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4.c 6 Karen Schik SolarFarm letter to PC 1 March 19, 2016 Planning Commission City of Scandia 14717 209th St N Scandia, MN 55073 RE: CUP Application of Ameresco/Green Mark for Oldfield Avenue Solar Garden Dear Planning Commissioners: While I am a strong supporter of alternative energy, I would like to voice my firm opposition to Ameresco/Green Mark proposal for a solar installation at Oldfield Ave, because it is simply an inappropriate site for the following reasons: Property Values The conclusion on p. 10 of the memorandum from TKDA that “the proposed use will not have a negative impact on adjacent property values or scenic views” is not supported by any data. There is simply no basis for making that statement. A more factual conclusion would be that the impacts on property values are not known. Concern among nearby property owners for impacts to their property value is extremely important and should not be minimized, disregarded or treated lightly. Common sense would indicate that there would be an impact – most people would strongly prefer looking at a field than an industrial installation. It is not adequate, therefore, for the planning commission to simply say that information is difficult to obtain nor is it appropriate for the city planner to make a claim that there will be no impact. It is the responsibility of the city to protect the interests of the residents - that’s what our taxes pay city staff to do - and to fully vet this question and find as much accurate information as possible. Screening On page 12 of the memorandum, no. 11 states “The revised project plans shall include a landscape plan that provides for screening of approximately 50% of the view of the site from Oldfield Road.” This assignment of “50% screening” is arbitrary and has no basis in the ordinance, which states that the installation shall be screened “to the extent possible.” There is no mention of any percentage amount in the ordinance. “To the extent possible” implies that the maximum amount of screening will be provided. Given the slope and elevation of this site, proper screening would require installing corridors of trees and shrubs at intervals up the slope to fully obstruct the visibility of the panels from Oldfield Ave, 237th St, and from any adjacent properties. That screening should be as complete as possible, year-round. Since we have no leafy foliage for about 7 months of the year, the use of red cedar trees and other dense evergreens should be a significant component to provide winter screening. As stated in the memo, there should be a mix of numerous native species so that it appears natural, in keeping with the rural character and the SCENIC VIEWS criteria of the city. Furthermore, trees and shrubs grow slowly in 2 Minnesota’s climate. The city should require that mature plants should be used so that screening provides FULL COVERAGE in the FIRST year of the installation. Erosion control Even if the site was fully screened, I still have significant concerns about the highly erodible soils on the site. According to the USDA Soil Conservation Service, all of the soil types at the site are fine sands or loamy fine sands (see Map 1 in the attachments). Two of the soil types in particular (Zimmerman and DeMontreville), have slopes of 6 to 25 percent and are described as having SEVERE erosion potential (see description in attachment). These soil types cover nearly half the site. With TWENTY acres of new impervious surface being added, there is cause for concern. Anyone who lives in the neighborhood will tell you how badly the site eroded the one year it was converted from hayfield to cropland. There were several blow-out spots where deep gullies formed and sediment flowed across the road. And that was with vegetation cover (crops). The applicant states that erosion will be controlled by silt fence, fiber logs, erosion blankets and temporary sediment basins and that they will “establish temporary and permanent vegetation as quickly as possible” and that permanent vegetation will consist of prairie grasses (P. 8 of application). As an ecologist, I work to restore native prairie vegetation so I am quite familiar with the process of establishing prairie. While native prairie plants, with their deep and fibrous root systems, are by far the most optimal vegetative cover type for these soils, they do NOT establish quickly. It generally takes at least two growing seasons to get good coverage, and likely longer on droughty soils. Furthermore, native prairie plants thrive on full SUN. They do not grow well or vigorously in shade. I am very skeptical that a dense cover of native prairie vegetation can be established under the panels, which are specifically designed to capture as much sunlight as possible. I understand that the applicant plans to install some sort of HYBRID prairie grass, which may have better shade tolerance than most of the natives. Given the highly erodible soils described above, it is essential to know for certain, before this installation is approved, that the vegetation will be well established. It is not acceptable to find out at the next big storm that the vegetation was not adequate. Furthermore, Scandia leaders should be aware that hybrid prairie species do NOT provide the same value to pollinators as native prairie species. Saying that “prairie” will be established under the panels to benefit pollinators is a good marketing tool but may be misleading unless they actually plant the native species that benefit pollinators. And it does not seem feasible that native prairie species would survive under the panels. I suggest the applicant be required to provide evidence from similar sites, with similar soil types and slopes, where the “prairie” vegetation that they are suggesting has actually grown well underneath solar panels and provided solid cover. Furthermore, I request that the following conditions are required of the applicant. These are not part of the existing ordinance, but would be in keeping with the stated intent of the applicants to provide pollinator habitat, and would also be in keeping 3 with other Scandia ordinances and the recently adopted Scandia Pollinator Resolution. • No fencing • No lighting • The areas that are outside of the solar panels, and not occupied by trees and shrubs for screening, should be seeded with NATIVE MINNESOTA prairie vegetation – not cultivars or hybrids. Studies have shown that cultivars/hybrids have significantly less value to native pollinators and other wildlife. They have been bred to better suit human needs, but the alterations have negative results for pollinators, such as less nectar, less nutrients, less pollen etc. • Species should be of NATIVE MINNESOTA ECOTYPE to ensure that they are well-adapted to the climate here, and not originating from other parts of the country. • The mix should include native wildflowers (at least 25%), not just grasses. There should be at least 25 flowering species, with three species blooming at any time from May to October to benefit pollinators. Thank you very much for you consideration of these requests and comments. Karen Schik 13860 236th St N Scandia, MN 55073 4 ATTACHMENTS 5 Exerpt from the Soil Conservation Service (1980) on the two most erodible soil types.