HomeMy WebLinkAboutSP202100001 Narrative Special Use Permit 2021-01-04Special Use Permit Application
Midway Solar
Albemarle County, Virginia
Submitted By:
Midway Solar, LLC
300 East Main Street
Suite 200
Charlottesville, VA 22902
Submitted To:
Albemarle County, Virginia
Planning and Zoning Department
401 McIntire Road
Charlottesville, VA 22902
Table of Contents
AboutSun Tribe.................................................................................................................................................................................3
ProjectProposal................................................................................................................................................................................3
RuralZoning Designation.............................................................................................................................................................4
Consistency with Comprehensive Plan.................................................................................................................................4
RuralAreas.................................................................................................................................................................................4
NaturalResources..................................................................................................................................................................5
PublicNeed and Benefit................................................................................................................................................................6
DirectRevenue to the County.........................................................................................................................................
6
EconomicDevelopment......................................................................................................................................................7
ClimateProtection.................................................................................................................................................................7
Quantification and Mitigation of Potential Development Impacts..........................................................................8
PublicInfrastructure.............................................................................................................................................................8
NeighboringParcels..............................................................................................................................................................8
Visual.............................................................................................................................................................................................8
RealEstate..................................................................................................................................................................................9
Glintand Glare.........................................................................................................................................................................9
Noise.............................................................................................................................................................................................
9
Lighting......................................................................................................................................................................................10
WaterResources.................................................................................................................................................................10
HazardousMaterials Statement..................................................................................................................................10
Quantificaiton of Potential Impacts on Environmental Features..........................................................................11
CriticalSlopes........................................................................................................................................................................11
Wildlife......................................................................................................................................................................................11
Cultural and Historical Resources...............................................................................................................................12
Streamsand Wetlands......................................................................................................................................................13
FacilityConsiderations...............................................................................................................................................................13
EquipmentDesign...............................................................................................................................................................13
Interconnection....................................................................................................................................................................14
ProjectSite Access..............................................................................................................................................................14
VegetativeBuffer.................................................................................................................................................................14
Fencingand Security..........................................................................................................................................................15
Signage......................................................................................................................................................................................15
Confidential and Proprietary 1 Midway Solar
Lighting......................................................................................................................................................................................15
FacilityPermitting..........................................................................................................................................................................15
StormwaterManagement Plan.....................................................................................................................................15
Erosionand Sediment Control......................................................................................................................................
15
LocalBuilding and Electrical...........................................................................................................................................16
PermitBy Rule.......................................................................................................................................................................16
FacilityConstruction....................................................................................................................................................................16
FacilityOperations and Maintenance..................................................................................................................................17
FacilityDecommissioning..........................................................................................................................................................18
Attachments.....................................................................................................................................................................................19
Appendix - Contextual Plan and Area Map.......................................................................................................................I
Appendix B - Viewshed and Visual Simulations................................................................................................................11
Appendix C - Real Estate Impact Analysis..........................................................................................................................III
AppendixD - FAA Notice criteria............................................................................................................................................IV
Appendix F - Manufacturer's Specification Sheets.........................................................................................................V
AppendixF - Hazardous Material Review..........................................................................................................................VI
Appendix G - Wildlife Resource Review............................................................................................................................
VI 1
Appendix H - Cultural/Historical Resource Review..................................................................................................
VI I I
Appendix I - Environmental Site Assessment and Wetland Deliniation..............................................................IX
Appendix - Emergency Management Details.................................................................................................................X
AppendixK - Decommissioning Plan.....................................................................................................................................XI
AppendixM - CVEC Letter of Support...............................................................................................................................X11
Confidential and Proprietary 2 Midway Solar
About Sun Tribe
As Sun Tribe's provider of large-scale renewable energy solutions, Sun Tribe Development partners
with landowners, local governments, and leading utilities as they move towards a cleaner energy
future. With an emphasis on quality, community -focused projects, Sun Tribe Development
specializes in sustainable solar solutions. Sun Tribe Development has built one of the most
experienced teams in the business, with over 20 gigawatts of collective renewable energy
experience.
Project Proposal
This application for special use is submitted to Albemarle County (the "County") by Midway Solar,
LLC, (the "Applicant"), a wholly owned subsidiary of Sun Tribe Development ("Sun Tribe"), to
construct an eight megawatt photovoltaic ("PV") solar energy system and four megawatt battery
energy storage system ("BESS") on Parcel 08500-00-00-017BO in the Samuel Miller District of
Albemarle County (the "Midway Solar Project" or the "Project"). The project company is party to a
Power Purchase Agreement with Central Virginia Electric Cooperative ("CVEC") and will produce
energy that will be purchased by CVEC for delivery to their members for at least two decades.
Serving almost 37,000 accounts, Central Virginia Electric Cooperative is a member -owned, not -for -
profit electric utility headquartered in Colleen, Virginia.
The Project is located on Parcel 08500-00-00-017BO ("Project Parcel"), off of Craigs Store Road
approximately 1.8 miles from the community of Batesville, Virginia. The Project Parcel is owned by
CVEC and a Lease Agreement has been established to allow the Applicant to develop and construct
an 8 MW solar array and a 4 MW battery storage system. The Lease Agreement applies to the entire
136 acres of the Project Parcel, but the solar and battery faci lity will not utilize the entire property
and therefore will establish a Project Site within the Parcel that in turn reserves a substantial area for
preservation. See AppendixAfor Conceptual Layouts depicting existing and proposed sitefeatures.
The Project Parcel is currently zoned Rural Area ("RA") and taxed as Agricultural Land Use. It is, and
has historically been, utilized for livestock grazing and siviculture. There are multiple vacant farm -
use buildings on the Project Parcel that are in disrepair. Any structure within the Project Site will be
removed but those that are located outside the Project Site will remain. The parcel totals 136 acres
and is approximately 30% cultivated timber and 70% pastures.
The Project Site is located in the Upper Mechums River Watershed within the larger South Fork
Rivanna Reservoir Watershed. Although the site will remove existing vegetation and replace it with a
different mix of panels and vegetation, the project's unique use does not impact water quality as a
traditional impervious development would, due to limited site access and low potential for pollutant
runoff.
Asolar energyfacility such as Midway will provide an increase in direct, indirect, and induced
revenue to Albemarle County. The County will also achieve a significant increase in tax revenue from
the Project site through the permitting and operation of the facility while requiring minimal to no use
of County services such as water, wastewater, schools, and other infrastructure. Although it is
acknowledged that emergency services may be engaged (See Appendix J) for reviewing
Confidential and Proprietary 3 Midway Solar
documentation from the battery storage manufacturer to guide in developing an Emergency
Management Plan. The Applicant intends to conduct a work session with the appropriate emergency
services personnel to develop a permanent Emergency Management Plan for the facility that blends
local knowledge with specific technical information provided by the manufacturers of the facility
components.
The project will be constructed and operated in accordance withal I applicable Federal, State, and
Local building codes and regulations.
Rural Zoning Designation
The Project Site, Parcel 08500-00-00-017130, is zoned Rural Area ("RA"). The Albemarle County
Code of Ordinance, Chapter 18, Sec.10, allows for solar energy systems in RA Zoning by Special Use
Permit. The intent of the RA Zoning is the preservation of agricultural and forestal land activities,
water supply protection, limited -service delivery to the rural areas, and conservation of natural,
scenic, and historic resources. The Midway project aligns with all these intents.
The Project Site will only utilize approximately 60 acres of the parcel's 136 acres. The parcel acreage
outside the Project Site will be kept in its current condition, with forested vegetation being
preserved.
Construction of Midway Solar ensures that the 136-acre parcel remains protected from intensive
development. At the end of the project's life, the site will be returned to its current condition.
Consistency with Comprehensive Plan
Rural Areas
Objective 2. Protect and preserve natural resources, which include mountains, hills, valleys, rivers, streams,
groundwater, and continuous and un fragmented land for agriculture, forestry, biodiversity, and natural
resource protection.
For the life of the facility (30+ years), the Project Site will be protected from further development.
Forested areas will be left in place where possible. Areas outside of the fenced project area will
remain available for grazing, wildlife corridors and habitat. After construction and for the life of the
facility, site visits by operation and maintenance personnel will be limited to an average of twice a
month, allowing the site to remain much as it is today, a natural landscape. Onsite streams and their
riparian buffers will be protected.
Objective 3: Protect the County's historic, archeological, and cultural resources.
The Project will ensure there is no impact to historic, archaeological, and cultural resources that are
present on the Project Site. The Applicant has already conducted desktop reviews to understand
potential resources that may be present onsite.
Confidential and Proprietary 4 Midway Solar
Natural Resources
Recognizing that natural resources are one of the area's most valued features, in the 2015
Comprehensive Plan the County identified certain objectives regarding the protection of natural
resources within the county. The following is a list of some of those objectives and a narrative on
how M idway Solar meets the spirit of those objectives.
Objective 1: Ensure clean and abundant water resources for public health, business, healthy ecosystems,
and personal enjoyment by preventing shortages and contamination."
Strategy 1a: Continue to apply the Watershed Protection Ordinance throughout the County to help
protect and preserve water resources.
The Applicant is dedicated to ensuring that M idway Solar will have no negative impact on water
resources on or surrounding the Project Site during construction or once operational. All applicable
sections of Chapter 17, Water Protection, of the Zoning Ordinance will be followed to the highest
degree.
The operation of a solar facility requires no water use. Therefore, Midway Solar will not put any
pressure on precious drinking water resources and associated infrastructure. Unlike traditional
development, a solarfacility has a very low probability of producing pollutant run-off which could
endanger groundwater, streams, creeks, and rivers. The components of a solar generating facility do
not require oil -based lubricants which are oftentimes the sources of pollutant discharge.
The land disturbance required for construction of a solar facility is far less than most other types of
development, such as residential development. Care was taken to design the Project Site so that
solar panels and equipment will be placed in areas that will require the least land disturbance. Where
land disturbance will occur, grading will be thoughtfully planned to ensure stormwater is responsibly
managed to protect downstream resources according to County and State guidance.
Objective 2: Protect air quality.
Strategy 2o: Help protect local and regional air quality by reducing the County's carbon footprint..."
Once operational, Midway Solar will provide 8MW of solar energy and 4M W of battery storage. This
carbon -free, renewable energy will power 2,600 Central Virginia Electric Cooperative households in
Albemarle County.
Objective 4: Protect the biological diversity and ecological integrity of the County in both the Rural Area and
Development Areas.
Strategy 4e: Encourage the use of native plants in landscaping to protect and provide habitat for
native biodiversity, to save water, and to connect landowners to the local ecosystem.
The use of native plantings for buffering and erosion and sediment control at Midway Solar will serve
to increase the biodiversity of the site. Research shows that pine stands planted at a lower density
(300 trees per acre) significantly increase the quality of wildlife habitat. The pine stands on the
Project Site exceeds this recommended density, reducing species diversity by preventing
germination of hardwoods. This lack of tree diversity reduces food and coverage for wildlife,
therefore also negatively impacting wildlife diversity.
Confidential and Proprietary 5 Midway Solar
Objective 5: Retain mountain resources.
Strategy 5b: Continue to protect critical slopes in Rural Area
The Midway Solar facility aligns with the intention of Objective 5 of the Natural Resources section of
the Comprehensive Plan, as development will largely avoid slopes of 25%or greater and solar panels
will be placed on the least slope areas of the Project Site.
Public Need and Benefit
Direct Revenue to the County
Albemarle County will benefit directly from the project in the form of increased tax revenue, both
from real property tax and from personal property taxation.
Currently, the parcel where the Midway Project will be located contributes just under $500 annually
to the Albemarle County tax base. This is in the form of real property tax. After construction of the
solar project, we anticipate this real property taxation to increase due to increased value placed on
the project site as well as rollback taxes due when the parcel is removed from its current land use
designation.
In addition to taxes on real property, personal property tax wiII provide additional revenue for
Albemarle County. Solar projects in Virginia can be assessed for Personal Property Taxation in one
of two ways, dependent on the County's choosing:
1) Machine and Tools (M&T) Tax Stepdown- this begins asan80%abatement for Personal
Property Taxes in years 1-5. It steps down to 70% in years 6-10, and 60%after year 10.
Utilizing this taxation methodology would represent more than $12,000 in Personal Property
Tax revenue for Albemarle County in year 1 of operations, and more than $380,000 over the
life of the project.
2) Energy Revenue Share -this is a straightforward taxation methodology which requires
$1,400/MWac/year in Personal Property Taxation. Utilizing this taxation methodology
would represent $11,400 in Personal Property Tax revenue for Albemarle County in year 1
of operations, and more than $445,000 over the life of the project.
Accounting for the additional Personal Property Tax revenue associated with the construction of this
project, Albemarle County could be expected to receive over $23,000 in year 1 of the project
operation, and more than $960,000 over the life of the facility. In comparison to the current tax base
for this parcel, which would be expected to result in approximately $20,000 over the next 40 years,
this project represents an approximately 48 times increase in current tax revenue received from the
parcel. Another consideration is the amount of public services that accompany this additional tax
revenue base; while the Project will increase the tax base provided to the County from the Project
Site, it will not have any significant draw on public resources such as schools, emergency services, or
roads. Because of this, the benefits of the additional tax revenue are amplified by the lack of
additional public costs necessary to support them.
Confidential and Proprietary 6 Midway Solar
Economic Development
In addition to direct revenue from taxes, there are other economic benefits to consider. The largest
of these is jobs directly attributable to the facility.
Because of the local nature of the Midway Solar Project, Albemarle County residents are already
employed in the development of the project. Sun Tribe Development, Central Virginia Electric
Cooperative, and the local environmental, engineering, and other consultants we employ establish
this project as a unique contributor to the local economy in Albemarle County.
Upon reaching construction, the project would continue to support local jobs with Sun Tribe as the
general contractor during the construction phase and a commitment to sourcing local sub-
contractors wherever possible. From fence and lighting installers, to panel electricians, civil
engineers, and construction laborers, significant local job creation during the engineering and
construction of the solar facility is guaranteed.
Climate Protection
Albemarle County's signature on the "We Are Stil I In" Declaration shows a commitment to the
continued support of the 2015 Paris Climate Agreement.
Sun Tribe shares the County's viewthat local governments play an important role in addressing
climate change, and as an Albemarle County business we want tojoin the County in assuming a
leadership role.
To meet the County's (and Commonwealth) carbon reduction goal, it will be necessary to accelerate
the shift to clean energy through deliberate and responsible renewable energy development.
Renewable energy projects like Midway align with the County's Climate Action Plan targets:
o "Benefit the health of the residents"
Fossil Fuel energy facil [ties not only increase the greenhouse gases directly contributing to climate
change but also create pollution which is known to adversely affect health. Renewable energy
alternatives, such as Midway Solar, create none of the same adverse health effects.
o "Protect the local natural environment"
Solar facilities such as Midway will operate for 20+ years, allowing the land to be protected from
more intensive development uses with the opportunity to reevaluate land use at the end of the
project's life. As noted, there are also 55 acres on the Midway parcel which remain outside the
Project Site.
Confidential and Proprietary 7 Midway Solar
Quantification and Mitigation of Potential Development Impacts
Public Infrastructure
As noted, Midway Solar will provide a tax base to Albemarle County that is not accompanied by a
burden on County services such as schools, roads, or other public utilities such as water and sewer.
At the conclusion of the approximately six-month construction timeline, visits to the site will be
limited to approximately two times per month. Therefore, the Midway Solar project will not
introduce a burden to county roads or facilities. The site will not require use of the County's water
and sewer infrastructure as no permanent staff will be stationed on site. Due to the lack of
permanent, on site, staff for the facility, a measurable burden to other public facilities will not occur,
Neighboring Parcels
Fourteen parcels border the Project Parcel. Nine adjacent parcels are single-family residential; one is
Conservation Use; one is Vacant Residential Land; three are designated in Agricultural Land Use.
Table 1 Adjacent Parcels
Landowner
Parcel ID
Parcel Address
Tax Type
Mark&Sara Tueuiig
085000-00-00UI600
1832 Craigs Store Road
A riculhiral Land Use
Calvin & Ruby Canody
085000-00-00-016A0
1876 Crai sStore Road
Reg. Taxable/Sinle Family
Diane S an-,&
085000-00-00-01700
1888 Crai sStore Road
Reg. Taxable/Single Family
Patti Riker
085000-00-00-004DO
1913Crai s5tore Road
Reg. Taxable/Sinle Family
Frank G. R der Rev. Trust
085000-00-00-00400
No 911 Address
Vacant Residential Land
William Marshall Life Estate
085000-00-00-004CO
1972 Crai sStore Road
Reg. Taxable/Sinle Family
Fellows Living- Trust
085000-00-00-00300
1915 Thunder Ridge Road
Agricultural Land Use
Haupt Trust
085000-00-00-0030A0
7181 Batesville Road
Conservation Use
Rose Zavada
085000-00-00-001BA1
6925 Batesville Road
Rem. Taxable/Single Famil
Elizabeth Williams
085000-00-00-0018DO
6793 River Hill Lane
Reg. Taxable/Single Family
Alma Ball
085000-00-00-0018E0
6809 River Hill Lane
Reg.Taxable/Single Family
Life Estate Bett Jean Maw er
085000-00-00-001880
6722 EII dia Lane
Re.. Taxable/Single Family
Carolyn U aves
I 085000-00-00-001883
1754 Crai sStore Road
Reg. Taxable/Sinle Family
Shelton Lor SharonA Root, III
1 085000-00-00-001500
6755 Black Oak Ride
A ricultural Land Use
The Project will mitigate impacts to neighboring parcels through maximizing the use of naturally
occurring vegetative screening paired with the installation and maintenance of both adequate
setbacks and additional vegetative buffering as necessary.
Visual
Recognizing the importance of conservation of scenic resources, great care was taken to design
Midway Solar in a way that protects the viewshed of the neighboring properties and roadways. This
is accomplished by adhering to all setback requirements, maintaining mature vegetative buffering in
place where available, conducting visual simulation renderings, and supplementing vegetative
buffering with additional native vegetation where appropriate.
The racking and panels which comprise the solar generating facility will not exceed the 20-feet height
restriction, measured from the base of the structure to its highest point. There will be no signage on
site, except for that required for safety, security or the requirements of the interconnecting utility
(CVEC).
Confidential and Proprietary 8 Midway Solar
Existing slopes, mature vegetation, and supplemental vegetation will further reduce the visual impact
to adjacent parcels. The applicant prepared a series of visual simulations of the viewshed of adjacent
parcels and along Craigs Store Road. These simulations show the viewshed impacts of the Project
when the facility is complete and vegetative buffering is in place. There will be no visual impact on any
other parcels adjacent to the Project Site. These simulations, as well as a viewshed map showing
elevations whereby the project maybe visible further away can be seen in Appendix B.
Vegetative screening wil I adhere to the requirements set out in Chapter 18, Sec. 32.7.9.7, of the
Zoning Ordinance and be no less than 20 feet in depth, utilizing double staggered rows of evergreen
trees planted on center with a minimum planting height of 4feet.
Real Estate
Solar generating facilities have no impact, positive or negative, on the value of neighboring properties
across the Commonwealth of Virginia. Using matched -pair analysis, a real estate impact analysis
performed on the Midway Solar area shows that the project will have no impact on home values on
abutting or adjoining properties and no impact on adjacent vacant residential or agricultural land. It
is important to note that the analysis also determined that solar farms using fixed or tracking panels
are a passive use of the land that is in keeping with the rural/residential area. The results of a real
estate matched -pair analysis performed by Kirkland Appraisals can be found in AppendixC.
Glint and Glare
Glint, momentary flashes of light, and glare, continuous source of excessive brightness, are caused
when sunlight is reflected off a flat, shiny surface. While solar panels are flat and somewhat shiny,
they are designed to capture light, rather than reflect it. Research shows solar panels produce less
glare than standard residential window glass, snow, or concrete. Photovoltaic panels are covered in
anti -reflective coating to mitigate any low levels of glare and glint.
Using the Federal Aviation Administration's Notice Criteria Tool, which takes into consideration the
Project Site latitude, longitude, horizontal datum, site elevation, and structure height, it was
determined that Midway Solar introduces no risk to air traffic and no further glint and glare study
would be necessary. A copy of the Notice criteria Tool results can be found in Appendix D.
Noise
An operating solar facility produces negligible noise when operating. Any noise produced by the
operating facility becomes inaudible at approximately one hundred (100) feet from the noise -
producing components. These noise -producing components, such as inverters, and tracker motors
have few moving parts that produce decibel levels that will not be heard from adjacent properties.
For example, the proposed solar inverters have a manufacturer listed noise rating of sixty-five (65)
decibels at one meter away from the inverter. The CDC reports this level of noise is comparable to an
air conditioner, washing machine, or dishwasher. The vast majority of inverters on the site will be set
back at least three hundred (300) feet from property lines, but no inverter will be closer than one -
hundred (100) feet from a property line. At one hundred (100) feet awayfrom the inverter, the noise
is reduced to approximately thirty-five (35) decibels which is comparable to the noise level of a soft
whisper or refrigerator hum. The proposed battery storage inverters have a manufacturer listed
noise rating of 75 decibels at three meters awayfrom the inverter and will be located no closer than
Confidential and Proprietary 9 Midway Solar
four- hundred (400) feet from property lines. At that distance, the noise reduces to approximately
forty-three (43) decibels which is comparable to a refrigerator hum. Since the facility will only
operate during daylight hours, there will be no noise produced at night.
There will be a short-term increase in noise levels during construction of thefacility. It is estimated
construction will take six months. However, noise -producing construction activities which will occur
during short increments of time throughout the construction schedule and will not be ongoing.
Noise -producing construction activities will be limited to daytime hours. The Applicant wishes to be
a good neighbor and will work with the County and adjacent landowners to minimize any impact
construction noise may have on the surrounding community.
Manufacturer specification sheets listing noise levels can be viewed in Appendix E.
Lighting
The Applicant recognizes and appreciates the County's efforts to protect the county's dark skies. To
that end, all lighting at Midway Solar will comply with all applicable sections of the Albemarle County
Code of Ordinance (Zoning Ordinance) and will be kept to the minimum necessary to ensure the safe
operation of the facility. All lighting will be designed to prevent spillover lighting and will be arranged
or shielded to reflect light away from adjoining residences and roads.
Water Resources
Midway Solar will be designed to minimize impacts to waterways onsite and downstream of the
Project Site. Both water quality and quantity will be considered and protected as the facility design
progresses. See AppendixAfor a Conceptual Grading, Stormwater, and Erosion and Sediment
Control Plan and for Conceptual Stormwater Details and Calculations. These conceptual plans depict
a very early stage of project design and will be updated to include information such as topographic
survey data, final equipment selection, and feedback from the County. The Applicant will continue to
solicit and incorporate County Engineering feedback through the Site Plan Approval process, where
the detailed stormwater and erosion and sediment control plans will be finalized.
Water resource protection is closely tied to land use and ground cover as activities upstream have an
impact on the downstream environment. While the Project proposes tree clearing, it also proposes
establishment of additional visual vegetative buffers and healthy vegetative cover under the
proposed PV panels including native species. The establishment of healthy ground cover after the
construction phase will be heavily monitored and emphasized as the first step in water quality
protection, in addition to the temporary erosion and sediment control and permanent stormwater
Best Management Practices (BM Ps) that will be implemented in accordance with County and DEQ
guidance. Vegetation in all areas outside the Project Limits of Disturbance (LOD) will be untouched
and preserved.
Hazardous Materials Statement
The Project does not pose a risk to public health due to the presence of hazardous materials.
Although PV panels may contain small amounts of some potentially hazardous materials such as lead,
these materials are sealed within the panel to prevent environmental exposure. Similarly, the battery
energy storage system is lithium -ion based and is totally self-contained and monitored. See Appendix
Confidential and Proprietary 10 Midway Solar
F for a detailed description of panel construction, additional discussion of the negligible public health
and safety impacts of solar PV projects, and safety information from the battery storage
manufacturer.
Quantificaiton of Potential Impacts on Environmental Features
Critical Slopes
The Midway Solar Project design will not encroach on any large contiguous areas of critical slopes, as
defined in Chapter 18, Article I, Section 3.1 and described in Chapter 18, Article 11, Section 4.2 of the
Zoning Ordinance. Care was taken to design the Project Site in a manner that follows existing site
topography and avoids areas of high slope that would negatively impact downslope land or
waterways if disturbed. The current design does impact two small areas of non-contiguous critical
slope that are less than 100feet in length, totaling0.046 acres, and surrounded by areas of non-
critical slope. As part of additional design and due diligence, a topographic survey is underway and
data from the survey will be evaluated to understand these areas of critical slope with higher
granularity. As the design progresses, these areas of impact will be reevaluated and, if necessary, the
Applicant will undertake the waiver process as described in Chapter 18, Article 11, Section 4.2.5.
Wildlife
As part of the environmental due diligence performed on the Midway Solar Project Site, the
Applicant engaged with the industry -expert consulting firm Timmons Group to determine the
likelihood of encountering any species on the State or Federal lists of Threatened and Endangered
Species. The complete Threatened and Endangered Review conducted on the Midway Solar site is
available in Appendix B; below is an excerpt from that review:
Table 2 Threatened and Endangered Species Review
U.S. Fish and Wildlife Services
I nformati on, P1 a nning and Consul tationsSystem
Virginia Department of Game and Inland Fisheries
Virginia Fish and Wildlife Informations stem
Virginia Department of Game and Inland Fisheries
Wildlife Environmental Review Map Services
Virginia Department of Game and Inland Fisheries
Northern Long-eared Bat Winter Habitat and Roost Locator
Virginia Department of Game and Inland Fisheries
Little Brown Bat and Tri-colored Bat Winter Habitat and Roosts Locator
Virginia Department of Game and Inland Fisheries
Division of Natural Heritage Database
The Center for Conservation Biology
Virginia Eagles Nest Locator
The comprehensive review identified the potential for the following species to be present on the
Midway Solar site:
Common Name 9r
Scientific Name
Status
Agwaa&Saurce
Northern Lono eared fiat
Myotis septentrionalls
Federal Threatened
USFWS
Little Brown Bat
Myotis IUclfugus
State Endangered
VDWR
James spinymussel
Parvaspina collina
Federal Endangered; State
Endangered
VDWR
Confidential and Proprietary 11 Midway Solar
Based on the results of the desktop review, a comprehensive field habitat study was conducted on
site to determine if species identified in the State and Federal databases actually had potential
habitat present on the Midway Solar Project Site. The results of the comprehensive field habitat
review determined:
James spinymussel: Due to excess off iner sand and silty substrate, lack of fast-f lowing, well
oxygenated water, and evidence of recent flooding events, it was determined that no suitable habitat
exists on the Project Site to support the presence of the James River spinymussel.
Northern long-eared bat: Review of the Virginia Department of Game and Inland Fisheries Northern
Long-eared Bat Winter Habitat and Roost Indicator determined there were no maternity roosts or
hibernacula located within or near the Project Site. Therefore, it was determined that the Project is
unlikely to have any effect on any known northern long-eared bat areas.
Little brown bat: The Wildlife Environment Review Map Services identified little brown bat
hibernacula within a5.5-mile buffer of the Project Site. However, this 5.5-mile buffer does not
intersect with Project Site, and therefore there is no expected impact. There were no tri-colored bat
hibernacula identified within range of the Project Site.
The Applicant will continue to coordinate with Local, State, and Federal agencies through the State -
led Permit By Rule process to ensure there is no impact to local fish and wildlife species. If a potential
impact is identified, the Applicant will coordinate with those applicable agencies to draft and enact
plans to mitigate the impact.
The complete wildlife resource review can be viewed as Appendix G.
Cultural and Historical Resources
Timmons Group was retained to conduct a comprehensive desktop review to determine if any known
historical and archaeological resources were present on the Project Site or within a one -half -mile
buffer surrounding the Site. Eight architectural resources were identified within the one -half -mile
buffer, none of which were within the site boundaries. No archaeological resources were identified.
One architectural resource, the Batesville Historic District, is listed on the National Register of
Historic Places and Virginia Landmarks Register. The remaining resources identified have not been
evaluated for listing on the National Register of Historic Places. The complete Cultural and Historical
Resource study can be viewed as Appendix H.
Table 3 Historic/Cultural Resources Identified
Site Description
Location
1 e Evaluation Status
002-0194
1 IaLlptl 10LiSe
Adjacent
Not EI g ble
002-1279
Moons Mille Site
Adacent
Not Eligible
002-1281
Quai ry Site. Route 636
Adjacent
Not Eligible
002-2212
Batesville Historic District
Adjacent
NRHPListing; VLR Listin_-
002-0655
Mt. Ed. Baptist Church
Adjacent
Not Eligible
002-1278
Kennedy Farm
Adjacent
Not Eligible
002-1211
Harold Brown House
Adjacent
Not Eligible
002-0709
Barksdale Farm
Adjacent
Not Eligible
Confidential and Proprietary 12 Midway Solar
The Applicant has engaged a licensed archeological firm (Dutton and Associates) to conduct a Phase
IACultural Resource study to determine if a full Phase I Cultural Resource study will be appropriate.
These Cultural Resource studies will identify any potential impact to identified historical and cultural
resources. The Applicant wil I coordinate with the Virginia Department of Historical Resources
through the Permit By Rule process to assess whether there are any impacts to off -site resources
and, if an impact is identified, to develop an appropriate mitigation plan. The results of any studies will
be provided to the County once complete.
Streams and Wetlands
Awetland delineation was performed by Timmons Group to identify all streams and wetlands on the
Midway Project Site. The complete delineation can be reviewed as Appendix I. A Preliminary
Jurisdictional Determination was issued by the U.S. Army Corps of Engineers (USAGE) confirming
the locations of streams and wetlands identified by Timmons and is also included for review in
Appendix I. The Project was designed to ensure there will be no impact on any identified streams or
wetlands. Consistent with the Albemarle County Water Protection Ordinance, the project design
incorporates a 100-foot buffer around all identified streams and wetlands. Additional buffer will be
provided where possible. Seethe Conceptual Grading & SWM/ESC Plan on Sheet B in AppendixA
for a conceptual depiction of proposed stream and wetland setbacks.
The Applicant has secured a Preliminary Jurisdictional Determination (" J D") with the U.S. Army
Corps of Engineers (USACE) to confirm stream and wetland areas identified in the field delineation.
The Project will not impact any delineated streams or wetlands. the Project will be developed and
constructed in conformance with all applicable federal, state, and local laws and regulations, including
the Chesapeake Bay Act, Clean Water Act, and VA-DEQ Stormwater Management Program
Regulations.
Facility Considerations
Equipment Design
The Midway Solar Project is an 8 MW alternating current ("AC") photovoltaic solar electric power
generation facility and includes a 4 M W battery energy storage system ("B ESS" ).
The Project will utilize photovoltaic (PV) panels to convert the sun's energy into electricity (direct
current, "DC"). The PV panels are electrically connected and mechanically mounted on racking
equipment made from metal framing driven into the ground. The racks are oriented in rows along a
north -south axis. These rows of panels use self -powered motors to rotate east -west following the
sun's path each day facing east in the morning, horizontal midday, and west in the afternoon. This
single axis tracking mechanism provides more megawatt hours (MWhs) of power production as
compared to a fixed -tilt racking system using a similar footprint. Additionally, most panels used on the
Project Site will be bifacial, meaning both sides of each panel are used to produce energy. This
increases total energy generation and improves plant efficiency. Sun Tribe has selected both the
bifacial panels and single axis tracking racking to maximize efficiency and, therefore, reduce the
amount of land needed to produce 8 MWs of power.
Confidential and Proprietary 13 Midway Solar
The electricity produced by the panels is collected by wires in both aboveground and underground
conduits before connecting to inverters that convert the electricity from direct current to alternating
current. The inverters are then connected through additional wiring in conduit to transformers that
step up the power to a higher voltage for transmission and interconnection to the existing electrical
grid. Inverters and transformers will bed ispersed throughout the site.
The energy storage facility includes self-contained battery enclosures, inverters, and transformers.
The battery enclosure is a rectangular container that hold stacks of batteries and include fully
integrated HVAC, communications, and fire suppression equipment. The container is approximately
40 feet in length, 8 feet in width, and 9.5 feet in height. The battery container is electrically
connected to inverters and transformers whose purpose are described above.
All the equipment utilized for the Project will be UL listed (or equivalent) and the design will comply
with the current version of the National Electric Code. Meters, safety switches, and combiner boxes
will be utilized as necessary. The exact manufacturer and type of equipment and associated design is
subject to change based on future availability and pricing.
Interconnection
Interconnection of the Midway Solarfacility will occur on the Central Virginia Electric Cooperative's
24.9kV distribution system via attachment facilities directly on the Midway Project Site. Assuch,no
additional right-of-way easements will be necessary to accommodate interconnection of the facility.
The attachment facilities consist of pole mounted electrical equipment including switches, reclosers,
and meters. The photovoltaic array and battery storage system will share a common Point of
Interconnection (POI) and associated equipment.
An interconnection requestwas filed with Central Virginia Electric Cooperative on August 8, 2020.
It is anticipated the interconnection studies will be completed in January 2021.
Project Site Access
Access to the Project Site will occur by a single gravel access road off Craigs Store Road. Several
small accessways will be installed within the Project Site boundary to allow access to all site
equipment. Minimum impact to traffic is expected during construction. Once operational, there will
be no daily staff at the Project Site, and site visits are expected to be limited to approximately two
times per month.
Vegetative Buffer
Existing mature vegetation will be utilized as buffer wherever possible on the Project Site. Any
needed additional vegetative screening is identified in AppendixA and will adhere to the
requirements set out in Chapter 18, Sec. 32.7.9.7, of the Zoning Ordinance and be no less than 20
feet in depth, utilizing double staggered rows of evergreen trees planted on center with a minimum
planting height of 4 feet and achieve 8 feet in height within 3 years. Native, non-invasive species will
be utilized for all installed vegetative buffering. Vegetative buffering will be maintained throughout
the life of the Project.
Confidential and Proprietary 14 Midway Solar
Fencing and Security
All system components will be enclosed in a perimeter fencing of not -less -than 7 feet in height.
When possible, non -adjacent system component areas will be fenced individually to allow for natural
wildlife corridors through the Project Site. The fencing will serve to prevent unauthorized personnel
from entering the Project Site and will protect the system components from damage by wildlife. A
locked gate will be installed to al low for ingress and egress of authorized personnel. The security
fencing will be installed interior of vegetative buffering in areas where the security fencing may
impact the viewshed of neighboring properties.
Temporary fencing will be installed, as necessary for safety and security, during construction. Access
will be limited to authorized personnel, including designated County officials.
Signage
Safety and security signs will be located every 100 feet along the perimeter security fencing. Speed
limit signs will be posted on Project Site interior access roads. Temporary instructional or safety
signs will be posted during construction, as appropriate and necessary.
Lighting
The Applicant recognizes and appreciates the County's efforts to protect the county's dark skies. To
that end, all lighting at Midway Solar will comply with all applicable sections of the Albemarle County
Code of Ordinance (Zoning Ordinance) and will be kept to the minimum illumination necessary to
ensure the safe operation of the faci I ity. All lighting wi I I be designed to prevent spillover I ighti ng and
will be arranged or shielded to reflect light away from adjoining residences and roads.
Facility Permitting
Stormwater Management Plan
Recognizing and respecting the importance of protecting our clean water sources, the Applicant will
coordinate with the County, as the designated program authority for the Virginia Stormwater
Management Program ("VSM P"),for review and approval of Midway Solar's stormwater
management plan. The Project's conceptual Stormwater Management Plan can be viewed in
Appendix A.
Erosion and Sediment Control
The Applicant places great value on the protection of Albemarle County's water and soil resources.
As such, the Applicant will ensure strict compliance with all applicable erosion and sediment control
laws and regulations. Management practices utilized on site will be designed specifically to prevent
the discharge of sediment and other pollutants into nearby streams. The Applicant will coordinate
with Albemarle County, as the designated Erosion and Sediment Control Program ("VESCP")
Authority, on submittal and review of the Project's erosion and sediment control plans. The Project's
conceptual Erosion and Sediment Control Plan can be seen in AppendixA
Confidential and Proprietary 15 Midway Solar
Local Building and Electrical
The Applicant will adhere to all County building and electrical codes. The Applicant wil I coordinate
with the County to secure al I applicable building and electrical permits prior to start of construction
Permit By Rule
All renewable energy generating facilities in the Commonwealth of Virginia must complete
requirements setforth under the Department of Quality Permit By Rule ("PBR") process. The PBR
process provides a streamlined method for cultural and environmental permitting of renewable
energy projects. PBR incorporates reviews from the Department of Quality (DEQ), Department of
Wildlife Resources (DWR), Department of Conservation and Recreation (DCR), and Department of
Historic Resources (DH R) to identify and mitigate potential impacts a project may have to the state's
cultural, historical, natural, and wildlife resources. Any identified impacts must be sufficiently
mitigated to receive approval under the PBR process.
The PBR process addresses 15 major points required by DEQ for approval. These points include the
completion of reviews from the DH R, DWR, and DCR, as well as assessments on air quality and
interconnection. A mitigation plan and operating plan outlining how the Applicant will avoid
environmental and cultural impacts are also required. A 30-day review and public comment period,
inclusive of a public community meeting, must occur prior to the permit submittal.
DEQ recommends submittal of the project's Notice of Intent (NOI) to complete the PER process
after local land use approval has been secured. However, Applicant will begin initial discussions with
DEQ prior to local land use approval in order to coordinate with applicable agencies and ensure
compliance with all federal, state, and local laws and regulations.
The Applicant will submit a NO[ for the Midway Solar project to DEQ if a Special Use Permit is
secured. The Applicant will update Albemarle County staff on permit progress through the PBR
process. A complete permit will be forwarded to the County once secured.
Facility Construction
Construction of the Midway Solar project is expected to take approximately six months, beginning in
early 2022, and concluding in mid-2022.
A Sun Tribe construction manager will coordinate, direct, and manage all logistical and workforce
aspects of construction of the facility. It is estimated that there will be approximately 20 personnel
on site daily during construction, with some construction activities requiring fewer personnel to be
on site. Personnel will park only in designated areas on the Project Site during construction of the
facility.
On -site construction activities fall into the following main categories:
• Civil & Environmental: Temporary erosion and sediment control Best Management Practices
(BM Ps), permanent stormwater management BM Ps, internal site road construction,
construction entrances and material laydown area
• Fence: Permanent fence surrounding Project Site
Confidential and Proprietary 16 Midway Solar
• Mechanical: Racking foundation pile driving, metal racking assembly, and solar panel
installation
• Electrical: Mounting of electrical equipment, trenching, and installation of conduit and wire
Materials and equipment necessary to construct Midway Solar will be manufactured off site but will
be delivered to the Project Site by truck. Trucks delivering project materials wi I I be both staged and
unloaded on the Project Site. Major materials that maybe stored on site prior to installation include
PV modules, inverters, racking, and spooled wire. Other materials arriving by truck for more
immediate installation include fencing, conduit, concrete, reinforcing steel, wire management
hardware, communication equipment, and other electrical components. A temporary gravel
construction laydown and parking area is depicted on the Conceptual Grading & SWM/ESC Plan in
Appendix A.
Construction will occur during daylight hours. If scheduling anomalies require construction activities
to occur outside of daylight hours, the Construction Manager will ensure these activities are limited
in scope and do not include activities such as delivery of materials or pile driving.
The detailed construction plan will include phasing considerations to minimize disturbed area during
construction. Construction will aim to seed or mulch disturbed areas immediately upon bringing the
site to grade and will ensure both temporary and permanent seeding and other stabilization
requirements are met. Individual erosion control measures will not be removed until approved by a
County inspector. The Project will treat drainage areas and corresponding BM Ps individually and will
aim to convert temporary devices to permanent in a strategic sequence to minimize potential impacts
resultingfrom individual rain events. The Project Site is divided and drains to two different receiving
channels; therefore the upstream area of disturbance is split similar to two different projects.
Facility Operations and Maintenance
Solar generating facilities such as Midway Solar are monitored and operated remotely. The facility
will be monitored 24/7 for performance and safety. Midway Solar's remote monitoring system will
alert project personnel of any system fault/failure. The interconnecting utility, Central Virginia
Electric Cooperative, will also have remote monitoring systems in place to notify of system
fault/failure. In the event of fault or failure, operations personnel will be dispatched to the facility to
take appropriate actions to restore the facility.
Ongoing maintenance of facility components will occur at intervals and using the protocols
prescribed by the equipment manufacturer. All maintenance activities will adhere to NFPA 70E
safety standards.
All vegetative areas in and around the Project Site will be maintained by qualified grounds
maintenance crew.
Confidential and Proprietary 17 Midway Solar
Facility Decommissioning
At the time the Project permanently ceases to operate, the Project Owner ("the Owner") will perform
decommissioning activities. The Owner will provide notification to the Zoning Administrator of the
abandonment or discontinuance of the use, and complete physical removal of the project within 6
months of abandonment. Decommissioning includes the remove all equipment and materials related
to the operation of a solar PV project, including:
• Removal of all racking, panels, and electrical equipment
• Removal of all cabling above 30"
• Removal of all above ground cabling
• Removal of all concrete foundations
• Removal of all internal roadways and fencing
Any existing vegetation and buffering will remain in place and disturbed areas will be covered with
topsoil. All refuse and materials will be removed from the site and disposed of according to applicable
laws and regulations. Where possible, materials will be recycled, salvaged, or reused.
Decommissioning is designed to restore the property to its condition prior to the Project's
construction.
The Applicant has developed a preliminary Decommissioning Plan. Prior to Project construction the
Owner will enter into a written agreement with the County to decommission the facility in the event
the Owner is not able to do so. This agreement will be developed in accordance with State regulation
[15.2-2241.21. The Projects Preliminary decommissioning plan can be viewed in Appendix K
Confidential and Proprietary 18 Midway Solar
Attachments
AppendixA - Contextual Plan and Area Map
Appendix B - Viewshed and Visual Simulations
Appendix C - Real Estate Impact
Appendix D - FAA Notice Criteria
Appendix E - Manufacturer's Specification Sheets
Appendix F - Hazardous Materials Review
Appendix G - Wildlife Resource Review
Appendix H - Cultural/Historical Resource Review
Appendix I - Environmental Site Assessment and Wetland Delineation
Appendix - Emergency Management Details
Appendix K- Decommissioning Plan
Appendix M - CVEC Support Letter
Confidential and Proprietary 19 Midway Solar
Appendix A - Contextual Plan and Area Map
Confidential and Proprietary I Midway Solar
Appendix B - Viewshed and Visual Simulations
Confidential and Proprietary I I Midway Solar
Appendix C - Real Estate Impact Analysis
Confidential and Proprietary III Midway Solar
Appendix D - FAA Notice criteria
Confidential and Proprietary IV Midway Solar
Appendix E - Manufacturer's Specification Sheets
Confidential and Proprietary V Midway Solar
Appendix F - Hazardous Material Review
Confidential and Proprietary VI Midway Solar
Appendix G - Wildlife Resource Review
Confidential and Proprietary VI I Midway Solar
Appendix H - Cultural/Historical Resource Review
Confidential and Proprietary VI I I Midway Solar
Appendix I - Environmental Site Assessment and Wetland Deliniation
Confidential and Proprietary IX Midway Solar
Appendix J - Emergency Management Details
Confidential and Proprietary X Midway Solar
Appendix K - Decommissioning Plan
Confidential and Proprietary XI Midway Solar
Appendix M - CVEC Letter of Support
Confidential and Proprietary Al Midway Solar
--Sun Tribe
Building Solar. ReimaginingTomorrow.
DECOMMISSIONING PLAN
MIDWAY SOLAR CENTER
ALBEMARLE COUNTY, VIRGINIA
-SunTribe
Building Solar. Reimagining Tomorrow.
1
--Sun Tribe
Building Solar. Reimagining Tomorrow.
1. INTRODUCTION
The Midway Solar Project ("Project"), is a solar photovoltaic power generating facility on
approximately 60 acres of land in Albemarle County, Virginia. This conceptual plan outlines the
responsible parties and timeframes for proper removal of all Project faci I ities at the end of its useful
life of the Project, or when the project is otherwise abandoned.
MEa0.1011X40914101IS10972!1A21P
Photovoltaic power generating systems are arrays of solar panels containing a material that
converts solar radiation into direct current ("DC") electricity. The Project uses inverters to
convert the direct current to alternating current ("AC"), which is required for connecting and
injecting power into the electrical grid.
The project will consist of photovoltaic modules affixed to a low -profile, single -axis, tracking system.
The racking system uses a "rammed post" technique for installing the steel posts directly into the
soil, eliminating the need for concrete footings. I n different sections of the facility the cabling will be
(1) affixed to the underside of the photovoltaic panels, (2) run in cable tray or another above -ground
cable management system, or (3) directly buried to conduct electricity generated by the solar panels
to the grid. The system is designed to operate efficientlywithout interruption during a lifespan of
more than twenty-five years.
The photovoltaic modules will be mounted on racking along a north/south axis, which will be
connected to a drive system to rotate the modules. Electrical equipment, including inverters and
transformers are grouped throughout the site. Inverters convert the low voltage DC electricity
generated by the modules to AC electricity. The transformers then step up the voltage of the AC
electricity to match the grid voltage. A medium voltage, underground AC circuit connects the
Project transformers to the electrical grid.
2.1. ACCESS ROADS
Existing site access off Craigs Store Road will be used to access the Project. Internal to the site, an
improved gravel maintenance road will be located through the Project to provide maintenance
access to the solar equipment. The perimeter of the Project property will be secured, and
controlled access gates will be located at the Project entrance.
The Midway Solar Project will be an unmanned facility. All internal access roads will be designed to
accommodate a vehicular load of 75,000lbs and will be finished with an all-weather gravel surface
(aggregate base course).
IrJP# y 4 ► Ee11 z Eey_1 z 193 0.7-ICe1 E110 Eel 9033 &1
2
` Sun Tribe
Building Solar. Reimagining Tomorrow.
As described above, the solar array construction consists primarily of ramming galvanized steel
piles into the ground. Typically, the piles are embedded approximately 7 feet into the ground. The
proposed fence will be six (6) feet tall and topped with three (3) strands of barbed wire (12") to
ensure public safety and security. As noted above, two access gates will be positioned to provide
access to the Project.
3. DECOMMISSIONING PLAN
At the time the Project permanently ceases to operate, the Project Owner ("the Owner") will
perform decommissioning activities to remove all equipment and materials related to the
operation of a solar PV project and restore the property to its condition prior to the Project's
construction. The following activities discuss the steps taken after the Project is disconnected
from the utility power grid.
CSa9W_A0I0IIz[ey-A0l•]»:7ulraI IOrel
Governmental regulations at the time of decommissioning may require specific plans and permits
to be in place prior to site decommissioning activities. The Owner will develop a comprehensive,
site specific plan based on this conceptual Decommissioning Plan to follow during the
deconstruction process. The Owner will identify and acquire all local, state, and federal permits
required for this work. The Owner will identify subcontractor(s) and waste/recycling companies
during the planning phase.
3.2. REMOVAL OF PV EQUIPMENT
3.2.1. All PV modules will be removed and disposed of at a licensed disposal facility that
recycles or safely deconstructs PV modules, if such a facility is available at the time of
decommissioning. If such facility is not available, modules will be returned to the PV
module supplier via any available take -back or manufacturer recycling program. If
such recycling facility or take -back program is not available, PV modules will be
disposed of in accordance with applicable law and then -current environmental
standards.
3.2.2. Above ground racking support structures will be removed. Below ground piles will
be removed entirely where practical. Any such structures that cannot practically be
pulled out (for example, posts embedded in bedrock) will be cut three feet below
grade and the remainder will be left in place and covered. This will allow
agricultural activities to resume over top of the material.
3.2.3. All power collection equipment including cabling, combiner boxes, inverters,
transformers, control cabinets, and switchgear will be removed from the site and
disposed of at a licensed disposal facility or recycling center.
3.2.4. Underground cables buried at least 30" will remain in place. All above ground cable
will be removed from the site. This will allow agricultural activities to resume over
top of the material.
3
--Sun Tribe
Building Solar. Reimagining Tomorrow.
3.2.5. All concrete foundations will be broken up and debris will be removed from the site.
3.3. SITE RESTORATION
3.3.1. The site fence will be pulled out and removed from the site.
3.3.2. Gravel access roads and staging areas will remain until all other materials have been
removed from the site to facilitate decommissioning activities. Once equipment
removal is concluded, the road material will be removed from the site and replaced
with fill. The fill will be graded to follow the contours of the site.
3.3.3. Any disturbed areas will be covered with topsoil, consistent with the composition of
the soil prior to construction of the Project.
3.3.4. Existing access shall be left in place so that the property owner can continue to access
their property.
3.3.5. Any vegetation planted as buffers and screening for the facility will remain.
3.4.ADDITIONAL PLAN NOTES
3.4.1. All decommissioning construction shall take place during daylight hours and shall
conform to any applicable restrictions as related to noise levels.
3.4.2. Environmental mitigation measures similar to those employed during the construction
phase of the Project shall be implemented to reduce environmental effects during the
decommissioning.
3.4.3. Albemarle County and all stakeholders shall be notified thirty days in advance of any
action to decommission the Project.
3.4.4. The Owner shall provide proof of disposal to Albemarle County or other agencies
upon request.
4. DECOMMISSIONING SCHEDULE
The Project is intended to operate for a term of 20 years with the potential for three (3) additional
five (5) year periods. The Project will sublease the propertyfor a term of up to 35 years. At the end of
the sublease term, the Owner will cease operation of the Project and execute a Final
Decommissioning Plan agreed to by Landlord and Project Owner. The duration of decommissioning
activities will be approximately 6 months.
rd