STATE OF MAINE

BOARD OF ENVIRONMENTAL PROTECTION

IN THE MATTER OF

NORDIC AQUAFARMS, INC Belfast and Northport Waldo County, Maine

) APPLICATION FOR AIR EMISSION, SITE ) LOCATION OF DEVELOPMENT, ) NATURAL RESOURCES PROTECTION ) ACT, and MAINE POLLUTANT ) DISCHARGE ELIMINATION ) SYSTEM/WASTE DISCHARGE LICENSES ) )

PRE-FILED DIRECT TESTIMONY OF EDWARD COTTER, PROJECT DIRECTOR. NORDIC AQUAFARMS, INC.

1. My Name is Edward Cotter. I hold a Bachelor of Science Degree in Ocean Engineering from the

University of Rhode Island. I have 20 years’ experience in design, planning, permitting, and

construction of coastal structures, commercial and industrial buildings, and large scale

infrastructure. I have managed planning and construction of nearly one billion dollars in

projects over that time. In 2018, I joined Nordic Aquafarms AS as Project Director for US

operations, directing engineering and construction projects for NAF, Inc, a subsidiary company

of Nordic Aquafarms AS. My professional experience and qualifications are further detailed by

my curriculum vitae, which is included as Addendum A.

2. The proposed Belfast facility is the Nordic Aquafarms Inc. flagship facility internationally due to

its location and long-term development potential. The purpose of the project is to provide

33,000 metric tons of high quality, sustainable seafood to consumers in the northeast United

States. Considerable local engineering has been completed to achieve infrastructure

connectivity, local adaptation of the project, and to minimize impacts from development.

3. The Nordic Aquafarm project is proposed to be located on the northwest side of Route 1

(Northport Avenue) in Belfast, Maine adjacent to the Belfast Reservoir Number One, as shown

on the United States Geologic Survey (USGS) topographic map attached as Nordic Exhibit 1. The

project site consists of parcels owned by the Belfast Water District (BWD), Mathews Brothers

and Sam Cassida. The development also includes easements to the northwest of the entire

parcel to connect a sewer line to the existing Belfast city sewer on Northport Avenue, by way of

Perkins Road, and an easement through the Eckrote parcel for the intake and outfall piping. The

primary access to the site will be off Route 1 at the current site access for the BWD. The

proposed project is located within the Route 1 South Business Park district and is abutted to the

north by the Mathews Brothers facility. The Residential II zone abuts the site to the north and

east, with residential properties located directly north of the site and along Route 1. The

existing BWD parcel adjacent to Reservoir Number One, contains approximately 14 acres that

will be retained by the City of Belfast and kept undeveloped as resource protection and

buffering. There is an existing trail system through this area and along the reservoir and Little

River. Approximately 2 acres of the BWD parcel is currently developed with an office building, a

former filter house, two garage buildings, and associated driveways and parking. A concrete

dam controls the water level to the reservoir, and piping associated with the former use of the

reservoir as the water supply for the City of Belfast still exists adjacent to the dam and the office

building.

4. In May, 2019, Nordic Aquafarms submitted an application package to the Maine Department of

Environmental Protection for consideration of multiple permits under the jurisdiction of the

following regulations: Site Location and Development Act, Natural Resource Protection Act, a

Chapter 115 Minor Source Air Pollution License, and a Maine Pollution Discharge Elimination

System and Waste Discharge License. These permit applications were consolidated to allow for

all aspects of the proposed development to be considered as a whole.

i. Site Location of Development Act (SLODA): The applicant proposes a phased build out of

a land based aquaculture facility on approximately 32 acres of land. The remainder of

the land purchased will remain as undisturbed buffer or be transferred back to the City

for recreational use (Shoreland Zone along Reservoir 1). The proposed facility includes

finfish rearing facilities as well as associated support buildings and site improvements. A

seawater intake and discharge system is proposed to be installed in the adjacent portion

of the Penobscot Bay.

ii. Natural Resource Protection Act (NRPA): The aquaculture facility avoids, mitigates and

compensates for impacts to protected natural resources (coastal wetlands, upland

wetlands, stream etc.) for which there is no practicable alternative that would meet the

project purpose.

iii. Minor Source Air Pollution License: The project has been developed to use waste heat

from the fish husbandry process as a heat source for all buildings, therefore eliminating

the requirement for a traditional boiler system. However, the need for reliable

electrical power for the filtration and water quality processes in order to avoid fish

mortalities makes back-up power generation a requirement for the project. In addition

to back-up generation, the applications also include the proposed use of the generators

for “peak shaving”, or reduction of demand from the external power grid during

traditional peak load times. This will allow the project to reduce demands on the

external grid at times when the grid is most stressed. This arrangement is mutually

beneficial to the applicant as well as users of the local infrastructure because it

increases reliability during high stress periods. The applicant has proposed to limit use

of the generators by placing a cap on fuel usage at 900,000 gallons per year, ensuring

classification as a minor source is maintained while maximizing this mutual benefit.

iv. Maine Pollution Discharge Elimination System (MEPDES) and Waste Discharge License:

The proposed project is a Recirculating Aquaculture Facility which employs significant

water treatment infrastructure to vastly reduce the quantity of water that is taken into

the system and discharged compared to any currently operating facilities in the area,

including other RAS facilities. The water is treated within the facility and reintroduced

into the process system using internal treatment measures. Only a small portion of the

overall system water is then taken from the production system, piped to a separate

wastewater treatment plant where solids and nutrients are removed and ultraviolet

light treatments are used to neutralize any potential pathogens before it is discharged

into the Penobscot Bay.

a. The water treatment technology includes denitrification and other best in class

technologies for nutrient removal even though there are not yet water quality

standards for these nutrients.

b. The flow rate of the proposed system is .337 m3/sec (7.7 mgd)

c. The effluent concentrations for the proposed discharge are as follows:

Total suspended solids (TSS)= 6.33 mg/l (185 kg/day)

Biochemical Oxygen Demand (BOD)= 5.55 mg/l (162 kg/day)

Total Nitrogen (TN)= 23.02 mg/l (673 kg/day)

Ammonium Nitrogen (NH4)= 0.0024 mg/l (0.07 kg/day)

Phosphorus (P)= 0.20 mg/l (5.8 kg/day)

5. In addition to the applications before the Board, the applicant has also pending applications in

front of other local, state, and federal authorities.

i. The City of Belfast Planning Board is in the midst of a review of the applicants request

under five separate ordinances: Site Plan, Zoning, Shoreland Zoning, Significant Water

Intake/Discharge Pipes, and Significant Groundwater Wells.

ii. The Maine Department of Agriculture, Conservation, and Forestry Bureau of Parks and

Lands (“BPL”) approved a Submerged Lands Lease for the project which is currently on

appeal and awaiting remand to the BPL for reconsideration.

iii. The Maine Department of Agriculture, Conservation, and Forestry has approved an

Aquaculture License for the proposed project.

iv. The Army Corps of Engineers, New England Division has under review, an application for

a development permit under Sections 10 (Rivers and Harbors Act) and 401 (Clean Water

Act).

[INTENTIONALLY LEFT BLANK]

EDWARD M. COTTERProject Director

EXPERIENCENordic Aquafarms, Inc. Portland, MEProject Director 2018-Present

• Responsible for engineering and construction related activities for US capital projects. Lead US engineering staff and outside vendors through planning, permitting, and construction phases.

• Establish project goals for schedule, budget, and quality and develop action plan for achieving such.

• Work with design and construction partners to establish a comprehensive commissioning and turn-over plan that will allow a smooth transition into operations and maintenance phases.

Gilbane Building Company Glastonbury, CTProject Manager 2006-Present

• University of Connecticut NextGen Capital Improvement Program. Leading team of engineers and superintendents for multiple projects from programming through closeout to meet project objectives while maintaining budget and schedule. Provide leadership for campus wide construction initiatives such as ongoing safety evaluations, campus logistical coordination, and utility framework programming support. Report to multiple Directors and Vice President of University Planning, Design, and Construction.

• Jackson Labs- Farmington, CT. Management and oversight of new campus construction for life science client establishing a new team in CT. Provided swing space renovation, move management, and management of 183,000 s.f. new building construction.

• Electric Boat- Groton, CT. Oversight and Quality Control of an $85M upgrade to existing dry dock structures on campus. Maintain cost, schedule, and quality documentation for the US Navy certified structures to ensure certification was re-established at the completion of the project.

Ocean and Coastal Consultants, Inc. Trumbull, CTProject Structural Engineer 2004-2006

• Project Engineer for design, production of construction documents, and shop drawing review of various coastal installations.

• Member of Construction Document Committee, review of specifications and construction drawings for accuracy and adherence to company policies and guidelines prior to client delivery

EDUCATIONUniversity of Rhode Island Kingston, RI

• Completed Master’s Level courses in structural engineering including Steel, Timber, and Foundation Design.

University of Rhode Island• Bachelor’s of Science, Ocean Engineering

CERTIFICATES AND PROFESIONAL REGISTRATIONS• Engineer in Training (EIT), Rhode Island• OSHA Confined Space Safety Entry

Supervisor Program• Member, Association of General

Contractors• OSHA certified 30-hour Construction Safety

Certification

Kingston, RI2000

• OSHA HAZWOPER 40 hour training• Certified Welding Inspectors Welding

Fundamentals Seminar• Member, CMAA• Member, Construction Institute• Associate Member, American Society of

Civil Engineering

ADDENDUM A

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!PIntake

Discharge

Copyright:© 2013 National Geographic Society, i-cubedS:\Data\NH\Project\171_05027\Maps\location_map.mxd

Site Location Map

Proposed Aquaculture Facility285 Northport AvenueBelfast, Maine

[0 2,0001,000

1 inch = 2,000 feet

Scale and Orientation

Prepared For

Site Address

Regional Locator Map

171.05027 Apr 2019

Notes1. Data Source: USGS National Map Seamless Server, 24K2. USGS Quad: 7.5 Minute Searsport & Belfast 1976 (revised 1979)3. Latitude: 44° 23' 43" N Longitude: 68° 59' 39" W UTM Northing: 4915777 mN UTM Easting: 500444 mE

Belfast

Nordic Aquafarms, Inc.159 High StreetBelfast, Maine

Site Boundary

Ocean Pipelines

Legend

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24x36

CURRENT ISSUE STATUS:

0"

PROJECT MANAGER: PROJECT NO:

A/E OF RECORD:

DRAWN BY:

SCALE:

SHEET No.

PROJECT NORTH:

C COPYRIGHT 2018 SMRT INC.

ARCHITECTURE

SMRT FILE:

SHEET TITLE:

REV DESCRIPTION DATE

NOT FOR CONSTRUCTION

144 Fore Street/P.O. Box 618Portland, Maine 04104

SMRT Architects and Engineers

AS NOTED

1/4" 1/2" 1" 2" 3"

JOB CAPTAIN:

ENGINEERING PLANNING INTERIORS ENERGY

Ransom Consulting Engineers and Scientists400 Commercial Street, Suite 400Portland, Maine 04101

NORDIC AQUAFARMS

BELFAST, MAINE

OVERALL SITE PLAN

ADB 18076-00

Checker

AP001

ISSUED FOR PERMIT4-25-19

AP001-18076-00

285 NORTHPORT AVENUE

Author

FSP

KEYNOTEBUILDING 1: GROW-OUT MODULES1ST FLR: 336,669 SF

BUILDING 7: OFFICE / ADMINISTRATION1ST FLR: 8,936 SF2ND FLR: 8,371 SF

BUILDING 5: CENTRAL UTILITY PLANT1ST FLR: 18,998 SF2ND FLR: 18,998 SF

BUILDING 3: SMOLT1ST FLR: 107,893 SF

BUILDING 6: OXYGENGENERATION

BUILDING 4: FISH PROCESSING1ST FLR: 24,096 SF2ND FLR: 24,096 SF

BUILDING 2: GROW-OUTMODULES

1ST FLR: 336,669 SF

BUILDING 9: GATE HOUSE1ST FLR: 298 SF

BUILDING 8: WATER TREATMENT1ST FLR: 20,056 SF

BUILDING 10: VISITOR CENTER1ST FLR: 2,188 SF

FISH POND

SWITCH YARD

UNDERGROUND FUEL STORAGE

EXISTING DAM