beaver wood pownal 248 filing: no. 8c - pre-filed testimony of richard heaps sd

8/8/2019 Beaver Wood Pownal 248 Filing: No. 8C - Pre-Filed Testimony of Richard Heaps SD

1/37

STATE OF VERMONTPUBLIC SERVICE BOARD

Petition of Beaver Wood Energy Pow nal, LLC )for a Certificate of Public Good, pursuant to 30 )V.S.A. 248, to insta ll and operate a Biomass )Energy Facility and an integrated woo d pe llet Docket Nomanufacturing facility located north of the old )Green Mountain Racetrack in Pown al, Verm ont, )to be known as the Pownal Biomass Project )

PREFILED TESTIMONY OFRICHARD W. HEAPSON BEHALF OFBEAVER WOOD ENERGY POWNAL, LLC

October 25, 2010

Th e purpose of the prefiled testimony of Mr . Heaps is to demonstrate that the propo sedPow nal Biom ass Project will result in an economic benefit to the state and its residen tspursuan t to 30 V.S.A . 248(b)(4).


2/37

TABLE OF CONTENTS

1. Introduction 12. Summary of Findings 43. Conclusion 5

EXHIBITSExhibit Petitioners RWFI-1 Economic Benefit AnalysisExhibit Petitioners RWH-2 Resum of Richard Heaps


3/37


Petition of Beaver Wood Ene rgy Powna l, LLC )for a Certificate of Public Good, pursuant to 30 )V.S.A. 248, to install and operat e a Biom ass )Ene rgy Facili ty and an integ rated wood pellet ) Docke t Nomanufacturing facility located north of the old )Green Mountain Racetrack in Pownal, Vermont , )to be known as the Powna l Biomass Project )

PREFILEI) TESTIMONY OFRICHARD W. HEAPSON BEHALF OFBEAVER WOOD ENERGY POWNAL, LLC

1 1. Introduction

2 QI. Please sta te your name, business address and employment.3 Al. My name is Richard Heap s, and I am Vice-President of Northern Economic4 Consulting, Inc ., an economic consulting and ana lysis firm loca ted in Westford,5 Ve rmont . My fill resum is provided as Exhibit Petitioners RWH- 1.

6 Q2. Please descr ibe your educational background and professional experience.


4/37

Pownal Biom ass Project, PSB Docket No.

_____

Prefiled Testimony of Richard W. HeapsOctober 25, 2010Page 2 of 5

1 A2. I received a masters degree in economics from the University of Illinois in 1977.2 I continued my education at the University of Illinois, finishing all course wo rk3 and examinations necessa ry for a doctorate by 1979. From 1980 thr ough 1998,14 taught economics at the University of Vermont, St. Michaels College, and5 Middlebury Co llege. In 1985, I began Northern Economic Consul tin g wi th two6 other economists. Since 1998, I have worked fill time for Nor the rn Econom ic7 Consu lting .89 With Northern Economic Consulting, I undertake a range of economic stud ies for

10 priva te and public clients. This includes econom ic- and fisc al-im pact ana lyses of11 proposed projects for Act 250, economic-impact ana lyse s of existing institutions12 for public rela tions and other in ternal needs and economic-impact analysis of13 legislative proposals. Recent research projects have examined issues such as a14 similar analys is and testimony before thi s Board wi th respect to the economic15 benefit of the proposed Georgia Mountain Community Wind Project; Vermonts16 economic competitiveness; the impacts of sales-tax differentials on Connecticu t17 Rive r border tow ns ; the impact of slowing population growth on State of18 Vermonts budge ts; and the impact of an electric-utility rate increase on low-19 income res idents. I also prepare bus iness valua tions and litigation support in the20 area of forensic economics.21


5/37

Pownal Biomass Project, PSB Docket No.

_____

Preflied Testimony of Richa rd W. HeapsOctober 25, 2010Page 3 of 51 In addition, my firm has pub lished the Vermont Economy Newsletter sinc e 1991.2 This monthly newsletter exam ines issues such as prospects for economic growth,3 job cre ation, income grow th, the ou tlook for retail sales, tourism, housing prices4 and trends in State governmen t spending and revenue. I write articles on a5 monthly basis examining the se and simi lar economic developmen ts and trends in6 Vermont.7

8 Also, each January since 1992, the Vermont Economy Newsle tter has hosted the9 Vermont Economic Outlook Conference. This annual event provides an

10 opportunity for area economists, policymakers, busin ess people and othe r11 interested Vermonters to explore Vermonts econom ic ou tlook in relation to the12 national and global economic envir onment.13

14 Q3. What is the purpose of your testimony?15 A3. The purpose of my testimony is to demonstrate that the Powna l Biomass Projec t16 (PBP Project or Project) satisfies the requ irements of 30 V.S.A. 248 (b)(4).17 Section 248(b)(4) provides, in pertinent part, that a generation or transmission18 facility should provide an economic benefit the to state and its residents.19

20 Q4. Have you testified previously before the Board?21 A4. Yes. I submitted testimony on behalf of the Vermont Department of Publ ic22 Service in Docket No. 6300, which examined the proposed sale of the Vermont

__


6/37

Pownal Biom ass Proj ect , PSB Docket No.

___

Pref iled Testimony of Richard W. HeapsOctober 25, 2010Page 4 of 5

1 Yankee Nuclear Power (WY) Statio n, and in Docket No. 7440 in connection2 with the proposed relicensing of the VY Statio n. I also submitted testimony on3 behalf of the developer in Docket No. 7508 in connection with the proposed4 Georgia Mountain Community Wind Projec t.5

6 2. Summary of Findin2s7 Q5. Ba sed upon your evaluation and analyses , will the Project provide an economic8 benefit to the state ofVermont and its residents?9 A5. Yes. By way of a brief summary, the proposed Project consis ts of a 29 .5 MW

10 power plant and an integrated wood pellet manufacturing plant . The constructionII of the facility is estimated at $250 million in 2009 prices. Th e combined fac ili ties12 will have a payroll of $3.4 million for 45 employees plus an annual spending of13 $9.9 million for contractors. Th e facilities will be purchasing $18.2 million in14 forest products from loggers harvesting within a 50 mile rad ius of the pla nt . Th e15 construction of the Project will lead to the crea tion of about 960 jobs in Vermont.16 Operation of the facility will create over 140 new jobs with a payroll of over $817 million statewide from 2013 forward. State tax revenues will increase by over18 $2.3 million with the ongoing operations of the plant. The Project will have a19 very positive fis ca l impact on the host town of Pownal, easily paying much more20 in local property taxes than demanding in municipal services. Th e Project will21 make a positive contribution to the states efforts to meet future electricity22 demand, diversify its power generation sources, and maintain a clean energy

_____


7/37

Pownal Biomass Project, PSB Docket No.Prefiled Testimony of Richa rd W. HeapsOctober 25, 2010Page 5 of 5I generation portfolio. Accordingly , it is my conclusion that the Projec t will2 provide an economic benefit to the sta te of Vermont and its res idents. A copy of3 my report is included with my tes timony as Exhibit Petitioner RWH-2.45 3. Conclusion6 Q6. Does th is conclude your testimony?7 A6. Yes.


8/37


Petit ion of Beaver Wood Energy Pownal, LLC )for a Certificate of Pu blic Good, pursuant to 30 )V.S.A. 248, to install and operate a Biom ass )Energy Facility and an integrated wood pe lle t I) k Nmanufacturing facility located north of the old ) oc e OGreen Mountain Racetrack in Powna l, Vermon t, )to be known as the Pow nal Biomass Project

PREFILEI) TESTIMONY OFRICHARD W. HEAPS

Exhibit BWEP - RWH -1Regional Economic Impact Analysis


9/37

NORTHERN ECONOMIC CONSULTING, INC.PUBLISHING THE VERMONTECONOMVNEWSLETTER SINCE 1991

Regional Economic Impact AnalysisforaBiomass Fired Power Generation and Wood PelletManufacturing Facility

in Pownal, VermontProposed byBeaver Wood Energy Pownal, LEC

Prepared byRichard W. HeapsSeptember 8, 2010

669 CAMBRIDGE ROAD WESTFORD, yr 05494 (802) 879-7774 Cell (8021 318-7374email: rheapsvteconomy.coni web page http://wwwvteconomy.com


10/37

Economic Im pact Analysis - Biomass Facility in Pownal, VT September 8, 2010Page i

Executive SummaryBeaver Wood Energ y Pownal LLC proposes to construc t an int eg rated wood biomass-firedelectric gen erat ion plant and wood p ellet manufacturing facility (the Integrated Facility)in the Town of Pownal, Vermont . The total construction cost of the project is estimated to be$250 million at 2009 p ri ces . The Int egrat ed Facility will directly employ 45 peop le wi th anannual pay roll of $3.4 million plus have an an nual spend ing of $9.9 million with third-partycontractor s. In addition, the Integrated Facility will annually pu rchase abou t $18 .2 million inforest pro ducts from local loggers.Th e purpos e of this analys is is to estimate the ec onomic impacts of the proposed Beaver WoodIn tegrated Facility on the state of Ve rmont for presentation to the Ve rmont Public Serv ice Boardas part of the app licat ion for a Sect ion 248 Certificate of Pub lic Good .The integra ted energy generation and wood pellet manufacturing faci li ty will bring significanteconomic benefits to the host town , the neighboring region, and the state ofVe rmont. Thecons truction of the Int egra ted Facility in 2012 through 2013 will lead to the creation of more than770 jobs in Bennington County and a total of about 960 jobs in all of Vermont. Operation of theIn tegrated Facility wi ll lead to the crea tion of over 120 jobs in Bennington County and a total ofmore than 140 jobs in all of Vermont from 2014 forward . Payrolls across the sta te will increaseby over $8 million annually with operation of the Beaver Wood faci lity.Tax revenues to the State of Vermon t from the op eration of the In tegrated Facility are es timatedto increase by an annual total of approximately $2.3 million.Th e Integrated Fac ility will clear ly have positive fiscal impac ts on the host town of Pownal,paying over $500,000 more in annual municipal proper ty taxes than demanding in mun icipa lservice s.Finally, the Beaver Wood Integrated Facility for Pownal will make a pos itiv e co ntribu tion toVermonts effo rts to meet future base-load elec trici ty demand, insulate the state from foreignsou rces of energy, diversi its power gen eration source s, and maintain a clean renewable energygeneration portfolio.

Northern Economic Consulting, Inc. Westford, Vermont 05494


11/37

Economic Impact Analysis - Biomass Facility in Pownal, VT September 8, 2010Page ii

Table of Contents

I. Introduction Page 1II . Detailed Integrated Facility Description Page 2III. The Regional Economy and Demographics Page 3IV. Economic Impacts in Vermont Page 6V. Vermont Energy Market Considerations Page 15VI. Tourism and Property Valuation Impacts Page 16VII. Summary and Findings Page 19



12/37

Economic Impact Analysis - Biomass Facility in Powna l, VT September 8, 2010Page 1

I. IntroductionBeaver Wood Energy Pow nal LLC proposes to const ruc t an int eg rated wood bio mass-firedele ct ric generatio n plant and wood pe llet manufac turing facility in the Town of Pown al,Vermon t. The In teg rated Facility will be located on the west sid e of Route 7 on a parcel of landwhich previou s ly h oused the Green Mountain Race track,Beaver Wood Energy will be subm ittin g an app lica tion for a Section 248 Certificate of PublicGood from the Vermont Pub lic Servic e Board. The ap plication requires an economic benefitanalysis of the In tegrated Facility. This report presents the results of such an analy sis. In sectionII we de scribe the In tegrated Facility in detai l. In section ifi we prov ide a brief econo mic anddemograp hic description of the reg ion in order to put this Integrated Facilitys im pact intope rspe ct ive. In section IV we present our estimate of the impac t of the Beave r Wood Integ ratedFac ility on economic ac tiv ity in the county and state during both its constr uc tion and operatingphases. In sec tion V we discu ss the importance of this In tegrated Facility in meetin g Vermontsenergy needs and renew ab le energy goals. Section VI discusses the impact of the IntegratedFacil ity on tour ism and property value s. We summarize ou r findin gs in section VII.



13/37

Economic Impact Analys is - Biomass Facility in Pownal, VT September 8, 2010Page 2

II . Detailed Integrated Facility DescriptionBeaver Wood En er gy Pownal LLC proposes to construct an in tegrated wood biom ass-firedelectric generation plan t and wood pellet manufacturin g facility in the Town of Pownal,Vennont. The Integrated Facility will be loc ated on the west side of Route 7 on a parcel of landwhich previously housed the Green Mounta in Rac e track.The power plant wil l be fueled by was te wood chips from the surrounding fores t lands withinapproximately a 50 mile radius of the plan t. The wood feedstoc k will include chips from low-va lued trees and wood waste residue s from the logging of hig h v alued trees. It wi ll have a netou tpu t of 29.5 MW of base load powe r. The Integrated Facility is designed to be operated 24hours per day. It is expected that the power will be contracted for by Vermon t utilities unde rlong term power purchase ag reements. Th e wood pellet production facility will have a capacityof approximately 110 ,000 tons per year and utilize waste hea t from the power plan t. Pe lle ts willbe sold in the local market to businesses, schools, governmen t office s, etc., typic ally under mu lti-year sales agreements. The Inte grated Facility is current ly in the permitting stage of itsdev elopmen t. The In tegrated Facility is expected begin commercial operation by 2014.Based on cu rrent information provided by Beave r Wood En ergy , the In tegrated Facility will costa total of $250 million to construct and bring to operation. Th e building, site work, engineering,and other construction wi ll cost approximately $123 million . This wi ll h ave a sign ificant impacton local emplo yment. BeaverWood es timates that $93 million will be expended to proc uremachine ry and equipment for the In tegrated Facil ity. The rem aining cos ts are for fmancing ,reserves , etc. Cons truction will take approximately 26 months.The major econom ic impact of th is In tegrated Facility o n the local and regional economy willcome during its operation. The com bined generation plan t and pel let manufacturing facility wil lhave an employmen t of 45 and an annua l p ayroll of $3 .4 mill ion. The op eration will contractwith outside firms to supply maintenance , repairs, and distribution services at an an nua lexpenditure of $9.9 mill ion. In addition, the facility will contr act with local suppliers fo r forest-product inputs totaling approximately $18 .2 million per year. (All f igure s are in 2009 dollars.)Therefore a key impact of th is Integra ted Fa cility during its operation is the employmen t andwages it creates and maintains in Bennington Coun ty and the rest of Vermont as well as theproduction of electr icity that diversifies Vermonts e lectricity generation in a renewable manner.



14/37

Economic Impact Analysis - Biomass Facility in Pownal, VTPage 3 September 8, 201 0

Ill. The Regional Economy and DemographicsThe Beaver Wood Energy Integrated Facility will be built on l and in Bennington County in theTown of Pownal. In order to put the economic impact of the Integrated Facility into perspective,we briefly present some key summary statistics on the demographics and economics of thecounty and town.Bennington County is the eighth smallest of the fourteen counties in the state of Vermont interms of population. It is home to s ix percent of the states population. Bennington Countyspopulation declined by 565 people, a decline of 1.5%, from 2000 to 2009. The population of theTown of Pownal also declined during the period 2000 to 2009, falling by 86 people, for a declineof 2.4%. During this period, the population of Vermont grew very slowly, increasing by only1.9% in nine years. Nearly all of southern Vermont has lost population in t he last decade. Allpopulation data are from the U.S. Census.

Regional Population GrowthJuly 1, July 1,2000 2009

Area Population Population Growth RateTown of Pownal 3,551 3,465 -2.4%Bennington County 36,976 36,411 -1.5%State of Vermont 609.903 621,760 1.9%

Bennington County is also home to 6% of the states employment. From 2000 to 2009,Bennington County lost 2,149 jobs or 11.2% of its total jobs just nine years ear lier . The Town ofPownal los t 19.5% of its jobs during this period. During this period payroll employment in thestate ofVermont fell just 1.4%, a loss of 4,098 jobs. All employment data are from the VermontDepartment of Labor.

Regional Employment Growth2000 2009 Growth

Area Employment Employment RateTown of Pownal 241 194 -19,5%Bennington County 19,112 16,963 -11.2%State of Vermont 296,468 292,370 -1.4%

Northern Economic ConsuLting, Inc. Westford, Vermont 05494


15/37

Economic Impact Analysis - Biomass Facility in Pownal, VT September 8, 2010Page 4Bennington County s indus trial structure is generally similar to that of the state as a whole.Em ployment at goods-producing firms (most ly cons truc tion and manufactur ing companies ) madeup 20% to 22% of tot al private employmen t in the county and sta te. Emp loymen t at servic e-producing finns (trade , professional services , health care , tourism, etc) accounted for theremainder of the private employment. Be nnin gton County had a sligh tl y higher concentration ofprivate sector jobs in manufacturing than did the state (17% to 13%) as well as a high erconcentration of re tail jobs (20% to 16%) .Public sector jobs only accounted for 13% of the total jobs in Bennington County versus 18% forthe state. Be nnington Co unty has a disp roportionate small share of federal and sta te governmentjobs compared to the sta te.

Regional_Employment Structure 2009Private Goods- Service- PublicSector Jobs producing producing Sector JobsArea (% of total) industries industries (% of total)

Bennington County 87% 22% 78% 13%State of Vermont 82% 20% 80% 18%

Finally, according to the Vermont Tax Departmen t median family incom e in 2008 was S47,583or 9% below the leve l of $52,192 for Benning ton County. Th is was also 18% be low thestatewi de median of $58,069.Over the last eight years, med ian family inc ome grew fairly consistently in the town, county andstate, increasin g at an annual rate of 3.0% in Pownal and 3.3% in all of Vermont.

Regional Median Family Income Growth2000 2008 AnnualArea Income Income Growth Rate

Town of Pownal $38,733 $47,583 3.0%Bennington County $42,139 $52,192 3.1%State of Vermont $46,113 $58,069 3.3%



16/37

Economic Impact Analysis - Biomass Facility in Pownal, VT September 8, 2010Page 5

In sum, Pownal and Benn ington Coun ty are s low growing regio ns, even more slow growing thanthe sta te of Vermont as a whole. Both the tow n and coun ty have seen their populations decreaseslightly and the trend is for tha t to con tinue. Like the state (and na tion), Pownal and Benningto nCounty employers have lost jobs in the last decade. But the town and county have lost jobs at amuch higher rate than the sta te. This is pa rticu larly difficul t for the town and region to absorb asmed ian fam ily income in both is significantly below tha t for the state as a whole.A project such as the Beaver Wood In teg ra ted Facility, wh ich will boos t the local economy andcreate much needed jobs, is sorely needed in the region.



17/37

Economic Imp act Analysis - Biomass Facility in Powna l, VT September 8, 2010Page 6

IV. Economic Impacts in VermontA. Economic Model InputsWe estim ate the impac t of the proposed Beaver Wood Energy In tegrated Facility planned for theTown of Pownal by use of a regional econom ic model maintained by Regional Dynam ics Inc.(REDYN) . The REDYN model is a dynamic, multi-regio nal , en dogenous, input-outpu teconom ic and demog raph ic mode l based on the North Americ an Industrial Classification System(NAICS). The model estim ates a range of economic impac ts of concern to this analysis :employmen t, wages, tax revenues, etc. It also estimates demog raphic impac ts.The inpu ts to this model we re developed with data supplied by Beaver Wood Energy and inconsultation with REDYN staff. The model inputs we used in thi s analysis included theconstruction costs plu s expected opera tiona l expenditures. Th e inpu ts into the REDYN model(in 2009 dollars) are given be low. Because of the locat ion of the Powna l plan t near the NewYork border, Beaver Wood estimates only 30% of the planned purchases of fores t p roduc t inputsfor the power gen erat ion and pellet manu facturing will be with Vermont firms.The inputs are listed in a table on the following page .

Northern Economic Consulting, Inc . westford, Vermont 05494


18/37

Economic Impact Analysis - Biom ass Facility in Pownal, VT September 8, 2010Page 7

Inputs to REDYN Model (2009 dollars)Item Cost DateConstruction $123,000,000 2012- 2013Opera tion

Power GenerationEmployment 22 FT jobs begin 2014

Payroll $1,768,200Maint., repair, etc. $3,571,200

Biomass fuel $10,500,000Pellet Manufacturing

Employment 23 FT jobs begin 2014Payroll $1,626,600

Maint., repair , etc $576,000Distribution $5,760,000

Wood inputs $7,735,000

Based on these inpu ts, we estimated with the REDYN mode l the indirect economic impacts forthe region and the state as well as the demographic impacts.For purposes of this analysis we used a REDYN mode l w ith the following three regions:Bennington County , the rest of Vermon t, and the rest of the U.S. Also , because the RED YNmodel opera tes on an an nual ba sis , we assume all perm itting occurs in 2010 and 2011 , allconstruction in 2012 and 2013 , and operations beg in on January 1,2014 .



19/37


B. Economic Model OutputsWe show the major econom ic and demograph ic impacts tha t are of interest to this analysis fromthe proposed Pow nal Beaver Wood Energy Integrate d Facil ity in th e tab le be low.During the construction phase employm ent will inc rease by more than 770 in Benn ington Coun tyand about 960 throughou t the en tire state ofVe rmont, (this inc ludes the 770 jobs in Benning tonCounty). Then in 2014 and the following years, the operation of the Integ rated Fac ili ty willgenera te over 120 jobs in Bennington Coun ty (including the 45 at the Integ rated Facility site) anda total of more than 140 jobs sta tew ide (inc luding the 120 in Bennington County).

Economic Impacts of the Beaver Wood Energy- Pownal, VT Integrated Facility(Changes from the Baseline)Variable Region 2012 2013 2014 2015 2016

Employment Bennington Gty 786 770 123 122 121All Vermont 976 957 144 143 142

Wages ($million) Bennington Cty $27.3 $27.2 $7.1 $7.2 $7.2(In 2010 dollars) All Vermont $36.1 $36.0 $8.1 $8.2 $8.3

State Taxes ($million)(In 2010 dollars) AllVermont $2.7 $2.7 $2.3 $2.3 $2.4

Population Bennington Cty 48 94 104 68 34Alt Vermont 70 137 148 94 43



20/37

Econom ic Impact Analysis - Biomass Facili ty in Pownal, VT September 8, 2010Page 9

Wage ga ins fol low the employment pattern. During the construction years, wages paid in thestate rise by $36 mi llion . With the op eration of the In tegrated Facility beginning in 2014 thewage gain in the sta te totals over $8 million. Wages then grow with general wage inflation.The Integrated Facility will generate new tax revenu es from its construction and opera tion inBenn ington County and from the economic ac tivity elsewhere in the state. The REDYN modelestimates that tax paymen ts to the state will inc rease about $2.7 millio n du ring the constructionyears. Th is includes sales taxes, income taxes, co rporate income tax es, and other state taxes.Then, wi th the operat ion of the plant, new tax revenues wi ll equal $2.3 million per year (as theplant also begins to pay state education property taxes).Finally, with the ongoing operation of the Integrated Facility, population will rise by 34 people inthe Bennington County and 43 in to tal throughout the state.

C. Reasonableness of EstimatesWe examine the reasonableness of our es timates in two ways. First, we examine thereasonableness of the inputs we used in the REDYN model. Second, we compare thereasonablen ess of the ou tputs from the model with that from another, w idely-used economicmodel.Fir st , the Bur lington Electric Depa rtmen t has been gen erating ele ctricity from the McNeilGenera ting Station since 1984. The plant is a 50 MW facility tha t operates at about 60% ofcapacity . It has an annual payroll of ab out $2.5 million with an emplo yment of approximately40 people. It purchases about $11.5 million per year in biomass fuel. The proposed Pownalgeneration plan t (w ithou t the pel let manufacturing operation) is rated at 29.5 MW, will directlyemplo y 23 peop le plus co ntractors, will operate at 92% of capacity, and use $10.5 million ofbiomass fuel.With a plan t about 60% of the rated size of the Burlington electric plant , the Beaver Wood plantcalls forjust about 60% (22 versu s 40 ) of the employment and 70% ($1.8 mill ion vers us $2.5million) of the payroll. Th e ratios of production capacity , empLoyment, and wages between the

Burlington Electric Commission, Performance Measures Report, March 2009.2 See the AnnuaL Report at wwwdldrconi.



21/37


McNeil plant and the proposed Pownal plant demonstrate the reasonableness of the inputs usedin the REDYN model.We also compared the estimated total statewide employment from the REDYN model to theemployment suggested by the multipliers produced by th e U .S . Bureau of Economic AnalysisRIMS II model. As discussed using the REDYN model, th e 45 jobs and contractor payments atthe proposed Pownal combined facility are estimated to lead to about 140 jobs in a ll of the stateof Vermont during its operation. The RIMS II model estimates these 45 jobs plus contractorpayments would lead to the creation of 298 jobs in the state. The difference is accounted for bythe location of the plant in Pownal, at the extreme southwest corner of Vermont. Much of thegain in jobs that would be captured by the state if the plant was located in the center of the stateoccur instead in Massachusetts and New York.The estimate from the RIMS II model supports the estimate presented in this report from theREDYN model.

Ryegate Associates operates a 20 MW wood-fired electricity generating plant in Ryegate. Vermont. Theplant states that it has an employment of 21 people. which is also consistent with the plans for the Beaver woodfacility in Pownal.

The RIMS II jobs multiplier for electrical generation plants is 3.0743, for wood products manufacturing is2.0774, and for the logging industry is 2.0291. These multIpliers suggest a total of 298 jobs would be created inVermont from the proposed plant(22 jobs times 3.0743 plus 23 jobs times 2.0774 plus 90 jobs times2.0291).



22/37


D. Fiscal Impact on the Host Town of PownalThe proposed Beaver Wood biomass facility will be sited in the Town of Pownal. The town willbe impacted positively by any tax revenues generated by the Integrated Facility and negatively byany demands for town services from the Integrated Faci li ty or any new employees attracted to thetown as residents by the Integrated Facility.We estimate that Bennington County will see a population increase of 34 people because of thisIntegrated Facility. A few of these new residents will choose to l ive in the Town of Pownal.U.S. Census data on commuting patterns show that 53% of the employees of Pownal townbusinesses live in Pownal. Therefore, we assume that Pownal will see eighteen new residentsfrom this Integrated Facility (34 times 53%)5 And we expect they will live in eight newhouseholds based on the average household s ize for the region (eighteen divided by 2.41 averagehousehold size in Bennington County).Note that the population impacts are all sma ll. The 2009 population of Pownal is estimated bythe Census Bureau to be 3,465. If eighteen residents were added to the total, the increase wouldbe less than one percent (only 0.5%). And we note that Pownals population has declined duringthis decade (by 86 people) . The potential for these new residents to cause a fiscal problem, ratherthan being a fiscal benefit, is small.In the following section, we examine in detail the fiscal impact on the Town of Pownal from theproposed Integrated Facility.

A. Impact on the Demand for Municipal Services in the Town of PownalThe budgeted expenditures for Town of Pownals municipal general and road find in FY I 1 is$1,789,690, of which $1,319,105 will be raised through property t axes . We est imate the currentmunicipal costs per employee and per household by use of a per capita expenditure methodcommonly used in conducting an impact analysis. Th e method divides municipal expendituresinto residential and nonresidential based on grand l ist data. The following table shows thecalculations for the municipal cost per new employee (excluding highway costs) and per newresidence in the Town of Pownal.

This is an overstatement of the actual number of residents that will likely choose to live in Pownal. As theanalysis shows, the conclusion is not sensitive to the number chosen.

6 Development ImpactAssessment Handbook, Robert W. Burchell, David Listokin, William R. Dolphin,Lawrence Q. Newton and Susan!. Foxley, Urban Institute, 1994, page. 129.



23/37

Economic Impact Analysis - Biomass Facility in Pownal, VTPage 12 September 8, 2010

Town of Pownal Municipal Impact Parameter CalculationI. Municipal budgeted expenditures (FYI!)2. Total Taxable Parcels

$1,789,690I ,7 I I

Residential parcels 1,4 37Percent of total 84 .0%Nonresidential parcels 274Percent of total 160%

2. Total Assessed Value $205,045,000Residential parcels $179,322,600Percent of total 87.5%Nonresidential parcels $25,722,400Percent of total 12.5%

3. Expenditure parametersResidential

Share residential 85.7%Estimated residential expenditure $1,534,133Cost per residence $897

Non-residentialShare nonresidentiaL 14.3%Estimated nonresidentialexpenditure $255,557Total employees at Town ofPownal businesses (2009) 241Cost per employee $1,060

The cost of municipal se rvice s per new residence and new emplo yee is ca lculated in the table tobe $897 and $1,060 , respe ctively. The cost is based on the average share of the parcel total andassessed Value represented by re sidences and employm ent.

Northern Economic Consulting, Inc. Westford, vermont 05494


24/37

Economic Impact An alys is - Biomass Facility in Pownal, VT September 8, 2010Page 1 3

Next, we ca lculate the total cost, total tax revenue and net benefit from bo th the IntegratedFacility itself and the new residences. Our ca lculations are shown be low.Town of Pownal Municipal Impact AnalysisExpenditure and Revenues

Beaver Wood FacilityAssessment $96 ,100 ,000Tow , Tax rate $05842Taxes $573,100Cost fran the 45 emp4oyees $47,700Net benefit from Integrated Facility $525400

New residencesAssessment of 5 new residences $1,289,392Towi Tax Rate $05842Taxes $7,533Cost from 8 residences $7,176Net benefit from new residences $357

Total net benefit $525,757

First, we consider the fiscal impact on the mun icipa l budget from the Integrated Facility itself.We estim ate the assess ed v alue of the Integrated Facility would he $98.1 million for FY11.Municipal prope rty taxes on the In tegrated Facility would be $573 ,100 based on the FY11mun icipal tax rate of $05842 per $100 of lis ted value. Us ing the per employee munic ipa lexpenditur e p arameter developed above, the cost of new municipal services su pplied to theBeaver Wood Integrated Facili ty (using 45 employees) would be $47,700. Therefore, the netim pac t on the municipal budget from the Integrated Facility itselfwill equal a ne t bene fit of$525 ,400 in FY11. (This is a sign ificant net benefit to the small Town of Powna l, amounting toabout 45% of pro perty tax receipts at the current tax rate. )

Industrial properties in the Town of Pownal are listed at 79.72% of fair market value according to theCertified Final Computation Sheet for Pownal prepared in December 2009. Therefore, based on its constructioncost of $123 million the Integrated Facility will be listed at $98.1 million.

Northern Economic Consulting, Inc. westford, Vermont 05494


25/37

Economic Impact Analysi s - Biomass Facility in Pownal, VT September 8,2010Page 14

Next, we assume the four new household s that move into residences in Pownal because of theBeaver Wood Integrated Facility will live in homes of ave rage lis ted value , which equaled$161,174. The total assessed housing valu e of the eight new househ olds would be $653,7 12.Th is will generate $7 ,533 in new mun icipal tax revenue. The cost from the eight residenceswould be $7,176 based on the spendin g p arame ters detennined above . Therefore, the town willseen see a net fis cal benefit from the four new residences of $357.Fina lly, the combined net benefit to the Pown al munici pal budget from the proposed BeaverWood facility and the eight new hou seholds is es timated to be $525,757. If the town chose tokeep spending constan t (excep t for the estimated increase for the plant and the four newhouseholds), the municipal tax rate could fall from $0.5842 to $O.4106 saving the ave rage-valuedhom e in Pownal $280 per year in taxes.Th erefore, the proposed Beaver Wood facil ity will have a very sign ificant positive impact on themunicipal budget of the Town of Pown al.

Based on the December 2009 Final Computation Sheet from PVR



26/37


V. Vermont Energy Market ConsiderationsThe Vermon t econ omy needs to have reliable and competitively pric ed ele ctricity in order topromote economic grow th and the wel l-being of its citizens. Tn addi tion, Vermon ters haveexpressed their de sire to use renewable energy sources to the exten t po ssible. Several salientcharacteristics of the states provision of electricity are :

The demand for electricity in Vermont grew stead ily from 1989 unti l the curren trecess ion . Acco rding to the ISO New England 2009 Regional System Plan , Ve rmontsdemand for electricity will grow at an annual rate of 0.5% from 2009 to 2010.Vermonts source of elect ric power has been highly concentrated from two producers:Entergy Yankee (nuclear) and Hyd ro-Quebec (hydroe lectric). According to the Ve rmon tDepartmen t of Pub lic Service, in 2003 the former supp lied 36% of the state s powe r andthe latter 28% . Both produce power without emitt ing greenhouse gase s.Entergy Yankees license to operate ends in March 2012. The question of renew ing thislicense is before the state s legisla tu re and regu latory board. A long-term power cont ractwith Hyd ro-Quebec was just signed in August 2010.

The future supply of elec trical power to Vermon t is still unce rta in. In any outcome, secur ing amore diverse portfolio of power is a prudent ac tion. One of the major prio rities of the 2005Vermont Elec tr ic Plan prepared by the Vermont Department of Pub lic Se rvice is to ensure thatVermonts ove rall energy portfolio is suffic ien tly diverse ...Part of the an sw er to the future of elec trical genera tion in Vermont will inc lude biomassgenerated power . Th is would help replac e som e of the possibly reduced elect rical power fromYankee (or mee t the futur e growth in demand for electr ical power), aid in the goa l of diversifyingpower source s, and k eep the Vermont powe r generat ion portfolio clean. The Beave r WoodEnergy Integ rated Facility is an important part ofVermonts long term electric al energyproduction.



27/37

Economic Impact Analysis - Biomass Facility in Pownal, VT September 8, 2010Page 1 6

VI. Tourism and Property Valuation ImpactsTwo frequen tly ra ised concerns abou t new elec trici ty generation (and othe r) fac ili tie s inregulatory hearing s in Vermont are the po tential impacts they could have on the local tourismindustry and local property valu ations. We provide a brief rev iew of these two concerns as theymight affect the Pownal Integrated Facility below.

A. Potential Tourism ImpactsThe poten tial of this Integrated Facility to negatively impact the local tou rism industry is verylim ited for three reasons (assum ing it actually would have a sign ificant , negative imp act on sometourists ).

First, the Beave r Wood Energy Powna l will be locate d on a 45 acre parce l within the 144-acre site of the fonner Green Mountain Race Track, west of Route 7 just south of thecenter of Pownal. The ex ten sive groun ds will allow the fac ility to be hidden from tour ist straveling Rou te 7, except fo r the estimate d 180 to 230 foot high stack. Even the largeststru cture of the Integ rated Fac ili ty is small er than the enc losed grandstand build ingcurrent ly on the property.Second, the potential to negatively impact the local tou rism indu str y is very lim ited by thesma ll size of the tour ism industr y in Pownal. U.S . Census repo rts show only one lodg ingestablishment and three food service bus iness es in the town.

Therefore, we conclud e there will be no measurable impact from the proposed BeaverWoodEnergy Integrate d Facility on the loc al tourism economy .



28/37

Economic Impact Analysis - Biomass Facility in Pownal, VT September 8, 2010Page 1 7

B. Potential Property Valuation ImpactsAnother concern sometimes raised with biomass generating plants is the potential negativeimpact of the Integrated Facility on local property values. Often a claim is made that the plantswill be negatively perceived, thus the demand for local properties will fall, and hence, localproperty valuations will fall.Again the Beaver Wood Energy Pownal Integrated Facility will be located on a 45-acre parcelwithin the 144-acre parcel that used to house the former Green Mountain Race Track. Most ofthe facility will be hidden from direct site except for the water-vapor stack. For the fewproperties located nearby to the north, wood storage silos will be constructed on that side of theproperty to reduce any noise headed in that direction.A small number of rigorous, unbiased studies of the impact of power plants on local propertyvalues have been completed over the years. Most have been done on large power plants insuburban/urban areas. The most recent study we found, which builds on previous research, wascompleted in 2008 by Lucas W. Davis of the University ofMichigan. His study looked at theimpact of large power plants (greater than 100MW) on property values within two miles of theplant. He found housing property values near smaller (less than 325 MW ) , as opposed to larger,power plants fell on the order ofjust 1.2%. Given that the Beaver Wood plant is rated at just29.5 MW, this suggests the impact on nearby housing values is likely less than l%!0In addition, there is a great deal of academic literature on the impact of a variety of potentiallyundesirable land uses including high tension power lines, landfilLs, roads, airports, etc. Ourreview of this literature shows that when a Integrated Facility is well-designed (that is, takesreasonable efforts to minimize the negative impacts) the adverse impacts on property values aresmall (generally less than 5%) and very localized (usually felt only within 500 feet of the landuse. This suggests the impact of the Beaver Wood Integrated Facility on local property valueswill be Limited to the few residential properties located very near to the Integrated Facility. Thereare few such residences.

Lucas W. Davis, The Effect of Power Plants on Local Housing Values and Rents... Review ojEconomicsand Statistics, forthcoming. We note that the average $161,000 home near the plant would see a drop in value of less than $1,610 at

the 1% level. We previously showed that the proposed plant could result in a municipal tax decrease of $280 peryear. This would compensate a homeowner in just six years for the loss in property value.



29/37


Fina lly, we no te that Vermont has actual experience with the Burling ton Electric Departm entsMcNei l Generating Station. Th is plan t is loca ted within 500 feet of a number of propertieswhich have a direct sigh t view of the plant. According to the city assessor (Tom Vickery), thecity has seen no evidence to suggest property va lues should be low ered for those res ide nceswith in close proximity of the genera ting plant. No reques ts have been sent to the asses sorsof fice requesting such a reductio n.We conclude there wi ll b e essent ially no negat ive impact from the proposed Beaver WoodEnergy In tegrated Facility on neighboring prope rty va lues.



30/37

Economic Impact Analysis - I3 iom ass Fa cility in Pownal, VT September 8,2010Page 19

VII. Summary and FindingsThe proposed Beaver Wood Energy Integ rate d Facility consists of a 29.5 MW pow er plant and anintegrated wood pe llet manufacturing plant. The const ruction of the facility is estimated at$250 million in 2009 prices. The combined facilities will have a payrol l of $3.4 million for 45employee s p lus an annual spending of $9.9 million for contractors. The facilities will bepurchasing $18 .2 million in forest products from loggers liv ing within a 50 mile radius of theplant.The construction of the In tegrated Fa cility in Pownal will lead to the creation of about 960 jobsin Vermont. Opera tion of the facility will create over 140 new jobs with a payroll of over$8 million statewide from 2013 forwa rd. State tax revenues will increase by over $2.3 millionwith the ongoin g operation of th e p lant.The In tegrated Facility will have a very po sitive fiscal impact on the hos t tow n of Pown al, easilypaying much more in local property taxes than demanding in mu nicipal serv ices .The In tegrated Facility wi ll make a positive contributio n to the sta tes efforts to me et futureelectricity dem and, diversif its power generation source s, and maintain a clean ene rgygeneration portfolio.



31/37


Petition of Beaver Wood Energy Pownal, EEC )for a Certificate of Public Good, pursuant to 30 )V.S.A. 248. to install and operate a Biomass )Energy Facility and an integrated wood pellet Docket Nomanufacturing facility located north of the oldGreen Mountain Racetrack in Pownal, Vermont, )to be known as the Pownal Biomass Project

PREFILED TESTIMONY OFRICHARD W. HEAPS

Exhibit BWEP - RWH -2Resum


32/37

NORTHERN ECONOMIC CONSULTING, INC. Resume

RICHARD W. HEAPSEconomist

EDUCATIONB.S., 1971 , University of illinois , Secondary Education

POST GRADUATE STUDYM.S. , 1977, University of Illino is, Econom ics

COMPANY DIRECTOR1985 - presen tVice Presiden tNorthern Economic Consulting, Inc.Perform s econom ic analys is of legal, bus iness and pub lic policy issues. Pub lishes TheVermont Economy Newsletter.

OTHER PROFESSIONAL EXPERIENCE1980- 1986, 1987- 1991, 1993- 1996Departm ent of Econom icsUniversi ty ofVermontOffered course s in International Finance; Financial Markets; Money and Banking;Stat is tics and Economeirics1992Department of EconomicsSt. Michael s CollegeOffered cour ses in Economic Theo ry1986- 1989, 1996-1998Departm ent of Business AdministrationUniversity ofVermontOffered courses in Financial Markets; Interna tional Business Fina nce; Bus inessEconom ics

669 Cambridge Road Westford, Vermont 05494 (802) 879 - 7774Page 1


33/37

NORTHERN ECONOMIC CONSULTING, INC. Resume1986- 1987Departmen t of EconomicsMidd lebury CollegeOffered cour ses in Money and Bank ing; Economic Theory1976- 1978 and 1979-1980Departm ent of EconomicsUniversity of IllinoisTeaching assistantOffered courses in statistics and econometrics1978- 1979Departamen to de EconomiaUniversidad Ca tolica del PeruLim a, PeruResearch Assistan t1971 - 1975Ch icago Pub lic School SystemMathemati cs Teacher

MEMBERSHIP IN PROFESSIONAL ORGANIZATIONSNatio nal Associa tion of Forens ic EconomistsAmerican Academy of Econom ics and Financial Exper tsAmerican Soc iety ofAppraisers, cand idate memberTrea surer, VennontNew Hampshire Chapter of the American Society of Appra ise rs

VERMONT AFFILIATIONSPlannin g Commission , Town ofWestford, 1991- prese ntChairman, Planning Comm iss ion, Town ofWestford , 1992 to 2000

OTHER VERMONT ACTIVITIESTestifies on econom ic issues to Vermont legisla tive committees.Regu larly quo ted by Vermon t media on economic ma tters.Give s presentations and talks on eco nom ic issues throu ghou t the state.

669 Camb ridg e Road Westford, Vermont 05494 (802) 879 - 7774Page 2


34/37

NORTHERN ECONOMIC CONSULTING, INC. ResumeRECENT RESEARCH AND OTHER STUDIES (SINCE NOVEMBER 2002)

Ve rmont Economy Newsle tter , edited and published by Richard W. Heaps and Ar thurWoolf since 1991.Employment Impact of the Proposed TDIManufacturing Facility in Rutland County.prepared August 30, 2010 for Tactic al Developmen t Innovations, Inc.Price Analysis of the Addison-Crown Point Ferry Service, prepared Apri l 9, 2010 for theVermont Agency of Transportation.Economic Issues Concerning the Adoption ofLocal Op tion Taxes in the Village ofEssexJunction, prepared January 26, 2010 for the Local Option Taxes Committee of the Vi llageand for presentation to the Villag e Trus tees .Economic, Demographic and Fiscal Impact of the proposed Brandon Plaza, August 26,2009 , prepared for Second Generation Developmen t LLC for su bmission with an Act 250app licatio n.Regional Economic Impact Analysis for the Georgia Moun tain Commun ity Wind Project,March 23, 2009 , prepared for GMCWP for submission before the Vermon t PublicService Board.Employm ent Impact ofa Proposed Lodge at Quarry I-Jill in South Burling ton, April 29,2009, prepared for the Bul iro ck Corporation in connection wi th an EB-5 application.The Economic Impact ofSugarbush Resort, November 7, 2008 . Prepared for the Resort.The Econom ic, Demographic and Fiscal Impact of the Proposed Wal-Mart Retail Storein St. Albans Town, Vermont, October 20, 2008. Prepared for ED Properties of St.Albans , LLC for prese ntat ion to the Vennont Environmental Court.Economic, Demographic and Fiscal Impact of the Proposed Expansion of the She lburneBay Senior Living Community, October 15, 2008. Prepa red for pres entation to theVermon t En vironmen tal Commission .The Economic Impac t of the VYS tation on Windham County and Vermont, February 15,2008. Prepared for Entergy Nuclear Vermont Yankee for presentation to the VermontPublic Service Board .Economic, Fiscaland Demographic Ana lysis of the Proposed Tractor Supply Sto re inDerby, Vermont, Feb ruary 14,2008. Prepared for Primax Properti es, LLC and forpresentation before the Dist rict Environmental Commission.

669 Cambridge Road Westford, Ve rmont 05494 (802) 879 - 7774Page 3


35/37

NORThERN ECONOMIC CONSULTING, INC. Resum eAn Analysis of the Proposed Staples Project... and the Middlebury Zoning Ordinance,January 17, 2008. Prepared for Middllebury Assoc iates, LLC and for presentation to theMiddlebury Development Review Board.Demographic Change s in the Elderly Population of Vermont. Test imony presented April9, 2007 for the app lica tio n of Vermont Eye Laser for a Certificate of Need from theVermont Depar tmen t of Banking, Insur ance, Secur ities, and Health Care Adm inistra tion .The Economic. Demographic and Fiscal Impact of the Home Depot Store in Berlin,Vermont, March 29, 2007. Prepa red for Cross Consulting Engineers and for presen tationto the District Environmen tal Commission .The Economic Impact ofChamplain College, January 8, 2007. Prepared for ChamplainCollege, Burlington, Vermon t.The Econom ic, Demographic and Fiscal Impact of the Proposed Rutland CommonsDevelopmen t, January 3, 2007. Prepared for presenta tion to the District 4 EnvironmentalCommiss ion .Demographic Changes and Their Fiscal Consequences in Vermont, December 1, 2006 .Prepared for the Ethan Allen Foundati on .1-91 Airspace Lease: Greater Upper Valley Solid Waste Management District and TwinState Sand & Gravel, Inc., Sep tember 5, 2006. Prepared for the Vermont Agency ofTranspor tation.The Impact of the Shelburne Road Reconstruction on Local Businesses, Augu st 7, 2006.Prepared for the Vermont Agency of Transpo rtation .The Economic impact ofPike Industries Operations in the State of Vermont, July 21,2006 . Prepa red for Pike Indust ries, Inc.A Market Analysis of the Proposed Home Improvement Stores: Plymou th, NewHampshire, July 17, 2006 . Prepa red for The Home Depot, Inc. And presen ted to theTown of Plymouth, New Hampshire Planning Commission .The Econom ic, Fiscal, and Demographic Impact of the Proposed South Peak Resor t byRichard W. Heaps, January 26, 2006. Prepared for Centex Desti na tio n Properties andpresented to the Town of Lincoln, New Hampshire Plann ing Commission.An Analysis of the Common Level ofAppraisal Determinedfor the Unorganized Towns &Gores of Vermont by Richa rd Heaps, October 14, 2005. Prepared for the UTG.

669 Cambridge Road Westford, Vermon t 05494 (802) 879 - 7774Page 4


36/37

NORTHERN ECONOMIC CONSULTING, INC. ResumeAn Ana lysis ofRetail Trade in the St. Johnsbury, Vermont Area by Richard Heaps andArthur Woolf, August 11, 2005. Prepared for the St. Johnsbury Office of Economic andCommunity Development.Review and Evaluation of the Economic and Fiscal Impact Analysis of the Proposed WalMan in the Town ofSt. Alban s by Richa rd Heaps and Arthur Woolf, May 2, 2005.Prepared for pres entation to the St. Albans Developmen t Review Board.Economic Impact of the Vermont and New York Slate Industry by Rich ard Heaps, March24, 2005. Prepa red for the Slate Discovery Center, Poul tney, Ve rmont.The Economic Impact of Vermont Railroad industry on the Vermont Economy by Richa rdHeaps and Arthur Woolf, March 4,2005. Prepared for the Rai l Assoc iatio n of Ve rmont.The Verm on t Alpine Ski Industrys Impact on the Vermont Economy 2003/04 by Ri cha rdHeaps, January 29, 2005. Preparedfor the Vermont Ski Areas Associa tion .Economic and Fiscal Impact of the Proposed Expansion and Renova tion of the GreenMountain Dharma Center by Richard Heaps, October 20, 2004. Prepare d forpresentation to the District Env ironmental Commission.Fiscal impact to the Town ofKilling ton ofJoining the State ofNew Hampshire byRichard Heaps and Arth ur Woolf, Februa ry 27, 2004. Prepared for the Town ofKillington.impact ofGrow th and Economic Review of the ProposedMcLean EnterprisesCorporation Cavendish Stone Quarry by Richard W. Heaps, Septem ber 12,2003.Prepared for prese ntat ion to the State of Vermont En vironmen tal Board.A Co st/Benef it Ana lysis ofSegm ents A & B of the Ch itten den County CircumferentialHighway by Richard W. Heaps and Arth ur Cl. Woolf, September 11, 2003. Prepa red forpresentation to the Sta te ofVermont Water Resources Board.Economic and Fiscal Impact of the Proposed Shaw s Supermarketfor Waterbu ry,Ve rmont by Richard W. Heaps, April 17, 2003. Prepared for presen tation to the Di strictEnvironmental Commissio n.Fiscal impact ofMiddlebury College on the Municipal Property Taxes ofMiddleb ury,Vermon t Residents by Richard W. Heaps and Arthur G. Woolf , March 27, 2 003.

669 Cambridge Road Weseford, Vermont 05494 (802) 879 - 7774Page 5


37/37

NORTHERN ECONOMIC CONSULTING, INC. ResumeThe Economic Impact ofMidd lebury Co llege on the Econom ies ofMiddlebury Town andAddis on County by Rich ard W. Heaps and Arthur 0. Woolf, March 27, 2003 .The Economic Impact ofPike Industries Operations in the State of Vermont andWashington County by Richard W. Heaps, February 27, 2003.Economic and Fiscal Impact of the Proposed Lodge at Lincoln Peak ofSugarbush Resortby Richard W. Heaps , Feb ruary 27, 2003. Prepared for presentation to the DistrictEnvironmental Commission.Economic and Fiscal Impact of the Proposed Pike Indust ries, Inc. Quarry andAggregateProcessing Facility in Wil liamstown, Vermont by Rich ard W. Heaps, January 14, 2003 .Prepared for presentation to the District En vironmen tal Commission .

669 Cambridge Road Westford, Vermont 05494 (802) 879 - 7774Page 6

beaver wood pownal 248 filing: no. 8c - pre-filed testimony of richard heaps sd

Documents