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HomeMy WebLinkAbout01-21 Impact Analysis Statement rev 020921 1 Conditional Use Permit Impact Analysis Statement Hollow Road Solar A. Suitability of the Site 1. General Overview Hollow Road Solar, LLC (“Hollow Road Solar”) is a wholly owned, indirect subsidiary of Blue Ridge Energy Holdings LLC. Hollow Road Solar has the right to acquire approximately 236 acres (parcels 27-A-11 and 27-A-12) located at 806 Hollow Road in Gore (“ Project Site”). The Project Site is just slightly over 1,000 feet from Shenandoah Valley Electric Cooperative’s (“SVEC”) Gore substation. The Project Site was previously operated as an apple orchard by National Fruit Orchards Inc. (“National Fruit”). National Fruit decided to discontinue operations at the Project Site and put the property up for sale. Recognizing the advantages of the proximity of the Project Site to the Gore substation and the benefits to the local community of being able to repurpose the land in a productive manner that preserves the rural nature of this area of Frederick County without corresponding strains on local infrastructure and resources, Hollow Road Solar decided to pursue the development of an approximately 20 megawatt (“MW”) photovoltaic solar generation facility at the Project Site (“Project”). The Project Site currently is zoned RA. Section 165-401 of the Frederick County Zoning Ordinance (“FCZO”) permits a multitude of uses for land zoned RA, including single-family homes (one per every five acres); group homes; radio and television towers; oil and gas exploration; and public utilities, such as coal- or gas- fired generation facilities. However, pursuant to an amendment to § 165-401.02Q of the FCZO in January of 2020, utility-scale solar facilities were specifically excluded from the public utilities permitted use and, as such, a conditional use permit is required. Hollow Road Solar is submitting this Impact Analysis Statement in support of its application for a conditional use permit for the Project, as now required by § 165-401.03CC of the FCZO. 2. Site Composition and Project Layout The Project is graphically depicted on the Preliminary Site Plan prepared by The Timmons Group and attached hereto as Exhibit A. The solar panels will be on ground-mounted trackers that will be attached to metal racking, which, in turn, is attached to metal posts driven approximately six feet into the ground. The solar panels will stand approximately 7 feet above ground level when flat and up to a maximum of approximately 13 feet when tracking. After accounting for various characteristics inherent in photovoltaic solar generating facilities, the Project is expected to deliver approximately 18 MW of electric energy to the Gore substation via a tie line running approximately 1,000 feet from the Project Site to the Gore substation through a subsurface easement on parcel 27-A-8. The Project Site has two access points. The first is via a right-of-way over parcel 27-A-8 from Parishville Road to the Project Site. A right-of-way over this parcel was National Fruit’s primary method of accessing the Project Site and will also be Hollow Road Solar’s primary method of access. The second access point is over Anchorage Lane and then over a right-of-way extending from the end of Anchorage Lane to the Project Site. The rights-of-way for access and the easement to connect to SVEC’s Gore substation are discussed in further detail below in Section D. 2 Currently, it is not expected that the Project will incorporate mass storage batteries, but Hollow Road Solar remains open to discussion about incorporating storage should potential offtakers demonstrate a need for storage. In the event an offtaker requests the incorporation of storage, Hollow Road Solar would submit an amended conditional use permit application incorporating such storage into the design of the Project. As can be seen in the Preliminary Site Plan, much of the border of the Project Site to the east, south and west contains woodlands, which provide a natural setback and buffer between the Project Site and the contiguous parcels. The proposed layout will leave much of those woodlands intact. Hollow Road Solar will retain existing apple trees to the north and northwest and/or place such other landscaping screens in such areas as is usual and customary for such projects. There is no 100-year floodplain located within the Project Site. No known subsoil conditions have been identified that would make the installation of solar panels problematic. A full geotechnical study will be conducted prior to construction to identify any adverse subsurface conditions. The Project lies at approximately 1,164 feet above mean sea level (amsl) and the topography of the area of the property is hilly. Areas of high slope (>15%) which are not practical to grade for tracker installation will be avoided. The surface elevation varies from 903 to 1,170 feet amsl. Natural surface water drainage for the Project Site is generally south southeast. The Applicant conducted an archival database review and found no jurisdictional wetlands present on the property. The Applicant will conduct a wetland delineation study and obtain approval from the Army Corps of Engineers. This approval is required to obtain authorization for the project under the Virginia Department of Environmental Quality’s Permit-by-Rule (“PBR”) process. Also, as part of the PBR process a Threatened and Endangered Species evaluation will be conducted. Coordination with the Virginia Department of Wildlife Resources and Department of Conservation and Recreation will proceed to assess for the presence of threatened and endangered species on the project area and to determine appropriate mitigation, if required. Assuming timely completion of the interconnection process with PJM Interconnection, LLC (“PJM”), Hollow Road Solar expects to commence construction around December of 2021 and reach commercial operations by May of 2022. During the approximately four-month construction period, construction crews will be present and will be accessing the Project Site. Once completed, the Project will be monitored remotely, with a limited number of personnel accessing the Project Site while in operation to inspect, maintain and repair the site and Project equipment, as necessary. 3. Decommissioning As required by law, Hollow Road Solar will commit to a decommissioning plan for removal of the equipment both above and below ground and return of the land to substantially its original condition upon retirement of the Project. The decommissioning plan will provide for security that runs to the benefit of the County as required by state statute. B. Comprehensive Plan Conformity As set forth in the 2035 Comprehensive Plan, Frederick County, Virginia, adopted January 25, 2017 (“Comprehensive Plan”), the County is striving to maintain a balance between rural and urban areas. 3 “Preserving and protecting rural areas of Frederick County is important not only to ensure the economic viability of agricultural and forestall operations but to also guarantee that those lands are present for the use and enjoyment of future generations.” As noted above, the Project Site is zoned RA. Utilizing the Project Site for solar generation is one of the lowest impact uses permitted under the FCZO. Compared to other potential uses, the Project will not include high-rise structures, such as radio or television towers or a gas-fired power plant; increased housing density, which would produce higher traffic volumes on Parishville Road and surrounding areas; the drilling of exploration wells that would be occur with natural gas development; or many of the other adverse impacts that come with utilization of the property for other permitted RA uses. Once constructed, the Project will be quiet, have a low visual impact compared to many other RA uses and will not produce a strain on local resources. Furthermore, the County and its residents will know that the land will not be placed in any such use for several decades. At the end of the Project’s life, the plant and equipment can easily be removed with little impact on the land and return the land essentially to the condition it is in today. C.Agricultural and Forestal Considerations The site contains forested areas. However, no area is in a zoned forestal district. The Project is planned to be constructed on the land previously utilized as an orchard and any forested tree clearing will be minimized. D.Surrounding Properties As set forth in Sections 7 and 10 of the Application, the Project Site is bordered by eight properties. Of those eight properties, three will be directly impacted during the construction of the facility. The Project Site is benefitted by an existing right-of-way that extends from the end of Anchorage Lane along the borders of parcels 26-7-3-20 and 26-7-3-21 to parcel 27-A-11. The landowners of parcels 26-7-3-20 and 26- 7-3-21 have been made aware of, and not objected to, the use of the existing right-of-way for access to the Project Site for construction of the Project. Hollow Road Solar also has reached out to the remaining four landowners on Anchorage Lane, two who have responded and stated they have no objection to Anchorage Lane being used to access the Project Site during construction. We continue to follow up with the remaining two Anchorage Lane landowners. The other property that will be directly impacted during construction is parcel 27-A-8, which is referred to in various Project Documentation as the “Anderson Parcel”. Historically, National Fruit Orchards Inc. accessed parcel 27-A-8 via a right-of-way extending from Parishville Road over the Anderson Parcel to the northern edge of parcel 27-A-8. Hollow Road Solar has secured rights-of-way and easements over the Anderson Parcel to provide for access to the Project Site during construction and operation, as well as interconnection access from parcel 27-A-8 under the Anderson Parcel to parcel 27-A-8A, which is the Shenandoah Valley Electric Cooperative’s Gore substation. The property identified with PIN 27-A-8 will only be used for interconnection with the substation and easement and ingress/egress to the project. We have reached out to all of the remaining landowners identified in Section 10 of the Application. We have received favorable responses from the owners of parcels 27-A-50 and 27-A-53C and 27-A-10. We have not heard back from the owner of parcel 27-A-14 and will continue to follow up with them. 4 E. Traffic Hollow Road Solar expects construction to be completed within four months. Once construction of the Project is completed, the impact of the Project on traffic essentially will be unnoticeable other than for limited periods of maintenance. Traffic management during construction will be addressed by the Project’s construction plan, which will be developed in close coordination with the County. F. Sewage and Conveyance Treatment The Project will not produce any sewage. G. Water Supply The Project will not use water. H. Drainage An exhibit depicting the drainage flows is included with the Preliminary Site Plan. As part of the formal site plan review process, detailed preliminary erosion and sediment control and stormwater management plans will be prepared that identify best management practices required to minimize the discharge of sediment into surface water bodies and sensitive areas of the Project Site, meeting all required rules and regulations set forth by the Virginia Department of Environmental Quality. I. Solid Waste Disposal Facilities There is virtually no solid waste produced from operation of a solar facility. Any waste generated during construction or decommissioning will be disposed of in accordance with federal and state law and Frederick County ordinances. During decommissioning (or arising from maintenance or replacement during the operational life of the Project), any materials that can be recycled in a commercially reasonable manner will be recycled rather than disposed of as solid waste. J. Historic Sites and Structures Hollow Road Solar commissioned a desktop review of the Department of Historic Resource’s Virginia Cultural Resources Information System to identify any previously recorded historic and cultural resources. No known cultural resources exist within the Project Site. Hollow Road Solar will pursue authorization for the project under the Department of Environmental Quality’s PBR process. As required, an archaeological and architectural investigation will be conducted by a qualified historian, resulting in a Phase I Cultural Resources survey which will be submitted to the Department of Historic Resources for review. K. Impact on Community Facilities Education The Project will have no adverse impact on education. Police Protection This is typically required, if at all, during the construction phase. Fire and Rescue Protection 5 Any impact on fire and rescue protection should be minimal and predominantly during the construction phase, as with any other construction project. Solar facilities do not present an inherent risk of fire. Parks and Recreation The Project will have no impact on the County’s park and recreational resources. Solid Waste Disposal See above. Other Government Activities The Project will not adversely impact any other government activities. I. Other Impacts Hollow Road Solar believes that repurposing the Project Site for solar generation has substantial long- term benefits for the County and its residents. As noted above, utilizing the Project Site for solar precludes the site from being developed in a manner that while consistent with the FCZO, may present some tension with the objective of preserving the rural nature of this part of Frederick County. Additionally, as older power plants serving the region are retired, replacing that electric generating capacity with clean energy sources, such as solar, will contribute to cleaner air, soil and water for residents of Frederick County, thus furthering the County’s objective of protecting the rural and agricultural nature of western Frederick County.