Certification for all projects that require
and Public Need under Article VII Secretary to the Commission Article VII application is a robust procedure that involves and one year for time of a federal permit (such as a Section
alternatives analysis, public and stakeholder involvement, Environmental submission is CY 404 Permit). However, under Article IIV
Environmental Management and Empire State Plaza environmental studies, purpose and need statements, and Management and 2022. regulations, the DPS will issue the water
Construction Plan Agency Building 3 other information. PSC issues approval. Construction Plan quality certification.
Water Quality Certification, Section 401 of Albany, NY 12223-1350 approval (may be
the Clean Water Act Phone: 518.474.6530 partially concurrent)
Email: [email protected]
Certificate of Public Convenience and
Necessity under PSL Section 68
New York Independent Systems Operator NYISO NYISO typical interconnection process includes several Varies Estimated time of
(NYISO) Consultation re: design and 10 Krey Boulevard procedures including but not limited to these: submission is CY
operational criteria Rensselaer, NY 12144 • NYISO TPAS/OC approval of System Impact Study Scope 2022
Phone: 518.356.6000 • System impact study completed and approved by NYISO
• Facilities study completed and approved
• Class Year 2021 completed and settled
• Interconnection Service Agreement
New York Fish and Wildlife Law, New York NYS Department of Environmental Conduct initial online review of NYS database 3-4 weeks typically Consultation Article 11 of the ECL prohibits "taking" of
Environmental Conservation Law (ECL) Conservation (Environmental Resources Mapper) to determine if general required for initial initiated in Q1 state-listed threatened and endangered
(Article 11 requirements will be incorporated Natural Heritage Program area is identified as potential habitat for a state-listed Natural Heritage 2021; estimated species or habitat occupied by such
into Article VII process) NYSDEC-DFWMR species. Program response. time of species. “Take” is defined very broadly.
New York Natural Heritage Program If yes, then submit letter to Natural Heritage Program to submission is CY Status: Online review identified no state
625 Broadway, 5th Floor request an official letter for recorded rare, threatened, and 2022. listed species or critical habitat on or near
Albany, NY 12233-4757 endangered species in or near the project site. A response the project.
http://www.dec.ny.gov/animals/31181. is typically 3 to 4 weeks and remains valid for one year. Article 11 requirements will be folded
html If necessary: Undertake studies in consultation with into the Article VII process and may
Phone: 518.402.8935 NYSDEC and USFWS (see below). be applied to this project if there is a
possibility of disturbing a listed species.
Listed grassland birds are the primary
species of concern for a solar project.
Table 11-1. State and federal permitting matrix.


New York State Parks, Recreation, and New York State Office of Parks, Initiate project review in online Cultural Resources 6-12 months, Consultation Consultation with OPRHP regarding
Historic Preservation Law, § 14.09 Recreation, and Historic Preservation/ Information System (CRIS) depending on initiated in a project's potential effect on historic
State Historic Preservation Cultural If requested by New York State Office of Parks, Recreation, State Historic Q2 2021; and archeological resources is required
Resources Information System and Historic Preservation (OPRHP): Preservation estimated time of under Section 14.09 of the NYS Parks,
https://cris.parks.ny.gov Office review and submission is CY Recreation, and Historic Preservation Law
• Archaeological Survey any subsequent 2022 for any projects requiring state funding or
Peebles Island State Park • Historic Resources Survey requests for a state agency approval. Similarly, OPRHP
P.O. Box 189 • State Historic Preservation Office review, determination of additional consultation is required under Section
Waterford, NY 12188-0189 effect information or 106 of the National Historic Preservation
If effect determined, then: studies Act for any projects that receive federal
• Mitigation plan funding or require approval by a federal
• Memorandum of Agreement (MOA) agency.
Tidal Wetland Permit, ECL Article 25 New NYSDEC Region 4 (Delaware Counties) Wetland and stream permitting at the state level will occur Permit review varies Consultation Articles 15 and 24 provide protection to
York, Tidal Wetlands Act, 6 NYCRR Part 661 Region 4 Sub-office through the unified Article VII process; however, the depending on initiated in Q1 specific streams and wetlands that are
Floating object permit/Letter of No Objection 65561 State Highway 10 NYSDEC will be consulted throughout the process. type and extent of 2021; estimated under state jurisdiction. Typical Articles 15
Stamford, NY 12167-9503 Typical consultation process includes the following: wetland or stream time of and 24 requirements will be incorporated
Temporary revocable consent pursuant to impacts. submission is CY into the Article VII process.
Title 6 of NYCRR and ECL Articles 3, 9, 11, Contact: Martha Bellinger • Review NYSDEC protected wetlands/streams mapping
Division of Environmental Permits Typically, 3-6 2022. Work plan and impact avoidance
and 51 • Conduct wetland/stream delineations (Note: Wetland
Phone: 607.652.7741 delineations cannot occur with snow cover) months, but will be measures to be integrated in the
NYSDEC Region 3 (Sullivan, Orange, • Prepare/submit to NYSDEC regions Wetland Delineation integrated into the Environmental Management and
Rockland, Dutchess, Putnam, and Reports with a request for boundary line confirmation Article VII process. Construction Plan.
Westchester Counties) • Meet NYSDEC representative on site to review boundary
21 South Putt Corners Road lines
New Paltz, NY 12561 • Adjust wetland boundary lines and modify maps as
Contact: John Petronella necessary
Division of Environmental Permits • Submit final map to the NYSDEC Regions for validation
Phone: 845.256.3054 • Schedule pre-submittal consultation meetings with
NYSDEC Regional offices
NYSDEC Region 2 (New York City) • Prepare Best Management Practice work plan for wetland
1 Hunter’s Point Plaza and subaquatic work (Water Quality Plan, Sediment
47-40 21st Street Control Plan, Dredging Plan, etc.) for inclusion in the
Long Island City, NY 11101 Article VII Environmental Management and Construction
Contact: Stephan Watts Plan
Division of Environmental Permits
Phone: 718.482.4997
NYS Agriculture and Markets Law, § 305(4) NYS Department of Agriculture and Consultation with the New York State Department of Typically, 3-6 Consultation Proposed construction of nonagricultural
NYS Soil and Water Conservation/Soil and Markets Agriculture and Markets is expected to be required, months initiated in Q2 structures within a designated agricultural
Water Districts 10B Airline Drive particularly if prime agricultural lands or designated 2021 district requires that a Notice of Intent be
Albany, NY 12235 agricultural districts will be impacted. If the project is filed with New York State Department of
Phone: 518.457-3738, 800.554.4501 utilizing state funding, a Notice of Intent will need to be Agriculture and Markets.
completed to address agricultural impacts occurring within To be coordinated with the Article VII
a county Agricultural District, and agricultural protection and process.
restoration measures will need to be discussed during the
environmental review process.
Table 11-1 (continued). State and federal permitting matrix.


State Pollutant Discharge Elimination System NYSDEC Division of Water • Develop/prepare Stormwater Pollution Prevention Plan 2 months upon filing To be initiated Required for construction activities that
(SPDES) Permit for Stormwater Discharges 625 Broadway (SWPPP) Notice of Intent prior to issuance result in disturbance of more than one
DEC General Permit No. GP-0-20-001 Albany, NY 12233-3505 • Note: Preparation of the SWPPP requires close to final (NOI) of final approvals. acre of land.
engineering plans (e.g., grading plans) The SPDES program (and the MS4 review)
http://www.dec.ny.gov/chemical/43133. • Submit Notice of Intent (NOI) to NYSDEC prior to final site
html#Forms are the delegation of the NPDES program
plan approval and are thus not supplanted by Article VII.
• Will also require local approval in MS4 municipalities Therefore, the substantive reviews will
occur as part of the Article VII process
but filing of the NOI will be required
separately from the Environmental
Management and Construction Plan to
satisfy SPDES/NPDES.
NYS Highway Law, Article 3, § 52 NYSDOT Region 9 (Otsego, Delaware, If activity will be conducted in the right-of-way for a Varies Anticipated after The use of New York State highway right-
NYS Department of Transportation and Sullivan counties) State Route, an application for a Highway Work Permit is issuance of local of-way must be carried out and completed
(NYSDOT) Highway Work Permit 44 Hawley Street required. The required forms depend on the type of activity: discretionary in accordance with terms and conditions
Binghamton, NY 13901 installation of a driveway, utility work, drainage features, or approvals or of a highway work permit issued by the
New York State Vehicle and Traffic Law other. approval of the NYSDOT. Anyone who plans to do work
§ 385 Nicolas Choubah, PE, Environmental on any part of the state highway system,
Accommodation of Utilities Within State Regional Director Management its properties or right-of-way, must
Highway Right of Way (17 NYCRR, Part 131) Phone: 607.721.8116 and Construction obtain a permit. This is to ensure that
NYSDOT Region 8 (Ulster, Dutchess, Plan. work done on the right of way, and the
Orange, Putnam, Rockland, and finished projects, meet the standards and
Westchester Counties) policies of public safety, highway laws and
Eleanor Roosevelt State Office regulations, preservation and function of
Building the highway, and that the work is in the
4 Burnett Boulevard best interests of the traveling public as
Poughkeepsie, NY 12603 well as the owner of the project.
Lance MacMillan, PE, Regional Director
Phone: 845.431.5750
NYSDOT Region 11 (New York City)
Hunters Point Plaza
47-40 21st Street
Long Island City, NY 11101
Craig Ruyle, Regional Director
Phone: 718.482.4526
New York State Department of State Office New York State Dept. of State Consistency review is the tool that enables the Dept. Varies Consultation
of Planning and Development Consistency Review Unit of State to manage coastal uses and resources while initiated in
Coastal Zone Management Program 99 Washington Avenue facilitating cooperation and coordination with involved state, Q2 2021;
One Commerce Place, Suite 1010 federal, and local agencies. estimated time of
Federal/state consistency determination submission is CY
Albany, NY 12231-0001 Both the Hudson and Harlem Rivers are Designated
Email: [email protected] Waterways under the jurisdiction of the Coastal Zone 2022
Phone: 518.474.6000 Management Program.
Alternate: 518.474.6572 Process is initiated with submittal of Joint Application for
Permits to NYSDOS.


New York State Office of General Services Office of General Service, Bureau of Structures and utilities, including fill, located in, on, or Typically, 3-6 Consultation
Application for State Submerged Lands Land Management above state-owned lands now or formerly underwater months initiated in
Easement Corning Tower are regulated under the Public Lands Law. Permission Q2 2021;
26th Floor may be required to build on these lands, including docks, estimated time of
Empire State Plaza boathouses, or marinas, or to install utilities over or through. submission is CY
Albany, NY 12242 Application through Joint Application Form. Easement 2022
Email: [email protected] acquisition requirements will be determined by the Office of
Phone: 518.474.2195 General Service.
Process is initiated with submittal of Joint Application for
Permits to NYS Office of General Service.
Federal permits
§ 404 & 408 of the Clean Water Act US Army Corps of Engineers Review National Wetlands Inventory (NWI) maps Nationwide permit Consultation Section 404 regulates placement of
(Individual or Nationwide permits) New York District (completed). Status: NWI mapped wetlands and streams typically 6-8 months initiated in Q1 dredged or fill materials in federal
§ 10 of the Rivers and Harbors Act Regulatory Branch, Rm 16-400 identified on and near project. Individual permit 2021 jurisdictional waters/wetlands (i.e.,
26 Federal Plaza Conduct site reconnaissance to determine the presence/ typically 12-18 To be filed wetlands that have connectivity to
New York, NY 10278-0090 absence of any mapped or unmapped wetland resources. months concurrently with navigable waters of the US) by requiring
Phone: 917.790.8511 (Eastern Permit Environmental application for a permit to the Army Corps
Anticipated to be needed: 408 permit can be of Engineers. As part of their review of
Section, NYC area) up to 18+ months Management
Phone: 917.790.8411 (Western Permit • Conduct on-site wetland/stream delineations. and Construction a permit application, the Army Corps of
Section, all other counties) • Prepare/submit to Army Corps of Engineers a wetland Plan process Engineers is required to comply with the
Email: [email protected]. delineation report with a request for a jurisdictional Endangered Species Act and Section 106
mil determination of the National Historical Preservation
• Meet Army Corps of Engineers representative on site to Act, which requires consultation with the
review boundary lines. USFWS and State Historic Preservation
• Adjust wetland boundary lines and modify maps as Office. It is likely an individual permit will
necessary. be required.
• Prepare/submit joint application for permit to Army Corps
of Engineers for individual or nationwide permit.
– Provide record of US Fish and Wildlife Service (USFWS)
consultation
– Provide record of State Historic Preservation Office
consultation
– Army Corps of Engineers issues permit
Endangered Species Act, §7, §9, and §10 US Fish & Wildlife Service (USFWS) Consult with USFWS to determine species that may be USFWS response Unofficial inquiry Section 7 requires federal agencies to
Migratory Bird Treaty Act 16 (U.S.C. 703- New York Field Office present within the project area. Consultation valid for 90 occurs the same day conducted consult with USFWS prior to approving
711 and § 3 of Executive Order 13186, 50 3817 Luker Road days and can be updated online as needed. as official inquiry Report identified or funding an undertaking to ensure
CFR 10.13, regulations 40 CFR Parts 13 21 Cortland, NY 13045 Compare habitat of listed species to habitat at the project. Not anticipating one species: that undertaking is not likely to
Migratory Bird Permits Phone: 607.753.9334 need for federal Indiana Bat. jeopardize federally listed threatened
• If impact to federally listed threatened and endangered and endangered species’ critical habitat.
Bald and Golden Eagle Protection Act Fax: 607.753.9699 species habitat is expected, species-specific surveys may Incidental Take However, the
Email: [email protected] Permit or Habitat project is outside Section 9 prohibits activities that
Fish and Wildlife Consultation under §2 of be required. directly or indirectly affect threatened
• If species-specific survey identifies that the project is likely Conservation Plan the critical
the Fish and Wildlife Coordination Act habitat for this and endangered species. Section 10
to adversely affect threatened and endangered species, Authorizes the USFWS to issue permits
Coastal Barrier Resource System project may require submission of an application for an species.
to incidentally take threatened and
Incidental Take Permit. endangered species.
• If so, requires preparation of a Habitat Conservation Plan.

§106 of the National Historic Preservation See NYS Parks, Recreation, and See NYS Parks, Recreation, and Historic Preservation Law, 3-6 months Consultation will See NYS Parks, Recreation, & Historic
Act Historic Preservation Law, §14.09 §14.09 be initiated in Q2 Preservation Law, §14.09
(see NYS Parks, Recreation, and Historic 2021
Preservation Law, § 14.09, above)
US Department of Agriculture, Natural New York State Natural Resource Consultation required if Wetland Reserve Program lands are Varies Consultation will
Resource Conservation Service Conservation Service Office identified on proposed route be initiated in Q2
441 S. Salina Street, Suite 354 2021
Syracuse, NY 13202
Phone: 315.477.6505
National Park Service Easement National Park Service Easement required for utilities to pass over, across or Varies Consultation will
1849 C Street NW through a National Park System (e.g., Appalachian Trail) as be initiated in Q2
Washington, DC 20240 per 54 U.S.C. 100902 (a) and (b) 2021
David Vela, Deputy Director
Phone: 202.208.6843
Native American Tribal Groups Consultation To be confirmed by New York State National Historic Preservation Act of 1966, 16 U.S.C. et seq., Varies Consultation to
Historic Preservation Office § 106 be initiated as
part in Q2, 2021
US Coast Guard (USCG) Aids to Navigation USCG Private and/or temporary aids-to-navigation may be Varies Consultation will
Consultation Jason Tama, Commander, required for areas in the Hudson River and/or Harlem River be initiated in Q2
Sector New York Consultation typically initiated following issuance of project 2021
408 Atlantic Avenue approvals
Boston, MA 02110
National Oceanic and Atmospheric Greater Atlantic Regional Fisheries Section 7 Consultation regarding endangered and Varies Consultation
Administration (NOAA Fisheries), Office protected species under National Marine Fisheries Service initiated in Q21
National Marine Fisheries Service National Marine Fisheries Service jurisdiction Essential Fish Habitat 2021
55 Great Republic Drive

Gloucester, MA 01930
Phone: 978.281.9300

Potential municipal land use controls, permits, and approvals

Public
Zoning utility Wetland/
reg- defined Site plan Special Zoning aquatic Floodplain MS4
County Municipality ulations use approval use permit variance permit permit approval LWRP
Delaware Towns
County Colchester N/A N/A N/A N/A N/A N/A ✓ N/A N/A
Delhi ✓ ✓ ✓ ✓ ✓ N/A N/A N/A N/A
Hancock N/A N/A ✓ N/A N/A N/A ✓ N/A N/A
Hamden N/A N/A N/A N/A N/A N/A N/A N/A N/A
Sullivan Towns
County Bethel ✓ ✓ ✓ ✓ ✓ N/A ✓ N/A N/A
Callicoon ✓ N/A ✓ ✓ ✓ N/A ✓ N/A N/A
Forestburgh ✓ N/A ✓ ✓ ✓ N/A ✓ N/A N/A
Fremont N/A N/A N/A N/A N/A N/A N/A N/A N/A
Liberty ✓ ✓ ✓ ✓ ✓ N/A ✓ N/A N/A
Mamakating ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
Rockland ✓ ✓ ✓ ✓ ✓ ✓ ✓ N/A N/A
Thompson ✓ ✓ ✓ ✓ ✓ N/A ✓ N/A N/A
Villages
Monticello ✓ ✓ ✓ ✓ ✓ N/A ✓ N/A N/A
Orange Towns
County Deerpark ✓ ✓ ✓ ✓ ✓ N/A N/A N/A N/A
Cornwall ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ N/A
Goshen ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
Greenville ✓ N/A ✓ ✓ ✓ ✓ ✓ N/A N/A
Hamptonburgh ✓ ✓ ✓ ✓ N/A N/A ✓ ✓ N/A
Highlands ✓ N/A ✓ ✓ ✓ N/A ✓ ✓ N/A
Mount Hope ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
New Windsor ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
Walllkill ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
Wawayanda ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
Cities
Middletown ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
Villages
Cornwall-on-
Hudson ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
Table 11-2. Local permitting matrix.

Potential municipal land use controls, permits, and approvals

Public
Zoning utility Wetland/
reg- defined Site plan Special Zoning aquatic Floodplain MS4
County Municipality ulations use approval use permit variance permit permit approval LWRP
Dutchess Towns
County Fishkill ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ N/A
Putnam Towns
County Phillipstown ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ N/A
Rockland Towns
County Stony Point ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ ✓
West- Towns
chester Cortlandt ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ N/A*
County Greenburgh ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ N/A
Mount
Pleasant ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ N/A
Ossining ✓ N/A ✓ ✓ ✓ ✓ ✓ ✓ N/A
Cities
Peekskill ✓ N/A ✓ ✓ N/A N/A ✓ ✓ N/A
Yonkers ✓ ✓ ✓ ✓ ✓ N/A ✓ ✓ N/A
Villages
Buchanan ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ N/A*
Croton-on-
Hudson ✓ N/A ✓ N/A ✓ ✓ ✓ ✓ ✓
Ossining ✓ N/A ✓ ✓ ✓ N/A ✓ ✓ ✓
Bronx, Cities
New York,
Queens New York ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
Note: It is noted that local permits and approvals are generally limited to stormwater pollution prevention plan (SWPPP) and MS4 Plan approvals as the Article VII process pre-empts local approvals.
Regardless, Clean Path New York will work with the local governments throughout the permitting process to incorporate their input into the planning process and to obtain local permits when
possible. N/A indicates that local regulation information could not be found on public websites.
* Currently developing a joint LWRP, draft is anticipated in the first quarter of 2021,
Table 11-2 (continued). Local permitting matrix.

11.7. New Transmission project permitting General Work

description within
plan Transmission Length of proposed existing
line segment (miles) action ROW Work setting
Project description and location
Fraser 105 New Yes Terrestrial;
The proposed project involves the construction of a high-voltage
Substation to underground existing
direct current (HVDC) transmission line that will extend from the
Rock Tavern construction transmission line
Fraser Substation in the Delaware County, New York, to the Rainey Substation ROW
Substation in Queens County, New York (see Figure 11-1 below). The
Rock Tavern 11 New Yes Terrestrial; public
project will include a combination of underground and subaquatic
Substation to underground roadways and
cable transmission line segments and supporting interconnection
Hudson River construction ROWs
components. A description of the proposed transmission line (Town of New
segments is provided in Table 11-3; supporting interconnection Windsor)
infrastructure are described in Table 11-4. Hudson River 17 New No Submarine;
(Town of New underground Hudson River
Windsor) to construction
Buchanan
Substation
Buchanan 11 New Yes Terrestrial; public
Substation to underground roadways and
Hudson River construction ROWs
(Village of
Ossining)
Hudson River 20 New No Submarine;
(Village of underground Hudson River
Ossining) to construction
Harlem River
Harlem River 11 New Mixed Submarine:
to Rainey underground Harlem River,
Substation construction East River;
Terrestrial: public
roadways and
ROWs
Total ±175 miles
Table 11-3. Transmission line segments.
Figure 11-1. Proposed route overview map.

Interconnection infrastructure Location Regulatory review and permitting process

Alternating current (AC) to direct Adjacent to Fraser Substation Permitting plan approach
current (DC) converter station Successful projects require engaging regulatory agencies and
other stakeholders in honest, open, and meaningful dialogue early
DC to AC converter station Bronx and often throughout the life of a project. Identifying the least
environmentally intrusive and permittable project is the goal of such
CECONY interconnection Rainey Substation a program. Existing relationships between Clean Path New York and
[Primary Point of Interconnection agency staff and other stakeholders are important; however, Clean
(POI)] Path New York is committed to building relationships of trust specific
Table 11-4. Supporting interconnection infrastructure. to this project.
Building trust with agency personnel and other stakeholders will

For the purposes of this permitting plan, the project was defined as take time and dedication on the part of Clean Path New York. The
a 150-foot-wide corridor centered on the proposed transmission line permitting approach outlined herein has been successfully utilized
route (see Figure 11-1 ). The project crosses 35 municipalities and eight on Article VII infrastructure projects in the state of New York. The
counties including New York City (Bronx and Queens) and is made following plan strives to build understanding and acceptance of this
up primarily of existing transmission line ROWs, active agricultural project among the stakeholders who may participate in, or influence
fields, fallow/successional fields, public roads and developed areas, the project. To accomplish this goal Clean Path New York will do the
and wetlands/waterbodies. Further information on land use within the following:
project site is provided in subsequent sections of this plan.
• Coordinate with permitting agencies and other stakeholders
with regulatory jurisdiction of the project. Nongovernmental
Content of this plan
organizations will be identified to determine potential project
This plan identifies and describes the regulatory and permitting
concerns and address them as appropriate.
processes that may be applicable to the project. It also evaluates the
potential environmental review and permitting issues that may be • Coordinate activities with key internal disciplines: land and right-of-
identified during the development of the project, with a primary focus way, communication, regulatory, and engineering to quickly respond
on wetland and water resources, flood plains, ecological resources, to agency and other stakeholder input.
land use, and cultural resources that will require impact avoidance • Meet early with nongovernmental organizations and special interest
discussion and permitting under Article VII. The plan also includes groups, including potential project opponents, to hear their concerns
general conclusions and pertinent supporting materials provided in and express to them that Clean Path New York is interested in
Appendices 14 and 15. their input. These discussions often allow Clean Path New York to
alleviate and minimize concerns. Clean Path New York will attempt
to meet early with potential project opponents when concerns can
be readily addressed in the project planning.
• Inform agency personnel ahead of project milestones.
Early identification of issues, concerns, and opponents is extremely State and local permitting
important and often results in a more positive outcome for all The project is considered a major electric transmission facility under
parties. Being proactive allows Clean Path New York to work with Article VII of the New York State Public Service Law due to the fact
regulators and other stakeholders to identify meaningful solutions that it is greater than 10 miles in length and has over 100 kV design
to environmental concerns. At a minimum, Clean Path New York will capacity, therefore an application for a Certificate of Environmental
adhere to the following overarching principles when conducting Compatibility and Public Need (Certificate) will need to be submitted
consultation for the project. to the New York State Public Service Commission (PSC).
The New York State Legislature enacted Article VII in 1970 to establish
Proactivity. Clean Path New York will communicate early and a single forum for reviewing the need for, and environmental impact
often with agency personnel and stakeholders.
of, certain major electric and gas transmission projects. Article VII was
intended to be a “one-stop” permitting process covering all required
Transparency. Clean Path New York will provide state and local permits and is discussed in more detail below.
appropriate information to ensure agency personnel and other
Article VII of the New York State Public Service Law
stakeholders have the data required to provide meaningful input.
Article VII of the Public Service Law governs the siting of major utility
transmission facilities in the state. The law requires a full review of the
Credibility and professionalism. Clean Path need for a project and the environmental impacts of its siting, design,
New York will share accurate and timely information to build construction, and operation. The law also establishes a process for
relationships of trust and establish credibility. community engagement, allowing the public to participate with state
and local representatives in the review of the Article VII Application
(PSC, 2021).1 Clean Path New York is fully aware of these requirements
and have extensive experience shepherding projects through this
Responsiveness. Clean Path New York values input
process.
received and will ensure that input is considered. Clean Path New
York will be responsive to information requests and questions and The format of the application for this project will follow the Regulations
will communicate in an appropriate manner when information is for Electric Transmission and Gas Transmission Lines Ten Miles
available. or Longer, Chapter 1, Subchapter G, Certificates of Environmental
Compatibility and Public Need (16 NYCRR Parts 85 through 88). It is
anticipated that the following exhibits will be applicable:
Flexibility. Clean Path New York will be flexible in its
engagement process to accommodate the needs of individual • Exhibit 1: General Information Regarding Application
regulatory bodies and stakeholders. • Exhibit 2: Location of Facilities
• Exhibit 3: Alternatives
Respect. Clean Path New York will respect all who may be • Exhibit 4: Environmental Impact
interested in or who are affected by the project.
1
New York State Public Service Commission (PSC). 2021. The Certification Review Process for Major Electric and Fuel Gas Transmission Facilities. Available at: https://www3.dps.ny.gov/W/PSCWeb.
nsf/96f0fec0b45a3c6485257688006a701a/a021e67e05b99ead85257687006f393b/$FILE/19336071.pdf/Article%20VII%20Guide%20Web%2011-17%20Final.pdf (Accessed April 2021).
• Exhibit 5: Project Design Drawings • That the location conforms with applicable state and local laws,
• Exhibit 6: Economic Effects of Proposed Facility except that the Commission may refuse to apply local laws
determined to be unreasonably restrictive in view of the existing
• Exhibit 7: Local Ordinances
technology, cost, economics or needs of the consumers
• Exhibit 8: Other Pending Filings
• That the construction and operation of the facility is in the public
• Exhibit 9: Cost of Proposed Facilities interest
• Exhibits E1 through E6 (Transmission Line Description, Engineering
Justification, Underground Construction, Construction, Effects on Clean Path New York will develop an Environmental Management
Communications, Effects on Transportation) and Construction Plan, along with other post-certification filings, as
required. The Environmental Management and Construction Plan
The application for this project will be filed with the PSC and reviewed is the primary post-certification filing; however, the development
by the New York State Department of Public Service staff to determine of this plan may be initiated during the certification process. It will
completeness. If the application lacks required information, Clean address how the project will be constructed and how each Certificate
Path New York will be informed of the deficiencies and will submit condition will be achieved. It is anticipated that the Environmental
supplemental information until it is deemed complete. Management and Construction Plan for this project would minimally
consist of the following; however, additional elements may be added
Once the application is deemed complete, Public Statement
as identified through the consultation process:
Hearing(s) will be scheduled to solicit feedback and a Procedural
Conference will be held to determine the procedural path of the • Narrative report
application. Following a public comment period, evidentiary hearings • Plan and profile drawings
(if required), and the settlement of issues, a Certificate will be issued • Stormwater Pollution Prevention Plan (SWPPP)
via a PSC Order. This Certificate will contain conditions on how the • Construction methods
project can be constructed to avoid adverse environmental impacts.
• Environmental Best Management Practice plans (typical plans listed
To grant a Certificate, either as proposed or modified, the PSC must
below)
determine the following:
– Maintenance and protection of – Agricultural plan
• The facility avoids or minimizes to the extent practicable any traffic plans – Cultural resources mitigation
significant adverse environmental impact – Wetland and stream crossing plan
• The basis of the need for the facility plan – Unanticipated discovery plan
• The nature of the probable environmental impact – Habitat avoidance work plans
– Noise mitigation plan
• The facility avoids or minimizes to the extent practicable any – Subaquatic work plans
significant adverse agricultural impact – Vegetation management plan
• What part, if any, of the line shall be constructed underground
Once the Environmental Management and Construction Plan is
• The extent to which the facility conforms to the long-range plan for approved by the PSC, public notifications will be required and a Notice
the electric power grid and interconnected utility systems to serve to Proceed will be issued prior to the commencement of construction
the electric system with economy and reliability
(PSC, 2021). – Map(s) showing the specific geographic location of the proposed
facility
Coastal Zone Consistency Review – Site map(s) and diagram(s) drawn to scale showing all components
The New York State Department of State manages coastal uses of the activity and their location on the site
and resources, while facilitating cooperation and coordination with
– Written statement on the purpose and need for the activity
involved state, federal, and local agencies through the use of the
Coastal Zone Consistency Review process. The “consistency” of – Written analysis of alternatives to the proposed activity considered
a proposed activity with the New York State Coastal Management which support the selection of the proposed alternative
Plan is determined through a set of coastal policies and procedures – Any other supporting documentation submitted with the federal
designed to enable appropriate economic development while application
advancing the protection and preservation of ecological, cultural, • Copy of the final Environmental Impact Statement, if required by
historic, recreational, and aesthetic values (DOS, 2021a).2 the federal agency or by a state agency having jurisdiction over the
proposed activity.
The Coastal Management Plan has established statewide coastal zone
boundaries in accordance with the requirements of the Coastal Zone • Copies of all applications and related correspondence submitted
Management Act of 1972. Approximately 60 miles of the proposed to involved state agencies for permits, licenses, etc. (e.g., New York
project is located within New York’s Coastal Area Boundary. Because State Office of General Services, State Historic Preservation Office,
the project will require wetland permitting from the US Army Corps DEC, PSC).
of Engineers and consultation with the New York State Department Clean Path New York has preliminarily prepared much of this
of Environmental Conservation (NYSDEC), it will be subject to documentation and will submit all necessary data and information
consistency review by the DOS. The DOS requires the following
materials be submitted in any application for Consistency Certification:
• Completed and signed federal consistency assessment form, which The Waterfront Revitalization of Coastal Areas and Inland
includes a signed consistency certification and a written analysis of Waterways Act offers local governments the opportunity to
the proposed activity’s consistency with enforceable state coastal participate in the Coastal Management Plan on a voluntary basis by
policies. preparing and adopting Local Waterfront Revitalization Programs
• Copies of the application materials for a federal permit, license, or (LWRPs) (DOS, 2021b).3 LWRPs provide local governments the
other approval, including the following: opportunity to conduct a more detailed implementation of the
Coastal Management Plan using existing zoning and site plan review
– Detailed description of the proposed activity, its associated
processes. Any village, town, or city located along New York State’s
facilities, and coastal effects
coast or designated inland waterway can prepare or amend an
existing LWRP.
2
New York State Department of State (DOS). 2021a. Consistency Review. Office of Planning & Development. Available at: https://www.dos.ny.gov/opd/programs/consistency/index.html.
(Accessed April 2021).
3
New York State Department of State (DOS). 2021b. Local Waterfront Revitalization Program. Office of Planning & Development. Available at: https://www.dos.ny.gov/opd/programs/lwrp.
html#:~:text=The%20Waterfront%20Revitalization%20of%20Coastal,provides%20more%20detailed%20implementation%20of (Accessed April 2021).
is received, the DOS so it can begin its consistency review of the Clean Path New York’s easement Application for Use of Land
proposed project. Underwater to the Office of General Services will contain the following
applicable supplemental materials:
The Village of Croton-on-Hudson, the Village of Ossining, the City
of Peekskill, the Town of Stony Point, and the City of New York are • Joint Application for Permit form
the only five municipalities intersecting the project that have an • Plan and profile showing the proposed work or structures
LWRP approved by the New York Secretary of State. Although not
• Map of the project showing the location of proposed structure(s), the
currently enacted, the Town of Cortlandt and the Village of Buchanan
upland property of the applicant and those of adjoining properties
are currently developing a joint LWRP, with the goal of having a draft
along the waterfront
prepared in the second quarter of 2021. For all other municipalities
within the project that lack an approved LWRP, the action will fall • Metes and bounds description of the land applied for, including the
under the jurisdiction of the DOS (DOS, 2021b). desired width of the proposed easement
• Certified copy of the deed(s) adjacent upland or the consent of the
Lands under water owner of such adjacent upland
Most navigable waters, including the beds of navigable waters, are • Copy of adjoining shorefront deed(s) and a copy of the applicable
owned by the state of New York and are held in trust by the Office of tax map section
General Services. The Office of General Services has the authority • Completed environmental assessment form
to regulate public and private use of the state’s underwater lands
in a manner that is consistent with the public interest in navigation, Additionally, pursuant to Section 1301 of the New York State Charter
commerce, recreation, etc. In addition, structures and utilities, and Title 22 of the New York City Administrative Code, the New York
including fill, located in, on, or above state-owned lands now or City Department of Small Business Services (SBS) is responsible
formerly underwater, are regulated under the Public Lands Law (Office for issuing waterfront permits for all maritime and non-maritime
of General Services, 2021).4 construction related to improvement or maintenance for all city-owned
waterfront properties. New permit applications consist of a completed
The Office of General Services requires an easement to install utilities SBS Intake Checklist and PW1 form, three sets of drawings, and other
above or below lands now or formerly under the waters of state- required information and forms for review by SBS. Once the project’s
owned waterbodies. Clean Path New York will provide notice of filing applications are reviewed by the Waterfront Permits Unit, objections,
an easement application at least 20 days prior to filing an easement if any, will be resolved by Clean Path New York. Upon final acceptance
application with the Office of General Services. The notice will be from the SBS, a PW2 form and current ACORD Insurance Certificates
provided to the following: will be submitted for a work permit (Office of General Services,
• The city, town, or village in which the proposed project is located 2021). As noted previously, the Article VII process pre-empts local
permitting authority; however, Clean Path New York with work with
• The owners of any properties immediately adjacent to the project
local governments throughout the permitting process to incorporate
area
their input into the planning process and to obtain local permits when
• The owners of any properties immediately adjoining the shorefront possible.
where any project cable, conduit, or pipeline will enter or leave the
water Federal permitting
4
New York State Office of General Services (OGS). 2021. Lands Now or Formerly Underwater. Available at: https://ogs.ny.gov/real-estate/lands-now-or-formerly-underwater (Accessed April 2021).
Clean Water Act State Pollutant Discharge Elimination System

Federal wetland/stream permits from the Army Corps of Engineers The National Pollutant Discharge Elimination System (NPDES)
would likely be required for any unavoidable impacts to jurisdictional regulations authorize states, tribes, or territories to administer the
wetlands and streams resulting from the construction or operation NPDES program locally. New York has an authorized State NPDES
of the project.5 The installation of structures, caisson foundations, program, referred to as the State Pollutant Discharge Elimination
manholes, buried cable, culverts, access roads, and other fill in System (SPDES). This is a federally delegated process, so approval
jurisdictional wetlands would be considered an impact. takes place outside the context of Article VII.
The project is situated within the New York City District of the Army If a given activity disturbs more than one acre of soil (which will be the
Corps of Engineers, coordination with this office will be required to case for the project), the project will be required to seek authorization
obtain permit(s). The recently issued Nationwide Permit 57 (Electric to construct in accordance with the SPDES general permit for
Utility Line and Telecommunications Activities) may be applicable if construction issued by DEC (DEC, 2021a).6 The permit application
project-related impacts to federal jurisdictional wetlands can be kept must address stormwater management and associated sediment and
under 0.5 acres for each single and complete project (e.g., crossing). erosion control measures. These permits can be issued relatively
quickly following submittal of an SWPPP and associated Notice of
However, project disturbance at individual locations are anticipated to Intent (NOI). Additionally, the DEC SPDES general permit is further
exceed this threshold and therefore an Individual Permit is anticipated. implemented at the local level in municipalities designated as being
In addition to the Individual Permit (Section 404), the project crosses under municipal separate storm sewer system (MS4) regulations. Work
Section 10 navigable waters which may be subject to Section 408 within MS4 communities (see Local Law Matrix, Table 11-2) requires
permitting requirements. The time frame of 12 to 24 months to obtain SWPPP review and approval by a locally designated MS4 authority
an Individual Permit and Section 408 Permit approvals is reasonably (e.g., Town Engineer).
foreseeable.
The Army Corps of Engineers is obligated to consider the project’s National Environmental Policy Act
potential effect on cultural resources in accordance with Section The National Environmental Policy Act (NEPA) requires federal agencies
106 of the National Historic Preservation Act. This would require to assess the environmental effects of their proposed actions prior to
consultation with the State Historic Preservation Office, Native making decisions. All agencies carrying out major federal actions are
American Tribal Nations, and any other applicable parties requesting responsible for complying with the requirements of NEPA. The USACE
status during Section 106 Consultation. Consultation with the US will likely be the lead agency and will complete the necessary level
Fish and Wildlife Service (USFWS) to assure compliance with Section of NEPA review to issue their permits. Clean Path New York will work
7 of the Endangered Species Act would also be required. See the through the required NEPA process, concurrent with the Article VII
completed Permitting Matrix (Table 11-1) for additional information. process.
5
Please note that State wetland and stream permits are required if projects impact wetlands or streams under DEC jurisdiction in accordance with Article 15 and Article 24 of the Environmental
Conservation Law. However, these permits are not issued when the Article VII process is utilized; rather, Clean Path New York will consult with these agencies to ensure protective measures for
these resources are incorporated into the Article VII process.
6
New York State Department of Environmental Conservation (NYSDEC). 2021a. State Pollutant Discharge Elimination System (SPDES) Permit Program. Available at: https://www.dec.ny.gov/
permits/6054.html (Accessed April 2021).
Other federal permits

Watershed River systems
Other federal permits, consultations, and approvals may be required
as indicated in the Permitting Matrix (Table 11-1). Hudson River Lower Hudson (HUC 2030101)
watersheds Hudson-Wappinger (HUC 2020008)
Significant resources/issues Rondout (HUC 2020007)
The resource/issue evaluation conducted to support this plan
Bronx (HUC 2030102)
addresses water resources, flood zones, ecological resources,
land use regulations, agricultural land, cultural resources, and Long Island Sound Northern Long Island (HUC 2030201)
environmental justice concerns within and/or adjacent to the Delaware River East Branch Delaware (HUC 2040102)
proposed project. Clean Path New York will continue to refine this watersheds Middle Delaware-Mongaup-Brodhead
evaluation during agency consultation to minimize environmental (HUC 2040104)
conflicts associated with the project.
Upper Delaware (HUC 2040101)
Data collection Table 11-5. Watersheds over the length of the project.
Existing mapping and databases were reviewed to identify significant
resources and potential permitting issues in the vicinity of the Watersheds, wetlands, and streams
proposed project.
Watersheds
Sources of information included the following: Over its 175-mile length, the project intersects eight different
• US Geological Survey topographic mapping watersheds. These watersheds outlet to the Atlantic Ocean through
three different river systems, as detailed in Table 11-5.
• Natural Resources Conservation Service web soil survey
• National Register of Historic Places listed sites and historic landmarks A portion of the project occurring in Delaware County passes through
• DEC freshwater wetland mapping the New York City water supply watershed. Certain development
activities within New York City’s Delaware System Reservoir Basin
• USFWS National Wetlands Inventory (NWI) mapping
are regulated by the NYC Department of Environmental Protection
• Federal Emergency Management Agency (FEMA) National Flood (NYCDEP). The NYCDEP has regulatory authority over the following
Hazard Layer types of actions that may be applicable to the project:
• DEC state lands/DEC geographic information system (GIS) database
• Construction of a paved driveway or other impervious surfaces
• State and National Registers of Historic Places
adjacent to a stream
• US Geological Survey 2016 National Land Cover Database
• Crossing, diverting, or piping a stream
• DEC Environmental Resource Mapper and New York Nature Explorer
• Construction of a house or other structure adjacent to a stream or
online databases
watercourse
• USFWS Information for Planning and Consultation website
• Plans for development or sale of land that will result in the

disturbance of five or more acres of total land area as described
in the definition of “larger common plan of development or sale”
in Table 1 of the General Permit No. GP-0-10-001. See Watershed
Regulations § 18-39(b)(3)(I).
• Construction of a subdivision. See Watershed Regulations § 18-39(b)
(3)(ii).
• Construction of a new industrial, institutional, municipal, commercial,
or multifamily residential project that will result in creation of an
impervious surface totaling over 40,000 square feet in size. See
Watershed Regulations § 18-39(b)(3)(iii).
• A land clearing or land grading project, involving two or more acres,
located at least in part within the limiting distance of 100 feet of a
watercourse or wetland, or within the limiting distance of 300 feet of
reservoir, reservoir stem, or controlled lake or on a slope exceeding
15%. See Watershed Regulations § 18-39(b)(3)(iv).
• Construction of an impervious surface for a new road, as required
by paragraph (a)(6) of Section 18- 39. See Watershed Regulations §
Figure 11-2. The Hudson River is a vital waterway stretching from Upstate New York to New
18-39(b)(3)(vii).
York City. • Construction of an impervious surface in the West of Hudson
watershed within a village, hamlet, village extension, or area zoned
• A land clearing or land grading project, involving two or more acres, for commercial or industrial uses, as required by paragraph (a)(8) of
located at least in part within the limiting distance of 100 feet of Section 18-39. See Watershed Regulations § 18-39(b)(3)(viii).
a watercourse or wetland, or within the limiting distance of 300 • Up to 25% expansion of an existing impervious surface at an existing
feet of a reservoir, reservoir stem, or controlled lake or on a slope commercial, institutional, municipal, or industrial facility within the
exceeding 15% limiting distance of 100 feet of a watercourse or wetland, as required
in subdivision (a)(4)(iii) of Section 18-39 See Watershed Regulations §
Additionally, the NYCDEP requires that a SWPPP be prepared and 18- 39(b)(3)(ix).
submitted to the department for review and approval when the
following development activities, which may be applicable to the
project, are proposed within the watershed (NYCDEP, 2011):8
8
New York City Department of Environmental Protection (NYCDEP). 2011. Applicants Guide to Stormwater Pollution Prevention Plan. Available at: https://www1.nyc.gov/assets/dep/downloads/pdf/
watershed-protection/regulations/AppGuide_SWPPP2-2011_Final.pdf (Accessed April 2021).
Streams and surface waters level summary of state-protected streams crossed by the project is
Under Article 15 of the Environmental Conservation Law (Protection provided below. Impacts to the bed or banks of these streams will
of Waters), the DEC has regulatory jurisdiction over any activity that require state approval, as described above.
disturbs the bed or banks of protected streams. Small lakes and
ponds with a surface area of ten acres or less, located within the • Delaware County: approximately 3,255 feet of Class C(T)/C(TS)
course of a stream, are considered part of a stream and are subject streams
to regulation under the stream protection category of Article 15. • Dutchess County: approximately 31 feet of Class B streams
However, it is noted that Article 15 requirements will be incorporated • Orange County: approximately 1,153 feet of Class A/A(T) streams,
into the Article VII process and the DEC will not issue a separate 6,847 feet of Class B streams, and 140 feet of Class C(T) streams
Article 15 permit. • Putnam County: approximately 7,032 feet of Class B streams
Protected streams have been assigned the following classifications • Rockland County: approximately 1,871 feet of Class SB streams
or standards: AA, AA(t), A, A(T), B, B(T), or C(T) (6 NYCRR Part 701). A • Sullivan County: approximately 156 feet of Class AA(T) streams,
classification of AA or A indicates that the best use of the stream is 4,966 feet of B/B(T)/B(TS) streams, and 1,235 feet of C(T)/C(TS)
as a source of water supply for drinking, culinary, or food processing streams
purposes; primary and secondary contact recreation; and fishing. The • Westchester County: approximately 729 feet of Class B Streams
best usages of Class B waters are primary and secondary contact and 3,202 feet of Class SB streams
recreation and fishing. The best usage of Class C waters is fishing.
Streams designated (T) indicate that they support trout, while those Mapped wetlands
designated (TS) support trout spawning. The Freshwater Wetlands Act (Article 24 and Title 23 of Article 71 of
the Environmental Conservation Law) gives the DEC jurisdiction over
The DEC also classifies marine waters. A classification of SA indicates
state-protected wetlands and areas within 100 feet of state-protected
a best usage for shell fishing for market purposes, swimming and
wetlands (100-foot Regulated Adjacent Areas). The Freshwater
other recreation, and fishing. A classification of SB indicates a best
Wetlands Act requires the DEC to map all state-protected wetlands
usage for swimming and other recreation, and fishing. A classification
(typically over 12.4 acres) to allow landowners and other interested
of SC indicates a best usage for fishing. A classification of SD
parties a means of determining where state jurisdictional wetlands
indicates a best usage for fishing, but these waters may not support
exist (DEC, 2021c).9 However, similar to the process noted for Article
fish propagation (DEC, 2021b).8
15 requirements, Article 24 requirements will be incorporated into the
DEC stream classification maps indicate that 107 state-protected Article VII process and the DEC will not issue a separate Article 24
streams (i.e., streams with C(T) classification or higher) intersect permit. Review of DEC freshwater wetland mapping indicates that 25
the project, including eight streams that are designated Class state-regulated wetlands occur within or near the project. A summary
A/A(T)/AA(T), 53 that are designated class B/B(T)/B(TS), 27 that are of state-regulated wetlands crossed by the project by county is
designated C(T)/C(TS), and 18 that are designated SB. A county- provided below and additional information is provided in Table 11-6.
8
NYSDEC. 2021b. Protections of Waters Program. Available at: https://www.dec.ny.gov/permits/6042.html (Accessed April 2021).
9
NYSDEC. 2021c. Freshwater Wetlands Program. Available at: https://www.dec.ny.gov/lands/4937.html (Accessed April 2021).
• Orange County: approximately 24 acres of DEC-mapped wetlands

Wetland-ID Class Acres Latitude Longitude County
• Sullivan County: approximately 31.3 acres of DEC-mapped wetlands
CO-1 2 1.8 41.4792 -74.7304 Orange
CO-2 2 0.6 41.4834 -74.1102 Orange • Westchester County: approximately 3.2 acres of DEC-mapped
wetlands
GO-20 2 2 41.4403 -74.3379 Orange
GO-23 3 2.7 41.4476 -74.2865 Orange A review of USFWS NWI mapping (USFWS, 2021a;10 Appendix 14,
GO-30 2 2.3 41.4264 -74.3623 Orange Figure 3 ) indicates 240 NWI features or streams are crossed by the
MB-18 1 1.5 41.4666 -74.2227 Orange project. A summary of NWI-mapped features crossed by the project
MB-20 3 0.2 41.4668 -74.1872 Orange by county is provided below.
MB-22 3 0.2 41.4675 -74.1807 Orange • Bronx County: approximately 73.6 acres of NWI features
MB-23 3 0.2 41.4678 -74.1753 Orange • Delaware County: approximately 7.6 acres of NWI features
MB-30 3 1.2 41.4527 -74.2442 Orange • Dutchess County: approximately 8.7 acres of NWI features
MD-17 4 0.6 41.4246 -74.4858 Orange • New York County: approximately 96.7 acres of NWI features
MD-18 2 1.9 41.4229 -74.4558 Orange
• Orange County: approximately 187.1 acres of NWI features
OT-18 3 0.8 41.4247 -74.5459 Orange
• Putnam County: approximately 70.3 acres of NWI features
OT-19 2 2.5 41.4231 -74.499 Orange
• Queens County: approximately 4.8 acres of NWI features
OT-5 2 5.4 41.4799 -74.5749 Orange
• Rockland County: approximately 26.1 acres of NWI features
HA-5 3 1.4 41.9043 -74.9229 Sullivan
• Sullivan County: approximately 33 acres of NWI features
LM-18 2 3.3 41.8986 -74.866 Sullivan
LW-30 2 0.01 41.7565 -74.7602 Sullivan • Westchester County: approximately 367.4 acres of NWI features
LW-28 2 1.4 41.764 -74.7667 Sullivan Federal wetland/stream permits will be required for any unavoidable
MO-62 2 15.4 41.6364 -74.6945 Sullivan impacts to jurisdictional wetlands and streams associated with the
RO-7 3 1.3 41.90432 -74.923 Sullivan project construction (see Permitting Matrix, Table 11-1). Timeframes
WL-19 2 3.8 41.7069 -74.7529 Sullivan and required studies to obtain these permits has been considered and
WL-31 3 1.2 41.68441 -74.7623 Sullivan incorporated into the project schedule.
WL-7 2 3.5 41.7324 -74.7593 Sullivan
Flood zones
H-3 1 3.3 41.1904 -73.8791 Westchester
According to the FEMA website, Special Flood Hazard Areas are
Table 11-6. DEC-mapped wetlands crossed by the project. defined as areas that will be inundated by a flood event having a 1%
chance of being equaled or exceeded in any given year (i.e., base
10
United States Fish and Wildlife Services (USFWS). 2021a. Wetlands Mapper. National flood or 100-year flood). Special Flood Hazard Areas are labeled as
Wetlands Inventory. Available at: https://www.fws.gov/wetlands/data/mapper.html (Accessed Zones A, AO, AH, A1-A30, AE, A99, AR, AR/AE, AR/AO, AR/A1-A30,
April 2021).
AR/A, V, VE, and V1-V30. Moderate flood hazard areas, labeled Zones
11
Federal Emergency Management Agency (FEMA). 2021. Flood Zones. Available at: https://
www.fema.gov/glossary/flood-zones (Accessed April 2021).
B or X, are the areas between the limits of the base flood and the
0.2%-annual-chance (i.e., 500-year) flood (FEMA, 2021).11
Clean Path New York avoided flood zones to the degree possible – Approximately 2,688 feet are within a 0.2% annual chance flood
during preliminary routing. In total, approximately 45 miles of the hazard.
proposed transmission line are located within a Special Flood Hazard • Putnam County: Approximately 19,550 feet of the reported footage
Area and approximately 92 miles are located within a moderate flood below constitutes subaquatic footage within the Hudson River.
hazard area (see Figure 4 in Appendix 14). However, it is noted that
– Approximately 19,550 feet of the project corridor are within a
of these higher-risk areas, the majority of the mileage is attributable
mapped AE Zone associated with the Hudson River.
to subaquatic portions of the project A more in-depth description of
FEMA flood zones within the project is provided below.12 • Rockland County: Approximately 6,369 feet of the reported footage
below constitutes subaquatic footage within the Hudson River.
• Bronx County: Approximately 17,330 feet of the reported footage
– Approximately 6,639 feet of the project corridor are within a
below constitutes subaquatic footage within the Hudson (14,042
mapped AE Zone associated with the Hudson River.
feet), East (3,125 feet), and Harlem Rivers (163 feet).
• Queens County: Approximately 1,314 feet of the reported footage
– Approximately 3,456 feet are within an AE flood zone.
below constitutes subaquatic footage within the East River.
– Approximately 856 feet are within an VE flood zone.
– Approximately 1,466 feet are within an AE flood zone.
– Approximately 16,879 feet are within open water.
– Approximately 390 feet are within an VE flood zone.
– Approximately 1,505 feet are within an X flood zone.
– Approximately 1,876 feet are within a 0.2% annual chance flood
– Approximately 4,214 feet are within a 0.2% annual chance flood
hazard.
hazard.
• Dutchess County: Approximately 2,579 feet of the reported footage
• Sullivan County.
below constitutes subaquatic footage within the Hudson River.
– Approximately 1,019 feet are within an A flood zone,
– Approximately 2,579 feet of the project corridor is within a
mapped AE Zone associated with the Hudson River. – Approximately 1,771 feet are within an AE flood zone,
• New York County: Approximately 32,098 feet of the reported footage – Approximately 223,752 feet are within an X flood zone,
below constitutes subaquatic footage within the Hudson River. – Approximately 1,151 feet are within a 0.2% annual chance flood
– Approximately 31,658 feet of the project corridor are within a hazard.
mapped AE Zone associated with the Harlem River. • Westchester County: Approximately 106,278 feet of the reported
– Approximately 440 feet are within open water. footage below constitutes subaquatic footage within the Hudson
River.
• Orange County: Approximately 43,320 feet of the reported footage
below constitutes subaquatic footage within the Hudson River. – Approximately 109,282 feet are within an AE flood zone.13
– Approximately 1,687 feet are within an A flood zone. – Approximately 51,038 feet are within an X flood zone.
– Approximately 59,434 feet are within an AE flood zone. – Approximately 1,712 feet are within a 0.2% annual chance flood
hazard.
12
Based on publicly available online mapping. In instances where a county (such as Delaware County) is missing, it should not be assumed that one is not present. Not all FEMA maps have been
digitized and additional document review will be required during planning and permitting.
13
Approximately 90,816 feet of the AE flood zone are within the Hudson River.
To the extent practicable, efforts have been made to minimize siting Administration (NOAA) threatened and endangered fisheries list
new aboveground facilities within the floodways. No facilities will was consulted to determine which federally listed aquatic species or
be constructed within mapped floodway zones unless it can be habitat may be known to occur within the project.
demonstrated through hydrologic and hydraulic analyses that the
development will not result in any increase in flood levels during the A summary of our findings is presented in Table 11-7. Clean Path New
base flood. Generally, floodway impacts will be avoided due to the York will also consult with DEC’s Natural Heritage Program to identify
underground nature of the facility. If work in floodways is required, state-listed species with the potential to occur near the project.
Clean Path New York will implement best management practices and
Transmission
related erosion control measures to avoid temporary and long-term Listed species Status line segment
construction-related impacts. Clean Path New York will obtain local
Indiana Bat Endangered 1, 2, 3
flood plain development permits prior to construction as necessary.
(Myotis sodalist)
Ecological resources Northern Long-eared Bat Threatened 1, 2, 3
The USFWS maintains the Information, Planning, and Consultation (Myotis septentrionalis)
(IPaC) system, which aided Clean Path New York in identifying Piping Plover Threatened 3, 4, 5
potential project conflicts with federally listed threatened and (Charadrius melodus)
endangered species and habitat areas (USFWS, 2021b).14 The IPaC Red Knot Threatened 5
mapper was consulted to determine which federally listed threatened, (Calidris canutus rufa)
endangered, or candidate species may potentially occur in the vicinity Roseate Tern Endangered 5
of the project. Additionally, the National Oceanic and Atmospheric (Sterna dougallii dougallii)
Bog Turtle Threatened 1
To support an appropriate level or resolution in the data resulting (Clemmys muhlenbergii)
from querying these databases, the proposed project was broken Dwarf Wedgemussel Endangered 1
into five segments based on ecological characteristics and the type (Alasmidonta heterodon)
of work proposed: Atlantic Sturgeon (Acipenser Endangered 3, 4
oxyrhynchus oxyrhynchus)
1. Fraser Substation to Rock Tavern Substation
2. Rock Tavern Substation to Hudson River (Town of New Windsor) Shortnose Sturgeon Endangered 3, 4
(Acipenser brevirostrum)
3. Hudson River (Town of New Windsor) to Harlem River
Small Whorled Pogonia Threatened 1, 2, 3
4. Harlem River to Mott Haven Substation (Isotria medeoloides)
5. Mott Haven Substation to Rainey Substation
Seabeach Amaranth Threatened 5
(Amaranthus pumilus)
Notes: Transmission line segments for this analysis include (1) Fraser Substation to Rock
14
USFWS. 2021b. Information for Planning and Consultation. Available at: https://ecos.fws.gov/ Tavern Substation, (2) Rock Tavern Substation to Hudson River (Town of Windsor), (3) Hudson
ipac/ (Accessed April 2021). River (Town of Windsor) to Harlem River, (4) Harlem River to Mott Haven Substation, and (5)
15
As identified by the USFWS’s the IPaC system. Mott Haven Substation to Rainey Substation.
Table 11-7. Federally listed species with a potential presence in the vicinity of the project.15
Under the SCFWH program, a site is considered significant if it serves

one or more of the following functions:
• Is essential to the survival of a large portion of a particular fish or

wildlife population
• Supports populations of species that are endangered, threatened or
of special concern
• Supports populations having significant commercial, recreational, or
educational value
• Exemplifies a habitat type that is not commonly found in the state or
in a coastal region
The proposed transmission line segment running from the Rock
Tavern Substation to the Rainey Substation will pass through four
SCFWHs identified by the DOS. These identified habitats, along with
the approximate distance anticipated to be impacted by the project
Figure 11-3. The bog turtle is a threatened species located around the project area.
are detailed below:
• Lower Hudson Reach, 6.7 miles

Permanent loss of habitat is not anticipated as a result of the
• Croton River and Bay, 0.3 miles
construction and operation of this project. The design of this project
minimizes new disturbance by using existing cleared ROWs and • Hudson Highlands, 16.2 miles
installing new underground transmission lines within previously • Moodna Creek, 0.1 miles
developed corridors. Furthermore, Clean Path New York is committed
As the proposed project is anticipated to be subject to Coastal
to implementing construction-phase activities in a manner that
Zone Consistency Review under federal and state laws, a habitat
minimizes the disturbance to habitats of federally listed species
impairment test will be required for those sections of the project that
identified above. Particular attention has been given to minimizing
are located within the four SCFWHs identified above (DOS, 2021b).
impacts to aquatic habitats as described below.
Aquatic considerations and potential management methods that may
need to be incorporated into the design of the project or be provided
Aquatic habitat
as compliance filings to support Article VII and/or federal permitting
Throughout the State’s coastal area, 250 Significant Coastal Fish
are summarized in Table 11-8 on the next page.
and Wildlife Habitats (SCFWHs) have been designated by the DOS’s
Division of Coastal Resources (DOS, 2021c).16
16
DOS. 2021c. Significant Coastal Fish & Wildlife Habitats. Office of Planning & Development. Available at: https://www.dos.ny.gov/opd/programs/consistency/scfwhabitats.html (Accessed April
2021).
Table 11-8. Acquatic considerations and management methods.
Consideration Description Management method

Time of year work To avoid adverse impacts to habitat (such as sturgeon habitat), Prepare an Aquatic Work Plan and
restrictions to avoid considerations will be made to conduct dredging (if needed) during the late schedule to demonstrate adherence
adverse impacts to fish summer/fall. to time of year restrictions.
habitat
Soil dredging and impacts As part of project permitting, considerations for best management practices Prepare a Dredging Plan.
to riverbed to be implemented for dredging and/or riverbed disturbance. This plan
should include standards and methods for soil removal and coordinating
environmental characterization of riverbed soils and identification of
disposal sites, as needed.
Turbidity during Establish monitoring protocols and standards for measuring total suspended Prepare a Water Quality Monitoring
construction solids during construction activities. Address and outline methods for Plan.
collecting samples during construction activities and reporting.
Enforce conditions and Outline procedures, monitoring, and compliance requirements, including Prepare an Environmental
demonstrate compliance frequent and routine inspections. The plan is intended to ensure compliance Monitoring and Compliance Plan
with permit conditions with certification conditions, etc., and will communicate procedures and that summarizes environmental
protocols. Define and outline pre-construction training (if needed), agency protection requirements that must
consultations, and construction standards. be implemented to satisfy various
permit conditions.
Navigational risk Initial review indicates the project site does not appear to be located with If warranted, prepare a Navigational
mapped navigational channels. However, detailed coordination with NOAA Risk Assessment.
and/or the Coast Guard will occur.
Land use and local laws electric utility ROWs on undeveloped or agricultural land. From the
Land use Rock Tavern Substation, the project traverses an increasing amount of
The project extends over 175 miles from the Catskills region of New developed land (i.e., residential and commercial) before reaching the
York to New York City. Both land use and development intensity are western shoreline of the Hudson River. From this point to the southern
highly variable across the project. From the Fraser Substation to the terminus at Rainey Substation, the surrounding land uses continue to
Rock Tavern Substation, the project is primarily located within existing transition to more intensive development.
Local laws It is anticipated that a Phase 1A survey, and a Phase 1B Survey will
Pursuant to Public Service Law § 130, no municipal agency approval, be required for areas of new ground disturbance. Documentation
permit, or consent is required for the construction or operation of a of the Phase 1B Survey will be provided within the Environmental
facility subject to Article VII, unless otherwise required by the PSC. Management and Construction Plan.
However, Public Service Law § 126(1)(f) requires that the PSC find “that
the location of the facility as proposed conforms to the applicable Electric and magnetic fields
state and local laws and regulations…” Electric and magnetic fields (EMF) are invisible lines of force that
surround power lines and are associated with the use of electrical
In Exhibit 7 of the Article VII application, Clean Path New York will power. Electric fields are produced by voltage and increase in
demonstrate compliance with any applicable substantive local laws strength as the voltage increases. Magnetic fields result from the
or request a waiver. Waivers can be granted by the PSC for laws that flow of current through wires and increase in strength as the current
are determined to be unreasonably restrictive in view of the existing increases. Both electric and magnetic fields decrease rapidly as the
technology, cost, economics, or needs of the consumers. Clean Path distance from the source increases.
New York will comply with local laws or will request waivers from the
PSC where it cannot do so.
Cultural resources
As identified in the Permitting Matrix (see Table 11-1), authorization
under Chapter 14.09 of the New York State Historic Preservation
Act and Section 106 of the National Historic Preservation Act will be
required for the project to support Article VII and any federal wetland
permitting.
National Register of Historic Places listings in New York State17 were

reviewed to identify listed sites and state parks within three miles
of the project (see Figure 5 in Appendix 14). As with other sensitive
resources, Clean Path New York avoided these sites to the degree
possible during planning and siting of the project.
Clean Path New York will consult with the State Historic Preservation
Office to determine if the New York State Historic Preservation Office
Transmission Line Guidance Project Types and Associated Survey
Requirements apply to this project and what studies will be required
to support the State Historic Preservation Office’s review.
Figure 11-4. Gantry Plaza State Park is located in Long Island City and is within three miles of
the project site.
Based on October 2018 data provided by the New York State Office of
17
Parks, Recreation and Historic Preservation.

Clean Path New York has completed preliminary EMF analysis • Aquatic ecology and threatened and endangered species. Portions
associated with portions of the land-based sections of the project. of the project include subaquatic cable installations in the Hudson
However, additional studies are ongoing for land-based and River, Harlem River, and East River. Agency correspondence
submarine sections of the project. These studies are being refined conducted to date has identified Atlantic and shortnose sturgeon
as routing and design is completed. Clean Path New York will consult habitat occurring, or potentially occurring, within the riverine
with the PSC regarding input parameters throughout this process. The portions of the project. Clean Path New York will prioritize
project will be designed to comply with the PSC’s EMF guidelines. consultation with USFWS, NOAA, and DEC to determine the extent
Final EMF reports will be made available during the Article VII of habitat, the need for, and potential scope of surveys for each
process. listed species. Additionally, Clean Path New York will consult with
the agencies to identify work plans and Best Management Practices
Environmental justice to be included in the Environmental Management and Construction
A detailed assessment of environmental justice considerations Plan. If it is determined that any portion of the project represents
surrounding the project are discussed in Section 15 of this proposal. “occupied habitat” for any of these species, preparation of a Net
Conservation Benefit Plan may be required as part of the Article VII
Conclusions process. In addition, time-of-year restrictions for certain construction
Based on the analyses conducted as part of this initial permitting activities will likely be required; Clean Path New York will continue
review, the following are several key activities that Clean Path New to coordinate with these agencies identify and adhere to potential
York will perform to progress the permitting and project: construction constraints and requirements.
• Agency coordination. The project spans numerous municipalities • Cultural resources and visual impacts. Clean Path New York has
and is within the jurisdiction of several state or municipal agencies attempted to avoid known historic resources during the routing
Clean Path New York will demonstrate compliance with local phase of the project. It is anticipated that Phase 1A and Phase 1B
regulations pursuant to Article VII. The variability of local laws, high surveys will be conducted. Clean Path New York will consult with the
number of host municipalities, and the need to comply with SPDES State Historic Preservation Office and complete Phase 1A studies
and MS4 regulations will require substantial coordination during early in the development process.
planning and permitting. Clean Path New York will seek out early • Wetlands. Existing wetland and soils mapping indicates the
engagement with agencies to determine the studies that may be likelihood of wetlands occurring along the project, including wetland
required for the Article VII application and the level of construction and waterbodies anticipated to be regulated by the Army Corps
detail that will be required to be included in the Environmental of Engineers and the state of New York. Clean Path New York will
Management and Construction Plan. complete reconnaissance-level wetland investigations early in the
siting process to design and develop impact avoidance measures,
where feasible.
11.8. Resources portfolio permitting plan Article VII is a separate permit applicable to transmission lines that
meet specific length and voltage minimums. In the case of renewable
and progress to date energy generation projects permitted under Article 10, the generation
The Resources in this portfolio share a very similar set of required tie-line (gen-tie) between the generation project area and the point of
permits, which differ slightly from one project to the next based on the interconnection to the grid has in certain cases been permitted under
finer points of the project layout. Article VII. However, under 94-C, a renewable project does not need
to seek a separate permit for its gen-tie line under Article VII, unless it
The generation projects in this portfolio share a very similar set of is over 10 miles in length. The gen-tie line is included in the evaluation
required permits, which differ slightly from one project to the next under 94-C. Projects that have not completed Article 10 and wish
based on the finer points of the project layout. Wind and solar projects to transfer into 94-C are able to do so, and some of the projects in
have the same permits generally speaking. There are three main this portfolio have or soon will complete that transfer. They also can
categories of permits required- federal, state, and local, commonly complete Article 10 and not transfer, if they prefer.
with overlapping schedules, but some are dependent on others.
Among the many permits needed for renewable energy projects in For projects under 25 MW, Article 10 and 94-C do not apply.
NYS, the most involved one is Article 10, which several of the projects Instead the permits are run under the process laid out by the State
in this portfolio have been permitted through . The permitting of Environmental Quality Review Act, SEQRA, in which the local town
renewable energy projects over 25 MW has recently been changed is the lead agency on the proceedings and other agencies and
from Article 10, to a new program administered by the Office of jurisdictions have input but not final determination.
Renewable Energy Siting, referred to herein as “94-C”. Projects that
Tables 11-10, 11-11, and 11-12 below list all the federal, state, and local
have not completed Article 10 and wish to transfer into 94-C are able
permits and approvals that onshore wind and solar projects over 25
to do so, and some of the projects in this portfolio have or soon will
MW nameplate capacity may require. Not every permit is relevant to
complete that transfer. They also can complete Article 10 and not
every project, depending on the specific circumstances. For example,
transfer, if they prefer.
although solar projects do not extend into airspace, and in the past
The Article 10 or 94-C permit is the first one undertaken in were not subject to FAA review, it has become de rigueur to request
development, because the precise layout and construction details it Determinations of No Hazard from FAA for large solar arrays, to allay
eventually specifies informs all the other permits in these tables, from any concerns that they might impact pilot vision due to reflectivity,
the turbine coordinates sent to FAA, to the stormwater calculations especially near airports.
built into the SPDES permit, or the wetland impacts areas to be
permitted by USACE. Therefore, in the tables indicating permit status Federal agency Permit name
of each project, many of the permits have not been attained because
FAA Determination of No Hazard/lighting plan approval
they await completion of the Article 10/94-C process first.
FWS Endangered and Protected Species Consultations
USACE 401/404 Permit
Table 11-10. Federal permits and approvals.

Mitigation plans Wetland impacts are first avoided and minimized through careful
Mitigating the environmental impact of any large-scale renewable siting, and any unavoidable impacts are mitigated either through
energy project is an exercise that begins in the very first stages of on-site wetland mitigation projects, or through in-lieu fee wetland
siting a project, and continues right up until the final plans are agreed mitigation projects performed by others. These projects ensure that
to with NYSDEC before construction begins. total area of wetland in the state is increased, not decreased, by the
construction of renewable energy projects.
When choosing a site for a new project, a developer always starts with
screening sites for wetlands, threatened and endangered species, State agency Permit name
protected lands, and related sources of data that indicate that a NY Siting Certificate of Environmental Compatibility and
particular site hosts a sensitive environmental resource. One of the Board (Article Public Need or Permit for a Major Renewable Energy
first steps of developer takes is requesting a letter from the New York 10) or Office Facility
of Renewable
State Natural Heritage Program, requesting specific information for a
Energy Siting
given project area. (94-C) 10
Wetland delineations are another one of the early steps of Article VII Certificate of Environmental Compatibility and Public
development, to determine where the New York State DEC Need
jurisdictional wetlands are, where the USACE wetlands are, and thus Section 68 Certificate of Public Convenience and Necessity
how to site individual facilities within the project area to minimize
impacts to Wetlands. NYSDEC SPDES General Permit for Construction Activity
As development progresses, bird and other wildlife surveys are NYSDOT Special Use Permit for Oversize/ Overweight
performed to gain greater insight into how the project area is used Vehicles
as habitat, and to inform the specifics of any mitigation plans that are NYSDOT Highway Work Permit
developed as a condition of permit award.
Table 11-11. State permits and approvals.
Most of the projects in the portfolio that comprises this proposal are
not far along enough in development to have finalized mitigation
plans in place with state or federal agencies. The studies that inform
them are underway currently. Even for the most advanced projects Local agency Permit name
in this portfolio, the last details of the wildlife mitigation plans are still Town Board or SEQRA
actively being worked out with NYSDEC and are outside the scope Planning Board
of this discussion. However, all renewable energy projects in this
Host Towns Town Road Use Agreements
portfolio can only be constructed and operated with the concurrence
of NYSDEC to ensure that net conservation benefit plans are in place County Highway County Road Use Agreements
to ensure that any impacts to wildlife caused by these facilities are Departments
more than offset by the benefits provided to the species through the Host Towns Town Host Agreement
activities in these plans. Beneficial activities include protecting critical
habitat, reducing predation, and performing research. County IDAs Town-County-School PILOT Agreement
Table 11-12. Local permits and approvals.

Generation permitting
Heritage Wind
Bull Run Wind
Bull Run Solar
Twinleaf Solar
Corners Solar
Taproot Solar
Ball Hill Wind
Verona Solar
Baron Winds
Sandy Creek
Wintergreen
High Bridge
Prattsburgh
Seven Solar
Horseshoe
West River
Orangville
Bluestone
Number 3
Mountain
Sky High
Alle-Catt
Canisteo
Seventy-
Greens
Wind
Wind
Wind
Wind
Wind
Wind
Solar
Solar
Solar
Solar
Solar
Solar
Solar
Bald
Agency Permit
Federal permits and approvals
FAA Determination of No Hazard/ 9/1/21 N/A Yes Yes Yes Yes 12/1/22 Yes 12/1/21 12/1/21 6/1/21 Yes Yes 12/1/22 12/1/22 N/A 12/1/22 N/A 12/1/22 12/1/22 12/1/22 N/A 12/1/22
Lighting Plan Approval
FWS Endangered and Protected Yes N/A Yes Yes Yes 6/1/22 6/1/23 Yes 6/1/23 6/1/22 Yes 9/1/22 Yes 6/1/23 6/1/23 N/A 6/1/23 N/A 6/1/23 6/1/23 6/1/23 N/A 6/1/23
Species Consultations
USACE Wetlands Permit 12/1/21 12/1/22 Yes Yes Yes 4/1/22 12/1/23 4/1/22 12/1/23 4/1/22 5/1/21 2/1/22 5/1/21 6/1/23 6/1/23 12/1/22 6/1/23 12/1/22 12/1/23 6/1/23 6/1/23 12/1/22 12/1/23
State permits and approvals
Article 10 Certificate of Environmental Yes N/A N/A Yes Yes N/A N/A Yes N/A N/A Yes N/A Yes N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Compatibility and Public Need
Article VII Certificate of Environmental 6/1/22 N/A N/A N/A N/A N/A N/A 6/1/21 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Compatibility and Public Need
94-C Permit for a Major Renewable N/A N/A N/A N/A N/A 6/1/22 6/1/23 N/A 6/1/22 3/1/22 N/A 6/1/22 N/A 1/1/23 6/1/23 N/A 1/1/23 N/A 1/1/23 1/1/23 1/1/23 N/A 1/1/23
Energy Facility
SEQRA Environmental Impact N/A 6/1/22 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 6/1/22 N/A 6/1/22 N/A N/A N/A 6/1/22 N/A
Assessment
Section 68 Certificate of Public 12/201 N/A Yes Yes Yes 1/1/23 1/1/23 12/1/21 1/1/23 6/1/22 6/1/21 1/1/23 Yes 1/1/23 1/1/23 N/A 1/1/23 N/A 1/1/23 1/1/23 1/1/23 N/A 1/1/23
Convenience and Necessity
NYSDEC SPDES General Permit for 3/1/22 3/1/23 Yes Yes Yes 2/1/23 1/1/24 5/1/22 1/1/23 8/1/22 5/1/22 8/1/22 Yes 1/1/24 3/1/23 2/2/23 2/2/23 2/2/23 4/1/24 2/2/23 2/2/23 2/2/23 1/1/24
Construction Activity
NYSDOT Special Use Permit for 1/1/23 N/A Yes 1/1/22 Yes 1/1/24 N/A 1/1/22 N/A 1/1/23 1/1/22 N/A 1/1/22 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Oversize/ Overweight Vehicles
NYSDOT Highway Work Permit 7/1/21 N/A Yes 7/1/21 Yes 1/1/24 5/1/23 12/1/21 1/1/23 1/1/23 1/1/22 4/1/22 1/1/22 5/1/23 11/1/23 N/A 11/1/23 N/A 12/1/23 11/1/23 11/1/23 N/A 5/1/23
Local permits and approvals
Host Towns Town Road Use Agreements Yes 7/1/22 Yes Yes Yes 1/1/22 2/1/23 Yes 6/1/22 3/1/22 6/1/21 12/1/22 Yes 1/1/23 6/1/23 7/1/22 1/1/23 7/1/22 8/1/22 1/1/23 1/1/23 7/1/22 1/1/23
County County Road Use Agreements 6/1/21 7/2/22 Yes Yes Yes 6/1/22 6/1/23 Yes 6/1/22 3/1/22 6/1/21 12/1/22 Yes 1/1/23 6/1/23 7/2/22 1/1/23 7/2/22 8/2/22 1/1/23 1/1/23 7/2/22 1/1/23
Highway Depts
Host Towns Town Host Agreement Yes 7/3/22 Yes Yes Yes 6/1/22 6/1/23 Yes 6/1/22 3/1/22 6/1/21 12/1/22 Yes 1/1/23 6/1/23 7/3/22 1/1/23 7/3/22 8/3/22 1/1/23 1/1/23 7/3/22 1/1/23
County IDAs Town-County-School PILOT 9/1/21 7/4/22 Yes Yes Yes 6/1/22 6/1/23 Yes 6/1/22 3/1/22 6/1/21 12/1/22 Yes 1/1/23 6/1/23 7/4/22 1/1/23 7/4/22 8/4/22 1/1/23 1/1/23 7/4/22 1/1/23
Agreement
‘Yes’ is marked where permit has already been attained; Dates are projected likely attainments for permits not yet completed. N/A indicates permits which are not applicable to that project.
Table 11-13. Generation permitting matrix.
Section 12
Environmental
mitigation plan
12 Environmental mitigation plan
12.1. Introduction 12.2. Specific measures to mitigate adverse

As noted within this plan, our project team has begun consulting environmental and agricultural impacts
with government agencies. At this stage, these meetings have been
primarily focused on introducing the project, preparing for field Water resources
reviews, and discussing routing opportunities and constraints. The construction and operation of the project will result in temporary
impacts to wetlands and waterbodies due to the underground
Mitigation considerations are directly correlated with resource installation of the transmission cable. This may include direct impacts,
impacts. Therefore the primary mitigation concern at this time is to where the cleared construction corridor traverses a wetland or riparian
avoid or minimize impacts through routing or construction methods. area, and indirect impacts from vegetation clearing and ground
As the project alignment is finalized through the Article VII siting disturbance in adjacent uplands. In some instances, permanent
and consultation process, and resources are clearly identified during conversion of forested wetland to scrub-shrub wetland may occur in
field surveys, a detailed mitigation plan will emerge that will address areas where vegetation management is needed.
resource impacts.
Waterbody resources may be impacted during construction at crossing
Despite the preliminary nature of the project, certain mitigation locations or during extended stretches of in-water installation, such
measures and best management practices are likely to emerge as in the Harlem, Hudson, and East Rivers. Potential short-term water
regardless of the final alignment. While we acknowledge the need for quality impacts may include turbidity, downstream sedimentation,
a more robust and customized mitigation plan in the future, this section water temperature, temporary water chemistry changes (e.g., pH and
provides a high-level and preliminary assessment of anticipated dissolved oxygen levels) and localized effects on organisms.
mitigation for specific resources.
To minimize and mitigate negative impacts to water resources, the
project team will develop a Wetland and Waterbody Construction
and Mitigation Plan that will detail construction and restoration
The primary mitigation concern at this time is techniques appropriate to site-specific resource conditions that will be
encountered during construction. Additional plans will be developed to
to avoid or minimize impacts through routing or address horizontal directional drilling/inadvertent returns, groundwater
construction methods. resources, construction stormwater management, spill prevention and
cleanup, and unanticipated discovery of contaminated materials.
Ecological and cultural resources pertain to the project. In general, it appears the project is consistent
For the purposes of this document, ecological resources include with published LWRPs. However, additional consultation with these
vegetation and natural communities, wildlife, rare or threatened communities will need to occur as routing is refined, particularly as
and endangered species, and geology and soils. Cultural resources the Town of Cortlandt and the Village of Buchanan are finalizing
include archaeological, prehistoric, and historic resources. their plans. The project team will work with DOS to identify specific
construction options beyond routing (e.g., horizontal directional drilling
Mitigation requirements pertaining to these resources will be highly [HDD] installation, revitalization options, landfall siting considerations,
dependent on the completion of field surveys and subsequent habitat protections) to be consistent with the federal Coastal Zone
consultation with agencies. It is premature to postulate specific Management Act as outlined in the Coastal Management Program.
mitigation measures for these resources. However, we recognize
the importance of these resources and will implement the necessary To minimize potential construction effects to adjacent landowners,
mitigation measures to avoid or minimize impacts. Detailed plans, our team will develop a public outreach program that will provide
including unanticipated discovery plans, will be developed with timely information to stakeholders, adjacent property owners, and/or
agency input as appropriate. tenants regarding the planned construction activities and schedule.
Specific mitigation plans will be developed for Agricultural Districts,
Land use and zoning recreational areas, and public lands as applicable.
Land use adjacent to the proposed project was evaluated during the
siting process to minimize negative impacts to the natural landscape Other considerations
and anthropogenic land uses. Mitigation focused firstly on avoidance In addition to resource-specific mitigation planning, a broad array of
and secondly on minimization of impacts at known sensitive areas or best management practices is common to most large-scale transmission
designated special-use areas (e.g., agricultural districts, parks, natural projects that will be implemented upon agreement with agencies
or protected areas, trail systems or other intensive recreational areas, and local authorities. Plans may be developed to address, among
residential areas). other things, overland and underwater construction techniques, noise
impacts, visual resources, steep slopes, invasive weeds, environmental
Our team recognizes the need to coordinate further with individual justice areas, etc. The project team is committed to minimizing
land management agencies, cities, towns and villages, to determine impacts to the degree possible and will work with stakeholders to
whether the proposed transmission facilities minimize conflict with any develop robust mitigation options throughout the Article VII process.
present or future land uses. This effort will be ongoing throughout the
Article VII process and routing will need to be adjusted accordingly. Another issue commonly faced by energy projects in New York is
Most upland impacts have been minimized by burying the proposed opposition by local residents. Past regional transmission projects have
transmission line within existing utility corridors and roadways. This generated organized and vocal opposition. It can be assumed that
approach minimizes greenfield construction and associated impacts some residents may be concerned with the project’s land use and
such as vegetation clearing, visual impacts, habitat fragmentation, and potential impacts and will actively oppose it. Therefore, our team will
its associated impacts to terrestrial and avian species. implement an open and robust community engagement process. We
will host a website with project-specific information, attend local board
Per Article 42 of the Executive Law entitled Waterfront Revitalization meetings, sponsor local events, host online virtual meetings, and
of Coastal Areas and Inland Waterways, the project team has support other similar efforts to engage the public.
completed an initial review to determine consistency with LWRPs that
12.3. Collaborative work with stakeholders Based on modeling performed by PowerGEM and AKRF, Clean Path
New York conducted a thorough assessment of the reduced demand
to define mitigation measures for electrical generation and found that the project would result in
Please refer to Tables 11-1 and 11-2 of the Preliminary Permitting Plan in an average reduction of 4.6 TWh in electricity generation per year
Section 11 for specific details regarding collaborative work completed that would otherwise be generated through fossil-fuel combustion:
to date with stakeholders. Likewise, the anticipated and ongoing approximately 2.6 TWh from the portfolio of Resources and 2.0 TWh
approach for stakeholder collaboration is found within Section 11.7 of from New Transmission to bring renewable energy into New York City.
the Preliminary Permitting Plan.
Our estimates of reductions in annual emissions for carbon
dioxide (CO2), oxides of nitrogen (NOx), and sulfur dioxide (SO2) are
12.4. Support to New York’s 80% GHG summarized in Table 12-1. The AKRF report documenting the analysis
is provided under Appendix 16.
reduction by 20501
Clean Path New York offers an impressive portfolio of instate 2025 2030 2035 Average
renewable Resources. This additional renewable energy availability Baseline
is expected to allow for the reduction of fossil-fuel consumption at
generation facilities that serve the New York City metropolitan area, Power (TWh) 46.4 22.5 15.4
resulting in an overall reduction of emissions. CO2 (million ton) 25.4 11.7 7.9
NOx (ton) 17,340 7,984 5,428
SO2 (ton) 125 57 38
Proposed Clean Path New York
Power (TWh) 39.9 18.0 12.5
CO2 (million ton) 21.5 9.3 6.4
NOx (ton) 14,714 6,385 4,363
SO2 (ton) 106 45 30
Increment
Power (TWh) -6.5 (-14%) -4.4 (-20%) -2.9 (-19%) -4.6
CO2 (million ton) -3.8 (-15%) -2.3 (-20%) -1.6 (-20%) -2.6
NOx (ton) -2,625 -1,602 -1,065 -1,764
Figure 12-1. Clean Path New York's
(-15%) (-20%) (-20%)
Resource portfolio is located entirely
instate. SO2 (ton) -19 (-15%) -13 (-22%) -8 (-20%) -13
Table 12-1. Clean Path New York impact on GHG.
1
The PowerGEM cases underlying the [AKRF/Appleseed] analysis have Blenheim-Gliboa modeled differently than those used in the rest of the Step Two Proposal. This more conservative modeling
of Blenheim-Gliboa slightly understates the emissions reductions of the Clean Path New York project.
Greenhouse gas reduction Clean Path New York provides the targeted CO2 emissions reductions
In addition to its goal of 70% renewable energy by 2030, New York that are the driving force behind the Tier 4 program. Over 60%, or
State has a goal of reducing carbon emissions to at least 85% below 1.56 million tons, of these reductions are located in New York City,
1990 levels by 2050. According to the New York State Department of and 85% of them — 2.13 million tons — are located in the constrained
Environmental Conservation, the state emitted 410 million metric tons downstate New York capacity zones (Zones G to K). In the 2035 case,
of CO2 equivalent in 1990.2 This implies that the state must reduce with 9 GW of offshore wind interconnecting in Zones J and K, Clean
its CO2 emissions by 349 million metric tons — to 61 metric tons — by Path New York reduces statewide carbon emissions 22% versus
2050. business as usual, for a total of 1.74 million tons.
Assisted by PowerGEM, Clean Path New York conducted extensive Clean Path New York achieves these impressive reductions by
modeling of the system to understand the impact of the project on the adding significant in-state renewable Resources and providing the
CO2 emissions. The modeling assumes the state will meet its goal of critical transmission infrastructure needed to reduce congestion
70% renewable energy by 2030. between upstate and downstate New York. The transmission allows
both existing generation and incremental project generation to be
In 2030 Clean Path New York is expected to reduce New York State’s dispatched more efficiently — reducing curtailment of renewables
annual CO2 emissions by 2.5 million tons. This represents an overall upstate, bringing clean power into Zone J, and thereby reducing the
22% reduction in statewide CO2 emissions from electric generation. output of downstate New York’s less-efficient fossil fuel generation.
Clean Path New York provides consistent incremental CO2 emissions
reductions even when considered in conjunction with a similar-sized A project injecting renewable power directly into Zone J from outside
HVDC transmission line interconnecting into Zone J from Canada. New York may provide similar emissions reductions, but would do
so by bringing out-of-state renewables into the state, not improving
the intrastate transmission system to dispatch New York’s own
22% 39m
renewables more efficiently. Based on our modeling, a fully utilized
1,200 MW transmission line from Canada into Zone J would increase
New York’s net electricity imports by 52% in 2030 and 57% in 2035.
reduction in statewide tons reduction in New While such a project will reduce emissions in Zone J, from a system
carbon emissions York State's carbon perspective it does so by injecting external renewables into the state,
through Clean Path emissions over 25 rather than allowing New York State to more efficiently utilize in-state
New York years renewables.
2
https://www.dec.ny.gov/docs/administration_pdf/revexpterms496.pdf
Nitrogen oxides, VOCs, and ozone Clean Path New York expected NOx reductions are illustrated in
NOx are of principal concern because of their role, together with Figure 12-2. The reductions are estimated to be 15% for 2025, 20% for
VOCs, as precursors in the formation of ozone. In addition, current both 2030 and 2035.
scientific evidence links short-term NO2 exposures (ranging from
30 minutes to 24 hours) with adverse respiratory effects, which is Sulfur dioxide
of particular concern for “susceptible individuals,” including people SO2 emissions are primarily associated with the combustion of sulfur-
with asthma, children, and the elderly. EPA states that the highest containing fuels (oil and coal). SO2 is also of concern as a precursor in
concentrations of outdoor NO2 are found in large urban regions, such the formation of particulate matter (PM) pollution. As with NO2, current
as the Northeast Corridor, Chicago, and Los Angeles, with levels scientific evidence links short-term SO2 exposures with adverse
highest near heavily traveled roadways.3 respiratory effects, which is of particular concern for “susceptible
individuals,” including people with asthma, children, and the elderly.
In addition to impacting human health, EPA has found that at high
concentrations, SO2 may result in damage and decreased growth in
trees and plants.
Clean Path New York is expected SO2 reductions are illustrated in

Figure 12-3 on the next page. The reductions are estimated to be 15%
for 2025, 21% for both 2030 and 2035.
NOX (ton)
NOX with Clean Path New York

NOX baseline
Figure 12-2. Clean Path New York expected NOX reductions. Year
3
U.S. EPA. Risk and Exposure Assessment to Support the Review of the NO2 Primary National
Ambient Air Quality Standard. EPA-452/R-08-008a, November 2008, p. 15.
SO2 (ton)
SO2 with Clean Path New York

SO2 baseline
Figure 12-3. Clean Path New York expected SO2 reductions. Year
Respirable particulate matter: PM10 and PM2.5

PM is a broad class of air pollutants that includes discrete particles
of a wide range of sizes and chemical compositions, as either liquid
droplets (aerosols) or solids suspended in the atmosphere. PM is
162 tons
annual Particulate Matter
regulated in two size categories: particles with an aerodynamic emissions reduction
diameter of less than or equal to 2.5 micrometers (PM2.5) and
particles with an aerodynamic diameter of less than or equal to 10
micrometers (PM10, which includes PM2.5).
While we did not directly project reduced emissions of PM, we
PM2.5 has the ability to reach the lower regions of the respiratory used our estimates of fuel consumption to project that annual
tract, delivering with it other compounds that adsorb to the surfaces of statewide emissions of PM would be reduced by approximately 162
the particles, and is also extremely persistent in the atmosphere. tons per year.
12.5. Clean Path New York support to

CLCPA’s strategy
Clean Path New York worked with Appleseed to calculate the
beneficial impact of the project, including the avoidance of social
costs from reductions in CO2 and NOx emissions over a 25-year
period. Benefits from project Resources and New Transmission
will reduce the health, social, environmental, and economic costs
associated with those emissions by more than $8 billion, with at least
40% of those savings concentrated in Disadvantaged Communities,
both in New York City and elsewhere in the State. A more detailed
analysis and explanation of those outcomes and alignment with
CLCPA is also provided under Sections 15 and 16 of this proposal.
Delivering benefits to disadvantaged communities

Approximately 57% of the emissions reduction would occur within
New York City (Zone J), with an additional 15% within Long Island
(Zone K), 10% within the Hudson Valley (Zone G), and 10% within the
Capital District (Zone F).
Therefore, most of the benefits from reduced emissions of NOx, SO2,

and PM would directly impact communities in these areas within the
vicinity of the impacted electricity generating facilities, see Figure 12-4
for an illustration of such an impact. Figures 12-5 to 12-9 provide more
granuality of such impact for the positively affected areas. To assess
the estimated benefits that would directly impact disadvantaged
communities, a refined air quality dispersion modeling analysis was
performed; refer to AKRF report in Appendix 16 for more details.
57% 40%
of the emissions of emissions reductions
Figure 12-4. Reduced emissions impact on communities.
reduction would occur in occur in disadvantaged
New York City communities
Lower Manhattan-Northwestern Brooklyn Contours Northeastern Bronx Contours

(decreased in µg/m3) (decreased in µg/m3)
0.1-0.25 0-0.1
0.25-0.5 0.1-0.25
0.5-1
1-5
Figure 12-5. Reduced emissions in Lower Manhattan-Northwestern Brooklyn . Figure 12-6. Reduced emissions impact on communities.
Northeastern Staten Island Contours Northwestern Queens-Southern Bronx Contours

(decreased in µg/m3) (decreased in µg/m3)
0.1-0.25 1-5
0.25-0.5 5-10
0.5-1 10-15
1-5
Figure 12-7. Reduced emissions in Northeastern Staten Island. Figure 12-8. Reduced emissions impact in Northwestern Queens-Southern Bronx.
Concentrations were predicted at locations across New York City.

Our analysis found that approximately 53% of short-term reduction
would occur within disadvantaged communities. The most significant
reductions would occur within Northwest Queens, Southwest Bronx,
and West Central Queens. Approximately 30% of total air quality
benefits are anticipated to directly impact disadvantaged communities
within New York City.
Concentration decreases would extend up to four miles from

facilities, with the most significant reduction occurring within two
miles. Disadvantaged communities adjacent to electricity-generating
facilities in Long Island and the Hudson Valley would also be directly
impacted. Subsequently, additional air quality benefits that directly
impact disadvantaged communities are calculated to be 6% in Long
Island, 6% in the Hudson Valley, and 5% in the Capital area. Therefore,
the project is anticipated to achieve New York State’s goal of
disadvantaged communities receiving 40% of the benefits associated
with the reduced emissions of NOx, SO2, and PM.
Impact on climate change

As part of the CLCPA, New York State has called for stringent limits
on the statewide emission of GHGs, requiring that those emissions
on a statewide basis be reduced by 40% by 2030 and 85% by 2050,
compared with statewide 1990 levels. New York State estimates
that statewide GHG emissions in 1990 were 409.78 million metric
tons of CO2 equivalent. Statewide GHG emissions accounted for
approximately 205.61 million metric tons in 2016 (50% of 1990 levels).
Clean Path New York would result in a reduction of approximately
2.6 million metric each year and will further the state’s emissions
Southern Queens-Southeastern Brooklyn Contours
(decreased in µg/m3) reduction goals for 2030 and beyond.
0.1-0.25
0.25-0.5 Increased GHG emissions are projected to have wide-ranging
0.5-1 effects on the environment, including rising sea levels, increases
1-5 in temperature, and changes in precipitation levels. Although this
is occurring on a global scale, the environmental effects of climate
Figure 12-9. Reduced emissions impact in Southern Queens-Southeastern Brooklyn.
change are also likely to be experienced at the local level within
coastal areas of New York State — primarily within New York City and
Long Island.
Climate change projections from the New York City Panel on Climate
Change (NPCC) include a summary of baseline and projected climate
12.6. Project’s carbon intensity in project
conditions throughout the 21st century, including heat waves and cold design, sourcing, construction, operation,
events, intense precipitation and droughts, sea-level rise, and coastal
storm levels and frequency.
and maintenance
Our approach
NPCC projected that sea levels are likely to increase by up to 30
Reducing costs while lowering carbon is an integral component of our
inches by the 2050s and up to 75 inches by the end of the century.
approach and management of the project’s design and construction
In general, the probability of increased sea levels is characterized as
phases. In large and complex infrastructure projects like this one,
“extremely likely,” but there is uncertainty regarding the probability
reducing project costs while reducing the carbon impact is essential
the various levels projected and timescale. Intense hurricanes are
not only for project success but to deliver socially responsible,
characterized as “more likely than not” to increase in intensity and/or
inclusive, and community-focused projects. We aim to support
frequency.
environmental justice, pass on benefits to New York ratepayers, and
Many disadvantaged communities in New York City are located within contribute to the achievement of New York CLCPA targets.
a coastal floodplain, including the coastal communities of the Bronx,
To focus on carbon reduction, the embodied carbon must be
portions of Northwest Queens, Northwest Brooklyn, South Brooklyn,
effectively measured at this early stage of the project and then at key
and North Staten Island. Therefore, a significant portion of the benefits
design, procurement, and construction milestones. By highlighting
associated with reduced GHG emissions would result in indirect
carbon hotspots early in the design, carbon can be managed and
benefits to these communities and would continue to further New
intelligently reduced.
York State’s goal of directing a significant portion of the anticipated
benefits towards disadvantaged communities. Clean Path New York is determined to implement the best measures
and practices to influence the reduction of carbon:
✓ Optimizing the route
Procuring the material from local sources to the extent

✓ possible, thereby minimizing the carbon associated with
material transport
✓ Bundling deliveries to the job site to minimize trips
Proposing an optimized construction contracting strategy that

✓ will improve production and minimize material and equipment
needs
Conversion Carbon
Activity
(Carbon factor) Footprint
The amount of “stuff” Release of Carbon

we consume: Emissions to the
Figure 12-10. How • Embodied (Materials) atmosphere associated
carbon footprint is
• Operational (Energy) with the activities
calculated.
At each phase of the project, we will use the Moata Carbon Portal to Information Management, enabling the carbon impacts of design
calculate the embodied carbon emissions released, including material changes to be visualized as they are made. The Carbon Portal is
fabrication, material transport, labor, and equipment emissions during globally compliant with PAS2080 certification — the world’s first
construction, and to identify where savings can be made at the carbon management standard for infrastructure.
various stages.
By assessing the carbon impact at each phase of the design process,
The Carbon Portal is a proprietary tool developed by Mott MacDonald, we believe that embodied carbon can be reduced between 50% and
our technical advisors on this project. It is a solution for modeling 80% as we illustrate in Figure 12-11 below. We know that new complex
the capital and operational carbon of new assets. It will enable us to infrastructure must be designed, procured, and built to respond to
quickly identify carbon hot spots in the project, facilitating low-carbon the decarbonization needs in New York State. We have consistently
design. The Carbon Portal is built on the infrastructure industry’s optimized our design so that we only build what is required and we
most comprehensive carbon database and is integrated with Building can use the existing infrastructure to the maximum extent possible.
We know that the greatest opportunity to reduce carbon impact lies

within these early design stages. That is why we are focused on
the win-win opportunities to reduce carbon impacts, reduce new
infrastructure construction, and reduce overall project costs.
‘Build nothing’ ‘Build less’ ‘Build clever’ ‘Build efficiently’
wh Abilit f assessm
ent
ole y to acy o
life infl Accur
cyc uenc
le c e
arb
on
100% 80% 50% 20%
Construction and Handover and

Strategy Brief Concept Definition Design Commissioning Closeout
Operation End of life
Work stages of infrastructure delivery

Procurement Maintenance
Use of
Figure 12-11. Ability to influence carbon through a project lifecycle. the asset
The opportunity We spent the majority of the past eight months performing site
Clean Path New York will deliver Tier 4 eligible renewable energy reviews, facilitating route review and converter station siting
power to the New York City electrical grid via a new HVDC workshops, performing risk assessments, and preparing CAPEX
transmission link. Our team proposes to deliver 1,300 MW through studies, with the ultimate goal of optimizing the underground/
an underwater/underground HVDC electric transmission system underwater duct bank route, reducing capital costs, and reducing
extending at least 175 miles from the withdrawal point of Fraser carbon footprint.
Substation in Delaware County, New York to the primary point of
We have performed evaluations for converter station siting to find
interconnection at the Rainey Substation in Queens, New York, the
the best and most reasonable locations for the stations and are
delivery point. We have performed carbon intensity modeling in the
negotiating lease options with landowners. We have determined
early design and conceptual phase to determine ways to achieve
the most constructable in-water cable route in the Hudson, Harlem,
these goals:
and East Rivers to minimize congested inner-city street ROW work,
✓ Prepare a design that optimized existing infrastructure in reduce the amount of utility relocation, increase overall construction
upstate New York productivity, and minimize traffic impacts.
Develop a procurement strategy to maximize locally sourced Finally, we prepared a contracting strategy that defines the methods
✓ materials like vaults, concrete, sand/gravel, pavement, wood,
and other construction materials
to maximize construction efficiency by contracting with contractors
with expertise in each aspect of construction.
✓ Develop a contracting strategy that increases construction

efficiency
Based on the above, we have conducted carbon assessment and
simulated the embodied carbon emissions associated with the
procurement, logistics, and construction activities. The outcome
✓ Route the conduit along previously disturbed areas to minimize
greenfield disturbance results are carbon intensity breakdowns by construction scope,
operations, and maintenance activity, and a commentary with regards
✓ Optimize converter station efficiency to the decommissioning. Those are detailed below.
Carbon modeling outcomes

✓ Optimize cable pulling and duct bank installation methods The breakdown structure of the embodied carbon calculation
is presented in the diagram on the next page, Figure 12-12. The
Identify and evaluate innovative materials (e.g., fiberglass
✓
below sections report the carbon portal simulation results for each
vaults versus traditional concrete vaults) to increase component within the structure.
construction efficiency
HVDC cable
Figure 12-12. Carbon modeling outcomes
8-inch conduit
Cable procurement HVAC cables
Fiber optic cables

HVDC converter station
4-inch conduit
Material
Major crossings materials HVDC duct-bank concrete
HVAC duct-bank concrete
Duct-bank and manhole

vaults procurement Sandbed
Manholes concrete
All cables
Construction HDD concrete
phase Material transport
HDD activities Rock excavation
Sandbed
Duct-bank and manhole Soil backfill

vaults installation
Clean Path New York Concrete blocks

Embodied carbon
structure
Installation HVDC converter station Rock backfill
Operations and logistics
HDD activities Pumps
Equipment operations
Plant emissions
Operation and
maintenance phase Operations crew
Transportation
Maintenance crew
12.7. Construction phase

Overview Material
Figure 12-13 below provides the carbon modeling outcomes broken Figure 12-14 below presents the carbon emissions by activity within
down by scope during construction phase. Of the total carbon material scope. As stated previously, the majority of the carbon
emissions, 91% results from the procurement stage and is attributable emissions come from the materials used for the cable along the route
to the material fabrication and procurement. This is largely due to (80%). The next largest carbon emission factor is the duct bank and
the significant cable and vault procurement associated with the vault procurement and installation (11%). Because there are only two
175-mile electric transmission project. 7% of the total emissions converter substations at intervals along the route, the procurement
results from material transportation attributable to transporting and installation of the station materials was the third carbon
cable transportation from Southeast Asia to New York by barge and emissions component (9%). Materials used in major railroad, road, and
specialized vessels and then to the job site by truck (assumed 13,000 wetland/waterbody crossings resulted in additional carbon emission
nautical miles). The remaining carbon emissions are from installation, components of less than 1%.
which is estimated to be as low as 2% of the construction phase. The
below subsections provide the breakdown of the subcomponents. 10.19K (11.01%)
7.2K (7.05%) 8.01K (8.65%)
2.38K (2.33%) 0.37K (0.4%)
92.55K
Metric ton CO2
102.13K Activity
Metric ton CO2
Cable procurement
and install
Duct bank and vault
procurement and install
Converter procurement
Scope and install
Material 73.98K (79.94%) Major crossing
Material transport
92.55K (90.62%) Installation Figure 12-14. Carbon emissions by activity.
Figure 12-13. Carbon modeling outcomes broken down by scope.

Cable procurement Duct bank and vault procurement

Figure 12-15 below shows material carbon impacts from cables. The Figure 12-16 below shows material carbon impacts from duct banks
major materials that contribute to carbon impacts come from DC cable and vaults. Concrete blocks for AC duct banks contribute the most
(70%) and 8-inch conduit (22%). The carbon impacts from AC cable, (65%) to carbon impact, followed by concrete blocks used for DC duct
4-inch conduit, and fiber optic cable make up the remaining 8%. banks (18%) and sandbed (14%). Concrete used for manholes and the
horizontal directional drilling (HDD) duct bank contribute minimally to
carbon impacts (less than 3%).
16.07K (21.72%)
1.86K (18.29%)
3.37K (4.56%) 1.42K (13.94%)
2.14K (2.89%)
0.28K (2.73%)
73.98K
Metric ton CO2
10.19K
Metric ton CO2 Component
Component Concrete blocks for
DC cable Duct bank (DC)
8-in conduit Concrete blocks for
AC cable Duct bank (AC)
4-in conduit Sandbed
51.82K (70.05%) Fiber optic cable Concrete blocks for
Splice vault manholes
Figure 12-15. Material carbon impacts from cables. Concrete blocks for Duct
6.6K (64.8%) bank Onshore HDD
Figure 12-16. Material carbon impacts from duct banks and vaults.
Converter procurement 372.59 (100%)
Figure 12-17 below shows that 8,000 metric tons of CO2 come from the Figure 12-18. Carbon
assumed 3,000 metric tons of steel structures used for two converters emissions by timber
mats at major crossings..
(based on a conceptual plot plan). As the project progresses, more
information regarding materials used within these two converters can
be gathered and utilized to update the carbon model.
372.59
Metric ton CO2
8.01K (100%)
Component
8.01K
Timber mats
Metric ton CO2 Material transport

Figure 12-19 below represents the carbon emissions by activity within
the material transport scope. The majority of the carbon emissions
come from transporting cables (95%). The remaining 5% comes from
HDD-related material transportation.
Component
Steel for converters
0.38K (5.33%)
Figure 12-17. Carbon emissions from steel for converters.

Figure 12-19. Carbon
emissions by activity
within the material
transport scope.
Major crossing
Figure 12-18 shows that 373 metric tons of CO2 come from
approximately 43,000 timber mats used at major crossings. 7.20K
Metric ton CO2
Activity
Cable procurement
and install
Horizontal Directional
6.81K (94.67%) Drilling (HDD)
Cable installation
Figure 12-20 below shows that 6,800 metric tons of CO2 come from Installation
transporting cables. Figure 12-22 below represents the carbon emissions by activity within
the installation scope. Out of an approximate 2,400 metric tons of
6.81K (100%) CO2, 60% originates from duct banks and vaults work, 22% from
converters, and the remaining 19% from HDD.
0.52K (21.69%)
6.81K
Metric ton CO2
0.45K (18.98%)
2.38K
Metric ton CO2
Figure 12-20.
Carbon emissions Component Activity
from transporting Cable transportation Duct bank and vault
cables. procurement and install
Converter procurement
and install
Horizontal Directional
HDD tranportation 1.41K (59.33%) Drilling (HDD)
153.16 (39.91%)
Figure 12-21 shows
Figure 12-22. Carbon emissions by activity within the installation scope.
the distribution of an
estimated 400 metric
tons of CO2 across
HDD-related material
48.46 (12.63%)
transportation trucks.
383.79
Metric ton CO2
Component
Figure 12-21.
HDD vacuum trucks
Carbon emissions from
transporting HDD- HDD water trucks
related material. 182.17 (47.47%) HDD dump trucks
Converter installation
517.23 (100%)
Figure 12-23 to the right shows that an estimated 500 metric tons of
CO2 come from constructing the assumed 3,000 metric tons of steel Figure 12-23. Carbon
structures used for two converters (based on a conceptual plot plan). emissions from converter
As the project progresses, more information regarding materials used installation.
within these two converters can be gathered and utilized to update

the carbon model.
517.23
Metric ton CO2
Duct bank and vault installation
Figure 12-24 below shows the distribution of an estimated 1,400
metric tons of CO2 from duct bank and vault installation for rock
excavation, sandbed, soil/rock backfill, and concrete blocks.
Component
343.12 (24.25%)
Steel for converters
240.32 (16.99%) HDD installation

Figure 12-25 below represents the distribution of an estimated 450
metric tons of CO2 from HDD installation.
173.28 (38.29%)
1.41K 200.35 (14.16%) 58.44 (12.91%)

Metric ton CO2
Component
Rock excavation
452.52
Sandbed
Soil backfill
Concrete blocks
Metric ton CO2
Rock backfill
432.58 (30.58%) 198.15 (14.01%)
Figure 12-24. Carbon emissions from duct bank and vault installation.
Component
HDD operations
HDD pump
220.8 (48.79%) HDD plant emissions
Figure 12-25. Carbon emissions from HDD installation.

Equipment operation
12.8. Operations and maintenance Figure 12-28 below represents an estimated 12,000 metric tons of
CO2 derived from excavators’ fuel consumption rate operating for two
Overview years.
Figure 12-26 below provides the carbon modeling outcomes broken
down by scope during operations and maintenance (O&M). 95% 12.26K (100%)
of the total carbon emission is resulting from equipment operation
derived from excavator fuel consumption. The remaining 5% carbon
emission is from personnel transportation for O&M crews. The below Figure 12-28. Carbon
emissions derived
subsections provide the breakdown of the sub-components. from excavators' fuel
consumption rate.
0.64K (4.98%)
12.26K
Metric ton CO2
12.90K 12.26K (95.02%) Activity

Excavators
Metric ton CO2
165.06 (25.71%)
Scope
Equipment operation
Personnel transportation
Figure 12-26. Carbon modeling outcomes broken down by scope during O&M.
641.89 476.83 (74.29%)
Metric ton CO2
Personnel transportation
Figure 12-27 to the right shows that an estimated 650 metric tons
of CO2 come from transporting O&M crews, assuming a two-year
operating period and a 25-year maintenance period. Transporting Activity
operations crews accounts for 75% of carbon emission from personnel Operations crew
Maintenance crew
transportation, with the remaining 25% accounted for transporting
maintenance crews. Figure 12-27. Carbon emissions as a result of transporting operations crews.
12.9. Decommissioning
For power projects like Clean Path New York, industry standards
estimate that the carbon impact for decommissioning converter
stations and duct banks is approximately 35% of the calculated
carbon impact for the project. For this project, an estimated carbon
impact of 103,000 tons of CO2 equivalent would result in an additional
decommissioning carbon impact of about 36,000 tons of CO2
equivalent.
Section 13
Project schedule
13 Project schedule
13.1. Demonstrate project can be Clean Path New York developed realistic work packages, inclusive of
associated durations, by gathering inputs from technology providers,
developed, financed, and constructed manufacturers, contractors, and other members of the supply chain.
within a commercially reasonable Early communications with agencies such as NYISO, NYSDOT,
NYSDEC, and USFWS was key to understanding schedule drivers and
timeframe the impact of key permitting requirements in developing a realistic and
Clean Path New York has developed a detailed project schedule achievable target COD.
integrating transmission system requirements, associated The development, construction, and completion of the HVDC
development resources, and project execution including the following: transmission component is the main driver for achieving the targeted
COD, and more specifically, the critical path for this component
1
includes the NYSDPS Article VII permitting and construction phase.
An achievable Commercial Operation Date (COD)
Given the current progress and the development schedule of
2
the remaining activities, the portfolio of power generation supply
Utilizing deep understanding of critical activities resources is expected to achieve COD one to four years before the
completion of the new transmission system.
3 Strategic planning
To manage the risk of delay in the resources schedule, such as
4
unforeseen substantial delay that may extend beyond the new
Effective resource management transmission COD, Clean Path New York has developed several
schedule-driven risk management strategies. These include replacing
Clean Path New York members have the necessary resources and and/or adding other generation resources to the portfolio as
experience to successfully deliver large complex development alternatives for projects that are not able to achieve COD in a timely
projects on schedule. fashion. This is achievable given Clean Path New York LLC’s access to
a large portfolio of resources. As evidenced by our letters of support
The overall project schedule is developed around various discrete but from several renewable project developers in addition to support from
integrated work packages, incorporating diligently evaluated potential our partner Invenergy, Clean Path New York already has direct line-of-
contracting and procurement strategies to maximize productivity and sight to a significant portfolio of projects that can be brought to bear to
understand what can be concurrently delivered. the task of supplying the transmission line with renewable energy.
Please refer to Section 4 for details about each resource’s expected • Consulted and continue to discuss with NYISO regarding open
commercial operation date (COD) and major schedule milestones access transmission tariff and the changes needed for the market
that precede it, as well as the site control document included as rules to manage and utilize an intrastate HVDC transmission line
Appendix 3. If any resource experiences a significant delay that • Performed electrical studies to determine project transmission
causes its projected COD to fall substantially behind that of the new capability and rating
transmission, we would consider replacing it and/or adding another
• Performed engineering feasibility studies to validate proposed
resource to the portfolio to either substitute or otherwise backstop
project concept and route
the production of the delayed project. Please refer to Section 2 for the
suggested organizational structure and Section 5 for the delivery plan. • Assessed workspace feasibility of siting underground conduit
installation in NYPA ROW
A detailed project schedule is • Reviewed geologic conditions along NYPA ROW to assess rock
06.30.26
provided under Appendix 17 of this excavation requirements
proposal. The schedule is focused • Evaluated terrain along NYPA ROW to understand cable and duct
on the development of the new bank installation requirements
Target COD transmission line but also includes
• Performed electromagnetic field studies for NYPA ROW to
COD milestone dates for project
determine siting location within ROW
resources. Clean Path New York is targeting a commercial operation
date within the second quarter of 2026. The specific COD target is • Performed field site evaluations to review key routing and siting
June 30, 2026. The restoration activities will continue thereafter and areas
will be finalized by August 14, 2026, which represents final project • Evaluated requirements and feasibility of trenchless crossings for
completion. major rivers, conservation areas, and other features
• Performed and continue to perform detailed routing assessments of
These target milestones are based on reviewing the
multiple alternatives
interdependencies and expected durations of the major project
drivers, including commercial, development, permitting, and • Reviewed and developed mitigation strategies for Hudson, Harlem,
construction activities for the project. Clean Path New York has and East River constructability challenges
completed extensive outreach to lenders, environmental and • Reviewed entry/exit landfalls for access to the rivers to assess
permitting agencies, major material vendors, and construction construction methods
contractors to further refine the proposed project schedule. Further • Assessed public road ROW siting, including public road ROW widths
detail is provided below on the activities performed to date to develop and existing utility information
and validate the proposed project schedule. • Reviewed environmental impacts of project route utilizing publicly
• Studied and developed power system modeling for interconnection available NWI and NHD datasets
at Fraser and Rainey • Assessed community impacts along project route and known
• Consulted with NYISO on initial project concepts and revised scope community interest drivers
to provide improved reliability • Performed environmental agency consultation including NYSDEC,
USFWS, and others to understand agency project schedule drivers
• Coordinated with multiple public road state agencies, including • Solicited construction execution methodologies from experienced
NYSDOT and New York State Thruway construction contractors
• Developed a detailed permitting plan including understanding • Reviewed and benchmarked the project schedule against other
sequencing of activities similar complex infrastructure projects developed by Clean Path
New York members
Development, permitting, and construction • Reviewed project schedule activities with construction contractors
The schedule illustrates an overall development, permitting, and including the following:
construction duration of five years, including commissioning and – Mobilization/demobilization
restoration activities. We have rigorously reviewed and prepared – Duct bank installation production rates
this schedule in conjunction with a procurement strategy for major – Public road ROW installation production rates
materials required for the project. We have incorporated challenges such – Submarine installation production rates
as allowable construction windows and the availability of resources for
– Cable pulling, splicing, and terminating
parallel activities while accounting for permitting requirements. The
– Converter station logistics and site erection production rates
following activities were conducted to validate the targeted COD date:
– Restoration rates for various installation types (land and submarine)
• Consulted with environmental permit agencies to baseline permit
lead times including NYSDPS Article VII and ACOE Section 404/10 13.2. Documentation that resources,
• Engaged a legal team to review applicable permit time frames and
durations for the “Hearings and Decisions” phase of the NYSDPS process, and schedule are adequate for
Article VII permitting process the acquisition of all rights, permits, and
• Developed environmental and cultural field survey strategies and
reviewed resource requirements and protocols to achieve desired approvals for financing
project durations Clean Path New York’s schedule for the development and construction
• Developed a field investigation and execution plan of the new transmission line is commercially achievable. As described
• Engaged an engineering and civil survey consultant to review in Section 13.1, the Clean Path New York members have established
durations and requirements for associated activities experience with developing and executing large-scale, complex
• Engaged a land/row consultant to provide applicable activities and infrastructure projects. The members have an extensive knowledge and
associated durations understanding of engineering, supply chain bottlenecks, permitting,
• Reviewed typical permitting agency lead times including approval of and regulatory regime. In addition to its members’ in-house capabilities,
the project environmental management and construction plan Clean Path New York has retained a reputable engineering firm with
• Reviewed lead times for major material vendors including original the requisite technical expertise to conduct project management,
equipment manufacturers (OEMs) for the HVDC land and submarine development, planning, design, and constructability reviews. Section
cables and converter stations 3 of this proposal provides details in regard to Clean Path New York’s
• Evaluated logistics for material deliveries and staging for both NYPA capabilities and organization structure to deliver the project, as well as
ROW and public road ROW experience with similar successfully delivered projects.
• Evaluated logistics for material deliveries and staging for converter The transmission line project is in the early stages of development
stations and substation work and as detailed in Section 5, the proposed ROW for the new
transmission requires minimal to no acquisitions. The proposed route As described in Section 4, the generation resources provided in this
will largely utilize NYPA Marcy South transmission ROW between the proposal are being developed and are at varying stages. Most of
withdrawal point at Fraser and Rock Tavern. From Rock Tavern to the those resources are also contracted under Tier 1 and those resources
Bronx, where the southern converter station will be located, and into submit quarterly progress reports to NYSERDA. Those reports provide
Rainey Substation, the path will utilize public ROW including existing details on the development progress, including financing, permits, and
utility leases. Clean Path New York has secured an option agreement acquisition of rights. Refer to Appendix 3 which provides details of the
for the Fraser converter station location and also has site control for site control status for each Resource.
the Zone J converter station location in the Bronx. Documentation and
agreements to verify site control can be provided to NYSERDA upon
request.
2020 2021 2022 2023 2024 2025 2026
Clean Path New York transmission project
Field constructability review/surveys
Environmental/cultural survey window
Permitting
NYSPSC Article VII
Application development phase
♦ Application submitted
NYSPSC review of Article VII
♦ Application deemed complete
Hearings and decisions phase (legal process)
EM&CP preparation and ROW acquisitions
♦ EM&CP filed
♦ EM&CP approved
Construction
Construction management/administration
Underground construction existing ROW
Underground construction restoration
Converter station construction
Converter station restoration
Project commissioning/operation
Figure 13-1. Critical path schedule.
Project completion ♦
13.3. Critical path schedule • Article VII Application submittal and review. Clean Path New
York will develop the Article VII application in parallel to the
The critical path schedule is illustrated in Figure 13-1 below. environmental and cultural surveys in anticipation of submitting an
The key schedule drivers for Clean Path New York are the NYSPSC application to the NYSDPS in June 2022. Clean Path New York will
Article VII process, and the construction/commissioning phase of the process, review, and develop the application material on a real-time
project. Procurement has the longest duration, but this was managed basis as the environmental/cultural survey work is completed. The
and relatively de-risked in the schedule and was disintegrated from schedule allows for an 8-month review period for the NYSPSC to
the critical path by creating floats around key interface activities. assess and deem the Article VII application complete by January 29,
Additional detail for each of these items is provided below: 2023.
• Hearings and decisions phase. Following the submittal and review
NYSPSC Article VII process by the NYSPSC of the Article VII application, a legal process will
Clean Path New York has started initial consultation with the NYSDPS commence once the agency deems the application complete. Clean
and other environmental permitting agencies to commence the Article Path New York has allowed for a one-year duration for the hearing
VII process. This reflects an Article VII permit issue date of January and decisions phase of the Article VII process. We understand that
31, 2024 along with an Environmental Management and Construction this phase will include a pre-hearing conference, public statement
Plan approval date of July 30, 2024. These approvals are the key hearings, and other evidentiary hearings toward the issuance of an
drivers to allow for field construction to begin on this project. Below Article VII permit. Clean Path New York is targeting Article VII permit
are additional details related to more specific tasks for achieving these issuance on January 31, 2024.
milestone dates: • Environmental Management and Construction Plan. Following
the issuance of the Article VII permit, Clean Path New York will
• Environmental/cultural surveys. Clean Path New York has
immediately file the Environmental Management and Construction
consulted with NYSDEC, USFWS, and other permitting agencies to
Plan. Clean Path New York will be proactively compiling comments
establish protocols for completing the environmental and cultural
as received during project Hearings and Decisions Phase to
surveys for the project. These protocols are anticipated to be in
accelerate approval of the plan. The project schedule anticipates
place by July 2021 to allow for these surveys to begin on July 21,
that this phase will be completed and approved by July 30, 2024.
2021. The surveys are expected to start before the NYSERDA
award date of Q3 2021. However, Clean Path New York is willing to
Major material procurement
progress these activities in advance to achieve the overall COD date
During the Article VII process, Clean Path New York will procure the
indicated above. The environmental/cultural surveys will be largely
major materials for the project. Based on initial discussions with the
complete in Q3 2021 and may continue into Q1 2022. Further detail
material suppliers, lead times are expected to be two years from
regarding these surveys can be found in the Field Investigation Plan
contract execution to initial receipt of materials on-site. Procurement is
developed for Clean Path New York, which is provided in
expected to have the largest duration in the project schedule. These
Appendix 18.
lead times are for the HVDC land and submarine cables and the two
converter stations. Purchasing these major materials in the early
stages of the project will help de-risk the procurement and create
a float of approximately four months. This float period removes the
procurement from the critical path and allows the project adequate • Public Road ROW duct bank installation. Construction of the public
time to respond with mitigation measures in the unlikely event of road ROW duct bank installation will start immediately following
major delays. approval of the Environmental Management and Construction Plan.
This component includes approximately 29 miles of duct bank
Construction installation in primarily NYSDOT and NYCDOT roads and involves
Following receipt of approval of the Environmental Management and installation of a concrete duct bank/conduit system, HVDC cable
Construction Plan from the NYSDPS, Clean Path New York expects pulling, splicing, and terminating activities, trenchless installations,
to immediately start construction with a start date of July 31, 2024. and other construction-related activities. It is anticipated that this
The overall construction duration is expected to be 25 months with section will proceed with three mainline construction spreads for the
a COD date of June 2026 where additional restorations will continue following areas: Orange County, Westchester County, and New York
thereafter. Below are additional details related to the construction City streets with a targeted completion date of May 2026.
activities included in this critical path task: • Submarine installation. Construction of the submarine components
of the transmission route will begin immediately following approval
• Mobilization. The project anticipates mobilizing to the site several
of the Environmental Management and Construction Plan and
months in advance of approval of the Environmental Management
includes 36 miles of submarine installation in the Hudson River
and Construction Plan to the extend permissible. This early
(36 miles), Harlem River (5 miles), and the East River (1 mile). It
mobilization will allow for construction field offices to be installed,
is anticipated that dedicated crews will be engaged for each
material to be received and unloaded at designated material
component previously described, as different installation vessels will
storage yards, and construction management staff to be prepared
be required based on the varying construction parameters required
for immediate start of construction following approval of the
for the various rivers. Further discussion on the construction
Environmental Management and Construction Plan. We anticipate
windows for the submarine installations is provided in Section 13.6.
that construction management and administrative personnel will
mobilize to the project site in April 2024. • Converter station installation. In addition to the transmission line
components, Clean Path New York anticipates commencing the
• NYPA ROW direct bury conduit installation. Construction on the
converter station construction at Fraser and Zone J immediately
existing NYPA ROW component will proceed immediately following
following receipt of the Environmental Management and
approval of the Environmental Management and Construction Plan.
Construction Plan. Each converter station location will require a two-
This includes 105 miles within the existing NYPA ROW from the
phase construction process, the first phase for the site/civil works
Fraser Substation interconnect to the Rock Tavern Substation and
and the second phase for the erection of the converter station with
will involve installation of a direct bury conduit system, HVDC cable
a target completion date of May 2026 and has been validated with
pulling, splicing, and terminating activities, trenchless installations,
several OEM vendors.
and other construction-related activities. It is anticipated that
this section will proceed with three to four mainline spreads of • Project synchronization. Following the completion of the
construction activity to achieve completion by May 2026. construction activities previously described above, the project
schedule allows for a 45-day project synchronization period • Right-of-way support for field investigation program
to commission and test the integrated transmission system
components including the converter and substations) leading to Financing. Financing activities are included in the project schedule as
energization and a subsequent COD date of June 2026. milestones and include activities, durations, and completion dates for
the following:
• Final Investment Decision: targeted for January 2023, mainly tied to

13.4. Preliminary engineering, the receipt of the Article VII permit.
financing, property acquisition, • Construction debit financing due diligence period: one-year duration
permits, environmental assessments, following Final Investment Decision with a targeted completion date
of January 2024
interconnection studies, and financial close • Construction debit financing financial close: targeted for February
The proposed schedule provides details with regards to preliminary 2024
engineering, financing, property acquisition, permits, environmental
Acquisition of real property rights. The proposed project maximizes
assessments, interconnection studies, and financial close. Those are
the use of existing transmission and publicly available project
detailed below.
corridors. This includes the use of the existing NYPA ROW and public
Preliminary engineering. Preliminary engineering for the project NYSDOT and NYCDOT road corridors. Based on this approach, the
commenced in January 2020 and has progressed based on acquisition of real property rights is limited and is focused on securing
assessments, evaluations, field visits, and engagement of various assets for the converter station sites. Preliminary site locations
subject matter experts to develop the project scope described in have been identified, and Clean Path New York is currently in final
this proposal submittal. If selected, the engineering activities will negotiations with the landowners to secure the property locations for
continue to advance following submission of this proposal and include the Fraser converter station and the Zone J converter station.
a field investigation program to collect data to support further project
Federal, state and/or local permits, licenses, environmental
development and detailed design. The Field Investigation Plan is
assessments and/or environmental impact statements (including
attached as Appendix 18 to this proposal and includes the following
anticipated permit submittal and approval dates). Clean Path New
activities:
York has commenced consultation with federal, state, and local permit
• Land-based preliminary civil survey agencies. We have depicted the processes, durations, and anticipated
• Water-based geophysical surveys target dates for receipt of the major project permits in the provided
project schedule. Additional information regarding the permitting
• Field route reconnaissance and constructability reviews
approach is provided in Section 11 of this proposal.
• Geotechnical investigation and soil boring program
• Thermal resistivity/conductivity
• Environmental/cultural surveys
Completion of interconnection studies and approvals culminating in Construction and construction duration. Clean Path New York is
the execution of the Interconnection Service Agreement. Clean Path proposing to commence construction immediately following receipt
New York has submitted an interconnection request to the NYISO and and approval of the NYSDPS Article VII Environmental Management
is expecting a scoping meeting will be held in the near future. It is and Construction Plan on July 31, 2024. Construction for the project is
anticipated that the system impact study phase of the NYISO process anticipated to achieve a COD date of June 2026, with final restoration
will commence in the Summer of 2021. Our team is progressing activities completed by Q3 2026.
toward an interconnection service agreement with NYISO by 2022.
Engineer/procure/construct contracts. Our proposed EPC contracting 13.5. EPC contract activities
strategy is further defined in Section 13.5 of this document. This
Clean Path New York is proposing to engage a program manager
section details the program management approach and contract work
to execute the project and manage interfaces across various
packages that we anticipate using for the project. The anticipated
work packages. The strategy for engaging an EPC or construction
contracts for these services will be initiated at various stages of the
contractor varies based on the work packages. These in turn are
project, as required to support the project COD.
Construction Constructor
Construction Bid processes
contracting pre-qualification
bid packages and awards
strategies process
Cost estimating Safety Instructions to bidders Bid meetings/coordination
breakdowns
Detailed scheduling Environmental compliance Contract T&Cs Bid tabulations/evaluations
Segment/spread Construction scope/ Contractor shortlist

Experience/qualifications
breakdowns schedule interviews
Market/industry research Availability/ Pricing schedules Selection

and conditions competitiveness
Contracting and
Client references Specifications Execution plan
procurement mechanisms
Contract pricing structure Manpower and equipment Permits/commitments Awards/negotiations
Contractor availability Proposed teams ROW stipulations

evaluations Figure 13-2. Summary of
key activities involved in
Execution plan Recommendations selecting construction and EPC
contractors.
developed on the basis of geographic locations, type of installation/ • Work package 1: AC and submarine cable installation (+/- 400 kV DC
methodology, proposed construction activities, preferred risk and 345kV AC) in the Hudson, Harlem, and East rivers from Fraser
mitigation strategy, and other project contracting considerations. Substation (north end of project) to Rainey Substation (south end of
Clean Path New York has developed a comprehensive Preliminary project)
Contracting Strategies and Execution Overview Plan. This plan is • Work package 2: Underground duct bank within existing NYPA
provided in Appendix 19. ROW in Delaware, Sullivan, and Orange counties
The program manager will coordinate early contractor involvement in • Work package 3: Underground duct bank within existing public road
the pre-construction design/planning phase on behalf of Clean Path ROW in Orange, Westchester, Bronx, and Queens counties
New York. The construction contractors involved in this phase will • Work Package 4: Converter Station #1 adjacent to the NYSEG Fraser
contract directly with Clean Path New York. The program manager substation in Delaware County and Converter Station #2 in Zone J
will perform pre-qualification, scoping and bidding, and contract • Work Package 5: Substation interconnect modifications at NYSEG
conformance of the construction contractors on behalf of Clean Path Fraser Substation
New York. The construction contractors will typically support the • Work Package 6: Substation interconnect modifications at CECONY
following activities during the early contractor involvement phase: Rainey Substation
• Constructability and construction methodology
• Construction workspace, access, and work area selection 13.6. Construction windows for aquatic
• Construction cost estimating
• Construction schedule development
sites
• Construction risk management/mitigation Clean Path New York has an understanding of the allowed
construction windows for the proposed in-river submarine installation
• Early construction planning
components of the project, including the Hudson River, Harlem River,
• Construction scope of work development and East River. Based on a preliminary review of previous Army Corps
• Logistics and planning of Engineer permits for similarly scoped projects and conditions, the
• Environmental permit application review and input following are the anticipated submarine construction windows:
• Construction execution plan development • Hudson River: July 1 to January 14
• Execution plan • Harlem River and East River: June 1 to January 14
• Cost
Clean Path New York has incorporated these windows into the overall
• Schedule
project schedule, and these are key drivers to achieving the targeted
• Organization and staffing COD date. Based on a construction start date of July 31, 2024, Clean
• Construction contractor selection Path New York’s schedule utilizes and leverages the allowable
windows to the maximum extent practical. In the event of a schedule
Summary of the work packages delay due to unforeseen conditions, Clean Path New York has
Six construction work packages have been identified and those are investigated several preliminary land alternatives to mitigate the risk
summarized as follows:
to the project and will continue to develop these further during future
project development activities.
13.8. Critical milestones
In addition to the critical path milestones listed in Section 13.3 above
Based on Clean Path New York’s current schedule, the project takes and other key schedule drivers, the project schedule also includes
advantage of the allowed windows and incorporates the following the milestones in Table 13-1 below, which are critical activities for
two construction seasons into the project schedule for the Hudson advancement toward the proposed June 2026 COD date.
River installation. Note that the project currently proposes to install
Activity Milestone
approximately 36 miles of submarine cable within the Hudson River
from New Windsor to Buchanan, NY and from Ossining, NY to the NYISO Interconnection Service Agreement November 25, 2022
Harlem River junction. PSC financing review and approval June 1, 2023
• July 31, 2024 through January 14, 2025 Secure community host agreements January 11, 2026
• July 1, 2025 through January 14, 2026 Environmental/cultural surveys begin July 5, 2021
Civil surveys begin October 1, 2021
For the Harlem River and East River, it is anticipated that only one
construction season will be required for the submarine installation. Right-of-way/land acquisition complete March 14, 2025
Note that the Harlem River submarine installation length is Army Corps of Engineers Section 404/10 February 13, 2024
approximately 5 miles and the East River submarine installation length approval
is approximately 1 mile. For these two rivers, Clean Path New York Detailed engineering complete March 29, 2024
proposes to utilize the first available construction window as shown
NYSDPS Article VII Environmental July 30, 2024
below. This proactive approach leaves the second construction Management and Construction Plan approval
window in 2025 available in the event it is required to complete the
installation. End of other agency coordination window July 29, 2024
Project construction debt financing financial March 12, 2024
• July 31, 2024 through January 14, 2025 close
Cable and converter station procurement March 31, 2022
begins
13.7 Siting, environmental, and NYISO
Major material available March 20, 2024
approvals Construction begins July 31, 2024
Please refer to Section 13.3 for the critical path siting and environmental
Submarine installation (Hudson River) season July 31, 2024
approvals which will be required for this project. Additional 1 begins
information on the regulatory and environmental permitting can be
found in Section 3: Delivery Plan and Section 11: Permitting Plan. Submarine installation (Hudson River) season July 1, 2025
1 begins
Submarine installation (Harlem River) begins July 31, 2024
Project commissioning/operations begins April 29, 2026
Table 13-1. Critical milestones.
Commercial Operation Date June 30, 2026
Section 14
Operational flexibility
and peak coincidence
14 Operational flexibility and peak coincidence
14.1. Contributions of project to operational More details on the modeling conducted by PowerGEM and the
associated assumptions is provided under Appendix 7.
flexibility and peak coincidence in Zone J
The technology
Operational flexibility Clean Path New York proposes to build a New Transmission line
Introduction that will utilize state-of-the-art high-voltage direct current (HVDC)
Clean Path New York has conducted extensive modeling and system technology that can deliver a capacity of 1,300 MW. The proposed
analysis and has engaged in an iterative approach to improve the technology will utilize a voltage source converter (VSC) configured as
proposed New Transmission. Clean Path New York goal is to reliably a symmetrical monopole. A +/- 400 kV operating voltage was selected
export Tier-4 RECs to New York City (Zone J) and to help provide as the optimal voltage to maximize capacity.
additional system benefits such as operational flexibility, relief of
congestion, and reduced curtailment. The below subsections provide This state-of-the-art configuration recommended by Clean Path New
additional explanation on such benefits. York is a feasible and attractive technology that will provide distinct
advantages in controllability and flexibility. The proposed New
Assisted by PowerGEM, Clean Path New York modeled the reliability Transmission is designed to manage challenges mainly arising from
and wholesale energy market impacts of the Resources portfolio and
the New Transmission. The analysis covered the years 2025, 2030,
and 2035. Three scenarios were modeled for each year studied; they
are summarized below as they will be referred to in the subsequent
sections:
1. A Reference Case: This case uses a base case without the New
Transmission and the proposed portfolio of Resources portfolio.
2. A Resources Only Case, which is the Reference Case plus the

portfolio of Clean Path New York Resources.
3. A Resources and New Transmission Case, which is the Resources

Case plus the Clean Path New York New Transmission (a 1,300
MW HVDC interconnect between Fraser substation in Zone E
and Rainey substation in Zone J). Figure 14-1. Inner view of a VSC-HVDC converter (image courtesy of ABB).
the large renewables Resources portfolio and the associated increase station is grounded, and the converter stations are connected to two
in the level of intermittency and unpredictability of generation transmission links at equal and opposite potentials (the HVDC poles
connecting in to the NYISO system. or the cables): the positive pole and the negative pole. A schematic of
the New Transmission is shown in Figure 14-2.
The New Transmission will provide more flexible power flow control to
intelligently maximize the utilization of the Resources while relieving The project will include two VSC HVDC converter stations at each
transmission bottle necks and managing the difficulties of obtaining end of the transmission link: Fraser in Zone E (withdrawal point) and
new transmission corridors in New York State. Additional benefits to Astoria in Zone J (delivery point). At the withdrawal point, the northern
NYISO and the grid include the ability to independently control active converter station will connect to the NYSEG Fraser 345kV yard by
and reactive power and to provide very fast control response and installing a new breaker in a spare bay position in the existing breaker-
black start ability. and-a-half substation. At the delivery point, we plan to connect the
southern converter station to the CECONY 345 kV Rainey Substation
The VSC-based converters offer a great amount of flexibility. The by installing two new breakers and expanding the existing ring bus to
converter employs an Insulated Gate Bipolar Transistor to switch the meet CECONY operations procedures and reliability standards.
DC voltage. It can be turned on and off many times per cycle and
thus is very controllable. This switching commutates the DC voltage The symmetrical monopole link will include a buried section of
to the expected AC voltage of the grid to which it is delivering power. two 2,500 mm2 underground cross-linked polyethylene (XLPE)
The transistors operate based on information provided by the control HVDC cables. A fiber optic communication link will connect the two
systems, increasing the control of real and reactive power with converter stations, with submarine portions of single-core 2500 mm2
reactive compensation capabilities. armored copper XLPE cable in the Hudson, Harlem, and East Rivers,
to Zone J.
The proposed configuration uses a single transformer secondary
that feeds a simple pole. The center of the DC bus of each converter
Converter
transformer
+ + 400 kV pole DC underground cable + Converter
transformer
Zone E Zone J
DC AC
Fraser 345 kV Rainey 345 kV
substation substation
AC DC
1,300 MW - 400 kV pole DC underground cable 1,300 MW

sending receiving
end converter end converter
station station
Figure 14-2. New Transmission schematic.

Enhanced system reliability change in the AC network impedance. This reduces the stresses on
Clean Path New York New Transmission technology enhances the remaining AC transmission lines after a certain relevant contingency.
system reliability to include capabilities to respond and mitigate Additionally, a VSC HVDC system design has an embedded fast
certain contingency events on the system. The VSC HVDC link reactive power control. The converter station at each end can
controls can be configured, and the link can be scheduled to NYISO’s independently act as a STATCOM device, offering reactive power
requirements to respond to specific contingency events. support even when one terminal is out of operation. VSC stations
have no minimum short circuit capacity requirement and can thus be
Clean Path New York reliability attributes can be summarized as used to black start one terminal from the other and quickly energize
follows: a blacked-out AC network.
• The New Transmission VSC HVDC terminals and their inherent
performance characteristics can maintain and potentially
Load savings
As New York progresses towards its CLCPA targets, the percentage
increase significantly the transmission transfer capability (TTC) if
of renewable generation on the system is expected to significantly
considered as an integral part of TTC. Under contingency events,
increase. With this increase, congestion and curtailment must be
the VSC HVDC link controls can be configured, and the link can
addressed to ensure that benefits of these renewables are adequately
be scheduled to NYISO’s requirements to respond to specific
captured. Clean Path New York will play a pivotal role in reducing
contingency events. This is not novel or unique: At multiple global
congestion, reducing curtailment, and decreasing total load costs
and local projects, HVDC is an integral part of the existing internal
to customers and ratepayers as more and more of New York State’s
control area interface and is managed by the relevant independent
energy is generated from renewable sources.
system operator. The Mackinac project in Michigan is an excellent
example.1 This can be done by measuring voltages and currents
locally at the HVDC terminals and having the HVDC controls
respond to changes in such data to meet NYISO TTC requirements
and remain compliant with NERC requirements.
• The New Transmission VSC HVDC can emulate an AC line in terms

of responding to a contingency. This can be done by automatically
changing the power flow on the line based on sudden changes
to the voltage phase angle at the terminals. This requires only
locally measured signals at both ends, without the need for a
wider communication protocol. In summary, the VSC is capable
of automatic power changes (e.g., as part of an AC line emulation
functionality) in the event of major disturbances that give a large
1
https://www.atc-projects.com/projects/mackinac-hvdc-flow-control-project/ Figure 14-3. Clean Path New York will play a pivotal role in increasing renewable generation.
Conducted modeling shows that in 2025 the Resources and New

Transmission Case, will provide New York State with total load
payment savings of $242 million, or 5%. About $96 million of these
savings will be in Zone J. In 2030, as more renewables are added to
$12 billion
total load payment savings over 25-year
the system to meet the State’s 70% renewables by 2030 goal, the NYSERDA contract period
Resources and New Transmission Case reduces the statewide load
payments even further, by $438 million. This is an 11% reduction in the
amount New York State ratepayers pay for their electricity. A little less years modeled by PowerGEM to interpolate the total load payment
than half of these savings will be in Zone J, where load payments will savings over the 25-year NYSERDA contract period. This was done
decline $204 million. For the same Resources and New Transmission by using a weighted average of the 2025 and 2030 results for the
Case, these savings are projected to be even higher in 2035, with next four full years of operation. Similarly for the period 2030 to 2035,
statewide load payments reduced by $528 million or 13%, and Zone J PowerGEM’s 2030 results were used for the fifth year of operation
load payments by $247 million or 16%. and a weighted average of the 2030 and 2035 results for years six
through nine. As for the 16 years after 2035, PowerGEM 2035 results
Clean Path New York estimates that the total load payment savings were used uniformly throughout. Those savings are in today’s nominal
will amount to $12 billion over the 25 years NYSERDA contract period. dollars, with no escalation factor applied.
This was calculated using the load payments savings from the three
Total load payment savings

2035
New York State
Zone J $528
2030 million
$438
million
2025
$242 $247
$204 million
million
million
Figure 14-4. Total load payment savings

$96
will continue to increase in New York State million
and subsequently in Zone J.
Congestion
Much of the load savings discussed above comes in the form of
reduced congestion over the Total East interface, a critical internal
transmission constraint in the New York Control Area. Congestion
over Total East keeps renewable generation in upstate and western
New York from reaching customer demand in southeastern New York.
As renewables are developed in upstate and western New York,
congestion over this interface will continue to increase.
Generally speaking, adding generation without improving the

transmission system increases congestion. For the Resources Only
Case in 2025, modeling shows that congestion more than doubles
over the Total East interface, increasing congestion costs up to $123
million. However, the Resources and New Transmission Case for the
same year shows a reduction in net congestion by $145 million relative TOTAL EAST
to the Resources Only Case.
$145M
savings in congestion
relative to the Reference
Case
$5.6B
UPSTATE
DOWNSTATE
total load payment savings
over 25-year NYSERDA
contract period
Figure 14-5. New York State Total East grid constraints (image courtesy of NYISO).
This pattern holds true for 2030. Using the Resources Only Case becomes more congested. In 2030, Resources and New Transmission
and meeting the state 70% renewables by 2030 goal, increases Case relieves 21% of the congestion over the UPNY-SENY interface,
congestion costs over the Total East interface by $103 million, or 31%. and in 2035 it relieves 59%.
This case is a good representation of what congestion in the state
will look like without the Clean Path New York New Transmission. Clean Path New York estimates that the total savings in congestion
Modeling the Resources and New Transmission Case reduces costs over Total East will amount to $5.6 billion over the 25 years
congestion costs over Total East by $250 million, making the NYSERDA contract period. This was calculated using the Total East
net impact of Clean Path New York in 2030 to be $146 million congestion savings from the three years modeled by PowerGEM to
or a 44% reduction of congestion costs over Total East. interpolate the total load payment savings over the 25-year NYSERDA
contract period. This was done by using a weighted average of
In 2035, the net impact is even greater, Resources and New the 2025 and 2030 results for the next four full years of operation.
Transmission Case reduce Total East congestion costs by $154 million Similarly for the period 2030 to 2035, PowerGEM’s 2030 results were
or 55%. used for the fifth year of operation and a weighted average of the
2030 and 2035 results for years six through nine of operation. As for
The Upstate New York–Southeast New York interface (UPNY-SENY) the 16 years after 2035, PowerGEM 2035 results were used uniformly
is not a binding constraint in the modeled 2025 Reference Case. throughout. Those savings are in today’s nominal dollars, with no
However, as renewables penetration increases across the state, it too escalation factor applied.
$103 million $2 billion

increment due to addition increment due to addition
of Resources of Resources
$250 million $5.6 billion
$333 million savings in congestion due $6.7 billion savings in congestion due
Reference Case to Clean Path New York's Reference Case to Clean Path New York's
New Transmission New Transmission
$187 million $3.1 billion

congestion Resources and congestion Resources and
New Transmission Case New Transmission Case
Figure 14-6. Clean Path New York 2030 congestion impact over Total East interface. Figure 14-7. Clean Path New York 25-year congestion impact over Total East interface.
Renewables curtailment
As with congestion, curtailment of renewable Adding the Clean Path New York portfolio
generation increases over time, as a greater
of Resources and New Transmission to the
proportion of the state’s generation comes from
renewable resources. In the 2025 Reference Case,
reference case reduces renewable curtailment
renewables are curtailed around 0.1% of the time. In allowing additional generation to be dispatched.
the 2025 Reference Case, curtailment increases a
hundredfold, to 10%. When renewables are curtailed,
they cannot be delivered to customers. Additional
energy must be generated to serve those customers,
often from less efficient generating sources.
2.9 TWh 2.05 TWh
Increases renewables flow Increases renewables flow
by 25% by 2030 by 8.6% by 2035
In 2030 the Resources Only Case increases
renewables curtailment by 3.6 TWh, bringing
renewable curtailment in the state to 7.7%. Again, Capacity market benefits
this 2030 Resources Only Case with no incremental At present, as discussed in more details under Section 5, the NYISO does not have
transmission to bring the power downstate represents rules to allow Clean Path New York New Transmission and other intrastate HVDC
the level of curtailment the state should expect to transmission projects to secure capacity rights. However, Clean Path New York can
see if the 70% renewable by 2030 goal is met and still provide significant capacity benefits to customers in Zone J. As the percentage of
no additional transmission is added to the system. New York State’s energy from renewables increases, the installed capacity required to
Adding the New Transmission to this case (Resources meet the state’s resource adequacy criterion will increase as well. Clean Path New York
and New Transmission Case) reduces the state’s is expected to have a significant positive impact on the Zone J Locational Minimum
renewable curtailment by 25%, from 7.7% to 5.8%, Installed Capacity Requirement (LCR).
and allows for an additional 2.9 TWh of renewable
In 2020, the New York State Reliability Council looked at the impacts of large volumes
generation to be dispatched.
of intermittent renewables on the state’s reliability criteria.2 The Council modeled a
In 2035, when the state is seeing a full 10% of its hypothetical scenario with 12,000 MW of renewable generation, almost 4,500 MW
renewable generation curtailed in the Resources Only located in New York City and Long Island. Under such a scenario, the state’s Installed
Case, the Resources and New Transmission Case Reserve Margin increased to 142.9% from a baseline of 118.6%. The impact on the LCRs
reduces curtailments to 8.6% and allows an additional in downstate New York was also significant. New York City’s LCR increased to 97.9%
2.05 TWh of renewables to be dispatched onto the from a baseline of 83.9%.
system.
These increases in LCR have a direct impact on customers, who will have to purchase
additional capacity due to higher LCRs. It is also important to note that, while 12,000 MW
is a significant amount of generation, New York will have to install about twice as many
https://nysrc.org/PDF/MeetingMaterial/ECMeetingMaterial/EC%20 renewables to achieve its goal of meeting 70% of its energy needs from renewables by
2
Agenda%20252/4.2a%20HR%20White%20Paper%20-%20Clean%20
Final%20Draft-Attachment%204.2a.pdf 2030.
4 contract. Clean Path New York, however, will continue to be a

transmission asset controlled by the NYISO to allow for efficient and
reliable dispatch of the New York state electric grid.
While a revenue mechanism to ensure high-quality operation and

maintenance of the transmission would need to be determined, the
project would be largely depreciated, meaning that New York State
ratepayers could benefit from its continued operation for much less
money than it would cost to build additional transmission.
Peak coincidence
As an internal controllable HVDC line operated by the NYISO,
Figure 14-8. Ravenswood Generating Station in Queens. Clean Path New York will provide the New York system operator
with significant operational flexibility. Clean Path New York will
We can confidently claim that Clean Path New York New Transmission be dispatched by NYISO, which can use the line to respond to
connecting Zone J and upstate New York can help mitigate this contingencies and other system emergencies. Dispatch by the
increase. When the New Transmission goes into service, the NYISO will also ensure that the operation of Clean Path New York
incremental transmission capability will measurably lower the Zone J complements peak coincidence and other market conditions in Zone J.
LCR. This benefits the state directly, by reducing overall capacity costs
to Zone J ratepayers, and indirectly, by decreasing the volume of in- The generation resources will facilitate the NYISO’s dispatch efforts
city generation that must remain in service to meet the LCR. by balancing flows across capability periods. Of the 7,496,113 MWh
delivered by Clean Path New York, 3,732,462 MWh (49.8%) will be
Post Tier-4 contract benefits delivered in the summer capability period and 3,763,650 MWh (50.2%)
As time passes, the system benefits of Clean Path New York will allow will be delivered in the winter capability period.
for change in the overall electric system. Lower LCRs will allow for the
Clean Path New York will have the ability to flow from south to north if
retirement of in-city fossil fuel generation, and reduced congestion
NYISO dispatch and market conditions were to dictate this dispatch.
and renewable curtailment throughout the state will allow for the cost-
Such conditions might include full-capacity generation of 9 GW of
effective development of additional in-state renewables. The state’s
offshore wind during a period of low load in Zones J and K. If the line
electrical grid will evolve to incorporate and rely on the transmission
were to flow south, it would allow for this offshore wind energy to be
capability provided by Clean Path New York.
delivered to upstate New York customers, rather than being curtailed
As a project fully integrated with the New York Control Area, Clean or exported to out-of-state markets.
Plath New York will continue to be a transmission resource for the
The proposed New Transmission technology is capable of automatic
state even after any Tier 4 REC contract with NYSERDA has ended.
power changes in the event of major disturbances that give a large
Practically, the owners of any transmission projects connected
change in the AC network impedance. This reduces stresses of
into Zone J from outside the New York Control Area could elect to
remaining AC transmission lines in certain contingency conditions.
stop sending power into Zone J following the conclusion of a Tier
14.2. P(50) delivery schedule of aggregate

Zone J energy deliveries
Clean Path New York offered portfolio of Resources and New
Transmission will meet both the summer and winter minimum
deliverability requirement as defined in the RFP.
We are submitting under Appendix 21, and also uploading as an Excel

workbook, the P(50) 8760 schedule of aggregate Zone J energy
deliveries to supplement the 12 x 24 delivery schedule provided in
the Offer Data Form, Delivery Profile worksheet. The 8760 delivery
schedule represents the aggregate of all proposed Resources into the
Zone J Delivery Point with and without Blenheim-Gilboa storage.
Section 15
Communities
engagement plan
15 Communities engagement plan
15.1. Introduction
Clean Path New York proposes this Communities Engagement Plan Communities surrounding the generation projects and along the
(CEP) as a companion to Section 16, Incremental Economic Benefits proposed transmission line will have the opportunity to have their
Plan, and as a starting point for consultation and collaboration with voices heard and to be partners along the way. Clean Path New
NYSERDA on developing and implementing an inclusive and equitable York will emphasize engagement with Disadvantaged Communities
plan that achieves the outcomes envisioned by the Climate Leadership and at-risk populations to ensure that they can equally benefit from
and Community Protection Act (CLCPA). opportunities the project will provide.
Robust community engagement is vital to any successful project. The goals of this CEP are as follows:
Clean Path New York will develop a comprehensive CEP that will
provide key stakeholders, interested parties, and the public at
large with project information throughout development, permitting,
construction, and operation. Project representatives will proceed with
1 Inform and educate stakeholders about the project
proactive outreach to public and private community stakeholders.

Clean Path New York encourages public input as a way to share
information, develop necessary relationships to ensure appropriate 2 Advise stakeholders and the public on how to contact Clean
Path New York with questions regarding the project
project implementation and improve upon existing ideas about how to
Provide transparency between stakeholders and Clean Path
incorporate communities into the new green economy.
Clean Path New York is proposing to construct approximately 2,000

3 New York throughout the Article VII, Article 10, and Office of
Renewable Energy Siting (ORES) processes
MW of new solar generation throughout upstate and western New
York; approximately 1,800 MW of new wind generation, also in
upstate and western New York, and a new 1,300 MW underground
4 Solicit and consider stakeholder and public input to minimize
impacts
and underwater HVDC transmission line beginning in Delhi, NY and
terminating in Queens, NY.
5 Demonstrate a commitment to the community outreach
process
6 Execute all identified mandatory outreach under the Article VII,

Article 10, and ORES processes
. Description and analysis of communities hosting

To aid the NYSERDA review team with their evaluation of this CEP,
generation Resources
Figure 15-1 below depicts the location of the various solar and wind
Clean Path New York has developed the following structure:
Resources throughout the state.
• Part 15.2. Communities hosting the generation Resources.
• Part 15.3. Communities hosting the New Transmission infrastructure.
Figure 15-1. Clean Path New York's
– In both cases, Clean Path New York will provide a description wind and solar Resources are located
and analysis of the affected communities, along with standard throughout New York State.
permitting requirements related to public involvement.
• Part 15.4. Engagement strategy
– In this CEP we will summarize targeted education and marketing
strategies, and inherent economic and environmental benefits.
These inherent economic benefits are the basis upon which the
incremental economic benefits are
founded and presented in Section 16.
– As Category 3 Benefits, these
initiatives are quantified and described
in further detail in the Section 16
Incremental Economic Benefits Plan.
• Part 15.5. Alignment with the CLCPA.
• Part 15.6. Proposed Progress Reports to
NYSERDA.
15.2. Communities hosting generation

resources
This section provides a detailed description of the communities
hosting the generation resources and the public engagement required
in the permitting process.
The population of each county and town that hosts a Resource facility
is detailed in Table 15-1 below. The population data was derived from
the 2010 US Census. More recent data sources were used where
available.
Capacity County Town

Developer Project name (MW-AC) Technology County population Town population
Invenergy Alle-Catt 142 Wind Allegany 48,946 Centerville 822
Allegany — Rushford 1,111
157 Wind Cattaraugus 80,317 Freedom 2,299
Cattaraugus — Farmersville 1,053
40 Wind Wyoming 42,155 Arcade 4,118
Invenergy Bull Run Wind 449 Wind Clinton 82,128 Altona 2,900
Clinton — Ellenburg 1,827
Clinton — Clinton 1,830
Clinton — Mooers 12,958
Invenergy Canisteo 290 Wind Steuben 98,990 Cameron 926
Steuben — Canisteo 2,341
Steuben — Jasper 1,424
Steuben — Greenwood 801
Steuben — Troupsburg 1,267
Steuben — West Union 300
Steuben — Hornellsville 3,991
Invenergy Horseshoe 15 Solar Monroe 741,770 Rush 3,478
165 Solar Livingston 62,914 Caledonia 2,078
Invenergy Number Three 105 Wind Lewis 26,572 Harrisburg 428
Lewis — Lowville 3,233
Invenergy Verona 1 200 Solar Oneida 228,671 Verona 1,024
Invenergy Verona 2 150 Solar Oneida — Verona —
Invenergy Bull Run Solar 170 Solar Clinton 82,128 Clinton 1,830
Clinton — Ellenburg 1,827
Clinton — Mooers 3,589
Table 15-1. The population of each town and county where a Resource is located.
Capacity County Town

Developer Project name (MW-AC) Technology County population Town population
Invenergy Wintergreen 75 Solar Montgomery 49,221 Canajoharie 1,905
Montgomery — Root 1,677
Invenergy Taproot 205 Solar Montgomery — Charleston 1,373
Montgomery — Glen 2,507
Invenergy Seventy-Seven (Sheldon) 100 Solar Wyoming 42,155 Sheldon 2,409
Invenergy Orangeville 75 Solar Wyoming 42,155 Orangeville 1,308
Invenergy Twinleaf 75 Solar Lewis 26,572 Croghan 3,033
Northland Bluestone 124 Wind Broome 190,488 Windsor 999
Broome — Sanford 2,305
Northland High Bridge 100 Wind Chenango 47,909 Guilford 2,922
RWE Baron Winds 238 Wind Steuben 98,990 Cohocton 2,500
Steuben — Dansville 1,800
Steuben — Fremont 1,000
Steuben — Wayland 4,000
Northland Ball Hill 100 Wind Chautauqua 134,905 Villenova 1,100
Apex Heritage 147 Wind Orleans 42,883 Barre 2,000
Terra-Gen Prattsburgh Wind Farm 145 Wind Steuben 98,990 Prattsburgh 2,000
Steuben — Wheeler 1,200
Steuben — Avoca 2,100
Steuben — Howard 1,400
Steuben — Troupsburg 2,500
Boralex Greens Corners (NY38) 120 Solar Jefferson 116,229 Watertown 27,000
Jefferson — Hounsfield 3,500
Table 15-1 (continued). The population of each town and county where a Resource is located.
Table 15-2 below provides a list of the affected school districts.
Generation school districts Generation school districts

Alle-Catt Cuba Rushford Central School District Seventy-Seven Yorkshire-Pioneer Central School District
Yorkshire- Pioneer Central Schools Attica Central School District
Franklinville Central School District Orangeville Warsaw Central School District
Fillmore Central School Twinleaf Beaver River Central School District
Bull Run Wind Northern Adirondack Central School District Bluestone Deposit Central School District
Northeastern Clinton School District Windsor Central School District
Canisteo Addison Central School District High Bridge Bainbridge-Guildford Central Schools
Canisteo-Greenwood Central School District Norwich Central Schools
Hornell City School District Gilbertsville-Mt Upton Central School District
Jasper-Troupsburg Central School District Baron Wayland-Cohocton Central Schools
Horseshoe Avon Central School Dsitrict Alfred-Almond Central Schools
Caledonia-Mumford Central School District Arkport Central Schools
Number Three Lowville Academy and Central School Canisteo-Greenwood Central Schools
Copenhagen Central School District Avoca Central Schools
Verona 1 Vernon-Verona-Sherrill Central Schools Hornell City School District
Oneida City School District Heritage Albion Central School District
Verona 2 Vernon-Verona-Sherrill Central Schools Ball Hill Wind Forestville Central School District
Bull Run Solar Northern Adirondack Central School District Pine Valley Central Junior/Senior High School
Northeastern Clinton School District Prattsburgh Prattsburgh Central School district
Wind
Wintergreen Canajoharie Central School District Onondaga Central School District
Taproot Canajoharie Central School District Avoca Central Schools
Fonda-Fultonville Central School Dsitrict Greens Corners Watertown City School District
Table 15-2. A list of school districts affected by a nearby Resource. South Jefferson Central Schools
Sackets Harbor Central Schools
Potential Environmental Justice Areas (PEJA) in proximity to the generation Resources are depicted in
Figure 15-2 below. The PEJAs indicated are based on data provided by the New York State Department of
Environmental Conservation Office of Environmental Justice.1
Figure 15-2. PJEA

areas in New York
State.
1
Wind
PJEA and
source: Solar Generation Projects
https://www.dec.ny.gov/pubs/103459.html Tier 4 Proposal
A map of New York State Opportunity Zones is provided in Figure Article 10 and ORES process
15-3 below. As detailed in Section 11, Permitting Plan, many of these generation
resources are in the late stages of development and were previously
Additional demographic data of each community hosting the
subject to New York State’s Article 10 Law administered by the New
generation Resources is provided in Appendix 23.
York State Public Service Commission. The balance of the resources
As the definition of disadvantaged communities comes into focus, the will participate in the new process established by the Accelerated
Clean Path New York team will work with NYSERDA to ensure that Renewable Energy Growth and Community Benefit Act. The process
the most recent low-income census tracks, potential Environmental is administered through the new Office of Renewable Energy Siting
Justice Areas, and New York Opportunity Zones hosting or in (ORES), which is housed within the New York State Department of
proximity to the project are given priority regarding the Incremental State. Both permitting processes allow for public involvement, and
Economic Benefits Plan of the project, in line with the objectives of the Clean Path New York is committed to working with the affected
CLCPA.. communities to minimize impact throughout the duration of the
project.
Legend
High poverty/high income
High poverty/low income
Low poverty/high income
Low poverty/low income
Figure 15-3. Map of New York State opportunity zones by criteria.

The Department of Public Service (DPS) provides guidance on The regulations require an applicant to submit a written plan
preparing a Public Involvement Plan for all Article 10 applicants. An describing its proposed program to DPS for review at least 150
excerpt is provided below: days prior to submission of a preliminary scoping statement. DPS
Staff will provide specific comments to the applicant if it finds
Article 10 of the Public Service Law empowers the State of New the proposed plan is inadequate. This guidance memorandum
York Board on Electric Generation Siting and the Environment offers suggestions that potential applicants should consider in
(Siting Board) to issue Certificates of Environmental Compatibility developing PIP plans. Every project and every community will
and Public Need (Certificate) authorizing the construction of major have its own characteristics and public information needs, and
electric generating facilities. On July 17, 2012, the Siting Board DPS encourages potential applicants to tailor their proposals
adopted regulations to implement Article 10. The regulations accordingly.2
include requirements that are intended to “ensure that the Board
is aware of the concerns of stakeholders” and to encourage The Accelerated Renewable Energy Growth and Community Benefit
stakeholder participation throughout the certification process. Act requires ORES to promulgate regulations within one year of its
effective date, which was March 3, 2021. These new regulations
One of the key element [sic] of the regulations is the requirement include specific requirements regarding community engagement:
that applicants develop and implement a Public Involvement
Program (PIP). Section 1000.4 of the regulations specifies that the §900-1.3 Pre-application procedures
program must include:
(b)Meeting with community members. No less than sixty (60)
1. consultation with the affected agencies and other stakeholders; days before the date on which an applicant files an application,
2. pre-application activities to encourage stakeholders to and following the meeting(s) held pursuant to subdivision (a) of
participate at the earliest opportunity; this section, the applicant shall conduct at least one meeting for
community members who may be adversely impacted by the siting
3. activities designed to educate the public as to the specific
of the facility. The purpose of the meeting is to educate the public
proposal and the Article 10 review process, including the
about the proposed project, including the anticipated application
availability of funding for municipal and local parties;
date and information regarding the future availability of local agency
4. the establishment of a website to disseminate information to the account funds, citing to the requirements set forth in Subpart 900-
public; 5 of this Part, including, but not limited to, the requirement that
5. notifications; and any local agency or potential community intervenor shall submit
6. activities designed to encourage participation by stakeholders a request for initial funding within thirty (30) days of the date of
in the certification and compliance process. application filing and that such request be made to the Office of
Renewable Energy Siting, at the Albany, New York office, Attention:
Potential applicants should note that a PIP should be designed to Request for Local Agency Account Funding. The applicant shall
facilitate public participation at all phases of the Article 10 process, provide notice of the meeting no sooner than thirty (30) days and no
from pre-application through certification and compliance. later than fourteen (14) days prior to the meeting in accordance with
the publication requirements of section 900-1.6(c) of this Part.
2
https://www3.dps.ny.gov/W/PSCWeb.nsf/96f0fec0b45a3c6485257688006a701a/6fd11ce8db088a2785257e200054a99b/$FILE/PIP%20Guidance%20Document%202.8.13.pdf
(c) The applicant shall provide as part of the application copies

of transcripts (if any), presentation materials, and a summary
15.3. Communities hosting New
of questions raised and responses provided during the pre- Transmission resources
application meeting(s). In the event the applicant is unable to This section provides a detailed description of the communities
secure a meeting with a municipality, the application shall contain a hosting the New Transmission facility of Clean Path New York and the
detailed explanation of all of applicant’s best efforts and reasonable public engagement required in the permitting process.
attempts to secure such meeting, including, but not limited to, all
written communications between the applicant and the municipality. Description and analysis of communities hosting New
(d) At least sixty (60) days before the date an applicant files an
Transmission infrastructure
Figure 15-4 below depicts the location of the new HVDC transmission
application, the applicant shall publish a notice of intent to file
line and facilities:
an application in accordance with the publication requirements
of section 900-1.6(c) of this Part and provide a copy thereof to
the Office, and to all local agencies in attendance at the pre-
application meeting. The notice of intent to file an application may
be included as part of the notice requirement of subdivision (b) of
this section. The notice shall contain, at a minimum, the following:
(1) A brief summary of the proposed facility and location;
(2) A designated contact person, with telephone number, email

address and mailing address, from whom information will be
available on a going-forward basis, as well as a proposed
project website to disseminate information to the public; and
(3) A statement of future availability of local agency account

funds, citing to the requirements set forth in Subpart 900-5 of
this Part, including, but not limited to, the requirement that any
local agency or potential community intervenor shall submit a
request for initial funding within thirty (30) days of the date of
application filing and that such request be made to the Office
of Renewable Energy Siting, at the Albany, New York office,
Attention: Request for Local Agency Account Funding.3
Clean Path New York has developed this CEP with these Article 10
and ORES public involvement guidelines and requirements in mind.
Figure 15-4. Proposed New Transmission route overview map.
3
https://ores.ny.gov/system/files/documents/2021/03/chapter-xviii-title-19-of-nycrr-part-900-subparts-900-1-through-900-15.pdf
The 10 counties and 54 municipalities that host the New Transmission County Town EJ community
facility are detailed in Table 15-3 below. The population data was County pop. Municipality pop. within town?
derived from the 2010 US Census. More recent data sources were
used where available.
County Town EJ community

County pop. Municipality pop. within town?
Table 15-3. A list of towns and counties that host the New Transmission.
Table 15-4 below, based on public data, provides a list of the 38 County/
school districts in areas hosting the New Transmission resource. This borough School district AssetTx facility
list is preliminary and subject to any changes to the proposed route.
County/
borough School district AssetTx facility
Table 15-4. A list of school districts near the New Transmission line.
Potential Environmental Justice Areas (PEJA) hosting and in proximity

to the New Transmission facility resources are depicted in Figures 15-5
through 15-10 below. The PEJAs indicated are based on data provided
by the New York State Department of Environmental Conservation
Office of Environmental Justice.4
Figure 15-6. Potential EJ area map #2.
4
PJEA source: https://www.dec.ny.gov/pubs/103459.html Figure 15-7. Potential EJ area map #3.

Maps of New York State and New York City Opportunity Zones are Additional demographic data on each community hosting the New
provided below in Figures 15-11 and 15-12 below. Transmission resource is provided in Appendix 24.
Legend
High poverty/high income
High poverty/low income
Low poverty/high income
Figure 15-11. New York State Opportunity Zones.

As the definition of disadvantaged

Legend communities comes into focus, the Clean
High poverty/high income Path New York team will work with NYSERDA
High poverty/low income to ensure that the most recent low-income
Low poverty/high income census tracks, potential Environmental
Justice Areas, and New York Opportunity
Zones hosting or in proximity to the project
are given priority regarding the Incremental
Economic Benefits Plan of the project, in line
with the objectives of the CLCPA.
Article VII process

As detailed in Section 11, Permitting
Plan, the transmission infrastructure of
the project is subject to the permitting
requirements of Article VII of the New York
State Public Service Law and must receive
a Certificate of Environmental Compatibility
and Public Need from the New York State
Public Service Commission (PSC) prior to
construction commencement. The Article
VII process allows for public involvement,
and Clean Path New York is committed to
working with the affected communities to
minimize impact throughout the duration of
the project.
Figure 15-12. New York City Opportunity Zones.

Guidelines provided by the PSC regarding public involvement: Clean Path New York has developed this CEP with the Article VII,
Article 10, and ORES public involvement processes in mind. Clean
The Commission strongly encourages applicants to voluntarily Path New York intends to go above and beyond the recommendations
communicate with the public early in the project’s planning phase, to ensure an equitable outcome for all New York stakeholders.
as well as during all subsequent phases of the Article VII process.
A public involvement program is made up of a variety of public
activities to achieve different objectives during the course of the 15.4. Engagement strategy
Article VII process.
Clean Path New York’s goal is to build support, respond to questions
• To first alert the public to its proposal, an applicant may choose or concerns, and provide opportunities to build community equity
to conduct an awareness campaign using fliers, print and in the project. This section presents Clean Path New York’s overall
broadcast media, information kiosks, bill stuffers, brochures, engagement strategy and the community benefits common to both
videos or displays. the generation and transmission aspects of the project. A summary of
• To explain its proposal to the public, an applicant may choose to these benefits is provided in this CEP , while detailed descriptions and
hold open public forums, tours, or one-on-one discussions or to quantification of the eligible Category 1-3 benefits and programs are
offer speakers to established groups that meet regularly. provided in Section 16, Incremental Benefits Plan.
• To collect input and provide feedback, an applicant may choose The Clean Path New York team comprises both public and private
to hold focus groups or public meetings, or use surveys, entities that have excellent existing relationships throughout New
questionnaires, public comment cards, direct mailings or an York, and along the proposed transmission route and at the respective
Internet Website. generation sites. Utilizing the existing reputations and relationships
• To establish a presence in the community, an applicant may of NYPA and Invenergy, and expanding their reach, the team will
choose to open a field office, establish a toll-free telephone line coordinate several methods of outreach.
or a community advisory group.
NYPA and the Forward Power team are deeply experienced with
• To keep the public informed and provide information and direct outreach to residents and other stakeholders in the context of
updates, an applicant may choose to use a pre-recorded new transmission development. For its generation projects, Invenergy
telephone line, a newsletter, or local radio or public access uses a range of tools from direct mailings to open houses and virtual
television, or to hold briefings or issue technical reports or fact events. These outreach campaigns can last years and cover all phases
sheets. of project implementation and operation.
Regardless of which tools are used, an applicant should identify
its stakeholders and develop a public involvement plan with
techniques and tools to communicate with the community.5
5
https://www3.dps.ny.gov/W/PSCWeb.nsf/96f0fec0b45a3c6485257688006a701a/a021e67e05b99ead85257687006f393b/$FILE/19336071.pdf/Article%20VII%20Guide%20Web%2011-17%20Final.
pdf - Page 6.
Outreach to Environmental Justice (EJ) communities will be prioritized. interacting with community boards, political leaders, and strategic
The Clean Path New York project will seek to fund and replicate key partners. All these stakeholders will play an essential role in the
aspects of NYPA’s dedicated EJ program, which has been in existence success of Clean Path New York and proposed community outreach
since 2001. programs.
In 2016, NYPA’s EJ team embarked on a listening tour that included Clean Path New York is accustomed to executing a long-running
extensive conversations with community-based organizations, series of different outreach efforts associated with a single project
EJ advocates, local schools and elected representatives. These over its lifecycle. Clean Path New York intends to go above and
engagements culminated in a revamped EJ program for the benefit beyond the minimum requirements outlined by Article VII, Article 10,
of and informed by the underserved communities. A cornerstone of and the ORES permitting processes. Local outreach and relationship
the program is a fully integrated, enterprise-wide plan that aligns with building is integral to Clean Path New York’s development approach
NYPA’s strategic initiatives, State energy policy, and the environmental and project success. A range of tools may be used depending on
concerns of communities. NYPA’s EJ staff works side by side with the need. A notification of a particular permit filing may require a
neighbors at community fairs, neighborhood beautification projects, postcard, and an introductory which notice may be also coupled with
and back to school events across the state. events such as a series of open houses, online events, etc.
These opportunities help Clean Path New York develop a deeper, Tailoring outreach strategies is important to reaching the largest and
one-on-one understanding of the concerns and challenges of most diverse audience. The team will use a combination of methods in
those who live in EJ communities. The NYPA EJ team is committed different areas and different communities.
to developing and maintaining relationships with Clean Path New
York’s statewide stakeholders. NYPA’s EJ programs are designed to Typical outreach activities to build public acceptance for projects will
meet the specific challenges of local communities and often include include:
workshops and engagements on weekends, evenings, and public • Open houses and events (in person and/or virtual)
holidays to best accommodate community members. Transportation
• One-on-one meetings with stakeholders
can be a barrier to participation, so the EJ team often travels to deliver
workshops and programing at local schools or community centers. • In-person presentations at town and county meetings
NYPA’s EJ outreach program and methods will serve as a model to be • Direct mail to residents of specified target areas, with mailing lists
utilized by Clean Path New York throughout the project’s footprint. developed by internal team using public datasets
• Collateral materials including project fact sheets, FAQs, myths/facts
Making a meaningful impact in this space means working at the
documents, posters, maps, and presentations
grassroots level and building relationships with the communities
Clean Path New York both impacts and serves. Clean Path New York • Print, radio, and online ads through local news outlets
will utilize an investment model that leverages the experience and • Earned media with local news outlets
relationships of its partnership’s regional offices to listen to those • Flyers posted at community venues such as post offices, libraries,
communities, understand the issues they are facing, and make town halls, etc.
informed decisions. As fixtures in the communities they serve, the
project’s regional offices will identify and respond to local needs by
• Project websites, project social media communities, and/or notices The Clean Path New York stakeholder list will be continuously
posted to the Clean Path New York website and social media updated to reflect changes and additional stakeholders as the project
channels progresses.
• Goodwill activities including charitable giving to community causes
Project hotline
• Documentation and affidavits of all of the above to satisfy any proof
A telephone hotline will allow interested stakeholders to reach the
requirements of DPS
project team to get their questions answered and provide feedback.
At every step of the way, the public will be informed of the various Clean Path New York will publicize the hotline on project collateral, the
aspects of the projects — from the potential environmental impacts, project website, and direct mail pieces. The local hotline number and
to process and participation, to economics and opportunities for message system will operate 24 hours a day. The message system
employment and small business engagement through the supply will be checked every business day by the stakeholder relations team,
chain. Clean Path New York understands the impact that COVID-19 who will respond to inquiries within 24 hours or the next business day.
has had on many of our communities of color, and special emphasis
will be placed on MWBEs and employment outreach in these areas. Stakeholder meetings
Face-to-face meetings are critical to the success of Clean Path New
Targeted education and marketing York, and our team will conduct proactive outreach and respond to
Clean Path New York’s stakeholder relations team will focus its any requests for meetings. Interested stakeholders will be able to
education and communications efforts on engaging with the following request a meeting in a variety of ways: website, hotline, or email.
key stakeholders: Clean Path New York’s accessibility is important to a strong outreach
program.
• Landowners abutting the proposed generation and transmission
projects Clean Path New York will also host public information meetings
• Impacted communities throughout the duration of the project. These meetings will be
scheduled after the applications for either Article VII, Article 10, or
• Elected officials and agency regulators at the state, county, and
the new ORES siting process have been submitted, and will be in a
town levels representing most or all of the counties and towns
public setting such as a library or community center. The meetings
serving as host communities to the generation Resources and New
will be scheduled for various times during the day to accommodate
Transmission line
differing schedules. Information regarding the time and location of
• Local emergency service personnel the meetings will be provided via direct mail to the stakeholder list
• Local transportation authorities and landowner list. The information will also be posted to the project
• Environmental organizations and special interest groups website and communicated to local media outlets.
• Civic and business groups Public information meetings are particularly educational and
• Sporting clubs informative as the entire project team is on site to answer
• Native American tribes stakeholders’ questions, solicit input, and listen to concerns. During
• Local media these open house events, stakeholders and the public will have the
opportunity to discuss the project with professionals in renewable
generation and transmission line engineering, construction, and Document repositories

environmental science, and other subject matter experts working on While the project’s Article VII, Article 10, and ORES applications and
the project. related documents will be made available for public view on the
project website, it will be necessary to provide hard copies for viewing.
For open house events, NYPA and Forward Power will manage all
Clean Path New York will deliver the Article VII, Article 10, and ORES
notices/invitations, develop all public-facing material and take-aways
applications and all supporting documents to local libraries and town
for visitors, and manage the event agenda/moderation/presentation.
halls for public viewing. Upon selection and through consultation with
The three main subject areas to be covered at such events are:
NYSERDA and the various permitting agencies, the optimal document
• Environmental topics such as visual impacts, wildlife, traffic, etc. repositories will be identified.
• Economic topics such as jobs, tax revenues, host agreements (as
Mailings
applicable)
Pre-construction mailings. Mailings will be an important part of the
• Process and participation topics (regulatory steps, ways to be a outreach program, as they provide an opportunity to share project
stakeholder and provide public comment, etc.) information with a large audience in a consistent manner and meet
After each meeting, the stakeholder relations team will document regulatory notification requirements pursuant to Article VII, 10 and
all communications, capture action items, and follow up with ORES processes. The pre-construction mailings will include:
stakeholders as needed. All meeting materials will be available on the • Letter to specific landowners asking permission to survey and test
project website or mailed to stakeholders upon request.
• Article VII, Article 10 and ORES intent to file letter sent to impacted
landowners and municipalities, including a project fact sheet,
Project website
milestones, and information on the Article VII, Article 10 and ORES
Clean Path New York has developed an educational website for
processes, and how to be added to the stakeholder list
the project (www.cleanpathny.com). Stakeholders will have the
opportunity to view project maps and FAQs and to learn about the • Newspaper advertisements announcing the intent to file Article VII,
project route and the Article VII, Article 10 and ORES processes. The Article 10 or ORES
website will also feature collateral pieces for the project, including • Public statement hearing invitation letter to be sent to impacted
fact sheets, safety information, project applications, and other key landowners and municipalities
documents. The website will be updated on a regular basis to provide • Newspaper advertisements regarding the public statement hearing
new information and construction milestones.
Construction mailings. Mailings during construction will notify
Project email stakeholders of construction commencement, milestones, and safety
Throughout the project, the stakeholder relations team will maintain information, and provide updates as needed. Construction mailings
a special project email address ([email protected]) and will will include the following:
document all communication and corresponding resolutions. The
• Construction commencement notice letter sent to impacted
stakeholder relations team will respond to email communications
landowners and municipalities, local media, and other key
in a timely manner. All correspondence will be entered into a
stakeholders, and placed on community public information boards
communications log for future reference.
around the region
• Notification to local emergency response agencies (police, fire Emails

departments, and EMS) of on-site hazardous materials, along In addition to letters sent via the US Postal Service, stakeholders will
with construction commencement and updates to the hazardous have the opportunity to receive information from the project team via
materials list and milestone updates as needed email. All interested parties will be able to sign up for email updates
on the project website, at public information meetings, during door-to-
• Notification to local traffic departments regarding the traffic
door outreach efforts, or by phoning the hotline. Project emails will be
management plan for the project
sent in conjunction with direct mailings to the stakeholder email list.
• Email notifications and phone calls to municipalities for after-hours
and Sunday/holiday work Open house and public statements
Clean Path New York will conduct open house events as part of the
Post-construction mailings. The stakeholder relations team may mail project application process . The events will be held in the affected
post-construction letters to impacted landowners, municipalities, community or communities, likely at a community hall or library. The
and key stakeholders when construction is complete, outlining steps events will be college-fair style, bringing in project subject matter
moving forward and safety messages. Such mailings may include: experts to answer questions and concerns from the public and
stakeholders.
• Restoration notices if restoration will occur at a significantly later
date due to inclement weather The open houses will be held in multiple locations at multiple times
• Rights-of-way trespass letters and newspaper publications, to accommodate a variety of schedules. Stakeholders, including
if required by the PSC or ORES landowners, residents, and the public, will be invited at least
• “Thank you” notes to landowners, residents, municipalities, and two weeks prior via direct mail and email, and the events will be
emergency response agencies, and other key stakeholders, alerting advertised via newspaper ads and on the project website. Materials
them of construction completion for the open houses will include fact sheets, field cards, project
maps, safety messages, etc. Clean Path New York will work with
Additional mailings. The stakeholder relations team may elect to send the Department of Public Service and/or ORES in planning for and
the following additional mailings to municipal officials, landowners, advertising any public statement hearing.
and other key stakeholders to ensure engagement with, and
understanding of, the project: Door-to-door outreach
Clean Path New York’s stakeholder relations team will conduct door-
• Invitations to public information meetings/open house events to-door outreach in counties and towns adjacent to the generation
• Construction schedule update notices projects and New Transmission route to hand out pertinent
• Restoration notices for specific areas of disturbed land information and be a visible and engaged presence in the community.
• Time-sensitive safety messages (e.g., hunting season) It is critical to foster relationships with municipal officials, landowners,
business owners, and other key stakeholders who are affected
• Project status updates
by the project. If a landowner or resident is not home or does not
• Major scope of work changes answer the door during outreach, a special notice will be left on the
doorknob, giving the resident the information needed to contact the

project team. These efforts will be conducted prior to construction Community engagement will be a priority
commencement. These door-knocking efforts will be conducted prior
to construction commencement.
throughout the various stages and duration of
the project. Clean Path New York has proactively
Construction signage begun reaching out to potential stakeholders.
Clean Path New York will erect signage in key locations along any
impacted rights-of-way to direct the public to avoid trespassing and
time, subject discussed, names of parties, and the ultimate
be aware of construction crews in the area. The signs will display the
resolution. Upon receipt of an inquiry, each will be disseminated
project hotline number and website address.
to the appropriate subject matter expert to be resolved.
Crew pads
Stakeholder outreach timeline
The stakeholder relations team will provide special project crew pads
Community engagement will be a priority throughout the various
to field employees and contractors working in the project area. These
stages and duration of the project. Clean Path New York has
small tear-off pads will contain general information about the project,
proactively begun reaching out to potential stakeholders.
including the website address and hotline number. The goal is to help
the field workers answer questions while in the field, and to provide Stakeholder outreach is one of the very first development tasks in
contact information to the stakeholders. The stakeholder relations the arc of developing any generation or transmission project. Early
team will brief the workers on the proper protocol while handling outreach typically consists of mailings to an area several miles’ radius
customer inquiries. around a given generation project site, or along the transmission line
route, followed by open house events and public hearings.
Media briefings
The Clean Path New York media relations team will update local There are typically several cycles of mailings, open houses, and
media personnel on the status of the project. Throughout the duration hearings as the design and permitting progress. One-on-one
of the project, the team will disseminate project information via press meetings are held with local officials and interested stakeholder
releases or advertisements to ensure public awareness. groups, and any interested people who request more information.
Presentations are regularly made at town board meetings of the host
Public inquiry process municipalities. Throughout the outreach process, contact information
The public will be able to reach the project team with any questions or is provided. Paper copies of the project documents can be found at
comments via the local hotline or project email. Open house meetings local document repositories.
will also provide the public the opportunity to obtain information and
Many of the generation resources that form a part of this project have
ask questions of the project team.
been in development since 2015 or earlier, with public outreach as
Inquiries from the public after the open house meetings will continue outlined above being a regular component of their development.
to be facilitated through the project hotline and email. Any inquiries One to two community-wide mailings and open houses every year
received through the telephone hotline, emails, and in-person throughout development is typical for a single generation project.
meetings will be logged into the stakeholder database with the date, Most or all of the outreach techniques outlined above have been
completed.
For earlier-stage projects, the first year of development is the most Economic development and local jobs (Category 1 and 2)
intense period of public outreach, to ensure that all parties who are The project will provide these benefits through several
interested in learning more, or in participating in the various avenues channels, including:
for public input, have been notified and are engaged in the process.
Once the permitting process is underway, general public mailings, • Direct in-state expenditures on goods and services
meetings, and open houses continue, but outreach is typically more • Development, construction, and operating jobs
focused on the parties most engaged in the process. • Payment-in-lieu-of-taxes (PILOT) programs with several Industrial
Later in the development cycle, typically as a project gets closer to Development Authorities
construction, there is a renewed level of intensity of public outreach • Host community payments
efforts to ensure everyone in proximity knows the timeline to • Real property taxes
construction, and the contact information for the community liaison for
questions or concerns on any field activities. • New York Independent System Operator interconnection fees
• Financing fees paid to New York State banks and other providers of
Lastly, there is always a point of contact for the community for financial services
an operating project, to ensure that there is a clear channel for
communication of questions or concerns, as well as a clear complaint • Lease payments to owners of land on which the proposed
handling procedure and emergency response plan that have been generation and transmission facilities are located
developed in consultation with emergency responders in the • Revocable consent fees to be paid to the City of New York for work
project area. in city streets
These Category 1 and 2 benefits are described in more detail and
Community benefits quantified in Section 16, Incremental Economics Benefits Plan.
Section 7.6.15 of the RFP asks proposers to describe how the project
offers benefits related to economic development, the creation of Reduced energy burden
local jobs, and the environment, among others. Section 7.6.16 asks for • The project will save New York State ratepayers $12 billion in energy
detailed descriptions and specific data associated with such benefits. costs over its 25-year term.
A summary of these benefits is provided in this CEP, and the detailed
• To determine the project’s impact on ratepayers across the state,
descriptions and estimated economic figures are provided in the
PowerGEM modeled the project as a 1,300 MW HVDC transmission
Incremental Economic Benefits Plan in Section 16 of this proposal.
line interconnecting at the Fraser Substation in the north and
Clean Path New York’s diverse portfolio of generation resources the Rainey Substation in the south, and ran several modeling
offers benefits throughout New York State, as opposed to projects sensitivities examining the behavior of the state’s electric system
from a single generation resource. This provides an opportunity to with and without the project.
make a greater impact and reach more Disadvantaged Communities • A more detailed description of the modeling methodology and
than would otherwise be the case. assumptions can be found in the PowerGEM report under Appendix
7. In this section Clean Path New York summarizes the impact of
the project on ratepayer burden and the drivers of the energy cost
savings.
• As New York progresses towards its aggressive renewable energy

goals, the percentage of generation coming from renewables
increases. With this increase in renewable generation comes $12
billion
increased congestion and renewables curtailment. Clean Path
New York will play a pivotal role in reducing congestion, reducing
renewables curtailment, and decreasing total load costs to
customers as more and more of New York State’s energy is Statewide ratepayer savings
generated from renewable sources.
As shown below in Figure 3, based on the cases described above,
statewide load payment savings (ratepayer energy cost savings, $5.5
billion
relative to what they would be paying without Clean Path New York)
are expected to be approximately:
• $242 million in 2025 (a saving of 5%) Zone J ratepayer savings

• $438 million in 2030 (a saving of 11%)
Figure 15-12. Ratepayer savings produced by Clean Path New York, 2025 – 2050.
In Zone J, the combination of 3,800 MW of new wind and solar Avoided health and social costs6
generating capacity and a new transmission line connecting upstate In addition to the impact of its investments in the development,
New York to New York City would yield savings to ratepayers in the construction, and operations of renewable energy generating and
five boroughs of approximately: transmission facilities, and the more targeted impacts of its proposed
community investment fund, Clean Path New York will contribute
• $96 million in 2025 (a saving of 6%) to the economic, social, and physical health of New York State by
• $204 million in 2030 (a saving of 13%) reducing emissions of carbon dioxide and other pollutants.
Increased availability of clean, carbon-free power will allow New York
Over 25 years, statewide ratepayer savings would total $12 billion – – especially New York City – to reduce its reliance on some of the
a reduction of approximately 11.7% relative to what ratepayers would State’s oldest and dirtiest fossil-fuel fired generating plants, many of
be paying in the absence of Clean Path New York’s investments in which are located in disadvantaged communities.
generation and transmission. In Zone J, ratepayer savings would total
Extensive research over the last several decades has documented
$5.5 billion over 25 years (about 46% of total statewide savings), a
the social costs that are associated with emissions of carbon dioxide,
reduction of approximately 14.5% relative to what customers in Zone J
as well as other pollutants such as SO2, NOx and particulate matter.
would be paying without Clean Path New York.
The social costs as defined by the federal Environmental Protection
Agency and Department of Transportation can include such effects
6
The PowerGEM cases underlying the [AKRF/Appleseed] analysis have Blenheim-Gliboa modeled differently than those used in the rest of the Step Two Proposal. This more conservative modeling
of Blenheim-Gliboa slightly understates the emissions reductions of the Clean Path New York project.
as property damage and disruption of economic activity caused by Year CO2 NOX SO2 PM
extreme weather events, increased health care costs, increases in
children’s absence from school, and lost productivity associated 2020 $51 $15,700 $40,400
with pollution-related diseases such as asthma, chronic obstructive 2025 $56 $16,800 $45,500 $807,500
pulmonary disease (COPD) and other respiratory ailments.
2030 $62 $18,000 $48,200 $852,700
For several reasons, these costs can increase over time – for example:
2035 $67 $18,000 $48,200 $852,700
• The adverse effects of greenhouse gas emissions can increase over
2040 $73 $18,000 $48,200 $852,700
time as these gases accumulate in the atmosphere.
2045 $79 $18,000 $48,200 $852,700
• Economic losses associated with any given level of emissions may
increase as the overall value of economic activity increases. The 2050 $85 $18,000 $48,200
losses associated with one worker being absent for one day, for
example, will increase as GDP per worker increases. Table 15-5. Social cost of CO2 and NOx emissions per metric ton through 2050 (in 2007 dollars,
assuming a 3% discount rate).
• The aggregate health care costs that pollution imposes on a

• 2.3 million tons of CO2
community can increase as its population increases. Such costs can
• 1,602 tons of NOx
also increase as the composition of the local population changes; an
aging population, for example, may be more vulnerable to several • 13.2 tons of SO2
types of pollution-related diseases. • 147 tons of PM2.5
In February 2021, the U.S. Environmental Protection Agency, After converting the above estimates to metric tons8, applying the
Department of Transportation and Office of Management and Budget cost-per-metric ton estimates for 2030 cited above in Table 4, Clean
released new estimates of the social cost of CO2, NOx, SO2 and Path New York estimates that in 2030, Clean Path New York it will
particulate emissions, for use by federal agencies in evaluating the have reduced the social cost of emissions in New York State by
costs and benefits of actions aimed at reducing such emissions. $272 million, including:
The agencies estimated the current social cost per metric ton of these
pollutants; and projected how these costs were likely to increase • $132 million for CO2
through 2050. The EPA/OMB estimates for the cost of CO2 and NOx • $26 million for NOx
are shown below in Table 4.7 • $0.58 million for SO2
An analysis conducted by PowerGem and AKRF estimates that • $114 million for PM2.5
implementation of Clean Path New York will reduce emissions Using PowerGem and AKRF’s analysis of impact reductions within
in New York State in 2030 by: Zone J (New York City), Clean Path New York estimates that
reductions in emissions of these four pollutants resulting from
7
Interagency Working Group on Social Cost of Greenhouse Gases, “Technical Support Document: Social Cost of Carbon, Methane and Nitrous Oxide, Interim Estimates Under Executive Order
13,990 Technical Update of the Social Cost of Carbon for Regulatory Impact Analyses under EO12866,” February 2021, appendix; U.S. Department of Transportation, Benefit-Cost Analysis
Guidance for discretionary Grant Programs, February 2021, p. 34.
8
One American (or “short”) ton equals 2,000 pounds; 1 metric ton equals 2,204 pounds.
$6.25
Clean Path New York project operations would reduce the social cost
of emissions in the five boroughs by $173 million (more than 63.4% of
the statewide total), including:
• $84 million for CO2

• $17 million for NOx
billion
$3.76
Statewide social cost
• $0.40 million for SO2
reductions
• $72 million for PM2.5
Moreover, the value of the projected reduction in emissions should

not be viewed solely in terms of its impact in a single year. The social
billion
benefits of reduced emissions – such as fewer episodes of illness, Zone J social cost reductions
fewer days of school or work missed, less disruption of business,
lower health care costs and fewer premature deaths can also be Figure 15-13. Reductions of health, social, and environmental costs produced by Clean Path
New York, 2025 – 2050.
counted cumulatively.
Based on PowerGem and AKRF’s estimates of reductions in CO2, approximately $3.76 billion – 57% of the long-term value of social cost
NOx, SO2 and particulate emissions in Zone J that the project would savings throughout the State. Three other zones – Long Island (Zone
achieve through 2035 and beyond, and using EPA’s and DOT’s K) at 15%, the Hudson Valley (Zone G) at 10 percent, and the Capital
estimates of the social costs of CO2, NOx, SO2 and PM2.5 per metric Region (Zone F) at 10% – account for another 35%.
ton ($71, $18,000, $48,200, and $852,700 respectively) in 2038 (the The benefits of reduced emissions from power plants are not,
midpoint of the proposed contract), Appleseed estimates that over however, distributed evenly. AKRF’s modeling of how emissions from
the life of the contract, Clean Path New York will have cumulatively power plants in New York City disperse geographically indicates that:
reduced the social cost of these emissions
• 37% of the reduction would occur within one mile from the source;
• $4.2 billion for CO2
• 74% would occur within two miles from the source; and
• $720 million for NOx
• 99% within four miles from the source.
• $8.7 million for SO2
• $3.1 billion for PM2.5 A two-mile radius from major generating plants in New York City
encompasses many disadvantaged communities, such as Mott Haven
Over the 25-year life of the proposed contract, reductions in in the South Bronx and Manhattan’s Lower East Side; and large New
emissions resulting from the operation of Clean Path New York would York City Housing Authority (NYCHA) housing projects in Astoria and
cumulatively reduce the social cost of these emissions in New York Long Island City (Astoria Houses and Queensbridge Houses) and near
State between 2025 and 2050 by approximately $6.25 billion the Brooklyn Navy Yard (Farragut Houses).
In Zone J, reductions in emissions of these four pollutants resulting Overall, AKRF estimates that disadvantaged communities in the four
from the operations of Clean Path New York would cumulatively Zones cited above (F, G, J and K) account for at least 40% of the
reduce the social cost of these emissions between 2025 and 2050 by statewide reductions in power plant emissions expected to result from
the development of Clean Path New York.
Added climate resilience between upstate and downstate New York. The transmission allows
The project enhances the resilience of the New York State electric both existing generation and incremental project generation to be
system by providing a 1,300 MW HVDC link from Fraser to New York dispatched more efficiently – reducing curtailment of renewables
City, all of which is located underground or underwater. Underground upstate, bringing clean power into Zone J, and thereby reducing the
infrastructure is more resilient against extreme weather events and output of downstate’s less-efficient fossil fuel generation.
is generally subject to fewer faults, delivering more robust system
A project injecting renewable power directly into Zone J from outside
uptime than overhead transmission lines. The link into Zone J itself
of New York State may provide similar emissions reductions but
provides a pathway for a more diverse resource mix to be delivered
would do so by bringing out-of-state renewables into the state, not by
into that Zone, which also bolsters the overall resilience of the system.
improving the intrastate transmission system to dispatch New York’s
Avoided environmental costs own renewables more efficiently. Based on Clean Path New York’s
In addition to its goal of 70% renewable energy by 2030, New York modeling, a fully utilized 1,200 MW transmission line from Canada into
State has a goal of reducing carbon emissions to at least 85% below Zone J would increase New York’s net electricity imports by 52% in
1990 levels by 2050. According to the New York State Department of 2030 and 57% in 2035. While such a project would reduce emissions
Environmental Conservation, the State emitted 410 million metric tons in Zone J, from a system perspective it would do so by injecting
of CO2 equivalent in 1990. This implies that the State must reduce its foreign renewables into the state, rather than allowing New York State
CO2 emissions by 349 million metric tons – to 61 million metric tons – to better utilize in-state renewables.
by 2050.8 Based on PowerGEM’s modeling, which assumes the state The concomitant emissions reductions of NOx and SOx will have a
will meet its 70% renewable energy by 2030 goal, Clean Path New positive outcome not only on public health, but with respect to acid
York in that year will reduce New York State’s annual CO2 emissions rain and other environmental problems associated with acidification
by 2.5 million tons. This represents an overall 22% reduction in and ozone formation.
statewide CO2 emissions from electric generation. Clean Path New
York provides similar incremental CO2 reductions even when modeled NOx is of principal concern because of its role, together with volatile
in conjunction with a similarly sized HVDC line interconnecting into organic compounds (VOC), as a precursor in the formation of ozone.
Zone J from Canada. Ozone is formed through a series of chemical reactions that take place
in the atmosphere in the presence of sunlight. Because the reactions
Clean Path New York provides the targeted CO2 emissions reductions are slow, and occur as the pollutants are advected downwind,
that are the driving force behind the Tier 4 program. Over 60% of elevated ozone levels are often found many miles from sources of the
these reductions, or 1.56 million tons, are in New York City, and 85% precursor pollutants. The effects of NOx and VOC emissions from all
of them – 2.13 million tons – are located in the constrained downstate sources are therefore generally examined on a regional basis.
New York State capacity zones (G-K). In the 2035 case, with 9 GW of
offshore wind interconnecting in Zones J and K, Clean Path New York In addition to being a precursor to the formation of ozone, one
reduces statewide carbon emissions 22% versus the base case, for a component of NOx, nitrogen dioxide (NO2), has been identified as
total of 1.74 million tons. a significant danger to public health. According to the EPA, current
scientific evidence links short-term NO2 exposures (ranging from 30
Clean Path New York achieves these impressive reductions by minutes to 24 hours) with adverse respiratory effects, which is of
adding significant in-state renewable generation and providing the particular concern for “susceptible individuals,” including people with
critical transmission infrastructure needed to reduce congestion asthma, children, and the elderly.
SO2 emissions are primarily associated with the combustion of sulfur- impacts future generations face. As these developments unfold, Clean
containing fuels (oil and coal). SO2 is also of concern as a precursor Path New York has an obligation to engage thoughtfully in the green
in the formation of particulate matter (PM) pollution. Like As with NO2, economy, interceding in areas where transition threatens to deepen
EPA has found current scientific evidence that links short-term SO2 existing inequalities in our society.
exposures with adverse respiratory effects, which is of particular
concern for “susceptible individuals,” including people with asthma,
children, and the elderly. In addition to SO2’s impacts on human A green economy that leaves historically
health, EPA has found that at high concentrations, this pollutant may disadvantaged populations behind will not be
result in damage and decreased growth in trees and plants. a sustainable economy.
Added environmental benefits
One element of the Clean Path New York project that has not been Equitable opportunity is extremely important to the project. The Clean
quantified, but that provides a meaningful environmental benefit, is Path New York development team will take considerable time and
the repurposing of the site in Queens that hosts the withdrawal point effort to ensure that outreach, access, and opportunities are made
converter station in Zone J. The site is an eight-acre industrial parcel available to environmental justice communities, communities of color,
on which. 6 fuel oil tanks are currently located. As part of the project, and economically depressed and at-risk populations. The new green
Clean Path New York will remediate the environmental contamination economy should benefit all of New York’s residents.
created by previous operations on the site. This will benefit the Category 3 incremental economic benefits may include workforce
surrounding communities, which are disadvantaged and overly development activities, actions aimed at increasing the likelihood that
burdened from an environmental justice perspective. New York residents will find work on the project, and other actions
that provide assistance to disadvantaged communities.
Opportunities to build community equity
The next generation will face challenges when it comes to the The COVID-19 pandemic laid bare the deleterious impact of
impacts of climate change on the environment, economy, and long-standing systemic health and social inequities in New York
society. These challenges will be exacerbated by the issues we face State’s economy. According to the Centers for Disease Control and
today: a widening wealth gap, racial disparity, a mid-level skills gap, Prevention, these social determinants of health put many people
and a health system recovering from a global pandemic. Rightfully, from racial and ethnic minority groups at increased risk of dying from
there is hope on the horizon with a clean and just energy transition, COVID-19.9 One study by Lauren Holmes Jr. et al. stated,
bringing innovation and jobs to the economy while increasing energy
efficiency, reducing pollution, and reducing the negative climate “The COVID-19 mortality [cumulative incidence] indicated Blacks/AA
[experienced] 34% of the total mortality in the United States, albeit
their 13% population size.”10
9
https://www.cdc.gov/coronavirus/2019-ncov/community/health-equity/racial-ethnic-disparities/disparities-deaths.html
10
Holmes Jr., Lauren, et al. “Black–White Risk Differentials in COVID-19 (SARS-COV2) Transmission, Mortality and Case Fatality in the United States: Translational
Epidemiologic Perspective and Challenges,” Int. J. Environ. Res. Public Health 2020, 17(12), 4322.
A growing body of literature correlates environmental justice burdens • Enhancements to Public Health
with negative health impacts in minority communities. The New York • Environmental Justice
Times Magazine asserts that not only are “African Americans 75%
more likely than others to live near facilities that produce hazardous An overarching goal of each of these priorities is to focus
waste” but that “[B]lack Americans are exposed to 1.5 times as much opportunities in disadvantaged populations and environmental
of the sooty pollution that comes from burning fossil fuels than the justice communities. Through community engagement and outreach,
population at large.” The article goes on to explain:“[a] study of more Clean Path New York will develop a community investment fund that
than 3,000 U.S Counties released in April [conducted by Harvard is in line with specific community needs. By funding programs with
University researchers] shows a statistical connection between these priorities in mind, Clean Path New York will be able to nurture
death rates from COVID-19 and long-term exposure to air pollution. meaningful socio-economic growth in some of the most depressed
Each increased microgram of [particulate matter pollution] per cubic communities in the state, while ensuring that each and every New
meter of air is associated with an 8 percent increase in death from Yorker is given the opportunity to be part of the next phase of energy
COVID-19.”11 infrastructure.
Couple these disturbing findings with other recent studies, one The fund will be managed by a board of directors to be named after
quantifying higher-than-appreciated global mortality (1 in 5 early the project secures a funding award from NYSERDA. The full scope
deaths globally) from outdoor fine particle pollution generated by of economic benefits to be provided under Category 3 will only be
fossil fuel combustion13 and another showing increased prevalence of determined through consultation with NYSERDA and engagement
street-level particulate matter pollution in New York City in excess of with the affected host communities.
20 times what it was previously thought to be, and the importance of
A preliminary array of programs and investments is provided in the
projects like ours is brought into stark relief.
Table below. The full scope of economic benefits to be provided
Reducing air pollution, hardening infrastructure, and creating a under Category 3 will only be determined through consultation with
greener, cleaner New York are significant benefits to New Yorkers. NYSERDA and engagement with the affected host communities.
However, Clean Path New York believes that community benefits
Detailed descriptions of these programs and estimated economic
need to be taken a step further to support the new green economy
benefit figures are provided in the Incremental Economic Benefits
that the state envisions.
Plan in Section 16 of this proposal.
To that end, Clean Path New York will constitute a community
The Clean Path New York community investment fund will be a
investment fund of at least $270 million over 25 years prioritizing the
collaborative program, informed by meaningful stakeholder outreach
following areas:
and community priorities. With special focus on disadvantaged
• Workforce development and Job Creation populations and environmental justice communities, Clean Path New
• Economic Development York looks forward to providing opportunities for all to thrive in the
new green economy.
11
Villarosa, Linda “Pollution is Killing Black Americans. This Community Fought Back.” New York Times Magazine, July 28, 2020. Found at: https://www.nytimes.com/2020/07/28/magazine/pollution-
philadelphia-black-americans.html.
13
Vohra, Karn et al. “Global mortality from outdoor fine particle pollution generated by fossil fuel combustion: Results from GEOS-Chem.” Environmental Research. Vol. 195. April 2021.
Category 3
Economic
Initiative Workforce/jobs development Public health Env. Justice Total
Thru 3rd year of CDT $20,000,000 $10,000,000 $10,000,000 $10,000,000 $50,000,000
Remainder of CDT $80,000,000 $40,000,000 $40,000,000 $60,000,000 $220,000,000
Total $100,000,000 $50,000,000 $50,000,000 $70,000,000 $270,000,000
Table 15-6. Economic benefits under Category 3.
Detailed descriptions and estimated economic figures are provided in Table 15-7 on the next page summarizes Clean Path New York
the Incremental Economic Benefits Plan in Section 16 of this proposal. outcomes and how it contributes to meeting the Climate Act targets.
15.5. Alignment with the CLCPA 15.6. Progress reporting

Clean path New York contributes in every aspect to the Climate Act Clean Path New York will work with NYSERDA to develop an effective
and specifically to the goal of transforming the way we generate reporting process and format before and during all community
and transmit electricity, reduce carbon emissions, empowering engagement activities in concert with the Economic Benefits
disadvantaged communities, enhancing New York State economy Verification Plan discussed in Section 16.
through increased jobs and specifically improving health and quality of
life for New York families and communities.
Climate Act targets and Clean Path New York outcomes

CLCPA target Clean Path New York outcome How outcome is met
Clean electric grid 3000+ MW of new onshore wind and Solar with 10+ TWh Clean Path New York boasts a portfolio of 3000+ MW of new onshore
of tomorrow of clean energy generation capability and at least 7+ TWh wind and solar resources zonally diversified and all exclusively New York
of the energy delivered into New York City. Renewable Generation. The advantages of this large portfolio are further
amplified by leveraging the state’s largest storage resource, Blenheim-
A green state-of-the-art flexible HVDC transmission Gilboa to maximize the utilization of those resources.
capable of transferring 1,300 MW from upstate to
downstate New York. Clean Path New York suggested New Transmission is feasible,
constructable, permittable and have a minimum impact on communities.
The line will provide ultimate flexibility to meet New York City green
energy requirements while at the same time enhancing the grid reliability.
Refer to Sections 4, 5 and 9 of this proposal for more details on how Clean
Path New York accelerates the achievement of a green electric grid.
A clean energy Clean Path New York aims to providing communities and Clean Path New York have created a reliable path to transmit 7+ TWh
economy for businesses in New York City access to clean energy as of clean energy directly in to New York City. The portfolio of Resources
everyone well as the resulting economic opportunities that arise is assembled along with Blenheim Gilboa in an intelligent fashion to
with the development of such project. maximize renewable energy flows over the New Transmission and alleviate
the bottleneck preventing upstate-generated clean energy from reaching
New York City.
Clean Path New York will help the State achieve the CLCPA goals while
delivering huge economic, social and health benefits to disadvantaged
communities.
Refer to Sections 4, 5 and 14 of this proposal for more details on how Clean
Path New York helps in creating a clean energy economy for New Yorkers.
Jobs Clean Path New York will create over 10,500 person years Clean Path New York construction and operations requirements for its
of in-state jobs over the first three years of the contract Resources and the Transmission line is extensive and is expected to
delivery term – all paying prevailing wage. generate jobs mostly within the construction phase of the project.
Refer to Sections 15 and 16 of this proposal for more details on how Clean
Path New York creates jobs focusing opportunities in disadvantaged
populations and environmental justice communities
Table 15-7. Clean Path New York's alignment with Climate Act targets.
Climate Act targets and Clean Path New York outcomes

CLCPA target Clean Path New York outcome How outcome is met
A healthier New Largely contribute to reducing greenhouse gases and Clean Path New York will reduce the output of oil- and gas-fuelled
York local pollution to keep our communities healthier. generation sources by an average of 4.6 TWh per year state-wide and 2.56
TWh per year in New York City, reductions of 8% and 16%, respectively.
Clean Path New York will reduce carbon emissions by 39 million tons in
its first 25 years and will further the state’s emissions reduction goals for
2030 and beyond.
Refer to Sections 12 and 15 of this proposal for more details on how Clean
Path New York helps in creating healthier New York.
Affordable energy Clean Path New York will deliver $12 billion of cost Over 25 years, Clean Path New York Resources and specifically the New
savings to ratepayers across the State in its first 25-years Transmission largely contributes to the resolution of the “Tale of Two
of operation. Such savings are expected to outweigh the Grids”. Thanks to the flexibility and enhanced transfer capability of the
total REC cost over 12 years by two folds. New Transmission, Clean path New York expects to alleviate renewables
curtailment and reduce overall congestion. The savings from such benefits
are estimated to be $5.6 billion over 25 years.
The remaining benefits are driven by the avoided social and public
health costs due to emissions reductions across the state. Thanks to the
enhanced portfolio of Resources and the planned delivery into New York
City.
Refer to Sections 14 of this proposal for more details on how Clean Path
New York helps in creating an affordable energy.
Empowerment Create the following: Clean Path New York generates over $4.3 billion Category 1 and 2
• Workforce development and job creation incremental economic benefits, 36.3% of which flow to disadvantaged
• Economic development communities.
• Public health
• Environmental justice Through community engagement and outreach, Clean Path New York will
develop a community investment fund of US$ 270 million that is in line with
An overarching goal of Clean Path New York is to focus specific community needs. The fund will focus on Category 3 workforce
those opportunities in disadvantaged populations and development, public health, and community programs to provide a
environmental justice communities By funding programs pathway for members of our most vulnerable populations to emerge as a
with these priorities in mind, Clean Path New York will vibrant new green workforce that will continue to build New York’s future
be able to nurture meaningful socio-economic growth in while also enhancing the overall quality of life in these communities.
some of the most depressed communities in the state,
while ensuring that each and every New Yorker is given Refer to Sections 15 of this proposal for more details on how Clean Path
the opportunity to be part of the next chapter in energy. New York helps in empowering disadvantage communities.
Table 15-7 (continued). Clean Path New York's alignment with Climate Act targets.
Section 16
Incremental economic
benefits plan
16 Incremental economic benefits plan
16.1. Introduction
The Clean Path New York Team has developed this Incremental
Economic Benefits Plan (“IEBP”) in lockstep with the Communities
$12 billion
Engagement Plan (“CEP”), informed by expert consultants, and aimed saved for New York ratepayers
at fulfilling the targeted outcomes of the CLCPA.
It is very important to note the use of the term “Incremental” in the

title and intent of this IEBP. Before Clean Path New York discusses
these incremental benefits, it is also essential to make clear the
49%
of projected reductions in emissions in
Clean Path New York Project’s inherent economic and environmental Disadvantaged Communities
benefits to New York State ratepayers, residents and Disadvantaged
Communities. These inherent benefits are described in detail and
quantified in the CEP, but significant enough to restate here as they
form the basis of the incremental economic benefits of the Clean Path
New York project.
39 million
tons in emissions reductions
16.2. Inherent economic and

Avoided health and social costs
environmental benefits Over the 25-year life of the proposed contract – from 2025 to 2050
– reductions in CO2, NOx, SO2, and particulate emissions resulting
Reduced energy burden
from the operations of the project would cumulatively reduce the
The Clean Path New York project will save New York State ratepayers
social cost of these emissions in Zone J between 2025 and 2050
over $12 billion in energy costs over its 25-year life reducing
by approximately $6.25 billion. 49% of the projected reductions in
congestion and renewable energy resource curtailments and
the social costs of these emissions would occur in Disadvantaged
decreasing total load costs.
Communities in Zones J, K, and G (Downstate).
Added climate resiliency

A technologically and geographically diverse mix of generation There is therefore...
resources linked to transmission infrastructure that is buried
underground or underwater provides resiliency against extreme zero net expense
weather events and is subject to fewer faults. to ratepayers
Avoided environmental costs i.e., the residents of New York who will
The dramatic emissions reductions discussed above include an overall ultimately fund all energy projects
reduction in carbon emissions of 39 million tons over the 25-year life
of the project.
When the value of $6.25 billion in avoided social and public health
Altogether, these inherent economic and environmental benefits form costs due to emissions reductions across the state and the billions of
the launching pad from which the incremental economic benefits take dollars invested in economic development, job creation, and tax and
off for the ratepayers, residents and Disadvantaged Communities in PILOT revenues demonstrated in this IEBP are combined, the NPV of
New York. Clean Path New York benefits all New Yorkers and more the project benefits outweigh the expense by a margin of 2:1.
than pays for itself in the process. The net present value (NPV) of
NYSERDA’s portion of the Tier 4 REC payments is $6.2 billion over 25 Incremental economic benefits summary
years while the NPV of direct cost savings to ratepayers resulting from A summary of the Incremental Economic Benefits of Clean Path New
the project over the same 25-year term is $7.02 billion – $828 million York is provided in Table 16-1 below.
more than the value of the REC payments.
Investment in New York State and
Disadvantaged Communities ($000) NYS DACs % to DACs
Generation and Through 3rd year of Contract $2,060,650 $453,634 22.0%
Transmission
Full term $4,375,200 $1,586,566 36.3%

Community and Through 3rd year of Contract $50,000 $50,000 100.0%
Workforce
Remainder of Contract $220,000 $220,000 100.0%
Full term $270,000 $270,000 100.0%
Combined Through 3rd year of Contract $2,110,650 $503,634 23.9%
Full term $4,645,200 $1,856,566 40.0%
Table 16-1. Incremental economic benefits.
• 7.6.16 Incremental Economic Benefits Plan

To be very clear... that's... • Appendix E – Standard Form PSA (namely Exhibit F)
• Appendix G – Economic Benefits Claims and Verification
$4.4 billion in economic benefits
to New York State including This IEBP Narrative, developed in concert with the CEP, and informed
$1.8 billion to Disadvantaged by the studies conducted by Appleseed, attached as Appendix
Communities (40%) 17 serves as an accompaniment to the Offer Data Form (“ODF”)
to support and provide detailed descriptions of the Incremental
Economic Benefits claimed in Parts V-1, V-2 and V-3 of the ODF.
These expenditures result in a significant amount of full-time
equivalent (FTE) job creation in New York State and to the Evaluation Period
Disadvantaged Communities hosting the Generation and New In this IEBP and associated ODF, the time period considered to be
Transmission resources. “through the end of the first three (3) years of the Contract Delivery
Term (“CDT”)” is based on an interpretation of conflicting definitions
NYS DACs % in DACs between the RFP Definitions and Appendix E Definitions. Namely,
Thru 3rd year of CDT 10,618 2,016 19.0% the conflict as to whether the period begins either on the Award
Notification Date, as defined in the RFP, or on January 1, 2021, as
Remainder of CDT 210 26 12.3% defined in Appendix E. The conflicting definitions are provided below
Total 25-yr term 10,827 2,042 18.9% for reference (emphasis added):
Table 16-2. Job creation in New York State. Relevant Definitions from RFP:
• “Economic Benefits Report – An independently audited report,
Each incremental benefit is described in detail in this IEBP. documenting the total dollar amount of actual Incremental Economic
Benefits accrued to New York and associated activities and
IEBP Approach commitments undertaken from the Award Notification Date through
To aid NYSERDA with its evaluation, Clean Path New York provides
the end of the first three (3) years of the Contract Delivery Term.”
the following points of clarification about the assumptions,
RFP Page vii
interpretations and formatting choices used to develop this IEBP.
• “Verified Total Dollars – The total dollar amount of Economic
Key Assumptions: Benefits in Categories 1 and 2 as separate sums for all New York
Clean Path New York has developed this IEBP based on the State benefits and for benefits in Disadvantaged Communities,
guidelines provided in the following RFP sections: verified by NYSERDA to have accrued to New York as a result of
the development, construction, modification, interconnection, and
• 3.3 Incremental Economic Benefits to New York State Including operation of the Project from the Award Notification Date through
Disadvantaged Communities the end of the first three (3) Contract Years.” RFP Page x
• 7.5.5 Part V - Incremental Economic Benefits Worksheets
• 7.6.15 Communities Engagement Plan
Relevant Definitions from Appendix E: Project-Specific Expenditures

• “Expected Total Dollars: The total amount, in nominal dollars, of All monetary values are nominal and expressed as ($000), i.e., $2,000
Economic Benefits (as described in Exhibit F) expected to accrue represents $2,000,000. The estimates of employment, earnings and
to New York State as a result of the development, construction, payments for goods and services reflect direct spending and jobs
modification, interconnection, and operation of the Selected Project only. They do not include any indirect or induced effects of Clean Path
from January 1, 2021 through the end of the first three (3) Contract New York’s investment in Resources or New Transmission. All figures
Years. The amount of Expected Total Dollars under this Agreement are bases on the Appleseed report, informed by the Generation and
is $______.” Appendix E, Page 4. New Transmission development team and consultants.
• “Verified Total Dollars: The total dollar amount of Economic Benefits
Unique Jobs
as calculated pursuant to Exhibit I and verified to have accrued to
Per the response to Question 24 of NYSERDA’s posted response to
New York as a result of the development, construction, modification,
questions dated 4/30/2021, the two categories of Unique Jobs in
interconnection, and operation of the Selected Project from January
Category 1 and 2 are not provided in the ODF but will be discussed in
1, 2021 through the end of the first three (3) Contract Years.”
relation to the FTE job claims.
Appendix E, Page 7
IEBP Format
Therefore, for the purposes of this IEBP and ODF, Clean Path New
To aid the NYSERDA review team in its analysis of this proposal, the
York defines the period of time “through the end of the first three
structure of this IEBP narrative is presented in the format required in
(3) years of the Contract Delivery Term,” to be from January 1, 2021
Appendix G, Table G.1, wherein the Economic Benefit IDs in the tables
through the 3rd Year of the CDT.
below correspond to the EB ID in the Offer Data Form. The tables are
partitioned by Category and Evaluation Period. The Project Phase
Project Phases
and/or Target Beneficiary, and Term (short or long) is indicated within
The IEBP and ODF do not make a distinction between the
the description of each benefit.
Development Phase and Construction Phase within this period, but
does indicate where benefits are occurring during the Operations The order of tables is as follows:
Phase, i.e. from the Commercial Operation Date through the first three • 16.3 Category 1 Benefits
(3) Contract Delivery Years. As such, the benefits occurring during • 16.4.1 Through 3rd Year of CDT
• 16.3.1 Through 3rd Year of CDT
either the development or construction phase of the project are all • 16.4.2 Remainder of CDT
• 16.3.2 Remainder of CDT
labeled as “Construction” in the “Project Phase” column of the ODF. • 16.5 Category 3
• 16.4 Category 2
All of the benefits claimed during the Construction Phase have a
start date of January 1, 2021 and an end date at the COD in order to These Incremental Economic Benefits must be quantifiable and
provide flexibility with the actual delivery of the benefits. Similarly, verifiable. Therefore, each benefit claimed in the IEBP has been
all of the claimed Operations Phase benefits occurring in the same quantified in Sections 16.3 through 16.5 below and will be verifiable
evaluation period have a start date at COD and an end date at the based on the proposed Economic Benefits Verification Plan,
conclusion of the 3rd year of CDT. presented in Section 16.6.
The NYSERDA review team will find that these expenditures Appleseed’s estimates of direct in-state expenditures for the
and investments are firm and credible, will create persistent and proposed new renewable generating capacity, and the number of
sustainable institutional or worker capabilities in New York State, construction and operating jobs associated with each, are shown
distribute economic benefits more heavily within Disadvantaged below in Table 16.3.
Communities, and are expected to lower the cost of future projects in
the State that use similar technologies. Extrapolating from Invenergy’s analysis of these five projects,
Appleseed then estimated the direct payments and jobs attributable
to the development, construction and operation of the additional
16.3. Category 1 – Project-specific spending wind and solar power generating facilities in the Clean Path New York
portfolio.
and job creation in New York State
For all Category 1 claimed benefits, Appleseed’s estimates of the
Clean Path New York’s Category 1 project-specific expenditures will
value of incremental economic benefits accruing to Disadvantaged
relate to the development, construction and in some cases, initial
Communities assume that, in the case of the proposed generation
operation of approximately 3,817 MW of new land-based wind and
projects, 10 percent of statewide incremental economic benefits
solar power generating capacity in upstate New York.
will accrue to Disadvantaged Communities, due to the inherent
Based on detailed data on five of the Generation Resources included remoteness of wind resources and the current definition and
in the Clean Path New York portfolio (Number Three Wind, Alle-Catt approximate location of DACs, which generally tend to be in more
Wind, Canisteo Wind, Bull Run Wind and Horseshoe Solar) submitted urban areas. When combined with the Category 2 and 3 benefits,
by Invenergy to the Public Service Commission pursuant to Article the portion of incremental benefits accruing to DACs meets the 40%
10, Appleseed has estimated the economic benefits that would be target of the CLCPA.
provided to New York by the development, construction and operation
of 3,817 MW of new wind and solar generating capacity.
($000s)
Number Alle Catt Canisteo Bull Run Horseshoe
EB ID# Benefit description Three Wind Wind Wind Wind Solar Other wind Other solar Total ($000) $ to DACs
Construction 10%
N/A Unique Construction Jobs 330 430 385 520 300 1,133 2,743 5,841 584
EB1-001 Construction person-yrs. 165 175 147 215 261 478 2,388 3,829 383
EB1-002 Construction payroll $15,000 $24,600 $20,300 $30,100 $28,800 $61,241 $263,360 $443,401 $44,340
EB1-003 Non-payroll construction spending $8,100 $8,730 $7,010 $21,690 $4,390 $30,981 $40,144 $121,045 $12,105
EB1-004 Non-payroll construction jobs (FTE) 44 93 73 108 10 217 95 642 64
EB1-005 NYISO interconnection fees $200 $200 $200 $200 $200 $1,200 $2,400 $4,600 $460
Operations: Through 3rd year of CDT
EB1-006 Operating jobs (FTE) 7 12 11 16 3 31 27 107 11
EB1-007 Operating payroll $990 $1,605 $1,485 $2,055 $465 $4,175 $4,252 $15,027 $1,503
EB1-008 Local purchasing $423 $2,344 $2,470 $1,939 $2,050 $4,883 $18,746 $32,855 $3,286
EB1-009 Local purchasing jobs (FTE) 2 5 5 7 8 12 70 107 11
EB1-010 Land lease payments
EB1-011 PILOT & HCA payments
Operations: Remainder of CDT
EB1-012 Operating jobs (FTE) 7 12 11 16 3 31 27 107 11
EB1-013 Operating payroll $7,260.0 $11,770.0 $10,890.0 $15,070.0 $3,410.0 $30,613.6 $31,182.6 $110,196 $11,020
EB1-014 Local purchasing $1,108.0 $2,586.0 $2,706.0 $7,198.0 $9,450.0 $9,252.8 $86,415.0 $118,716 $11,872
EB1-015 Local purchasing jobs (FTE) 1 1 1 2 8 3 69 85 8
EB1-016 Land lease payments
EB1-017 PILOT & HCA payments

Total Expenditures
Thru 3rd Year of CDT $29,367 $52,566 $44,277 $75,688 $41,116 $137,914 $376,554 $757,482 $75,748
Remainder $42,497 $124,994 $107,547 $166,761 $51,074 $299,725 $467,043 $1,259,640 $125,964
Total 25-Term $71,864 $177,560 $151,824 $242,448 $92,190 $437,639 $843,598 $2,017,122 $201,712
Total Jobs
Thru 3rd Year of CDT 218 285 236 346 282 738 2580 4685 468
Remainder 8 13 12 18 11 34 96 192 19
Total 25-Term 225 298 248 364 293 772 2676 4876 488
Table 16-3. Generation figures.

16.3.1 Through 3rd Year EB1 ID Detailed description

of CDT EB1-001 Generation - Construction Person Years - Construction Phase In NYS In DACs
The Category 1 benefits
Short-term Direct Job Creation (FTE-Years) 3,829 383
occurring from January 1, 2021
Unique Jobs 5,841 584
through the 3rd year of the
For purposes of this RFP response, we have defined “unique” construction jobs as, in effect, unique hires. The
CDT and claimed in the ODF relationship of unique jobs to total payroll or person-years of employment can vary considerably from project to
are quantified and described project. Estimates of unique jobs are based upon Unique Job estimates reported by Invenergy for several upstate
in the following table based wind and solar development projects under New York’s Article 10 process and extrapolated to the complete CPNY
portfolio. A “person-year” is a measure of employment that generally represents the equivalent of one employee
on industry standards for working full-time for a year. It could for example consist of two workers, each employed full-time for six months; or
development, construction two workers employed half-time for a year.
and operations cost estimating For additional details on how these benefits accrue to DACs, refer to the Section 15 - Communities Engagement
Plan.
methods. The Clean Path New
York team is comprised of well- EB1-002 Generation - Construction Payroll In NYS In DACs
established generation and Net Expenditures ($000) $443,401 $44,340

transmission developers and is These benefits are based on estimated payments for labor-related expenditures for work that is performed in
New York State. Examples include gross wages (including employer side payroll tax payments), and benefit costs
advised by expert consultants incurred in association with the employment of construction, rail and port workers, contractors and laborers,
experienced with projects of operations and maintenance personnel, engineering or environmental service providers, consultants, other
this size and scope. The claimed employees and financial and legal service providers associated with the Project.
benefits are therefore credible, EB1-003 Generation - Non-Payroll Construction Spending In NYS In DACs
reliable and verifiable to ensure Net Expenditures ($000) $121,045 $12,105
these benefits are realized These benefits are based on estimated payments for in-State purchases of goods and services. Including
expenditures resulting from the purchase and consumption of local goods and services (including sales tax), such
by New York rate payers and as, but not limited to, food, lodging, vehicles, equipment; and the purchase of materials sourced from within New
Disadvantaged Communities York State such as, but not limited to, gravel, steel, concrete and similar materials and/or the purchase and use of
associated with the project. equipment and products manufactured or assembled within New York State and/or the use of rental equipment or
similar supplies sourced within New York State.
For additional details on how EB1-004 Generation - Non-Payroll Construction Jobs In NYS In DACs
these benefits accrue to Short-term Direct Job Creation (FTE-Years) 642 64
DACs, refer to the Section 15, Estimates of jobs supported through in-state purchases of construction-related goods and services were
Communities Engagement derived from Invenergy’s Article 10 reports, as further described in the Appleseed report. These jobs include
an establishment of a project office in New York State, pre-development activities, leases/purchases, and other
Plan. Details regarding the related non-payroll employment.
estimation methods used to EB1-005 Generation - NYISO Interconnection Fees In NYS In DACs
determine the project-specific
Net Expenditures ($000) $4,600 $460
expenditures and job creation
NYISO Interconnection fees help to fund NYISO operations and those employees and third-party consultants
benefits are provided in the called upon during the system impact study process. The vast portfolio of CPNY Generation projects
Appleseed reports in Appendix provides significant funding for these operations and activities. Futher details regarding the benefits of NYISO
Interconection Fees can be provided upon request.
17 and additional details can be
provided upon request of the Table 16-4. Through 3rd year of CDT.
NYSERDA review team.
Each claimed incremental EB1 ID Detailed description

economic benefit in the
EB1-006 Generation - Operating Jobs (FTE) In NYS In DACs
following tables detail the
Long-term Direct Job Creation (FTE-Years) 107 11
corresponding EB ID# in the
ODF, the Project Phase, the These benefits include, but are not limited to, jobs associated with operations and maintenance, plant
management, and long-term project development.
Evaluation Period, the value
EB1-007 Generation - Operating Payroll In NYS In DACs
of the benefit to NYS, portion
Net Expenditures ($000) $15,027 $1,503
accruing to DACs, and a
These benefits include, but are not limited to, jobs associated with operations and maintenance, plant
reference to its alignment with management, and long-term project development.
the benefit eligibility criteria
EB1-008 Generation - Local Purchasing In NYS In DACs
stated in the RFP.
These benefits are based on estimated payments for in-State purchases of goods and services. Including
as, but not limited to, food, lodging, vehicles, and equipment
EB1-009 Generation - Local Purchasing Jobs (FTE) In NYS In DACs
Short-term Direct Job Creation (FTE-Years) 107 11
Estimates of jobs supported through in-state purchases of local goods and services were derived from Invenergy’s
Article 10 reports, as further described in the Appleseed report.
EB1-010 Generation - Land Lease Payments In NYS In DACs
Net Expenditures ($000)
NYSERDA’s Tier 4 RFP specifies that land lease payments may be counted as eligible economic benefits only
to the extent that they exceed the fair market value of the leased property. In most cases, however, the only
alternative use of land leased for wind and solar facilities in upstate areas would be agricultural. The price of land
leased for agricultural purposes is typically much lower on a per-acre basis than the rents paid by developers of
renewable power. The cited here represents only the amount by which lease payments exceed the
estimated agricultural value of the leased land, assumed here to be approximately per acre.
EB1-011 Generation - PILOT and HCA Payments In NYS In DACs
Estimates of Payment-In-Lieu of Taxes (PILOT) and Host Community Agreement (HCA) payments assume that
these payments will start as of the Commercial Operation Date; and will initially total
. (The relevant local governments will determine how these
payments will be allocated among PILOT, HCA and other local taxes.)
Table 16-4 (continued). Through 3rd year of CDT.
16.3.2 Remainder of CDT EB1 ID Detailed description

The benefits being delivered to the State EB1-012 Generation - Operating Jobs (FTE) In NYS In DACs
of New York and the host Disadvantaged
Communities for the remainder of the
These benefits include, but are not limited to, jobs associated with operations and maintenance,
CDT are an extension of the estimates of plant management, and long-term project development.
the Operating Payroll, Local Purchasing, EB1-013 Generation - Operating Payroll In NYS In DACs
Land Lease Payments, Taxes, PILOTs and Net Expenditures ($000) $110,196 $11,020
Host Community Agreements established
between January 1, 2021 and the COD. plant management, and long-term project development.
EB1-014 Generation - Local Purchasing In NYS In DACs
16.4. Category 2 – Net Expenditures ($000) $118,715

These benefits are based on estimated payments for in-State purchases of goods and services.
$11,872
Transmission and other Including expenditures resulting from the purchase and consumption of local goods and services
(including sales tax), such as, but not limited to, food, lodging, vehicles, and equipment.
infrastructure, supply chain, EB1-015 Generation - Local Purchasing Jobs (FTE) In NYS In DACs
and community economic Long-term Direct Job Creation (FTE-Years) 85 8

Estimates of jobs supported through in-state purchases of local goods and services were derived
development in New York from Invenergy’s Article 10 reports, as further described in the Appleseed report.
EB1-016 Generation - Land Lease Payments In NYS In DACs
State Net Expenditures ($000)
Clean Path New York’s Category 2 NYSERDA’s Tier 4 RFP specifies that land lease payments may be counted as eligible economic
incremental economic benefits associated benefits only to the extent that they exceed the fair market value of the leased property. In most
cases, however, the only alternative use of land leased for wind and solar facilities in upstate areas
with Project-related transmission and would be agricultural. The price of land leased for agricultural purposes is typically much lower
infrastructure are derived primarily from on a per-acre basis than the rents paid by developers of renewable power. The amount cited here
represents only the amount by which lease payments exceed the estimated agricultural value of
Clean Path New York’s investment in the the leased land (assumed in this analysis to be per acre).
development and operation of a new, 1.2
EB1-017 Generation - PILOT and HCA Payments In NYS In DACs
GW, 175-mile transmission line that will
extend from Fraser in Delaware County to
Estimates of Payment-In-Lieu of Taxes (PILOT) and Host Community Agreement (HCA) payments
Rock Tavern in Orange County, and then assume that these payments will start as of the Commercial Operation Date; and will initially total
down the Hudson River to Con Edison’s (The relevant
Rainey substation, in Queens. local governments will determine how these payments will be allocated among PILOT, HCA and
other local taxes.)
The Project-related transmission and Table 16-5. Remainder of CDT.
infrastructure expenditures on the
development and construction of the New
Transmission delivering to Zone J are herein
claimed as Eligible Economic Benefits. All
expenditures and job creation claims for construction labor on the 18.10 and 18.11 of the Agreement as though it were the Seller under the
Associated New Transmission Facility intends to adhere to Sections Agreement.
To DACs
Fraser to Rock Tavern New York Fraser- To DACs Total to
EB ID# Benefit description Rock Tavern to Yonkers City Total Yonkers NYC DACs % To DACs
Construction
N/A Unique Construction Jobs 1,280 464 586 2,330 262 469 730 31.3%
EB2-001 Construction person-yrs. 2,561 929 1,172 4,662 524 938 1461 31.3%
EB2-002 Construction payroll $405,900 $256,300 $180,000 $842,200 $99,330 $144,000 $243,330 28.9%
EB2-003 Non-payroll construction spending $58,332 $28,308 $17,660 $104,300 $12,996 $14,128 $27,124 26.0%
EB2-004 Non-payroll construction person-yrs. 201 105 43 349 46 34 80 23.0%
EB2-005 NYS-based professional services spending N/A N/A N/A $242,700
EB2-006 NYS-based professional services person-yrs. N/A N/A N/A 904
EB2-007 ROW usage fee paid by CPNY to NYPA N/A N/A N/A $63,000
Operations: Through 3rd year of CDT
EB2-008 Operating jobs (FTE) 4 2 2 8 1 2 3 31.3%
EB2-009 Operating payroll $1,758 $814 $702 $3,274 $386 $562 $947 28.9%
EB2-010 In-state purchasing $1,956 $730 $2,396 $5,082 $403 $1,917 $2,320 45.6%
EB2-011 Local purchasing jobs (FTE) 4 2 4 10 1 3 4 41.0%
EB2-012 PILOT payments (100% to DACs) 100.0%
EB2-013 NYC revocable consent fee $ 80.0%
EB2-014 Easement fees paid to NYS agencies 27.1%
Operations: Remainder of CDT
EB2-015 Operating jobs (FTE) 4 2 2 8 1 2 3 31.3%
EB2-016 Operating payroll $12,890 $5,972 $5,148 $24,010 $2,829 $4,118 $6,948 28.9%
EB2-017 In-state purchasing $14,345 $5,354 $17,570 $37,269 $2,955 $14,056 $17,011 45.6%
EB2-018 Local purchasing jobs (FTE) 4 2 4 10 1 3 4 41.0%
EB2-019 PILOT payments (100% to DACs) 100.0%
EB2-020 NYC revocable consent fee 80.0%
EB2-021 Easement fees paid to NYS agencies 27.1%
Total Expenditures
Thru 3rd Year of CDT $467,946 $314,057 $278,465 $1,303,169 $139,876 $238,010 $377,885 29.0%
Remainder $27,235 $272,608 $755,066 $1,054,909 $258,678 $748,291 $1,006,969 95.5%
Total 25-Term $495,182 $586,666 $1,033,531 $2,358,078 $398,553 $986,301 $1,384,854 58.7%
Total Jobs
Thru 3rd Year of CDT 2,770 1,038 1,221 5,933 571 977 1,548 26.1%
Remainder 8 4 6 18 2 5 7 36.7%
Total 25-Term 2778 1042 1227 5951 573 982 1555 26.1%
Table 16-6. Transmission figures.
For all Category 2 claimed EB2 ID Detailed description

benefits, Appleseed’s estimates
EB2-001 New Transmission - Construction person-yrs In NYS In DACs
of the value of incremental
Short-term Direct Job Creation (FTE-Years) 4,662 1,461
economic benefits accruing to
Unique Jobs 12,331 730
Disadvantaged Communities
assume that, for the proposed For purposes of this RFP response, we have defined “unique” construction jobs as, in effect, unique hires. The
relationship of unique jobs to total payroll or person-years of employment can vary considerably from project
transmission line, 15% of eligible to project. Estimates of unique jobs are based upon Unique Job estimates reported by Mott MacDonald for the
spending on construction proposed New Transmission facility. A “person-year” is a measure of employment that generally represents
the equivalent of one employee working full-time for a year. It could for example consist of two workers, each
between Fraser and Yonkers employed full-time for six months; or two workers employed half-time for a year. For additional details on how
will accrue to Disadvantaged these benefits accrue to DACs, refer to the Section 15 - Communities Engagement Plan.
Communities; and in New York EB2-002 New Transmission - Construction Payroll In NYS In DACs
City, 80% of direct benefits of Net Expenditures ($000) $842,200 $243,330
construction spending within Mott MacDonald’s estimates of the transmission construction payroll assume that construction workers are
the City (excluding purchases employed an average of 60 hours per week during the two-year construction period. These benefits are based
of professional services) will on estimated payments for labor-related expenditures for work that is performed in New York State. Examples
include gross wages (including employer side payroll tax payments), and benefit costs incurred in association with
accrue to Disadvantaged the employment of construction, rail and port workers, contractors and laborers, operations and maintenance
Communities. When combined personnel, engineering or environmental service providers, consultants, other employees and financial and legal
service providers associated with the Project.
with the Category 1 and
EB2-003 New Transmission - Non-Payroll Construction Spending In NYS In DACs
3 benefits, the portion of
incremental benefits accruing to Net Expenditures ($000) $104,300 $27,124
DACs exceeds the 40% target of Payments for in-State purchases of goods and services. Includes expenditures as a result of the purchase and
consumption of local goods and services (including sales tax), such as, but not limited to, food, lodging, vehicles,
the CLCPA. equipment and the purchase of materials sourced from within New York State such as, but not limited to, gravel,
steel, concrete and similar materials and/or the purchase and use of equipment and products manufactured or
16.4.1 Through 3rd Year assembled within New York State and/or the use of rental equipment or similar supplies sourced within New York
State.
of CDT EB2-004 New Transmission - Non-Payroll Construction Person-yrs In NYS In DACs
The Category 2 benefits
Short-term Direct Job Creation (FTE-Years) 349 80
associated with Project-related
Estimates of jobs supported through in-state purchases of construction-related goods and services, as further
transmission and infrastructure described in the Appleseed report. These jobs include an establishment of a project office in New York State, pre-
occurring from January 1, 2021 development activities, leases/purchases, and other related non-payroll employment.
through the 3rd year of the EB2-005 New Transmission - NYS-Based Professional Services Spending In NYS In DACs
CDT and claimed in the ODF Net Expenditures ($000) $242,700 N/A
are quantified and described EB2-006 New Transmission - NYS-Based Professional Services Person-yrs In NYS In DACs
in the following table based Short-term Direct Job Creation (FTE-Years) 904 N/A
on industry standards for
development, construction Table 16-7. Through 3rd year of CDT.
and operations cost estimating

methods. The Clean Path New EB2 ID Detailed description

York team is comprised of well-
EB2-007 New Transmission - ROW Usage Fee Paid by CPNY to NYPA In NYS In DACs
established generation and
Net Expenditures ($000) $6,300 N/A
transmission developers and is
advised by expert consultants NYSERDA’s Tier 4 RFP specifies that land lease payments may be counted as eligible economic benefits only
to the extent that they exceed the fair market value of the leased property. In most cases, however, the only
experienced with projects of alternative use of land leased for wind and solar facilities in upstate areas would be agricultural. The price of land
this size and scope. The claimed leased for agricultural purposes is typically much lower on a per-acre basis than the rents paid by developers
of renewable power. The amount cited here represents only the amount by which lease payments exceed the
benefits are therefore credible, estimated agricultural value of the leased land (assumed in this analysis to be $100 per acre).
reliable and verifiable to ensure EB2-008 New Transmission - Operating Jobs (FTE) In NYS In DACs
these benefits are realized
by New York rate payers and
These benefits include, but are not limited to, jobs associated with operations and maintenance, plant
Disadvantaged Communities management, and long-term project development.
associated with the project. EB2-009 New Transmission - Operating Payroll In NYS In DACs
For additional details on how Net Expenditures ($000) $3,274 $947

these benefits accrue to These benefits include, but are not limited to, jobs associated with operations and maintenance, plant
management, and long-term project development.
DACs, refer to the Section 15,
EB2-010 New Transmission - In-State Purchasing In NYS In DACs
Communities Engagement
Plan. Details regarding the Net Expenditures ($000) $5,082 $2,320
estimation methods used to These benefits are based on estimated payments for in-State purchases of goods and services. Including
determine the project-specific as, but not limited to, food, lodging, vehicles, and equipment.
expenditures and job creation EB2-011 New Transmission - Local Purchasing Jobs (FTE) In NYS In DACs
benefits are provided in the Short-term Direct Job Creation (FTE-Years) 10 4
Appleseed reports in Appendix
These benefits are based on estimated payments for in-State purchases of goods and services. Including
17 and additional details can be expenditures resulting from the purchase and consumption of local goods and services (including sales tax), such
provided upon request of the as, but not limited to, food, lodging, vehicles, and equipment.
NYSERDA review team. EB2-012 New Transmission - PILOT Payments In NYS In DACs
Each claimed incremental
Payments in-lieu-of taxes to school districts, cities, towns, and other taxing jurisdictions.
economic benefit in the
EB2-013 New Transmission - NYC Revocable Consent Fee In NYS In DACs
following tables detail the
corresponding EB ID# in the
ODF, the Project Phase, the Underground conduit installation fee paid to New York City Department of Transportation
Evaluation Period, the value EB2-014 New Transmission - Easement Fees Paid to NYS Agencies In NYS In DACs
of the benefit to NYS, portion Net Expenditures ($000)
accruing to DACs, and a Table 16-7 (continued). Through 3rd year of CDT.
reference to its alignment with
the benefit eligibility criteria
stated in the RFP.
EB2 ID Detailed description 16.4.2 Remainder of CDT

EB2-015 New Transmission - Operating Jobs (FTE) In NYS In DACs
The benefits being delivered to the State
of New York and the host Disadvantaged
Communities for the remainder of the
plant management, and long-term project development. CDT are an extension of the estimates of
EB2-016 New Transmission - Operating Payroll In NYS In DACs the Operating Payroll, Local Purchasing,
Land Lease Payments, Taxes, PILOTs and
Host Community Agreements established
plant management, and long-term project development. between January 1, 2021 and the COD.
EB2-017 New Transmission - In-State Purchasing In NYS In DACs
Net Expenditures ($000) $37,269
$17,011
16.5. Category 3 - Other
Including expenditures resulting from the purchase and consumption of local goods and services
activities that provide
EB2-018 New Transmission - Local Purchasing Jobs (FTE) In NYS In DACs opportunities for the
Short-term Direct Job Creation (FTE-Years) 10
4
New York workforce and
Including expenditures resulting from the purchase and consumption of local goods and services
communities
EB2-019 New Transmission - PILOT Payments In NYS In DACs The impacts of climate change on the
Net Expenditures ($000) environment, economy and society are
Payments in-lieu-of taxes to school districts, cities, towns, and other taxing jurisdictions.
becoming ever more apparent and will be
still greater in the future. The challenges
EB2-020 New Transmission - NYC Revocable Consent Fee In NYS In DACs
will be exacerbated by the issues we
Underground conduit installation fee paid to New York City Department of Transportation
face today: a widening wealth gap, racial
EB2-021 New Transmission - Easement Fees Paid to NYS Agencies In NYS In DACs
inequities, a mid-level skills gap, and a health
system recovering from a global pandemic.
Table 16-8. Remainder of CDT. However, there is hope that a clean and just
energy transition can bring innovation and
jobs to the economy while increasing energy
efficiency, reducing pollution, and combating
the threat of climate change. Clean Path
New York therefore has an obligation to
engage thoughtfully in the green economy,
interceding in areas where transition
threatens to deepen existing inequalities in
our society.
health impacts in minority communities. The New York Times

A green economy that leaves historically Magazine asserts that “[B]lack Americans are exposed to 1.5 times
disadvantaged populations behind will not be a as much of the sooty pollution [particulate matter] that comes from
sustainable economy. burning fossil fuels than the population at large.”4
The article goes on to explain that, “[a] study of more than 3,000
Equitable opportunity is extremely important to the Clean Path New US Counties released in April [conducted by Harvard University
York project. Clean Path New York will devote considerable time and researchers] shows a statistical connection between death rates from
effort to ensuring that outreach, access, and opportunities are made COVID-19 and long-term exposure to air pollution. Each increased
available to environmental justice communities, communities of color, microgram of [particulate matter pollution] per cubic meter of air is
and economically depressed and at-risk populations. The new green associated with an 8 percent increase in death from COVID-19.”
economy should benefit all of New York’s residents.
Couple these disturbing findings with other recent studies, one
As discussed in the CEP , and further defined and quantified in quantifying higher-than-appreciated global mortality (1 in 5 early
this IEBP, Category 3 incremental economic benefits may include deaths globally) from outdoor fine particle pollution generated by
workforce development activities, actions aimed at increasing the fossil fuel combustion5 and another showing increased prevalence of
likelihood that New York residents will find work on the project, and street-level particulate matter pollution in New York City in excess of
other actions that provide assistance to Disadvantaged Communities. 20 times what it was previously thought to be, and the importance of
projects like Clean Path New York is brought into stark relief.
The COVID-19 pandemic laid bare the deleterious impact of
long-standing systemic health and social inequities in New York In addition to directly reducing criteria pollutants NOx, SOx, and
State’s economy. According to the Centers for Disease Control and Particulate Matter from electric generation by 40% in Disadvantaged
Prevention, these social determinants of health put many people Communities through the delivery of clean energy and the
from racial and ethnic minority groups at increased risk of dying concomitant displacement of fossil fuel-fired generation sources,
from COVID-19.2 One study by Lauren Holmes Jr. et al. stated, “The Clean Path New York will drive significant direct environmental
COVID-19 mortality [cumulative incidence] indicated Blacks/AA justice benefits to Disadvantaged Communities. Clean Path New York
[experienced] 34% of the total mortality in the United States, albeit believes that even this substantial impact is by itself insufficient, and
their 13% population size.”3 that Clean Path New York must be leveraged to the greatest extent
possible as a remedy to the structural inequities described above.
A growing body of literature clearly documents the painful reality of
environmental justice burdens and their correlation with negative
2
https://www.cdc.gov/coronavirus/2019-ncov/community/health-equity/racial-ethnic-disparities/disparities-deaths.html
3
Holmes Jr., Lauren, et al. “Black–White Risk Differentials in COVID-19 (SARS-COV2) Transmission, Mortality and Case Fatality in the United States: Translational Epidemiologic Perspective and
Challenges,” Int. J. Environ. Res. Public Health 2020, 17(12), 4322.
4
Villarosa, Linda “Pollution is Killing Black Americans. This Community Fought Back.” New York Times Magazine, July 28, 2020. Found at https://www.nytimes.com/2020/07/28/magazine/pollution-
philadelphia-black-americans.html.
5
Vohra, Karn et al. “Global mortality from outdoor fine particle pollution generated by fossil fuel combustion: Results from GEOS-Chem.” Environmental Research. Vol. 195. April 2021.
Category 3 Economic
Initiative Workforce/jobs development Public health Env. Justice Total
Thru 3rd year of CDT $20,000,000 $10,000,000 $10,000,000 $10,000,000 $50,000,000
Remainder of CDT $80,000,000 $40,000,000 $40,000,000 $60,000,000 $220,000,000
Total $100,000,000 $50,000,000 $50,000,000 $70,000,000 $270,000,000
Table 16-9. Economic benefits under Category 3.
To that end, Clean Path New York will constitute a Community A preliminary array of programs and investments is provided in
Investment Fund of at least $270 million over 25 years prioritizing the Table 16.10 below. The full scope of economic benefits to be provided
following areas: under Category 3 will only be determined through consultation with
NYSERDA and engagement with the affected host communities.
• Workforce development and job creation
• Economic development The Clean Path New York Community Investment Fund will explore
partnering and funding with various institutions and programs that
• Enhancements in public health
are in line with the priorities outlined below, with reference to the
• Environmental justice Category 3 claimed benefit in the ODF:
An overarching goal of each of these priorities is to focus
opportunities in disadvantaged populations and environmental justice
communities. Through community engagement and outreach, Clean
Path New York will ensure that our Community Investment Fund is
in line with specific community needs. The fund will be managed by
a board of directors to be named after the project secures a funding
award from NYSERDA.
16.5.1 Workforce development and job creation

EB3 ID Detailed description
EB3-001 Workforce Development plus Job Creation - Through 3rd Year of CDT
Investment: $15,000,000
EB3-002 Workforce Development plus Job Creation - Remainder of CDT
Clean Path New York will help make New York a leader in the new green economy by creating the infrastructure that will support a diverse new green workforce.
Our current workforce must transition along with our energy system and support programs if that goal is to be achieved. The transition to a cleaner, decarbonized
economy will create millions of green jobs across the state. Such jobs will decrease inefficient consumption of energy or raw materials, limit greenhouse gases,
minimize waste and contamination, and protect or restore ecosystems. To support the green workforce, Clean Path New York will sponsor programs that provide
job training, promote career awareness, and strengthen the workforce pipeline through education. A special emphasis will be placed on programs that address
disadvantaged populations and environmental justice communities.
Over the next 25 years, the Clean Path fund will invest $100 million in the development of a workforce by promoting access to STEM, green, tech and other
essential jobs for members of historically Disadvantaged Communities, including those who have encountered barriers to entry due to their race, economic status,
former incarceration, gender, or ability.
Critical to success is the coordination of education, workforce development, and economic development, with a strengthened role for community-based service
providers — including community colleges, universities, vocational training programs, and local workforce nonprofits — to match employers’ needs to training and
education.
Workforce Pipeline and Career Awareness:
When Governor Andrew M. Cuomo announced New York’s bold commitment to become the nation’s leading green energy economy in his State of the State
message earlier this year, he rightly focused our attention on the importance of education in creating the new workforce that will drive New York’s success. The
State University of New York, as the nation’s largest comprehensive system of higher education, with 95% of all New Yorkers living within thirty miles of at least
one of its campuses, is charged with expanding and developing its commitment to studies aimed at making its graduates the best prepared when it comes to
taking up the thousands of jobs that will be created by Clean Path and by a myriad of other green energy projects in New York and elsewhere.
Clean Path New York will support the state’s efforts and, in fact, we have already briefed SUNY about its potential interest in helping the state to further its
commitment to New Yorkers who wish to enter the field of green energy and sustainability. The fund will commit significant funding to the SUNY system for the
following purposes:
• developing its green energy curriculum
• creating scholarships and financial aid programs for students who wish to pursue careers related to green energy and sustainability
• providing paid internships throughout the project and across the industry for enrolled students and enabling SUNY to expand programming for workforce
preparedness in green industries throughout the system’s 30 community colleges.
The 2012 report by the 21st Century Commission on the Future of Community Colleges underscored the essential role community colleges play in opening up
opportunities to all Americans, especially those who are new immigrants or come from Disadvantaged Communities.
Clean Path New York also intends to provide funds for:
• Experiential learning opportunities through job shadow, paid internships, mentorships, and apprenticeships.
• Creating and expanding STEM programs for the K-12 students who will become tomorrow’s innovators.
• Career and Technical High Schools – Investing in CTE high schools focused on preparing students for careers in energy and other technical fields is critical
to developing a green workforce. These programs allow students to pursue a targeted education that meets the needs of the workforce without spending
additional time and money at a four-year college. To make these programs work, however, public-private partnerships are essential. In addition to Department of
Education investment, industry expertise is vital to shaping the curriculum, offering mentorship, preparing students to enter the workforce, and being engaged
in recruitment when it comes time to pick up where the degree programs leave off. (cont.)
Table 16-10. Category 3 workforce development and job creation.

• College and University Scholarships —To offer underserved communities access to education, Clean Path New York pledges to fund endowed scholarships in
STEM disciplines at private and public higher education institutions across Clean Path New York’s service territory. In this way, Clean Path New York plans to
play a key role in educating future generations in STEM fields which offer strong job opportunities in diverse settings.
• STEM Curriculum and Educator Training Programs – A plethora of local organizations have worked for years to bring specialized educational opportunities into
the classroom by designing and sharing STEM curricula and training teachers to deepen students’ education in these subjects. By leveraging their expertise,
Clean Path New York proposes to expand the availability of such programs for local teachers in the Clean Path New York area who wish to expose their students
to diverse subjects that will better prepare them for careers in these specialties. Through these programs, Clean Path New York may distribute educational
materials such as textbooks or workbooks or may provide specialized kits for performing experiments. Training teachers to administer such curricula gives them
transferable skills and the tools needed to continue to reimagine the way they teach.
• After school programs
• Career fairs and career days
Job Training
For the unemployed and underemployed, job training will be key to providing meaningful career opportunities in the field of energy. Clean Path New York will work
with local job training programs to develop or expand programing to ensure that communities have access to these opportunities.
Some of the programs that will be considered include:
• Grassroots programs that provide job training and skills development while dismantling barriers to entry faced by marginalized populations such as the formerly
incarcerated, immigrants, and at-risk youth.
• Efforts to focus job recruitment on targeted distressed and environmental justice communities.
• Next Century Job Corps Training Facility – As technology continues to develop at a rapid pace, private companies will invest in facilities to train their existing
workforce on how to safely implement and use new systems. While these facilities will be primarily leveraged for internal training, Clean Path New York
proposes expanding the internal infrastructure to develop accessible training sites and programs for those interested. By making this training curriculum
available and affordable, Clean Path New York will give community workforce development candidates the opportunity to complete the training required to
enter the company at the entry-level union role. Nonprofit partners will also have the opportunity to utilize certain facilities to carry out licensing and certification
for those facing barriers to entry.
Even with significant investments to provide people with the skills necessary to obtain jobs in the green economy or technical sector, marginalized populations
can continue to face challenges when they enter the workforce. Difficulties with dependent care, transportation, and inflexible work arrangements can challenge
the retention of qualified employees from marginalized communities.
Working with NYS Pathways Program Employers is an opportunity for Clean Path New York to learn about best practices for making careers available to all
communities. Leveraging our own experiences, Clean Path New York will determine best practices for providing benefits, creating flexible work arrangements
when possible, and recruiting and retaining underserved populations..
Table 16-10 (continued). Category 3 workforce development and job creation.

16.5.2 Economic development

EB3-003 Economic Development - Through 3rd Year of CDT
EB3-004 Economic Development - Remainder of CDT
The new green economy is positioned to breathe new life into New York coming out of the pandemic. Recovery has already begun, and Clean Path New York will
prioritize community funds where the needs are greatest. Through its outreach, the team will engage with local Chambers of Commerce, small businesses and
non-profits to best position funds to support economic development in areas touched by transmission and generation projects. In addition, the support of MWBE,
VOSB and SDVOSBs will be an important priority.
Collectively, Clean Path New York partners have created a significant number of jobs with their green energy programs and administered high value programing
across the state.
Some of the actions that will be considered include:
• Supporting programs with similar goals, such as NYPA’s ReCharge NY and Municipal and Rural Electric Cooperative IEDP Programs. These programs have
helped to create and preserve about 170,000 jobs across the state.
• Supporting other related initiatives, such as the Smart Cities Program, which provides financial, logistical, technical, and informational support for cities that want
to make energy upgrades, and coordinate technology, such as:
– Connectivity (Public WiFi, Digital Kiosks, Smart Phone Applications)
– Environmental (Air Quality Sensor, Ice/Snow Detection, Sewer/Storm Water Monitoring)
– Transportation (Traffic Optimization, Traffic Monitoring, Parking Management)
– Public Safety (Video Analytics, Noise/Motion Detection, Gunshot Detection)
– Providing assistance for new and emerging businesses in the green energy sector, with a special emphasis on new MWBE, VOSB and SDVOSBs.
• Bridging the digital divide - The digital divide will become a primary driver of socioeconomic outcomes in the 21st century.
As labor productivity becomes increasingly reliant on information technology, inequality of economic outcomes will be more tightly correlated with access to the
next generation of telecommunications networks. These networks, whether wireline or wireless, are dependent on the fiber optic backbone necessary to satisfy
the incessant demand for bandwidth. Clean Path New York is uniquely positioned to help bridge this divide by leveraging its investment in infrastructure to extend
the telecommunications network to underserved communities.
If selected for this award, Clean Path New York would commit to help bridge the digital divide in New York State. Clean Path New York would start by
characterizing the communities of need that fall along the transmission line route. Specific targets would include educational centers and industry partners.
Table 16-11. Category 3 economic development.

16.5.3 Enhancing public health

EB3-005 Enhancing Public Health - Through 3rd Year of CDT
EB3-006 Enhancing Public Health - Remainder of CDT
Cleaner energy means healthier communities and that’s why Clean Path New York will embrace additional opportunities to help communities become healthier
and stronger. Existing health disparities became more obvious during the pandemic and communities in more polluted areas were affected at a much higher rate.
Clean Path New York will focus some of its funds toward those communities that are behind the curve and need additional resources.
Potential concepts that will be explored:
• Mount Sinai Public Health Partnership - Clean Path New York is focused on improving health outcomes in environmental justice communities that have
historically been underserved. In partnership with Mount Sinai, Clean Path New York will focus specifically on the South Bronx (Mott Haven and Hunts Point in
particular) and Astoria to create “Virtual First Community Care Access Hubs.” This ongoing commitment and program would specifically target children, families,
and pregnant women of color who face economic and access barriers to care. The goal of Clean Path New York’s yearly investment in these communities would
be to increase access to physical, behavioral, and social care, ultimately improving clinical outcomes and reducing the disparities in services these communities
have historically faced.
Based on a model already successfully established at the Dream Charter School in East Harlem, a Community Health Worker (CHW) positioned at public,
neighborhood schools provide facilitation for telehealth access. The facilitation includes providing education regarding the technology, helping students
and families navigate telehealth platforms, and connecting them directly for behavioral and physical health. Mount Sinai would partner with us to provide the
behavioral health access and the local Federally Qualified Health Centers would provide most of the physical care including prenatal care. Remote monitoring
for pregnant women with comorbid conditions is also available. Critically, social care (food, transportation, benefits, etc.) is coordinated by the community health
worker.
By bringing care to the community in an efficient manner, these hubs are easy to scale and provide new access points for those at highest need. The hubs target
high risk, vulnerable communities that often struggle with accessing telehealth due to mistrust, lack of awareness and education, or lack of broadband and WIFI
infrastructure.
• The Clean Path New York team will seek to take these successful public health programs and expand them throughout the generation and transmission footprint
of the project. The lack of affordable and accessible primary care options for communities along the project footprint will be a primary focus of the Clean Path
New York Community Investment Fund.
• Access to open community space, bike paths and supporting beautification efforts. These all contribute to healthier ways of living and will be considered where
project opportunities present themselves.
Table 16-12. Category 3 public health.

16.5.4 Environmental justice

EB3-007 Environmental Justice - Through 3rd Year of CDT
EB3-008 Environmental Justice - Remainder of CDT
The new green economy must be an economy with opportunities for all - from the construction site to the living room. Equal protection from environmental
hazard and equal opportunities for creating cleaner, greener homes are among the main objectives of Clean Path New York. Project partners have successfully
implemented clean energy and market accelerating investments across the Capital, Mid-Hudson and Southeast NY Regions.
These efforts encompass Energy Efficiency, Clean Energy Advisory Services (Solar and Storage Projects) and advancing the decarbonization of the transportation
sector. NYPA also continues to enhance its communication to its public customers, including municipal and governmental entities, on how to take control of
their energy use, providing insights and resources to achieve GHG and energy reductions. These priorities and communication processes will continue and be
enhanced to meet the needs of Clean Path New York.
Improving energy efficiency also has an economic impact. Through its continuously evolving partnership with the private sector, NYPA has made investments of
over $1.2 billion, creating over 22,000 jobs and avoiding emission of close to 9,000 metric tons of GHG CO2e. Clean Path New York will consider ways to bolster
these programs to complement its transmission and generation projects.
Further, housing is an area that cannot be ignored when it comes to environmental justice – both the outside and inside environments contribute to a community’s
overall health and wellness. One of the areas Clean Path New York will look at, based on experience at NYPA, is public housing. While environmental justice
communities will be benefit from all of the priorities outlined above, additional measures can be taken to help these communities.
Some of the programs that will be considered include:
• Improving affordable housing and reducing emissions in Disadvantaged Communities through electrification retrofits to spur local investment, create good jobs,
and reduce the environmental burden existing buildings place on local communities
• Working with public housing entities throughout the state to upgrade facilities with energy efficient products and technologies, such as:
– Energy Star refrigerator updates
– HVAC/boiler replacement
– Steam
– Hot water systems
– Heating systems
– LED lighting upgrades
– Building Envelope-external weatherization
• eMobility – transportation and congestion can be a contributing factor to pollution in environmental justice communities. The team will review programs that
focus on the following transportation solutions:
– Supporting programs like EVolve NY, which provides Level 2 and DC fast charging stations for electric vehicles
– Electrification of transit fleets
• Alternative methods of transportation such as bike shares and bike paths, where communities desire more connectivity.
• Supporting the environment – Clean Path New York will support environmental causes and priorities throughout the transmission and generation footprints –
from clean water and clean air to habitat protection and conservation..
Table 16-13. Category 3 environmental justice.

The Clean Path New York Community Investment Fund will be a A preliminary list and description of anticipated documentation is
collaborative program, informed by meaningful stakeholder outreach provided below.
and community priorities. With special focus on disadvantaged
populations and environmental justice communities, Clean Path New List of Anticipated Documentation
York looks forward to providing opportunities for all to thrive in the • Labor-related expenses:
new green economy.
– W-2s, 1099s or other tax documents
– Copies of subcontracts
16.6. Economic benefits verification plan – Project Labor Agreements
Clean Path New York will consult with NYSERDA on developing an • Local Goods and Services:
effective Economic Benefits Report and Verification Plan to ensure – Receipts
claimed benefits are realized. As stated in Appendix G of the RFP, – Check registers
“Proposers must provide an Economic Benefits Verification Plan – Invoices with proof of payment
specifying how the claimed Incremental Economic Benefits will be – Bank statements
documented for contract compliance. Specifically, Proposers should • Operations and Maintenance:
include a description or list of the documents, reports, contracts,
– Receipts
invoices, or other information that they anticipate submitting to
allow NYSERDA to verify the actual economic benefits that accrue – Check register
to New York State. Such description or list need not be exhaustive – Invoices with proof of payment
and may be amended and refined at the election of the Proposer – Bank statements
at any time prior to submission of the Economic Benefits Report. • Other evidence or documentation, subject to NYSERDA’s approval
A section of the Economic Benefits Report shall state the final
description and/or list of documentation used for measurement and
verification of the economic benefits claimed.”
The guidelines and requirements regarding the Economic Benefits Clean Path New York looks forward to delivering
Claims and Verification in Exhibit F of the PSA provide a detailed and
both the inherent and incremental Economic
thorough outline for such a Plan and Clean Path New York proposes
to work within that framework when selected by NYSERDA to enter
Benefits we’ve presented in the CEP and IEBP to
PSA negotiations. New York State.
RFP No. T4RFP21-1 • May 2021

Clean Path NY

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New York State Energy Research and

Development Authority (NYSERDA)

Purchase of New York

Cover letter Section 9. Energy storage operation plan 152

Acronyms and abbreviations Section 10. Business entity and

Section 3. Proposer experience 27 Section 13. Project schedule 221

Section 4. Resource description and Section 14.O

Section 6. Baseline verification plan 142 Section 16. Incremental economic

Section 8. Energy resource assessment 150

Appendices Appendix 18. Mott MacDonald Field Investigation Plan

Appendix 11. P(50) 12x24 energy resources

Appendix 16. AKRF Air Quality and Benefits Distribution to

Appendix 17. Appleseed Economics and Community Benefits report

Acronyms and abbreviations

An “All Renewable, All New York” Resource Portfolio

Beyond that, NYSERDA will be able to establish a resale market for

1.2. Fulfillment of PSC Evaluation Criteria

4. Impacts to disadvantaged communities.

$6.25 billion in avoided social and public

Over 50% of this benefit occurs

6. Economic benefits to the state.

Creates 10,618 person years of in-state jobs

Generates $1.6 billion in tax revenue,

The Marcy-South corridor to be used for Clean Path New York

The transmission route represents the optimal balance of increasing

1.4. Supply Plan

Project Developer Capacity Location Technology Tier-1 Contract COD

1.5. Utilization of Blenheim-Gilboa

The incorporation of the Blenheim-Gilboa facility in the Clean

We offer an alternative (reduced) strike price of $ Twinleaf Solar

Sandy Creek Solar

West River Solar

Contracting Blenheim-Gilboa Heritage Wind

pumped storage to balance Horseshoe Solar

New Transmission Baron Winds

Canisteo Wind Bluestone Wind

The most important congestion point on the bulk power system

The transmission resource developed by Clean Path New York

By developing 3,800 MW of clean energy throughout

Based on PowerGEM’s modeling, which assumes the State will meet

Clean Path New York provides the targeted CO2 emissions

Over 57% of these reductions, or 1.5 million tons, are located in

In the 2035 case, with 9 Gigawatts (GW) of offshore

1.8. Complement to Offshore Wind 1.9. NYISO Leadership on Intrastate HVDC

1.11. Economic Development by

Investment in New York State and Disadvantaged Communities ($000)

Community and Workforce

Job Creation in New York State and Disadvantaged Communities

New York Disadvantaged % to Disadvantaged

See Appendix 25.

1.12. Team Experience

Clean Path New York

Figure 1-17. Management chart for project bid phase

The business model for Clean Path New York is

• Funds REC payments • Energy market,

resources from Rock Tavern to

Acronyms and abbreviations Section 10. Business entity and

Section 4. Resource description and Section 14.O

Section 6. Baseline verification plan 142 Section 16. Incremental economic

Appendix 16. AKRF Air Quality and Benefits Distribution to

Appendix 17. Appleseed Economics and Community Benefits report