ML15096A467

Comment (17) by Anonymous Individual on NRC-2015-0004 Re Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report

ML15096A467
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	03/20/2015
From:	Windham Regional Commission
To:	Rules, Announcements, and Directives Branch
References
80FR1975 00017, NRC-2015-0004
Download: ML15096A467 (70)

Text

Paue I of 3 ,,. Y'.,:'CTIVES As of: 3/30/15 3:33 PM Received:

March 20, 2015* tus: PendingPost PUBLIC SUBMISSION 0:,i tacking No. ljz-8htv-kaoy Comments Due: March 23, 2015 Submission Type: Web Docket: NRC-2015-0004 Ff-'\/VD Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report Comment On: NRC-2015-0004-0001 Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report Document:

NRC-2015-0004-DRAFT-00 18 Comment on FR Doc # 2015-00450 Submitter Information Name: Anonymous Anonymous

/7'Address: 139 Main Street Suite 505 Brattleboro, VT, 05301 Email: wrc@windhamregional.org Submitter's Representative:

Lawrence C. Campany Government Agency Type: Local Government Agency: Windham Regional Commission General Comment The Windham Regional Commission (WRC) is writing to comment on the Site Assessment Study (SAS) and Post-Shutdown Decommissioning Activities Report (PSDAR). WRC is the regional planning commission that serves 27 towns in southeastern Vermont, including the 23 towns of Windham County, Readsboro, Searsburg and Winhall in Bennington County, and Weston in Windsor County. The Windham Region is the host region of the station. Through participation as a party in dockets related to Vermont Yankee before the Vermont Public Service Board, the WRC has for several years explored the issues surrounding the eventual cessation of operations at the station, whenever and for whatever reason that might occur. Through this effort we have established positions concerning the decommissioning and site restoration of Vermont Yankee in our regional plan. These include: Recognize the value of the Station to the region and state while it is operating, and that the general good would be best served if, upon cessation of operations, the Station is promptly decommissioned with complete site restoration so that the site can be reused and serve the orderly development of the region and state.Require that ENVY (Entergy Nuclear Vermont Yankee), ENO (Entergy Nuclear Operations), and Entergy Corporation be held jointly and severally responsible for all costs associated with operations, decommissioning, https://www.fdms.gov/fdms-web-agency/component/contentstreamerobjectld=090000648 1 a5521 c&for... 03/30/2015 Page 2 of 3 spent fuel management, and site restoration..

Require the prompt and complete' decommissioning and site restoration of the VY Station after shutdown (whenever that occurs) and prohibit the use of SAFSTOR. The best way to accomplish this is to ensure the decommissioning trust is adequate.Recognize the Decommissioning Cost Analysis prepared by TLG is inadequate.

Recognize the Decommissioning Cost Analysis and Decommissioning Trust Fund do not adequately account for the costs of removing all structures, reasonable property taxes, and additional elements identified by other parties. Entergy VY should fully fund the decommissioning trust to cover all potential costs associated with radiological decommissioning, spent fuel management, and complete site restoration without the use of SAFSTOR.Require Entergy VY to meet its MOU (memorandum of understanding) commitment to remove all structures as part of site restoration, rather than just removing structures to three feet below grade.Require Entergy VY to establish separate and adequate funds to cover radiological decommissioning, spent fuel management, and site restoration, and require substantial additional payments into those funds.Require Entergy VY to identify a suitable location for a second ISFSI (independent spent fuel storage installation).

Require Entergy VY to consider shifting spent fuel from wet to dry storage, or alternatively require a payment-in-kind into the decommissioning trust as if fuel had been moved.Require that Entergy VY provide funding to the decommissioning trust to cover all the costs of managing spent fuel.Require specific actions from Entergy VY to comply with its commitment to use its commercial best efforts to have the spent fuel removed from Vermont.We have also taken the positions that: Off-site radiological emergency planning and preparedness should be maintained until all spent fuel has been transferred to dry cask storage, and that the associated costs should be borne by Entergy but not by the decommissioning trust fund.The comments provided by the State of Vermont and Town of Brattleboro are consistent with our positions and we appreciate their engagement.

The GEIS (generic environmental impact statement) (NUREG-1437, Supplement 30 Vol. 1 and others) by which Entergy claims their PSDAR is "bounded" does not satisfy the requirements of the National Environmental Policy Act. In our comments we provide specific evidence that calls into question the NRC's small impact findings of the GEIS related to both socioeconomic impacts and environmental justice impacts.We further believe it is the responsibility of the NRC to assess the socioeconomic and environmental justice impacts under both DECON and SAFSTOR scenarios to fully characterize the impacts of the choice by Entergy to pursue the SAFSTOR option and present evidence to support this position.We understand that some citizens of our region may request that the NRC's period for public comment on the VY PSDAR be extended.

We would support an extension of the public comment period.Our full comments on the VY PSDAR have been submitted with referenced attachments.

Attachments Exhibit EN-RWH-3_Heaps Report https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectId=090000648 1 a5521 c&for... 03/30/2015 Page 3 of 3 Docket NRC-2015-0004 Windham Regional Commission Comments on Entergy VY PSDAR -DRAFT UMDI Economic Impacts VY Closure Dec2014 https://www.

fdms.gov/fdms-web-agency/component/contentstreamer?objectld=090000648 1 a5521 c&for... 03/30/2015 Exhibit EN-RWH-3 NORTHERN ECONOMIC CONSULTING, INC.PUBLISHING THE VERMONT ECONOMY NEWSLETTER SINCE 1991 The Economic Impact.of the VY Station on Windham County and Vermont Prepared by: Richard W. Heaps July 12, 2012 669 CAMBRIDGE ROAD 9 WESTFORD, VT 05494 * (802) 879-7774 -FAX: (802) 879-1691 email: rheaps@vteconomy.com

-web page http://www.vteconomy.com Economic Impact of the VY Station July 12, 2012 Executive Summary This study estimated the impact of the Vermont Yankee Nuclear Power Station (or "VY Station")

on the economy of Windham County and the state of Vermont under three scenarios.

The three scenarios are referred to as "2032 Prompt Decommissioning", "2032 Deferred Decommissioning", and "2013 SAFSTOR".

Details of these three scenarios are presented in reports prepared by TLG Services.At the end of 2011 there were 623 employees at the VY Station with a payroll of about $65.7 million. Under the 2032 Prompt Decommissioning and 2032 Deferred Decommissioning scenarios, the plant keeps operating until March 2032. Under the 2013 SAFSTOR scenario operations at the plant cease in 2013. The differing economic impacts from either of the two"2032" scenarios compared to the 2013 SAFSTOR scenario are very large, mostly because of the lack of operations from 2013 to 2032 with the 2013 SAFSTOR scenario.Comparison of the 2032 Prompt Decommissioning scenario versus the 2013 SAFSTOR scenario Over the period 2013 through 203 1, there would be an average of 1,085 more employees in Windham County with the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.

In the rest of Vermont there would be an average of 257 more employees with the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.Over the period 2012 through 2093, all Windham County employers, including the VY Station, would have a payroll that totaled $2,082 million (in constant 2011 dollars) more under the 2032 Prompt Decommissioning scenario than the 2013 SAFSTOR scenario.

In that same period, employers elsewhere in Vermont would have a payroll that totaled $296 million more with the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page i Economic Impact of the VY Station July 12, 2012 Over the period 2012 to 2093, Windham County residents would have a disposable income that totaled $1,596 million more with the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.

Elsewhere in Vermont, residents would have a disposable income that totaled $446 million more with the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.During the period 2012 to 2031, Windham County would see a population of about 400 more residents under the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.The State of Vermont would gain a total of $226 million more in general tax revenues over the period 2012 through 2093 with the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.Local governments in Vermont would see total property tax revenue $64 million larger from 2012 through 2093 under the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.Comparison of the 2032 Deferred Decommissioning scenario versus the 2013 SAFSTOR scenario Over the period 2013 through 2031, there would be an average of 1,085 more employees in Windham County with the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.

In the rest of Vermont there would be an average of 257 more employees with the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.Over the period 2012 through 2093, all Windham County employers, including the VY Station, would have a payroll that totaled $2,091 million (in constant 2011 dollars) more under the 2032 Deferred Decommissioning scenario than the 2013 SAFSTOR scenario.In that same period, employers elsewhere in Vermont would have a payroll that totaled$277 million more with the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.Over the period 2012 to 2093, Windham County residents would have a disposable income that totaled $1,514 million more with the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.

Elsewhere in Vermont residents would have a disposable income that totaled $427 million more with the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page ii Economic Impact of the VY Station July 12, 2012 EcnmcImato teV tainJl 12-21 During the period 2012 to 2031, Windham County would see a population of about 400 more residents under the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.The State of Vermont would gain a total of $231 million more in general tax revenues over the period 2012 through 2093 with the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.Local governments in Vermont would see total property tax revenue $62 million larger from 2012 through 2093 under the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.Northern Economic Consulting, Inc.Westford, Venront 05494 Page iii Economic Impact of the VY Station July 12, 2012 Table of Contents I. Introduction

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Page 1 II. The Vermont and Windham County Economies

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Page 2 III. Importance of the VY Station Today ...................................

Page 9 IV. Economic Activity with the 2032 Prompt Decommissioning Scenario ...... Page 12 V. Economic Activity with the 2032 Deferred Decommissioning Scenario ...... Page 15 VI. Economic Activity with the 2013 SAFSTOR Scenario ....................

Page 18 VII. Economic Impact of the 2032 Prompt Decommissioning Versus 2013 SAFSTOR Scenarios

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Page 2 1 VIII. Economic Impact of the 2032 Deferred Decommissioning Versus 2013 SAFSTOR Scenarios

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Page 27 IX. Appendix I -Methodology of this Analysis ............................

Page 33 Northern Economic Consulting, Inc.Westford, Verniont 05494 Page iv Economic Impact of the VY Station July 12, 2012 I. Introduction In April of 2012 Entergy Nuclear Vermont Yankee, LLC ("Entergy VY") asked Northern Economic Consulting, Inc. to estimate the economic impact of the operation and eventual decommissioning of its power station in Vermont ("VY Station")

under three scenarios.

I will refer to the three scenarios as "2032 Prompt Decommissioning", "2032 Deferred Decommissioning", and "2013 SAFSTOR".

Details of these three scenarios are presented in reports prepared by TLG Services.'

We provide an analysis of the economic impact from these scenarios in the following six sections of this report. In section II we review the current condition of the Windham County and state of Vermont economy. It is necessary to have an understanding of the local economy to grasp the magnitude of the economic impacts from the VY Station. In section HI we briefly discuss the importance today (in 2011) of the VY Station's employment and payroll to the local and state economy. An understanding of the impact today of VY Station makes it easier to understand the implications of decommissioning the plant at any future date.In section IV we present our estimate of the impact of the VY Station on economic activity in the county and state with the 2032 Prompt Decommissioning scenario.

We do the same in section V and VI with the 2032 Deferred Decommissioning and 2013 SAFSTOR scenarios, respectively.

In each case we measure the impact against the economy continuing to operate in the future as it is today. This makes it easier to understand the timing of the impacts from any of the scenarios.

Then in section VII we present the economic impact of the VY Station under the 2032 Prompt Decommissioning versus 2013 SAFSTOR scenarios by comparing employment, payroll, disposable income, population and tax revenues in the county and state. In the following section VIII we present the economic impact of the VY Station under the 2032 Deferred Decommissioning versus 2013 SAFSTOR scenarios.

A knowledgeable reader could skip directly to sections VII and VIII.The reader of this report should keep in mind that these are estimates of the likely future economic impact of the VY Station. We use the best estimation techniques available along with the current estimates of the future costs of the three scenarios to obtain our estimates.

However, they remain estimates and should be interpreted with appropriate care.See "Decormmissioning Cost Analysis for the Vermont Yankee Nuclear Power Station" of February 2012 and "Post Shutdown Decommissioning Activities Report Pursuant to Docket No. 6045 Sale Order" of June 2012, both prepared by TLG Services, Inc. Specific references to the materials used from these reports is given later in this report.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 1 Economic Impact of the VY Station July 12, 2012 II. The Vermont and Windham County Economies In order to fully understand the economic impact of the VY Station on the state and local economy, it is necessary to review the recent history of the economy's performance.

In this section we briefly present and examine the state's and Windham County's employment and income growth since 2000. In addition, we review the major demographic changes affecting the state and local economy in this period. Lastly we present a basic sketch of the Windham County economy.It is clear that economic activity in Windham County has significantly lagged that of the rest of Vermont. In addition, even as Vermont is a slow growing state from a demographic perspective, Windham County is even a slower growing area. This suggests that any major, negative economic impacts could be felt more acutely in Windham County than elsewhere in Vermont.A. Measures of Economic Activity in Vermont and Windham County 1. Employment and Unemployment The Vermont Department of Labor (VDOL)publishes an annual count of the number of Annual Employment Growth in payroll jobs at Vermont businesses.

This Windham County and Vermont includes about 80% of the state's employment, 3.0%excluding the self-employed.

The graph to the right shows the annual job growth from 2000 1.0%through 2011.2 Job growth in Windham County has lagged that of the state as a whole in nine of .2.%the last eleven years. In only one of those years -3.0% v did Windham County post a positive job gain. -4.oA .2001 2003 2005 2007 201 2000 2002 2004 2006 2008 2010 From 2000 to 2010, employers in the state of Vermont cut 3,400 jobs, a cumulative loss of 1.1%. However, in Windham County alone the number of jobs declined by 2,200, a cumulative decline of -9.0%. While total wages paid at all employers in the state grew by 35%, in Windham County total wages only grew 22%.-The estimate for 2011 is based on the change from the 3 rd quarter of 2010 to the 3 rd quarter of2011.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 2 Economic Impact of the VY Station July 12, 2012 EooiImac ofteV SainJly1,21 VDOL also publishes an annual estimate of the unemployment rate for the state and Windham Annual Unemployment Rates County. This is the most frequently used in Vermont and Windham Co.measure of economic hardship in the regional 7o.0.%labor market. The graph to the right shows the 6.0% -annual unemployment rate in Windham County 50%from 2000 to 2011. Based on the low job growth, it is initially somewhat surprising that Windham 30%County's unemployment rate has remained below 2.0%1.0%or equal to the state's rate during most of the 0 period under review. However, it appears that 2001 2003 2o00 20'0 200. 2011 2000 2002 2004 2006 2008 2010 this has been the case only because Windham County's residents have been able to find employment in neighboring Cheshire County, New Hampshire and Franklin County, New York.2. Wages and Income The third measure of economic activity we examine is wages and/or incomes. The VDOL publishes an annual average wage per job for the state and Windham County. This is shown below.Averaie Wame per Job 2000 2010 Change All Vermont $28,925 $39,425 36%Windham County $27,851 $37,335 34%In 2010, the average wage per job in Vermont was $39,425, up 36% from 2000. In Windham County the average wage increased slightly less, 34%, to $37,335.The above figure is the average wage from all jobs in Windham County. Because many county residents work outside the county, it is also illustrative to look at the resulting incomes of county residents.

This can be obtained from the Vermont Department of Taxes, based on data from the state's personal income tax. We examine the income for the median family in Vermont and Windham County, which is available for 2000 to 2010.According to the 2000 U.S. Census, about 4,000 of the 23,000 working Windham County residents worked outside the county. Over 1,000 crossed the river into New Hampshire's Cheshire County.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 3 Economic Impact of the VY Station July 12, 2012 Economic Impact of the VY Station July 12, 2012 Median Family Income 2000 2010 Change All Vermont $46,113 $57,665 25%Windham County $42,045 $49,744 18%In 2010, the median family income in Vermont was $57,665, up 25% since 2000. In Windham County, the median family income was $49,744 in 2010, up only 18% in the decade. It was about $8,000 (14%) less than the statewide median. The median family income in Windsor County was the fourth lowest of the fourteen counties in Vermont, only above the three Northeast Kingdom counties.Finally, the U.S. Bureau of Economic Analysis prepares annual estimates of personal income for states and counties.

Per capita personal income in Vermont was $40,134 in 2010. In Windham County it was $39,475, only 2% less than the statewide average. This is accounted for by the relatively higher amount of dividends and interest earnings plus transfer payments received by Windham County residents (suggesting a large number of retiree residents).

B. A Closer Look at the Windham County Economy In this section we briefly describe the Windham County economy and present measures of the importance of the VY Station to that economy. The Bureau of Economic Analysis (BEA)publishes estimates of employment (full and part time combined, including the self-employed) for counties.

We show the BEA nonfarm employment totals below (only 1% of Windham County employees work on farms).'All data are from the BEA except that for utilities, which isnot publicly available.

The utility figures are our estimates based on infonnation from Entergy VY and estimates for the small power producer'and four owners of transmission lines in the county.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 4 Economic Impact of the VY Station July 12, 2012 Employment and Compensation by Industry -Windham County 2010 Compensation Compensation Industry Employment Percent in 000s Percent per employee All 33,011 100% $1,093,699 100% $33,131 Utilities 500-999 -2% -S65.000 -5% -$100,000 Construction 2,558 8% $68,295 6% $26,699 Manufacturing 2,103 6% $121,492 11% $57,771 Wholesale trade 1,281 4% $63,605 6% $49,653 Retail trade 3,265 10% $78,679 7% $24,098 Real estate and rental and leasing 1,312 4% $11,440 1% $8,720 Private educational services 2,748 8% $82,546 8% $30,039 Health care & social assistance 3,883 12% $139,062 13% $35,813 Arts, entertainment, and recreation 1,044 3% $5,206 0% $4,987 Accommodation and food services 3,441 10% $75,709 7% $22,002 Other services, except public administration 1,944 6% $31,390 3% $16,147 Government

-federal 494 1% $28,195 3% $57,075 Government

-state 322 1% $18,520 2% $57,516 Government

-local 2,494 8% $113,329 10% $45,441 Based on employment, the Windham County employment is well balanced, without any heavy concentration in any one sector. There are eight industries with at least five percent of the county's employment.

Compensation is not nearly as balanced, with an obvious reliance on manufacturing, health care, and local government for earnings and benefits.According to 2000 U.S. Census data, Windham County employers drew 75% of their employees from Windham County itself.' Another 13% made the trip across the river from neighboring Cheshire County in New Hampshire.

A small percentage come from the other three counties that 5 This information was not collected in the 2010 Census.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 5 Economic Impact of the VY Station July 12, 2012 border Windham County: Bennington and Windsor Counties of Vermont and Franklin County of Massachusetts.

6 County of Residence of Employees of Windham County Businesses County of residence Number Percent Windham County, VT 18,833 74.9%Cheshire County, NH 3,196 12.7%Windsor County, VT 759 3.0%Franklin County, MA 668 2.7%Bennington County, VT 521 2.1%Other 1,154 4.6%Total 25,131 100.0%Finally, as demonstrated in the chart below, 82% of Windham County residents work in Windham County itself. Only 5% make the trip across the river to businesses in neighboring Cheshire County.County of Work of Windham County Residents County of residence Number Percent Windham County, VT 18,833 82.3%Cheshire County, NH 1,078 4.7%Windsor County, VT 740 3.2%Franklin County, MA 485 2.1%Bennington County, VT 475 2.1%Other 1,284 5.6%Total 22,895 100.0%6 Data on conmmuting patterns comes from the 2000 US Census and is based on a sample of all those surveyed.

Data on employment is from the Bureau of Economic Analysis which comes from state reports.Therefore, the number of conmmuters in the Census data does not equal the number of workers in the BEA data.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 6 Economic Impact of the VY Station July 12, 2012 C. Demographic Changes in Vermont and Windham County Population data for the state and Windham County is published by the U.S. Bureau of the Census. We review the demographic changes in Windham County for the years 2000 to 2010 below.1. Total Population From July 1, 2000 to July 1, 2010, the total resident population of Vermont increased from 609,618 to 625,960. This was a gain of 16,342 people or just 2.7% over the ten-year period.Vermont is one of the slowest growing states in the nation and during this period the annual growth rate steadily declined to just barely 0.1% or less per year.During the same period, the population of Windham County increased from 44,112 to 44,510.The increase equaled 436 or 1.0% in the ten years from 2000 to 2010. Windham County's population growth was less than half of that of the state as a whole and had basically stagnated after 2006.2. Working-Age Population.

For purposes of this report, we define the working-age population to include residents aged 20 to 64 years old. During the period 2000 to 2010, the Census Bureau estimates that the working-age population of Vermont increased from 365,493 to 384,578, a gain of 5%. All of this occurred from a gain in the number of older workers aged 45 to 64 -the Baby Boom generation.

The number of younger workers -aged 25 to 44 -actually declined during this period.The same trend occurred in Windham County, where the working-age population increased from 26,463 to 27,275, a gain of 3.2%. As with the state, the gain in the county was only from increased numbers of older workers aged 45 to 64. The number of younger workers aged 25 to 44 declined in Windham County.Northern Economic Consulting, Inc. Westford, Verniont 05494 Page 7 Economic Impact of the VY Station July 12, 2012 Economic Impact of the XW Station July 12, 2012 3. Over 65 Population Finally, the number of Vermonters aged 65 and older increased from 77,945 to 91,238, a gain of 17% from 2000 to 2010. In Windham County, the number increased from 6,199 to 7,214, a gain of 16%. This population age cohort will grow rapidly in the coming years with the aging of the Baby Boom generation.

Vermont is one of the oldest states in the nation, measured by the median age of its population.

In 2010 the median age was 41.5 years, up from 37.8 years in 2000. In 2010 Vermont was the second oldest state in the nation. In Windham County, the median age is significantly higher -44.9 years in 2010.4. Demographic Summary Vermont is a slow.growing state in terms of population, with very little growth expected for the coming years. The population is aging. While the working-age population is still increasing, that will soon slow and then begin declining (by 2012 is the forecast) as the Baby Boomers retire.Windham County population growth has essentially ended for the foreseeable future. Its workforce will soon begin to decline as well.From an economic perspective, a declining population generally means a declining demand from the regional market for goods and services.

A declining labor force means that it will be increasingly difficult for employers, particularly for those serving the broader U.S. or global market, to find the labor needed to operate efficiently in Windham County.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 8 Economic Impact of the VY Station July 12, 2012 III. Importance of the VY Station Today This analysis will measure the impact of the VY Station's operation on the Windham County and Vermont economies in the future, while the plant operates and is eventually decommissioned.

The impact is significant.

We briefly show why that is the case by presenting the VY Station's direct and indirect impact on the economy today (in 2011). This sets the stage for understanding the future impacts of the VY Station.A. The VY Station's Employment and Total Wages Today The VY Station's operations are located entirely in Windham County in southern Vermont.Entergy VY operates its nuclear power station in Vernon and a small training center in Brattleboro.

In addition, Entergy VY contracts out for a limited amount of construction work on the site which, from an economic perspective, adds to its total employment.

Lastly, the nuclear power plant routinely shuts down for refueling.

This occurs about every 18 months and brings in a large number of outside employees who are specialized in this process. The total employment and wages of the VY Station are the sums of the company's employment and wages, the on-site contracted employment and wages, and the periodic outage employment and wages. Because the potential impact from the outages is relatively small compared to the impact from the other employment, we exclude it from this analysis.7 The number and size of the payroll for the other two activities follows.The VY Station Employment

-In 2011 the VY Station had 623 employees working at the power station and training center combined.

In that year Entergy VY paid $65.7 million in wages and bonuses. The 2010 employees and payroll were nearly identical.

Contracted Employment

-In 2011 the contracted employment at the VY Station equaled just four people.The importance of the VY Station in the county's economy is demonstrated by the fact this one firm directly accounts for about 2% of the employment and about 5% of the compensation earned in Windham County. The VY Station's compensation per employee is higher than that of any industry in Windham County. In addition, the Vermont Department of Labor reports that the VY Station is one of the top five employers in Windham County.7 It should be noted, however, that the influx of outage workers for several weeks every 18 months does result in tangible short-term benefits for many local businesses, particularly in the restaurant and accommodations industries.

Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 9 Economic Impact of the VY Station July 12, 2012 B. The VY Station's Impact on Windham County's Economy Today Based on the above information we estimate the impact of the VY Station on Windham County's and Vermont's economy. We exclude the expenditure impact from the temporary employees associated with the refueling outages.The impact of the VY Station on the county and state economy is much greater than that due solely to its own payroll and that of its on-site contractors.

That is because much of the $65.7 million in payroll is spent locally and elsewhere in Vermont at other businesses, thereby creating additional jobs and additional payroll. This is known as the multiplier process in economics.

By use of a dynamic input-output model (REDYN) we estimate the following impact of the VY Station on the state and county economy.8 Total Economic Impact of the VY Station in 2011 Disposable Wages Income (in Jobs (millions millions of Created of 2011 $) 2011 $)Windham County 1,049 $84.5 $38.9 Rest of Vermont 244 $10.6 $15.5 Total Vermont 1,293 $95.1 $54.4 The total number of jobs created in Windham County in 2011 due to the operation of the VY Station equals 1,049 (of which 623 are Entergy VY employees and 4 are VY contract employees).

These jobs include 45 in retail trade, 75 in construction, 40 in accommodations and food services, 28 in health care and social assistance, and 59 in professional services among other jobs. Through the multiplier process, the VY Station accounted for nearly 5% of all the jobs in Windham County in 2011.The REDYN model is described in the Appendix to this report.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 10 Economic Impact of the VY Station July 12, 2012 Elsewhere in Vermont an additional 244 jobs exist today due to the operation of VY Station in Windham County. These jobs include 35 in retail trade, 27 in construction, 24 in accommodations and food services, 28 in health care and social assistance, and 29 in professional services among other jobs.The total number of jobs created in the state of Vermont by the VY Station's 623 jobs (at the plant and through contractors) equals 1,293. This implies an employment multiplier of 2.07. This relatively large multiplier is due to the high wages at the power station itself which generates the large multiple impact. (Note: additional jobs are created across the New Hampshire and Massachusetts borders, but are not counted in this figure.)The total payroll at all Vermont employers due to the operation of the VY Station equals$95.0 million (in 2011$). The total payroll at all Windham County employers equals$84.5 million. Payrolls at employers in the rest of Vermont equals an additional

$9.7 million due to the VY Station. Through the multiplier process, the VY Station accounted for nearly 11% of all the payrolls at employers in Windham County in 2011.Finally, disposable income of all Vermont residents is $54.4 million higher than otherwise due to the operation of the VY Station. Disposable income of Windham County residents is $38.9 million higher. Elsewhere in the state, disposable income is$15.5 million higher due to the VY Station.9 In summation, the operation of the VY Station in Vernon has a large and positive economic impact on Windham County and the rest of Vermont in 2011.In 2011 about 40% of the employees of the VY Station resided in Vermont with the remainder in New Hampshire (mostly Cheshire County) and Massachusetts (mostly Franklin County). Therefore, the payrolls from firms located in Vermont will be higher than the disposable income earned by households in Vermont because the former is by place of work and the latter by place of residence.

Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 11 Economic Impact of the VY Station July 12, 2012 IV. Economic Activity with the 2032 Prompt Decommissioning Scenario In this section, it is assumed that the VY Station continues operating as it is today through the year 2031.'° The plant then begins the decommissioning process. At the end of 2083 site restoration is complete and no activity or stnrctures associated with the VY Station remain.The economic activity during the operation of the VY Station through 2031 is estimated by assuming the current level of employment and wages (adjusted for real wage growth) at the VY Station continues into the future at the 2011 levels. That is, employment at the power station continues at 623 with a payroll of $65.7 million (in 2011 dollars).

Contract employment remains at just four employees.

Then from 2032 through 2083 the economic activity is measured by use of the annual expenditures presented by TLG Services, Inc.This scenario covers the period from 2012 through 2083, a period of 71 years. Because another scenario, the 2032 Deferred Decommissioning scenario, continues through 2093 we estimate the economic impact of the 2032 Prompt Decommissioning scenario also through 2093. The REDYN model allows estimation from 2012 to 2055. The activity at the VY Station during the period 2056 through 2083 is little changed from 2041 to 2055, so our estimate for that period is simply an extrapolation from the earlier period.The estimated future employment and wages of Windham County under this scenario are presented in the following graphs.0 The REDYN model which is used to estimate economic impacts is based on calendar year periods.Therefore, although a twenty year extension of the VY Station's license would allow it to operate until March 2032, for the purposes of this analysis it is best to assume it operates from 2012 to 2031 and ceases operations after 203 1.See the report "Decommissioning Cost Analysis..." prepared by TLG Services, Inc., dated February 2012. This section uses the estimate in Table 3.4.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 12 Economic Impact of the VY Station July 12, 2012 A. Windham County Employment 2032 Prompt Decommissioning The level of employment in Windham County over the period 2012 to 2093 is presented in the graphic below.Annual Employment in Windham County with 2032 Prompt Decommissioning 80,000 70,000 B 60,000//2032 Prompt 50,000 50,000 40,000 'o~sln Ioo o I ' 1 1 I I '2017 037 2047 2057 2067 2077 20871 2012 2022 2032 2042 2052 2062 2072 2082 2092 The baseline estimate for employment in Windham County is shown by the dashed line. It is based on the assumption that the VY Station would continue to operate indefinitely.

Generally, employment is forecasted to slowly increase over the entire period.1 2 After 2031, the VY Station ceases operating as a power plant in the 2032 Prompt Decommissioning scenario.

The employment associated with this operation is lost to Windham County and we see an immediate, large decrease in employment.

This decrease is somewhat moderated by the expenditures at that time estimated by TLG Services but not by enough to prevent a significant decline. From 2032 to 2037 when large expenditures would be occurring with the 2032 Prompt Decommissioning scenario, the employment decline is in the range of 650 to 900. The process continues through 2040, with a declining need for employees in the later years. Therefore, the employment loss in Windham County will be in the range of 1,200 to 1,350 per year.12 The baseline is the forecast for the county as prepared by the REDYN model. It is a more optimistic forecast than we would prepare. That, however, does not matter to this analysis as we are concerned about the difference in the impacts to the regional economy under two scenarios.

The difference in the impacts would be virtually identical if a less optimistic forecast was prepared as the baseline.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 13 Economic Impact of the VY Station July 12, 2012 B. Windham County Total Wages with 2032 Prompt Decommissioning The total wages paid by employers in Windham County over the period 2012 to 2093 is presented in the graphic below. Total wages follow the same path described above for employment.

Annual Wages in Windham County with 2032 Prompt Decommissioning

$ millions 8,000 7,000 6,000 Baseline 5,000 4,000 2032 Prompt 3,000 Decommissioning 2,000 201712027 203720147 2057 2067 2077 2087 2012 2022 2032 2042 2052 2062 2072 2082 2092 Total wages paid in Windham County increase steadily through 2032, then fall with the shutdown of the plant. The immediate decrease in wages from the end of operation of the plant is offset somewhat by the wages paid for the decommissioning process of the plant. From 2032 to 2037 the decline in annual wages is approximately

$90 million (in 2011 dollars).

By 2040 the full impact of the absence of VT Station is apparent.

The annual decline in wages is over $100 million (in 2011 dollars) from 2041 forward and grows with general real wage inflation.

Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 14 Economic Impact of the VY Station July 12, 2012 V. Economic Activity with the 2032 Deferred Decommissioning Scenario In this section, it is assumed that the VY Station continues operating as it is today through the year 2031. The plant then enters the SAFSTOR process as described in the TLG reports. At the close of 2093 site restoration is complete and no activity or structures associated with the VY Station remain.The economic activity during the operation of the VY Station through 2031 is estimated by the same method as in the previous section. From 2032 through 2093 the economic activity is measured by use of the annual expenditures presented by TLG Services, Inc." 3 This scenario covers the period from 2012 through 2093, a period of 81 years. The economic activity at the VY Station during the period 2032 through 2093 is compressed into the period 2032 to 2055 then extrapolated back out to the full period.The estimated future employment and wages of Windham County under this scenario are presented in the following graphs.'s See the report "Decommissioning Cost Analysis..." prepared by TLG Services, Inc., dated February 2012. This section uses the estimate in Table 3.5.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 15 Economic Impact of the VY Station July 12, 2012 A. Windham County Employment with 2032 Deferred Decommissioning The level of employment in Windham County over the period 2012 to 2093 with the 2032 Deferred Decommissioning scenario is presented in the graphic below.Annual Employment in Windham County with 2032 Deferred Decommissioning 80,000 70,000 60,000 50,000 40,000 30,000 2017 2027 203712047120571206712077120871 2012 2022 2032 2042 2052 2062 2072 208.2 2092 After 2031, the VY Station ceases operating as a power plant in the 2032 Deferred Decommissioning scenario.

The employment associated with this operation is lost to Windham County and we see an immediate, large decrease in employment.

This decrease is somewhat moderated by the expenditures at that time estimated by TLG Services but not by enough to prevent a significant decline. From 2032 to 2037 when large expenditures would be occurring with the 2032 Deferred Decommissioning scenario, the employment decline is in the range of 850 to 1,150. The employment loss in Windham County after 2037 will be in the range of 1,250 to 1,350 per year until 2086 when large expenditures associated with the 2032 Deferred Decommissioning scenario begin. From 2086 to 2093 the employment loss ranges from 650 to 1,200.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 16 Economic Impact of the VY Station July 12, 2012 B. Windham County Total Wages with 2032 Deferred Decommissioning The total wages paid by employers in Windham County over the period 2012 to 2093 with the 2032 Deferred Decommissioning scenario are presented in the graphic below. It follows the same path as the employment described above.Annual Wages in Windham County with 2032 Deferred Decommissioning S millions 8,000 7,000 6,000 6,000Baseline 5,000 4,000 2032 Deferred 3,000 Decommissioning 2,000 2017 20271203712047 2057 2067 2077 2087 2012 2022 2032 2042 2052 2062 2072 2082 2092 The wages associated with the VY station are lost to Windham County in 2032 and we see an immediate, large decrease in wages paid by all Windham County employers.

This decrease is somewhat moderated by the expenditures at that time estimated by TLG Services but not by enough to prevent a significant decline. From 2032 to 2037 when large expenditures would be occurring with the 2032 Deferred Decommissioning scenario, the wage decline is in the range of$93 million to $116 million. The wage loss in Windham County after 2037 rises to $125 million and grows with general wage inflation until 2086. From 2086 to 2093 the wage loss decreases by$5 million to $60 million from the trend.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 17 Economic Impact of the VY Station July 12, 2012 VI. Economic Activity with the 2013 SAFSTOR Scenario In this section, it is assumed that the VY Station ceases producing power at the end of 2012. The facility is placed and maintained in SAFSTOR and the entire decommissioning process continues through 2074. At the close of 2074 site restoration is completed and no activity or structures associated with the VY Station remain. The economic activity in this scenario is measured by use of the annual expenditures presented by TLG Services, Inc.1 4 This scenario covers the period from 2012 through 2074, a period of 62 years. The economic activity at the VY Station during the period 2032 through 2074 is compressed into the period 2032 to 2055 then extrapolated back out to the full period. In order to compare this to other scenarios, the estimation is carried out through 2093.The estimated future employment and wages of Windham County under this scenario are presented in the following graphs."4 See the report "Post Shutdown Decommissioning Activities Report..." prepared by TLG Services, Inc..dated June 13, 2012. This section uses the estimate in the table on page 15-16.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 18 Economic Impact of the VY Station July 12, 2012 A. Windham County Employment with 2013 SAFSTOR The level of employment in Windham County over the period 2012 to 2093 with the 2013 SAFSTOR scenario is presented in the graphic below.Annual Employment in Windham County with 2013 SAFSTOR 80,000 70,000 60,000 50,000 40,000 30,000 2017120271203712047 12057 1206712077120871 2012 2022 2032 2042 2052 2062 2072 2082 2092 In 2013 there is a loss of jobs in Windham County when the VY Station ceases producing power.The job decline is somewhat offset by the jobs needed at the power station to put it into SAFSTOR mode. From 2013 to 2018, employment in Windham County is 625 to 1,050 less than the baseline depending on the level of spending with the 2013 SAFSTOR scenario.The from 2019 through 2066, when the VY Station is in SAFSTOR mode, the loss of jobs is from 1,150 to 1,300 below the baseline estimate.From 2067 to 2074, the loss of jobs falls to 750 to 1,200 as the work at the VY Station with the 2013 SAFSTOR scenario is completed.

Then in 2075 the loss returns to about 1,350 from the baseline.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 19 Economic Impact of the VY Station July 12, 2012 B. Windham County Total Wages with 2013 SAFSTOR The total wages paid by employers in Windham County over the period 2012 to 2093 with the 2013 SAFSTOR scenario is presented in the graphic below. It follows the same path as the employment described above.Annual Wages in Windham County with 2013 SAFSTOR$ millions 8,000 7,000 6,000 Baseline 5,000 2013 SAFSTOR 4,000 3,000 2,000 2017 20127120137 2047 2057 2067 2077 2087 2012 2022 2032 2042 2052 2062 2072 2082 2092 In 2013 the total wages at Windham County employers drop off from the baseline estimate.

This is because the VY Station has ceased producing power and the payroll from that activity ceases.The payroll is partially offset by the payroll associated with preparing the plant for SAFSTOR mode, but not enough to prevent a decline. The decline from 2013 to 2018 averages $81 million per year.From 2018 through 2066 payrolls at Windham County firms ranges from $96 million to $168 million less per year compared to the baseline as only a minimal amount of spending occurs with SAFSTOR during this period.The payroll difference narrows somewhat (falling to as little as $125 million) from 2066 through 2073 when significant expenditures occur with the end of the 2013 SAFSTOR scenario.Beginning in 2075 the payroll loss returns to about $186 million when all work associated with the 2013 SAFSTOR scenario has ended.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 20 Economic Impact of the VY Station July 12, 2012 VII. Economic Impact of the 2032 Prompt Decommissioning Versus 2013 SAFSTOR Scenarios The economic impact of the 2032 Prompt Decommissioning scenario versus the 2013 SAFSTOR scenario is measured by comparing the estimated employment, wages, disposable income, and other economic indicators under these scenarios.

A. Employment Impact in Windham County The differing employment impacts in the two scenarios from 2012 through 2093 can be seen in the diagram below. The major difference occurs from 2013 to 2031. On average, from 2013 to 2031 Windham County would have 1,085 more employees under the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.

This difference is less from 2013 to 2017 when there are considerable expenditures with the 2013 SAFSTOR scenario and more from 2018 to 2031 when there are relatively minimal expenditures associated with the 2013 SAFSTOR scenario.Employment in Windham County: 2032 Prompt Decommissioning

v. 2013 SAFSTOR 75,000 7 0 2013 SAFSTOR 2032 Prompt Decommissioning 65,000 55,000 45,000 35,000 1201712027120371204712057120671207712087ý 2012 2022 2032 2042 2052 2062 2072 2082 2092 From 2067 to 2074 there are slightly more jobs with the 2013 SAFSTOR scenario than with the 2032 Prompt Decommissioning scenario (somewhat hard to see as the average difference is only 279 employees).

There are significant expenditures with the 2013 SAFSTOR scenario in those years.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 21 Economic Impact of the VY Station July 12, 2012 B. Total Wage Impact in Windham County The total wages paid by Windham County employers will be significantly less in the 2013 SAFSTOR scenario than with the 2032 Prompt Decommissioning scenario.

Almost all the difference occurs during the 2013 to 2031 period.In the 2032 Prompt Decommissioning scenario, the simple sum of the total wages (in constant 2011 dollars) paid by Windham Total Wages Paid in Windham County County employers equals $331,840 million 2012 to 2093 from 2012 to 2093. In present value terms, (in millions of2011 dollars)this totals $115,560 million.'5 Simple Present In the 2013 SAFSTOR scenario, the simple Scenario Sum Value sum of the total wages paid by Windham 2032 Pr. Dec. $331,840 $115,560 2013 SAFSTOR $329,758 $114,013 County employers equals $329,758 million from 2012 to 2093. In present value terms this equals $114,013 million. Difference

$2,082 $1,547 The difference in the wages paid between these two scenarios equals $2,082 million over the period 2012 to 2093. In present value terms this equals $1,547 million." 6 C Income Impact on Windham County Residents Wages paid at area businesses do not necessarily equate to income earned by area residents.

A number of workers of Windham County businesses live out of the county (and out of state as well). In addition, income is derived from a variety of sources in addition to wages. Therefore, we are concerned not only with the payrolls of local businesses but also with the disposable (after tax) income of local residents.

Over the period 2012 to 2093, the disposable income (in 2011 dollars) earned by Windham County residents totals $1,596 million more in the 2032 Prompt Decommissioning scenario than in the 2013 SAFSTOR scenario.

In present value terms this equals $1,186 million.15 We use a real interest rate of 2.5% for this discounting.

The nominal interest rate we estimate to be 5%with inflation of nearly 2.5%.6 If a real discount rate of 3.5% were used instead of 2.5%, the present value of the difference would equal$1,392 million. Ifa 1.5% real rate was used, the present value would equal $1,730 million.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 22 Economic Impact of the VY Station July 12, 2012 D. Demographic Impact on Windham County With the estimated loss of jobs in Windham County under either the 2032 Prompt Decommissioning scenario or the 2013 SAFSTOR scenarios, some population decline will occur. The graph below depicts the estimated net loss of population in Windham County during the period 2012 through 2093. This is the difference in the county's population under the 2013 SAFSTOR scenario versus the 2032 Prompt Decommissioning scenario.Loss of Population Windham County: 2013 SAFSTOR v. 2032 Prompt Decommissioning 200 100-200-300 2017 2027 2037 2047 2057 2067 2077 2087 2012 2022 2032 2042 2052 2062 2072 2082 2092 The 2013 SAFSTOR scenario compared to the 2032 Prompt Decommissioning scenario leads to a loss of nearly 400 more county residents from 2015 to 203 L." The loss decreases until there is basically no net population impact between the two scenarios by 2042. Then there is a comparative net gain, especially from 2067 to 2074, as the 2013 SAFSTOR scenario entails significant expenditure during this time period.17 This is the net loss for any year. The loss is not cumulative.

Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 23 Economic Impact of the VY Station July]12, 2012 E. Employment Impact in the Rest of Vermont Most of the impact of the VY Station occurs within Windham County. However, some impact spills over into Bennington, Windsor, and other counties in the state (as well as into New Hampshire and Massachusetts).

As measured in section III of this report, the VY Station led to the creation of an additional 244 jobs and an additional payroll of $10.6 million elsewhere in Vermont in 2011. A similar spillover into the rest of Vermont will be felt in the future with the VY Station under the three scenarios being considered in this report.Employment in the rest of Vermont under the 2032 Prompt Decommissioning scenario compared the 2013 SAFSTOR scenario follows the same pattern as the other economic indicators reviewed in this section of the report. From 2013 to 2031 employment in the rest of Vermont averages about 257 jobs more with the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.

This is reduced in the early years (2013 to 2017) when the VY Station is being readied for SAFSTOR.The job difference is only positive for the 2013 SAFSTOR scenario versus the 2032 Prompt Decommissioning scenario during the period 2067 to 2074 when considerable expenditures occur with 2013 SAFSTOR scenario.

During that period the job total averages 97 more with the 2013 SAFSTOR scenario than with the 2032 Prompt Decommissioning scenario.F. Total Wages and Disposable Income Impact in the Rest of Vermont In the rest of Vermont the total wages paid by employers is higher with the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.

The difference in the total wages equals $296 million over the period 2012 to 2093. In present value terms this equals $229 million.Disposable income earned by residents in the rest of Vermont is also higher in the 2032 Prompt Decommissioning scenario than with the 2013 SAFSTOR scenario.

The difference in disposable income earned by residents of the rest of Vermont equals $446 million over the period 2012 to 2093. In present value terms this equals $324 million.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 24 Economic Impact of the VY Station July 12, 2012 G. Tax Revenue Impacts on State Government When economic activity slows, state government tax revenues slow as well. This Net Loss in State Tax Revenues is true for individual income taxes, general 2012 to 2093 sales taxes, and most other taxes. By use of (in millions of 2011 dollars)the REDYN model we estimate the net reduction in state taxes due to the difference Simple Present between those revenues received under the Source Sum Value 2032 Prompt Decommissioning scenario All state taxes $225.9 $164.0 versus the 2013 SAFSTOR scenario.Individual income $60.7 $44.1 These taxes received are the consequence of Property $57.3 $41.7 either the operation of the VY Station or from Selective sales $52.8 $38.4 the economic activity created through the General sales $32.0 $23.2 multiplier process. For example, the income taxes are paid by both the VY Station employees and by employees of other businesses in the state that exist because of the operation of the VY Station in Vermont.Over the period 2012 through 2093 the sum of all taxes paid to the State of Vermont is $225.9 million less under the 2013 SAFSTOR scenario than under the 2032 Prompt Decommissioning scenario.

In present value terms this difference equals $164.0 million.The four largest tax sources are individual income taxes, property taxes, selective sales taxes, and general sales taxes.'8 The net loss to the state treasury in present value terms from these tax sources equals $44.1 million, $41.7 million, $38.4 million, and $23.2 million, respectively.

'8 Selective sales taxes includes a wide variety of specific taxes levied on sales, including motor fuel, tobacco, alcoholic beverages, etc.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 25 Economic Impact of the VY Station July 12, 2012 H. Revenue Impacts on Local Governments Just as the state will see a fall in tax revenues from the reduction of economic activity, so will the many local governments in Vermont where residents and businesses created due to the operation of the VY Station reside. The single largest tax source to local governments in Vermont is the property tax and that accounts for 97% of the tax reduction.

The net loss of local property tax revenues is difference between the local tax payments under the 2032 Prompt Decommissioning scenario versus the 2013 SAFSTOR scenario.The net loss in local property taxes over the period 2012 to 2093 equals $64.3 million (in 2011 dollars).

In present value terms this equals $46.7 million.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 26 Economic Impact of the VY Station July 12, 2012 VIII. Economic Impact of the 2032 Deferred Decommissioning Versus 2013 SAFSTOR Scenarios The economic impact of the 2032 Deferred Decommissioning scenario versus the 2013 SAFSTOR scenario is measured by comparing the estimated employment, wages, disposable income, and other economic indicators under these scenarios.

A. Employment Impact in Windham County The differing employment impacts in the two scenarios from 2012 through 2093 can be seen in the diagram below. The major difference occurs from 2013 to 2031. On average, from 2013 to 2031 Windham County would have 1,085 more employees under the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.

This difference is less from 2013 to 2017 when there are considerable expenditures with the 2013 SAFSTOR scenario and more from 2018 to 2031 when there are relatively minimal expenditures associated with the 2013 SAFSTOR scenario.Employment in Windham County: 2032 Deferred Decommissioning

v. 2013 SAFSTOR[2017120271203712047120571206712077120871 2012 2022 2032 2042 2052 2062 2072 2082 2092 From 2067 to 2074 there are slightly more jobs with the 2013 SAFSTOR scenario than with the 2032 Deferred Decommissioning scenario (somewhat hard to see as the average difference is only 285 employees).

There are significant expenditures with the 2013 SAFSTOR scenario in those years. The opposite happens from 2087 to 2093 when the average difference is 464 employees more with the 2032 Deferred Decommissioning scenario.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 27 Economic Impact of the VY Station.July 12, 2012 Economic Impact of the VY Station July 12, 2012 B. Total Wage Impact in Windham County The total wages paid by Windham County employers will be significantly less in the 2013 SAFSTOR scenario than with the 2032 Deferred Decommissioning scenario.

Almost all the difference occurs during the 2013 to 2031 period.In the 2032 Deferred Decommissioning scenario, the simple sum of the total wages (in constant 2011 dollars) paid by Windham Total Wages Paid in Windham County County employers equals $331,849 million 2012 to 2093 from 2012 to 2093. In present value terms, (in millions of 2011 dollars)this totals $115,502 million.9 Simple Present In the 2013 SAFSTOR scenario, the simple Scenario Sum Value sum of the total wages paid by Windham County employers equals $329,534 million 2013 SAFSTOR $329,534 $113,932 from 2012 to 2093. In present value terms this equals $113,932 million. Difference

$2,091 $1,489 The difference in the wages paid between these two scenarios equals $2,191 million over the period 2012 to 2093. In present value terms this equals $1,489 million.C Income Impact on Windham County Residents Over the period 2012 to 2093, the disposable income (in 2011 dollars) earned by Windham County residents totals $1,514 million more in the 2032 Deferred Decommissioning scenario than in the 2013 SAFSTOR scenario.

In present value terms this equals $1,139 million.9 We use a real interest rate of 2.5% for this discounting.

The nominal interest rate we estimate to be 5%with inflation of nearly 2.5%.Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 28 Economic Impact of the VY Station July 12, 2012 D. Demographic Impact on Windham County With the estimated loss of jobs in Windham County under either the 2032 Deferred Decommissioning scenario or the 2013 SAFSTOR scenarios, some population decline will occur. The graph below depicts the estimated net loss of population in Windham County during the period 2012 through 2093. This is the difference in the county's population under the 2013 SAFSTOR scenario versus the 2032 Deferred Decommissioning scenario.Loss of Population Windham County: 2013 SAFSTOR v. 2032 Deferred Decommissioning

-200 I'-300-400 I I I I I I 2017 2027 12037 2047 2057 2067 2077 2087 2012 2022 2032 2042 2052 2062 2072 2082 2092 The 2013 SAFSTOR scenario compared to the 2032 Prompt Decommissioning scenario leads to a loss of nearly 400 more county residents from 2015 to 2031.20 The loss decreases until there is basically no net population impact between the two scenarios by 2042. Then there is a comparative net gain, especially from 2067 to 2074, as the 2013 SAFSTOR scenario entails significant expenditure during this time period. This reverses after then as the 2032 Deferred Decommissioning scenario entails significant expenditures from 2087 to 2093 and there are no expenditures with the 2013 SAFSTOR scenario.20 This is the net loss for any year. The loss is not cumulative.

Northern Economic Consulting, Inc.Westford, Vermont 05494 Page 29 Economic Impact of the VY Station July 12, 2012 E. Employment Impact in the Rest of Vermont Employment in the rest of Vermont under the 2032 Deferred Decommissioning scenario compared the 2013 SAFSTOR scenario follows the same pattern as the other economic indicators reviewed in this section of the report. From 2013 to 2031 employment in the rest of Vermont averages about 257 jobs more with the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.

This is reduced in the early years (2013 to 2017) when the VY Station is being readied for SAFSTOR.The job difference is only positive for the 2013 SAFSTOR scenario versus the 2032 Deferred Decommissioning scenario during the period 2068 to 2075 when considerable expenditures occur with 2013 SAFSTOR scenario.

During that period the job total averages 94 more with the 2013 SAFSTOR scenario than with the 2032 Deferred Decommissioning scenario.This reverses at the end of the period in review when there are no expenditures with the 2013 SAFSTOR scenario and considerable expenditures with the 2032 Deferred Decommissioning scenario.

The average employment difference in the rest of Vermont is 111 jobs from 2086 through 2093.F. Total Wages and Disposable Income Impact in the Rest of Vermont In the rest of Vermont the total wages paid by employers is higher with the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.

The difference in the total wages equals $277 million over the period 2012 to 2093. In present value terms this equals $203 million.Disposable income earned by residents in the rest of Vermont is also higher in the 2032 Deferred Decommissioning scenario than with the 2013 SAFSTOR scenario.

The difference in disposable income earned by residents of the rest of Vermont equals $427 million over the period 2012 to 2093. In present value terms this equals $295 million.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 30 Economic Impact of the VY Station July 12, 2012 G. Tax Revenue Impacts on State Government When economic activity slows, state government tax revenues slow as well. This Net Loss in State Tax Revenues is true for individual income taxes, general 2012 to 2093 sales taxes, and most other taxes. By use of (in millions of 2011 dollars)the REDYN model we estimate the net reduction in state taxes due to the difference Simple Present between those revenues received under the Source Sum Value 2032 Deferred Decommissioning scenario All state taxes $231.0 $156.8 versus the 2013 SAFSTOR scenario.Individual income $62.0 $42.1 These taxes received are the consequence of Property $60.0 $40.7 either the operation of the VY Station or from Selective sales $54.0 $36.7 the economic activity created through the General sales $32.6 $22.2 multiplier process. For example, the income taxes are paid by both the VY Station employees and by employees of other businesses in the state that exist because of the operation of the VY Station in Vermont.Over the period 2012 through 2093 the sum of all taxes paid to the State of Vermont is $231.0 million less under the 2013 SAFSTOR scenario than under the 2032 Prompt Decommissioning scenario.

In present value terms this difference equals $156.8 million.The four largest tax sources are individual income taxes, property taxes, selective sales taxes, and general sales taxes.2' The net loss to the state treasury in present value terms from these tax sources equals $42.1 million, $40.7 million, $36.7 million, and $22.2 million, respectively.

21 Selective sales taxes includes a wide variety of specific taxes levied on sales, including motor fuel, tobacco, alcoholic beverages, etc.Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 31 Economic Impact of the VY Station July 12, 2012 H. Revenue Impacts on Local Governments Just as the state will see a fall in tax revenues from the reduction of economic activity, so will the many local governments in Vermont where residents and businesses created due to the operation of the VY Station reside. The single largest tax source to local governments in Vermont is the property tax and that accounts for 97% of the tax reduction.

The net loss of local property tax revenues is difference between the local tax payments uinder the 2032 Deferred Decommissioning scenario versus the 2013 SAFSTOR scenario.The net loss in local property taxes over the period 2012 to 2093 equals $62.3 million (in 2011 dollars).

In present value terms this equals $43.9 million.Northern Economic Consulting, Inc.Westford, Vernmont 05494 Page 32 Economic Impact of the VY Station July 12, 2012 IX. Appendix I -Methodology of this Analysis The economic, demographic and fiscal impact of the future operation and eventual decommissioning of the VY Station is measured by use of a dynamic, input-output model developed by Regional Dynamics Inc. ("The REDYN Model"). This model allows the estimation of economic, fiscal and demographic impacts from 2012 through 2055.Regional Dynamics is an economic modeling company. REDYN offers an advanced economic model by web subscription or batch services to consultants, agencies, firms, planners, and analysts (users). REDYN runs on the Internet.

The model estimates the multi-regional impacts and year-by-year (dynamic) nonlinear effects on industries, consumers, and governments from changes in company sales, jobs, wages, or investments; changes in taxes or personal or government spending; or public policy changes such as energy, environment, school, health, or security measures.

The results are called simulation forecasts, or simulations.

The model is a fundamental re-envisioning of economic theory applied to estimating multi-regional, dynamic effects. It reflects advances in New Economic Geography, especially gravity theory (regional attraction) and trade flow (regional imports/exports), based on a new distance impedance database from Oak Ridge National Laboratories that enables calculating trade flow by commodity by road, rail, water, air, and proxy transport.

The breakthrough in design is the commodity production linkage between the trade flow process and an entity-based data structure for the economy. Entities include industries, workers, governments, investors, etc., and commodities are the goods they use and make.REDYN is more flexible, complete, and accessible than any other modeling process available today.For this report we developed a four region REDYN model. The regions are: Windham County, the remaining counties of Vermont (called "Rest of Vermont"), Cheshire County in New Hampshire, and Franklin County in Massachusetts.

The economic impacts on the latter two counties are not of concern to this report. However, they were included in this analysis in order to fully measure the impact of the VY Station and increase our confidence in the reasonableness of the REDYN model's estimates.

Northern Economic Consulting, Inc. Westford, Vermont 05494 Page 33 WINDHAM REG 1ONA]1 c UM I I S q 0 IO March 20, 2015 United States Nuclear Regulatory Commission Office of Administration Attn:. Cindy Bladey Mail Stop 3WFN-06-A44M Washington, DC 20555-0001

SUBJECT:

Docket No. NRC-2015-0004 Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station Post-Shutdown Decommissioning Activities Report Comments of the Windham Regional Commission History &

Background:

The Windham Regional Commission (WRC) is writing to comment on the Site Assessment Study (SAS) and Post-Shutdown Decommissioning Activities Report (PSDAR). WRC is the regional planning commission that serves 27 towns in southeastern Vermont, including the 23 towns of Windham County, Readsboro, Searsburg and Winhall in Bennington County, and Weston in Windsor County. The Windham Region is the host region of the station.The WRC has always maintained a neutral position as to whether or not the plant should continue operation, as well as the merits of nuclear power for that matter, in order to facilitate conversations among all sides of the issue. Therefore, we approach the closure and decommissioning phase with a history of having been neither pro- or anti-Vermont Yankee or pro- or anti-nuclear power. We have, however, over a period of several years developed positions on decommissioning, spent fuel management, site restoration standards, and responsibility for decommissioning costs that we feel are in the best interests of the host region. These positions are included in the Windham Regional Plan, the most recent update of which took effect in November, 2014 (the full text is available at https://windhamregionalplan.wordpress.com/).

Positions on Vermont Yankee Decommissioning:

Through participation as a party in dockets related to Vermont Yankee before the Vermont Public Service Board, the WRC has for several 2 years explored the issues surrounding the eventual cessation of operations at the station, whenever and for whatever reason that might occur. The following excerpt from the Windham Regional Plan describes the positions of the WRC concerning the decommissioning of the station, as well as spent fuel management, site restoration, and responsibility for the costs associated with each. While this language describes actions the WRC feels the Vermont Public Service Board should have taken in their order related to Docket 7862, our policy positions have not changed.The Windham Regional Commission has always maintained a neutral position on the question of the continued operation of the Entergy Nuclear Vermont Yankee power station located in Vernon. The WRC has taken this position so it could facilitate discussion among those on all sides of the issue. The Commission has, however, been very involved in Vermont Public Service Board dockets since 2007, arguing not for whether or not the plant should continue operation, but rather for what is in the best interest of the region when the plant does eventually cease operation, whenever and for whatever reason that occurs. The WRC interests are to mitigate to the greatest extent possible the economic, employment, cultural and social impacts of the plant's closure on the region; to advocate for the fiscal well-being of towns; and to advocate for the restoration of the Vermont Yankee site to greenfield status as soon as possible so that it may be reused. These positions were most recently stated in the WRC's Initial Brief filed on August 16, 2013 in Public Service Board docket 7862...The following summarizes those positions excerpted from the brief:* Recognize the value of the Station to the region and state while it is operating, and that the general good would be best served if, upon cessation of operations, the Station is promptly decommissioned with complete site restoration so that the site can be reused and serve the orderly development of the region and state." Require that ENVY (Entergy Nuclear Vermont Yankee), ENO (Entergy Nuclear Operations), and Entergy Corporation be held jointly and severally responsible for all costs associated with operations, decommissioning, spent fuel management, and site restoration." Require the prompt and complete decommissioning and site restoration of the VY Station after shutdown (whenever that occurs) and prohibit the use of SAFSTOR. The best way to accomplish this is to ensure the decommissioning trust is adequate.* Recognize the Decommissioning Cost Analysis prepared by TLG is inadequate.

The Board should specifically recognize the Decommissioning Cost Analysis and Decommissioning Trust Fund do not adequately account for the costs of removing all structures, reasonable property taxes, and additional elements identified by other parties. The Board should require that Entergy VY fully fund the decommissioning trust to cover all potential 139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org 3 costs associated with radiological decommissioning, spent fuel management, and complete site restoration without the use of SAFSTOR." Require Entergy VY to meet its MOU (memorandum of understanding) commitment to remove "all structures" as part of site restoration, rather than just removing structures to three feet below grade." Require Entergy VY to establish separate and adequate funds to cover radiological decommissioning, spent fuel management, and site restoration, and require substantial additional payments into those funds." Require Entergy VY to identify a suitable location for a second ISFSI (independent spent fuel storage installation).

• Require Entergy VY to consider shifting spent fuel from wet to dry storage, or alternatively require a payment-in-kind into the decommissioning trust as if fuel had been moved.* Additionally, the Board should require that Entergy VY provide funding to the decommissioning trust to cover all the costs of managing spent fuel derived from any period of extended operations after March 21, 2012.* Require specific actions from Entergy VY to comply with its commitment to use its "commercial best efforts" to have the spent fuel removed from Vermont.The WRC feels that these positions are in the best interest of the region and the state. What Entergy Nuclear Vermont Yankee intends to do upon closure is on the record, under oath, before the Public Service Board. The Commission's position was developed in response to what has been entered into the record.The Public Service Board docket remains open, and the WRC believes that these positions should serve as the primary point of negotiation between the State and Entergy going forward. This filing, and other information related to the Commission's work on Vermont Yankee, can be found on the WRC website at http://windhamregional.org/vermont-vankee.

Additionally, at the request of the Town of Vernon and using a Municipal Planning Grant, the WRC prepared a study titled, Resiliency Action Plan for the Town of Vernon in Preparation for the Eventual Closure of the Vermont Yankee Nuclear Power Station. This plan, completed in June 2012, explains the closure and decommissioning process and what actions the town can take to prepare. It is available here: http://windhamregional.org/images/docs/vv/exhibits/wrc-cross-35.pdf.

As noted in the plan, federal law and regulations do not require Entergy Nuclear Vermont Yankee to work with the town or the region as they prepare for closure and decommissioning, but the WRC hopes they will voluntarily do so. The WRC is prepared to assist in this effort and has reached out to its counterparts in New Hampshire and Massachusetts to engage them in preparing for the closure of the plant as well.139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax.802-254-6383 www.windhamregional.org 4 The WRC recognizes the significant and diverse impacts the closure of the plant will have on the region, including its towns, families, friends, neighbors, businesses, and economy. The WRC has invested considerable staff and volunteer resources over the last six years in preparation for the plant's eventual closure in order to understand its impacts and develop mitigation strategies.

The WRC stands by to assist its towns with planning for a post-Vermont Yankee future, to lead a regional resiliency planning effort, and to provide support in statewide response and recovery efforts. Mitigating the impacts on the region's economy will require region-wide solutions, and the WRC will continue to participate in and support the Southeast Vermont Economic Development Strategy and the development of a Comprehensive Economic Development Strategy, led by our regional partner, the Brattleboro Development Credit Corporation.

The Commission will also encourage Entergy to voluntarily work with the region and our towns to establish a working group through which there will be clear communication about what the plant intends to do and what those actions mean for our communities.

We all must work together to plan for resiliency as the region loses not only a major employer and economic engine, but also many plant workers and their families (Windham Regional Plan, 2014, pp. 112-113).The PSDAR proposes the use of SAFSTOR rather than DECON, or prompt decommissioning.

This is contrary to what the WRC maintains is in the best interests of the region, its towns, and its residents.

We also have serious concerns that the site assessment and PSDAR insufficiently characterize the site conditions and true costs of decommissioning and site restoration, and concur with the questions and issues raised about these issues and what this means for the sufficiency and stewardship of the decommissioning trust fund.Emergency Planning Support: A matter that was not addressed as specifically in our regional plan is the continued support by Entergy Nuclear Vermont Yankee of external emergency planning support. Our position can be summarized by our comments to the Vermont Public Service Board in Docket 8300, which was opened to review the request for a certificate of public good for a second ISFSI (Independent Spent Fuel Storage Facitlity).

This document is available on the WRC Vermont Yankee web page http://windhamregional.org/vermont-yankee.

While we understand the potential for a catastrophic event will lessen once the Station ceases operations, there remains the potential for a significant event as long as spent nuclear fuel is stored on site, and regional emergency service providers must always be prepared to respond, and must be adequately funded to do so.WRC recognizes that on-site nuclear safety is regulated by the NRC, but off-site responders must be prepared to deal with any emergency that might occur on-139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org 5 site whether or not it extends to the off-site environment.

And the Board traditionally deals with emergency management issues and funding for off-site emergency support in other dockets dealing with different fuels such as natural gas. Likewise, it is not uncommon in non-nuclear Section 248 and Act 250 cases for petitioners to agree to cover specialized equipment and training costs necessitated by the unique elements of proposed development.

The Board should seek additional information from Entergy VY about all potential scenarios that might require an on-site or off-site emergency response, the type of response needed, and the cost for providing these services (including the costs of ongoing training necessary to respond).State agencies are holding discussions with Entergy VY about emergency response issues and are seeking input from the WRC and towns within the Emergency Planning Zone, and we hope a resolution of our concerns can be accomplished outside of the CPG process. The Board should be mindful of where funding for emergency services will come from, and should consider prohibiting the use of the Decommissioning Trust Fund for this purpose because, as described elsewhere in these comments, Entergy VY has previously done so little to identify, secure, and fund alternative spent fuel storage options (Windham Regional Commission Comments RE: Entergy VY Petition for a Certificate of Public Good for a Second Spent Fuel Storage Facility, August 13, 2014, p. 17 available at http://windhamregional.org/images/docs/vv/docket-8300 WRC-VY-2nd-ISFSI-Comments-re-Petition.pdf).

Avoiding Use of Decommissioning Trust Funds for Spent Fuel Management:

We are encouraged that Entergy Nuclear Vermont Yankee plans to offload fuel from the spent fuel pool to dry cask storage within a reasonable time frame, and we support the company's exploration of financing at these costs so as to reduce funds that would be taken out of the decommissioning trust fund.Vermont Nuclear Decommissioning Citizens Advisory Panel: We appreciate the willingness of Entergy Nuclear Vermont Yankee and Entergy Nuclear Operations to participate in the Nuclear Decommissioning Citizens Advisory Panel. While we may disagree with the decommissioning plans of the plant, it is important to have a forum where issues can be discussed and where common ground may be found. We do recognize that the Panel was formed to advise the state, and not the plant. It is our understanding that other advisory panels formed in response to decommissionings were intended to advise the plant as well. We hope that over time, Entergy Nuclear Vermont Yankee will be amenable to the panel assuming such a role.Comments of the State of Vermont on Docket NRC-2015-0004 and Docket 50-271: We have reviewed the state's comments and find them to be consistent with the aforementioned 139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org 6 positions the WRC has taken on the decommissioning of Vermont Yankee. We share the concerns the state has raised and appreciate its engagement with the NRC in these matters.The health, safety and welfare of the host region and its citizens are dependent upon the monitoring, oversight, regulation and enforcement of the decommissioning process by the State of Vermont and the U.S. Nuclear Regulatory Commission.

It is incumbentthat the decommissioning be held to the highest standards.

Insufficiency of the Generic Environmental Impact Statement:

Entergy states that it "has concluded that the environmental impacts associated with planned VYNPS site-specific decommissioning activities" are bounded by previous environmental impact statements (PSDAR at 22). We strongly concur with the state that the NRC must analyze the environmental impacts of Entergy's proposed PSDAR and related findings and that reliance on the generic EIS does not satisfy the requirements of the National Environmental Policy Act. We also concur with the comments submitted by the Town of Brattleboro in this matter.We will focus here on the insufficiency of the socioeconomic and environmental justice impact assessments and conclusions reached in NUREG-1437, Supplement 30 Vol. 1. Section 5.1.12 Socioeconomics of the PSDAR states: Decommissioning of VYNPS is expected to result in negative socioeconomic impacts. As VYNPS transitions from an operating plant to a shutdown plant and into the different phases of decommissioning, an overall decrease in plant staff will occur. The lost wages of these plant staff will result in decreases in revenues available to support the local economy and local tax authorities.

Some laid-off workers may relocate, thus potentially impacting the local cost of housing and availability of public services.Section 4.3.12 of the GElS evaluated changes in workforce and population, changes in local tax revenues, and changes in public services.

The evaluation also examined large plants located in rural areas that permanently shut down early and selected the SAFSTOR option. The GElS determined that this situation is the likeliest to have negative impacts. The GElS concluded that socioeconomic impacts are neither detectable nor destabilizing and that mitigation measures are not warranted.

Therefore, ENVY concludes that the impacts of VYNPS decommissioning on socioeconomic impacts are bounded by the GElS (p. 29).Section 5.1.13 Environmental Justice of the PSDAR "concludes that the impacts of VYNPS decommissioning on environmental justice are small and are bounded by the GElS (p.30)." We dispute the small impact findings of the GElS related to both socioeconomic impacts and environmental justice impact.139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org 7 When fully operational, VY had over 600 workers, most living in Windham County, VT; Cheshire County, NH; and Franklin County, MA. For over 40 years, VY has been an important component of this region's economy. Four regional economic development planning organizations sought to understand the magnitude of economic impact to our tri-state region due to the discontinuing of operations and decommissioning of VY, especially the loss of local income. The four organizations are: the Brattleboro Development Credit Corporation, the Franklin Regional Council of Governments, the Southwest Regional Planning Commission, and the Windham Regional Commission.

Through a state District Local Technical Assistance grant, the Franklin Regional Council of Governments retained the services of the UMass Donahue Institute to conduct a study (attached) that illustrates the anticipated direct, indirect and induced economic impacts to the local tri-county area (Cheshire, Franklin and Windham Counties), and assesses the ramifications on the long-term economic prospects of the region. Some of the findings are rather stark." The loss of total output (i.e. direct, indirect & induced) from when VY was operational to the year 2021 is a difference of $487 million. This represents the loss of the total value of wages and the total loss of goods and services produced, related to VY operations.

This is an important figure for understanding the broader implications of this event to the economic climate of the region." The two key data points that hold the greatest consequence from this event for our region are: the total loss of employment (approx. 1,200 jobs) and the total amount of indirect and induced output ($90 million).

This $90 million in output represents the annual loss of economic activity to the tri-county business community, in comparison to when VY was operational.

• The purpose of conducting this study was to offer an understanding of the order of magnitude for how this event will impact the tri-county area economy. These findings underline the importance and urgency for why our region must take steps to improve our economy and discover opportunities for collaboration to mitigate the losses anticipated as a result of VY closure." As seen in Table 2, the industry sectors anticipated to have the greatest impact (aside from Utilities, of course) is the Leisure & Hospitality sector and Other Services sector (255 jobs anticipated to be lost). These sectors often provide among the lowest wages. As a result, workers with the least amount of resources may be the most negatively impacted.* The pending economic impacts due to VY's closure in the Windham Region of VT, Cheshire County, NH, and Franklin County, MA are significant.

The comprehensive economic development strategy (CEDS) developed for each of these has noted the relative stagnation 139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org 8 of the area's economy and workforce challenges even before the closure of VY. The closure of VY will exacerbate existing trends.We would also like to direct your attention to an economic impact study commissioned by VY itself. "The Economic Impact of the VY Station on Windham County and Vermont" prepared by Richard W. Heaps in July, 2012 (attached) states the following:

The importance of the VY Station in the county's economy is demonstrated by the fact this one firm directly accounts for about 2% of the employment and about 5% of the compensation earned in Windham County. The VY Station's compensation per employee is higher than that of any industry in Windham County. In addition, the Vermont Department of Labor reports that the VY Station is one of the top five employers in Windham County.It is clear that economic activity in Windham County has significantly lagged that of the rest of Vermont. In addition, even as Vermont is a slow growing state from a demographic perspective, Windham County is even a slower growing area. This suggests that any major, negative economic impacts could be felt more acutely in Windham County than elsewhere in Vermont (p. 2).It seems profoundly incongruous that VY can argue before the VT Public Service Board that the loss of economic activity due the closure of VY will be significant in Windham County, yet claim in the PSDAR that the impacts are bounded by previous environmental impact statements which conclude employment and environmental justice impacts will be small.We sincerely hope the NRC will seriously reconsider the impact assumptions and findings made in NUREG-1437, Supplement 30 Vol. 1. Under the No-Action Scenario, in which VY's operating license would not be renewed and Entergy would cease operations, staff conclude the following about the socioeconomics of the plant closure: In Chapter 4, the NRC staff concluded that the socioeconomic impact of continued plant operation would be SMALL. There would be immediate socioeconomic impacts associated with the shutdown of the plant because of the reduction in the staff at the plant. There may also be an immediate reduction in property tax revenues for Windham County, and this is anticipated to be LARGE. The overall impact would depend on the state of the economy, the net change in workforce at the plant, and the changes in local government tax receipts.

Appendix J of Supplement 1 to NUREG-0586 (NRC 2002) shows that the overall socioeconomic impact of plant closure plus decommissioning could be greater than SMALL. The NRC staff concludes that the socioeconomic impact of VYNPS shutdown on employment would be SMALL because of the relatively small employment loss compared with total employment in the economy of the 139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org 9 surrounding area. Therefore, the NRC staff concludes that the socioeconomic impacts of plant shutdown would range from SMALL to LARGE. Impacts could be* offset if new power-generating facilities are built at or near the current site (p. 8-5).While we agree that the property tax revenue impact will in fact be large (see the aforementioned Resiliency Action Plan prepared for the Town .of Vernon), we disagree that the impact on employment would be small. More to the point, the EIS fails to take into account the disproportionate contribution the plant makes to total local income and how this translates into loss of employment and indirect and induced input. The conclusions of both the UMDI and Heaps studies make clear that the loss of income associated with VY employees will have significant reverberations throughout the local economy.We also dispute the finding that the environmental justice impact of the plant closure will be small. In the generic EIS, the NRC states: In Chapter 4, the NRC staff concluded that the environmental justice impact of continued operation of the plant would be SMALL. Continued operation of the plant would not have a disproportionately high and adverse impact on minority and low-income populations.

Shutdown of the plant also would not have disproportionately high and adverse impacts on minority and low-income populations resulting from the loss of employment opportunities at the site or from secondary socioeconomic impacts (e.g., loss of patronage at local businesses because the loss would be very minor in the context of the regional economy).

The NRC staff concludes that the environmental justice impact of plant shutdown is expected to be SMALL. Any impact would be offset if new power-generating facilities are built at or near the current site. See Appendix J to NUREG-0586, Supplement 1 (NRC 2002), for additional discussion of this impact (p. 8-6).The UMDI study found the loss of employment opportunities from secondary economic impacts will be substantial, and will most significantly impact service and low-wage earners. We believe the environmental justice impacts will be significant.

We further believe the NRC is obligated to compare the socioeconomic and environmental justice impacts under both DECON and SAFSTOR scenarios.

There is a fundamental difference in employment impacts under DECON versus SAFSTOR scenarios based on Entergy's own modeling.

The graphs below were prepared by Entergy for use in VT Public Service Docket 7862 and demonstrate the acute drop in employment under the SAFSTOR scenario versus DECON.139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org 10 in 79 DECON SAFSTOR WRC4-Q.2 Entergy anticipated that when the station shuts down the workforce will shrink from roughly 620 to about 250 over a 9-12 month period. With SAFSTOR, after a brief ramp up to button up the plant, the workforce would quickly drop further to about 50 people.Staffing Transition to Decommissioning

-prainI Dorrylan(y Preparation I SAFSTOR!20131 2014 1 2015 1 2016 12017 7 020 1 2021+ 1 I)eIiieI/ jj 9 q C 99(9/m I~ySwq I Decorn Planning I 9 In Section 2.2.8 Changes to Management and Staffing of the PSDAR, Entergy states staffing levels will be adjusted to reflect the ongoing transition of the site organization (p. 18). The graphic above titled "Staffing Transition to Decommissioning" was included in a presentation made by Entergy to the VT Nuclear Decommissioning Citizens Advisory Panel on September 25, 1 Vermont Public Service BoardDocket 7862 WRC-Cross-1 and WRC-Cross-2 are discovery responses provided by Entergy VY that describe employment levels. The DECON graphic is of scenario 3, and assumes the Station shuts down in 2032 with fuel removed by 2060. The SAFSTOR graphic is of scenario 5, and assumes the Station shuts down in 2032 with spent fuel removed by 2060, and the site restored by 2092 -60 years after shutdown.(Documents available at http://windhamregional.org/images/docs/vy/exhibits/wrc-cross-l.pdf and http://windhamregional.org/images/docs/vv/exhibits/wrc-cross-2.pdf.)

139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org 11 2014. It shows the anticipated change in employment under transition of the plant to SAFSTOR conditions.

This employment information was used in the UMDI study.The more gradual falloff of economic activity associated with DECON offers the region social, economic and fiscal benefits that SAFSTOR does not. We believe it is the responsibility of the NRC to assess the socioeconomic and environmental justice impacts under both DECON and SAFSTOR scenarios to fully characterize the impacts of the choice by Entergy to pursue the SAFSTOR option.Extension of Comment Period: It has come to our attention that some residents of the region may request an extension of the comment period on Docket NRC-2015-0004.

We would support an extension.

We have long recognized the significant and diverse impacts the closure of the plant will have in our region, our towns, our families, our friends, our neighbors, our businesses, and our economy. Understanding these impacts, and what might be done to mitigate them and make our region more resilient, is the reason we have invested all that we have into planning for the plant's eventual closure. We stand by to assist our towns with planning for a post-Vermont Yankee future.Thank you for your consideration of our comments.

Please contact me should you have any questions.

Sincerely, Chris Campany, AICP Executive Director 139 Main Street, Suite 505 / Brattleboro, VT 05301 / Phone: 802-257-4547

/ Fax 802-254-6383 www.windhamregional.org UMASS I 1AS-, I))\A WIII lI I\S I I I L Economic Impacts of Vermont Yankee Closure Prepared for the Franklin Regional Council of Governments Prepared by UMass Donahue Institute Economic and Public Policy Research December 2014/ ..../'i\. .2 V'N Economic Impacts of Vermont Yankee Closure Inroucio Entergy's Vermont Yankee Nuclear Power Station ("Vermont Yankee"), located in Vernon, Vermont along the Connecticut River, has been a crucial component of the Tri-County Region's economy for over 40 years.The Tri-County Region includes Franklin County, Massachusetts; Windham County, Vermont; and Cheshire County, New Hampshire (see Figure 1). As a fully operational electric power plant, Vermont Yankee has provided a foundation for the Tri-County economy, directly accounting for slightly less than one percent of regional jobs and a much higher share of the region's wage and salary income due to hundreds of highly-skilled, well-compensated jobs.Figure 1. The Vermont Yankee Nuclear Power Plant and the Tri-County Region WINDHAM COUNTY Vrmo6t CHESHIRE COUNTY New Hampshire FRANKUN COUNTY Massachusetts Maintenance costs in combination with competition from other, less expensive power sources in the United States, principally natural gas, have resulted in the planned closure of numerous nuclear power plants throughout the country, including Vermont Yankee. The closure of this facility (i.e., cessation of energy production and start of decommissioning), anticipated to take place in the fourth quarter of 2014, and the loss of its high-pay and benefits to workers will have a significant impact on the largely rural Tri-County Region. This study, using available data on Vermont Yankee's employment and payroll, provides estimates of the economic and job impacts on the Tri-County Region resulting from the decommissioning of the plant While the economic impact results, including their multiplier effects as generated from a regional economic model, will be important as they illustrate the immediate magnitude of the closure impacts on the region, the study also assesses the ramifications of the closure as they relate to the economic and demographic FA UMass Donahue Institute'A Economic and Public Policy Research 2 Economic Impacts of Vermont Yankee Closure fundamentals of the Tri-County Region. This last component is important as many of Vermont Yankee's highly paid and skilled workers are expected to move to other locations.

Recent evidence indicates the plant's skilled technicians are already leaving for other parts of the country even before power generation operations at Vermont Yankee have stopped. The three-county region does not presently offer sufficient depth in job prospects to retain a large portion of Vermont Yankee's employees, meaning the income, wage, and salary losses from the plant closure will likely take years to recover.The following analysis includes an estimate of the direct and total economic impacts generated by Vermont Yankee as a fully operational power generating, nuclear facility.

It then demonstrates the progressive decline in economic impacts as fewer and fewer people are needed to work at the property as it ends power generation and goes through successive phases of decommissioning.

The analysis, throughout, is based on demonstrating the economic impacts of the Vermont Yankee closure on the relatively small and contained Tri-County Region. Total economic impacts would actually be greater if measured at the state or national levels as they would capture a greater range of suppliers to the Vermont Yankee power plant.The findings are laid out as follows: a) Vermont Yankee employment and payroll values that serve as the foundation of the analysis; b) the economic impacts of the fully operational Vermont Yankee nuclear plant and the progressive reduction of economic impacts brought about by decommissioning; and c) a broader discussion of the closure of Vermont Yankee in the context of prevailing economic and demographic trends in the Tri-County Region.M, UMass Donahue Institute umAw Economic and Public Policy Research 3 Economic Impacts of Vermont Yankee Closure Overview The Vermont Yankee nuclear power plant is expected to close in late 2014 and thus end its 42 year run as a major supplier of electricity to New England. The closure and ensuing decommissioning process will also see Vermont Yankee's economic contributions to the Tri-County Region fall sharply over the course of five to six years to be followed by a long-period of continued but very low economic activity (especially in comparison with an operating nuclear power plant) associated with the decontamination and security of the property.

This section will briefly describe and compare the jobs and payroll at the fully operational Vermont Yankee plant compared to the number of jobs expected during the decommissioning process.Direct Economic Activity In 2014, Vermont Yankee employed 550 people according to Entergy. As recently at 2011, this figure was higher than 600. These employees, most requiring very specialized skills to manage and operate the nuclear power plant, receive relatively high wage and salary levels reflective of their training and responsibilities.

With an estimated average annual wage per worker of approximately

$105,000, the total payroll of the operational Vermont Yankee would be about $58 million in 2014.1 After the cessation of power generation at Vermont Yankee in late 2014, job levels at the site will decline as the plant begins the decommissioning process. Presently, the planned timeline for the decommissioning expects on-site jobs to fall from 550 in 2014 to as few as 24 during an extended period of dry fuel management.

The drop in jobs over only six or seven years between the operational phase of Vermont Yankee in 2014 to the dry fuel management phase beginning in 2021 will be sharp (see Figure 2). In 2015 and 2016, jobs are expected to decline to 316 during a period of wet fuel (hot) management.

For about four years, 2016-2020, the former Vermont Yankee nuclear power plant will be in a wet fuel (cool) management phase which will require fewer workers (approximately 127). Finally, beginning in 2021, a longer period of dry fuel management could bring employment levels on-site down to as few as 24. During at least the initial wet fuel management phases of the decommissioning, Vermont Yankee will continue to employ its existing, highly compensated workers. For this reason, total payroll, though only a fraction of previous levels, will continue to be significant through at least 2020 (i.e., payroll in 2020 could be as high as $13.5 million in 2020 if the wage and salary levels of Vermont Yankee's operation phase are maintained through that time). After 2021, the significantly lower job levels at the Vermont Yankee site may be accompanied by lower relative wage levels as occupations shift from technical workers to a higher proportion of workers in such jobs as grounds security while the site goes through what may be more than a decade of dry storage.1 Payroll and wage data were not available for 2014, but an estimate of over $105,000 per worker developed for 2011 was vetted for this study among regional and labor experts familiar with Vermont Yankee and deemed consistent with likely 2014 compensation levels.59 UMass Donahue Institute uuAA Economic and Public Policy Research Economic Impacts of Vermont Yankee Closure Figure 2. Worker Numbers at the Vermont Yankee Site Will Decline as Power Generating Operations End and the Decommissioning Phases Begin 600 500 400 300 200 100 0 2014 Operational 2015-2016 Wet Fuel (Hot)Management 2016- 2020 Wet Fuel (Cool)Management Dry fuel Management 2021 +Dry fuel Management 2021 4 (2)Source: Entergy, September 2014.Note: The transition from wet fuel (hot) to wet fuel (cool) management is anticipated to occur during 2016, as depicted in a slide describing Vermont Yankee's staffing transition to decommissioning.2 Vermont Yankee's employees live and spend a large part of their earnings where they reside. Current Vermont Yankee workers live overwhelmingly within the Tri-County Region (see Figure 3), a reflection of the plant's location close to the center of the 2,250 square mile region. The residency of Vermont Yankee employees is an important piece of this analysis as their buying power is significantly greater than average for the region (see Figure 6 on page 11) and their spending whether on homes, restaurants, groceries, or entertainment reverberates through the Tri-County Region, providing critical support to the regional economy. The Tri-County region was home to 481 of Vermont Yankee's 550 employees, accounting for 89 percent of the total in 2014 prior to the plant closure. In 2014, an estimated 204 Vermont Yankee employees lived in Windham County, 176 in Cheshire County, and 101 in Franklin County.3 In this economic impact analysis, the shares of Vermont Yankee employees by county of residence are held constant in future years (e.g., if the region had 89 percent of 550 employees in 2014 while the plant was operational, it will have 89 percent of 127 employees in 2020 during decommissioning).

2 Entergy presentation to the Nuclear Decommissioning Citizens Advisory Panel, September 25, 2014. Web: http://publicservice.vermfont.gov/sites/psd/files/NDCAP%2OSeptember%/"2025th%20201 4%2oPresentation%2ý0-%2OFinal.pdf 3 County estimates for 2014 are based on an actual 2011 allocation applied to the 2014 employment total for Vermont Yankee.FA UMass Donahue Institute u"AS8 Economic and Public Policy Research 5 Economic Impacts of Vermont Yankee Closure Figure 3. Place of Residence for Vermont Yankee Employees Other; 69 Franklin.County; 101._Cheshire County; 176 Windham-County; 204 Source: Vermont Yankee (2014); 481 of Vermont Yankee's 550 employees reside in Tri-County Region;county numbers apply the 2011 geographic place of residence allocation to the 2014 total of 550 employees M UMass Donahue Institute uml*A Economic and Public Policy Research 6 Economic Impacts of Vermont Yankee Closure The closure and decommissioning of Vermont Yankee will reverberate through the Tri-County Region in Vermont, New Hampshire, and Massachusetts and generate impacts beyond the on-site activities taking place at Vermont Yankee. This section of the study provides estimates of the overall economic impacts and reduction in jobs associated with the decommissioning and closure of Vermont Yankee. The economic impacts presented in this section, as estimated and reported, reflect changes in economic activity -both directly and indirectly in terms of the multiplier effects to the broader economy.The economic impacts and job effects were estimated specifically for the Tri-County area at the regional level. To conduct this analysis, we used a customized IMPLAN input-output model 4 for the region to estimate the direct, indirect, and induced effects of the Vermont Yankee closure, in terms of employment, labor income, business sales (output), value added, and state revenue. The results are generated and reported in terms of the following:

• Job impacts represent a change in average annual jobs for the year indicated.

• Labor income consists of total employee compensation (wage and salary payments, as well as health and life insurance benefits, retirement payments and any other non-cash compensation) and proprietary income (payments received by self-employed individuals as income).* Value added represents total business sales (output) minus the cost of purchasing intermediate products and is roughly equivalent to gross state/domestic product (commonly referred to as GSP or GDP). Value added is the enhancement a company gives its products before offering the product to customers.

For example, an oil refinery takes crude petroleum as an input and then transforms it into refined gasoline.

Simplistically, the "value added" in this instance is the difference between the greater value of refined gasoline and the lower value of crude petroleum.

• Output is a broader measure that consists of total business or industry sales. It includes sales to final users (e.g., the sale of gasoline at a service station) as well as intermediate good sales (e.g., the sale of crude petroleum that is required to produce the gasoline).

The total economic impacts as estimated by the IMPLAN model are the sum of direct, indirect, and induced impacts.* Direct impacts are only those associated specifically with activities taking place at Vermont Yankee, whether during the current operational phase or the progressive downsizing during the phases of decommissioning.

The direct impacts of Vermont Yankee include the employees who work at the site, their payroll, and the revenues (sales) associated with the activities taking place at the site.* Indirect impacts are generated when material, equipment or other intermediate purchases are made to support the direct activity.

For Vermont Yankee, indirect impacts come from the businesses supplying goods that the plant (or decommissioning process) needs to operate such as electronic equipment, building materials, specialized services, etc.4 For more information on IMPLAN, see http://www.implan.com/

1 W UMass Donahue Institute uMAs Economic and Public Policy Research Economic Impacts of Vermont Yankee Closure Induced impacts are generated by the local consumer spending, primarily from Vermont Yankee workers (whether in the operational or decommissioning phases) spending their earnings in the local economy. For example, spending by Vermont Yankee employees supports jobs in local stores, restaurants, hair salons, etc.The lower levels of economic activity emanating from Vermont Yankee after the ending of nuclear power generation will translate to fewer dollars available to consumers for spending.

The economic impact analysis includes estimates of the direct and total (sum of direct, indirect, and induced) economic impacts of Vermont Yankee by phase (e.g., the current operational phase as an active nuclear power plant as well as for four specified phases of decommissioning showing a progressive reduction of activity at the Vermont Yankee site). The economic impact methodology described above is visually presented in Figure 4.Figure 4. Economic Impact Analysis Methodology KEY CONCEPTS IN ECONOMIC IMPACT ANALYSIS Investment projects, changes in spending or government policies Iln Multiplier effects act by lndust --ý-- ---------------------------------------------

---

1 1 .."1 I!~I I DIRECT ECONOMIC IMPACTS INDIRECT ECONOMICIMPACTS INDU (intermediate Purchases) (Con R BUasiness Output/Revenues

• Employment Business Output/Revenues Busin* Labor Income Employment and Labor Income Empir* Government Expenditures Value Added

• Value.......... .. ..........

,.----------T E Id i TOTAL ECONOMIC IMPACTS[CED ECONOMIC IMPACTS sumer Spending Effects)ess output/revenues oyment and Labor Income Added nu across Direct. Indirect, and dced Impacts and across kUstries* Business output/revenues

• Employment

• Earned Income Sax revenues-Value Added Vermont Yankee has been a key driver of the Tri-County Region's economy for well over 40 years as an operational power plant. Due to the advanced nature of nuclear power generation, Vermont Yankee, while operational, employs a large number of highly-skilled engineers that receive compensation levels well beyond prevailing regional averages.

During its last year of operation, 2014, Vermont Yankee directly employed 550 people with a payroll (including benefits) of $82 million. By also including the indirect (282 jobs) and induced (387 jobs) impacts, shown in detail in Table 1, that include the positive influences on many local businesses such restaurants, real estate, retail shops, healthcare, and suppliers to the plant,UMass Donahue Institute uImSS Economic and Public Policy Research 8 Economic Impacts of Vermont Yankee Closure Vermont Yankee is estimated to contribute a total of 1,220 jobs in the region in 2014. An advantage of these Vermont Yankee generated jobs is that they are not seasonal or cyclical as are tourism and agricultural related jobs in the Tri-County Region, thus underscoring the plant's long-term role as a regional economic pillar. The overall total economic activity in the region associated with Vermont Yankee in its last year of operation in 2014 is estimated to be almost $500 million in output.Table 1. The Economic Activity Levels of Vermont Yankee to the Tri-County Region Over Time 550 318 126 58 24$82,099,127

$38,564,486

$15,508,264

$2,675,750

$1,100,406

$244,286,992

$66,121,377

$26,547,585

$7,849,919

$3,242,067

$402,707,428

$81,769,337

$32,091,293

$10,573,188

$4,328,235 282 93 37 16 6$10,425,325

$3,547,281

$1,426,498

$618,522 $246,311$31,131,267

$5,541,555

$2,224,922

$968,233 $386,153$47,691,302

$10,528,954

$4,227,352

$1,734,171

$692,314 387 165 66 10 4$14,377,220

$6,106,431

$2,455,631

$361,327 $148,855$26,575,152

$11,297,051

$4,535,741

$667,946 $275,168$43,008,077

$21,464,397

$8,617,908

$1,081,549

$445,562 1,220 577 229 84 34$106,901,672

$48,218,198

$19,390,393

$3,655,600

$1,495,572

$301,993,411

$82,959,983

$33,308,248

$9,486,099

$3,903,388

$493,406,806

$113,762,689

$44,936,552

$13,388,908

$5,466,111 Source: Results are from simulations run in IMPLAN.Notes: All economic activity levels shown are annual (e.g., the levels shown in the "2017-2020"column represent the annual contributions to the economy that are expected for each individual year during the indicated period; they are not multi-year cumulative contributions).

• Total impacts represent the sum of direct, indirect, and induced impacts.As can be seen in Table 1, the economic contributions of Vermont Yankee on the Tri-County Region are expected to decline progressively as the plant moves through successive phases of decommissioning.

In the initial wet fuel management steps of the decommissioning (through about 2020), Entergy will continue to use existing Vermont Yankee employees or bring-in substitutes from around the country, if necessary, to replace key Vermont Yankee workers who have already left for positions elsewhere.

5 Though drastically S The economic impact analysis, throughout, assumes that very few of the skilled Vermont Yankee employees are likely to stay in the Tri-County area to work or start their own businesses.

They are already being successfully recruited and moving to new jobs around the country. Entergy is needing to bring in replacement employees from other plants to do the work of the former Vermont Yankee workers who have already left.FA UMass Donahue Institute u Economic and Public Policy Research 9 Economic Impacts of Vermont Yankee Closure reduced compared to the operational plant in 2014, these highly compensated employees working on the Vermont Yankee decommissioning will continue to make significant economic contributions to the Tri-County Region through 2020. By 2020, the number of jobs supported by Vermont Yankee in the region is expected decline to 229 compared to 1,220 in 2014 (a loss of about 1,000 regional jobs over a relatively short timeframe) when the power plant was still generating electricity.

This includes the loss of about 320 induced jobs -the jobs in such industries as restaurants, retail, and personal services -that are supported by the spending of Vermont Yankee workers in the Tri-County Region.After 2021, when the wet fuel (de-fueling) management phases of the decommissioning are expected to be completed, Vermont Yankee will enter a prolonged phase of dry fuel management (dry cask storage of spent fuels) that may last a decade or longer. During this long-term period, the needs at the Vermont Yankee site will shift to more construction and security personnel.

With this shift, the economic contributions from the closed nuclear power plant to the Tri-County Region will decline further. As indicated in Table 1, the long-term period of interim care and maintenance at Vermont Yankee will have varying degrees of economic contributions to the Tri-County Region depending on the activities taking place at the site. At the lowest level, "2021 Plus (2)" (a term used by Entergy), the Vermont Yankee site will only be making a total contribution of 34 jobs to the Tri-County region, or less than three percent of the jobs contribution of the operational power plant in 2014.Figure 5 shows the impacts of the Vermont Yankee closure and decommissioning in terms of the reduction of jobs (the difference between the total job numbers in 2014 compared to the total job numbers in the upcoming decommissioning phases) in the Tri-County Region expected in coming years. In 2015-16, the region will have 643 fewer jobs compared to having an operational power plant. The economic impact of the closure will increase to 991 fewer regional jobs between 2017 and 2020 and finally to 1,185 fewer jobs during certain dry fuel management phases.Figure 5. Total Job Impacts of the Vermont Yankee Decommissioning in the Tri-County Region (net loss in jobs compared to an operational Vermont Yankee)-200 400 600 800*1,000 1,200 1,400 2015 2016 201 12020 2021 Plus 2021 Plus (2)Source: Results are based on simulations run in IMPLAN in September 2014.Table 2 demonstrates the economic contributions of Vermont Yankee by industry, in terms of jobs, in both its operational as well as its four decommissioning phases. As an operational, power-generating facility, the plant supported 1,220 jobs in the Tri-County Region, with nearly half of these in utilities, the industry A UMass Donahue Institute 10 umID Economic and Public Policy Research Economic Impacts of Vermont Yankee Closure sector classification of Vermont Yankee. As plant workers spend their paychecks in the region, the operational Vermont Yankee supported 141 jobs in Leisure and Hospitality (includes restaurants), 81 jobs in Retail, 54 jobs in Financial Activities (banking, money management, real estate, etc.), 116 jobs in Education and Health Services, and 46 jobs in Other Services (e.g., dry cleaning, pet care, repair services, etc.) in 2014. As Vermont Yankee goes through the decommissioning process, the number of Tri-County jobs supported by the plant in each of these industries declines sharply as shown in Table 2. For example, fewer employees and lower labor income emanating from Vermont Yankee as it is decommissioned will mean the number of jobs in Leisure and Hospitality will fall from 141 in 2014 to fewer than five by 2021, representing a net loss of 136 jobs for the industries classified within the sector (including restaurants, movie theaters, hotels, and performing arts, among others). This pattern of jobs decline resulting from the closure of Vermont Yankee takes place in all of the industry sectors of the Tri-County economy. The temporary upticks seen in Construction and Professional

& Business Services from the operational phase to the 2015-2016 initial phase of decommissioning is simply a shift in jobs from the utilities industry to other sectors as the economic activity taking place at Vermont Yankee can no longer be classified as within the utilities industry because the property is no longer producing energy.Table 2. Vermont Yankee's Jobs Contributions to Tri-Region Industries Will Decline Over Time with the Closure and Decommissioning (total employment associated with Vermont Yankee by industry)16 1 0 0 0 550 3 0 0 0 15 7 3 2 0 81 31 15 1 2 25 7 1 1 0 44 65 27 12 5 3 2 1 0 0 15 5 2 1 0 54 21 8 2 1 ill 320 127 55 23 116 49 20 3 1 141 42 16 5 1 46 22 9 2 1 4 2 1 0 0 1,220 577 229 84 35 Source: Results are from simulations run in IMPLAN.Notes: All employment levels shown are annual (e.g., the levels shown in the "2017-2020"column represent the annual contributions to the economy that are expected for each individual year during the indicated period; they are not multi-year cumulative contributions).

This economic analysis does not include a final upsurge, led by the construction of a shelter for spent fuel, likely to take place in the late 2020s or 2030s which would be the final phase of the Vermont Yankee decommissioning.

M UMass Donahue Institute 11 u"A28 Economic and Public Policy Research Economic Impacts of Vermont Yankee Closure The Vermont Yankee Closure in a Regional Context The economic contributions, as demonstrated in the previous section of the study, made by Vermont Yankee to the Tri-County Region will decline markedly as it transitions from being an active nuclear power plant and enters a series of decommissioning phases. The loss of Vermont Yankee workers, along with their high compensation levels will have long-term effects on the Tri-County economy. In order to provide some context for what this closure may mean to the Tri-County economy, a number of recent trends in jobs, income, unemployment, and population are briefly illustrated in this part of the study. The data and trends (generally 2003-2013) provide a greater understanding of the potential implications of the sustained loss of Vermont Yankee and its economic activities will have on the region.Figure 6. Average Wage Per Employee, Vermont Yankee Compared to Region, States, and U.S.$120,000$100,000$80,000$60,000$40,000$20,000 Source: Vermont Yankee (2011); Bureau of Labor Statistics QCEW (2013)There is a huge wage differential between Vermont Yankee and the Tri-County Region. The annual pay (wage and salary) of a Vermont Yankee worker, approximately

$105,000, is two and a half times greater than the average pay in the region (about $40,000 in 2013). Vermont Yankee, as an operating power plant now directly accounts for 0.7 percent of regional employment and 1.8 percent of regional payroll.Meanwhile, the Tri-County area's relatively low average wages (below the state and national comparison areas shown) are further at risk after the loss of high-paying Vermont Yankee jobs." UMass Donahue Institute 12 u"AS Economic and Public Policy Research Economic Impacts of Vermont Yankee Closure Figure 7. Jobs Growth Index (2003=1.00), Tri-County Region Compared to States and U.S.1.08 1.06 1.04 1.02 1.00 0.98 0.96 0.94 0.92-United States-Massachusetts

--New Hampshire-Vermont i mTri-County 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 Source: Bureau of Labor Statistics, Quarterly Census of Employment and Wages (QCEW)The Tri-County Region's recent jobs performance shows that it is underperforming.

The region did not participate fully in the economic expansion of the 2000s and got hit harder by the 2008-2009 recession.

As the nation tentatively enters a new period of economic expansion, the Tri-County Region is not recovering nearly as robustly as the United States, Massachusetts, New Hampshire, and Vermont, overall. Between 2003 and 2013, the number of jobs in the Tri-County area declined from 82,917 to 79,713, a drop of 3.9 percent. The closure of Vermont Yankee adds a significant obstacle for the region to partake in New England's and the nation's upward cycle of growth.SWUMass Donahue Institute u Economic and Public Policy Research 13 Economic Impacts of Vermont Yankee Closure Figure 8. Per Capita Income Relative to U.S. for Tri-County Region and States, 1990-2012 (Per Capita Income Growth Index, U.S=1.00)1.30 1 1.20-V 0 W-1.00 0 0.90 0.80-U.S. = 1.00-Massachusetts New Hampshire-Vermont ,,Tri-County o M- zT' m n ýo r- W. M O 0 -1 r4J M Ic un 1.0 r, WO M 0 -4 " Source: Bureau of Economic Analysis Per capita income is an encompassing measure of income that covers all income sources (wages, salaries, transfer payments like Social Security, and investment income) and represents the mean average for people living within a region. In general, as shown in Figure 8, the Tri-County Region is seeing a relative rise in its per capita income levels compared to the United States and is following a long-term trend seen throughout New England. In 1990, the Tri-County's per capita income level was five percent lower than the nation's.

By 2012, it had grown to 1.4 percent higher than the U.S. average. However, despite this relative progress compared to the U.S., the region's growth in income levels appears not to be keeping pace with its neighboring and host New England states. While income levels in the region were higher than Vermont's throughout the 1990s, the state has recently caught up and even surpassed the Tri-County area by 2012.The Vermont Yankee closure will affect the income in the Tri-County area by reducing payroll as positions are eliminated and by lowering the investment income of former employees who move away from the region.UMass Donahue Institute iuuM Economic and Public Policy Research 14 Economic Impacts of Vermont Yankee Closure Figure 9. Population Growth Index (1990=1.00), Tri-County Region Compared to States and U.S.1.30 1.25 1.20 1.15 1.10 1.05 1.00-United States-Massachusetts

-- New Hampshire-Vermont inTri-Cou nty 0.95 o -4 (N M -01 LA LO I- 00 M~ 0 Hl (-4 4 H-~ 4 H. H4 H4 ( rJ m oo- L .0o r- 00 0) D -4 (N ry 0 0 0 0 0 0 oooo o4 o4 `4 o 0 0 CD 0 0 0 0 0 0 Source: U.S. Census Bureau The Tri-County Region is following the northern New England trend towards slowing population growth.Unlike the rest of New England, Massachusetts (led by its Greater Boston region) has seen a recent acceleration in its rate of population increase and is now growing closer to the national rate. The Tri-County Region's population, according to the U.S. Census Bureau, has actually seen population declines every year since hitting a peak in 2007. The out-migration of Vermont Yankee workers, which is already taking place even prior to the stoppage of power generation later in 2014, will have a further dampening effect on the Tri-County area's population growth in coming years.FAJ UMass Donahue Institute I Economic and Public Policy Research 15 Economic Impacts of Vermont Yankee Closure Figure 10. Unemployment Rate, 2000-2013, Tri-County Region Compared to States and U.S.(Unemployment Rate, in percent)12 10-8-6-4-2--U.S.-Massachusetts

-.... New Hampshire-Vermont i ,Tri-County 0 2000 20012002 2003 2004 2005 2006 2007 2008 2009 2010 20112012 2013 Source: Bureau of Labor Statistics Figure 11. Tri-County Labor Force Growth, 1990-2013 (Labor Force, in thousands) 108 106 104 102 100 98 96 94 92 07 o -4 "N m -: Ln WD r, 00 M~ 0 ,-1ri MN mc L to rN 00 M~ 0 -4 EN4 On a) a)CY 0) G) O 0) 0) 0) a) 0 0 0 0 0 0 0 0D 0D 0 -4 14 -q -q 0) M~ M~ M~ M~ M M M M 0) 0 0 0 0 0 0 0 0 CD 0 0 0 0 0 v4- -4 --4 --4 4 4 ..EN EN EN EN EN .EN .EN EN EN Source: Bureau of Labor Statistics The Tri-County unemployment rate generally tracks with New Hampshire and Vermont as can be seen in Figure 10. The post-recession decline in the region's unemployment rate, however, is more the result of a shrinking labor force (see Figure 11) than jobs growth. The decline in the labor force suggests that many people may be discouraged with their prospects in the Tri-County area and have stopped looking, moved away, or made other long-term decisions such as retirement.

The loss of Vermont Yankee and the economic opportunities it provided to the region when fully operational, will further stress long-term labor force growth in the region.FAJ UMass Donahue Institute"A' Economic and Public Policy Research 16 Economic Impacts of Vermont Yankee Closure Since beginning construction in 1967 and its commissioning in 1972, Vermont Yankee has contributed significantly to the Tri-County Region's economy. As pointed out in this report, Vermont Yankee, as a fully operational electricity-generating nuclear power plant contributed 1,220 jobs, including multiplier effects, on an annual basis to the Tri-County Region. The high compensation levels of Vermont Yankee's employees who overwhelmingly reside within the region have helped support a range of businesses, including restaurants, retail outlets, and real estate services, among many others, that benefit from their spending.With the closure of Vermont Yankee in late 2014, the economic benefits that have been associated with the plant for over four decades will begin to erode. As shown in Table 1 of this report (page 9), starting in 2015 the economic contributions of Vermont Yankee will begin to decrease sharply, as compared to when the facility was fully operational.

As soon as 2021, depending on the progression of the decommissioning process, the economic contributions of Vermont Yankee will only be a small fraction of what they had been during the plant's 42 years of operation.

The plant's drawdown will adversely affect the Tri-County Region which was already confronting economic and demographic challenges, as shown in the latter part of this report, even before the announcement of Vermont Yankee's closure.This Economic Impact study was prepared by the UMass Donahue Institute for the Franklin Regional Council of Governments, as part of a Tri-County effort to forward economic development in the region.Participants in this effort include the Brattleboro Development Credit Corporation (VT), Franklin Regional Council of Governments (MA), Southwest Region Planning Commission (NH), and Windham Regional Commission (VT). These organizations are collaborating to explore ways to better understand and mitigate the economic impacts of Vermont Yankee's discontinuation of energy generation activities and it's decommissioning.

F UMass Donahue Institute 17"Ass Economic and Public Policy Research Economic Impacts of Vermont Yankee Closure The UMass Donahue Institute (UMDI) is the public service outreach and economic development unit of the University of Massachusetts President's Office. Established in 1971, the UMDI coordinates multi-campus initiatives that link U Mass, other public and private higher education, and other external resources with the needs of government agencies, corporations, and nonprofit organizations.

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UMDI draws on its unique position within higher education to serve as a bridge between theory, innovation, and real-world applications.

The Economic and Public Policy Research (EPPR) group is a leading provider of applied research, helping clients make more informed decisions about strategic economic and public policy issues. EPPR produces in-depth economic impact and industry studies that help clientsbuild credibility, gain visibility, educate constituents, plan economic development initiatives, and prioritize investments.

EPPR is known for providing unbiased economic analysis on state-level economic policy issues in Massachusetts and beyond, and has completed a number of economic studies on manufacturing, technology, defense industries, life sciences, telecommunications, health care, and transportation.

Their trademark publication is called MassBenchmarks, an economic journal that presents timely information concerning the performance of and prospects for the Massachusetts economy, including economic analyses of key industries that make up the economic base of the state.For more information, visit www.donahue.umassp.edu and www.massbenchmarks.or2.

A WUMass Donahue Institute UMASS Economic and Public Policy Research 18