Beaver Wood Pownal 248 Filing: No. 8A - Pre-Filed Testimony of David Raphael SD

STATE OF VERMONT
PUBLIC SERVICE BOARD
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 ) Docket No
manufacturing facility located north of the old
Green Mountain Racetrack in Pownal, Vermont,
to be known as the “Pownal Biomass Project”
PRE-FILED TESTIMONY OF
DAVID RAPHAEL
ON BEHALF OF
BEAVER WOOD ENERGY POWNAL, LLC
November 2. 2010
The purpose of the pre-filed testimony of Mr. Raphael is to demonstrate that the proposed
Pownal Biomass Project will comply with certain provisions of 30 V.S.A. § 248 (b)(l) &
(b)(5), namely those pertaining to orderly development, public investments and
aesthetics.
TABLE OF CONTENTS
1. Introduction
2. Summary of Findings Error! Bookmark not defined.
3. Conclusion Error! Bookmark not defined.
EXHIBIT
Petitione(s Exhibit DR-i Resume of David Raphael
Petitioner’s Exhibit DR-2 LandWorks Report

STATE OF VERMONT

for a Certificate of Public Good. pursuant to 30
Energy Facility and an integrated wood pellet
manufacturing facility located north of the old Docket No
to be known as the “Pownal Biomass Project” )
PRE-FILED TESTIMONY OF
DAVID RAPHAEL
ON BEHALF OF
BEAVER WOOD ENERGY POWNAL, LLC
1. IntroductionError! Bookmark not defined.
2 Qi. Please state your name, business address and employment.
3 Al. My name is David Raphael. and I am a Professional Landscape Architect and
4 Planner as well as Lecturer in the School of Natural Resources at the University
5 of Vermont. I am the Principal and owner of LandWorks, a multi-disciplinary
6 planning, design and communications firm based in Middlebury, Vermont. My
7 business address is 228 Maple Street, Suite 32. Middlebury. Vermont 05753.
8 Q2. Please describe your educational background and professional experience.
9 A2. I began my career as landscape architect and planner working for the State of
10 Massachusetts Department of Environmental Management. I have been
11 associated with LandWorks since its inception in 1986. LandWorks serves both
12 public and private sector clients in Vermont and the Northeast. Our areas of
13 expertise include visual, aesthetic and environmental assessment, site and master
_
Pownal Biomass Project, PSB Docket No.

Prefiled Testimony of David Raphael
November 2, 2010
Page 2 of 6
1 planning, graphic communications and GIS mapping, permit planning,
2 participatory and community planning, downtown revitalization, open space and
3 conservation plamilng, zoning ordinance and design review development.
4 landscape architecture and environmental design. At LandWorks we have
5 worked as advocates for communities, appellants, the State of Vermont, and
6 private corporations. I personally have testified and served as an expert witness
7 before most of the District Commissions in the State and the former
8 Environmental Board, as well as the Public Service Board.
9 LandWorks has extensive experience with regard to visual assessment and
10 environmental impact, Criterion 8 of Act 250, and the design and installation of
11 utility facilities and structures. We have evaluated the aesthetic and
12 environmental impact of (1) transmission lines and corridors (including the
13 Northwest Reliability, Lamoille and Southern Loop projects, and the PV2O line
14 removal along the Route 2 causeway in MiltonlSouth Hero); (2)
15 telecommunication facilities (Coy Mountain tower proposal and four
16 telecommunications facilities in Essex and Milton. Vermont proposed by
17 FairPoint Communications): and (3) wind energy development, the Searsburg
18 Project, the Sheffield Project (on behalf of UPC, now First Wind), and three wind
19 projects in Maine (on behalf of First Wind). We have prepared feasibility studies
20 for wind energy facilities siting for the Lainoille County Development
21 Commission. I have served as a member of the Design Issues Study Committee
22 appointed by the Secretary of the Agency of Natural Resources, an initiative

November 2, 2010
Page 3 of 6
1 which clarified the application of the Quechee Analysis for aesthetics and which
2 resulted in the publication of Vermont’s Scenic Landscapes: A Guide for Growth
3 and Protection. in addition, we have prepared a number of zoning ordinances
4 based on scenery preservation and environmental protection guidelines (such as
5 the Town of Stowe Ridgeline and Hillside Overlay District), prepared scenic
6 highway corridor studies (Interstate 91 in Brattleboro, The Molly Stark Byway
7 Management Plan and the Route 100B Scenic Byway Management Plan) and
8 authored a study and state policy which was adopted for permit review of the
9 night lighting of ski areas (Agency of Natural Resources). I have also recently
10 helped to author a revision to the EPRI Transmission Line Reference Book -115-
II 345kv Compact Line Design, Chapter 9. A copy of my resume is attached as
12 Exhibit Petitioners DR-i.
13 Q3. What is the purpose of your testimony?
14 A3. On October 27. 2010, the Petition for the Project was filed. As of that date, I had
15 conducted a site visit and preliminary analyses. but had not yet concluded my
16 report. My report, attached hereto as Petitioner’s Exhibit DR-2, is now complete.
17 The purpose of my testimony is to demonstrate that the Pownal Biomass Project
18 (the “Project”) satisfies the requirements of 30 V.S.A. § 248(b)(1) and (5),
19 namely those pertaining to aesthetics, orderly development of the region, public
20 investments, and historic resources.

November 2, 2010
Page 4 of 6
1 Q4. Have you ever testified before the Public Service Board?
2 A4. Yes, I have presented testimony on behalf of the Department in connection with
3 Dockets 6860 (Northwest Reliability Project), 7032 (Lamoille County Project),
4 7314 (East Avenue Loop), 7373 (Southern Loop), and 7250 (Searsburg Wind
5 Project). I have also testified on behalf of ILJPC (now First Wind) for Docket 7156
6 (Sheffield Wind Project). for Green Mountain Power regarding Docket 7558
7 (Kingdom Community Wind Project), and on behalf of Georgia Mountain
8 Community Wind, LLC, Docket 7508.
9 2. Summary of Findings
10 Q5. Based upon your evaluation and analyses, does the Project comply with
11 Section 248?
12 A5. Yes. On Friday, October 8. 2010, we visited Pownal to reconnaissance the
13 Project Site and surrounding area, to take photos, and to document historic
14 resources. We have prepared a visual simulation from the ball field at the Project
15 entry. A viewshed map has been completed to identify areas with potential
16 visibility, and we have reviewed a 3D model to confirm that visibility.
17 Q6. Please describe your analysis and conclusions.
18 A6. My report, attached as Petitioner’s Exhibit DR-2, addresses the Project in light of
19 the aesthetics, historic resources and orderly development and public investment
20 criteria of 30 V.S.A. 248(b). As set forth in the report, my analytical methods
21 include visual and cartographic analyses. document research and review.
22 LandworkW primary analyses assess the Project’s visibility and potential for
_

November 2, 2010
Page 5 of 6
1 visual and aesthetic impacts, with a focus on vantage points from major federal,
2 state or local roads; relationships to nearby areas of public interest; or high scenic
3 value and/or official designation as a cultural, aesthetic or recreational facility or
4 resource. Locations that involve residential areas in close proximity to the
5 proposed Project were also considered. I used on-site and field study to reinforce
6 my analyses and findings, and also documented public sentiment and concerns in
7 this process.
8 I conducted my Project aesthetic analysis within the parameters set forth
9 in Section 248 for review of utility scale energy generation and transmission
10 projects, including the Quechee Analysis, established in the 1985 Environmental
11 Board Quechee Lakes decision. This analysis also recognized that the Public
12 Service Board weighs “societal benefits” when considering the aesthetic impacts
13 of projects within its jurisdiction.
14 By way of summary we conclude unequivocally that the Project, if
15 constructed, would not result in an undue adverse impact to the aesthetics and
16 scenic beauty of the area because: 1) the Project will not be shocking or offensive
17 to the average person; 2) the Project does not violate any clearly written
18 community standard; and 3) the Petitioner has taken reasonably available
19 mitigation steps to reduce the Project’s visual and aesthetic impacts. In addition,
20 there will be no significant views from historic resources that will materially
21 impact the integrity of the site. The Town Zoning Regulations. the Town Plan,
22 the Regional Plan, and the Regional Energy Plan developed by the Beimington
_

November 2, 2010
Page 6 of 6
1 County Regional Energy Commission each has identified the area where the
2 Project is proposed for commercial and industrial development and encourages
3 towns to establish renewable energy sources, including biomass.
4 Based on the foregoing, and on our findings more specifically detailed in
5 my report, it is my conclusion that the Project has no undue adverse effects on
6 aesthetics, the orderly development of the region, public investments, or historic
7 resources
8 3. Conclusion
9 Q7. Does this conclude your testimony?
10 A7. Yes.
STATE OF VERMONT

for a Certificate of Public Good, pursuant to 30
Do C k e t N 0.
manufacturing facility located north of the old )
PREFILED TESTIMONY OF
DAVID RAPHAEL
Exhibit BWEP DR -1
Resumé
David Raphael, B.A., M.L.A. I Principal/Landscape Architect & Planner
David Raphael founded LandWorks in 1986 after ten years of professional work as
a Landscape Architect and
Planner for the public and private sector. He is a graduate, with honors, of Tufts Univer
sity and the School
of the Museum of Fine Arts in Boston, where he studied English, ecology and graphi
c design. He attended
Harvard University Graduate School of Design with a Crocker Scholarship and gradua
ted with a Masters in
Landscape Architecture. He also attended the Dartmouth College Outward Bound
program.
Mr. Raphael has been an Associate Professor in the Graduate Program in Urban
and Environmental Policy
at Tufts University, on the faculty of Middlebury College, and is currently a Lectur
er in the Universiw of
Vermont Rubenstein School of Environment and Natural Resources, where he has
been teaching courses
in aesthetics, environmental design, and landscape architecture since 1982. Additionally
, David has been
Chairman of his local Planning Commission and Development Review Board
for 25 years and was a found
ing member of the Middlebury Design Advisory Committee. Mr. Raphael is also memb
a er of the Vermont
Urban and Community Forestry Council and the American Society of Landscape
Architects.
EDUCATION
ML.A., Harvard University Graduate School of Design, 1977 Cambridge, Massachusetts
B.A. in English, Tufts University, Cum Laude, Minor in Ecology, 1972 Medford, Massachusetts
School of the Museum of Fine Arts, 1971, Boston, Massachusetts
Diploma, Dartmouth College Outward Bound Program, 1970, Hanover; New Hampshire
EMPLOYMENT HISTORY, PROFESSIONAL SKILLS, AND DUTIES

1986-present: Land Works, Middlebury, Vermont; Founded the firm and has
been Principal
Landscape Architect & Planner for most of the company’s projects.
1984- 1985: Alexander, Truex, deGroot Architects, Burlington, Vermont; Consu
ltant and staff
Landscape Architect/Planner
1980 - 1982: Kiley- Walker, Charlotte, Vermont; Associate Landscape Architect
1976 - 1979: Massachusetts Department of Environmental Management, Planner/Landscape
Architect
TEACHING/ACADEMIC APPOINTMENTS
1982-present: Lecturer, Rubenstein School of Environment & Natural Resour
ces, University of Vermont
1992-1994: Visiting Instructor, Middlebury College, Middlebury, VT
1991-1993: Adjunct Faculty Member, Vermont Technical College
1988- 1989: Director; “Design Vermont” project of the Vermont Council on the
Arts and the
Governor’s Institute on the Arts, funded by the National Endowment of the
Arts &
held at Castleton State College, July 1q89
1983: Visiting Assistant Professor, School of Architecture, University of Arkansas
1982-1984: Adjunct Associate Professor, Graduate Program in Urban and Environment
al Policy,
Tufts University
PROFESSIONAL REGISTRATIONS
• Registered Landscape Architect State of Rhode Island
-
* Passed Uniform National Examination: eligible for registration in other states

• Registered with the Professional Ski Instructors of America
MEMBERSHIPS
• Member, American Society of Landscape Architects
• Member, American Planning Association
• Member, Society of Environmental Graphic Designers
• Member, Board of Trustees, Lake Champlain Land Trust
• Member, Board of Directors, Vermont State Craft Center at Frog HoiJow
• Chairman, Town of Panton Planning Commission and Zoning Board of
Adjustment 1985 2005
-
• Delegate, Addison County Regional Planning Commission

• Member, Agency cf Natural Resources, Design Issues Study Committee
• Member, Town of Middlebury, Design Advisory Committee
• Member, Vermont Natural Resources Council
PARTIAL LISTING OF RESEARCH AND PUBLICATIONS

“BGOC (Big Graphics on Campus) Signs and environmental graphics that impact collegi
ate
environments” Signs of the Times, Oct. 2003
“A New Vision for Vermont,” Landscape Architecture Magazine, December 1999
Special Correspondent, Burlington Free Press, Burlington, Vermont, 1994 to 1998

“Brave New Vermont,” Vermont Magazine, June 1995, Contributor.
Sign Management: Aesthetics, Economics, Environment The Vermont Experience,
-
1992
(“Best of the Conference” award at national conference on sign management,
1992)
“Prospect,” Landscape Architecture Magazine, September/October 1985.
“Grounds for Playful Renaissance, Landscape Architecture Magazine, July
1975.
Richard P. White Award, Horticultural Research Institute, Washington, D.C.,
1983-1984 Windbreaks
and Shelterbelts for the Northeast
Rivers Downtown: Riverfront Revitalization in Vermont, for the Winooski Valley
Park District,
October 1931; funded with a Housing and Urban Development and Research
Grant
“Evolutionary Trends and Essential Themes of Wilderness Preservation” in
Public Space, Peter
Trowbridge, Ed. and with an Introduction by J.B. Jackson; Harvard University,
Cambridge 1975.
AWARDS
2005 View From the Road I Public Space Award
Vermont Chapter American Society of Landscape Architects
2005 Island Line Sign & Amenities Plan Award of Excellence
2005 Lake Morey Resource Conservation Project Merit Award
Vermont Chapter American Society of Landscape Architects Public Space
2005 Danvifle Transportation Enhancement Project Public Space Award Honor
I able Mention
2004 Manchester Design Guidelines I Honor Award
2003 The Pownal Municipal Plan & Land Use Regulations j Certificate of Merit
for Outstanding
Planning Project
Vermont Planners Association
2002 Danville Route 2, Danvifle, Vermont I Certificate of Merit for Engineering
Excellence
American Council of Engineering Companies
2001 Stowe Ridgeline Ordinance: Ridgeline & Hillside Overlay District Merit
I Award
2001 The University of Vermont Wayfinding System & Design Standards Certifi
cate of Merit
for Outstanding Planning Project
Vermont Planners Association
STATE OF VERMONT
Petition of Beaver Wood Energy Pownal, LLC )

for a Certificate of Public Good, pursuant to 30 )
Docket No
manufacturing facility located north of the old )
PREFILED TESTIMONY OF
DAVID RAPHAEL
Exhibit BWEP - DR -2
LandWorks Report
He,
—a I
11:
AESTHETIC ASSESSMENT OF THE PROPOSED
BEAVER WOOD BIOMASS FACILITY
Pownal, Vermont
Date:
November 3, 2010
Prepared for:
Beaver Wood Energy, LLC
Prepared by:
LandWorks
Landscape Architecture. Planning. Graphic Design.

228 Maple Street, Suite 32
Middlebury, Vermont 05753
Phone: 802388.3011
Fax: 802388.1950
www.iandworksvt.com
info@landworksvt.com
TABLE OF CONTENTS
1. PROJECT BACKGROUND...1
IJ Introduction.. .1
1.2 Report Organization and Contents.. .2
1.3 Project Description.. .2
1.4 The Aesthetic Assessment.. .3
2. THE QUECHEE ANALYSIS...4

2.1 First Step of the Quechee Analysis.. .4
2.1.A What is the nature of the Project surroundings?...5
2.1.B Is the Project’s design compatible with its surroundings?...6
2.1.C Are the colors and materials selected for the Project suitable for the
context within which it is located?...6
2.1.D What is the Project’s impact on open space?...6
2.1.E Where is the Project visible from?...7
2.1.F Conclusion to the First Step of the Quechee Analysis. .10
2.2 The Second Step of the Quechee Analysis.. .10
2.2.A Does the Project violate a clear written community standard intended to
preserve the aesthetics or scenic beauty of the area
7 10
2.2.B Does the Project offend the sensibilities of the average person? Is the
Project, when viewed as a whole, offensive or shocking, because it is out
of character with its surroundings, or significantly diminishes the scenic
qualities of the area?...12
2.2.C Has the applicant failed to take generally available mitigating steps which
a reasonable person would take to improve the harmony of the proposed
Project with its surrounding?...15
2.3 Overall Conclusion.. .16
3. IMPACTS TO HISTORIC RESOURCES... 17
4. ORDERLY DEVELOPMENT AND PUBLIC INVESTMENTS... 19

4.1 Orderly Development. .19
4.2 Public Investments.. .23
ATTACHMENTS
Exhibit 1. Photo Inventory
Exhibit 2. Photo Location Map
Exhibit 3. Potential Visibility from Open Areas
Exhibit 4. Plan Excerpts
Exhibit 5. Mitigation Planting Plan
Exhibit 6. Section
Exhibit 7. Sign Design
Exhibit 8. Visual Simulation
Aesthetic Assessment of the Proposed Beaver Wood Biomass Facility
1. Project Backgrovnd
1. Project Background
1.1 Introduction
This aesthetic assessment of the proposed Beaver Wood Biomass Facility in Pownal
(Project) is conducted in response to the requirements set forth for aesthetic review of
energy transmission and generation projects under Title 30 Section 248 of the
Vermont statutes. The Public Service Board has adopted the Quechee Analysis, a
two-step analysis as set forth originally for the review of aesthetics under Criterion 8
of Act 250.
This report will be referenced by the testimony of David Raphael, ASLA, Principal
and Landscape Architect with Land Works, the firm preparing this assessment. Thus,
this report and its accompanying appendices will become a part of the overall
aesthetics testimony submitted by Beaver Wood Energy, LLC in its application for a
Certificate of Public Good (CPG) from the Vermont Public Service Board (P58) to
construct a biomass facility under Section 248 of Title 30 of the Vermont Statutes.
The methodology for the aesthetics assessment of this Project includes visual and
cartographic analyses, document research aid review. Our primary analyses assess
the Project’s visibility and potential for visual and aesthetic impacts, with a focus on
vantage points from major federal, state or local roads, relationships to nearby public
lands and areas of public interest, high scenic value and/or official designation as a
cultural, aesthetic or recreational facility or resource. Locations that involve
residential areas in close proximity to the proposed biomass facility were also
‘Our analysis. . . . -
considered, although review of aesthetics under Section 248, using the Quechee
however, does not
end with the results Analysis, specifically does not guarantee that views from individual private homes
of the Quechee and properties will never change. We have used on-site and field study to reinforce
test. Instead, our our analyses and findings.
assessment of
whether a particular
The aesthetic analysis for this Project has been conducted within the parameters set
project will have an
forth in Section 248 for review of commercial energy generahon and transmission
. . . .
undue’ adverse .
projects. The analysis thus follows and responds to the process and determinations
effect on aesthetics .
. . . -
and scenic or required under the Quechee Analysis, established in 198o in the Environmental
natural beauty is Board’s Quechee Lakes decision. This analysis also recognizes that the Public Service
significantly Board weighs “societal benefits” when considering the aesthetic impacts of projects
informed by the within its purview (see side panel).
overall societal
benefits of the
project” Findings,
—
P9 Docket 6860
1.2 Report Organization and Contents
This analysis is organized around and relies on an extensive narrative of the Quechee
“Test” as it applies to this proposal. It also includes a number of exhibits and
studies, including the following:
El. Project context map.

2. Photographic inventory presenting the character of the area and views to the
Project area from a range of public locations.
3. Line-of-site sections.
4. Potential visibility map.
5. Visual simulation of the Project.
6. Analysis of the aesthetic impacts, which may result from the smoke stack
plume.
7. A review of applicable town and regional plans.
The following discussions, narratives, and appendices, assembled by the professional

staff at LandWorks, present a compelling case for the suitability of the Project and
collectively demonstrate and conclude that the Project will not result in an undue,
adverse impact on aesthetics.
1.3 Project Description
The proposed Project is a 29.5 MW wood biomass-fired electric generation plant and
integrated wood pellet manufacturing facility situated on approximately 45 acres on
the northern portion of the former Green Mountain Race Track in Pownal, Vermont.
The site plan submitted by the Petitioner illustrates the layout and components of the
facility, which includes but is not limited to several buildings and structures internal
to the Project: administration building, plant warehouse, boiler building, wood chip
processing building, pellet packaging and storage area, precipitator, main stack,
storage tanks, silos, conveyors, storage piles, pump house, and approximately 35
parking spaces for employees and visitors.
Access to the Project site will be via an existing driveway off of U.S. Route 7,
approximately 1,000 feet south of the Route 346 intersection. There will be no new
public road constructed for the Project, but a private road will be built on the site to
provide access for users of the broader parcel.
2
Aesthetic Assessment of the Proposed Beaver Wood Biomoss Facility
1.4 The Aesthetic Assessment
Under Section 248(b)(5) the Vermont Public Service Board must find that the Project
will not have an undue adverse effect on aesthetics, giving due consideration to
Criterion 8 of Act 250. Act 250’s Criterion 8 addresses aesthetic impact within the
parameters of the so—called Quechee Analysis, which was established to provide a
consistent and defensible method for evaluating the aesthetic impacts of projects
undergoing Act 250 review. The Quechee Analysis is a two-step process, which
begins with assessing the nature of the project, its context, and whether it will lead to
adverse aesthetic impacts. This step asks whether the project is in harmony with its
surroundings, and the analysis is based on a clear understanding of the nature of the
visual impacts. This step must describe the surrounding area of the project and the
compatibility of the project with those surroundings- It also asks: 1) whether suitable
colors and materials have been used; 2) how visible the project is; 3) how the project
affects open space in the area; and, 4) whether the project has been proposed for
visually sensitive land.
If the conclusion from this first step of the analysis is that the aesthetic impacts of the
project are considered to be in harmony or compatible with its surroundings, then
the aesthetic impacts of the project are considered not adverse. II this is not the case,
then the project is considered to have an adverse impact and the second step of the
analysis is required to determine if the adverse impacts are undue. The second step
asks three questions: 1) Does the project violate any clear, written community
standards intended to protect the scenic beauty of the area?; 2) Does the project
appear shocking or offensive to the average person?; and, 3) Has the applicant taken
all generally available and reasonable steps to mitigate the identified adverse impacts
of the project as proposed? If the answer to questions 1 or 2 is yes, or the answer to
question 3 is no, then the aesthetic impact of the project is considered unduly adverse
under the Quechee Analysis.
3
Aesthetic Assessment of the Proposed Beaver Wood Biornass Facility
2. The Quechee Analysis

As stated in the initial narrative regarding the Quechee analysis, the applicant must
address the relationship of the proposed project to its surroundings, describe its color
and materials, its impact on open space, and assess other aesthetic qualities.
Therefore, this section follows the Quechee analysis on a step-by-step basis. The first
step asks a series of questions to ascertain whether or not a project will have an
“adverse” impact. The second step determines whether that impact, if adverse, is
“undue.”
LandWorks employs a number of methodologies, as stated in Section 1.2, to assess

the nature of the project’s surroundings and the potential visual and aesthetic
impacts that the project may pose to those surroundings. Site reconnaissance efforts,
review of important pubLic vantage points and scenic and conservation resources, 3D
analysis, photographic simulations and traveL along local roads have all contributed
to our assessment and the conclusions derived from that assessment. In summation,
all of the research, activities and exhibits generated and presented as part of this
assessment have informed and guided the conclusions which have been reached by
the assessment.
2.1 First Step of the Quechee Analysis
2.1.A What is the nature of the Project surroundings?
The biomass facility is proposed in the Town of Pownal, which is bordered by

Massachusetts on the south and New York on the west. The Town is rural in nature
with an approximate population of 3,500 people. Pownal is situated in a valley
between two major mountain ranges the Taconic and Green Mountains. Within the
-
mountainous terrain are hundreds of acres of meadows, farmland and forested

hillsides. The Hoosic River runs north from Massachusetts through Pownal Village
and North Pownal, and turns west into New York, near where the Project will be
sited. Small farms and equestrian related activities are prominent in Pownal. The
Town was once a major industrial leader in the region, employing hundreds of
people in a tannery, saw mill, and plastics manufacturing facility. Unfortunately, the
Town has experienced a sharp decline in economic activity in the last decade with
cutbacks, plant shutdowns, and layoffs occurring in the major industrial and
commercial enterprises. Most people who live in Pownal commute out of Town to
work due to the declining local economy.
The approximately 45-acre Project site is situated within the former Green Mountain
Racetrack. The 144-acre track opened in 1963 and offered horse racing until 1976,
4
Aesthetic Assessment of the Proposed Beaver Wood Biomass Facilily
when it was replaced by greyhound racing. Since closing as a racetrack in 1992, the
site has occasionally hosted events, including a rock concert, big bucks bingo games,
and antique shows. The track was purchased in 2004 by the ownership group
Progress Partners, Ltd., with the intent to develop it for residential use, but switched
their focus to creating jobs due to the declining market and named it the Southern
Vermont Energy Park- The majority of the site is open, except for the track’s
grandstand, which is still standing and will be retained for entertainment events.
The stables located on the southern portion of tile track have been demolished in
preparation for the installation of a 2.
-megawatt solar farm.
2
The Project site itself is an open field surrounded on about 80% to 90% of its
perimeter by vegetative buffers of deciduous and coniferous foliage ranging in
height from 20 to 50 feet and of varying widths. Minimal additional clearing will be
required by the Project, as the footprint of the facility is contained within the open
field area. However, the integrity of the surrounding buffer will not be affected or
undermined. The Project site sits at the lowest point in the river valley and within
the Town itself, which lends itself well to hiding the facility within the topography of
the area.
The adjacent parcel to the north is an industrial site currently used as a sawmill.
Along the Project’s western boundary runs the Hoosic River and agricultural fields
beyond. On the east is the Vermont Railway, which will be utilized by the Project to
transport materials to and from the facility. Beyond the railroad right-of-way is the
US Route 7 highway and two mobile home parks with approximately 90 trailers.
2.1.B Is the Project’s design compatible with its surroundings?
The Project site is located at the former Green Mountain Race Track and in an area
previously identified for industrial development. The owners of the racetrack have
been seeking renewable energy tenants for their now called “Southern Vermont
Energy Park,” and a 2.2-megawatt solar farm has recently been given approval for
development at the southern end of the racetrack parcel- The track’s large
grandstand building will remain on the site and used for entertainment purposes. A
biomass facility at this location will be compatible with proposed uses at the former
racetrack, as well as current and historical industrial uses within the Town.
The Project lies in a rural area where much of the existing industry utilizes native
natural resources in its product. Logging is common throughout the region as there
are large tracts of forests, and logging trucks are commonly seen driving through
Town along US Route 7 and Route 346. A sawmill currently exists within the village
center and is contiguous to the Project site on the north. Stone and gravel quarries
5
are also common throughout the area, as seen just south of the Project site on Route
7, and northwest along Palmer Drive.
Pownal has historically been home to various industries ranging from sawmills and
cotton mills, to tanneries and plastics manufacturing. Its industrial heritage is
apparent throughout the Town, both in the current uses it supports, as well as the
remaining buildings and homes that once were part of the mills and worker housing.
Therefore, this aspect of the Project will be compatible with what is already in place
and common to residents and visitors of the area.
2.1.C Are the colors and materials selected for the Project suitable for the context
within which it is located?
While industrial in nature, the visual impact of the biomass facility will be minimized
by incorporating non-reflective earth tone colors wherever possible. The facility will
consist of buildings, chip silos, a chimney (or stack), and other associated smaller
silos and tanks as well conveyors. All buildings will have metal siding painted light
forest green. The silos will be constructed out of concrete and will be light tan in
color. Smaller silos and tanks will be metal and painted light tannish brown. The
chirrmey will be metal and may have a red stripe at the top, depending on the final
height of the stack. (200 ft or higher requires a stripe). If the stack is 200 feet or
higher, it will also require night lighting per FAA requirements. At this point, the
stack is proposed at 180 feet, so night lighting is not a factor.
Due to the site being surrounded largely by vegetation, the neutral earth tones, such
as the light forest green, were chosen to allow the buildings and associated structures
to blend into their surroundings as much as possible. Where this is not possible, as
with the chimney, the color or material was dictated by considerations for safety.
2.1.D What is the Project’s impact on open space?
This is not a public open space nor is there any designated or official public use or
access for this property. There is an idle ball field adjacent to the site that is privately
owned. This field, and the open field across from it, will be used for the Project’s
construction staging. The landlord of the field has not determined what his plans are
for replacement. The official Town ball field is located further north along Route 346,
so there will be no loss of public open space. The Project will not be visible from this
location and there will be no impact, visual or otherwise, to public open space
anywhere else within the Town.
6
2.1.E Where is the Project visible from?
Exhibit 1 of this assessment provides photographs of the site and environs,

demonstrating the limited visibility of the Project site from surrounding locations.
LandWorks also performed a viewshed analysis and created a Potential Visibility
Map (Exhibit 3) and it was determined that only very limited areas of visibility
would result from the Project (see also Notes with regard to Exhibit 3 in the box that
follows). A site reconnaissance was conducted by LandWorks along the roads
around the site, and within the 3 mile radius, to confirm visibility, including Route
346, US Route 7, NW Hill Road, Burrington Road, State Line Drive, Church Street,
Center Street, Oak Hill School Road, N Pownal Road, Barber Pond Road, and Middle
Pownal Road. This field trip yielded the conclusion that there is limited, if any,
visibility of the Project site from surrounding areas. The Project site is set down in
the valley and is almost impossible to pick out from most roads, whether pulled over
or traveling at the speed limit.
Along Route 7, visibility of the Project does not become possible until a traveler is
within about ½-mile of the Project site in either direction. This is due to topography,
angle of view, and roadside vegetation. As travelers approach the site from the
south, they wind through 3/10-mile of highway commercial and pass by an open
gravel pit on the east. Continuing around a sharp bend in the highway, the railroad
track, soon-to-be solar farm, and racetrack grandstand come into view before any
components of the Project will be visible. For the next ½-mile stretch of highway,
much of the facility will be visible, although low lying vegetation along the road will
screen the ground view (see visual simulation in Exhibit 8). Speeds along this stretch
of the highway are 50 mph, reducing the duration of view to less than a minute and
diminishing overall impact. Approaching the site from the north, visibility of the
Project will not be possible until the vicinity of the Route 346 intersection. This is due
to low lying hills, vegetation and the fact that the site is set at a lower elevation. As
such, only portions of the facility will be visible and again duration will only be for
about 1-2 minutes due to vehicle speed.
Along Route 346, glimpses of the site will not be possible until people traveling
southbound are within 1.5 mile of the facility. These glimpses will be long distance
views of the main stack only, and limited to portions of the top half of the stack.
While there are some open fields along this stretch of highway, buildings,
hedgerows, frees, roadside vegetation, angle of view, as well as vehicle speed greatly
limit visibility. Prior to entering the village from the north, travelers will pass by
former industrial sites including the old tannery and mill and MAC Molding. Within
the village proper, intervening buildings and frees will minimize visibility.
Moreover, due to the differences in elevation (i.e. the village sits higher than the
Project site), most areas will have views of portions of the main stack only if there are
7
Aesthetic Assessment ot the Proposed Beaver Wood Biomass Facility
open, cleared areas. However, in most instances, on-site trees will block views. For
example, views of the very tip of the main stack may be possible just above treeline
from the Post Office, but this is dependent on tree cover conditions. This will not be
in stark contrast to what is commonly seen in the village, where an existing sawmill
has been in operation for years (see Exhibit 1), and will not materially alter or affect
views. As one travels north along Route 346, there will be no views of the facility
except at the Route 7 and Route 346 intersection. Once travelers turn north on to
Route 346 from Route 7, the facility will be behind people and therefore not visible.
Within a ½ mile of the Project, there are approximately 290 residences. As shown on
the viewshed map (see Exhibit 3), higher ground to the east does not offer any
distinct views of the Project site due to topography and heavy vegetation. A field
check of the residences along State Line Drive indicates no visibility due to heavy
vegetation, topography and angle of view (see Exhibit 1). To the west, more visibility
is likely along NW Hill Road as well as from a residential development on Valley
View and Montgomery Road off of NW Hill Road. Some of these homes have
existing views of the grandstand and track and the existing sawmill due to open
land; however, lots with on-site vegetation and trees will have filtered and/or
blocked views. The mobile home park(s) to the east of the Project contain nearly half
of the residences within the ½ mile, and these homes will have some visibility of the
tallest structures of the facility above treeline, including the main stack, wood chip
silos and possibly the boiler building.
In sum, it is very difficult to pick out the Project site due to the landscape pattern of
rolling topography and woodlands, hedgerows, elevation differences, and
surrounding buildings. As such, the visual impact of that potential visibility will be
minimal because of the intervening elements that will make it very hard to see the
Project from even distances of over a half of a mile. The only locations with any
distinct Project visibility will be from a 1-mile stretch along Route 7, brief glimpses
within 1.5 mile along Route 346, the mobile home park adjacent to the site, and along
NW Hill Road. A simulated view of the Project just off of Route 7 at the Project entry
is provided in Exhibit 8.
Biomass electricity is created through direct combustion. The facilities (boilers)

produce steam to use either within an industrial process, or to produce electricity
directly. They can also produce heat, which is then captured for one purpose or
another. As such, the Pownal facility is expected to produce two possible plumes
depending on the outside temperature, which need to be accounted for in this
analysis. One is from the 180-foot tall stack and the other from the two cell cooling
towers. The plumes are the same for both in that when the outside air is at or near
saturation, the tower and/or stack adds more water vapor to the air. Saturated air
8
with liquid water droplets can be discharged and this is what is seen as fog. This
typically occurs on cool, humid days and can be mistaken as smoke.
The developer has provided the following narrative about plume visibility:
Air leaving the cooling tower is usually saturated with moisture and is wanner than the
ambient air, causing a wet exhaust plume to be created. The saturated exhaust plume
may be visible or not depending on the specific meteorological condit ions. This plume will
also vary in size depending on meteorological conditions and operational factors.
Conditions favoring a condensed plume occur more frequently in the fall and winter
seasons, as atmospheric conditions, such as air temperature and relative humidihj, are
more favorable during these periods for plume formation. Also, plume formation tends to
occur more frequently during nighttime hours and during adverse zoeather conditions.
Industry research indicates that the visible plume formation will occur 20% of the time
during visible hours and will stay within the facility boundary during all seasons. The
estimated downward visible plume length will he less than 300 feet and the estimated
plume visible height can reach up to 300 feet above ground level, depending on
meteorological conditions. In the winter the plume length and height may be 20% larger.
Plume breadth is estimated at 40 to 50 fret.
The boiler chimney plume is funned for all the similar reasons as the cooling tower
plume, and the height and width is all determined by operational and weather conditions.
At times the detached plume will be almost horizontal and at other times it is almost
straight up. The plume length in either direction, horizontal or vertical, is estimated to
be 150 ft or less with a diameter of approximately 30 fret.
The plumes are a necessary byproduct of the plant’s operation and will be seen
intermittently in surrounding areas, usually rising above treeline. Overall, visibility
of the plumes will be limited since formation is dependent on atmospheric and
operational conditions, and will not be dominant in the visual landscape on a daily
basis. Plumes and stacks are not uncommon sites in our developed landscapes and
are often associated with manufacturing or energy generation.
In conclusion, due to the limited visibility, the topographical nature of the site itself,
and compatible uses within the vicinity, this seems to be an ideal site for a biomass
facility. If constructed, the Project will result in minimal off-site aesthetic impacts.
Note5 wIth regard to ExhIbIt 3. Potential Visibilily Map
The potential visibility map provides a point of departure for assessing how visible a
project may be within its delineated viewshed. The process includes an initial
assessment using GIS software and data sets and is then refinednalysis an the
9
Notes with regard to Exhibit 3. PotentIal Visibility Map

ground. 3D modeling and field assessment provides additional verification of visibility
or lack of visibility. Land Works conducted a field study to ascertain the extent of
visibility within the 3-mile radius, using the GIS analysis as a point of departure. The
following notes are keyed to the numbers inserted on the Potential Visibility Map and
they explain why the visibility of the Project, as verified in the field, will be extremely low
even within the areas of potential visibility displayed on Lxhibit 3.
I. Only portions of the Project (i.e. main stock) will be visible from some locations within
this area. Visibility will be minimized by the presence of buildings and existing structures.
as well as trees and vegetation.
2. Limited visibility of the Project may be possible from areas along Route 346 but the
visual impact will be negligible due to speed of travel, the distance from the Project,
and the extent of the Project that will be visible (i.e. only a portion of the main stack
will be visible). Additionally, there is a much broader view from some locations in the
area that will diminish the presence of the Project within the landscape and thus the
visual impact.
3. Some residences in this area may have more visibility than others due to intervening
topography and on site vegetation and trees. The racetrack grandstand and
highway is also in view in many of these locations.
2.1.F Conclusion to the First Step of the Quechee Analysis
The conclusion of the first step of this assessment is that the Project will most likely
result in an “adverse” impact on the aesthetics and scenic beauty of the area under
the Quechee Analysis, given that siting a biomass facility in an open field is
sufficiently different than the existing land use, and will alter existing conditions
within the landscape. The Project will not, however, result in an undue adverse
impact to aesthetics and the scenic beauty of the region, and the basis for that
conclusion is presented in the next section of this assessment.
2.2 The Second Step of the Quechee Analysis
2.2.A Does the Project violate a clear written community standard intended to
preserve the aesthetics or scenic, natural beauty of the area?
“In order for a provision to be considered a clear, written conimunitij standard, it

must be ‘intended to preserve the aesthetics or scenic beauty of the area’ where the
proposed project is located and must apply to specific resources in the proposed
project area.
‘In re Halnon, NM-25, Order of 3/15/rn at 22 n.5.
10
In evaluating whether a project violates a clear community standard, which directly

addresses aesthetics or a scenic resource under the Quechee test, the Board routinely
looks to the town plan as the foremost document for providing these standards. If
the Board finds that such standards do exist, and that the project as designed would
violate those standards, the adverse impact would be undue.
The development boundaries of the Project are located in the Town of Pownal and
under the purview of the Bennington County Regional Commission (BCRC). A
review of the Pownal Town Plan and the Bennington County Regional Plan yields
the conclusion that the Project will not violate a clear, community standard intended
to preserve the aesthetics or scenic beauty of the area in accordance with the Quechee
test (see Exhibit 4 for plan excerpts).
The 2007 Bermington County Regional Plan makes many references to the scenic
quality of the region, and that particular attention should be given to these resources.
It states,.. .the natural appearance of the region’s landscape is fundamental to its
rural character and appeal. As such, it is clear that scenery is a very real economic
asset. People are drawn to this area by the beauty of the hillsides, mountains, rivers,
fields, and the traditional townscapes that are complemented by this natural
landscape. These scenic values should be protected” (p. 45). The policy to implement
this goal is included on page 48, “New construction on visually prominent
shorelines, hillsides, or ridges should include provisions for siting and screening
buildings to protect important scenic values. Towns in the Bennington region are
strongly encouraged to adopt appropriate ordinances to ensure that scenic values,
including the natural appearance of view sheds and ridgelines, are protected
adequately.” However, this policy does not pertain to the Project since it is not
proposed on a visually prominent shoreline, hillside or ridge as identified by the
Regional Planning Commission, or the Town of Pownal. Even so, the Plan does nol
contain specific provisions for siting and screening buildings in these visually
prominent areas. The Plan goes on to recognize scenic roads as an important
resource for the Region and encourages each town to formally designate and refine
those roads identified in the Regional Plan, which include the following for Pownal:
Route 346, Witch Hollow Road, County Road, Brookman Road, South Stream Road,
Northwest Road (p. 73). The policy for scenic roads states “Scenic roads should be
maintained for their scenic value while providing safe access for residents. Road
construction and maintenance should he consistent with scenic values (width,
alignment, roadside vegetation, etc.)” (p. 76). While the Plan includes a list of roads
with scenic value in Pownal and encourages maintaining them for their scenic
quality, it is not mandatory for each town to comply, nor does it expressly prohibit or
limit development along these roads. In fact, none of the policies or goals included
in the Bennington County Regional Plan are mandatory. Regional plans, in general,
contain overriding goals, policies and recommendations, which are characteristically
11
advisory and non-compulsory in nature. Statements are usually made in terms of

“encourage,” “support,” “promote,” and “should,” terms that in Act 250 cases have
been determined to constitute non-mandatory language. Regional plans, as a matter
of policy, are focused on broader issues, which affect the region as a whole, and
typically do not consider impacts on an individual town. Thus, while it is important
to consider relevant regional policies in this Quechee analysis, these must be
weighed against the independent and more specific standards provided in the local
town plans. In addition, the Plan specifically references the “old Green Mountain
Race Track” and the many challenges it faces. It recognizes that this parcel is not
scenically significant and can and should be developed (p. 55).
Page 1 of the Pownal Town Plan begins “With the backdrop of the Taconic and
Green Mountains and an abundance of rolling farmland, Pownal offers one of the
most pleasing visual landscapes in the region,” and continues on page 17, “Pownal’s
Routes 7 and 346 offer a high-quality visual approach for travelers from
Massachusetts and New York. As a gateway to Vermont the mstic integrity of these
areas are deserving of safeguards.” As such the Town states, “.. these corridor areas
should be delineated as a specific planning area and guidelines adopted to promote
appropriate development and conservation practices within these sections of the
corridor” (p. 21). The general policy related to these statements says to “Identify
scenic resources (view sheds, outstanding landscape character, etc.) along the
corridor and employ means to respect and protect those qualities where possible” (p.
22). However, nowhere in the plan are scenic resources specifically identified, nor
are there any clearly defined criteria, standards, or guidelines to implement these
broad goals, or that limit or strictly prohibit development anywhere along these
corridors due to scenic value. The Town Plan does include a section on scenic roads
and indicates that they “should be maintained in a manner which preserves theft
visual quality,” (p. 44) but provides no further guidance on what roads are scenic or
how they should be maintained. The plan’s final reference to scenic quality is
specific to the energy section and states “Assure that energy-related facilities are
properly sited with consideration to natural and scenic resources and environmental
impacts” (p. 46); but, again, there is no further commentary on this subject and there
are no specific standards or guidelines on how to achieve this goal.
In conclusion, the applicable Regional and Town plans do not contain “clear, written
community standards intended to preserve the aesthetics or scenic beauty of the
area” under Step 2 of the Quechee analysis because there are no mandatory
provisions or language that could be considered a clear guide for protecting scenic
values where the proposed Project is located.
12
2.2.8 Does the Project offend the sensibilities of the average person? Is the Project,
when viewed as a whole, offensive or shocking, because it is out of character with
its surroundings, or significantly diminishes the scenic qualifies of the area?
This is a challenging question insofar as a biomass plant of this scale is concerned.

There is no question that there may be some individuals or travelers on Route 7 who
wilt find this Project to not be pleasing or overly compatible with its surroundings.
We have already established that this plant, as proposed, will have an adverse
impact on the area from a visual perspective. It is, admittedly, at a scale and size that
wilt dominate its site as a single purpose energy generation facility. There are other
large structures and manufacturing complexes in the vicinity, which will reduce the
singular impact of this Project. A number of factors prevail under this step of the
Quechee Analysis when coming to an overall conclusion that the Project will not
have an undue adverse impact on aesthetics or the scenic beauty of the area. These
factors include:
1) The ongoing efforts of the community as a whole in considering this site as a

future development location, with a potential emphasis on energy and
renewables. There has long been the hope that this area would become a
growth center (and Pownal has conducted studies to that end), indicating that
the Tow-n and itscitizens have concluded that this location is a suitable site for
this type of development. Indeed the owners of the site renamed it Southern
Vermont Energy Park to reaffirm this intention and a 2.2 MW solar farm is
proposed for an adjacent site as well.
2) The consideration that energy generation via biomass fuel conversion is a form
of energy production that is becoming more widespread in the region and is
recognized as a renewable form of energy -hence more acceptance and
understanding by the general public. Both the Town Plan and Bennington
County Regional Plan confirm this by recognizing that biomass generation, as
a renewable energy generation option, may be a viable form of energy with
supplies coming from local sources. A biomass plant has long been operating
in Burlington’s Intervale without offending local sensibilities.
3) The overall lack of visibility from immediately adjacent areas (aside from
Route 7) of the Project reduces the potential for the Project to offend local
residents or visitors. The site is well screened from most directions and
adjacent settlement areas. This factor will reduce the presence of the plant in
the landscape - as it also will be well set back from local roads and
neighborhoods and there are very few residences in the vicinity.
4) The siting of the Project along a major highway corridor makes sense. The
Project is in area where development has already occurred, that has a mixed
land use quality, with other infrastructural elements such as the major
13
2. the Quechee Analysis
highway, a large grandstand structure, and a rail corridor. Gravel pits and a
sawmill are also nearby.
5) The Project will not be directly adjacent to or seen from any nearby designated
park, open space, recreation facility or conserved land, other than an existing
ball field, on private land, which may be relocated. Therefore there will be little
if any visual intrusion or effect of the Project and its operation on such facilities
or lands. The only exception to this is the potential view from the Taconic Crest
Trail and Pownal Woodlands open space areas. Two mitigating factors will
reduce the potential for visual impact and offensive views. These include the
distance from the Project that any views will be, and the heavily wooded
nature of most of the hillside and ridgetop lands that comprise the higher
elevation hillsides and ridgelines both to the east and the west.
Two particular issues that need to be considered with regard to “sensibilities” and
compatibility, the visibility from surrounding hillsides and ridges and the “plume.”
Despite the foregoing narrative, the view from the surrounding hillsides and
ridgelines, although intermittently and not densely developed will be an issue for the
Pownal plant. While the potential view of the complex and the stack will create an
adverse impact, due to its size and height, the impact will not rise to the level of
undue because ultimately it will not overly offend the sensibilities of the average
person. The average person understands that energy generation and production
facilities such as this biomass plant are necessary and not uncommon sites in our
settled and developed Landscapes. Those who would be hiking or experiencing
outdoor open spaces can make the connection between a biomass plant and
renewable energy, local jobs and the local economy. This is a project, which is based
in the local economy and will rely on local natural resources for its energy source,
thus creating an interconnection with the forests of the region. The heavily wooded
nature of most of the region, the National Forest and conserved lands and trails on
the Taconic Crest and hillside will reduce potential views and translate into
intermittent and not overly extensive exposure to the plant and its environs. Given
the location of the Project within an already developed linear corridor, with a major
highway, rail line, gravel pits, manufacturing facility, etc., it cannot be concluded
that the Project is totally out of context or will be shocking or offensive when viewed
in that context.
The plumes are a necessary byproduct of the plant’s operation and will be seen
intermittently in surrounding areas. Plumes and stacks are not uncommon sights in
our developed landscapes and are often associated with manufacturing or energy
generation. The cooling tower plume is visible only under certain weather
conditions, as outlined elsewhere in this assessment. It is estimated that a plume will
be generated 20% of the time during the plants operation, and with a variable
14
breadth of 40 to 50 feet from 80 to perhaps as much as 300 feet in height depending

on the season and atmospheric conditions. These plumes tend to dissipate much in
the way clouds do. The boiier chimney plume is not as extensive in height and
breadth. The plumes will not extend beyond the property of the plant and thus will
not create any off site impacts, such as odor, other than being visible from a distance.
It is not unusual to expect some byproduct from a energy generating facility such as
this, and again, given the limited overall visibility, it cannot be concluded the plumes
in and of themselves will be so extensive and so “present” in the visual landscape so
as to offend the sensibilities of an average, informed individual.
2.2.C Has the applicant taken generally available mitigating steps which a
reasonable person would take to improve the harmony of the proposed Project
with its surrounding?
The siting of the facility in a designated development area and “Energy Park”
indicates that the Project is consistent with the intent of the community and its long
term efforts to redevelop and revitalize this area of Pownal. The site is not a “visually
prominent shoreline, hillside or ridge,” which has been identified in the Regional
Plan as being visually sensitive. The selection
of the site can be considered a mitigating
factor. The site is relatively well screened and
a suitable location in and of itself given its low
elevation and the proximity to electrical
transmission lines and the rail corridor. It is
part of an already developed area and
corridor where such developments are
typically considered commonplace and
acceptable.
One form of potential mitigation includes the

proposal to develop interpretive information
about the biomass plant to explain its purpose
and operation, (and that the plume is steam)
and to provide an opportunity to educate
interested onlookers about this form of
renewable energy and its local benefits. The
option to place interpretive sign(s) can be
considered a mitigating element and will be
The height and scale of biomass plants are not so great that
considered for suitable or appropriate
even intervening deciduous trees, within a quarter to half mile.
or closer, lacking foliage, con provide a reasonable amount of locations, such as the town offices, elementary
effective screening for a roadside or nearby vantage point. school, or on the site of the biomass plant. The
In this simulation, the four trees and their branches partially
developers have a website and additional
screen a biomass plant and its primary stack.
15
Aesthetic Assessment of The Proposed Beaver Wood Biomass Facility
information and explanation can be posted on the website for those who would be
interested.
The site is also one that includes existing extensive perimeter screening with native
and mature vegetation. The retention of most of this perimeter vegetation will be an
important factor in helping to accommodate the development visually and will help
set the Project off from surrounding areas and vantage points. Proposed new
plantings and an identification sign is proposed for the entry area along Route 7 (see
Exhibits 5,6 and 7).
The selection of subdued and earth tone colors such as forest green and light brown
for the buildings and silo respectively will reduce the overall visual impact of the
Project. Additional materials selected will be in their native coloration such as the
concrete chip silo and as such will not be prominent or stand out.
Finally, it is possible that there are other potential mitigation measures that may not
have been identified as of yet. Additional mitigation measures that may be available
and that a reasonable person would consider may emerge or be proposed during the
review process with a project of this nature. The developers should consider such
proposals and thus be open to additional and suitable mitigation opportunities.
2.3 Overall Conclusion
Based on our analysis, as described in the narrative above, we conclude that the
Project, if constructed, would not result in an undue adverse impact to the aesthetics
and scenic beauty of the area The Project’s impacts will not be unduly adverse
because: 1) the Project will not be shocking or offensive to the average person; 2) the
Project does not violate any clearly written community standard; and 3) the applicant
has taken reasonably available mitigation steps to reduce the Project’s visual and
aesthetic impacts. In summary, this is an appropriate Project sited in an appropriate
location that will have limited, if any off-site aesthetic impacts.
16
3. Impacts to Historic Resources

A requirement of the Section 248 review includes a determination of whether a
What’s the Area of
proposed project will have an undue adverse effect on historic sites within the
Potential Effects?
surrounding areas of the project. To address this requirement, LandWorks has
The SHPO uses the undertaken a review of the historic structures within the Town of Pownal and has
federal definition of concluded that the Project will create no undue adverse effect on any historic sites.
“Area ol Potential
Effects” (APE) to
describe the This review was conducted following standards used by the Vermont Division for
maximum area that Historic Preservation (VDHP), guided by Section 106 of the National Historic
may be affected by
a project. Both Preservation Act, and that have been applied in other Section 248 cases, Project
direct and indirect review identified potential historic buildings, structures, and historic districts,
effects to historic Research of these resources was conducted by examining National Register and State
resources must be
considered when
Register (SR) files at VDHP offices in Montpelier, VT for structures that are currently
determining the listed. To establish an appropriate Area of Potential Effect (APE), LandWorks relied
APE, on our familiarity with the site and environs, as well as the viewshed map (Exhibit 3),
which provided a 3-mile radius around the Project Site and also identified areas with
‘The geographic
area or areas within potential visibility. Since the nature of the Project with its low profile within the
which on landscape greatly reduces visibility from long-distances, the 3-mile radius was used
undertaking may as the APE for the historic structure review. Fieldwork involved visiting,
directly or indirectly
cause changes in photographing, and identifying potential impacts to the structures within the APE
the character or and within the area of potential visibility.
use of historic
properties, if any
such properties There are eleven (11) individual sites listed on the State Register that are located
exist. The area of within the 3-mile APE. Based on research and field analysis it was noted that there
potential effects is did not appear to be any additional sites or structures eligible for listing on the State
influenced by the
or National Register within the 3-mile project radius. The following table and
scale and nature of
on undertaking and accompanying photographs and location map (see Exhibit 1 and 2) provide a listing
may be different for of these resources, their locations, and visibility. Due to topography, buildings and
different kinds of
forested woodland, there will be no views from these sites, and it can therefore be
effects caused by
the undertaking.” concluded that the Project will not have an undue adverse impact on historic
(36 CFR 800. 16(d)). resources.
Source: Vermont
Dept. of Historic Table 1. Listing of Historic Sites
Preservation
http://w’vw.historicv Potential
ermont.org/general Visibility!
/reviewfaq.html Site Address Site Name Impact
Pownal Center Private Residences,
Pownal Center Historic District (1) Civic SR None
Pownal Center Community Church Church SR None
17
Potential
Visibility!
Site Address Site Name Impact
Middle Pownal Wilhelm Strohrnaier
Rd. Farm -. Private Residence SR None
Middle Pownal William F.
Rd. Strohmaier Farm Private Residence SR None
North Pownal Private Residences,
North Pownal Historic District (2) Civic SI? None
Route 346, Our Lady of Lourdes
North Pownal Church Catholic Church SR None
Route 346,
North Pownal
Route 346,
North Pownal
Tannery Complex
I jFormer Industrial
Use
Former General
SR None
North Pownal Powell’s Store Store SR None

Town Highway
Furlong Road, Bridge over Hoosic
North Pownal Not extant SR None
2437 North Burton Peckham
Pownal Rd. Farm Private Residence SR None
141 Carpenter
Hill Road, I
North Pownal Maple Wind Farm Private Residence SR None
(1) The Pownal Center Historic District contains a total of 16 properties listed on the
State Register. Of these there are 7 residences, 2 shops, a store/meeting hall, the
Pownal Center Cemetery, the Town Office, the Veteran’s Memorial, the Pownal
Center Church, a farmhouse/inn/lodge, and a tavern.
(2) The North Pownal Historic District contains a total of 39 listed on the State
Register. Of these there are 32 residences/houses, the Post Office, a gas station,
Congregational Church, a parsonage, a tavern, a schoolhouse, and our Lady of
Lourdes Catholic Church.
18
4. Orderly Development and Public Investments
4. Orderly Development and Public

Investments
4.1 Orderly Development
Section 248 requires that a project not unduly interfere with the orderly development
of the region. With the assistance of counsel, we have evaluated the Pownal Town
2 and the Bennington County Regional Plan for the Project’s compliance with the
Plan
orderly development of the region. The Project is a 29.5 MW biomass electric power
plant with an integrated wood pellet manufacturing plant. The Project is a
renewable energy base load resource that will have a very positive fiscal impact on
the State of Vermont, Town of Pownal and its citizens. The Project will create
hundreds of jobs and make a significant contribution to the Town in form of property
tax revenue. It can be concluded from this review that the Project will not unduly
interfere with the Orderly Development of the Region and is, in fact, consistent with
the local and regional plans and those plans’ advocacy for the development of
renewable energy resources and generating facilities.
When the Town Plan was adopted in 2006, the former Green Mountain Race Track
the proposed Project Site had recently been purchased by a developer who intended
-
to develop the parcel as a mixed-use project including several levels of residential

housing, a transitional care facility, and commercial activities. As stated in the Town
Plan:
One objective of the current planning effort is to reflect on the purchase of the former
Green A/fountain Race Track and the master plan submitted by its new owners. This
long-dormant parcel was previously zoned to encourage industrial activity, but outreach
efforts were unsuccessfrl. The current proposed master plan for the property calls for a
relatively dense, mixed-use project including several levels of residential housing, a
transitional care facility, commercial activities and preserc’ation or creation of common
green space for the enjoyment of the residents of the Town and visitors. Accommodating
this proposal would require a change in the zoning of the area to a Village Mixed Use
versus industrial zone. This has led to a reviezo of the pra’ious industrial zone and
village areas that abut this property by the town’s various boards. Town Plan at § 1.2
Subsequent to the adoption of the Town Plan, the zoning district in which the Track
is located was changed from Industrial to Village Mixed-Use specifically to
accommodate the developer and to allow redevelopment of this “long-dormant”
‘Excerpts of the relevant portions of the Town Plan and Regional Plan are attached to the Application as
Exhibit 4.
19
parcel. After the district was changed, however, the mixed-use development
proposal was abandoned due to the declining residential market and, until recently,
the parcel has remained unused. Even though the property is no longer zoned
industrial, the Town has identified the Village District as an appropriate area for
increased development, stating that the “areas designated by this [Village] district
are considered the Town’s ‘growth centers’ because of their existing or planned
infrastructure which is capable of supporting future growth anticipated by the Town
in the next twenty years.” Town Plan at § 3.2(a). The Village District shall, among
other things “provide for more concentrated, high-density development” Town Plan
at § 3.2(a)(1).
Accordingly, although the current zoning designation is Village Mixed-Use, this is an

area that had previously been classified for industrial use and was amended to
accommodate the only plans proposed for the site at the time.
In addition, the proposed use of this site for a renewable energy facility conforms
with many of the Town Plan’s objectives. For example, Section 1.3 of the Town Plan
articulates its “Statement of Objectives”, which includes the following:
14. Encourage the conservation of energy and promote the development of

renewable energy resources which will benefit the Town’s citizens.
The Project is precisely the kind of project sought to be promoted under Section 1.3.
Section 13 of the Town Plan also addresses energy-related goals and policies for the
Town. The Plan expressly notes that “[w]ood resources in Pownal are considerable”
and “encourages the use of renewable energy resources”. See Town Plan at § 13.1.
More particularly, Section 13.2 articulates the Town’s goals with respect to Energy,
and states that the Town shouLd “[e]ncourage the development of renewable energy
resources.” See Town Plan at § 13.2. The Plan also emphasizes the need to bring new
industry and businesses to the area and creating jobs. See Town Plan at 5 6.
In 2004, the 144-acre parcel was purchased by Progress Partners, Ltd., the current
owner, who has been trying to attract energy companies to locate on the site.
Recently, EQS Ventures has submitted applications to construct on the property a 15-
acre solar panel array that would generate 2.2 megawatts on the property. Assuming
that EQS Ventures’ project obtains the necessary permits, Beaver Wood’s proposed
integrated biomass and integrated wood pellet facility would be the second
renewable energy project to locate at the former Race Track. In conclusion, the
Project is a renewable energy development that will have a significant, positive fiscal
impact on the Town and its citizens. As such, the Project fully conforms with the
Town Plan.
20
In Section VIII, the Regional Plan addresses the region’s energy resources, goals, and
policies and, in Section 8.2, the Regional Plan specifically addresses electrical energy
generation. The Regional Plan states that a variety of fuels, including nuclear, fossil
fuels, solar radiation, wood, water, and wind, can be used to generate electricity.
Because of the uncertainties associated with the supplies and costs of each of these
energy sources, the Regional Plan states that “it would seem prudent to obtain
electricity from a diversity of sources and to pursue local generating options.”
Regional Plan at § 8.2. The Regional Plan then specifically addresses, and
recommends, the type of project proposed by Beaver Wood. The Regional Plan
states as follows:
Another promising energy project that could he developed in the region using local
natural resources is a wood energy plant utilizing a technology that involves processing
wood chips to produce gas that in turn powers a jet turbine to create electricity. An
adequate supply of wood exists in the region and surrounding area to provide fuel for this
20-megawatt facility. The resulting demand for low quality timber would also make
efficient forest resource management more economically practical. Care must be taken in
siting such a power plant because of potential impacts associated with noise and truck
traffic, and in managing the forests that will provide the fuel for the plant. Nonetheless,
if the technology can be perfected, such afacility could be an important contributor to the
regions supply of electrical energy.
Thus, the Regional Plan expressly contemplates the Project and acknowledges it as
an “important contributor” to the region. Moreover, as stated above, the parcel on
which the Project is to be sited is being developed as a “hub” for a variety of
renewable energy ventures. Thus, this location is ideally suited for the Project; and,
given the mitigation and site improvements that Beaver Wood proposes to take to
minimize the impact of the Project upon the surrounding community, the Project
fully complies with the Regional Plan’s precaution regarding the minimization of
potential impacts associated with noise and truck traffic.
For the same reasons, the Project conforms with Section 7.2 of the Regional Plan,
which encourages redevelopment of the former Green Mountain Race Track,
provided that such redevelopment does not adversely impact neighboring residential
areas. See Regional Plan at §7.2.
Among the other goals recited by the Regional Plan with respect to energy are the
following:
2. Reduce the flow of energy dollars leaving the Bennington region by decreasing
our reliance on non-local energy sources.
21
4. Increase opportunities to make energy choices and decisions at the local level.
5. Make energy choices that maintain or improve environmental quality.
6. Encourage the development of renewable energy resources.
7. Assure diversity in the energy mix so as to mitigate the impacts of a supply
restriction in any particular fuel.
In addition to the Regional Plan there is a separate Energy Committee, formed by the
Bennington County Regional Commission, which developed the Energy Plan.
Among other things, the Energy Plan discusses the need for exploring renewable
energy resources in Bennington County. In particular, the Energy Plan discusses the
considerable amount of renewable energy resources that Bennington County has
within its borders, and encourages the production of locally generated electricity for
future consumption in Bennington County. See Id. at ii & 5. In particular, the Energy
Plan identifies as a goal and objective to “assure diversity in the mix of energy
sources to minimize impacts of a supply restriction in any particular fuel” as well as
to “decrease our reliance on non-local energy sources through conservation and
development in the use of local renewable energy sources.” Energy Plan at 8.
The Energy Plan encourages the exploration and development of biomass facilities in
Bennington County. See Energy Plan at 36-39. The Energy Plan discusses electricity
generated by wood hiomass in detail and remarks on the “enormous” potential
biomass energy “tied up in trees” in Bennington County. Energy Plan at 16. The
Energy Plan states, “there exists significant unrealized potential for obtaining energy
from [among other thingsl biomass sources in the region. Energy Plan at 16, More
.
specifically, the Energy Plan states that “enough wood biomass remains in the region
for [Bennington County] to supply a significant amount of the region’s total energy
demand as cordwood for residential space heating, as wood chips to fuel commercial
industry, direct burn or gasification boilers, or as fuel for biomass based electricity
generating plants.” See id. There is a significant quantity of wood, which could be
utilized for biomass facilities to generate electricity as well as for heating needs for
both commercial and residential buildings. See Energy Plan at 36.
In addition, the Energy Plan notes that there are no wood pellet manufacturing
facilities in Bennington County and, for that reason, “pellets must be shipped in from
a considerable distance (reducing net energy yield of this fuel.” See Energy Plan at 38.
The Energy Plan notes that “additional demand for pellets locally, through purchases
of new residential pellet stoves and furnaces as well as pellet-fired boilers used by
businesses and institutions, will provide an incentive for a [pellet] manufacturer to
locate in the region.” Energy Plan at 38.
22
The Project, which proposes to locate both a biomass-based electric generation

facility and an integrated wood pellet manufacturing plant in Bennington County,
fully conforms with the Energy Plan.
All in all, the Project will promote a number of central objectives stated in the Town
Plan and Regional Plan. Both plans encourage and support renewable energy
development, and in particular biomass energy. The former Green Mountain Race
Track is also identified in both plans as a potential development site. This Project
offers the best possible opportunity to combine these two objectives and is therefore
an integral part of the region’s orderly development. It is proposed for a site that is
suitable for the use being proposed and will, in fact, support Orderly Development
by providing a local source of renewable energy that is necessary for such
development to occur.
4.2 Public Investments
Section 248 references and incorporates 10 V.S.A. Section 6086, which includes
Criterion 9(K) Development affecting public investments. This criterion considers
whether a project, as proposed, will unnecessarily or unreasonably endanger the
public or quasi public investment in public facilities, services or lands or materially
jeopardize or interfere with the function, efficiency or safety of, or public’s use or
enjoyment of or access to the public facility, service or lands.
The proposed Pownal Biomass Project will not unnecessarily or unreasonably affect
public investments or services in the Pownal area. The applicable investments
include VT Route 346, US Route 7, the Vermont Railway (although this may be a
privately owned company running on a corridor that may or may not have public
investment), town land northeast of the Project, and trails and lands associated with
the Taconic Crest Trail as well as the former Tannery lands.
The site of the plant will be accessed from Route 7 directly from an entry road just
south of Route 346. The traffic impact assessment conducted by Resource Systems
Group concluded that “the construction of this facility will not cause undue adverse
traffic or safety conditions on the local roadway network” (p. 9). Therefore, there will
he no material change affecting the safety or operation of the highway, or specific
impact to the physical attributes of the investment.
There will be no specific impacts or changes to the existing rail line other than a
proposed spur (which would be privately funded and operated). The spur would be
consistent with the purpose and operation of the rail line and as such will not
adversely affect the operation or safety of the railroad.
23
There will be no direct impacts to the approximately 10-acre parcel owned by the
Town where the post office and fire protective association is located. The parcel is not
directly adjacent to the site (it is across the railroad tracks on the Project boundary’s
northeast corner) and there will be no direct physical impacts that could endanger
the public’s well being or safety, or interfere with the functioning of the post office or
fire station. In terms of the public’s use and enjoyment of the post office, most of the
activity is indoors, where people collect and send mail. Other than a potential view
of the tip of the main stack and/or the occasional resultant plume, the Project will
not affect the public’s use since they are not typically attracted to this site for
enjoyment rather to quickly transmit and receive mail. People generally do not
-
linger at the post office for any length of time. It can therefore be concluded that the
Project, as proposed, will not unnecessarily or unreasonably endanger the public or
quasi-public investment in this facility.
Also worth mentioning is the Taconic Crest Trail (Trail) and associated lands,
including the former Pownal Tannery lands now owned by the Town. The Trail
enters into the southwest corner of Vermont for a brief stretch (less than ½ mile).
There are no scenic vantage points along this stretch and there appear to be no views
of the Project from this point due mostly to dense vegetation and topography. The
Hopkins Memorial Forest encompasses the Trail and the southeaster corner of
Pownal, and several logging roads lead up to the Trail from here. However, views
will be limited, if even possible, again due to intervening vegetation. Even if visible,
potential views of the Project would be intermittent and brief and viewed within an
already developed linear corridor, with a major highway, rail line, gravel pits,
manufacturing facility, etc. There will be no impact to the use and enjoyment of the
Tannery lands because there is no visibility of the Project due to topography. Taking
all these factors into consideration, it can be concluded that the public’s use and
enjoyment of these areas will not be materially affected, nor will there be any safety
or other direct impacts to this investment as a result of the Project, as proposed.
24
• The Pownal Village Post Office and surrounding meadows. Project site 2. Looking south toward the Project site over the parting lot of an existing 3. Looking southwest toward Project site from Oak Hill School Road.
is approximately .14 miles sotithwest of the Post Office, landscaping business in Pownal Village. The Project site is approximately Project site is approximately 0.6 miles away.
0.15 miles away.
4. Looking south toward the Project site, approximately 0.25 miles away. 5. An industrial site located just north of in Pownal Village on Route 34k. 6. Looking north along Route 7 the Project site will be visible in the west.
from the pavilion at die American Legion. The Project site is approximately 0.5 miles south of this location, This photo was taken at a pull-oft near the gravel pit approximately 0.5
mites away.
Figure 1. Photo Inventory

Project Vicinity, Sheet 1 of 6 10129/10 LandxI’s
-
Beaver Wood Biomass Facility Pownal, Vermont Prepared for Beaver Wood Energy
7. Approaching the Project site from the south. The entrance is visible on 8. Looking south along the Route 7 corridor. The Project entrance is 9. The view from Northwest Hill Road overlooks the Project location ap
the left side of the photo. visible on the right. proximately (1.15 miles away. The existing track building is visihie over the
ridgetine.
10. “photo of the existing landscape and the view in easterly direction of II. A private residence located across from Post Office in Pownal Village. lZ.The ball field at the entrance to the Project site. A mobile home
the Project site from Northwest Hill Road. The Project site is approximate Project site is approximately 018 miles to the south of this residence. park is visible in the background.
ly 0.15 miles from this location.

Project Vicinity, Sheet 2 of S 10129110 Landds
Beaver Wood Biomass Facility - Pownal, Vermont Prepared for Beaver bod Energy
liThe race ack building just south of the Project site. -
l4. Looking south aL the site formerly the location of the old stabks and
what is now the site of a newly permitted solar farm.

Project Vicinity, Sheet 3 of 6 10/20/10 Lan4woiics
Beaver Wood Biomass Facility - Pownal, Vermont Prepared for Beaver Wood Energy
l5.A view from a farm on North Pownal Road highlights the interven 16.A ball field itt North Powna] is ttickcd against a sill to the east. 17. An historic marker located at the intersection of Route 346 and North
ing topography common throughout the Town. Pownal Road provides information about U.S. Presidents that taught there
early in their careers.
IS. A view dow,, the valley from the junction Route 346 and Cedar Hilt 19. The site of the former MAC Molding manufacturing facility located on 20. Looking south from Burrington Road toward Project site, approximately
Road may have views of the taller components of the Project. Route 346, just 0.8 miles north of the Project. 2.1 miles away.

Area Context! Sheet 4 of 6 10129110 Landleás
Beaver Wood Biomass Facility - Pownal, Vermont Prepared for 9eaver od Energy
21. Two of the historic homes in Pownal Center. 22. Historic Community Church and Town Officc in Pownal Center 23. The Burton Peckham Farm located on North Pownal Road it approxi
Histonc District. nutely 2.4 miles away from the Project site.
24. The main intersection of the North Povnal Historic District. 25. Many properties, including Our Lady of Lourdes Catholic Church, 26. Powell’s Store in North Pownal locatedjust off Route 346.
comprise the North Pownal Historic District.

Historic Resources, Sheet S of 6 10/29110 Lai’i’ks
-
Beaver Wood Biomass Facility Pownal, Vermont Prepared for Beaver od Energy
28.Ttse Town Highway Bridge site historic town bridge has recently en 29. North Pownal Historic District property on Roole 346.
replaced.
30, The William Strohmaier Farm on Middle Pownal Road is over 5

miles away from [he Project site.

Historic Resources, Sheet 6 of 6 10129110 La.às
-
Beaver Wood Biomass Facility Pownal, Vermont Prepared tar Beaver od Energy
30. The iMfliam SIrirnaier Famn
on Midd Pownal Road is nor
5 miles torn the Projeol sine
and nOnes on Isis map.
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Figure 2. Photo Inventory Key ‘41
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cacti buason To. ‘rap only acaoonts far topography and deradosus. anoitigrous, and rrdsed forest aver at an, abused freight of 40 feet. The snap does trot aarfsnn for curer factors soars as buiblingo fund olruoaIeb. actual tree heittu and densep,
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Exhibit 3a Potential Visibility from Open Areas bD b4
Beaver Wood Energy Pownal LLC

Exhibit 4. Excerpts from Town & Regional Plan

Pownal. Vt
Pownal Town Plan 2008
Page 1
1.0 INTRODUCTION
With the backdrop of the Taconic and Green Mountains and an abundance of rolling
farmland, Pownal offers one of the most pleasing visual landscapes in the region. A
community with a rich heritage and varied history, the Town today faces the challenges
of changing times, changing lifestyles, and changing economic conditions. Since 1960
PownaL has grown phenomenally and new problems have arisen which require attention
from an informed and concerned populace. This Town Plan has been prepared to serve
as a guide for decision-makers to influence the course of events in the coming years.
Page 2
One objective of the current planning effort is to reflect on the purchase of the former
Green Mountain Race Track and the master plan submitted by its new owners. This
long-dormant parcel was previously zoned to encourage industrial activity, but outreach
efforts were unsuccessful. The current proposed master plan for the property calls for a
relatively dense, mixed-use project including several levels of residential housing, a
transitional care facility, commercial activities and preservation or creation of common
green space for the enjoyment of the residents of the Town and visitors. Accommodating
this proposal would require a change in the zoning of the area to a Village Mixed Use
verses industrial zone. This has led to a review of the previous industrial zone and village
areas that abut this property by the town’s various boards.
Page 3
(1.3 Statement of Objectives)
14. Encourage the conservation of energy and promote the development of renewable
energy resources which will benefit the Town’s citizens.
Pages 8-9
f Land Use)
(a) Village)
The three areas designated by this district are considered the Town’s “growth centers”
because of their existing or planned infrastructure which is capable of supporting future
growth anticipated by the Town in the next twenty years. These villages should not be
confused with the official state designation of a “Growth Center;” rather we are using the
term in a descriptive manner. Specifically, the Villages centers shall:
1) provide for more concentrated, high-density development;
Page 17
(3.3.8 Agricultural Land)
The protection ofprime agricultural land in Pownal is desirable for reasons beyond the
basic desire to preserve a bucolic flfestyle. As transportation costs increase, locally
grown food products will become more essentiaL Vermont-made products are also
widely sought-after by residents and visitors alike, and should be actively encouraged
and supported The pastoral landscape is also the foundation of Vermont’s substantial
tourist trade. Pownal ‘s Routes 7 and 346 offer a high-quality visual approach for
travelers from Massachusetts and New York. As a gateway to Vermont the rustic
integrity of these areas are deserving ofscsfeguards
Page 21
3.3.10 Route 7 & Route 346 Corridors
One aspect of uncontrolled or undesirable growth in a community that can occur both
with and without sewer service is strip development along a highway corridor. Strip
development undermines community character and the historic settlement patterns,
promotes inefficient use of land and can also lead to traffic conflicts and safety concerns.
Pownal wants to promote development within the Village Districts and growth centers
and discourage sprawl and strip development patterns. This is a desirable goal with or
without sewer service. Currently there are extensive stretches that are undeveloped and
have scenic and natural resource values along the Routes 7 & 346 corridors that run
outside the village growth areas. Thus, these corridor areas should be delineated as a
specific planning area and guidelines adopted to promote appropriate development and
conservation practices within these sections of the corridor.
Pages 21-22
General Policies
1. Landscape, Aesthetics and Natural Resources
• Identif’ scenic resources (view sheds, outstanding landscape character, etc.) along the
corridor and employ means to respect and protect those qualities where possible.
Page 28
&& BUSINESS AND INDUSTRY)
Because of the need to stabilize the tax base and to provide more jobs, the Town
encourages the establishment of varied and appropriate commercial development.
Bringing new businesses to a town is a process which requires the support, enthusiasm
and participation of the community. In 1995, the Board of Selectmen created the Pownal
Community Development Committee, compromised of volunteers from the Pownal
community, to assist them in the evaluation of suitable businesses for the Town. The
Town should continue to encourage conunercial and business development but it should
be strictly controlled so as to preserve the high quality of life we all would like to
maintain.
Page 44
(10.0 TRANSPORTATION)
5. Scenic roads should be maintained in a manner which preserves their visual quality.
The Scenic Road Designation program should be studied as a method of achieving this
end.
Page 46
13.1 Overview
Sharp fluctuations in the prices of fuel oil and gasoline have vividly demonstrated
that energy is a scarce resource subject to quantity, management and distribution. Energy
conservation and the use of renewable energy resources provide opportunity at the local
level to influence overall consumption and resulting cost to consumers. Larger
users/consumers may have less choice in their dependence and at some point there may
be greater choice for all consumers by selecting the most competitive suppliers/brokers
and choice of energy source such as green energy. Wood resources in Pownal are
considerable and higher elevations may in some locations lend themselves to wind
energy. This plan encourages the use of renewable energy resources and takes into
accoimt the environmental policies in Section 3.0. The use of current energy sources can
also be influenced by conservation and effective land-use policies, including an efficient
land-use pattern. The new sewer system will help concentrate future development in an
energy-efficient land-use pattern. Energy conservation measures are encouraged for all
building construction and reconstruction. The siting and orientation of buildings to
maximize solar exposure is encouraged when feasible.
13.2 Goals
8. Assure that energy-related facilities are properly sited with consideration to natural
and scenic resources and environmental impacts.
THE REGIONAL PLAN
Bennington Region, Vermont
ADOPTED -- May 17, 2007
Bennington County Regional Commission

P0 Box 10— Arlington, VT 05250
(802) 375-2576
Nuisance Wildlife:
The national trend in the decline of hunting and trapping activities have led some wildlife species to
proliferate to levels where their presence is often viewed as a nuisance. While their populations have
steadily grown, many Canada geese appear to have abandoned their migration instincts. Large
congregations of these “resident” geese have caused site-specific pollution on lakes, ponds, golf courses
and lawns. Meanwhile the decreasing demand for natural flit pelts have led to a large growth of the
beaver population. Although often admired as nature’s engineers, the beaver’s dam building abilities can
lead to costly property damage by flooding roads, wells, septic systems and wood lots. It is advised that
municipal officials and private property owners consult with the Department of Fish and Wildlife toward
resolving such wildlife nuisances.
6.6 Unique Natural Features and Scenic Resources
The BCRC and the Vermont Natural Resources Council have compiled inventories of unique geological,
botanical, and hydrological natural features. The waterfalls, caves, glens, rock outcroppings, and other
unique features described in these reports are located throughout the region and add to its special
character. Any development that occurs near one of these sites should include undisturbed buffers around
the resource to ensure that it is not damaged.
Similarly, the natural appearance of the regions landscape is fundamental to its rural character and
appeal. As such, it is clear that scenery is a very real economic asset. People are drawn to this area by
the beauty of the hillsides, mountains, rivers, fields, and the traditional townscapes that are complemented
by this natural landscape. These scenic values should be protected. A beautiful agricultural valley set
against a backdrop of wooded hillsides is surely more valuable to the region than the same valley beneath
a hillside that is cluttered with unsightly buildings. Consequently, development on visually prominent
hillsides or ridgelines must be carefully planned, with special care given to the siting and screening of
buildings, to avoid the loss of scenic value. Development that reinforces traditional development patterns
— growth in and around historic village centers and in clusters will also help to maintain the regions
—
aesthetic appeal.
Scenic resources are often taken for granted until they are compromised or threatened. With assistance
from the BCRC. several towns in the region have recently completed scenic resource inventories. Once
identified, a town could utilize one of the following measures to protect scenic resources:
- purchase of scenic lands,

- scenic easements or purchase of development rights,
- consideration of scenic impacts of public investment activities such as utility poles, street
lights, and cleared power line rights-of-way,
- public education, and
- regulation through zoning, subdivision regulations, and the Act 250 review process.
The BCRC has developed several model bylaws to help communities protect scenic mountainsides and
ridgelines. A model telecommunications facilities bylaw developed by the commission has proven
particularly timely, as several towns have recently been planning for the age of wireless communications.
45
5. Developments or activities that would significantly degrade air quality in the region, or that would
impede economic development in the region, should not be permitted. Efforts to limit air quality
degradation from sources beyond the region should also be supported.
6. Public sector planning and investments should promote growth in designated growth centers and
discourage scattered development in outlying areas that would result in the loss or fragmentation of
important agricultural or forest lands.
7. Developments on agricultural lands shall be planned so as to preserve the viability, or potential

viability, of the site for agricultural use. Developments should also include the objective of
maintaining the values afforded by woodlands on or near the site.
8. Silvicultural practices that minimize soil erosion and impacts on roads, streams, wildlife habitat, and
the natural appearance of mountain and ridge tops should be employed.
9. Developments should be planned and permitted so as not to preclude the future utilization of
important earth resources.
10. The extraction and processing of earth resources and the disposal of wastes must not have an unduly
harmful impact on the enviromnent or surrounding land uses and development. Upon completion of
the extraction or processing, the site should be restored and left in a condition suited for an approved
alternative use.
11. An activity or development in the vicinity of an important natural area or wildlife habitat must be
carefully planned so that adverse impacts are avoided.
12. New construction on visually prominent shorelines, hillsides, or ridges should include provisions for
siting and screening buildings to protect important scenic values. Towns in the Bennington region
are strongly encouraged to adopt appropriate ordinances to ensure that scenic values, including the
natural appearance of view sheds and ridgelines, are protected adequately.
13. Acquisition of land, easements, or development rights by a public entity or nonprofit conservation
organization is an appropriate method to protect important resources or to provide public access for
recreation.
14. Owners of valuable agricultural and forest lands should contact the County Forester or the
Bennington County Conservation District to become informed of the Vermont Current Use Program
and encouraged to participate in that program.
15. The BCRC should continue to participate in cooperative pLanning for regional water resources. Such
projects may consider issues related to environmental quality, public health, recreational use and
public access, fish and wildlife habitat, and aesthetic values, and should involve representatives of
town governments (in the region and in neighboring regions and states, as appropriate), special
interest groups, and other interested persons.
16. The BCRC should compile a resource manual for municipalities that contains model bylaws that will
aid in the protection of important surface waters and aquifers and groundwater recharge areas.
48
7.2 ViIIa2es
The villages within the Bennington region are particularly important planning areas because they serve as
a key element for structuring new growth and development outside of the urban centers. Villages offer
many goods and services for local residents, present opportunities for local businesses and employment,
and provide rural towns with a sense of place. Many villages are also important historically and
contribute to the aesthetic appeal of the entire region. Characteristics of villages include a mix of
commercial and moderately dense residential development, community facilities (church, school, post
office, town hall, etc.), and perhaps some industrial development. A public water supply and a modest
network of paved roads are also present in most villages in the area. Examples of villages in the
Bennington region include: Dorset, East Dorset, Arlington and East Arlington, South Shaftsbury,
Pownal, Manchester Village, Old Bennington, and North Bennington (the village centers in Manchester
and Bennington overlap with elements of adjacent urban centers).
Towns should consider existing villages and surrounding areas as suitable locations for new growth.
Development in and around villages reinforces historical settlement patterns, is economically efficient,
and reduces the amount of less desirable growth scattered through the countryside. Maintenance and
improvement of the infrastructure that serves villages is important so that growth can be accommodated
with minimal environmental or financial costs to the community. Planning for these areas should
encourage a variety of residential and commerciallindustrial uses, but at a significantly smaller scale than
in urban centers. Residential development in villages should be permitted, for instance, at densities of
one to three units per acre depending upon the availability of adequate infrastructure and soil conditions.
Likewise, carefully designed and planned convenience shopping centers may be appropriate in villages,
but community and regional shopping centers must not be sited in villages.
Several difficulties typify planning for growth and development in village areas, however. Although
towns may want to encourage growth in and around villages, environmental conditions and limited
infrastructure capacity often present severe stumbling blocks. Villages may also be concerned that
excessive village development will detract from both the character and function of traditional villages.
For these reasons, the intensity and extent of development in village areas must be carefully managed.
Towns should assess the growth potential of villages, determine whether suitable areas for expansion can
be found in and around existing village districts, and evaluate the appropriateness and feasibility of
increasing the capacity or geographical extent of public water, sewer, and road systems. Vermont’s
Downtown Program now provides for designation of village centers, affording benefits to enhance the
vitality of those areas and encourage full use of existing and historic properties.
In addition to, or as an alternative to, further development of existing villages, some towns may want to
consider establishing new village areas. Prior to promoting concentrated village-type development in a
rural area, towns should consider factors such as proximity to existing neighborhoods, the adequacy of
roadways in the vicinity, soil conditions, and water supply potential. In some situations it may be
appropriate to encourage additional growth around existing small rural villages or hamlets. Zoning
regulations, which may include provisions for site plan review, performance standards, and historic
preservation, must be written to help encourage appropriate growth within villages while ensuring that
these areas retain their scale and unique character.
Pownal Race Track:
54
The old Green Mountain Race Track, located on a large tract of level land adjacent to Pownal Village and
the Hoosic River, presents some unique planning challenges. The property has not been regularly used
for a number of years and contains a large number of dilapidated structures as well as the large grandstand
building. Several ideas for re-use of the property have been advanced in recent years, the most recent
involving a mix of residential and commercial uses. Any redevelopment of the property should be
accomplished in a manner that enhances the environment and does not adversely impact neighboring
residential areas or Bennington’s commercial center and downtown. The Track property should be
considered as an extension of the Pownal Village area that can accommodate a moderate level of
residential development as well as planned commercial or light industrial uses at a scale appropriate for a
growing village area.
7.3 Development in Rural Areas
While concentrations of new development should be directed to established growth centers, some
development has occurred, and will continue to occur, in rural areas outside of villages and urban centers.
Such growth must be planned to avoid impacts on the region’s rural character, environmental quality, and
excessive costs to municipalities. Historically, rural homesteads were established in conjunction with
farms, sawmills, or other land-based family businesses. In addition, small settlements sprang up at many
rural crossroads and other locally convenient sites. These hamlets consisted of a small cluster of homes
and perhaps a school, church, store, or some other public building. Many rural hamlets are still evident
today. These areas are important as focal points for local communities and contribute to the diversity of
the rural landscape. For the most part, hamlets have no public water supply or sewage disposal systems,
and most of the buildings are located along one or two roads. Examples of hamlets in the Bennington
region include: Rupert, West Rupert, South Dorset, Peru, Landgrove, Sandgate, Richville and
Barnumville (in Manchester), West Arlington, Center Shaftsbury, North Pownal, and Stamford.
In recent decades, residential subdivisions have created new concentrations of settlement in mral areas.
These developments are generally entirely residential, with self-contained road networks and on-site wells
and septic systems (some subdivisions, particularly those with multi-family or clustered units, may have
community water supplies and wastewater disposal systems). Subdivisions in the region range in size
from a few to several dozen lots, and may consist of single-family homes on lots of one to ten or more
acres, clustered single-family homes on smaller lots, or multi-family condominiums. A few examples of
the many rural subdivisions in the region include: Dorset Orchard (Dorset), Bromley Brook Woods and
Eagle Rise (Manchester), Wilcox Road (Arlington), the several Sunderland Hill and Bacon Hollow
developments (Sunderland), and Hidden Valley (Shaftsbury). Subdivisions must be carefully planned to
provide a desirable living environment for residents, and to ensure that the rural character and natural
resources of the area are protected. In areas that have extensive or concentrated natural resources,
including important agricultural land, proposals for residential developments must retain the integrity of
those resources.
Municipal bylaws should ensure that development in rural areas reflects historical settlement patterns.
Scattered development in remote areas with poor access to town centers must be avoided. New
subdivisions must incorporate the positive characteristics of earlier rural settlements: a community
identity, public open spaces, preservation of economically important resources (such as agricultural soils),
and so on. Many of these objectives can be realized by clustering lots to create a hamlet-type character
around the homes, while setting a significant percentage of the project area aside as open space reserved
for agriculture, forestry, or public recreation. Such developments also are economically efficient because
roads and other infrastructure need not be as extensive or costly to construct and maintain.
55
VIII. ENERGY
Recent dramatic fluctuations in the prices of fuel oil and gasoline have vividly demonstrated that energy
is a scarce resource that should be considered in any comprehensive planning process. Both the type and
quantity of energy used have economic and environmental quality implications for the region. Various
fuels wood, oil, electricity, propane gas, and coal are used for space heating in residential households.
— —
Commercial, industrial, and public and institutional buildings use either oil or electricity (and to a lesser
extent propane gas and wood) for heating. All of these uses rely on electricity to power appliances, lights,
machines, and other conveniences. Of course, personal and commercial cars and trucks are responsible
for consumption of a great deal of gasoline. Each of these energy sources or forms presents certain
concerns, problems, and opportunities. Many such issues were thoroughly addressed in the Regional
Energy Plan adopted by the BCRC in 1982. The Regional Energy Plan should be updated to incorporate
new consumption data, demand projections, and recent energy initiatives in Bennington County. The
policy framework of that Plan is still relevant, however, and will form the basis for this chapter.
The ten basic energy goals identified in the Regional Energy Plan are certainly still applicable today.
Some progress has been made toward the attainment of many of these goals, but a continuing
commitment will ensure further progress toward promoting economic growth while maintaining
environmental quality. The goals are as follows:
1. Assure a safe and reliable supply of energy to meet reasonable consumer needs.
2. Reduce the flow of energy dollars leaving the Bennington region by decreasing our reliance on non
local energy sources.
3, Reduce local per capita energy consumption while maintaining a desirable living and working
environment.
4. Increase opportunities to make energy choices and decisions at the local level.
5. Make energy choices that maintain or improve environmental quality.
7. Assure diversity in the energy mix so as to mitigate the impacts of a supply restriction in any
particular fuel.
8. Strive for the most efficient use of each energy source, matching the fuel to the end use.
9. Assure an equitable and affordable energy supply for consumers across all economic strata.
10. Stimulate public commitment to the above goals by formulating specific land use, transportation.
economic development, and housing policies and strategies.
8.1 Energy Conservation
65
functions more efficiently than other fonns of energy (such as in the cases of lighting or the operation of
motors).
A variety of fuels nuclear (uranium), fossil fuels (coal, oil), solar radiation, wood, water, and wind
—
—
may be used to generate electricity. The Central Vermont Public Service Corporation (CVPS) owns and
maintains the distribution facilities through which most of the region’s electricity is supplied. CVPS
obtains that electricity from a number of sources. The Vermont Yankee nuclear plant in Vernon supplies
some of the region’s electricity, while nuclear
1 coal, oil, and hydroelectric facilities from outside the state
provide the rest. Because of uncertainties associated with the supplies and costs of each of these energy
sources, it would seem prudent to obtain electricity from a diversity of sources and to pursue local
generating options. The value of such a course of action is reinforced by the very real environmental
concerns presented by nuclear (radioactive waste), fossil fuel (stack emissions, greenhouse gases, and
acid precipitation), and large hydroelectric (destruction of natural riverine and terrestrial ecosystems)
generating facilities.
Two projects have explored the possibilities of developing alternative electrical generating facilities in the
region. Green Mountain Power Corporation (GMP) tested two wind energy turbines on Mt. Equinox in
Manchester (after a failed attempt with older technology machines by another company). The GMP
project has been designed to develop and test prototype wind turbines that will reliably generate
electricity in the severe conditions that occur at high elevations in this northern climate. The turbines
experienced problems due to severe weather conditions and icing. New technology has been developed
that limits these problems. Little Equinox Mountain has been the home of various wind turbines since
1981. Most recently Endless Energy Corporation has pursued a potential wind energy project on the site.
Improved technology, tax incentives, and “green” electric pricing will continue to position wind energy as
an important renewable energy resource.
Another promising energy project that could be developed in the region using local natural resources is a
wood energy plant utilizing a technology that involves processing wood chips to produce gas that in turn
powers ajet turbine to create electricity. An adequate supply of wood exists in the region and
surrounding area to provide ftiel for this 20-megawatt facility. The resulting demand for low quality
timber wouLd also make efficient forest resource management more economically practical. Care must be
taken in siting such a power plant because of potential impacts associated with noise and truck traffic, and
in managing the forests that will provide the fuel for the plant. Nonetheless, if the technology can be
perfected, such a facility could be an important contributor to the region’s supply of electhcal energy.
A number of other facilities can help satisfy portions of the region’s electrical energy needs. Small local
hydroelectric facilities may be appropriate at some sites in the region. Preferably, hydroelectric facilities
should be located at existing dam sites to minimize new impoundments. Rivers and streams that support
important fisheries and other recreational uses should not be dammed to create hydroelectric plants.
Moreover, any hydroelectric project must be preceded by thorough environmental studies and designed to
minimize ecological damage; in particular, run-of-river mode operations are preferred over store-and-
release systems.
8.3 Policies and Actions
1. All practical energy conservation measures should be taken during the siting, design, and
construction or reconstruction of buildings; insulation standards recommended by the Department of
67
Many towns contain Class 4 town roads (Table 9-1). Because of concerns over liability and maintenance
requirements, towns may choose to either abandon ownership of these roads or downgrade them to trail
status. In the future, reclassification of such roads to trails, rather than abandonment, should be the
preferred option so that public access for recreation can be retained.
Scenic Roads:
The scenic roadways that wind through Bennington County are a fundamentally important element of the
region’s valued rural character. Wherever possible, these roads should be preserved in theft present state;
care should be taken to maintain their existing dimensions, surface, and roadside vegetation. It is possible
for municipalities to formally designate local scenic roads and adopt ordinances to protect their character.
Residential developments in areas served by scenic roads should be planned to minimize heavy use of
such roads and subsequent demands for improvement.
Following is a partial list of particularly scenic roads in the region that can, and should, be refined by
towns:
Arlington: River Road, Route 313, Maple Hill Road

Bennington: Carpenter Hill Road, South Stream Road, Vermont Route 9
Dorset: Mad Tom Road, Dorset West Road, Dorset Hollow
Landgrove: Town Highway #2, Forest Highway #3, Vermont Route 11
Manchester: River Road, West Road, Three Maple Drive, Wideawake Road
Peru: Vermont Route 11, Forest Highway #3
Pownal: Route 346, Witch Hollow Road, County Road, Brookman Road, South Stream Road,
Northwest Road
Rupert: Route 315
Sandgate: The Notch, Camden Valley Road, Sandgate/Beartown Road
Shaftsbury: West Mountain Road-LeClair Road-Murphy Hill Road, East Road, Trumbull Hill
Road, Potter-Montgomery Road, Myers Road, Cold Spring Road
Stamford: Vermont Route 8/100
Sunderland: Kelly Stand Road, North Road
Woodford: Vermont Route 9
Region: Route 7 from Bennington to East Dorset
The BCRC has worked cooperatively with the Windham Regional Commission to secure designation of
Route 9 as a Vermont Byway (the Molly Stark Trail). Because of the designation, funding was made
available to develop informational signs, brochures, and a website that enhances the experience of
traveling the highway while encouraging tourists to stay and enjoy the resources available in the area.
Parking:
There are some localized parking problems in the region, particularly in Manchester Center and
downtown Bennington. A shortage of parking not only adversely affects business in the area, but can also
contribute to traffic congestion. Two actions can help to limit the problem and perhaps even improve the
situation in the future: (1) strict adherence to site plan requirements for on-site parking (in areas where
73
centers and existing and planned development in rural areas. Investment for roads sewing remote
and mountain areas should be minimized.
3. Additions and improvements to the transportation system should be designed to minimize impacts on
residential areas and avoid the loss of parks and recreation areas, agricultural land, wildlife habitat,
and other important natural resources.
4. All new road construction should be consistent with limitations imposed by topographical conditions,
natural areas, and areas having special resource value.
5. Residential development should be designed to avoid direct access to major roads from individual
lots.
6. Commercial and industrial developments should provide adequate parking and include provisions for
safe and efficient vehicular ingress and egress. Adjacent commercial or industrial uses should make
use of common parking and access drives, and other appropriate access management techniques.
7. Commercial truck routes should be planned to minimize conflicts with local traffic and impacts on
residential neighborhoods.
8. Scenic roads should be maintained for their scenic value while providing safe access for residents.
Road construction and maintenance should be consistent with scenic values (width, alignment,
roadside vegetation, etc.).
9. At interchanges of Route 7 and arterial highways, full control over access should be secured for a
distance of 700 to 1,000 feet from the onloff ramps. Land uses at interchanges must be carefhlly
regulated to avoid undesirable congestion and clutter.
10. Highway construction and reconstruction projects should be designed to accommodate bicycle use.
11. Encourage the development and maintenance of safe pedestrian pathways in villages, hamlets,
neighborhoods, and all areas of concentrated residential or commercial development. Traffic
calming techniques also should be used in these areas to reduce vehicle speeds and enhance safety.
12. Towns should ensure that plans for state highways are not contrary to their municipal planning
objectives, and that plans of adjacent municipalities are compatible with their own.
13. The BCRC adopted a position statement concerning regional rail improvements on November 19,
1998, and that statement is included by reference in this plan. The conclusion of that statement reads
as follows: .It is both feasible and appropriate to undertake the improvements necessary to restore
“. .
effective passenger and freight rail service to the region.”
14. Towns may want to utilize mechanisms such as impact fees and the adoption of minimum levels of
service standards to ensure that new development does not adversely impact local transportation
infrastructure.
15. The BCRC should assist towns that wish to develop capital plans, impact fee schedules, or level of
service standards.
76
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Beaver Wood Pownal 248 Filing: No. 8A - Pre-Filed Testimony of David Raphael SD

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Beaver Wood Pownal 248 Filing: No. 8A - Pre-Filed Testimony of David Raphael SD

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STATE OF VERMONT

PUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pownal, LLC

2. Summary of Findings Error! Bookmark not defined.

3. Conclusion Error! Bookmark not defined.

Petitione(s Exhibit DR-i Resume of David Raphael

Petitioner’s Exhibit DR-2 LandWorks Report

Petition of Beaver Wood Energy Pownal, LLC

1. IntroductionError! Bookmark not defined.

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

3 Al. My name is David Raphael. and I am a Professional Landscape Architect and

4 Planner as well as Lecturer in the School of Natural Resources at the University

5 of Vermont. I am the Principal and owner of LandWorks, a multi-disciplinary

6 planning, design and communications firm based in Middlebury, Vermont. My

8 Q2. Please describe your educational background and professional experience.

10 Massachusetts Department of Environmental Management. I have been

Pownal Biomass Project, PSB Docket No.

1 planning, graphic communications and GIS mapping, permit planning,

2 participatory and community planning, downtown revitalization, open space and

3 conservation plamilng, zoning ordinance and design review development.

4 landscape architecture and environmental design. At LandWorks we have

5 worked as advocates for communities, appellants, the State of Vermont, and

6 private corporations. I personally have testified and served as an expert witness

8 Environmental Board, as well as the Public Service Board.

9 LandWorks has extensive experience with regard to visual assessment and

11 utility facilities and structures. We have evaluated the aesthetic and

12 environmental impact of (1) transmission lines and corridors (including the

14 removal along the Route 2 causeway in MiltonlSouth Hero); (2)

15 telecommunication facilities (Coy Mountain tower proposal and four

16 telecommunications facilities in Essex and Milton. Vermont proposed by

17 FairPoint Communications): and (3) wind energy development, the Searsburg

21 Commission. I have served as a member of the Design Issues Study Committee

22 appointed by the Secretary of the Agency of Natural Resources, an initiative

2 resulted in the publication of Vermont’s Scenic Landscapes: A Guide for Growth

3 and Protection. in addition, we have prepared a number of zoning ordinances

4 based on scenery preservation and environmental protection guidelines (such as

6 highway corridor studies (Interstate 91 in Brattleboro, The Molly Stark Byway

II 345kv Compact Line Design, Chapter 9. A copy of my resume is attached as

12 Exhibit Petitioners DR-i.

13 Q3. What is the purpose of your testimony?

16 report. My report, attached hereto as Petitioner’s Exhibit DR-2, is now complete.

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

18 (the “Project”) satisfies the requirements of 30 V.S.A. § 248(b)(1) and (5),

19 namely those pertaining to aesthetics, orderly development of the region, public

20 investments, and historic resources.

3 Dockets 6860 (Northwest Reliability Project), 7032 (Lamoille County Project),

7 (Kingdom Community Wind Project), and on behalf of Georgia Mountain

8 Community Wind, LLC, Docket 7508.

12 A5. Yes. On Friday, October 8. 2010, we visited Pownal to reconnaissance the

16 visibility, and we have reviewed a 3D model to confirm that visibility.

17 Q6. Please describe your analysis and conclusions.

20 criteria of 30 V.S.A. 248(b). As set forth in the report, my analytical methods

21 include visual and cartographic analyses. document research and review.

Pownal Biomass Project, PSB Docket No.

3 value and/or official designation as a cultural, aesthetic or recreational facility or

4 resource. Locations that involve residential areas in close proximity to the

8 I conducted my Project aesthetic analysis within the parameters set forth

10 projects, including the Quechee Analysis, established in the 1985 Environmental

13 of projects within its jurisdiction.

14 By way of summary we conclude unequivocally that the Project, if

18 community standard; and 3) the Petitioner has taken reasonably available

Pownal Biomass Project, PSB Docket No.

2 Project is proposed for commercial and industrial development and encourages