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HomeMy WebLinkAbout239 Response LetterNY Groton I LLC NY Groton 11, LLC PO Box 384 Callicoon, NY 12723 August 26, 2024 Town of Groton Town Board 101 Conger Blvd. Groton, NY 13073 Attn: Town Board CIO Robin Cargian, RMC, Town Clerk Re: Community Utility Solar Development — South Main Street Project #1 and #2 Dear Mrs. Cargian, The Town Board requested at the last meeting for Delaware River Solar to respond to the Tompkins County 239 review letter dated August 9, 2024. Please see below for our response to reach of the recommended Modifications and the additional comments. Recommended Modifications • This proposal includes construction of an access road (aka permanent stream crossing) across an intermittent stream and a Tompkins County Water Resources Council designated wetland. While it is clear that there is no way to avoid crossing that area to construct this project, to help preserve and protect water quality, we recommend that the Town require the applicant to document that the functions of the wetland and the water quality of the intermittent stream were considered and elaborate on how the proposal of the permanent stream crossing will not negatively impact water quality or wetland functions. This modification is recommended to help preserve and protect water quality. Please see the plan submitted with this response, in which there will be a culvert installed for the stream crossing. The culvert will not inhibit the flow of the intermittent stream and thus will not alter the existing hydrology of the region. There will not be a negative impact to the water quality or wetland function. The design of the culvert will be reviewed and approved by the Town Engineer prior to installation. • We recommend that the Town require the applicant to relocate the proposed inverter outside of the 50-foot buffer of the intermittent stream. This modification is recommended to help preserve and protect water quality, as well as reduce the possible impacts of flooding on the proposed project. DRS requested permission from the Town Board to talk to directly to the representative at the Tompkins County Planning Department regarding this comment A phone call was made to the Tompkins County Planning Department to .speak to Abigail Conner to discuss this comment on August 10' 2024. Based on a conversation between DRS and Mrs. Conner it was determined that there was a mistake when the County representative reviewed the plans, The representative seemed to think the rain garden located outside the 5 0 foot buffer area of the stream was the inverter pad. While on the call the drawings were reviewed with Mrs. Conner, it was found that both the rain garden and the inverter pad were located outside of the buffer area. Mrs. Conner requested we demonstrate to the Town Board that these areas are in compliance. Please see the site plan sheet C-101 submitted that delineates the buffer area with the hatching showing the rain garden and the inverter located outside the buffer area. Comments In addition to the recommended modifications, we have the following comments on the proposed action: • The parcel contains a portion of Unique Natural Area -Groton Swamp (UNA-15). We suggest that the Town request that the applicant assess the potential impacts this proposal will have on the UNA. The UNA — Groton Swamp area appears to be outside of the project area. We will continue to look for better mapping of the area to confirm. The storm water controls provided on the plan set and the culvert installation at the stream will not alter the existing hydrology of the area and will keep the integrity of the swamp as is existing today. • We suggest that the Town request that the developer work with the electric utility company to outline the interconnection plan for this project so that the Town has the opportunity to review and comment on the construction of the interconnection prior to it becoming final. NYSEG does not engineer the final plans for connection until there is approval of the project receivedfrom the Town. The connection location has been defined on the site plan. The Point of Interconnection is also defined and should not change, unless there is a better connection available that NYSEG deems more suitable. • This project is located partially in The Nature Conservancy's Resilient and Connected Network that identifies areas that are considered important for species movement, which is emerging as a critical consideration as our climate continues to change and species need to adapt. We suggest that the Town encourage the applicant to contact The Nature Conservancy to discuss the project, review habitat connectivity areas, and discuss strategies, such as permeable fencing design, to allow for wildlife movement through the site. Katelyn Kaim, Senior Environmental Planner from PW Grosser Consulting sent an email requesting an appropriate contact to discuss the projects on August 16`h 2024. An automatic response was received on August 2e, 2024 stating someone would be in contact with us regarding the project. We have not received a response as of todays date. Mrs. Kaim sent another email August 26`h, 2024 requesting a contact. Once a response has been received, we will forward to the Town. • We suggest that the Town request that the developer follow the recommendations of the `° YSDAM (3, ulden'ines for °Soda= L?S:uzv i"3 C t onslt uci. 1 _ -ation c,,r Agric €llt; t: Lane n� (209 ) in their proposal as they consider the impacts to the farmland as well as the impacts of the proposed site grading. The project location is within Tompkins County Agricultural District 41. A NYSDAM application has been prepared to be submitted for your review by NYSERDA and the Division of Agriculture and Markets. Once the review is complete the Town will be made aware of any comments or conditions related to the projects and when the NOI is filed prior to construction. We suggest that the Town request that the applicant include mature plantings and native pollinator species in the Operations and Maintenance Section of their proposal. The project site consists mostly of fields. There will be clearing in a portion of the existing wooded area. The projects site that will be cleared will be planted with native vegetation, (low growing grasses). These grasses will grow amongst the solar panels. Screening will be installed along the east side of the solarfield. The screening will be a single row of Norway Spruce trees or equivalent. The Operation and Maintenance Plan submitted to the Town addresses the requirement to maintain the vegetation for the life of the project. Thank you for your consideration and review of these responses to the Tompkins County recommendations and comments. Should you have any additional questions prior to the September 1 Qih meeting please feel free to contact me Respectfully submitted, Mollie Messenger cc: Rich Winter, Chief Executive Officer