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HomeMy WebLinkAbout20191203_Abundant_Groton-Town-County-DOT commentsLaBeLLa Powered by partnership. December 3, 2019 April L. Scheffler, RMC 101 Conger Blvd. P.O. Box 36 Groton, NY 13073 RE: Groton Solar Array Review Comments Dear Mrs. Scheffler: I've reviewed the comments issued by Tim Buhl and have provided the following responses below in red. The new Long form EAF has Some Inconsistencies - for example , it lists 28 acres of solar panels (which appears to be about right on the site plan) the EAF mentions some 2254 tables and 27,048 solar panels. From the drawings, each panel is 3.24' x 6.4', or 20.7 sf. Even though the panels do fold up, there is no listing for the new impermeable area shown, for the racking and H -piles. More information is needed and details should be required for the actual foundation system. • Since the area below the panels is left undisturbed and impervious, the NYDEC does not require the panels to be included in the disturbance/impervious area calculations. After consideration to comments issued by the Town Board and other commenting agencies, the project's disturbance limits has been reduced from 33.7 +/- acres to 24.5 +/- acres, a reduction of approx. 27%. The EAF will be updated accordingly. The project will remove approximately 13.8 acres of trees and stumps from the site, which in itself will alter the runoff coefficient of 1/3 of the site. This ground disturbance alone will push the project into the requirement for a basic SWPPP, and more likely a full SWPPP under the NYSDEC Stormwater regulations. This means special procedures during the construction, and more probably permanent volume reduction and treatment practices, even though it is a solar project. No such documents have been provided. I have concerns over the east -west orientation of the arrays, which will allow runoff to sheet drain directly downhill. There are no provisions or room along the lower (west) property boundary for any practices that could be required if problems develop. A preliminary review of the project by the NYSDEC should be requested. • After consideration to comments issued by the Town Board and other commenting agencies, the project's disturbance limits has been reduced from 33.7 +/- acres to 24.5 +/- acres, a reduction of approx. 27%. A SWPPP will be provided for review and approval covering drainage concerns. The lower wooded drainage area in the west -central portion of the site is a likely a wetland area, and should be delineated before the site plan is finalized. • A wetland delineation will be completed once the growing season has begun next year. Normal NYSDEC permitting will be addressed once final design is completed. 300 State Street, Suite 201; Rochester, NY 14614: p (585) 454-6110 ! f (585) 454-3066 www,LabeLLapc.com U3 The town standard setback conditions appear to be met., but consideration should be given to increasing the open space/buffer along the south boundary adjacent & behind the residences along NYS Route 222 (to help with buffering of the project) and along the west property line, where permanent storm water practices will probably be necessary. • Acknowledged, we defer to Planning Board for further comment. Due to the size, scope, and because the project is in an Agricultural district, the project should be considered a Type 1 action for SEQR. • Acknowledged, we defer to Planning Board for further comment. The access driveways shown do not meet the requirements for emergency access, according the NYS ICC Building Code. They need to be all-weather, and at least 16 feet wide with pull-outs so that emergency vehicles can respond to fires or service personnel injuries. Access driveways will be revised per NYS, Town and DOT standards. I would like to see more details and a SWPPP prepared to address the storm water issues before the project reviews continue. I also believe a meeting with the developer and Labella Engineers would help address the main issues, and whet will be required going forward. • After consideration to comments issued by the Town Board and other commenting agencies, the project's disturbance limits has been reduced from 33.7 +/- acres to 24.5 +/- acres, a reduction of approx. 27%. A SWPPP will be provided for review and approval covering drainage concerns. We agree that a meeting with the Town Engineer, Abundant and Labella would be helpful in furthering the final site design. The following preliminary comments were issued to the Town by "Keith" from NYSDOT.... Will the site be stripped of topsoil, and what would the final site grading and surface look like? • No topsoil will be stripped. There is minimal to no site grading being proposed. What are the soil types (clay, etc.)? • The site contains approximately 40% Langford Channery silt, 40% Bath and Valois soils and 20 % Erie Channery Silt Loam. Has existing agricultural drainage (field tiles) been identified/located? It seems likely that driving panel posts would crush/damage tiles and therefore impact site runoff conditions. Existing field drainage should be identified and included as part of any site drainage design. • Acknowledged. A SWPPP will be provided for review and approval covering drainage concerns. The site access roadway could act as a channel/berm/collector directing runoff toward a point at the southern edge of the property. Storm runoff mitigation will be required. 2 • Acknowledged. A SWPPP will be provided for review and approval covering drainage concerns. An access drive culvert will be required, and will need to be properly sized and designed. (A potential "berm" is mentioned, and on initial review seems unlikely to be feasible.) • Acknowledged. The following comments were issued to the Town by Katherine Borgella, AICP. Commissioner of Planning and Sustainability.... To help clarify any potential adverse glare impacts to vehicles coming along Cortland Road we suggest the Town require the applicant to prepare a glare analysis for the proposed project. • Acknowledged, we defer to Planning Board for further comment. Should any wetlands be delineated on the site we suggest the Town require the applicant to design the project in such a way that allows wetland hydrological function to be maintained. • A wetland delineation will be completed once the growing season has begun next year. Normal NYSDEC permitting will be addressed once final design is completed. Respectfully submitted, La Bella Associates c Da rocht Senior Project Manager