ML061730169

Glebe Mountain Wind Energy, LLC Wind Energy Project

ML061730169
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	12/01/2004
From:	Charlebois R Glebe Mountain Wind Energy
To:	Matteau J Office of Nuclear Reactor Regulation, Windham Regional Commission
References
%dam200611
Download: ML061730169 (16)

Text

-Glebe Mountain Wind Eneray, LLC Members:

Catamount Energy Corporation' Marubeni Power International, Inc.

COley Delivered By Hand Mr. James Matteau, Executive Director Windham Regional Commission 139 Main Street Brattleboro, VT 05301 k-l

~rJ7wýk~~w Re:

Glebe Mountain Wind Energy, LLC Wind Energy Project

DearJim:

As discussed, and in accordance with Subsection 248(f) of Title 30, Vermont Statutes Annotated, this letter provides notice to the Windham Regional Commission (the "Commission") that Glebe Mountain Wind Energy, LLC, (the "Petitioner" or "GMWE") an affiliate of Catamount Energy Corporation and Marubeni Power International, Inc., proposes to construct a 47.5 megawatt

- (MW)-wind energy project (the "Project") to be located on Glebe Mountain on lands owned by-.

Magic Mountain Management, LLC and the McGraw Family Partnership, L.P.- in Londonderry and Windham, Windham County, Vermont. The Project will consist of approximately 19 individual wind turbines, with the final number and location of the turbines subject to the turbine technology ultimately selected for the Project and final engineering design necessary to achieve the proposed 47.5 MWS. The Project will also include an approximately 5,8 mile long 34.5, kilovolt (kV) electrical transmission system, a substation that will provide an interconnection to the existing electric transmissi6n system of Central Vermont Public Service (CVPS),:....

construction access and seivice roads, and an administration building that will serve as the Project's Operation and Maintenance (O&M) Center (the "O&M Building"). The Petitioner is submitting its Plans for the Project so that the Commission can evaluate whether the Project will unduly interfere with the'orderly development of the region.

The following Attachments are enclosed with this letter: -. Overall Facilities Plan - Preliminary Site Plan - Vicinity Map - Substation and O&M Facility Plan,- Typical Roadway Cross Sections - Potential Viewshed Impact Map - Typical Photo of Overhead Transmission Line Below follows a general overview of the Project. Please note that the construction dnd other';

details of the Project are subject to modification pending the permitting process and final construction plans.

71 Alien Street, Suite 101 - Rutland, VT 05701-4&70

• Phone: 802f773-6684

• Fax:'802/772.6799

Glebe Project Overview

1.

Project Energy and Economic Benefits The Project will provide a reliable, sustainable and cost-competitive energy source that may help stabilize electric prices in Vermont, including the communities surrounding the Project. The proposed Project will also result in direct and indirect economic benefits to the state and local communities through the creation of jobs, expenditures for construction and operation, and property tax and lease payments. The electric energy that will be generated by the Project is a non-polluting and renewable source of energy. At any given moment in time, electricity is a "zero-sum" game. To match demand, there must be just enough. and not too much power being produced on the grid.

Thus, whenever a kilowatt-hour of pollution-free wind energy is produced, other types of electric generation are avoided. Through generating energy with zero emissions, the Project reduces the amount of carbon, nitrogen and sulfur oxides in the, air that would otherwise be released by other electric generation facilities in the region. Moreover, increasing the region's reliance on wind energy dampens the exposure of energy customers to price fluctuations.

Details regarding the Project are provided in the following sections.

2.

Project Description 2.1 Wind Turbine Array The wind turbine array will be located within a 1200 foot wide Project corridor that extends approximately 3.7 miles along the Glebe Mountain ridge. However, the area of initial earth disturbance would be limited to approximately 1 acre at each turbine site depending on the existing terrain. Tree clearing associated with each turbine site will be approximately 2.2 acres with a total of approximately 42 acres of clearing. In addition, the construction-access and service roadways will require clearing of approximately 80 acres and earth disturbance of approximately 65 acres, primarily within the Project corridor along the ridge. A few other areas will be temporarily disturbed for equipment storage and laydown, and stormwater management; these areas will be restored following completion of construction.

The proposed wind turbines are three bladed horizontal-axis wind turbines with-the rotor mounted upwind of the nacelle. The nacelle is the cabin located on the top of the tower that contains the gearbox and generator. The blades are approximately 153 feet long and, when mounted on the rotor hub, provide a rotor diameter of approximately 315 feet. The tower is a four section conical steel tower providing a hub height (height above the ground to the center of the rotor) of approximately 262 feet. The overall height of each turbine from the ground to the tip of the blade in the upright position is approximately 420 feet.

A typical wind turbine generator layout and a diagram of a typical wind turbine is provided on Attachment 2 -

Preliminary Site Plan.

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The Project must comply with all applicable Federal Aviation -Administration (FAA) regulations including Subpart B of. Part,77 of Title 14 of the Code of-Federal -.Regulations "regarding installations close toairports arid lighting guidelines. - The Project will incorp6rate the minimum

• number of pilot warning and 'obstructi6n avioidancelighiinkImarking"as required by the FAA Advisory'Circular.AC 70/7460-1K "Obstruction 'Marking and Lighting" guidelines, inchiding recently: developed'wind park lighting standards. The 'new standards are: less stringent and are aimed-at -reducing overall lighting impacts.of wind projects, 'as compared to the current guidelines which.recommend that each wind turbine be equipped with two medium intensity flashing dual beacons (L-864 red at night and L-865 white during twilight and day)affixed to the top of the nacelle at an elevation approximately 280 feet above ground level. The Petitioner is

'committed to -working vi_'th i_ FAA in anfeffort to minimize the_overall lighting impgats. 9f the-

Project.'

2.2 Electric Facilities 2.2.1' Eletric Transniission'Facilities A critical colmpionent 'of the Project will, include: an approximately 5.8 mlile' long, 34.5.

kV electrical collection/transmission system to -connect the wind turbine'"array to 'the new

-- substation----and- -6

-... CVPS!---existing -- electric-tranrsmission-' -system.. --:-The -- eletrical collection/transmission system will' consist 'of two overhead collection/triansmission circuits, totaling approximately 3.7 miles in length,-with one circuit 'starting "at the north 'and the other starting at the south end of the turbine array. These 34.5kV transmission circuits will connect the

-individual turbines and meet-in' the-middle of the turbine array approximately at-the top of the Magic Mountain Ski Area. The two transmission lines will typically be*' installed within 'the corridor of the access road. From the top of the Magic Mountain Ski Area the two circuits will be run'undergrond :forapproximately 1.6 miles along ýKidting` workiroads a'nd ski trails to'.the existing CVPS'distributioi line located near the baie of MagicMountain: The transmission line

'will 'then be 'installed aboe. ground for' 'approximately 0.5 miles al6rig the existing -.CVPS distribuition right-of-Way, adjacenit to the* Magic MouhtainAccess Road," to the substatioin'site.

'The transmission.; line' will-"'re'quire an 'approkimnately':50 foot wide' easement.' The estimated temporary: eonstriictien disturbance 'for the uniddrgoundr-tansmission" -lines will be approximately 2 acres. The overhead transmission lines will be placed within the roadway disturbance corridor to ininimize impad' *to the area. -' In' certain areas along,the ridge -the

• overhead gathering system may deviate from the service road corridor to facilitate construction and. tfranspert.'ixceuirements2 "--These -off-road '1cations wvill be minimized and 'field verified as mioreble'tails'of the 'Project are7'estiblished.- In addition, the existing 'CVPS 'distribution system willb'e&6 ov0erbuilt to a-46 'kV systemrhfrofm the Project gubstation'to' the' CVPS.tLondondehfy substaiio or Iswitching 'station'as determined by the NEPOOL Interconnection Studies, utilizing the existing CVPS distribution of-way.

2.2.2 Electrical Substation A iiewv ubstaiion will be constructed 'on an -approximately 10-acr6 site located&-adjacent to the O&M bui-ilding 'as shown on'Attachmrenits I -'Overall'Facilities Plan'and 2 -Prfelimfiinary Site Plan."'The'new substation will provide'an inter'co'nection between the'ind turbine array and 3

CVPS' existing transmission system. Final design of the substation will be in accordance.with NEPOOL and CVPS specifications resulting from the Interconnection Studies presently being conducted.

The preliminary layout of the substation and control building is shown on - Substation and O&M Facilities Conceptual Layout Plan.

As shown, the substation would be approximately 90 feet by 140 feet. The final design, including lighting and landscaping details, will be determined following completion of additional studies. Total construction disturbance for the substation and O&M Facility will be approximately 2 acres.

2.3 Operations and Maintenance Building It is expected that operationand maintenance of the proposed Project will require four to six administrative and maintenance personnel who will work out of the proposed O&M building to be constructed near the intersection of the Magic Mountain Access Road and Route 11 as shown on Attachments 1 -- Overall Facilities Plan and 2 - Preliminary Site Plan. The O&M building will include offices, a storage area, sanitary facilities, and the O&M center. The one-story O&M building will be approximately 36 feet in width by 72 feet in length. It will include six off-street parking spaces and on-site water supply well and septic system. The Petitioner will apply for a Water Supply and Waste Water Permit from the Vermont Agency of Natural Resources (ANR) and will submit detailed plans regarding the specific location and design of the water supply well and on-site-septic-system to-ANR as-part of that permitting process. The O&M. building-area (including the parking spaces, water supply well and septic system, as well as the building) will be standard commercial construction and will be designed and constructed in accordance with local and state building codes.

3.

Construction Procedures Construction of the Project will follow a standard sequence of construction activities that have been demonstrated to minimize construction-related impacts. Specific construction procedures are described below for each component of the Project with the recognition that construction of individual Project components (e.g., wind turbines, transmission line, substation) may occur concurrently. The following information is conceptual and provided for informational purposes only; further detail will be developed as the Project progresses through final design.

3.1 Stormiwater Management and Operational Stormivater Permitting The Petitioner will apply for and obtain coverage under General Permit 3-90B5 (Stormwater Discharges for New Development and Redevelopment to Waters That Are Not Principally Impaired by Collected Stormwater Runoff (the Stormwater Discharge Operating Permit) from ANR for the discharges of stormwater runoff from the Project. Detailed plans, hydrology calculations, and supporting documentation will be prepared to address stormwater management and demonstrate compliance with applicable ANR guidelines and standards.

The west side of Glebe Mountain drains to Lowell Lake Brook (also known as Thompsonburg Brook). The north end of the east side of Glebe Mountain drains to the Middle Branch of the Williams River. The south end of the east side of Glebe Mountain drains to Cobb Brook. The east side of Glebe Mountain is developed to a lesser extent than the west side. The State has 4

designated the Cobb Brook watershed as Class A(1), the highest rating. Project design has recognized this by minimizing the extent of Project activities within this watershed. On a Project wide basis, the operational phase stormwater management plan will ensure that there is no increase in peak discharge to any of the receiving.streams for stormwater discharges. 'In addition, the stormwater management plan will provide for water quality treatment in accordance

'Lwith" the Vermont Stormwater Management Manual to protect existing water: quality in the

-receiving streams...

3.2 Storntiwater Permitting During Construction Construction of the "Project will result in the.disturbanceof more fthan 5.acres of land. Therefore, a permit fdr the discharge of storrnwater during construction is required,: under ý the NPDES Construction Stormwater Program, which is administered in Vermont by ANR. Further, projects located in Class A watersheds (waters above elevation 2,500 feet, or individually so designated) trigger the need for an Individual NPDES Permit. The Petitioner will apply for an Individual NPDES Permit to authorize construction phase stormwater discharges from the Project site.

3.3 Cotistruction Access anid Service Roads

...- The-movement of-construction-equipment, materials and-the.wind turbine components to each of the 19 wind turbine ýsites Will' require the constructioýxi':of access'and 'service roads 'capable 'of handling'thle-relevant truck weights,' 'dimensions and turning radii. The construction 'access and

- seirvice roads anticipated for'the 'Project will be gravel surfaced rroads. Access to the Project site

-. will 'b6 'directly off-Route approximately:0.5 miles to: the-West of the intersections -of Routes I Iand 121 as shown on:Attachments 1'- Overall Facilities'*Plan and 2'- Prelirhiary Site Plan.

The service road will extend 'from the access road along the Glebe -Mountain ridge to provide "access to each of the approximatel 19 "wind turbine sites.*

• Generally, the 'construction access and 'service roads will' have a finished surface width'of approximately 35 'feet including ýhoulders on either' side: of the roadway in the turbine area along the ridge to facilitate movement of the erection cranes. Following completion of construction,

• thes -shioulder' areas "wiil 'be"'re-vegetated, leaving' a final mniintenahce"' road, width 'of

ý'approxiriately' 16 feet> AAiypical roadway cross sectioi'i is provided as Attaclhient 5.

Byproperly lo6catinig the construction access and service road system,'the environmental i"mapacts to'existing viegetriti6n, water and soil res'burces willbe minimized. Basic 'considerations ielative to:'the location 'of the iccess '-and 'service roads will include "m.nimizing :tle im' pact on envirinmentally s

ve6siti, features (e.'g. wetlands 'and significant wildlife 'habitats)' faceilitating

, future maintenance activities; maximizing erosion control; and utilizing existing cleadred' aieas wherever possible. Erosion prevention and sediment control measures will be designed in accordance w*ith ANRgueln-to'""*"

withain the '"cwithd stomaintain And proteet the 'sbil'aind 'water resources'lo6cated witin'the access and service: road rights-of-way' during and after construction. These guidelines willinclude, but 'not be limited to, 'c6nsideration of the';folowing: timing of coinstru6tion; accessibility; movement".of construction 'traffic within the right-of-way at"stream. crossings; heavy equipment operation; ahd design of access ahd :service roads (cut and fill, waterbar, bridge and culvert installation).

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3.4 Wind Turbine Erection 3.4.1 Heavy Equipment Transportation During construction, an increase in heavy truck and haul traffic will be experienced in the Project area, and close coordination with state, county and local officials will be pursued to facilitate the delivery of oversized equipment to the Project property. The turbine components will be brought to the Project site by truck. The services of a transportation logistics specialist will be retained to ensure that the existing roadways and proposed access and service toads are designed to accommodate the height and weight requirements associated with the turbine components. The transportation logistics specialist will also identify what improvements, if any, will be required to accommodate construction activities.

3.4.2 Turbine Erection Details Each wind turbine will be located on a foundation specifically designed as a result of geotechnical analysis across the Glebe Mountain ridge. A typical foundation used, however, is called a spread footing mass foundation design. This is a shallow foundation design that relies on the mass-incorporated-into the foundation to provide-a-stable. base to the-turbine.

This foundation design only requires a shallow excavation. The need for blasting, if any, will be evaluated on a site-specific basis using geotechnical analyses. For the mass foundation, the base of the foundation is leveled and compacted. A seal slab of concrete is poured, and the rebar to provide integrity to the concrete mass is assembled in the excavation. Forms are placed around the rebar, and the base of the foundation is poured. A temporary batch plant may be established locally if there is no local source capable of supplying the volumes of concrete required or if transportation volume or distance is excessive. Spoil from the excavation is placed over the foundation base and compacted to bring the ground level back to finish grade, with the weight of the soil on the base part of the foundation design. The final area around the turbine foundation will be sloped away from the turbine foundation and finished with a gravel surface.

The area around the foundation is then prepared for the assembly and erection of the wind turbine.

This involves installing a crane pad, a level area adjacent to the foundation for placement of the erection crane during the erection process. The typical crane pad and turbine assembly area are shown on Attachment 2 - Preliminary Site Plan. As illustrated, the area within a radius of 175 feet will be cleared with stumps remaining. An inner radius of approximately 75 feet will be cleared and grubbed, graded and groomed to facilitate staging and rotor assembly including the blade areas. The crane pad is constructed in a manner similar to the construction access road.

Erection of each wind turbine will require a 200 to 400 ton class crane. A crane of this size will arrive on-site in about 10 to 12 truckloads. It typically takes four to seven days to assemble the crane on-site. Several cranes will be used at the Project site, including lower rigged cranes for the base and lower mid-tower sections and full height cranes to complete the turbine erection.

Once the tower reaches its maximum height, the nacelle is lifted into position at the top of the tower.

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The rotor is assembled in the laydown area adjacent to the'tower foundation prior to the arrival

- of the high rigged erection crane. Before lifting the rotor intoplace, the erection crane is used to move the rotor into position at the tower base after all tower sections have" been installed.-The lifting connection to the rotor hub is then changed to facilitate rotating the rotor to a vertical plane as it is lifted. A small crane is used to keep the lower blade off of the ground as the rotor rotates to a vertical position. The rotor's large surface area and relative low weight makes it easy

ýfor winds to move the rotor during the lift; therefore'6 tag'lines are attached to truck-mounted brakes to provide the necessary control. After the rotor is bolted to the main shaft in the nacelle,

-the final wiring and connections are made to the nacelle and rotor and the turbine is tested. This includes the connection of the powei cables from the control equiprment located inside'he'thower through sweeps in the concrete foundation to the pad-mounted transformer adjacent to the exterior of the tower.

3.5 Transmission Line Construction Construction of overhead electrical collection/transmission lines will be coordinated within the clearing and earth disturbance limits of the roadway along the 'ridge, line. areas. Where; the overhead and underground transmission lines deviate from the roadway clearing/disturbance

-corridor such areas willbe cleared as needed. Construction access for-the transmission -line-will.

be provided with the cleared right-of-way, but the requirements for this type of facility will not necessitate a stabilized (i.e., gravel) access road. The overhead gathering system (on the ridge)

'will consist of two 34.5 kV.circuits located on wooden mono-pole structures which will collect

--the electricity fromeaich-of-the-19 wind turbines,--The transmission lines -will-proceed-down the

,mountain buried underground to the existing CVPS distribution network at the bottom-of the mountaifi at which point the lines will continue overhead.to thenew Project substation utilizing CVs existing right-of-way and infrastructure. Attachment 7 provides a typical photo of a 34.5 kV overhead collection/transmission line similar to that prioposed for the Project It is envisioned that some upgrades to the existing infrastructure will be necessary but the Petitioner will not know :the full extent until NEPOOL Interconnection 'Studies 'are completed. '-The underground lines 'will be buried along 'existing work r6ads and ski trails utilizing a commercial trenching machine which digs, places in cables, and backfills the trench in one process.

The Project substation will'include a transformer that will step up the 34.5 kV. Project voltage to CVPS's local transmission voltage of 46 kV. The Project generated power will then be delivered to CVPS's existing substation or switching station as determined by

• the,.NEPOOL Interconnection Studies via existing CVPS infrastructure and right-of-way. This infrastructure will require upgrades, but the Petitioner will not know the extefit 6f the upgrades until further

-NEPOOL Interconnection 'Studies are completed.

These. upgrades may include'the existing

' CVPS Londondetfry'and Rawsonville substations and infrastructure.

3.6 Substation Construction Construction of the proposed substation will entail activities similar to those described above including: site clearing; site grading; erosion and sedimentation"control installation; foundation installation; structure erection and equipment installation; conductor stringing; and clean-up and 7

restoration.

Site preparation will include site grading and the installation of equipment and building foundations. A layer of clean fill and crushed rock will be spread over the entire area to level the site to finished grade for proper drainage. Any disturbed areas not located within the substation fence will be seeded.

3.7 O&M Building Construction Construction of the O&M building will entail typical construction techniques for commercial buildings that will include: site clearing; site grading; erosion and sedimentation control installation; foundation installation; building erection; heating, ventilation and air conditioning (HVAC), plumbing and electrical installation; interior finishing; site restoration; and landscaping.

3.8 Clean-up and Restoration Clean-up and restoration activities will be conducted as construction of each Project component is completed.

This work may include: regrading; temporary and permanent seeding and mulching for erosion control; and landscaping.

All permanent seeding and tree and shrub planting work will be conducted during the growing season.

3.9 Construction Schedule Site preparation for and construction of the Project will not commence until all necessary permits and approvals have been obtained. It is estimated that it will take 9 to 12 months to construct the Project, not including the lead time required to order equipment (including turbines, towers, blades and transformers) and services.

4.

Operation, Maintenance and Removal of Improvements Long term operations of the Project will be under the direction of the Petitioner. The four to six staff persons operating out of the new O&M Building will conduct the necessary O&M of the Project. Control systems housed in the O&M Building will manage the continuous collection of data from the Project's wind turbine generators. The control system will also manage and execute the communications between the control center and each wind turbine.

4.1 Security Operational personnel will be trained to ensure the Project has sufficient security measures in place. A fence will surround the substation and switchyard area. One gate will provide access to the facility yard, restricting access to this area.

The gate will be locked during normal operations, with access provided by facility personnel.

Low wattage security lighting and emergency temporary lighting will be installed in the O&M area (the O&M building and substation). Depending on the O&M agreement, the Project could operate one or two shifts (8 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per day). Operational personnel would be on-site during operational hours, and the staff would rotate through a 24/7 on-call work schedule.

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I 4.2 Stormwater Management As discussed above, the Petitioner will apply for and obtain coverage under.General Permit 3-9015 (Stormwater Discharges for New Development and Redevelopment to Waters That Are Not Principally Impaired by Collected Stormwater Runoff (the Stormwater Discharge Operating Permit) from ANR for the discharges of stormwater runoff from the Project.- A condition of the permit will be that the stormwater collection, treatment, and control system be inspected at least

'. semi-annually, and that copies of the inspection reports be forwarded to ANR. This ensures that the system is maintained and operating as designed.'

With the exception of transformers, no equipment.or-operational materials are used or stored on the Project property that could adversely affect stormwater runoff. The transformers at the substation and wind turbines, which contain cooling fluids, will be designed in accordance with applicable regulations. The SPCC Plan to be prepared by the Petitioner will specify inspection frequency and a preventive maintenance. - With secondary containment.these materials will be prevented from contacting stormwater runoff.

Temporary changes in the surface area during construction and permanent changes due to installation of turbine pads and access and maintenance roads could alter stormwater runoff patterns;- -The -final-Project design-will -attenuate post-development-peak-discharge -to -rates equal to or less than existing conditions.

The stormwater management features will discharge generated -runoff in a manner to prevent localized -soil erosion and transport of soil,..thereby minimizing -potential ý turbidity' -and/or, sedimentation.

Although the addition of impervious

-."surfaces -are :unavoidable,- the -localized -changes :in -surface -flow during -storms -is -expected -to be

-minor becausethe fouhidation area is small and the turbines are widely spaced.

~ 4.3 "'Emergency Response The Petitioner will consult and interact with appropriate local and county authorities and

' representatives to develop a Project! emergency response aplan., This will. ensure that the, plan addresses' local -issues -and doncerms.

Issues are anticipated to include:" site -access; on-site

• emergency personnel contact information; and emergency routes to and from -the site. : The plan will address local.ommunity service demarids anticipated -for the Project and will identify the

.service providers that are currently responsible for providing services to the Project site. These services include police protection; fire, and emergency medical services (EMS).-- -The ability of these providers to serve the proposed facility, either alone or in conjunction with a similar service provider will be assessed. Additionally, the plan will provide an inventory of community

- facilities (schools, hospitals, religious facilities, arid police, fire and emergency services),located within a one-.mile radius of the Project site.

4.4

-.Traffic Improvements',-

.PDuring the approximately -9 to -,12 month construction phase, of: the.Project traffic,will temporarily increase as a result of construction-related traffic:.Once the construction phase is completed, the proposed Project is expected to require approximately four to six O&M personnel. The proposed substation has been designed as an unstaffed facility.

Jn view of the 9

low existing traffic volumds in the Project area (other than during ski season) and the minimal increase that will result from the permanent jobs created by the Project, no permanent improvements to the geometry of existing roadways or intersections are expected as a result of the operation of the Project.

4.5 Removal of Improvements The Petitioner will be responsible for the removal of all improvements not needed or useful f6r future uses (such as the O&M Building) at the earliest to occur of the date the Project ceases operation or the expiration of the Project's Certificate of Public Good ("CPG"). The Petitioner will provide a surety bond or other acceptable financial instrument to ensure such removal.

5.

Potential Impact Overviewv Environmental and community issues have been considered in the Project design. The following provides a brief overview of considerations regarding: watercourses, wetlands, and streams; unique plant communities; critical wildlife habitat; aesthetics; historic and archaeological resources; noise; and orderly development of the region.

5.1 Watercourses, Wellands and Streams Watercourses within the Project areas have been field mapped. Site reconnaissance involved traversing the entire proposed route, encircling all mapped wetlands, and traversing the slopes on either side of the proposed route. Identified features included streams, skidder road ditches, anid wet areas that are within the proposed road route and up to approximately 600 feet on either side of the proposed road route center line, where possible. In general, mapped streams along the proposed route are limited to channels associated with skidder roads, as well as ephemeral dr intermittent steams, with the a few small perennial streams.

Wetlands have been delineated at the site within a 600-foot corridor, 300 feet on either side 6f the centerline of the turbine string as it was originally designed, as well as along the proposed access road from Vermont Route 11, as well as certain laydown or staging areas both on Glebe Mountain and near the base of the mountain. Wetland inspections have also occurred along the existing CVPS transmission line and near the existing CVPS substation. Streams have beeh identified throughout the Project site. Some additional areas will be revisited in the next field season.

In general, the wetlands on summit of Glebe Mountain are small and scattered, and their distribution is strongly controlled by the bedrock geology. Some are near others, and form groups or systems on the landscape, while many are quite isolated one from another. Many are in small "pockets" where drainage is impeded; but many are also at the very upper ends of seasonal or small perennial streams. The Project will be constructed and operated to minimize impact on wetlands, streams and other sensitive environmental area consistent with the Vermont Wetland Rules and Army Corps of Engineers requirements.

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S As stated above, the west Side of Glebe Mountain drains to Lowell Lake Biook (alsoknown is

,Thornpsonburg Brook).% The north endof the east side of Glebe Mountain drain 'io the Middle Branch of the Williams River. 'The south end of the eiast side'6fGlebe Mountain drains to Cobb Brook. The east side of Glebe Mountain is developed to a lesser extent than the west side. The State has designated the Cobb Brook watershed as Class A(l), the highiest rating. Project design has recognized this by minimizing the extent of Project activities within this watershed. On a Project-wide basis, the 'dperational phase stormwater management plan will ensuie that there is no increase in peak discharge to any of the receiving streams for stormwater discharges.- 'In addition, the stormwater management plan will provide for water quality treatment in accordance with the Vermont Stormwater Management Manual to protect existing.wat~r' quality in'the receiving streams._..

5.2 Unique'Plant Communities UniquePlant Communities, including any rare and any irreplaceable plants, have been delineated at the site Within the' areas to be'disturbed by the Project, TheProject will be constructed and operated to minimize the effect on'any stich unique plant communities.

5.3 Critical Wildlife Habitat -

The impact of the Project'on critical wildlife habitat and any endangered species his been' ;

evaluated,,with the Project designed to minimize stch' li ipact.1'Specifically-bea-and'dee'- feeding and habitat areas have been identified that could be potentially impacted by the Project and acoustical and oiher'sudi:have been -conducted to eivaliute and mfiigatet Project's-i, mpact on e

sae'h rq dc'imato migratory birds and bats.

5.4 Aesthetics As shown on the map depicting the Potential Viewshed Impact on the Project eh.lo'sed as, the wind turbines will potentially be viewed from a number of locations within a ten-mile radius of the ridgeline. The attached map accounts for topography and trees with assumed tree height of 40 feet, but does not account for other factors such as building and structures, actual tree height and density, site-specific vegetation and/or removal, variations in eyesight, atmospheric and weather conditions. Efforts have been made in-the design of the

Project to minimize the visual impact of the Project from surrounding locations, including a significant reduction in the total number of turbines from the original 27 to approximately 19.

5.5 Historic and Archaeological Resources The archaeological sensitivity of a project area is established through the application of Vermont SHPO's (Division for Historic Preservation) predictive model and some combiniationh"o6f background research, site visit, and consultation with knowledgeable individuals and organizations. Altogether, the process is known as an Archeological Resources Assessment (ARA).

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Based on the results of this ARA, the archaeological impact of the Project, if any, is being reviewed with input from the Vermont Division for Historic Preservation (VDHP) as to any appropriate actions that my need to be taken to mitigate such impact.

5.6 Noise Noise modeling is now being completed to identify anticipated sound levels from the proposed Project.

5.7 Orderly Development The Petitioner will review the comments and recommendations of the Windham Regional, Windham and Londonderry Planning Commission as to the Project's impact, if any, on the orderly development of the region.

This letter and its enclosures are provided to the Commission pursuant to Subsection 248(f),

which requires that the Petitioner provide the Cormmission with plans and notice at least forty-five (45) days in advance of the Petitioner's filing of its application with the Vermont Public Service Board under Section 248. Please also note the requirement under Section 248 (f) that the Commission "shall make recommendations, if any, to the Public Service Board and to the

[Petitioner] at least seven (7) days prior to the filing of the Petition with the Public Service Board." The Petitioner intends to file its Petition for the Project on or about March 1, 2006.

Please also note that the Commission has the right to review the Petitioner's proposal, either informally or by holding a public hearing. Also, the Commission has the right to participate in the Board's 248 proceeding as a full party, if the Commission so chooses.

If you have any questions about this notice or GMWE's proposal, please let me know. We look forward to the Commission's review of the within matters.

Sincerely, GLEBE MOUNTAIN ND ENERGY, LLC By:

Robe t..

ar ebois Its: Ma ager Enclosures c:

Vermont Public Service Board Vermont Department of Public Service McGraw Family Partnership, L.P.

Magic Mountain Management, LLC BRT.59568.I I 12

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