Board of Selectmen Regular Meeting (linked)

Waterford Youth & Family Services
To: Board of Selectmen
From: Dani Gorman, Human Services Administrator
Cc: Mike Buscetto, Chairman
Brett Mahoney, Parent
Michelle Mahoney, Parent
Elizabeth Sutman, Parent
Heston Sutman, Parent
Meaghan Lineburgh, Record Secretary
Re: Youth Appointments to the Waterford Youth & Family Services Advisory Board
Date: September 6, 2023
On behalf of Youth & Family Services advisory board chairman Mike Buscetto, I respectfully
ask that consideration and appointments be given to the following students as follows:
Clara Mahoney (Waterford resident / address omitted)
Waterford High School
Grade: 11
Representation: Student Representative
Term: Present ~- 05/31/24 (06/01/23-05/31/24)
Brady Sutman (Waterford resident / address omitted)
Waterford High School
Grade: 11
Representation: Student Representative
Term: Present - 05/31/24 (06/01/23-05/31/24)
Both students have been involved with Youth and Family Services and Camp DASH. Each
exemplifies the qualities we look for in our youth; especially in advocating for the interests
and needs of their peers.

From: Laurette Saller <Jaurettesaller@gmail.com>
Sent: Tuesday, August 15, 2023 10:22 AM
To: Robert Brule <rbrule@waterfordct.org>
Subject: Data center proposal
“We are encouraged to see our largest taxpayer reinvest in our community,” said
Waterford First Selectman Rob Brule. “This particular collaboration will undoubtedly
benefit every taxpayer in the Town of Waterford, not only today, but for generations to
come.”
Dear Mr Brule,
I do not support the construction of a data center near Millstone Point as proposed. I am a
taxpayer that will not benefit. Our property value will go down and we will not be able to live in
peace. In light of our location next to a noisy nuclear power plant, it is untenable that we should
suffer insult to injury with an additional source of noise. The combined effect of daily operation,
construction and special events(over heating)noise in addition to the nuclear power plant drone
would prevent the peaceful sleep and enjoyment of our home on Gun Shot Rd. (So many nights,
Tam awakened by loud diesel generators, back up tones from trucks working on the silos for
spent fuel etc. .
Our neighborhood has done enough for the good and well being of Waterford . NIMBY does
not apply because we already have a nuclear power plant in our backyard. What’s in yours?
I am disturbed that you and Ms Sabilia are promoting this project near our neighborhood in
newspapers using such glowing terms without considering the effects on nearby residences.
These articles quoting you, in the Day have only stated the positive but not the negative effects.
Just a few...
~ This company was not allowed to build in both Groton and Montville for good reasons . The
track record of their business practices is poor and perhaps
unethical. (https://www.datacenterd ynamics.com/en/news/groton-connecticut-ceases-data-center-
discussions-with-ne-edge-with-prejudice/)
-We have many elderly and compromised residents that would suffer from disturbance.

-Waterford has other land designated for industrial purposes and even a large half empty mall,
near a highway that could be utilized .
-baseball fields (another source of noises)utilized by many children are located too close to the
proposed site.
-Environmental impacts, especially noise. we live next to a NUCLEAR power plant with silos
full of spent radioactive fuel.
-Regulatory oversight is nonexistent or “self” regulatory.
(The article above is just one of many illuminating the problems created when a Data Center is
placed near residences.)
[ urge you to respect our property rights to peace as well as the $$$rights for profit of Dominion.
Laurette Saller
4 Gun Shot Rd

August 21, 2023
Dear Mr. Brule:
| felt gratified when | saw that the sign at the Waterford Duck Pond which dedicated the park to a
Vietnam veteran had been taken down. Later
| realized that it might have been taken.down temporality while the park is being re-landscaped. |
hope not.
| realize that we lost over 58,000 service members during the war and another 110,000 troops to
suicide after they returned, Nevertheless, the war has not been shown to be justified and the war
cost millions of the lives of the people of Southeast Asia. Because Agent Orange was used to
defoliate thé landscape, Vietnamese women became contaminated with it and Jeft to experience the
highest rates of reproductive system cancers in the world. Also, many children were born with
defects.
It isn’t clear that our nation has ever corne to grips with what it did in Vietnam. The dedication
therefore seems wrong-minded and | hope the park will be returned to its duck pond identity.
Sincerely, i
Jim McHugh (a Jn Magh
Waterford
i
i
i
|

Robinson+Cole
KENNETH C. BALDWIN
280 Trumbull Street
Hartford, CT 06103-3597
Main (860) 275-8200
Fax (860) 275-8299
kbaldwin@rc.com
Direct (860) 275-8345
Also admitted in Massachusetts
and New York
August 30, 2023
Via Hand Delivery
Melanie A. Bachman, Esq.
Executive Director/Staff Attorney
Connecticut Siting Council
10 Franklin Square
New Britain, CT 06051
Re: _ Petition No. 1586 - Dominion Energy Nuclear Connecticut, Inc. — Petition for a
Declaratory Ruling on the Need te Obtain a New or Modify an Existing Siting
Council Certificate to Modify the Boundary of the Site at the Millstone Power
Station, Waterford, Connecticut
Interrogatory Responses
Dear Attorney Bachman:
On behalf of Dominion Energy Nuclear Connecticut, Inc. (“Petitioner”), enclosed please
find the original and fifteen (15) copies of the Petitioner’s Responses to the Council
Interrogatories for Petition No. 1586. Electronic copies of these responses have also been sent to
the Council today.
If you have any questions or need any additional information, please do not hesitate to
contact me.
Sincerely,
Kenneth C. Baldwin
KCB/kia
Enclosure
Boston | Hartford | New York | Providence | Stamford | Albany | Los Angeles | Miami | New London {| re.com
Robinson & Cole Lie

STATE OF CONNECTICUT
CONNECTICUT SITING COUNCIL
IN RE:
A PETITION OF DOMINION ENERGY : PETITION NO. 1586
NUCLEAR CONNECTICUT, INC. FOR A
DECLARATORY RULING ON THE NEED TO
OBTAIN A NEW OR MODIFY AN EXISTING
SITING COUNCIL CERTIFICATE TO MODIFY
THE BOUNDARY OF THE SITE AT THE
MILLSTONE POWER STATION, WATERFORD, :
CONNECTICUT : AUGUST 30, 2023
RESPONSES OF DOMINION ENERGY NUCLEAR CONNECTICUT, INC
TO CONNECTICUT SITING COUNCIL INTERROGATORIES
On August 9, 2023, the Connecticut Siting Council (“Council”) issued Interrogatories to
Dominion Energy Nuclear Connecticut, Inc. (“Petitioner”), relating to Petition No. 1586. Below
are the Petitioner’s responses.
Notice
Question No. 1
Has Dominion Energy Nuclear Connecticut, Inc. (DENC) met with the Town of
Waterford (Town) and/or submitted any proposed site plans or applications for land use and
environmental permitting with the Town? What comments and concerns were expressed by the
Town?
Response
As discussed in the Petition, NE Edge, LLC (“NE Edge”) is leading the development of
the data center project and interacting directly with the Town of Waterford on this opportunity.
We understand the Town of Waterford entered into a Municipal Host Fee Agreement with NE
Edge for this data center. We are not aware of any concerns expressed by the Town.
27796334-v3

Question No. 2
Has DENC received any comments from the Town since the filing of the Petition?
Response
Yes. In the First Selectman’s letter dated August 23, 2023, to Melanie A. Bachman,
Executive Director of the Connecticut Siting Council, the Town of Waterford supports DENC’s
petition and agrees with DENC that neither a new Certificate of Environmental Compatibility
and Public Need nor a modification to its existing certificate is required to revise the boundaries
of MPS.
Question No, 3
What United States Nuclear Regulatory Commission (USNRC) requirements apply to the
proposed site boundary revision for the lease and collocation of the data center within DENC
property boundaries? How will DENC comply with these requirements?
Response
The site boundary is described within the Final Safety Analysis Reports (FSAR).
Revisions to the FSAR’s are governed by the 10CFR50.59 process to evaluate changes. DENC
will review the FSAR’s, and assess the changes needed using the 50.59 process. It is not
anticipated that prior USNRC approval will be required as it is expected that the changes will
have minimal to no impact on safety.
Question No. 4
What ISO-New England, Inc. (ISO-NE) requirements apply to the proposed
interconnection of the data center switchyard to the Millstone Power Station (MPS) switchyard?

Response
One potential ISO-NE requirement is that ISO-NE might need to review its existing
Interconnection Agreement with MPS to determine whether the description of the MPS facilities
would need to change in the existing Interconnection Agreement. Dominion does not believe that
there are ISO-NE interconnection requirements that apply to NE Edge itself.
Existing Facility Site
Question No. 5
Referencing Petition p. 3, Lease Area | is a vacant area used periodically for equipment
and material storage during site development activities. Where on the existing facility site would
DENC establish a new area for this purpose?
Response
DENC cutrently utilizes several existing open areas on the 526 acres MPS parcel for
equipment and material storage, from time to time, as needed for site development projects.
Presently, DENC is not using any portion of Lease Area | for this purpose. Most of the area
identified as Lease Area | remains wooded.
Question No. 6
Referencing Petition p. 3, Lease Area 2 is partially wooded, contains the existing salt
shed and is used to store equipment or trailers temporarily. Where on the existing facility site
would DENC establish a new area for these purposes? How would DENC continue to
access/manage the salt shed during the lease term?
Response
DENC would plan to relocate the existing sand and salt shed to another nearby location
on MPS property, yet to be determined. DENC will notify the Council once a new location has

been selected.
Question No, 7
Referencing Petition p. 3, Lease Area 3 is a vacant area used periodically for equipment
and material storage during site development activities. Where on the existing facility site would
DENC establish a new area for these purposes?
Response
Presently, DENC is not using any portion of Lease Area 3 for equipment and material
storage. When needed, DENC would plan to use other areas on MPS property for equipment and
material storage, yet to be determined.
Facility Site Revision
Question No. 8
What ts the term of the lease for the three areas? Are there any lease provisions for
restoration of the three areas at the end of the data center’s useful life?
Response
The terms of the ground lease between DENC and NE Edge are not yet final, but it is
expected to be in place for a long-term period. DENC would also expect that the ground lease
would require removal of all equipment and restoration of the three areas at the end of the data
center’s useful life.
Question No, 9
Could the data center buildings and/or switchyard be repurposed by DENC for MPS
operations at the end of the lease term? If not, are there lease provisions for decommissioning of
the data center and/or its switchyard at the end of the lease term?

Response
The ground lease between DENC and NE Edge has not yet been finalized. At this time,
neither DENC nor NE Edge are considering repurposing the buildings or switchyard at the end
of the lease term.
Question No. 10
How would construction and operation of the data center and its switchyard impact
current access to MPS? For example, would there be increased traffic, separate driveway
entrances and gates, additional security protocols, etc.? Explain.
Response
If the data center use is approved by the Town of Waterford, DENC would work with NE
Edge to develop a traffic safety and access plan for construction and operation of the data center
use. With this plan in place, no adverse traffic impacts are anticipated. Construction is expected
to be phased to minimize active areas of work, and construction material, parking, and storage
areas will be identified with separate driveway connections to Millstone Road. Adequate
construction driveway lengths will be provided in advance of security fences and buildings to
ensure adequate queuing without backup onto Millstone Road. During operations, we
understand that the data center will employ 120 people, over 3 shifts, potentially 40 cars per
shift. Each building will be surrounded by separate security fencing with 24/7/365 security staff
on site.
Question No. 11
How would the data center switchyard interconnect with the existing MPS switchyard?
What modifications would be required at the existing switchyard for this interconnection?

Response
The primary source of power for the data center will be from the MPS Units 2 and 3
generator terminals directly, which does not require a connection to the MPS/Eversource
switchyard. The details of the electric interconnection design have not yet been completed.
Question No. 12
What system impact studies has DENC and/or Eversource conducted to ensure that the
data center interconnection would not adversely affect the safe and reliable operation of MPS
and Eversource’s electric distribution system?
Response
The electrical supply from MPS to the data center is in the initial conceptual
phase. When the final design has been vetted, it will be determined what studies are required by
any third party(s), if any.
Question No. 13
Is the interconnection required to be reviewed by ISO-NE? Why or why not?
Response
See DENC’s responses to Interrogatory Nos. 4 and 12 above.
Question No. 14
What is the anticipated maximum load in megawatts from operation of the data center?
Response
The anticipated maximum load is estimated to be approximately 300 MW.
Question No. 15
Would operation of the data center and its switchyard have any potential adverse impact
on any of DENC’s obligations to federal, state or regional entities under any permit, contract or
license (ex. reserve margin, operating reserves, maintenance)? If so, how will DENC address
-6-

these potential impacts?
Response
No.
Question No. 16
Would interconnection of the data center to MPS have any impact on MPS’ winter or
summer reliability?
Response
No.
Public Safety
Question No. 17
In the event of a fire or other emergency associated with the data center and/or its
switchyard, would MPS revise its Emergency Response Plan to include Lease Areas 1-3?
Would the data center and its switchyard also have a separate Emergency Response Plan?
Explain.
Response
NE Edge would be responsible for emergency planning for the data center use and
operations. NE Edge will cooperate with DENC and the Town of Waterford to complete a
response plan specific to the data center use.
Question No. 18
How would operation of the data center and its switchyard contribute to existing
background noise levels at the MPS site? Would expected cumulative noise levels from the
operation of MPS, the data center and its switchyard comply with state noise control regulations?

Response
DENC does not have information on the expected noise levels from the proposed data
center and switchyard operations but would expect that those issues would be addressed through
the Town’s land use regulatory process. DENC understands that the NE Edge plans to install
sound attenuation measures and will meet all state noise control regulation.
Question No. 19
Does the location of the data center and its switchyard comply with the NRC minimum
distance requirement within an owner-controlled area?
Response
As discussed above in response to Interrogatory No. 3, DENC will assess the Site
boundary revisions and any associated minimum distance requirements using the NRC’s 50.59
process. It is not anticipated that prior USNRC approval will be required as it is expected that
the changes associated with the data center with have minimal or no impact on safety at MPS.
Question No. 20
What is the distance from the rail line to the proposed data center switchyard? Does this
distance comply with the National Electrical Safety Code (NESC)?
Response
The final design and layout of the new switchyard has not yet been completed. That said,
the design, construction and operation of the switchyard will comply with all federal, state and
local laws and regulations.
Question No. 21
Would the construction of the data center switchyard require notification to the operator
of the rail line and/or require any construction-related safety measures?

Response
The design of the switchyard has not yet been fully developed. As a part of that design,
all construction-related safety measures will be evaluated. Notice will be provided to the operator
of the rail line if required.
Question No. 22
Do any Occupational Safety and Health Administration restrictions apply to activities
beneath the electric lines associated with the data center in Lease Area 2?
Response
There are currently no overhead electrical lines through Lease Area 2.
Environmental Effects and Mitigation Measures
Question No. 23
Referencing Petition Exhibit 1, Connecticut Siting Council Site Plan, Map References
2A-2D, did any of the wetland scientists who performed the wetland and watercourse
delineations recommend any mitigation measures for the protection of the wetlands and
watercourses on or traversing Lease Areas 1-3, If yes, what are the recommendations?
Response
According to NE Edge, the data center building footprints and associated roadways and
site amenities have been located to minimize disturbance on inland wetlands and provide
adequate separation to sensitive areas.
Question No, 24
Referencing the attached State Plan of Conservation and Development Map by GZA,
dated December 20, 2011 (Attachment 9 to the Docket 265A application), what impact would
development of Lease Areas 1-3 for the data center and its switchyard have on the identified

“Preservation Areas”?
Response
According to NE Edge, the “preservation areas” identified in green on the referenced map
(Docket 265A Attachment 9) to the north of the railroad corridor and in the vicinity of Lease
Areas 1-3 align with the limit of wetland soil types identified on Natural Resources Conservation
Service Soil Survey mapping. There will be no work associated with the development of Lease
Area {-3 within these “preservation areas”. Further, each development will be designed with
adequate separation to inland wetlands. No adverse impacts are anticipated.
Question No. 25
What is the approximate acreage of vegetative clearing required to develop Lease Areas
1-3 for the data center and data center switchyard?
Response
The area of wooded and scrub vegetation to be cleared and grubbed is estimated as
follows:
Lease Area 1 approximately 24 acres
Lease Area 2 approximately 9 acres
Lease Area 3 approximately 1 acre
Question No. 26
How would construction of the data center and its switchyard change the visual character
of the area surrounding the existing MPS site?
Response
DENC does not anticipate any significant change to the visual character of the MPS site.
The location of the data center is deep within the MPS site and is not expected to be visible from
most locations in the surrounding communities.
-10-

Question No. 27
How would construction of the data center and its switchyard impact the current open
space areas on the MPS site? What is the current acreage of the existing open space areas on the
MPS site and what would be the approximate acreage of the remaining open space areas on the
MBS site post-data center development?
Response
As requested in the Petition, DENC seeks to remove 55 acres (Lease Areas | and 2 and 3)
from the previously defined MPS site. With the exception of the developed portion of Lease
Area 2 (existing Sand and Salt Shed ~ 2 acres) a majority of this area of land north of the rail line
would currently be considered “open space” (currently approximately 257 acres of the MPS land
area north of the railroad are considered open space). DENC estimates that the MPS land area
north of the rail line would continue to maintain approximately 204 acres of open space
following the development of the NE Edge data center (257-55+2=204 acres).
-{1-

CERTIFICATE OF SERVICE
I hereby certify that on the 30 day of August, 2023, a copy of the foregoing was sent,
via electronic mail, to:
Robert A. Avena, Waterford Town Attorney
Nicholas F. Kepple, Waterford Town Attorney
Suisman Shapiro
20 South Anguilla Road
P.O. Box 1445
Pawcatuck, CT 06379
ravena@sswbgg.com
nkepple@sswbgg.com
Robert J. Brule, First Selectman
Town of Waterford
15 Rope Ferry Road
Waterford, CT 06385
firstsel@waterfordct.org
fice 9 Gy —
Kenneth C. Baldwin
-12-

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MAN ROBERT BRULE
sident, voter, and/or property owner in the town of Waterford, request an
ng for information on the Data Center projects at the Dominion Power Plant
LoL Ae g eff

TO: FIRST SELECTMAN ROBERT BRULE
We, the undersigned resident, voter, and/or property owner in the town of Waterford, request an immediate
Town Meeting for information on the Data Center projects at the Dominion Power Plant property.
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TO: FIRST SELECTMAN ROBERT BRULE & RTM MEMBERS
We, the undersigned resident, voter, and/or property owner in the town of Waterford, OPPOSE the
development and implementation of Data Centers at the Dominion Power Plant property.
NAME (Print)
SIGNATURE
STREET ADDRESS ,|PHONE EMAIL
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From: rjmmddmd <rjmmddmd@aol.com>
Sent: Tuesday, September 5, 2023 8:19 PM
To: Robert Brule <rbrule@waterfordct.org>
Subject: Request of town wide meeting
: CAUTION: This email originated from outside of the organization.
\ ‘Do not click links or open attachments unless you recognize the sender's email address
and know the content is safe. :
Lo ane mow Me content 8 sate
Dear First Selectman Brule,
As a resident of Waterford | think it is important to hold a town-wide meeting for information and listening session on
the proposed data center.
My personal reservation is working with a company that has no proven track record. My secondary concern is the
location and size.
Thank you for your attention in this matter.
Sincerely,
Richard Martin
62 in Windward Way

From: jenlowney@aol.com <jenlowney@aol.com>
Sent: Tuesday, September 5, 2023 6:57 PM
To: Robert Brule <rbrule@waterfordct.org>
Subject: Request of Town-wide meeting
bo CAUTION: This email originated from outside of the organization. |
; Do not click links or open attachments unless you recognize the sender’ 's email address :
i pe I
and know the content is safe.
a aia ea an eer |
Dear First Selectman Brule,
As a resident of Waterford I think it is important to hold a town-wide meeting for information
and listening session on the proposed data center.
My personal reservation is working with a company that has no proven track record. My
secondary concern is the location and size.
Thank you for your attention in this matter.
Respectfully,
Jennifer Lowney
62 Windward Way
860-608-9563
Sent from the all new AOL app for iOS

From: James and Heather Fillion <eastfilli@aol.com>
Sent: Tuesday, September 5, 2023 5:01 PM
To: Robert Brule <rpbruie@waterfordct.org>
Subject: Fwd: Proposed Data Center
Sent from my iPhone
Begin forwarded message:
_ From: James and Heather Fillion <eastfilli@aol.com>
Date: September 5, 2023 at 12:54:03 PM EDT
To: rbrule@waterfordct.gov
Subject: Proposed Data Center
Sent from my iPhone
Begin forwarded message:
From: JAMES FILLION <eastfilli@aol.com>
Date: September 5, 2023 at 10:49:25 AM EDT
To: siting. council@ct.gov
Ce: rbrule@waterford.org
Subject: Re: The staggering ecological impacts of computation and the cloud - MIT
Schwarzman College of Computing
We are writing to the siting council and to notify Rob Brule, of our strong feelings of opposition
towards the data center proposal. We live at 63 Windward Way, Waterford.
Residing approximately 1500 feet from the suggested data site. It is obviously the most
vulnerable location in terms of being exposed to chronic noise pollution, but we do not feel any
resident of Waterford should be expected to live with the damaging effects of constant,
inescapable noise. We have been told that the proximity to Millstone is beneficial to NE edge
and and to the power plant for uninterrupted power.
This should not be at the expense of ruining the quality of life for thousands of residents. There
should be an industrial location at least a mile from any residential area that would be more
appropriate. Perhaps the town of Waterford can negotiate for less money to offset the expense of
keeping the facility away from our cherished neighborhoods. The articled published by MIT that
we have included, speaks to all of our concerns and hopefully yours as well. Even the most
accomplished data centers throughout the world have promised noise cancellation prior to

building, but have not been able to follow through with that pledge. The residents of these areas
are left fighting an endless battle to rectify a new, intolerable, quality of life. It then becomes
easier for the centers to pay the fines as there is nothing that can be done to stop the noise. It
seems that the questions asked by the siting counsel were answered with very vague responses.
There has not been an effort to include the residents of Waterford in this process. It is also very
concerning that the developer has never built a data center before, and that his reputation is in
question. The research on noise and environmental pollution related to data centers is
overwhelming and hard to deny.
We also have research on the large number of data center fires, which is a huge concern being so
close to the site. https://dgtlinfra.com/data-center-fires/
Please refer to this as well.
Sent from my iPad
On Sep 1, 2023, at 9:06 AM, JAMES FILLION <eastfilli@aol.com> wrote:
https://computing mit.edu/news/the-staggering-ecological-impacts-of-computation-and-the-
cloud/
Sent from my iPhone

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Shannon Withey
From: LaFountain, Dakota <Dakota.LaFountain@ct.gov>
Sent: Wednesday, September 6, 2023 11:42 AM
To: 
attorneyvalliere@aol.com
Ce: Robert Avena; Nicholas Kepple; kbaldwin@rc.com; First Selectman; CSC-DL Siting
Council
Subject: RE: Petition # 1586 from Dominion Energy Nuclear Connecticut, Inc.
Attachments: PE1586_Valliere_a.pdf
Good Morning,
Please see the attached correspondence.
Thank you,
Dakota LaFountain
Clerk Typist
Connecticut Siting Council
10 Franklin Square,
New Britain, Connecticut, 06051
P: 860.827.2940 | E: dakota Jafountain@ct.gov
fe
CONNECTICUT SITING COUNCIL
From: attorneyvalliere@aol.com <attorneyvalliere @aol.com>
Sent: Wednesday, September 6, 2023 8:06 AM
To: CSC-DL Siting Council <Siting.Council@ct.gov>; Bachman, Melanie <Melanie.Bachman @ct.gov>; Fontaine, Lisa
<Lisa.Fontaine @ct.gov>
Cc: Robert Avena <ravena@sswbgg.com>; Nicholas Kepple <nkepple@sswbgg.com>; kbaldwin@rc.com; Rob Brule
<firstsel@waterfordct.org>
Subject: Petition # 1586 from Dominion Energy Nuclear Connecticut, Inc.
Please accept my submission in opposition of a declaratory ruling.
1

Attached are my letter (which includes Exhibit # 3) and Exhibits # 1 and 2.
Thank you.
John C. Valliere

STATE OF CONNECTICUT
CONNECTICUT SITING COUNCIL
Ten Franklin Square, New Britain, CT 06051
Phone: (860) 827-2935 Fax: (860) 827-2950
E-Mail: siting council@ct. gov
Web Site: portal.ct.gov/esc
VIA ELECTRONIC MAIL
September 6, 2023
John Vatliere
294 Millstone Road East
Waterford, CT 06385
attorneyvalliere@aol.com
RE: PETITION NO. 1586 — Dominion Energy Nuclear Connecticut, Inc. petition for a
declaratory ruling, pursuant to Connecticut General Statutes §4-176 and §16-50k, that
neither a new Certificate of Environmental Compatibility and Public Need (Certificate)
nor a modification to its existing Certificate is required to revise the boundaries of the
Millstone Power Station electric generating facility site located off Rope Ferry Road,
Waterford, Connecticut.
Dear John Valliere:
The Connecticut Siting Council (Council) is in receipt of your recent correspondence concerning
Petition No. 1586.
Before reaching a final decision on any petition, the Council must carefully consider all of the
facts contained in the evidentiary record that is developed by the Council, the petitioner, parties
and intervenors in the proceeding, and consider all of the concerns received from members of the
public who submit written statements to the Council.
This petition will be placed on a future Council meeting agenda for discussion and decision.
Please note that you can view the petition filing on our website at portal.ct.gov/csc under the
“Pending Matters” link. You may also keep apprised of Council events on the website calendar
and agenda.
Thank you for your interest and concern in this very important matter. Your correspondence will
be entered in the public comment file related to this petition.
Sincerely,
Nit fal
Melanie A. Bachman
Executive Director
MAB/dll
c: Council Members
-\pelitions\5(11-1600\1586\pubticeamment\pe1 585, vulliere doux

From: attorneyvailiere@aol.com <attorneyvalliere@aol.com>
Sent: Wednesday, September 6, 2023 8:06 AM
Ta: CSC-DL Siting Council <Siting.Council@ct.gov>; Bachman, Melanie <Melanie.Bachman@ct.gov>;
Fontaine, Lisa <Lisa.Fontaine@ct.gov>
Ce: Robert Avena <ravena@sswbgg.com>; Nicholas Kepple <nkepple@sswbgg.com>; kbaldwin@rc.com;
Rob Brule <firstsel@waterfordct.org>
Subject: Petition # 1586 from Dominion Energy Nuclear Connecticut, Inc.
Please accept my submission in opposition of a declaratory ruling.
Attached are my letter (which includes Exhibit # 3) and Exhibits # 1 and 2.
Thank you,
John C. Valliere
sApetitions\1 50 |-160011586\publiccommentipe] 86, yalfire. dows.

John C. Valliere, Esq.
Attorney At Law
294 Millstone Road East Phone (860) 442-1294
Waterford, CT 06385 Fax (860) 442-1295
AttorneyValliere@aol.com
Via Email and Priority Mail
September 6, 2023
Melanie A. Bachman, Executive Director
State of Connecticut
Connecticut Siting Council
Ten Franklin Square
New Britian, CT 06051
RE: PETITION # 1586 from Dominion Energy Nuclear Connecticut, Inc.
Dear Ms. Bachman and Members of the Siting Council:
This is written requesting the Siting Council deny the Petition (#1586) from Dominion
Energy Nuclear Connecticut, Inc (DENC}. DIENC is seeking a declaratory ruling
regarding the Domition property on Millstone Road (off Rope Ferry Road) in Waterford,
While there are dozens of reasons why almost 20 percent of the site's north unallocated
land should not be leased out and be used for data center projects, I will highlight a few.
First, as you are aware, this property was specifically designed over 50 years ago to
accommodate nuclear reactors. Frankly, that plan and the critical thinking put into it 50
years ago, has beén a success and has enabled the property to host 3 nuclear reactors and
generate 50% of Connecticut’s energy for many years.
The plan 50 years ago-enabled the facility to have large swaths of land around it,
presumably for safety, security, and to offer a large buffer to protect the surrounding
neighborhoods.and communities, including Waterford and East Lyme.
The current site plan allows the reactors, personnel working in the facility, and the
surrounding community to remain safe. The site, with its latge tracts of land, allows the
energy producing equipment to be free from outside interlopers (including but not limited
to, domestic terrorists and ill-intentioned persons) and allows-the energy producing
equipment to be the sole equipment on the property.
In terms of security, the long-term. design for the property greatly assists Dominion to
keep the reactors from harm. The reality of domestic terrorism. in today’s world is real.
The current plan and layout of the property allows Dominion to control and secure the
important nuclear reactors by keeping them at a significant distance from the public and
Page | 1

public thoroughfares. (It was only about 20 years ago when military Humvees with
military. personnel were stationed outside the entrances of the property to protect the
property-during the 9-11 crisis). Allowing other outside entities to develop on the
property complicates the ability to: keep the reactors safe and secure. Given the proposal
in the Petition, there will be a much smaller buffer to keep the reactors isolated, safe, and
secure, reducing the buffer from about.a mile down to a little aver 1000 feet.
Protection of the surrounding community is also part.of the long-planned design of the
property. The site as it currently sets, hag done a great job of buffering the negative
effects of the power plant from the surrounding neighborhoods, Allowing data centers on
leased land on the Dominion property does not follow that plan, The data center projects
have not been well publicized to the surrounding neighborhoods, and the ill effects,
including but not limited to low level hum noise and environmental damage, have not
been explained nor publicized, There is growing opposition to the plan as it becomes
known.
Issuing a declaratory ruling without any stated long-term plan and allowing data centers
takes away Dontinion’s (or any future owner's) ability to develop the land for energy
generation. The property should be used exclusively for the generation of nuclear energy
as it was designed and intended. Although reactor #1 has completed its planned mission,
there are opportunities for newer nuclear reactor technologies to replace it, technologies
that are smaller and more efficient than #1 ever Was. Dismantling # 1 and building
smaller and more efficient reactors, as is being done in. Wyoming, is the type of
construction that should be occurring on the Dominion site, not energy drawing data
centers. Building nuclear reactors is what the site logically should be used for and fits
into the past and future long-term plans.
If the Siting Council allows the 50-year plan to be destroyed and allows leasing for non-
energy producing entities, where will it stop? Currently, the plan is for 2 data centers,
one 1.132 million square feet (// times the size of the average full scale data center) and
a second 428,000 square feet in size (4 times the size of the average full scale data
center), Although it is not outwardly shown, there iy a plan for-an-additional 2 more data
ceniters.on the site in the future. If the Siting Council allows for one or two, it would be
éasier to then request for number three and four. The Siting Council would lose control
of the ability to limit other “industrial uses” if it allows the data centers to start to grow
on the property.
Issuing a declaratory judgment allowing the leasing and building of data centers on the
Dominion site with no specifics of how the data.center will affect the future of energy
generation at the property is imprudent. There is no plan or documents offered on how
the construction of the massive data centers-and their long-term placement on the
property affects the current operation of the facility asa power generator. Dominion is
asking your permission to allow a company te lease and build data centers 4 and. 11 times
the normal size of average centers by. a company that is less than 2 years old and has
neyer successfully built a.data center. In fact, at least three other towns have rejected the
project, even though it would not have been placed in such a sensitive and secure location
Page | 2

as the Dominion site. This. project should not just to be allowed to be developed on the
Dominion site just by asking a simple declaratory ruling.
Enclosed, please find pictures of the site as Exhibits | and 2. In contrast to the map
provided by Dominion as their Exhibit 1, the enclosed Exhibits 1 & 2 demonstrate the
proximity to the-neighborhoods and recreational sports fields, the significant-amount of
trees, vegetation and woods that would be cleared and destroyed, and the proximity to a
large pond on the property, with no study of how this project will affect the numerous
osprey nests at that pond as well as other wildlife on the property as a whole.
Also, of concerning note, is the August 30, 2023 responses to interrogatories by
Dominion, which some at best are disingenuous and at worst misleading.
Question I and 2°s Responses about the Town’s expressed concerns and received
comments are misleading. This project appears to be spearheaded by Waterford’s First
Selectman Robert Brule, who ironically is-quoted by a Socal newspaper as.saying he
would not warit a data center near his residence given the data center’s extreme noise
generation. As stated herein, this project has had very little publicity, as has Waterford’s
entering the Municipal Host Fee Agreement with NE Edge. The “unanimous” vote from
the Board of Selectmen and the Representative Town Meeting (RTM) members was
done, as. some would say,” under the radar.”
Enclosed as Exhibit #3 is an email thread’ between RTM member Dan Radin and myself
regarding this project. Coming from one of the RTM’s own members, he states on page
One in paragraph #4 about the approval being “purely ceremonial” and about “optics” as
opposed to the proposed project being thoroughly explained to town residents and vetted.
He further expressed the First Selectman Brule could have signed the Agreement without
any approval from the Board or RTM.
Even more disturbing is Dan Radin’s assertion in Paragraph #6 that the meeting was
“poorly: publicized” and “held on short notice.” This unprecedented, massive project was
well in the. works long before that meeting and yet the document to start the project was
“approved” and entered into with little public comment or any reasonable notice to the
Town residents, especially and including to the surrounding neighborhoods. If such a
project. was truly good for Waterford and the Dominion site, why the seerecy and lack of
candor to the-public and allowance for real public review and response early on? There
will be mounting opposition to this project as more details are given to the Town’s
residents. Even with the mounting opposition, certain town officials continue to be not
forthcoming with information and deadlines, including this Siting Council Petition and
the ability to offer comment. This is concerning on many levels.
Question 3°s Response is also concerning in that there is no way to know the impact on
safety. Nobody knows ot has demonstrated the effects of removing the large, long
planned buffer of land or what placing non-energy generating buildings on the property
will do to safety, but there is one thing for sure; it will take away any platined safety
margin in the site’s design.
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Question 9°s Response regarding the plan at the end of the lease term (or the end of the
useful life of the data centers) shows the lack of planning and forethought as given to the
original site plan. of 50 years ago. Although the data center is supposed to be a 30-year
lease, given the speed of technology, there is ne guarantee the data centers will be viable
for that long. As pointed out by RTM member Dan Radin, just think back to the
technology from 30 years ago.as opposed to today. Who gets the cleanup mess if NE
Edge abandons the project early and is gone?
Question 14, [5 and 16’s Responses in relation to the number of megawatts the data
centers will consume is quite telling, and disturbing. Yanking out 300 MW of power
from the ISO-NE grid would be minimally disastrous. There is already energy insecurity
in Connecticut, New England and the country, given the current demand (especially at
peak times) and the known large future increases in demand in the years ahead. Once the
data centers are plugged in, they will continue to suck out 300 megawatts per year and
run 24/7 no matter what the other demands are for Connecticut and New England.
Unlike residential and business consumers, data centers cannot cut back on their energy
use when electricity demand is at its peaks in summer and winter. The data centers will
continue fo draw and have the need. Such a draw will lead to higher prices overall for the
residential and business consumers, as simple supply and demand economics oceur. As
stated earlier, the Dominion site should be used for future power generation. Leasing
large swathes of land only detracts from this ability and-does not allow for good future
planning of energy generation versus energy draining and depletion endeavors.
Question. 17°s Response leaving any emergency planning to NE Edge is also eye opening,
This is a company. that is less than 2 years old, with no previous experience. building data
centers, including no completed projects, and is looking to build minimally 2 hyper-sized
data centers in a sensitive nuclear site. Any data projections, including in Response #23,
are just that--projections. The Dominion-site should not be gambled with in hopes.of
getting it right, especially with no future oversight from the Siting Council.
Given the foregoing, itis respectfully requested the Siting Cotincil deny: Petition #1586
for a declaratory. ruling for the Dominion property.
Sincerely.
John € Valliere, Esq.
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CERTIFI