Letter

State of Vermont
ANR, DEC
APCD

April 27, 1999

Robert Votaw
Vermont Energy Park Holdings
C/o Farmington Power
390 Middle Road
Farmington, CT 06032

RE: Proposed Vermont Gas-Fired Merchant Plants

Dear Mr. Votaw:

The Vermont Air Pollution Control Division has received two separate inquires from Foster Wheeler Environmental concerning the two gas-fired utilities being considered for Vermont. The nature of the inquiries concerned the general application review process, Vermont requirements associated with major air pollution sources, and Vermont requirements for pre-construction monitoring. The latest call that we received from Foster Wheeler requested a meeting here in Waterbury, Vermont to discuss the above subjects, and in particular the need for pre-construction meteorological monitoring. Earlier discussions between the staff and the consultant have suggested that pre-construction meteorological monitoring is likely to be required. Apparently, Foster Wheeler wants to provide us with some data to demonstrate that pre-construction monitoring should not be required.

The APCD is willing to provide consultants with the information needs to support a permit application. However, without any details on these proposed plants, we cannot provide definitive answers. It is imperative that Vermont Energy Park Holdings begin documenting their plans and prepare a pre-application package containing some details about the project such as location, general design of the plant, type of electric generating units, emission potential, etc. As you know, Vermont is mandated to provide the opportunity for various state and federal entities, as well as the general public, to review and comment on the application. The earlier we can get written documentation containing some design specifications on this project, the better able we will be to provide you meaningful feedback.

Without a written proposal from Vermont Energy Park Holdings, any feedback or answer we provide to your consultants are purely speculative and could very well change in the future as more details about the project emerge. The Agency, as well as the Air Division, wants to identify and raise issues as early on in the process as possible. However, it does not serve either of us well to speculate on what may or may not be required prior to having a written proposal.

Please feel free to call me at anytime to discuss this matter. I am confident you will be satisfied with the response of the APCD once we have more information on the project. In the mean time, we will continue to provide as much general guidance to your consultants as available details allow.

Sincerely,

Brian J. Fitzgerald
Engineering Services Supervisor
Air Pollution Control Division

Cld

Cc: John Kassel, Secretary, ANG
Canute Dalmasse, Commissioner, DEC
Richard A. Valentinetti, APCD