December 19, Dear Elizabeth:

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Diana Bradley
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1 December 19, 2 Ms. Elizabeth Lord, Land Use Attorney Agency of Natural Resources ANR Legal Division One National Life Drive, Davis Building Montpelier, VT RE: South Face Village at Okemo Development Company, LLC Ludlow, Vermont Non-Native and Invasive Plant Species 2 Monitoring-Year 1 (Baseline) State of Vermont Land Use Permit #2S119-5 US Army Corps of Engineers Permit (#NAE ) Dear Elizabeth: This letter is to inform you that VHB performed the first annual survey for invasive plant species, as required by Condition #33 of the State of Vermont Land Use Permit ( LUP ) #2S119-5, and by Special Conditions # and #1 of the United States Army Corps of Engineers ( USACE ) Permit (#NAE ), on August 1, 2. The invasive species monitoring for 2 represents the baseline survey for this project. On behalf of South Face Village at Okemo Development Company, environmental scientists from VHB conducted the invasive species survey within the permitted forest management Cut areas. VHB monitored for the target invasive species that are specified in the USACE Permit and the LUP. No occurrences of non-native or invasive species were found within or adjacent to the study area. A summary memorandum, which includes a Non-Native and Invasive Plant Species Monitoring Map and representative photographs, is enclosed to provide documentation of the monitoring. Follow-up monitoring should occur in approximately ten years, at the time of the next patch cutting maintenance cycle, as specified by the permits, and the results of the future monitoring would be reported to your office and the Army Corps of Engineers approximately ten years from now. Additionally, the USACE Permit requires annual monitoring for five years once Project construction is completed (construction completion is expected in approximately ten years). Please feel free to call if you have any comments or questions. Sincerely, Owen McEnroe Environmental Scientist cc Andy Becker, South Face Village at Okemo Michael Adams, US Army Corps of Engineers OWM/jkw Enclosure \\VTSBDATA\projects\ South Face EV Comp 2\docs\memos\NNIS_2\South_Face_NNIS Mon_Cover Letter_2.doc

To: South Face Village at Okemo Project File From: Owen McEnroe, Environmental Scientist Date: December 19, 2 Project #: 5717.

2 To: South Face Village at Okemo Project File From: Owen McEnroe, Environmental Scientist Date: December 19, 2 Project #: Re: South Face Village at Okemo 2 Non-Native and Invasive Species Survey (Baseline Year Monitoring) INTRODUCTION On behalf of South Face Village at Okemo Development Company, LLC ( Client ), and in support of the South Face Village at Okemo project located in Ludlow, Vermont ( Project ), VHB has prepared this memorandum to summarize the results of the non-native and invasive plant species ( NNIS ) identification survey conducted by VHB on August 1, 2. Specifically, this memorandum presents baseline NNIS data collected by VHB as required by Condition #33 of the State of Vermont Land Use Permit ( LUP ) #2S , by Special Conditions # and #1 of the United States Army Corps of Engineers ( USACE ) Permit (#NAE ) 2, and as outlined in the Timber Creek at Okemo Number II Forest and Wildlife Habitat Management Plan Narrative ( Plan ) 3. The following sections describe the NNIS investigation methods and present the NNIS investigation results. METHODS Qualified VHB environmental scientists conducted the baseline NNIS monitoring in accordance with the methods described in the Plan, within and immediately adjacent to four Wildlife Enhancement Cut areas ( Study Area ) to be disturbed during the Project s required forest management activities. Management cutting in the four Cut areas is planned to occur during the winter, in accordance with the Plan and the Permits. The Study Areas and the overall Project Area are shown on the NNIS Monitoring Map in Attachment 1. The four Study Areas total approximately.1 acres and include mainly forested lands, with smaller portions of revegetating former logging/access roads. Representative photographic documentation of the NNIS survey is located in Attachment 2. As specified in the Plan, the target NNIS plant species are those listed in the Vermont Agency of Agriculture, Food & Markets ( AAFM ) Quarantine #3, which include Class A or B noxious weeds in Vermont, species listed on the Invasive Species Watch List for Vermont ( WL ) 5, species listed in Appendix D of the USACE New England District Compensatory Mitigation Guidance, and species required by Special Condition #1 of the USACE Permit, which include Common reed (Phragmites australis), Purple loosestrife (Lythrum salicaria), Glossy Buckthorn (Frangula alnus), Common buckthorn (Rhamnus cathartica), Russian olive (Eiaeagnus angustifolia), Autumn olive (Eiaeagnus umbellata), and Multiflora rose (Rosa multiflora). 1 State of Vermont Land Use Permit #2S Signed date: September 13, United States Army Corps of Engineers Permit #NAE Signed date: December 13, Holleran, Robbo, Forester. Revised May 21, 213. Timber Creek at Okemo Number II Forest and Wildlife Habitat Management Plan Narrative. Vermont Agency of Agriculture. Quarantine #3 Noxious Weeds Available online at: weeds/documents/noxiousweedsquarantine.pdf 5 Invasive Species Watch List for Vermont. 25. Available online at: IDX Drive, Building 1 Suite 2 South Burlington, Vermont 53

3 South Face Village at Okemo 2 Non-Native and Invasive Species Survey Ref: December 19, 2 Page 2 of 2 RESULTS Based on the baseline assessment, there are no occurrences of any of the aforementioned NNIS identified within the Study Areas. Additionally, VHB identified no NNIS occurrences adjacent to the Study Areas. SUMMARY AND RECOMMENDATIONS On behalf of the Client, VHB conducted the NNIS baseline survey as required by the permits on August 1, 2, prior to the initial cutting of the four required wildlife Cut Areas. No occurrences of NNIS were found within or adjacent to any portion of the Study Areas. 2 represents the baseline monitoring year. The first round of follow-up monitoring is scheduled to occur in approximately ten years, when the next maintenance patch cutting is performed as specified in the Plan. Additionally, Special Condition #1 of the USACE Permit requires annual monitoring for five years once Project construction is completed (construction completion is expected in approximately ten years). In the forthcoming years of NNIS monitoring, VHB recommends carefully assessing the Study Areas to determine the presence or absence of target NNIS, and to remove each occurrence, if any are found, as described in Special Condition #1 of the USACE Permit. As described in Special Condition #1, hand pulling is preferred, however, in the event that hand-pulling is not effective, alternate methods (i.e., herbicide) will need to be coordinated with both the Vermont Agency of Natural Resources ( ANR ) and the USACE. ATTACHMENTS 1. Non-Native Invasive Species Monitoring Map 2. Representative NNIS Baseline Assessment Photographs \\VTSBDATA\projects\ South Face EV Comp 2\docs\memos\NNIS_2\South Face NNIS Memo_Final.docx

4 ATTACHMENT 1

$222 21 226 22 23 232 23 236 \\vtsbdata\projects\5717.1\gis\project\nnis\nnis_monitoring_map_2.$ mxd 2 C-5 2-2 15 17 2-3 3 C 1 2 21 C -2 17 2 1 -T BSB 17 12 19 2 C1-15 C /2 7 2 rs Brook nd e Rd 27-7 21-1 T O W N O F L U D L O W Dr 27-6 176 2 192 Cut 22 vi ew 2 7 /2 C -15 C12 19 19 27C -1 27 C-13

mxd 2 C-5 2-2 15 17 2-3 3 C 1 2 21 C -2 17 2 1 -T BSB 17 12 19 2 C1-15 C /2 7 2 rs Brook nd e Rd 27-7 21-1 T O W N O F L U D L O W Dr 27-6 176 2 192 Cut 22 vi ew 2 7 /2 C -15 C12 19 19 27C -1 27 C-13

Cut 3 21 211 -TB -C1 226 22 27-1 -22 C 7 2 e 9 C 7 2 Cut 1 id Trails 2 7-T B-2 5 27-TB-17 22 26 2 7 -T B2 23 27-22 27-1 17 27 C- 27-15 27-17 Ede lwei ss 23 27-2 i Copyright: 213 National Geographic

5 November 1, 2 logos A C C VHB NNIS Study Areas \\vtsbdata\projects\5717.1\gis\project\nnis\nnis_monitoring_map_2.mxd 2 C C C T BSB C1-15 C /2 7 2 rs Brook nd e Rd T O W N O F L U D L O W Dr Cut 22 vi ew 2 7 /2 C -15 C C C-13 27SC C27-T 1 B CC-1 6A A 12 C TB 27 6 C C 7 2 Sa ve r O T B SC- 3B C-1 C C-5 27 C- 17 Cut C-21 Cut TB -C C 7 2 e 9 C 7 2 Cut 1 id Trails 2 7-T B TB T B C Ede lwei ss i Copyright: 213 National Geographic Society, i-cubed Legend 2 Study Area (VHB) Project Area (VHB) Resort Road Feet Perennial Stream Waterbody (VHD) Class II Wetland Parcel Boundary V Recon Wetland VStream V (VHD) I I SW V V VSWI Wetland (VT ANR) SW VS W V I Ephemeral Recon Stream (VHB) Class III Wetland I SW Intermittent V South Face Village at Okemo Development Company, LLC Delineated Wetland (VHB) Delineated Stream (VHB) VCGI 2 ft. Contour (VCGI) County Boundary Town Boundary Roads (VCGI) Ludlow, VT Non-Native Invasive Species Monitoring Map Sources: VCGI (Vermont Center for Geographic Information - Various Dates) VHD (Vermont Hydrology Dataset maintained by VCGI - 215) VT ANR (Vermont Agency of Natural Resources - Various Dates) VTrans (Vermont Department of Transportation - 215) Study Areas, Project Area, and Resort Roads Digitized by VHB (2); Background Imagery by VCGI (2)

6 ATTACHMENT 2

South Face Village at Okemo Development Company, LLC

Representative Photographs Ludlow, Vermont Photograph 1.

Representative view of a former access road within Cut- 2

Representative view of a former access road and forested area

Representative view of a forested portion of Cut-3 Photograph

7 South Face Village at Okemo Development Company, LLC Non-Native and Invasive Species - Baseline Survey - Representative Photographs Ludlow, Vermont Photograph 1. Representative view of forested area within Cut-1 Photograph 2. Representative view of a former access road within Cut- 2 Photograph 3. Representative view of a former access road and forested area within Cut-2, Photograph. Representative view of a forested portion of Cut-3 Photograph 5. Representative view of a former access road within Cut-3 Photograph 6. Representative view of forested area within Cut- Photographs taken by VHB Environmental Scientist O. McEnroe on August 1, 2 Page 1 of 1 \\vtsbdata\projects\ south face ev comp 2\sitephotos\12\owm\nnis_southface_photodoc_2.docx

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