DRAFT Minutes June 19, 2024 Cherry Valley Joint Planning Board

 2024-06-19 DRAFT Minutes Cherry Valley Joint Planning Board

Draft

Cherry Valley Joint Planning Board Meeting Notes

June 19, 2024

7:00pm Community Room at the Old School

Meeting was called to order 07:00pm  By C. Utter

1. Roll Call: Cierra Utter, Ellen LaSalle, Lorraine Bosma, Frank McGrath,    D. Cornelia arrive 7:19 pm

Absent: William Compton, Dave Cornelia 

2.  Review of last month’s Planning Board Minutes:

Motion to accept amended minutes by L. Bosma,  2nd. by E. Lasalle 

Approved 4-0

3.  Communications:

- Grant and Lyons law firm now on retainer for legal review of Carson Power solar project.

- Letter to Carson Power regarding points needing to be clarified in East Springfield Solar project proposal.  **See below

- Review of March 2024 letter from Town Board to Carson power regarding clarification of parcel size and project acreage as stated in the local law.   ** See below

- Chairperson Utter had a conference call with Nan Stalzenberg and John Lyons regarding application dimensions clarification ad also that it was premature to deem application complete with these outstanding discrepancies.

- Jeff Stiles interested in Code Enforcement position if created

 

4.  New Business:

Steve Pasternak 433 Salt Springville Road subdivision:  Motion by L. Bosma to approve sketch plan as presented contingent upon legal advice regarding how to create an easement on adjoining properties to avoid presented property and any adjoining properties becoming “land locked.”

2nd by F. McGrath

Approved 4-0   D. Cornelia abstain

5.  Old Business:

- Engage Photo simulation expert when/if project discrepancies are resolved.  Simulations recommended to be from surrounding residences with owners permission to more accurately represent viewshed of the project.

6.  Privilege of the Floor: 

Keith Shue:  resident who commented on thoroughness of initial solar law but aware that it needs some updating.  Concerned about the prime soil and additional farmland disturbance and topsoil storage

7.  Activities to be accomplished before the next meeting 06/19/24

Motion to adjourn the meeting by E. LaSalle    2nd by  L. Bosma, Approved 5-0 

Meeting was adjourned at 7:52pm

Respectively submitted by Frank McGrath,  secretary 

Letter to Carson Power regarding issues in proposal.

Cherry Valley Joint Town/Village Planning Board

2 Genesee Street

P.O. Box 386

Cherry Valley, New York 13320

June 17, 2024

Owen Hooper

Director of Development Operations Carson Power LLC

110 William St. 24 Floor New York, NY 10038

Dear Mr. Hooper:

At the last meeting (May 15, 2024), the Cherry Valley Joint Planning Board (Planning Board) identified a variety of outstanding matters related to the East Springfield Solar Project application (the “Project”). These include matters and issues arising from comments received from the preliminary reviews conducted by our Board's consultants, Community Planning & Environmental Associates (CP&EA) and Lamont Engineers (Lamont). These memorandums have already been provided to you, however, for your convenience, copies of the comment memorandums from both CP&EA and Lamont are attached to this letter. Please be advised that you must address these outstanding matters before the Planning Board can consider the application to be complete for the purpose of formally commencing the review of your project.

The Board has reviewed this matter in preparation for its upcoming meeting scheduled for June 1 9, 2024. Please be advised of the following:

1. Subsequent to the May 15, 2024, Planning Board meeting, the Board engaged the firm of Grant & Lyons, LLP, as the Board's legal counsel. Grant & Lyons will be assisting the Board in connection with both its environmental review pursuant to the State Environmental Quality Review Act (SEQR), and also the reviews to Cherry Valley's applicable local laws as they pertain to solar energy systems, including the special permit and site plan review and approval process.

1. The Board has received proof that the SEQR Coordination Letters were sent to both involved and interested agencies. Thank you for assisting in accomplishing the first step to initiate the SEQR review process for this project.

1. The Board will be considering engaging George 11. Janes, AICP, of George NI. Janes & Associates, New York, NY to assist us in evaluating the May 12, 2024 photosimulations that you provided to us. We recognize that the Town of Cherry Valley Comprehensive Plan, Land Use Law, Site Plan Law and Solar Law are all grounded in the Town's desire to protect and preserve important environmental resources, and to retain and enhance Cherry Valley's “unique rural, historical, scenic and agricultural character.” ' Mr. Janes is an expert in visual

' From the Cherry Valley Land Use Law Article 1, Section 1.03.

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impact assessment and analysis and his input will help the Board ensure we have the best information available to fully understand the potential impacts that the East Springfield Solar proposal may have on our community.

4. The Board has also identified an issue concerning the size of the parcel of land upon which the project is proposed. It appears that the parcel of land upon which the Project is proposed exceeds the dimensional limit set forth in the Cherry Valley Solar Law.

The term “large-scale solar energy system” in the Solar Law is defined in Article II of the Solar Law. That definition states as follows:

An energy generation facility designed to convert solar energy to electricity, whether by photovoltaics, concentrating solar thermal devices or other solar technologies, designed, and intended to supply energy solely into a utility grid for sale to the general public and which generates more than 25 kW and less than 20 megawatts of electricity on a parcel of land no more than ten (10) acres in size (emphasis added).

Pursuant to this definition, a large-scale solar energy system must be on a parcel of land no more than ten (10) acres in size. The East Springfield Solar project is proposed to be located on a parcel that is 14.96 acres. This exceeds the dimensional requirements of a “large-scale solar energy system” as defined in the Solar Law.

1. Another dimensional issue has been identified. According to the Solar Law, no large-scale solar energy system, including any of its associated equipment, roads, and components shall be larger than ten (10) acres, regardless of the total parcel size.2 As proposed, the East Springfield Solar system exceeds this dimensional limitation. To comply with this limitation, the entire facility, including all of its components (e.g., perimeter fencing, access road, etc.), should be within a 10-acre footprint. That is not the case with the Project as presently proposed. The site plan should be revised to bring all components of the Project within a 10-acre envelope.

1. Yet another dimensional issue has also been identified. As was noted in the earlier CP&EA memorandum,3 Article V(3)(b)(3) of the Solar Law requires that that there shall be a minimum 100 foot buffer between any component of the large-scale solar energy system and any front, side, and rear parcel boundary line.4 As the Project is currently proposed, there are components and infrastructure elements that are located within this 100-foot buffer. The proposed site plan should be revised to comply with this requirement so that no component is within the 100-foot buffer.

The Board received Kayleigh Furth's email dated June 6, 2024, as well as your recent email dated June 12, 2024. These emails requested that this matter be placed on our agenda for our June 19, 2024, meeting and discussed your request to attend and appear at that meeting to “work through any open items.”The emails also noted your plan to provide updated submissions for our July 2024 meeting.

• From the Cherry Valley Solar Law Article V, Section 3(b)(2).

• CP&EA memo, dated May 14, 2024, Site Plan Comments #3.

° From the Cherry Valley Solar Law Article V, Section 3(b)(3)

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Given the significant issues regarding the consistency of the proposed Project site plan with the Town's Solar Law dimensional requirements, and the still-outstanding questions raised by our consultants, the Board has decided that your application will not be on the agenda for our June 19, 2024, meeting. Instead, using the feedback and guidance set forth in this letter, we direct you to address these outstanding questions and issues, and where necessary, amend the proposed site plan to comply with the applicable provisions of the Solar Law.

If you wish to be considered for placement on the agenda at the Board's July meeting, revised plans and any narratives addressing issues that have been raised should be submitted to the Board in writing and submitted no later than two (2) weeks before a posted meeting agenda to afford both the Board members and our consultants the time needed to properly review those documents. Your application will not be placed on the agenda for a Planning Board meeting until such time as the issues that have been raised have been properly addressed or resolved.

The Board acknowledges your request that a public hearing be scheduled, and the Board begin the process of completing the SEQR Full Environmental Assessment Form (FEAF) Part 2, at our July meeting. This request is premature. Until the matters described above have been properly addressed or resolved, the application is not sufficiently complete to begin a public hearing to receive public comment, and neither is the application sufficiently complete for the purposes of the Board's preparation of Part 2 of the FEAF.

Sincerely,

Cierra Utter, Chairperson

Cherry Valley Joint Planning Board

cc: Joint Planning Board Members

Community Planning & Environmental Associates Lamont Engineers

Grant & Lyons, LLP

To: Town of Cherry Valley Planning Board

From: Nan Stolzenburg FAICP CEP

Date: May 14, 2024

Re: Preliminary Review of East Springfield Solar Special Use and Site Plan Application

Community Planning & Environmental Associates has reviewed the various submissions provided by Carson Solar for the East Springfield Solar project on Route 54 in the Town of Cherry Valley. The review included all site plans and all documents included in the three submissions from April to

I day 2024. The comments provided below are organized by topic where appropriate, but not listed

in any kind of priority order.

I have included a variety of comments and questions derived from the map and narrative submissions as well as the site plan set. As detailed below, there are multiple places needing clarification and changes. I’ Cost important for the Planning Board discussion is to determine whether the size of the solar facility (including all components) exceeds the Solar Laws 10 acre maximum size, and whether the fencing, access road, and other components can be within the 100’ setback area.

Summary of Project's I'1ajor Components For Context

• 2.5 MW facility with 12’ high solar panels

• 14.96 acre parcel
• Requires a special use permit and site plan review

• Access from CR 54

• Includes 7 utility poles and a 20’ wide access road
• Includes 2 identified National Wetland Inventory (NWI) wetlands and includes a Flood Area

(Zone A)

• Parcel includes both prime soils and soils of statewide importance

• Narratives identify that the NYS Department of Agricultural and Markets guidance on solar development on farms will be utilized.

• Provided information indicating no rare, threatened or endangered species utilize the site.
• Indicates it is partly in the Route 20/166 Scenic Corridor viewshed (1.6 miles away).

• Adjacent to the Lindesay Patent Rural Historic District

• Adjacent to the Cherry Valley Creek (a Class C(t) stream)

• Parcel is in Otsego Ag District #1

FEAF Part I Comments (corresponds to question numbers on FEAF)

B. Change to Otsego County Highway Permit, not Town Highway Permit.

B. Add under“other agencies”that a floodplain permit is required from the Town's Floodplain administrator,

D1b. This acreage listed here appears inaccurate (a total of 9.2 acres disturbance). See other comments below about this. This should be reviewed.

D2bi. Indicates that the wetland impact is related to access road and swale, but (ii) says that the impact is for post driving. Clarify.

D2e. See Lamont Engineering comments.

D2j. No indication is given as to what construction traffic and noise will be as construction 7 days a week from 7 am to 5 pm is listed.)

D2m. This is related to the sound study provided — which did not evaluate any construction level noise. There may indeed be increases over ambient noise during construction. Further, the sound study did indicate that there will be 3-4 dBa increases above ambient noise, so this answer seems inaccurate.

D1a. Check rural-nonfarm uses, as I would not think that Cherry Valley considers itself suburban.

E1b. Indicates a -.21 acre change in land considered meadow/grassland cover type. How was this calculated when there is to be - 9 acres of solar panels? While there is grass growing underneath the panels, the Planning Board should discuss whether this is still considered meadow/grassland as a cover type.

E2b. Indicates that there is a bedrock outcropping. Confirm. This feature is not shown on the provided site plans.

E2f. Indicates that 7% of the site has steep slopes. Confirm. The Erosion and Sediment Control plan shows the locations of steep slopes, and it appears as if that is greater than 7% of the entire parcel.

E2m. The answer for what species of wildlife are found at the site given is “typical wildlife for NE.” This implies that no site specific wildlife inventory has been done. Given the Solar Law requires documentation of wildlife use of the site (not just threatened and endangered species), this answer (and documentation or lack of) is not adequate.

E2o. Add Northern Long-Eared Bat as a potential threatened species. The site is indicated as potential habitat as per NYS DEC information. It is noted that the site specific study showed no likely habitat but given that it is shown on NYS maps as potential, it seems this should be included and noted.

General Comments

1. There are discrepancies in the acreage listed for the disturbed area: narrative indicates a 9.4 acre disturbance, while the site plan shows fenced in area as 9.18 acres. It is unclear whether areas outside the fencing (including the land between the fence and the

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landscaping) is also considered disturbed. Note that the Solar Law requires that no components of a solar facility shall be larger than 10 acres, regardless of parcel size (Article V (3) (b) indicates that no large-scale energy facility, including any of its associated equipment, roads, and components can exceed 10 acres). If the fenced area is 9+/- acres, and there is a setback between disturbed areas and landscaping, which is also part of the facility, it is likely this may actually be greater than 10 acres. In other words, what exact portion of the 14.96 acre site is used by the solar facility and any of its components?

Additionally, FEAF Part 1 indicates that 9.2 acres will be disturbed. Further, the cover sheet in the Site Plan set indicates that there is a 3.9 acre maximum lot coverage as part of the project. These are crucial calculations to be clarified to ensure that the project meets the local zoning and solar law rules.

2. Narrative provided indicates that 2 acres of prime soils and soils of statewide importance are to be impacted. Note that the FEAF Part 1 indicates that 4.3 acres of prime farmland are to be impacted, and 8 acres of soils of statewide importance are to be impacted. The Solar Law does not allow for more than 2 acres of prime soils to be impacted. The narrative indicating that 2 acres are to be impacted is inaccurate, and furthermore, the Planning Board will need to evaluate whether the 2 acre prime soil maximum is met or not.

1. Other than indicating that they NYS DAM Solar Guidelines will be utilized, there is no other information included as to how. Please explain and provide more detail how the plans will or have incorporated those guidelines.

1. Note that NYS SHPO has indicated no impact on the local historic district provided three criteria are met. The plan narrative from the applicant should indicate how they will meet those criteria and the Planning Board should ensure review includes evaluating whether those criteria have been met.

1. Sound Study — This does not account for any construction related noise at all. This is likely when the most noise will occur, and we have no information as to what those impacts will be. The Planning Board should consider asking for an updated sound study to evaluate this. Further, the Planning Board should review the sound study and ensure that all the receptors you wanted studied are included. Usually, the Planning Board identifies or accepts the identification of sound receptors for the study before it is actually conducted. Confirm if there are other locations that need to be included. Finally, the glossary does not define “sensitive receptor,” but that term is used in the study to show some increases in ambient noise from the project.
1. The site plan does not label, show or describe the U-shaped noise barrier used in the sound study. This needs to be addressed and either removed from the sound study or added to the site plan.

1. Property Assessment Study
1. The study evaluated a variety of locations that were identified as being able to view a solar facility. This was determined from Google Earth tools. In order for that to be

validated, I recommend that the Planning Board evaluate and confirm that the properties included in the evaluation do indeed view a solar facility. Some of the locations chosen do not seem to be like Cherry Valley: the Schenectady, Clifton Park, and Schodack sites have different suburban to urban real estate markets, and I am unsure whether the assumptions used hold for Cherry Valley. The information from Westerlo may be most akin to conditions in Cherry Valley. Wemple Road in Bethlehem is quite rural, but not very far from Delmar and large employers in the area so I am unsure whether those properties are similar to the rural properties in Cherry Valley.

2. I recommend that the Planning Board engage its own appraisal consultant to review and comment on this study.

7. Photosimulations and Viewshed Analysis:
1. There are confusing references to whether the project site is in or not in the Route 20/166 viewshed. The Viewshed Analysis provided shows the parcel is not in the viewshed, but the photosimulation included a map showing the parcel was in the viewshed. The narrative provided indicates that they will meet the screening requirements regardless. It is recommended that it be fully determined whether this is in or not in the viewshed as the solar law requires photosimulations from Route 20 or 166 to show the sites visibility. That has not been provided and if it is in the viewshed, then it is a required submission.

1. Figure 5 — the left side of the photosim is shows to be cleared outside the fence. Is that accurate? Are the lands between the fence and the property line to be cleared or changed? What about that area in the wetland/floodplain? Are those areas to be cleared?

1. Figure 8 — Keep in mind that it will take many years for the screening to become effective. The plans do include the double row of evergreen trees as required, and the photosim shows some lower planted vegetation. However, the site plans, landscape plan does not show those small tree feature. The photosim needs to be consistent with the site plan.

1. Figure 11- This figure and Figure 15 indicates that the view to this site from Route 54 needs additional screening (see other landscape plan comments below).
1. Why was this view shown as 1 year out, but not 5-7 years, as in the other views? Note that the solar law indicates that photosimulations in 1, 5 and 10 year intervals may be requested by the Planning Board. You can discuss whether you need a 10 year interval or if the 5-7 year one is adequate to learn about visual impacts.

1. If indeed this site is within the Route 20/166 Scenic Byway viewshed, then there must be additional information provided to show what this site will look like and visibility from Route 20/166 (Solar Law #11 (b) (1)). No information or photosimulation has been provided to address this part of the Solar Law.

1. As the floodplain of the Cherry Valley Creek and associated wetlands are on the parcel and are included in the disturbed area, has there been any correspondence yet from NYS DEC and USACOE? Who is the Town's floodplain administrator, and have they reviewed any of these plans yet? If not, I recommend they be included as soon as possible. I also suggest that the Planning Board together with Lamont Engineers evaluate any impacts on-site changes to the wetland and floodplain might have on downstream locations. Lamont should ensure that the facilities crossing and stormwater drainage from the adjacent pond to the wetland/floodplain area are addressed in the erosion/sedimentation and SWPPP.

9. Operations and Maintenance Plan
1. This indicates that they will mow grass on site 2-4 times per year. While this would maintain grass-like cover, it would not enhance use of that grassland as a meadow habitat. Use of an appropriate seed mix to be pollinator friendly and to let that grow during the growing season with mowing in the fall would facilitate use of that area for birds and insects. See also comments under landscaping plan.

1. There is mention of sheep grazing there. Will this be included?

C. The 0&M discusses use of chemical treatments on site for weed control. I recommend the Planning Board discuss the advisability of use of chemical treatments and other alternatives as part of the long-term maintenance plan.

d. The 0 & M plan should be updated to include any requirements that may be imposed by the Planning Board. It should also reflect the schedule and handling of inspections as per the SWPPP.

10. The Special Use Permit Application references that an “overlay” is included with submission #3. Please offer additional information as to what this overlay refers to.

1. The Project Locator Analysis (related to the electrical connections) provided indicates that the site “must have necessary electrical infrastructure physically present.” Yet the interconnect study provided shows that the site does not currently meet those requirements and significant upgrades to the electrical system is needed in order to attain the 2.5 megawatt generation capacity. It is assumed that the applicant will be using the Option 1 (2.5 mw) identified in the interconnect study and thus this new infrastructure will be provided for. This is not explained anywhere else in the application or narrative. Please explain this further.

Site Plan Comments

1. The site plan and solar laws require additional existing conditions to be shown. Please add prime soils, soils of statewide importance, location of mature forest (adjacent to parcel), existing vegetation to be cleared in the disturbed area. The local laws require that trees that are > 8” dbh, alongwith a description of those trees be included on the site plan. While these are described in the narrative provided, they are not shown on the site plan other than the underlaying aerial photo. Add these features to the existing conditions sheet (C-2).

1. The Site Plan law requires a minimum road frontage of 200’. Please add road frontage footage onto existing conditions sheet (C-2).

3. The Solar Law requires a 100’ setback for ALL components of a solar facility. The 100’ setback is shown on the site plans as being met in some places but not in others. Further, the 100’ setback is shown from property line to where the solar panels are, but the fence, is within the 100’ setback. In our reading of the Solar Law, all components must have a 100’ setback which would include the fence. The Planning Board should ask their attorney for advice on this, but there are many components of this project within the 100’ setback. This includes:
1. The fence is within the setback on all sides and is shown approximately 80’ from the rear property line.

1. All the infrastructure of the project including the access road, laydown area, and turnaround features are within the required setback, and in some cases, virtually on the property line. My interpretation is that it is not lawful for these features to be outside the 100’ setback. The Planning Board should consult with its attorney on this issue.

1. C-1 shows the seeding mix to be the Ernst Solar Farm and Conservation Mix. We recommend that the seeding mix be changed to be a more pollinator-friendly mix as recommended by New York State DOT. The Planning Board should discuss seeding needs with the applicant to ensure that it is not just grasses, but pollinator friendly.

1. C-11 notes at the bottom indicate that the knox box will have keys for and coordinate with the Plattekill and Lloyd Fire Departments. This appears to be in error and should be corrected.

1. C-4 legend notes the Flood Zone X. Although the label says Flood Zone A, it seems clearer if the legend also says Flood Zone A.

1. Please provide information to the Planning Board as to National Grid's requirements and ability to place more electrical wires underground as per the solar law. The poles and transmission lines are significant features that are highly visible, and the Planning Board should explore if there are ways to underground more of these features.

1. The fence is shown and described as an agricultural fence. This is illustrated on Sheet C-1 1. Although this is an improvement over the usual chain link type of fence, we suggest that the Planning Board explore with the applicant other fences that could be more suitable for matching the aesthetic values of the community. There are examples of other fencing that could be explored.
1. As per the Solar Law, it is strongly recommended that the Planning Board consider fencing to allow for small mammals to cross under. This is currently not included in the proposal but is highly recommended.

1. The legend includes a symbol for fire hydrants. Please show or identify where the nearest fire hydrant is located, if any. The Planning Board should explore with the applicant fire suppression needs (which may not require water). Emergency services to this site should be evaluated in terms of both access and fire department needs and knowledge of fighting a fire at a solar facility. It is recommended that the Cherry Valley Joint Fire Department be included as an interested agency for SEQR so that they can adequately review the plans and comment.

10. Please further explain construction plans included time of year, length of time construction would take place, noise impacts of such construction, and type and amount of traffic that would be generated during that time.

1. C-4 and C-7, please identify the percent of the whole parcel that is in slopes > 15%.

Please further describe the feature on the site plan labeled as 0 & M path.

1. Site plan sheets that show the area near the access road have many features shown. It is difficult to see the setback line there as it is obscured by other features. Please show the setback line more prominently.

1. C-14 shows a “Limited Use Pervious Access Road”, but the note indicates it is not to be used for construction. C-9 shows a portion of this access road as a ‘stabilized construction access”. Please further detail how the access road will be managed during construction. Is the stabilized construction access to be changed after construction to be the limited use pervious access?

1. C-8 Landscaping Plan
1. The plan includes primary use of a double row of evergreens, as called for in the solar law. It includes eastern red cedar, white spruce, and balsam fir to be planted with 8’ high specimens. Will any of these trees grow in the wet areas and floodplains? The Planning Board should ensure that these are appropriate species for wet areas.

1. The solar law includes specific landscaping features beyond the double row of evergreens to include smaller trees and shrubs to create a more natural looking hedge. These trees are not included in the landscaping plan, and we do not believe the screening provided looks, nor will function, as a natural hedge. It is recommended that the Planning Board work carefully to enhance the landscaping to meet the full screening requirements of the solar law, and of the requirements as stated by SHPO for screening.

C. The O & M plan needs to address inspection and monitoring of all landscaping and replanting of any dead material for at least 5 years after planting.

d. The landscaping plan does not include a design, labels or information about the sound barrier as discussed in the Sound Study. This should be added to at least this sheet, if not others.

May 13, 2024

Cierra Utter – Chairperson

And Planning Board Members Town of Cherry Valley

2 Genesee St.

Cherry Valley, NY 13320 Email: cuttercvpb@gmail.com

RE: East Springfield Solar Project

Review Comments on developer Submissions dated: 4/1/24, 4/15/24 and 5/1/24 Dear Ms. Utter:

Lamont Engineers has reviewed the abovementioned submissions for the East Springfield Solar Project in the Town of Cherry Valley. Comments as follows:

Plans:

1. The Construction Sequence should be shown on the Erosion and Sediment Control drawing.

1. The Limit of Disturbance should be shown on the drawings.
2. On detail 2/C212, the minimum distance from the panels to the fence is shown as 10’ and 20’. Please clarify.
3. The solar module details have conflicting dimensions. A cut-sheet of the proposed modules should be provided.
4. Is soil restoration proposed? If so, it should be indicated on the drawings.
5. The “fire access turnaround” should be detailed and dimensioned to show that an emergency vehicle can effectively utilize the turnaround.
6. The Erosion and Sediment Control drawing shows a concrete truck washout at the driveway culvert entrance. How will the wetland be protected here?

SWPPP:

7. A construction sequence specific to this project should be included.

lamont@lamontengineers.com / www.lamontengineers.com

Phone: 518.234.4028 / Fax: 518.234.4613

PO Box 610, Cobleskill, NY 12043  25 West Fulton Street, Gloversville, NY 12078  141 Ulster Avenue, Apt. 1C, Saugerties, NY 12477

Cherry Valley Planning Board May 13, 2024

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9. The ground cover for existing conditions of agricultural land should be meadow per section 4.6 of the NYSSWMDM.
10. If the soil will not be decompacted/restored, the HSG’s should be increased in the finished condition.

8. If the soil will be decompacted/restored, this area should be included in the disturbance.

1. The rainfall distribution should be NRCC-24-hr, not Type II. State Environmental Quality Review (SEQR):
2. As noted in #4 above, the proposed panel sizing should be consistent on the drawings and the FEAF.

9. The disturbance areas should be consistent throughout the submission.

Operation and Maintenance Plan:

10. If grazing by sheep is planned for vegetation control, a plan should be submitted to ensure over-grazing is not permitted.

Please contact me if you have any questions or need additional information. Once these comments have been addressed, review of the plans and Stormwater Pollution Prevention Plan can proceed.

Jodie Serowski, P.E. Project Manager Lamont Engineers, P.C.

ecc: Nan Stolzenburg nan@planningbetterplaces.com

Town Board Letter regarding Carson Power seeking clarification on solar law terms “parcel size” and “project size” in relation to acreage.