HomeMy WebLinkAboutGroton South Main I & II Solar - Updated Plan Review TCB 9-6-2025
TIMOTHY C. BUHL, P.E.
187 Burtis Point Road
Auburn, NY 13021
(607) 423-1919
September 6, 2025
Town of Groton
108 E Cortland Street
Groton, NY 13073
RE: South Main Street, Groton Solar Farm – North and South Site Plan Revisions
Tax Map Numbers 26-1-25.22 and 31-1-12.1 on the North (NY Groton I, LLC) and
South (NY Groton II, LLC)
Attn: Don Scheffler, Town Supervisor; Town Board Members; Robin Cargian, Town Clerk;
Rick Fritz, Town CEO; & Fran Cosullo, Town Attorney
This letter is to confirm my recent review of the updated Site Plans, SWPPP Reports, Noise
Studies, and related documents pertaining to the above referenced project, prepared and submitted
on or about July 22, 2025. I also spoke with the applicant and his engineer on Friday to discuss
the upgrades and the plans submitted.
As you know, the updated proposal for each of the parcels is to change from the previously
approved fixed racking system back to and upgraded version the original tracker racking system,
along with several other site upgrades and improvements. For example, the overall height and
number of panels has been significantly reduced, the amount of regrading on site slopes (cuts and
fills) has been lessened, and the equipment noise levels reaching nearby properties has been
lessened by the relocation of the project inverters and by using smaller equipment modules.
While all of these changes are positive, I still have some concerns with the project going forward.
First, The NYSDEC Stormwater SPDES Permit for the project shown in the SWPPP expired in
January of 2025; the e-NOI (Notice of Intent) for the new 2025 NYS permit shown is incomplete
– no specific data for the site was entered. It is not known if the applicant filed an extension request
to continue the project under the old 2020 permit rules, or if they have filed a new NOI for the
2025 permit. An approved copy of this extension request should be provided by the applicant, or
a copy of the new 2025 permit should be provided to the Town. Either way, during the
construction & development of the site, the applicant should adhere to the new NYSDEC Guidance
Document recently issued by the NYSDEC, a copy of which is attached. Not only does the
guidance cover the major concerns of solar project development, but there are recommendations
for many smaller site-specific problems such as localized washouts, construction sediment control,
inadvertent discharges, and decompaction during construction.
There are specific concerns about the stream crossing with the open bottom box culvert on the
south site (Groton II) – in addition to the major regrading in the stream ravine, concrete footings
next to the stream bed will have to be installed before placement of the culvert and wing walls
(which should not be optional). A work plan with thorough erosion control measures for this area
should be submitted prior to the start of the work, which should be reviewed and approved by the
Town’s CEO. The same holds true for the proposed site entrance at South Main Street for the
North site (Groton I), which is at the base of a steep hill and the upper portion is in a steep hillside
cut. I believe a special temporary stilling basin/sediment trap should be installed prior to the road
intersection. Concerning a more significant issue, the X-section grades shown for the north site
show grades in the 8-9%, which could trigger a closer review of the runoff conditions and may
require more permanent runoff practices being necessary due to the new NYSDEC guidance. The
same may hold true or Groton II, but is difficult to tell, as no grading cross sections have been
provided. Based on the topography here, slopes in the array area may be even steeper than those
in Groton I)
The bottom line is that I feel the applicant has submitted a much better overall project, but there
are a few remaining items that should be addressed; the NYSDEC permit status, final slopes on
both sites as they relate to the NYSDEC Guidance, and the micro-area treatments described above
(stream crossing/driveway entrance at South Street.) This could be done either with an approval
to re-submit the additional plan changes prior to issuance of the building permit, or a reschedule
and approval after the information/clarifications are submitted to the Town. The Town Attorney
may be the best help to you as to how to proceed.
Very truly yours,
TIMOTHY C. BUHL, P.E.
Timothy C. Buhl
Cc: Fran Casullo, Robin Cargian, Rick Fritz