STATE OF VERMONT PUBLIC SERVICE BOARD PREFILED TESTIMONY AND EXHIBITS OF IAN A. JEWKES

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1 STATE OF VERMONT PUBLIC SERVICE BOARD Docket No. Petition of Dairy Air Wind, LLC for a certificate of public good, pursuant to 0 V.S.A., for the installation of a single turbine,. MW wind-powered electric generation facility located on the Dairy Air Farm in Holland, Vermont ) ) ) ) ) PREFILED TESTIMONY AND EXHIBITS OF IAN A. JEWKES Mr. Jewkes describes the civil engineering site design for the Dairy Air Wind Project, and addresses certain Section (b)() criteria applicable to it. Specifically, Mr. Jewkes addresses Section (b)() with respect to water pollution and water purity, floodways, soil erosion, primary agricultural soils, and waste disposal. Exhibits: Exhibit DAW-IAJ- Exhibit DAW-IAJ- Exhibit DAW-IAJ- Resume of Ian Jewkes Site Plan and Elevation Drawings (including USGS Map, Orthophoto, EPSC Plan, typical Secondary Transformer Oil Containment Details) VTANR Natural Resource Atlas Flood Hazard Area Layer for Project Location

2 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of 0 0 Q. Please state your name, occupation and business address. A. My name is Ian A. Jewkes. I am the President of Krebs and Lansing Consulting Engineers, Inc. ( K&L ), State of Vermont Professional Engineer #00 and State of Vermont Licensed Land Surveyor #. My business address is Main Street, Suite 0, Colchester, VT. Q. Please describe your educational background and professional experience. A. After receiving my BS in Civil Engineering from the University of Vermont in, I joined Krebs and Lansing Consulting Engineers, Inc. where I have worked as an engineer and surveyor. In 00, I became an owner of the firm. In my present position, I continue to perform extensive work in civil engineering design, permitting and construction services for commercial, industrial, institutional and residential construction projects. I have performed civil site design and related work for utility wind projects and photovoltaic electric generation systems located in Vermont. This includes the MW, wind turbine, Kingdom Community Wind project in Lowell Vermont (Docket No. ). A more detailed description of my experience is provided with my testimony as Exhibit DAW-IAJ-. Q. What is the purpose of your testimony? A. The purpose of my testimony is to introduce the site plan and elevation drawings offered as Exhibit DAW-IAJ-, and to describe the civil engineering site design for the Dairy Air Wind Project. I also address certain of the criteria applicable to the Project under 0 V.S.A. (b)(), including primary agricultural soils, floodways, soil erosion, waste disposal (secondary containment), and water pollution and water purity.

3 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of 0 0 Q. Please describe the Project and Project components. A. The Project is a single turbine wind energy generation project located in Holland, Vermont. The wind turbine will have an associated electric generator. In my testimony, I use the term Wind Turbine Generator to refer to the wind turbine assembly (including but not limited to the tower, nacelle, and electrical generator). The Project will be accessed from School Road in Holland, Vermont. The proposed access spur is 0 feet wide and approximately, feet long (0. miles) off School Road. At the end of the access spur there will be an irregularly shaped turbine pad. See Exhibit DAW-IAJ- Site Plan. The main portion of the turbine pad, containing the turbine foundation, crane pad and laydown area, measures approximately 0 feet by 0 feet. The northern portion of the turbine pad measures approximately 0 feet by feet and provides area for an assist crane and equipment storage during construction. The main (southern) portion of the turbine pad will be used for wind turbine component storage and staging prior to assembly of the Wind Turbine Generator. The turbine pad area will be constructed of " to " pervious stone. The turbine pad grade will be shallow, with a % slope or less. Within the turbine pad area there will be an approximately -foot by 00-foot crane pad. For safety reasons, the crane pad needs to provide firm support for the crane while the Wind Turbine Generator is being assembled. The crane pad will be flat and constructed of compacted impervious road gravel. In general, the electrical infrastructure necessary to serve the Project consists of a three-phase overhead electric line from the interconnection point on Valley Road up to the access spur, where the electric line will be underground to the wind turbine. The

4 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of Project electrical interconnection point is at an existing -phase pole near the intersection of School Road and Valley Road, approximately 0 feet north of Valley Road. The upgraded overhead electric lines for the Project will proceed approximately,0 feet along the west side of School Road, feet across School Road, and another feet underground to the transformer located at the Wind Turbine Generator site. 0 0 Q. Please describe the wind turbine layout plans as provided in Exhibit DAW-IAJ-. A. The Wind Turbine Generator site is easily accessible from School Road. Delivery of Wind Turbine Generator components will be from the south. The intersection of the Project access road with School Road was designed at an acute angle to facilitate delivery of large Wind Turbine Generator components, thereby limiting the need for large roadway turning areas near School Road. The 0-foot width of the access road will allow for tractor trailer deliveries and for the specialized Wind Turbine Generator component delivery. The main assembly crane will be delivered to and assembled on the turbine pad/crane path area. A long flat area of approximately 00 to assemble the main crane for the Project is provided along the crane path and through the east side of the turbine pad. The remainder of the turbine pad was sized to allow for material and component storage during construction. The access road, crane path and crane pad will be constructed from compacted road gravel, an impermeable material. To treat and manage stormwater runoff from these new impervious surfaces, a new stormwater treatment was designed. The new impervious surface area (0. acres) is below the acre threshold that would trigger the need for a State of Vermont Discharge Permit. Nevertheless, the new stormwater treatment system will be constructed in compliance with the requirements of

5 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of 0 0 the State of Vermont Discharge Permit. There are Class II wetlands located south of the project site. Other than two utility poles that may be located in a wetland buffer along School Road, the project improvements have been design to keep clear of the wetland and the associated 0-foot-wide buffer areas. Q. Please describe the construction process. A. The general construction process will be as follows: Confirm that all permits have been obtained and proper notification, meetings, and consultations with all regulatory authorities have been completed. Complete any pre-construction surveys necessary for blasting work that may be needed on the wind turbine generator foundation and/or the new underground electric line from School Road. Flag, fence and stabilize staging areas with road fabric and gravel. Mark limits of clearing. Install temporary erosion and sediment control practices in accordance with Construction General Permit for Runoff from Construction Sites. Install upstream stormwater diversion ditches and culverts to keep stormwater from hillside out of work area on access road. Construct the access spur and turbine pad, stormwater treatment practices (STPs) and underground electric line as work progresses, along with connection to the new overhead electric line on School Road. Re-vegetate all areas designated on the plans. Maintain erosion prevention and sediment control measures until Project is

6 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of commissioned and all Project components are fully stabilized in accordance with the Construction General Permit for Runoff from Construction Sites. Remove remaining staging areas and stabilize their footprints. Ms. Staskus addresses the plans for blasting if the Balance of Plant ( BOP ) contractor determines that blasting will be necessary to install the wind turbine. Primary Agricultural Soils Q. What type of soils are present at the Project site? A. The soils on the site are "Prime" (primary) agricultural soils. 0 Q. How will the Project handle the Prime agricultural soils that will be disturbed by construction? A. The disturbed Prime agricultural soils will be preserved for use during decommissioning of the Project. The topsoil storage area is designed for stockpiling the soil stripped during the construction of the access road, crane path, turbine, and turbine pad. This soil will be conveniently located for future decommissioning work. 0 Q. Will the Project have an undue adverse impact on primary agricultural soils? A. No, it will not. The plan to stockpile the disturbed soils onsite for future decommissioning of the Project will ensure that the disturbed soils will be returned for future agricultural use. Floodways Q0. Is the Project located in a flood zone or floodway? A0. No, it is not. According to the Federal Emergency Management Administration (FEMA)

7 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of 0 0 website, a study has not been completed to determine flood hazard for the town of Holland. Additionally, Special Flood Hazard Area data for the town of Holland is not available from the VANR Natural Resources Atlas. However, Exhibit-DAW-IAJ- map, generated from the Atlas, illustrates the 00+/- foot Project base elevation and the nearest surface water body, an unnamed tributary of Stearns Brook, which is 0 feet elevation as it crosses School Road 00+/- feet away from the Project area. This information, along with other topographic landscape features indicate that it is unlikely the Project area is in a flood zone or floodway. Therefore, there will be no construction in a floodway or floodway fringe and no undue adverse impact on floodways. Soil Erosion Q. Will the Project cause undue soil erosion? A. No. The total disturbance footprint of this Project is. acres, which is comprised of 0. acres of new impervious surface area (new access and connection to crane pad, turbine foundation and crane pad) and.0 acres of pervious areas (soil stockpile, stormwater treatment). Please see Exhibit DAW-IAJ-, Sheet C-00. As noted below, the implementation of erosion prevention and sediment control measures during construction consistent with the EPSC Plan and the State of Vermont General Permit for Stormwater Runoff from Construction Sites will ensure that all sediment is contained on the site during construction. A suite of erosion prevention and sediment control measures and strategies have been proposed to control erosion and prevent sediment from leaving the site during construction. All measures have been designed in accordance with the Vermont Standards & Specifications for Erosion Prevention & Sediment Control (00).

8 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of 0 0 These include: Clearly demarcating the limits of construction prior to any ground disturbance. Demarcation limits the area of disturbed soils by confining earth disturbing activities to the appropriate areas. Installation of a stabilized construction entrance at the project entrance. The stabilized construction entrance will be maintained throughout construction. The stabilized construction entrance will reduce or eliminate the tracking of sediment onto adjacent roads. Installing perimeter erosion and sediment controls such as silt fence, reinforced silt fence, diversion berms, and diversion swales prior to construction of project components. Perimeter erosion and sediment controls will be maintained throughout construction. Silt fence will reduce runoff velocity and promote deposition of transported sediment load. Perimeter berms and swales will direct off-site drainage around the construction site, preventing any contamination from occurring. Limiting cuts and fills on the site. The project access road and crane path have been designed to maintain existing grades as much as possible. Limiting concurrent earth disturbance. Disturbed areas will be either temporarily or permanently stabilized within days of initial disturbance. Stabilization methods include mulching, rolled erosion control products (matting), stone, and gravel. Stabilizing soil stockpiles. Temporary soil stockpiles will be surrounded in silt fence and stabilized with seed and mulch or erosion control matting. Please see Exhibit DAW-IAJ-, Sheets C-0-C-0 for further detail.

9 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of 0 0 Q. Will the Project reduce the capacity of the land to hold water so that a dangerous and unhealthy condition results? A. No. The stormwater flows that are concentrated on the new improvements will be treated in a new grassed channel and a wet pond. These stormwater treatment practices, in accordance with the Vermont Stormwater Management Manual (VSWMM, 00) will treat and detain stormwater runoff generated on the site. Post development peak flows will be reduced to pre-development levels. Runoff from off-site areas will be diverted and treated via the implementation of erosion prevention and sediment control measures during construction consistent with the erosion prevention and sediment control (EPSC) Plans (see Exhibit DAW-IAJ-, for further detail) and the State of Vermont General Permit for Stormwater Runoff from Construction Sites. Waste Disposal: Secondary Containment Q. Do the Project plans include any secondary containment for oil-containing equipment used on the Project (e.g., the transformer)? A. Yes, the Project transformer will be oil-filled and located at the base of the Wind Turbine Generator. A typical secondary transformer oil containment design is included on the civil plans. See Exhibit DAW- IAJ-, Sheet C-0 for more detail. This design will provide secondary transformer oil containment for the transformer oils. The design accommodates an oil volume capacity of at least 0% of the transformer oil volume plus inches of freeboard in the containment sump. Water Pollution and Water Purity Q. Will the Project cause undue water pollution or have an undue adverse impact on water

10 Petition of Dairy Air Wind, LLC for a CPG December 0, 0 Page of purity? A. No, it will not. The Project plans include appropriate avoidance strategies and construction techniques to ensure that no undue adverse impact to water quality results. As my previous testimony explains, the construction plans include plans for stormwater treatment, erosion and sediment control, and secondary oil containment. 0 Q. Will the Project involve the injection of waste materials or harmful or toxic substances into ground water or wells? A. No. The Project will not use water or produce any wastewater or otherwise involve the injection of waste or harmful or toxic substances into ground water or wells. Therefore, the Project will not result in any undue adverse impact on water supplies. Q. Does this conclude your testimony? A. Yes.

NEW CASTLE CONSERVATION DISTRICT. through. (Name of Municipality) PLAN REVIEW APPLICATION DRAINAGE, STORMWATER MANAGEMENT, EROSION & SEDIMENT CONTROL

NEW CASTLE CONSERVATION DISTRICT through (Name of Municipality) PLAN REVIEW APPLICATION DRAINAGE, STORMWATER MANAGEMENT, EROSION & SEDIMENT CONTROL Office use only: Received by Municipality: Received by