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Petition of Beaver Wood Energy Pownal, LLC )

for a Certificate of Public Good, pursuant to 30 )
V.SA. § 248, to install and operate a Biomass
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old Docket No
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biomass Project” )



October 25, 2010

The purpose of the pre-filed testimony of Mr. Crary is to demonstrate that the proposed
Pownal Biomass Project will comply with certain provisions of 30 V.SA. 248 (b)(5).
namely those pertaining to outstanding resource waters, streams, wetlands, rare or
irreplaceable natural areas, and necessary wildlife habitat and endangered species.

1. Introduction 1
2. Summary of Findings 3
3. Conclusion 10

Exhibit Petitioners AC-i Resumé of Adam R. Crary

Exhibit Petitioners AC-2 Memorandum: Wetland, Stream, and other Natural

Resources Summary


Petition of Beaver Wood Energy Pownal, LLC )

for a Certificate of Public Good, pursuant to 30 )
V.S.A. § 248, to install and operate a Biomass )
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old Docket No
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biomass Project” )



1. Introduction

Qi. Please state your name, business address and employment.

Al. My name is Adam Crary and I am employed by Vanasse Hangen Brustlin Inc.

(VHB), formerly known as VHB Pioneer. The VHB business address is 7056

U.S. Route 7, North Ferrisburgh Vermont. I am a Senior Wetland Scientist

responsible for managing projects, staff, and technical work in conduct of various

ecological surveys and reporting, typically under the requirements of federal,

state, and local environmental regulatory programs. My resume is attached as

exhibit AC-i.

Q2. Please describe your educational background and professional experience.

A2. I hold a B.S. degree in Natural Resources with a concentration in Natural History

and Ecology (2000) from the University of Maine (Orono). My education,

training, and professional experience include wetland, waters, and stream


Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 2 of 10

delineation and jurisdictional determinations; wetland function and value

assessments; stream assessments (quality, flow, habitat, biological, and

geomorphological); compensatory wetland mitigation (feasibility, design, and

monitoring); stream restoration/enhancement (feasibility, design, and monitoring);

vascular flora identification and collection; floristic monitoring and surveys; rare,

threatened and endangered plant species surveys; natural community assessments

and environmental inventory; and technical and scientific report and oral

presentation development. I am a recognized Professional Wetland Scientist

(Society of Wetland Scientists Professional Certification Program, #1691), a

certified Professional Wetland Delineator (Virginia Department of Professional

and Occupational Regulation, #3402 000067), and a recognized Rare Plant

Surveyor (USFWS, Virginia Field Office).

Q3. What is the purpose of your testimony?

A3. The purpose of my testimony is to demonstrate that the Pownal Biomass Project

(the “Project”) satisfies the requirements of 30 V.S.A. § 248(b)(5). Section

248(b)(5) provides, in pertinent part, that a generation or transmission facility

should not have an undue adverse effect on water purity or the natural

environment, with due consideration having been given to the criteria specified in

10 V.S.A. § 1424a(d) (Outstanding Resource Waters) and § 6086(a)(1) through

(8) and (9)(K) (various Act 250 criteria). My testimony specifically covers

Outstanding Resource Waters [10 V.S.A. § 1424a(d))], Streams [ 6086(a)(1)(E)1,


Pownal Biomass Project, PSB Dockel No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 3 of 10

Wetlands R 6086(a)(1)(G)], Rare and Irreplaceable Natural Areas [ 6086(a)(8)],

and Necessary Wildlife Habitat and Endangered Species [ 6086 (a)(8)(A)].
Q4. Have you testified previously before the Board?

A4. Yes. Previously, I have testified regarding the Chittenden County Solar Partners,

LLC South Burlington Solar Farm project, PSB Docket No. 7611. In this prior

testimony, I testified as an expert witness regarding 10 V.S.A. § 1424a(d)

(Outstanding Resource Waters), Headwaters 6086(a)(1)(A)], Floodways [
6086(a)(1)(D)1, Streams [§ 6086(a)( I )(E)j, Shorelines [ 6086(a)( 1 )(F)],
Wetlands [ 6086(a)(1)(G)], Rare and Irreplaceable Natural Areas [ 6086(a)(8)],
and Necessary Wildlife Habitat and Endangered Species [ 6086 (a)(8)(A)].
2. Summary of Findings

Q5. Based upon your evaluation and analyses, does the Project comply with Section


AS. Yes. The project complies with the Outstanding Resource Waters criterion j10

V.S.A. § 1424a(d)] as the project is not located on, and would not affect any
segment of waters determined to be Outstanding Resources Waters. The project

complies with the Streams criterion [* 6086(a)(1)(E)] because the project requires
minimal work in streams and conforms to the ANR riparian buffer guidance, and

does not encroach on streams or their buffer zones. The project complies with the

Wetlands criterion [ 6086(a)(1)(G)]. because Project will not affect significant

wetlands as defined by the Natural Resources Board, as no State of Vermont

Class I or II Wetlands are present on the project site. The project complies with

Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 4 of 10

the Rare and Irreplaceable Natural Areas criterion [ 6086(a)(8)1, because the

project site is not within a state-designated Natural Area, Significant Natural

Community, or Natural Heritage Program Fragile Area. The project complies

with the Necessary Wildlife Habitat and Endangered Species criterion R 6086

(a)(8)(A)1 because the project site does not comprise necessary wildlife habitat or

endangered species.

Q6 What work have you conducted with respect to the Project?

A6 My staff and I have conducted site inspections, research, delineation, and

prepared a technical memorandum that addresses the natural resources criteria at

the site including streams, wetlands, and threatened and endangered species,

significant natural communities, and necessary wildlife habitat. Regarding

Outstanding Resource Waters [10 V.S.A. § 1424a(d)), we have researched Water

Resources Panel (WRP) designations for such waters. Regarding Streams [

6086(a)(l)(E)], we have performed site inspections to delineate the ordinary high

water marks and top-of-bank for the onsite stream channels, which include

segments of the Hoosic River (eastern bank) and Ladd Brook, and have made

riparian buffer assessments for both. Concerning Wetlands [ 6086(a)(1)(G)j. we

have performed site inspections to delineate the wetlands, collect data per federal

requirement, and coordinate with the U.S. Anny Corps of Engineers (USACE)

and the Vermont DEC-Wetlands Division regarding federal and state jurisdiction.

Concerning Rare and Irreplaceable Natural Areas criterion [ 6086(a)(8)], and

regarding Necessary Wildlife Habitat and Endangered Species I 6086 (a)(8)(A)j,


Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 5 of 10

we have reviewed available databases for known occurrences within or adjacent

to the site and have corroborated the findings with onsite inspections. Much of

the work I, or my staff, have conducted, is presented in the “Wetland, Stream, and

other Natural Resources Summary” memorandum included as Exhibit AC-2. I

have prepared this written testimony following review of the Bruno Associates

Inc. P.C. “2010 Construction Layout Plan”, dated 1015/10, as well as the Bruno

Associates Inc. P.C. drawing OA-1, revision date 10/18/10, sponsored in Exhibit

BHB-4 in the pre-filed direct testimony of Bruce Boedtker. I have also prepared

this written testimony in corroboration with my colleague, Meddle Perry, who

also provides pre-filed direct testimony regarding certain provisions of 30 V.S.A.

§ 248(b)(5), namely those pertaining to headwaters, waste disposal, floodways,

certain aspects of streams, shorelines, water supply for the project, and burden on

existing water supplies. In the following sections, 1 rely on the prefiled direct

testimony and supporting exhibits of either Mr. Perry or Mr. Boedtker for project

descriptions or conclusions drawn relative to the project plans or design.

Q7 Is the project located on, or would it affect any segment, of any desigiated

Outstanding Resource Waters [10 V.S.A. § 1424a(d)J?

A7 No. The Vermont Water Quality Standards (VWQS, effective January 1, 2008)

under section 1-03D, state that the Natural Resources Board (NRB) may, under

10 V.S.A. Section 1424(a), designate Outstanding Resource Waters, or “ORW”.

The Natural Resources Board, under 10 V.S.A. Section 1424(a), designates

Outstanding Resource Waters. A list of these waters is maintained on the Water


Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 6 of 10

Resources Panel (WRP) website ( The

following waterways have been classified by the WRP as Outstanding Resource


1. Batten Kill River, Towns of East Dorset and Arlington

2. Pike’s Falls/Ball Mountain, Town of Jamaica
3. Poultney River, Towns of Poultney and Fair Haven
4. Great Falls. Ompompanoosuc River, Town of Thetford

The proposed Project is not located in the vicinity of any of the listed waters;

therefore the project will have no affect on such features.

Q8 Will the Project have an undue adverse effect on the natural environment, with

due consideration being given to the criteria of 10 V.S.A. § 1424a(d) regarding

the designation of Outstanding Resource Waters?

A8 No. As presented in Exhibit AC-2, there are no streams or other natural water

bodies within the planned project development site and there will be no direct

impact to stream channels for the project other than a single intake pipe described

in some detail below and in Mr. Perry’s testimony. The Hoosic River and Ladd

Brook do occur nearby to the project development site, the Hoosic River bank

lying approximately 50-feet from the nearest perimeter fence limit and Ladd

Brook banks lying, on average, approximately 25-feet from the perimeter fencing

limit. As presented in Exhibit AC-2. the Hoosic River existing riparian condition

and the Ladd Brook existing stream channel and riparian condition have been

Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 7 of 10

degraded by past land uses. As discussed further below, it is therefore my opinion

that the project is not within the vicinity of any waterways that would be

considered significant, or that would otherwise support an ORW designation,

because the streams in the vicinity should not be considered “highly significant”

per Section 1424a(d), and considerations of these criteria are not applicable to the

project. Therefore, and as discussed further under the Streams section below and

in the testimonies of Mr. Perry and Mr. Boedtker’s, the Project will not have any

adverse effect on the natural environment with respect to waters that might be

considered significant or support an ORW designation.

Q9 Will the project maintain the natural condition of streams?

A9 Yes. My colleague Meddie Perry will testify regarding the proposed water

withdrawal from the Hoosic River, which will maintain natural conditions of

depth and velocity of flow downstream. My testimony pertains to the delineation

of streams and their buffers, and the project’s design insofar as it does not

encroach on the stream buffers. As presented in Exhibit AC-2, delineated

segments of the Hoosic River lie to the west of the project development site and

the Ladd Brook to the north. With exception of the placement of the river water

intake pipe below ordinary high water on the Hoosic River (generally described

below and in more detail in Mr. Perry’s testimony), the project will not require

any direct impacts to streams. Also as presented in Exhibit AC-2, VUB

recommended riparian stream buffers be maintained from the onsite streams,

which were assessed in accordance with Section III.B.3 of the Vermont ANR’s

Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 8 of 10

December 9, 2005 Guidance for Act 250 and Section 248 Comments Regarding

Riparian Buffers (the Guidance) and are graphically depicted on Page 21 of the

Attachment in Exhibit AC-2. The project development does not take place within

the Hoosic River stream buffer, and in most cases, the project site is sited well

beyond the buffer. Two minor perimeter fencing encroachments within the Ladd

Brook buffer will be necessary and is an acceptable activity per Section III.C of

the Guidance.

This river water intake will cause only a minimal amount of disturbance below

the basic River ordinary high water mark as it will be installed by hydraulically

jacking from a pit that is outside of the buffer, and the only disturbance will be an

8-inch diameter location where the intake pipe will protrude from the underwater

riverbank in the 5-foot deep intake pool. As Mr. Perry’s testimony explains, the

intake has been designed so that the maximum water velocity at the intake screen

will be less than 0.3 feet per second, which will not entrain or impinge fish and

aquatic organisms. This minimal intrusion will also not alter the natural fluvial

geomorphology process of the river (sediment and debris transport). A Vermont

ANR Water Quality Division Stream Alteration Permit is not required. A federal

permit from the U.S. Army Corps of Engineers (USACE) under Section 404 of

the Clean Water Act will be a requirement for the intake structure and water

withdrawal, for which pre-application coordination with the USACE has been


Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 9 of 10

Therefore, the project will have no undue adverse impact to onsite or downstream

stream channels, a conclusion which is supported in part by the testimonies of Mr.

Perry and Mr. Boedtker.

QlO Will the Project comply with the rules regarding significant (Class I or II)


AlO Yes. As presented in Exhibit AC-2, there are no areas within or adjacent to the

project site that are subject to the Vermont Wetland Rules as Class I or Class II

wetlands or associated buffers. Therefore, the Water Resources Board rules

regarding significant wetlands do not apply to the project.

As also presented in Exhibit AC-2, there is a wetland within the project site that is

subject to USACE (federal) jurisdiction associated with one man-made pond, but

is not included under Vermont (state) jurisdiction. The project will require the

filling of this man-made pond, which will result in approximately 2.6 acres of

impact requiring permit authorization from the USACE pursuant to Section 404

of the Clean Water Act. Due to the minimal functions provided by this man-

induced wetland and the mitigative measures expected as part of the Section 404

permit, it is my opinion that there will not be any adverse effect from the project

to those wetlands that are not under Vermont jurisdiction.

Q1 1 Will the Project destroy, or significantly imperil necessary wildlife habitat or any

endangered species?

All No. As presented in Exhibit AC-2 at Page 5, there are no known threatened or

endangered species at the project site, nor is there any necessary wildlife habitat.

Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of Adam Crary
October 25, 2010
Page 10 of 10

Q12 Will the Project have an undue adverse effect on any rare and irreplaceable

natural areas (RINA)?

A12 No. As presented in Exhibit AC-2 at Page 5 there are no natural communities that

have been identified within or proximal to the project site that are considered

significant by the Vermont Natural Heritage Information Program (NHIP).

Corroborative field assessments conducted by VHB confirmed the absence of

significant or uncommon natural communities. As such, the project will not

affect any state-designated Natural Area, Significant Natural Community, or

Natural Heritage Program Fragile Area that may be considered RINA.

3, Initial Project Work for 2010 and 2011

Q13 With respect to the criteria that you have testified about, will the initial phase of

work proposed for 2010 and 2011 affect the Streams, Wetlands, Rare and

Irreplaceable Natural Areas, and Necessary Wildlife Habitat and Endangered


A13 No. The initial phases of work will not involve any work within or adjacent to

streams, Class I or II wetland (or wetlands not under Vermont jurisdiction),

RINA, or necessary wildlife habitat or threatened or endangered species. As a

subset of the overall project and following the conclusions drawn in my testimony

above, the initial phases of work will not have any impact to these criteria.

4. Conclusion

Q14. Does this conclude your testimony?

A14. Yes.


Petition of Beaver Wood Energy Pownal, LLC

for a Certificate of Public Good, pursuant to 30 )
V.S.A. § 248, to install and operate a Biomass )
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old cket No
Green Mountain Racetrack in Pownal, Vermont, )
to be known as the “Pownal Biomass Project” )


Exhibit BWEP - AC -1

Adam R. Crary, PWS,
Senior Wetland Scientist

Mr. Crary is an experienced and skilled praCtitioner of wetland science, policy, botany,
and general ecological assessments. Since joining Vt-ID in 2009, Mr. Crary has applied Crary has worked as a state
these skills in technical and/or managerial roles for the following example projects:
park maintenance technician.
Mount Snow Ski Resort Expansion, Dover, VT a federal park ranger, a
In support of Mount Snow’s master planning efforts, Mr. Crary has served as the senior
wetland field ecologist in conduct of detailed and preliminary wetland delineation research assistant, a stream
efforts over several large developed and undeveloped land parcels owned by the resort, ecologist, a wetland ecologist.
Delineation efforts support planning under Vermont Act 250 and the state Wetland
Rules, as well as USACE 404 permitting. a botanist, and a project
manager. He has performed
Due Diligence Assessment Lot 15 Giroux Property, Hinesbwg, V’
In support of VI-IB Pioneer’s client’s purchase interest, Mr. Crary served as the project ecological services in 12
wetland scientist responsible for delineating wetland area on-site to facilitate project States and one U.S. territory
planning under Vermont Act 250 and the state Wetland Rules, as well as USACE 404
permitting. on both large- and small-scale
public and private projects. Mv.
Commonwealth Yogurt, Brattleboro, VT
Mr. Crary recently led a field crew conducting the third wetland delineation on the Crary has worked on rural and
property since 1998, the results of which were approved by the USACE and also urban sites acres, mum-state
resulted in a decrease in jurisdictional wetland area from previous studies. The project
development site has a complicated USACE 404 and Vermont Act 250 permitting lir- utility projects, as well
history, and Mr. Crary will serve as VHB Pioneer’s permitting specialist and regulatory as county-wide stream
liason for the project during acquisition of a Vermont General Permit from the USACE.
This development project is intended to incorporate sustainable and LEED practices assessment initiatives. At
with a goal of bringing dairy-focused industry to southeastern Vermont. VHB, Mr. Crary is responsible
Cape Cod National Seashore, Cape Cod, MA for managing or providing
In support of VHB’s Watertown, MA and Williamsburg, VA offices working for the oversight on projects focused
National Park Service, Mr. Crary compiled collected field data and offsite information to
complete a wetland function and value analysis of six wetlands located within the Route on ecological resource
6 roadway improvement study area, Utilizing the USACE Highway Methodology, inventory or involving lederal
wetland assessments were completed for estuarine, interdunal swale, and peatland
systems. or state environmental
permitting, as well as
Prior to joining VHB, Mr. Czar/s projects included the following:
managing wetland and
Cflesterfield Power Station, Chesterfield County, VA ecological services and
Prior to VFJB, in support of the 404/401 Individual Permit application, served as the
lead ecologist and task manager for the field assessments and Sections 404/401 technical staff.
regulatory coordination involved with this 250+ acre proposed ash monofill. The project
site is situated in the upper Coastal Plain and is subject to several environmental and
regulatory constraints, including tidal and non-tidal wetlands and streams, Chesapeake 12 years, professional
Bay Preservation Areas, rare flora and fauna, and several historical sites. To determine experience
wetland and stream constraints, the wetland delineation was performed for the facility
site as well as an access road corridor according to determine all areas subject to USACE
or VIJEQ jurisdiction. Perennial streams as well as tidal and non-tidal wetland were
assessed to determine the landward extent of the mandatory RPA according to the
Chesapeake Bay Preservation Act. Complete site surveys for several rare seepage or
powerline flora, as well as rare molluscan fauna were completed. Regulatory work

Adam R. Crary, PWS,
Confinued. p. 2

included alternatives analysis, compensatory mitigation feasibility and conceptual plan

development, historical resource coordination and mitigation, and Joint Permit

Copper Ridge Landfill, McDowell County, WV

Prior to VHB, for this new landfill in the coal mining region of West Virginia, served as
task manager/lead ecologist responsible for annual monitoring and corrective measures
for a stream enhancement project required as compensatory mitigation under a USACE
404 Individual Permit. Annual monitoring activities included in-stream structure
evaluations, stream habitat assessments, lab and in-situ water quality measurements,
riparian vegetation assessments, invasive species monitoring, and benthic
macroinvertebrate monitoring. Corrective and maintenance measures recommended per
annual monitoring results were designed and WVDNR and county permits were
acquired to complete in-stream work. Other responsibilities include working with the
client regulatory agencies, and the previous consultant to ensure 404 permit compliance
within a complicated management, land ownership, and permitting history.

Brink Mine Site; Greensville County, VA

Prior to VHB, for this new surface mining site (titanium sands), served as task
manager/lead ecologist responsible for completion of a compensatory mitigation plan,
conducting botanical surveys for two rare species, oversight of stream visual
monitoring, and collecting baseline wetland vegetation data for secondary wetland
impact (dewatering) monitoring. The final compensatory mitigation plan for impacts to
over 6-acres of wetlands and 225’ of stream channel was completed and approved by
the USACE and the VDEQ. Led a 3-member field crew in conduct of detailed surveys
for the state rare Rypericum setosum and Sc/erie minor no individuals were found

during the study and USACE sign-off was received. Prior to mine field development,
collected detailed botanical data by strata from a plot-based sampling design to support
secondary wetland dewatering impact monitoring.

Mayo CCP Monofill; Person County. NC

Prior to VHB, tasked with reviewing a previous wetland delineation and finalizing the
study on the 61-acre study area and obtaining jurisdictional determination for the
USACE (Wilmington District) and the NCDWQ. Tasks involved with this submittal
included verification/review of the previous delineation, additional delineation areas,
USACE Rapanos Jurisdictional Determination Form completion, and conducting the
following assessments: NCDWQ Stream Determination, USACE Stream Quality, and
NCDWQ Wetland Value Rating. The successful Jurisdictional Determination resulted in
a significant decrease in Waters of the U.S. and NC State Waters within the proposed
footprint from an original delineation, resulting in no impacts to Phase I of the original

VaDMA Fort Pickett Dinwiddie, Nolloway, Brunswick County, VA

Prior to VHB, sewed as a field crew leader tasked with supervising and conducting field
verification and mapping of all wetland, stream, or other aquatic resources within the
approximately 43,000-acre military facility. All accessible regions of the base were
walked and resources mapped through a combination of field mapping and GPS data
collection. Additionally, all wetland resources were mapped according to cover type
and representative photographs collected. In areas not accessible due to facility
Adam R. Crary, PWS,
Continued, p. 3

operations/safety precautions, a combination of aerial photograph interpretation and

ground-truthing was conducted. Fieldwork occurred over a period of three field seasons
resulting in a CIS-based deliverable. An additional component was the completion of a
wetland floristic inventory focused on rare plant and Virginia county record findings.
Upon completion of this floristic survey, 354 vascular plant species and 47 Virginia
County Records were identified and/or collected.

Wilton on the James; Henrico County, VA

Prior to VT-lu, served as the project task manager and lead ecologist for all ecology-tasks
in support of an Individual Permit application for this approximately 1300-acre private
multi-use development project. For the wetland delineation, Routine and
Comprehensive Determination Methods, as outlined in the 1987 Corps Manual, were
used to flag and map all areas subject to USACE or VDEQ jurisdiction on the project
development site and seven component study areas. Following submittal to the USACE,
all wetland delineations were confirmed. Additional responsibilities included RPA and
Henrico County SPA determinations; onsite wetland and stream mitigation feasibility
analysis; wetland functional assessment; rare flora and fauna surveys/agency
coordinatiory USFWS Section 7 (informal) consultation; endangered plant species
management plan, VDGIF bald eagle, anadromous fish, and colonial water bird
consultation; regulatory permitting support; and agency, client, surveyor, and engineer

SMR Camp Pendletoil; City of Virginia Beach, VA

Prior to VHB, served as the project lead field ecologist tasked with conducting the
detailed wetland delineation on this approximately 230-acre state military reservation.
Fieldwork was conducted according to the Routine Determination Method outlined in
the 1987 Corps Manual. Tasks associated with this project were related to satisfying
military environmental management requirements. Additional responsibilities included
natural community mapping. floristic surveys, wetland functional analysis, soil and
hydrology descriptions, and authoring environmental inventory components of the final
Integrated Natural Resources Management Plan (INRMP).

Physical, Habitat, and Perennial Stream Assessments; Fairfax County, VA

Prior to VT-TB, served as a stream ecologist crew leader on two separate initiatives to
assess stream resources throughout Fairfax County. Stream physical attributes and
habitat conditions were assessed using methodologies adopted by Fairfax County in
order to catalogue degraded stream condition and/or identif stream restoration
opportunities. Perennial stream determinations for the purpose of RPA establishment
were completed using the Fairfax County Perennial Stream Field Identification Protocol.
The results of all three assessments were utilized for stream management priorities by
Fairfax County Public Works. Other responsibilities under these projects included data
management, staff training, and coordination with Fairfax County and the lead

Branch Greek; Chesterfield County, VA

Prior to VHB, served as the project manager and lead ecologist for this 50-acre private
development project. The Perennial Stream Field Identification Protocol was utilized as
part of a 3rd-party review to determine perennial stream origin within the project site
following two previous assessments of differing results. This task included a detailed

Adam R. Crary, PWS,
Continued, p. 4

technical report of findings and a formal presentation to the Chesterfield County Office
of Water Quality. As a result of county-coordination and discussion, county perennial
stream determination procedures have evolved. Other responsibilities included wetland
delineation, RPA determination, regulatory support, and coordination with the USACE,
DCBLA, county staff, client, engineer, surveyor, and attorney.

Cabrita Point; St. Thomas, USVI

Prior to VHB, per U.S. Virgin Island regulation, an Environmental Resource Inventory
was needed for this proposed resort near Red Hook, St. Thomas. As a botanist and lead
Ecologist for this project, work entailed detailed surveys and literature reviews
addressing wetland, coastal mangroves, geology, soils, vegetation, and wildlife
resources on the proposed 13-acre site. A detailed wetland delineation was completed
according the 1987 Corps Manual. All mangrove species present were identified and
mapped. Geological and soil characteristics of the site were evaluated through available
literature. A complete natural community mapping and floristic survey effort was
completed. Terrestrial wildlife surveys were completed and supplemented by the
available literature. The final EM compiled the methods and results of all surveys in one
comprehensive report.

Education! Education:
85, Natural Resources (Natural History and Ecology), University
r IflIfl9
of Maine, Orono, ME, 2000
Professional Training:
Applied Fluvial Geornorphology WildIand Hydrology,
Shepherdstown, WV, April 2009
OSHA 10-HR Construction Safety, Richmond, VA, February 2008
Emerg. Medical Response and Bloodhorne Pathogen Training,
Richmond, VA, March 2008
Fire Safety ann’ Extinguisher Use, Richmond, VA, March 2008
Wetland Deliheat/on and Management. RCET, Charlotte, NC,
October 2005
Field Botany and Florist/cs, Humboldt Field Research Institute,
Steuben, ME, June 2004
Perennial Stream Origin Identification for Appilcation of the CBPA
Designation and Management Regulations in Virginia, NC State
Dept. of Forestry, Richmond, VA, Jtme 2004
Advanced Hydric Soils, VJMS, Gloucester, VA, October2003
Fairfax County Perennial Stream Field Identification Protocol,
Fairfax, VA, May 2003
Prince William Co. and Fairfax Co., VA Physical Stream
Assessments, Sept. & Oct. 2003
Adam R. Crary, PWS,
Continued, p. 5

Wetland Functional Assessment Methodology Environmental

Concern, MD, September 2002
Lent/c Proper Functioning Condition Methods — NRCS/1JSFWS,
CoeurdAjene, ID, 2000
USA CE Highway Methodology Wetland Assessments, USACE, N.
Sphngfield, VT, June 1999
Interpretive Training Institute, AMC Pinicham Notch Visitor Center,
Gorham, NH, June 1998-99

Professional Professional Wetland Scientist (#1691), Society of Wetland

Registrationsl Scientists Professional Certification Program, Inc.
Virginia Certified Professional Weand Delineator (#3402
000087), Virginia Dept. of Professional and Occupational
Approved Rare Plant Surveyor Small Whoiled Pogonia, Swamp

Pink, Harperella, Sensitive Joint-vetch, Smooth Coneflower,

Round-leaf Birch, Virginia Spiraea, and all ‘Plants of Virginia”,
U.S. Fish and Wildlife Service—Virginia Field Office
Chesterfield County, VA Approved Wetiand Professional
Wilderness FIrst Responder

Affiliationsl Society of Wetland Scientists (2001 present)


Virginia Association of Wetland Professionals (2001 present)

Southern Appalachian Botanical Society (2004 present)


Virginia Natural History Society (2004 present)


American Institute of Biological Sciences (2008 present)


Alpha Zeta and Golden Key National Honor Societies (1999-


Example Technical Technical or Scientific Writing Examples:

Writing and
Crary, AR. 2009. Compensatory Wetland and Stream Mitigation
Plan Bwnswick Solid Waste Facility. Contracted Report under

Colder #0739607509. Golder Associates Inc. (prepared for BFI

Crary, A.R. 2008 (Rev. 2009). Rare and Sensitive Species Survey
Report Chesterfield Power Station. Contracted Report under

Colder #0736607. Golder Associates Inc. (prepared for

Crary, AR.. M.G. Williams. 2008. Post-Construction Stream
Relocation Baseline Monitoring Report —623 Landfill. Contracted

Adam R. Crary, PWS,
Continued, p. 6

Technical Report under Colder #043677708. Colder Associates

Inc. (prepared for Republic Services, Inc.).
Crary, AR. 2007. Swamp Pink Conservation and Management.
Wilton on the James. Contracted Technkal Report under WEG
#2112. Williamsburg Environmental Group, Inc. (prepared for
HHHunt, Inc.).
Crary, AR. 2007. Rare and Sensitive Species Report Wilton on

the James. Contracted Technical Report under WEG #2112.

Williamsburg Environmental Group, Inc. (prepared for HhHunt,
Crary, A.R. 2006. Baseline Vegetation Community Investigation.
Contracted Technical Report under WEG #1759. Williamsburg
Environmental Group, Inc. (prepared for Greeley and Hansen).
Crary, AR. 2005. Barking Treefrog (Hyla gratiosa) in Virginia.
Intemal review. Williamsburg Environmental Group, Inc. 0.
DeBerry, and B. Helrnandollar reviewers. 3pp.
Crary, AR. 2005. Environmental Resource Inventory, Cabrita
Pofrit, St. Thomas, USVI. Contracted Technical Report under
WEG #2372. Williamsburg Environmental Group, Inc. (prepared
for Springline Architects). 22pp.
Crary, AR. 2004. Determination of Section 404 Jurisdictional
Areas Using the Atypical Situations Procedure: Nunrially Property,
Chesterfield County, Virginia. Contracted Technical Report under
WEG #2042. Williamsburg Environmental Group, Inc. (prepared
for E.W. Nunnalty, Jr.). l6pp. (plus appendices).
DeBerry, D.A., A. R. Crary (contributing author). 2004. Integrated
Natural Resources Management Plan: SMR Camp Pendleton.
Contracted Report. Williamsburg Environmental Group, Inc.
(prepared for Virginia Dept. of Military Affairs).
Crary, A.R. 2004. Charter Colony Lakes (LTC-30 and LTC-20-25)
WET II Functional Evaiuation. Contracted Technical Report under
WEG #1472D. Williamsburg Environmental Group, Inc. (prepared
for Chesterlield County, Virginia).
Example Oral Reports or Presentations:
Invasiveness of Phiagmites mistral/s.” May 2000. Senior
Research Paper Presentation. University of Maine — Natural
Resources Program.
7he Effects of Dam Removal.” May 2000, Poster Presentation.
University of Maine. Soil and Water Quality (PSE 344).
Hydric Soil: Using Field Indicators.” 8 January 2004.
Williamsburg Environmental Group Annual Ewlogy Seminar.
Richmond, Virginia.

Adam R. Crary, PWS,
Connued, p. 7

“Wetland flelineation. October 2006. ToIl Brothers, Inc. Loudoun

County, Virginia.
“Branch Creek Perennial Stream Determinaon. 6 March 2007.
Chestetfield County Office ofWaterQuaty. Chestet, Vhginia.
“Buena Vista Wetland Functional Analysis.” 25 April 2007.
Virginia Mitigation Bank Review Team. Richmond, Virginia.
“Small Whorled Pogonia in Virginia.” 27 A4xi 2007. 2007
Williamsburg Environmental Group Annual Ecology Seminar.
Richmond, Virginia.
“Compensatory Stream Mitigation.” 17 March 2008. Golder
Associates In-House Presentation. Richmond, Virginia.
“Basic GPS Field Use Trimble GeoXT.” 12 June 2008. Golder

Associates Training Presentation. Richmond, Virginia



Petition of Beaver Wood Energy Pownai, LLC

for a Certificate of Public Good, pursuant to 30
V.S.A. § 248, to install and operate a Biomass
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old Docket N
Green Mountain Racetrack in Pownal, Vermont,
to be known as the “Pownal Biomass Project”


Exhibit BWEP - AC -2

Memorandum: Wetland, Stream, and other

Natural Resources Summary
Land Development

7056 US Route 7
Post Office Box 120
North Ferrisburgh, VT 05473
Vanasse Hangen Brustlin, Inc. Telephone 802.425.7788
Fax 802.425.7799

Memorandum To: Beaver Wood Energy Project File Date: October 21,2010

Project No.: 57407.00

From: Ryan Scott, Adam Crary Re: Wetland, Stream, and Other Natural
Resources Summary

At the request of Beaver Wood Energy, LLC (the Client), Vanasse Hangen Brusthn, Inc.
formerly VHB Pioneer (VHBP), conducted wetland and stream delineations at the former
Mountain Race Track in Pownal, Vermont, as part of a proposed biomass energy project
Attachment, page 1, Site Location Map). The Study Area includes an approximate 90
-acre portion of
the former race track situated along the eastern bank of the Hoosic River. The intent of
the wetland
and stream delineation is to provide an inventory of regulated resources under the Vermo
nt Wetland
Rules and Section 404 of the clean Water Act. The presence/absence of regulated resources
associated buffers will be an aid in overall site design and regulatory review/permi
tting for the
planned project. Also included with this memorandum are the results of stream
riparian buffer
assessments, database-level reviews for other natural resource criteria, particularly significant
communities, rare, threatened, and endangered (RTE) species, and necessary wildlif
e habitat, each as
defined by Act 250 (and subsequently, 30 V.S.A. Section 248) criterion. A description
of the study area,
methods used, and findings are presented below and in the Attachment to this document.

The Study Area is located in Pownal, Vermont and is situated between the Hoosic River
and Route 7.
In the past, the site supported a dairy farm before opening as a racetrack in 1962. The
entire site is
paved except for the racetrack and two man-made ponds located within the racetra
ck. The site now
consists of grass that grew over the pavement, the racetrack grandstands, and various
associated with its past operations. There is a vegetated buffer between the paved area
of the site and
the Hoosic River. The site is bound to the north by Ladd Brook (a tributary to the Hoosic
railroad tracks to the east, unleased property associated with the racetrack to the south,
and the Hoosic
River to the west.

The project site occurs in the Southern Green Mountains biophysical region of VermonV
within the
Hudson Hoosic Watershed (HUC: 02020003). According to the Natural Resource

Service (NRCS) Web Soil Survey for Bennington County

, the entire site is underlain by
Udipsamments and Udorthents, gently sloping.

‘Thompson, E,H., and E. Sorenson. 2005 Wetland, Woodland, Widland, A Gtide

to the Nahsral Cmnmunities of Vermont. veont
Depaibnent of Fish and Wildlife and the Nature Conservancy.
Natj,ral Resource Conservation Service. 2010. Bennington County Soil Survey.
Accessed online at:
http:/ /

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biornassnr menoJo-ZFIO.docx
Beaver Wood Energy, LLC Project File
Pownal, VT
Wetland, Stream, and Other Natural Resources Summary
Page 2
October 21,2010



Vi-IB Environmental Scientists Chelsea Martin and Ryan Scott conducted the wetland and stream
delineations on June 22, 2010 and August12, 2010. The team performed the delineations in accordance
with methodologies outlined in the U.S. Army Corps of Engineers (USACE) regional wetland
delineation supplement
. The regional supplement requires the presence of three parameters to
establish the occurrence of wetland resources: hydric soils, hydrophytic vegetation, and wetland
hydrology. Under normal circumstances, all three parameters must be met for an area to qualify
as a
wetland resource under the method. Wetlands are flagged using pink”wetland delineation” survey
tape and labeled to include wetland ID and flag number (e.g., VHBP-2010-A1-1). Information
pertaining to vegetation, soil type, and hydrologic characteristics are recorded in the field to be
incorporated into USACE data forms as well as function and value forms for each wetland resource.

Stream determinations and ordinary high water (OHW) width is determined in the field from
guidance provided in the USACE “Regulatory Guidance Letter: Subject- Ordinary High Water
Identification.” Streams are typically flagged according to the Agency of Natural Resources
Riparian Buffer Cuidanc&. OHW width measurements are taken at regular intervals while flagging
along the length of a stream within the investigation area. Flow regimes are preliminarily classified
ephemeral, intermittent, or perennial and are determined based on qualitative observations
of in-
stream hydrology indicators at the time of delineation, as well as geomorphic characteristics.
are flagged using orange survey tape and labeled according to the type of survey (“SC” for stream
center and “TB” for top of bank) and include the stream ID and flag number (e.g., VHBP 2010-501-1).

Wetland and steam delineation flags were located by VHB in the field using a Trimble® GPS unit
capable of sub-meter accuracy. Data are post-processed using Trimble® Pathfinder software for
enhanced accuracy. Wetland data are collected according to the USACE regional supplement
procedure, and stream data pertaining to stream bed and bank condition, substrate, and flow
characteristics are recorded in the field.


VHB delineated two wetland/pond features and two watercourses within the Study Area. The
location and extent of each feature is shown on the Wetland and Stream Delineation Map (see
Attachment, page 2). The wetland/pond and streams are described generally below, as well as
in the
summary spreadsheets (see Attachment, pages 3 and 4). USACE Wetland Delineation forms further
describe vegetation, soils, and hydrologic characteristics for wetlands (see Attachment, page 5-7)
as do
the function and value Ionns provided in the Attachment (page 8). Representative photographs of
site as well as wetland and stream resources are provided (see Attachment, pages 9-13).

VHB environmental scientists delineated two wetland features in the Study Area (wetlands 2010-1
2010-2). Both features axe excavated features constructed as treatment and aesthetic amenity ponds
within upland areas during construction of the Green Mountain Race Track in the early 1960’s

$ (usAcs) US. Army Corps of Engineers. 2009. Intetin,

Regional Supplement of the Corps of Engineers Wetland Delineation
Manual: Northeast and North Central Region.
4 (USACE)U.S.Army Corps of Engineers.
2005. “Regulatory Guidance Letter. Subject: Ordinary High Water Mark
Identification.” No, 05-05. Accessed online at:
(ANR) Vermont Agency of Natural Resources. 2005. Riparian Buffer Guidance. Accessed online:,.

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Beaver Wood Energy, LLC Prqect File
Pownal, VT
Wetland, Steam, and Other Natural Resources Summary
Page 3
October21, 2010

further discussion below). Feature 2010-1 is located within the northern loop of the former track
and is
now characterized as a palustrine emergent wetland (PEM)
6 (see Attachment, page 11, Photograph 5).
Feature 2010-1 is inundated for a portion of the year and is vegetated with a narrow leaf cattail (Typhq
angustlfoiñl) monoculture. Soils within the wetland are hydric but have physical characteristics
consistent with surrounding upland soils at corresponding elevations.

Feature 2010-2 is also a man-made pond located inside the math ioop of the race track, and is
than feature 2010-I. The feature consists primarily of open water (POW), with a PEM fringe
Attachment, page 11, Photograph 6). Vegetation within the PEM fringe generally consists of
leaf cattail, common reed (Phrag,nites aus trails), jeweiweed (Impati ens capensis), reed canary grass
(Phalaris arundinacea), and willows (Salix sp.). The pond receives hydrology from stormwater
runoff on
the property that is directed into the pond via pipes.

Field efforts identified two water courses within/directly adjacent to the Study Area. Feature
consists of the east bank of the Hoosic Rivet Stream top-of-bank (rOB) and ordinary high water
(01-lW) was delineated along the eastern bank of this feature. The river flows north along the western
side of the Study Area and has steep banks that are well vegetated between the OHW and the
bank (see Attachment, page 9, Photographs 1,2). Undercutting was observed along portions
of the
bank generally located in areas on the outside bend of the channel. Within the project site, a
buffer exists between the top-of-bank flagging and the existing race track development, and
it is
estimated that this buffer ranges from less than 5-feet to 50-feet with an average of approximately
feet (see Attachment, Page 13, Photograph 9).

Feature 2010-TB2 is located at the northern extent of the Study Area and consists of a segment of
Brook. It is characterized as a smaller stream with steep banks. The stream begins at the eastern
property boundary and flows north into two 48-inch corrugated metal pipes before flowing
towards the confluence with the Hoosic River (2010-TB4) (see Attachment, page 10, Photographs
It is noteworthy that based on reviews of previous topographic and aerial imagery mapping
(described below and also included in the Attachment), this segment of Ladd Brook appears
to have
been re-located to follow the northern property boundary as part of the site racetrack/parking
development in the early 1960’s. Currently, trash and debris occurs within the channel and
riparian species, such as Polygonum cuspidatum, are prevalent in the riparian buffer. An existing
forested buffer exists between the stream top-of-bank and the former parking lot, and is estimated
average approximately 30-feet in width.


Based on current site conditions, information gathered through the Bennington County Soil Survey,
historic aerials, and conversations with the Energy Park Director, the artificial pond features
excavated from uplands. The Bennington County Soil Survey (2010) shows the site to be currently
underlain by Upsidamments and Udorthents, gently sloping (description included on Page 15
of the
Attachment). This series is characterized by areas where original soils have been removed or
with fill material. To determine the on-site soils before the site was developed and the soils
disturbed, VHB identified areas in the general vicinity of the project site that shared characteristics
with relation to site topography, proximity to the Hoosic River, and similar historic land use
Two sites, located approximately one mile and one and a half miles upstream of the Project
site, were
selected for its shared characteristics (see Attachment, page 14). Based on the most current soil

6 Cowardin, LM., V. Carter P.C. Golet, and E.T. LaRoe.1979. Classitcation o Wetlands and Deepwater
Habitat in the United
States. U.S. Fish and Wildlife Service. FWS/OBD-79J31 lO

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Beaver Wood Energy, LLC Foject Pile
Powna], VT
Wetland, Stream, and Other Natural Resources Summary
Page 4
October 21,2010

for Bennington County, the Occum soil series dominates the comparable parcel which consists
of very
deep, well drained loamy soils formed in alluvial sediments. This series is not considered a
]iydric soil
series and appears to accurately represent the site. The Occum series is measured to a depth
of 65
inches and is a fine sandy loam for the first 36 inches underlain by a loamy fine sand. Though
frequently floods, it is for brief durations as permeability is moderate to moderately rapid
in the solum
and rapid or very rapid in the substratum. Depth to seasonal high water table in this series generally
between 4 and 6 feet (see Attachment, page 16, Vermont Soil Fad Sheet Occum Series). -

The data gathered from the soil survey are confirmed by monitoring wells throughout the site,
further soil investigations within feature 2010—i. Monitoring well data indicates that groundwater
is at
its highest during the spring months located approximately seven feet below the natural ground
surface. During the summer months, groundwater is located approximately ten feet below
the natural
ground surface suggesting that the water table is not high enough to support hydric soils, or
hydrophytes in the areas surrounding the excavated ponds (evidence the ponds were excavated

Historic aerials from 1942 arid 1962 (see Attachment, pages 17,18) show the area as a dairy
farm, and
just before construction of the race track, respectively (staging areas are visible in the 1962
Wetland signatures at the locations of the current delineated features are not evident in either
of the
historic aerials, further indicating that the pond features were excavated from uplands. Additionally
the 1954 USGS topographic map shown on the Site Location Map (see Attachment, page 1), shows
Feature 2010-1 excavated from an elevation of approximately 540-feet above-mean-sea-level
which is
an elevation two feet above the high ground water table observed through soil borings and
well data.

Both features are known to function as stormwater basins through the presence of infrastructure
connecting the two ponds as well as connecting the larger pond (2010-2) with various catch
basins and
drains throughout the site. Both features still function as stormwater receivers for the site
and exist for
the purpose of retaining collected watet It is also known through interview of former employees
the depressions doubled as ornamental ponds during the operation of the race track and were
once part of a treatment system for the runoff from the racehorse stables that are no longer


The Vermont Agency of Natural Resources, Department of Environmental Conservation (ANR-DEC)

administers the Vermont Wetland Rules (VWR), which require a permit prior to activities
Class I or Class II wetlands, or their buffers, if the activities are not allowed uses or 7
exempted The
two wetlands on site are currently mapped on the Vermont Significant Wetlands Inventory
Through field investigations, interpretation of historic maps and aerial photography, VHB has
proposed that features 2010-1 and 2010-2 should not be regulated under the VWR. According
to the
VWR, Section 3.1.b.(1 and 6), “The following shall not be regulated as wetlands under the Vermont
Rules, but may be subject to regulation underfederal law: Stor-mwater conveyance, treatment, and/or control
systems” and “other similar ponds constructed in uplands.” Both features 2010-1 and 2010-2 are
constructed in uplands for the purpose of holding and treating stormwater runoff from surrounding
impervious areas and for aesthetics. Through conversations on September 8, 2010 and subsequent
September 30, 2010 electronic mail correspondence with Alan Quackenbush of the Vermont
DEC, it

Agency of Natural Resources Water Rources Panel. August 1,2010. Vermont Wetland Rules: Vt CodeR.
7 —

Accessed online at Jidp:J /

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Beaver Wood Energy, LLC Project File
Powrial, VT
Wetland, Stream. and Other Natural Resources Summary
Page 5
October 21,2010

has been confirmed that neither delineated feature 2910-1 or 2020-2 would be subject to regulation
under the VWRs or otherwise considered waters of the State (electronic mail correspondence
on pages 19-20 of the Attachment).



USACE regulates placement of fill material into navigable waterways and their tributaries,
adjacent wetlands, under Section 404 of the Clean Water Act (CWA). Among other conditions,
General Permit authorization is required for cumulative wetland or stream impacts greater
3,000 square feet, and an individual permit for impacts greater than one acre

Both wetland features on the property consist of artificial ponds excavated from uplands for
original purpose of stormwater retention and aesthetics. Under normal circumstances, both features
should be non-jurisdictional under Section 404 of the CWA. A site visit with Marty Abair of
USACE on August 20, 2010 confirmed that feature 2010-2 is not jurisdictional as it is an open
feature, excavated from uplands for the purposes of stormwater management and aesthetics
continues to provide these functions. From follow-up coordination with the USACE, feature 2010-1
would be jurisdictional under the CWA. Though it was excavated at the same time as feature
and for the same purposes, its current vegetated condition, presence of hydric soils, and lack of
defined inundation periods, have resulted in new normal wetland condition, This feature is
jurisdictional under Section 404 of the CWA and will require a permit for any fill placed within its
delineated boundaries.


Following VHB’s wetland and stream field delineation and flagging, stream riparian buffers
assessed in accordance with Section llI.B.3 of the Vermont ANR’s December 9, 2005 Guidance for
Agency Act 250 and Section 248 Comments Regarding Riparian Buffers (Guidance). Resultantly,
measured from the stream top-of-bank flagging, a 50-foot design buffer has been installed from 2010-
TB-i (Hoosic River) and a 25-foot design buffer has been installed in the plans for 2010-TB-2 (Ladd
Brook). Each buffer, overlaid with the design plans
, is depicted on the Stream Buffer Map, included
as Page 21 of the Attachment. Such buffer assessments take into consideration the riparian functions
and values as presented in Appendix A of the Guidance as well as the modifications! disturbance that
exist from previous site development and other existing degraded condition within these proposed



In order to identify the potential occurrence of rare or sensitive species, particularly those that are
federally- or Vermont-listed threatened or endangered’°, VHB researched the NHIP database
for the
presence of known element occurrences (FOs) of rare, threatened, endangered, or significant natural
community types within arid adjacent to the study area. A one-mile radius surrounding the study
area was used when querying the NUB’ database. Also included in this review was the Vermont
2008 Deer Wintering Areas mapping.

Department of the Array General Permit State of Vermont. General Permit No. NAE-2007-24.
D esign plans from Bruno Associates as received electronically by VHS on 10/20/10.
10 Federal-listed species are protected
under the U.S. Endangered Species Act and Vermont-listed species are protected
IOV.S.A. §123.

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Beaver Wood Etergy, LLC Project File
Powna], VT
Wetland, Stream, and Other Natural Resources Summary
October 21, 2010

Through review of the NHII’ database, one rare or sensitive species was identified that is known
occur within the one-mile radius of the Study Area, but there are no known species or significant
natural community EOs within or adjacent to the Project site. This EO is a plant considered
rare in
Vermont (S2), but is not afforded protection under Vermont Endangered Species Law. There
is a
mapped deer wintering area within the one-mile radius that is located within intact forestland
to the
west of the Project site, but is separated from the Project site by development roadways, agricultural
land, and the Hoosic River. The Rare Species and Wildlife Habitat Review Map is provided on
Page 22
of the Attachment, and details the map results of these database queries.

Based on the results of this database review, no species or community-specific surveys were
for any unknown threatened or endangered species or significant natural community types.
field investigations and data collection efforts as part of VHS’s wetland and waters delineation, site
conditions were found to be highly modified from natural undisturbed (or disturbed) condition
the likelihood that there are suitable habitats onsite for any protected species is minimal. There
are no
onsite habitat conditions that would be conducive to providing necessary wildlife habitat for
tailed deer or moose wintering or Hack bear (foraging or travel). These findings are similar to
included in the State of Vermont Public Service Board’s (P55) findings as part of Docket No.
7618 (2.2-
MW Solar Generation Facility at the Southern Vermont Energy Park).

• Site Location Map
• Wetland and Stream Delineation Map
• Summary of 2010 Delineated Wetlands and Summary of 2010 Delineated Streams
summary tables)
• USACE Wetland Determination Data Form
• USACE Wetland Function-Value Evaluation Form
• Site Photographs Wetland/Stream Delineation

• Soil Comparisons Locations (map)

• Vermont Soil Fact Sheet, 275 Udipsaminents and Udorthents
• Vermont Soil Fad Sheet, 29A Occum
• Aerial Jmagery 1942 —

• Aerial Imagery 1962 —

• 9/30/ 10 Electronic Mail Correspondence from Alan Quackenbush, Subject: Re: Pownal
Racetrack Beaver Wood Energy Project

• Stream Buffer Map

• Rare Species and Wildlife Habitat Review Map

\\vtdfl\prqjtcts\57407.OObeaverwood pownaI\docs\nemos\w merno\pownal bionjass

nr memojO-21IO.docx
Beaver Wood Energy Pownal, LLC
Sources: Background lopo Poima), North PownaL

Pownal Biomass Site Berlin, and North Adams Qiads from USGS (1954);
Roads and Property Parcels from VCGI (2005).
Legend Pownal, Vermont
Site Location Map
VHBP Investigathon Area
VT Class )&1I Roads August 18, 2010

70 US
ERt IZoult /F3 Ru :0
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Beaver Wood, LLC - Pownal, VT
Summary of 2010 Deflneated Wetlands
Vanasse Hangen Brustlin, Inc.
October20, 2010

Tatal USAGE 2010 VWR

Classification USACE Data Principal
Wetland ID 1
Delineated Areaj Jurisdiction Cowardin
and Vermont Form Functions and Descriptions and Notes
(Sq. It) i (YesINo) Complete? 2
Classificatio n
Jurisdiction 2

Man made depression originally consti-ucted as part of the Green Mountain Raceway in the
2010-1 early
¶14.420 Yes MiD Y PElt’ I 960’s to handle stormwater runoff and for aesthetic purposes. tJSACE jucisdictional feature
FF under
‘new normal circumstance’. Determined by the ANR-DEC to be non-jurisdictional under the VT
Wetland Rules or as a waters of the State, Typha angustifohia monocutture with s[wub fringe.

Man made depression originally constructed as part of the Green Mountain Raceway in the early
2010-2 390,844 No NJD N POW/PEM FF
1960’s to handle stormwatem runoff and for aesthetic purposes. USAGE non-jurisdictional ornamental
pond. Determined by the ANR-DEC to be non-jurisdictional under the VT Wetland Rules or as a
waters of the State. Mosgy open waler with porifons of hinge emergent vegetation.

All delineated wetlands flagged per the 1987 Corps Wetland Delineation Maunual and the 2010 Northeast Regional Supplement

Cowardin, LM., V,Carter, F.C. Golet, and E.T. LaRoe,1979. Classification of Wetlands and Deepwater Habitat in the United States. U.S. Fish and Wildlife Service. FWS/OBO-79131 IOSpp.

U.S. Army Corps of Engineers (USACE) New England District. 1999. The Highway Methodology Workbook: Supplement: Wetland Functions and Values A Descriptive Approach. NAEEP-360-l-30a. Functions and Values are
codified as follows: GW=Groundwater Rechargeloischarge, FFFloodflow Alleration, F Fish and Shellfish Habitat, STPSedimentiToxicant Retention. NU’VNuddent Removsl, Pt-Production Export, SSSedimenbShorene
Stabilization, W=Wildlife Habitat, R=Recreation, ES=Educationsl/Scientific Value, HHeritage/Uniqueness, V=Visual/Aesthetics, and RTERare, Threatened, or Endangered Species Habitat.

F;574O?.uo s,av., ‘No,4 PQ ,rd,C&,.rsS’NR Mc,c’e.’ W,c4 Po.e.2w,nd,k,,,,.-nnyWfla,ds loins

Beve, Wood, LLC Pownal, VI
Summary of 2010 DelIneated Streams
Vanasse Hangen Brustlin, Inc.
October 20, 2010

M.rage Ordinary
stream Blame Stream Associated Buffer
Stream Descnptton’ High Js (OHm
Width Notes

Moderately vegetated steepened banks between

the 0MW and the top-
of-bank; past aerial images and current conditon show
evidence of high
tlooslc River Perennial
se*ewsl depositIon *1 the past evidence of ecistlog
pipe outfats on
na Al 50 50 both belts. Sonie ijidercuttlog observed; f&ested
riparian tufter (from
top-of-bank) ranges apptoximately from <5-feet te
50-feet with an
average estimated at 35-teat wIth former raceway
development beyond.
frws*ve plank species , taller
Cutveded through nmtheastern portion of the site through
Lath Brook (tributary to the Hooaic River) (2) 36-Inch
Perennial na A4
conogated metal pipes- Channel re-located circa 1962 as
pad of
6 25 eaceway development; Esisffng forested buffer on project
site is
estknated to average atiçsoslosaiefy 30-feet seth
fertner paved pldng
lot beymd. Invasives it, buffer aid bastudebis ii diannel.
Stream flow regime determined based on quslitative observations of
innteeam y
hydrot o indicators and geomorphic characteristic end are subiect to professional
Rosgen, 0. ML Sslvey. Applied Poser Mnrpheley. 1996.

‘BuFfer recommendations 1mm the Decaniber 92305 Vermont Agency

of Natural Resources (ANti) Ripenion Butler Guidance. Section 111W)

ems.rekma,a— ascaeau_da,an

WETLAND DETERMINATION DATA FORM — Northcentral and Northeast Region

ProeW3ite: EA’Jt4c ‘su otñ) City/County: JL

fl’M /1*NkJ lI’i(ttVlJ samping Date:
ApplicantlOwner: ,JQtit) Slate: ‘N Sampling Point: I
Investigator(s): C.Wt&.SW A W’*Pfl ‘ ‘1 kt Zc_Cct’ Section, Township, Range:
Landform (hilistope, terrace. etc.): Local relief (concave, convex, none):
Slope(%): Lat:
Lj 1S’ gj OL(” Long: •*3°Z3’StIt” Datum: JW iIS
SoilMapUnitNarne: f atnJ UdtiMeit c
1 pil-’kj c(c,j NWlclessification: t744
Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.)
Are Vegetation Soil or Hydrology signiticantiy disturbed? Are Normat Circumstance? present? Yes No
Are Ve9etation Soil or Hydrology naturally problematic? (If needed, explain any answers in Remarks.)

SUMMARY OF FINDINGS — Attach site map showing sampling point locations, transects, important features,
Hydrophylic Vegetation Present? Yes No Is the Sampled Area
Hydric Salt Present? Yes ‘)( No within a Wetland? Yes X No
Wetland Hydrology Present? Yes No If yes, optional Wetland Site ID: Z—° IC’ —

Remarks: (Explain eltemative procedures here or in a separate report.)

Wetland Hydrology Indicators:
Secondary Indicators (minimum of two reouiredl
Primary Indicators (minimum of one is required: check WI that ac,clv Surface Soil Cracks (86)
Surface Water (Al) — Water-Stained Isaves (89)
— Drainage Patterns (810)
High Water Table (A2) Aquatic Fauna (813) — Moss Trim Lines (816)
Saturation (A3) — Marl Deposits (515)
— Dry-Season Water Table (02)
j, Water Marks (81) — Hydrogen Sulfide Odor (Cl) — Crayfish Burrows (Cs)
Sediment Deposits (62) Oxidized Riiizospheres on Uving Roots (C3)

Saturation Visible on Aerial Imagety (09)
Drift Deposits (83) — Presence of Reduced iron (C4) — Stunted or Stressed Plants (Dl)
Algal Mat or Crust (84) — Recent iron Reduction In Tilled Soils (Cs) Geomorphic Position (02)
iron Deposits (85) Thin Muck Surface (07) — Shallow Aqultard (D3)
Inundation Visible on Aerial Imagery (87) — Other (Explain in Remarks) — Microtopographic Relief (D4)
Sparsely Vegetated Concave Surface (88) — FAG-Neutral Test (D6)
Field Observations:
Surface Water Present? Yes No ,JS._ Depth (inches):
Water Table Present? Yes No — Depth (inches): tt in

saturation Present? Yes — No Depth (inches): Wetland Hydrology Present? Yes

judes capilary fringe) No
Describe Recorded Data (stream gauge, monitoring wWl, aerial photos, previous inspedions), if available:


US Army Corps of Engineers Northcentral and Northeast Region — Interim Version


VEGETATION Use scientific names of plants.

Sampling Point: I
Absolute Dominant Indicator
Tree Stratum (Plot size: % Cover Soecies? Status Dominance Test worksheet:
Number of Dominant Species
That Ne O&, FACW, or FAC: I (A)
Total Number of Dominant
3. 1
Species Across NI Strata: I (B)
5. That Are OBL, FACW, or FAC: I’
Prevalence Index worksheet:
Total % Cover of: MultIply by:
Total Cover OBL species xi = 9Th
S&inajShnt Strahzn (Plot size: FACWspecies x2
FACspeoles x3
FACt) species x4 =
UPL species x5 =
Column Totals: t (A) 9 ‘ (B)

Prevalence Index = B/A =

Hydrophytic Vegetation Indicators:

I.. Rapid Test for Hydrophytic Vegetation
= Total Cover J(. Dominance Test Is >50%
Herb Stratum (Plot size: Prevalence Index Is s3.&
Morphological Adaptatior& (Provide supporting
!P MtAShJcll(h “rfl ‘1 O1-

data in Remarks or on a separate sheet)

— Problematic l-lydrophytic Vegetation
1 (Explain)

lncllcators of hydric soil and wetland hydrology must

be present, unless disturbed or problematic.

Definitions of Vegetation Strata:

Tree Woody plants Sin. (7.6 cm) or more in diameter

at breast height (DBH), regardless of height.

Sapling/shrub—Woody plants less than Sin. DBH

and greater than 3.28 ft (1 m) tall.

Herb All herbaceous (non-woody) plants, regardless

of size, and woody plants less than 3.28 ft tall.

Woody vInes — P31 woody vines greater than 3.28 ft in

= Total Cover
Woody Vine Stratum (Plot size: V


4 Vegetation
Present? Yes 1 No
= Total Cover
Reniarks: (Include photo numbers here or on a separate sheet.)

US Army Corps of Engineers Northcentral and Northeast Region — Interim Vatsion

SOIL Sampling Point: I
Profile Description: (Describe to the depth needed to document the Indicator or confirm the absence of Indicators.)
Depth Matrix Redox Features
(Inches) Color (moist) % Color 1mot) % Tyce’ LocZ Texture Remarks
loLzjq 100

la- o (b_‘tcI’ iONlZb/L I

Type; Cconcentratlon, DDepleUon, RM=Reduced Matrix, CS=Covered or Coated Sand Grains.

1 ‘Location: PLPore Uning, MMatrix.
Hydric Soil Indicators: Indicators for Problematic Hydric Soils’:
— Histosol (Al) Polyvalue Below Surface (58) (LRR R,

— 2cm Muck (AiD) (LRR K, L, MLRA 14DB)

— I-fistic Epiperiori (A2) MLRA 1490) — CoastPrairieRedox(Ai5)(LRRK,L,R)

— Black 1-IISIIC (AS) Thin Dark Surface (59) (tSR B, MLRA 1490) — 5cm Mucky Peat or Peat (53) (tSR K, L, B)

— Hydrogen Sulfide (A4) Loamy Mucky Mineral (Fl) (LRR K. L)

Dark Surface (57) (LRR K, L)

— Stratified Layers (A5) Loamy Gleyed Matrix (F2)

Polyvalue Below Surface (58) (LRR K, L)

— Depleted Below Dark Surface (All)

Thick Dark Surface (Al2)
Depleted Matrix (P3)
Redox Dark Surface (P6)
— Thin Dark Surce (59) (LRR K, L)

— iron-Manganese Masses (P12) (LRR

K, L, B)
— —

— Sandy Mucky .tnerai (SI) — Depleted Dark Surface (P7)

Piedmont Floodplafri Sols (P19) (MLRA 1490)

— Sandy Gleyed Matrix (54) Redox Depressions (F8)

Mesic Spodic (TAG) (MLRA 144A, 145, 1490)

— Sandy Redox (55) — Red Parent Material (1F2)

— Stripped Matrix (56) — Very Shallow Dark Surface (TFI2)

— Dark Surface (57) (LRR B, MIRA 1498) Other (Explain In Remarks)

9ridicators of hydraphytic vegetaticn and wetland hydrology must be present unless disturbed or problematic.
Restrictive Layer (If observed):
Depth (inches): Hydric Soil Present? Yes X No —


US Army Corps of Engineers Northcentral and Northeast Region — Interim Version

of En9lneers.
New Englond Thsthct
Wetland Function-Value Evaluation Form
Wetland ID. 20IOi
Total area of wetland 26 acres Human made? Yes Is wetland part of a wildlife corridor? No or a ‘habitat island’? No
Latitude_.Th24M Longitude -73.235421
Adjacent land use Developed (former raceway) Prepared by: RMS Date 09/09/10
Distance to nearest roadway or other development Surrounded
Wetland Impact
Dominant wetland systems present_I-basic River
Contiguous undeveloped buffer zone present_No
Type Area__________
Is the wetland a separate hydraulic system?_Yes
If not where does the wetland lie in the drainage basin?__________________
Lvaluatbon based on:
How many tributaries contribute to the wetland? None Office \ Field_.___
Wildlife & vegetation diversity/abundance (see attached
Corps manual wetland delineation
completed? v_N N______
Suitability Rationale Principal
Function/Value y N (Reference #)* Function(s)/Value(s) Comments
— — —
Groundwater Recharqe/Discharqe 15

— Floodflow Alteration — — 5,6,7,8,9,1 0,15,18 Wetland originally constructedto acceptstormwater and actas an ornamental feature forthe
— Green Mountain Raceway.
Fish and Shellfish Habitat

SedimentfToxicant Retention 3,4,5,9 The constructed depression Is large and flat allowing opportunity for sedimentftoxicants to
settle out.
Nutrient Removal

it Production ExDort —

— 247 —

J. Sediment/Shoreline Stabilization 2,15

j, Wildlife Habitat 11F13,17

I .‘q. Recreation

Educational/Scientific Value


Visual Quality/Aesthetics

ES Endangered Species Habitat

Notes: Wetland consists of a depression constructed in the early 1960s as part of the Green Mountain Refer to backup list of numbered considerations.
Raceway.The jond was built to hold stormwater runoff from surrounding parking Adepted .
from: tLS.N,ny Corns of Enginesra New EnIsnd DIshict 1999. The flgtiway
areas and the
MeUlodology Wor*lioot Supplement WeOa,d Fuicifons aM values -A Oescdpve
grandstand. vegetation moved into the wetland due to lack of maintenance. Approsth, NAEEP-360-1-30s.
Site Photographs — Wetland/Stream Delineation

I’anasse Ihingen lirustliji. inc. Beaver Wood Energy LLC, Pownal Biomass Site

Photograph 2: Representative view of the Hoosic River, glide

pooi reach (C. Martin)

Photographer: VHB Pioneer

Photographs Taken: May, June, or August 2010
VHB Project# 57407
f:\37407.OO beaveT wood powiiahdoes’snemos\nr rneino\bvr wood biomass weti stream photo Jayout_1O-20-!O.docx
p Site Photographs — WetlandJStream Delineation
I anassc Hangen jJr,,siIin. Inc. Beaver Wood Energy LLC, Pownal Biomass Site

1 /‘t
— — i.—- -

* —


-‘:- - --: t

Photograph 3: Representative view of stream 2010-TB-2 (Ladd

Brook) (C. Martin)

:1i :W

‘2 N /; \\
t ’

r —

Photograph 4: View of downstream invert of culverted

crossing on 2010-TB-2 (Ladd Brook) (C. Martin)

Photographer: VHB Pioneer

Photographs Taken: May, June, or August 2010
VHE Project# 57407
f:\57407,00 beaver wood pownal\docs’xnemos\nr memo\bvr wood biomass weti stream photo layoutjO.20-1 O,docx
Site Photographs — Wetland/Stream Delineation

Vanasse Ilangen Brush/n, Inc. Beaver Wood Energy LLC, Pownal Biomass Site

Photograph 5: Representative view of the jurisdictional

excavated wetland 2010-1 (C. Martin).

Photograph 6: Representative view of the non-jurisdictional

excavated pond/wetland 2010-2 in the middle of the former race
track (R. Scott)

Photographer: VHB Pioneer

Photographs Taken: May, June, or August 2010
VHN Project# 57407
f:\57407OO beaver wood pownal\docs’menios\nr memo\bw wood biomass weti stream photo layout O2O-1 Odocx
Site Photographs Wetland/Stream Delineation

tj;rasse Iia2ge12 lir’u.stlbi, Izc. Beaver Wood Energy LLC, Pownal Biomass Site

Pbotograph 7: View of typical non-wetland condition in

northern over fonner (C. Martin)

Photograph 8: View of paved parking, former race track, and

excavated wedandipond 2010-2 (L. Stafford)

Photographer: VHB Pioteer

Photographs Taken: May, June. or August 2010
VFIB Project# 57407
f:\57407.OO beaver wood pownal\docs’memos\nr niemo\bvr wood biomass wet! stream photo layout 1O-20-lOdocx
Site Photographs — Wetland!Sfream Delineation

I 4anasse Ilanpen lirustlin, Inc Beaver Wood Energy LLC, Pownal Biomass Site

Photograph 9: View of typical Hoosic River buffer condition

within the site (C. Martin)

Photographer: VFIB Pioneer

Photographs Taken: May, June, or August 2010
VHB Project# 57407
f:\57407.OO beaver wood powia1\docs\memos\nr memo\bvr wood bioniass weti stream photo layout_1O-20-1Odocx
Beaver Wood Energy Pownal, S,rom Ba&gousnd Topo Fonia: North Powriat

BerSr. mid North Adams Quads from LSGS (19542

Legend Pownal Biomass Site Roads and Proprrty Parcels from VCGI (2%5) Soü Units
Pownal, Vennont from VCGJ (ZWS2
VHDl’ Jnvestiga6on Area
Soil Comparison Location Soil Comparison Locations
August 18, 2010
— VT Class j&ll Roads
7056 US Route 7PO Box 120
North Ferrjsburh VT 05473
1802 4257788 f802-4257799
r.’sNo’. Besaewosd
USDA NaIunI Resoisca
censervatlonsenlre Vermont SoIl Fact Sheet Bennington County, Vermont 15
27B: Udipsamments and Udorthents, gently sloping
This map unit consists of areas where the original soil has been removed or covered with fill material. The fill material is typically
loamy, but sandy and clayey areas are included. On-site investigation is needed to identify the soil properties and to determine the
hazards and limitations for specific uses.

The soil in this map unit has been altered or removed. This map unit is not suited to cultivated crops, hay or pasture.

Important farmland dassification: NPSL Land caoabiitv 8 s Vermont Agricultural Value GrouD: 11

Vermont Residential Wastewater Disposal - Group and Subgroup:

V.- This unit is not rated as a site for soil-based residential wastewater disposal systems. Due to the variable nature of the soils, on-
site investigations are needed to determine their suitability.


Depth Typical
Permeability I Organic I
Soil name reaction (ln/Hr) I matter I
(In) texture (Pd)
(Pet) Kw Kf T
tidipsamrnents 0-65 S 0-1 5.6- 7.8 20-100 0.0-0.5 .10 .15
Udorthents 0-65 GR-SL 1-15 4.5- 7.3 0.06-20 0.5-10 —- —- —.


I Hydrologic ( Depth to seasonal

high water table
Flooding Ponding
I Hydric I
Soil name group I I Depth to bedrocl(



Duration Frequency


I (range in inches)

Udorthents —- I .56.0 None None No -—


Soil name Land use Rating Reason **
Crop name Yield I acre
lJdipsammenls Dwellings with basements: Not rated
Udorthents Dwellings with basements: Not rated
Udipsarnments Pond reservoir areas: Not rated
Udorthents Pond reservoir areas: Very limited Seepage

Soil name concern Rating Reason Vermont natural communities
Udipsarnrnents Harvest equip operability: Not rated
Udorthents Harvest equip operability: Well suited
Udipsamments Road suitability: Not rated
Udorthents Road suitability: Well suited
Udipsamments Erosion hazard (off-road): Not rated
IJdorthents Erosion hazard (oft-road): Slight

Distribution Generation Date: 3/13/2008 Page 1 of 1

USDA Nannal RnotTc.S
Conservation Senlee Vermont Soil Fact Sheet Bennington county, vermont 16
29A: Occum fine sandy loam, 0 to 3 percent slopes
OCCUM SOILS formed in loamy over sandy alluvial deposits on flood plains that are frequently flooded for brief duration
from Mid
Winter through early Spring. They are very deep to bedrock and well drained. Permeability is moderate or moderately
rapid in the
solum and rapid or very rapid in the substratum.

This map unit is well suited to cultivated crops, hay and pasture. Flooding is a hazard, but is of short duration and usually
occurs in
the spring. Tillage operations may be delayed in some years.
Important farmland classification: Prime (I) Land caDabilitv: 1 Vermont Agricultural Value GrouD:

Vermont Residential Wastewater Disposal Group and Subgroup: - -

111g.- This unit is marginally suited as a site for soil-based residential wastewater disposal systems, based on a review by the
Resources Conservation Service of criteria set forth in the Vermont 2007 Environmental Protection Rules. The hazard of flooding
the major limitation, This unit is on floodplains and typically includes land in the floodway and the special flood hazard is
area. Consult
flood hazard maps prepared by the Federal Emergency Management Agency (FEMA) in local town offices for more information.
Wastewater systems must be located, designed and constructed in a manner that avoids impairment to the system and
contamination from the system due to flooding.


Soil name I Depth Tical clay
Soil I Permeability
reaction I (la/Kr)

(In) te4ure (Pot))

Occum 0-10
) ) (Pct) )KwIKfIT
FSL 2-12 4.5- 7.3 0.6-6 20-6.0 .20 20 3
10-36 FSL 2-12 4.5- 6.5 06-6 0.5-3.0 .20 20
36-65 LFS 0-5 4.5- 6.5 6-20 0.0-1.0 .17 .20

Soil name
I Hydrologic
Depth to seasonal
high water table

LFre quency Duration

I Pending
I Depth to bedrock
Frequency Duration
I (Feet) (range in inches)
Occurn B 4.0->6.0 Frequent Brief None No -—


Soil name Land use Rating Reason **
crop name Yield / acre
Occum Dwellings with basements: Very limited Flooding Grass hay 4 Tons
Occum Pond reservoir areas: Very limited Seepage Grass-clover 7 AUM
Alfalfa hay 4.5 Tons
Grass-legume hay 4 Tons
Corn silage 24 Tons

Soil name concern Rating Reason Vermont natural communities
Occurn Harvest equip operability: w€II suited I Silver Maple-Ostrich Fern Riverine Floodplain
Occurn Road suitability: Poorly suited Flooding I Forest.
I Sugar Maple-Ostrich Fem Riverire Floodplain
Occum Erosion hazard (off-road): Slight I Forest,
Successional Floodplain Forest Variant

Distribution Generation Date: 3/13/2008 Page 1 of 1

Beaver Wood Energy, LLC
FLgend .ey peeeided by Co
t.,one Aejal ba
Pownal, Vermont Un,.e,ilyeiVenoeiOlnn4ViaDniPeotad

vHepToszo1o Cun l*o.ed..nd0010,oanDi.

OHW 2010 VHBP Wetiands 201 Aerial Imagery

tHOr Delineation 2010 1942
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I’ownal, Vermont UrtteoiiyolWeeooifl%09 090 Ddbre.ted
VHSP 7081010 CoNed
VHSP DHW2OI0 WISP Wetlands 201 Aerial Imagery
WIOPO.ti..ntloe 2810
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WOP soeam suite, August 31,2010 7056 IS Souls 7P08Ox US
Not For4bogh. Orr 0S 1
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From: Quackenbush, Alan
To: Crarv. Adam;
Subject: RE: Pownal Racetrack Beaver Wood Energy project

Date: Thursday, September 30, 2010 4:36;59 PM


I have visited the Pownal racetrack several times over the past 15 years for various
projects. Two man-made features (ponds) there were part of a sewage treatment
system, even though now are not part of a working system. Under the new rules
now in effect, they are exempt from the Rules. They are also not considered
waters of the state. Hope this is what you were looking for. Alan Quackenbush

State Wetlands Coordinator.

From: Craw, Adam []

Sent: Thursday, September 30, 2010 3:33 PM
To: Quackenbush, Alan
Cc: Perry, Meddie
Subject: Pownal Racetrack Beaver Wood Energy project


I’m following up with you about the email I sent in early September (below) asking
for your written verification that the man-made ponds at the former Pownal
racetrack would not be jurisdictional under the new VT Wetland Rules. I know
you’re very busy, but your confirmation (an email will do very nicely) is needed as
Beaver Wood Energy nears a Section 248 filing. I’ve attached our delineation map
if it helps. If you need anything else, Alan, please let me know.

Thanks Adam

Adam R. Craw, PWS, PWD

Senior Wetland Scientist
802.425.7788 x6401

From: Crary, Adam

Sent: Thursday, September 09, 2010 8:51 AM
To: ‘Quackerthush, Alan’
Cc: Scott, Ryan; Perry, Meddle
Subject: Pownal Racetrack Beaver Wood Energy project

Good Morning, Alan:

Pvc passed along the results of our conversation yesterday following your VT
Wetland Rules presentation. Our project manager (Meddie Perry) was happy
hear the news that both constructed pond features at the racetrack in Pownal will
not be Class II or jurisdictional under the new rules. However, my word is not
quite what yours is when you can, would you mind passing along a quick email

we can use for the project file confirming that neither feature would be regulated
under the VWRs?

If you need more information we have plenty of it, but knowing your past

experience with the site, I’m trying to keep it brief.

Thanks, in advance, Alan!

Adam R. Crary, PWS, PWD

Senior Wetland Scientist
VHB Pioneer
Transportation Land Development I Environmental Services
7056 Us Route 7
Post Office Box 120
North Ferrisburgh, VT 05473
Phone: 802.425.7788 x6401 I Mobile: 802.999.3709 Fax: 802.425.7799

This communication is confidential and intended only for the recipient(s). Any other use,
dissemination, copying, or disclosure of this communication is strictly prohibited. If
have received this communication in error, please notify us and destroy it immediately.
Vanasse Hangen Brustlin. Inc. is not responsible for any undetectable alteration, transm
error, conversion, media degradation, software error, or interference with this transm
Vanasse Hangen Brustlin, Inc. 1101 Walnut St I Watertown, MA 024721
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(Appn 90 Aaes)
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Legend Beaver Wood Energy Puwnal, LLC — — -Nt

rco,-vr JD Wetimid Powual Biomass Site -
— ‘HB TOB 2010 Pownal Parcels Pownal, Vermont
Stream Buffer Map

Existing Culvert — Roads Vanasse Hangen B,’Jstlin, Inc.


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Beaver Wood Energy Pownal, TIC. —— — F___

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Pownal, Vermont —— — _c_t

5a(V,..t Il6pE•
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D 0* Rare Species and Wildlife Habitat Review Map ao,._

Octobea 18, 2010

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