7.b 1f Geronimo Argo Navis Project Narrative; BSM 58544941-v3-c
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Argo Navis Community Solar Gardens, LLC
Variance Application
Evidence Responses to Practical Difficulty Criteria
1) The applicant proposes to use the property in a reasonable manner not permitted by the
development code.
Argo Navis Community Solar Gardens, LLC (ANCSG) proposes to use the property to develop a
solar energy project consisting of up to three solar gardens. The site is located on a reclaimed
and yet to be reclaimed gravel mine currently operated by Tiller Corp. The parcel of land
ANCSG is proposing to use for its solar project is currently zoned as Agricultural – Core by the
City of Scandia’s zoning code. Solar projects like those proposed by ANCSG are a
Conditionally Permitted use under Scandia Zoning Code Chapter 2, Section 4. This same section
of the zoning code prohibits development “[w]ithin six hundred (600) feet of areas designated or
formally protected from development by Federal, State or County agencies as wildlife habitat,
wildlife management areas, or designated as National Wild and Scenic land or corridor.”
ANCSG has filed this request for a variance to obtain relief from this requirement.
ANCSG began working with the landowner in mid-2015 on the development of the proposed
solar project. During that time ANCSG made financial and development commitments to the
interconnecting utility (Northern State Power, Inc. d/b/a Xcel Energy) requiring it to operate
under Xcel Energy Solar*Rewards Community tariff. Concurrently with ANCSG making such
commitments to the project, Tiller Corp was implementing their reclamation plan as required by
their agreement with the City. As part of Tiller Corp.’s reclamation of the northwestern portion
of the proposed property, Tiller Corp. installed grades on the site on which the installation of a
solar project is not feasible. Accordingly, ANCSG has had to move the location of its proposed
solar project on the site so as to avoid these grade issues.
ANCSG requests a variance of the 600’ setback reducing it to 150 foot setback to the scenic river
easements and 10 foot setback to the St. Croix River District as described in Section 4 of the
Scandia Ordinance in order to allow the installation of the solar gardens at the site indicated on
the plans submitted herewith. Locating the project at the proposed location is reasonable
because it avoids the challenging grades on the site, aligns the project with the reclamation of the
mine, allows for use of the natural screening in the area, and is fully within an area of existing
disturbance on the site. Importantly, the setback variance will best mitigate any visual impacts
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that would otherwise occur along the scenic byway by creating a larger setback from the byway
and by using existing hills and berms on the site to create a visual break. The variance will also
provide for more room to plant vegetation should the City determine that additional plantings
would be important for visual screening along the byway. In short, because of the heavy woods
existing along the north, east, and south sides of the project that completely screen the project in
such locations, installing the solar gardens as far east on the site as possible is the most
reasonable way of locating such gardens in a manner that has the least amount of visual impact
to the public and neighboring property owners.
Notably, the existing reclaimed portion of the site contains some grades of between 12% and
25%. Because racking for solar panels requires a 5% grade or less, any location of solar panels
in these areas would require substantial retaining walls and other site modifications. However,
removal and modification of these grades would impact the hydrologic and visual character of
the area. The shade from the grades and associated walls would result in shading such that it
would prevent the solar facility from generating a majority of the time, nullifying an otherwise
appropriate use in that portion of the parcel.
2) The plight of the landowner is due to circumstances unique to the property not created by
the landowner.
ANCSG’s parcel contains an existing and reclaimed gravel mine the presence of which impacts
the project as described in item 1. The current mining operations are ongoing and need to be
accommodated with the development plan so as to avoid conflict between the two uses. The
current topography of the portion of the property that exists outside the setback would require a
significant amount of re-grading and engineering to make construction of solar panels possible
and would result in a situation that nullifies the usefulness of the site for solar generation. The
gravel mining and the reclamation plan were developed by the mining company and
implemented as part of their reclamation agreement with the City. The reclamation plans were
developed without ANCSG in mind and are primarily what is preventing the installation on the
reclaimed parcel. The operating mine is preventing installation in other portions of the parcel.
3) The variance, if granted, will not alter the essential character of the locality.
The current use of the parcel is mining, and the surrounding area is primarily agricultural and
rural residential in nature. The facility will be primarily natural in visual appearance from the
roadway because the use of native plantings and the substantial setback of approximately 300
feet from the road centerline along the west site of the parcel will minimize any visual impact.
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The solar facility will reduce the intensity of the use from the current mining activity and will
also be a lower intensity use than many other alternatives for the site, including housing
development and farming. The topography provides a visual screen from St Croix Trail and
existing homes. Due to the vegetation along the Riverway, it will not be highly visible from the
other side of the river. No significant tree removal is planned for the installation of the facility;
indeed, trees will be added to the site in connection with the project. Pollinator friendly native
vegetation will provide a more natural appearance around the Lower St. Croix National Scenic
Riverway. The solar panels are dark in color and the racking will be low lying with a maximum
height of 15 feet, and consequently would not be a dominant feature on the landscape. The
ultimate project will continue to support the natural character of the surrounding area while still
providing an economic use of the land.
4) Economic conditions alone shall not constitute practical difficulties.
The practical difficulty is related to the grade of developable land, the environmental concerns
that arise from the existing grade of the reclaimed mine, and the existing mine operations.
Further, the proposed location of the solar gardens is simply the best and most logical place to
install solar panels on this site.
5) That the proposed variance will not impair an adequate supply of light and air to
adjacent property, or substantially increase the congestion of the public streets, or
increase the danger of fire, or endanger the public safety, or substantially diminish or
impair property values within the neighborhood.
Solar panels are low profile, typically with a maximum height of 15 feet. The spacing and height
of the solar array would not impair the supply of light and air to the adjacent properties. The
installation of vegetation would not cast significant shadows or prevent airflow on adjacent
properties any more so than the existing wooded lots in the area already do. Traffic during
construction of the facility is anticipated to be approximately 25-35 trucks daily, ramping down
significantly after commissioning. During normal operations of the solar farm, maintenance staff
visits will occur infrequently with monthly visits being the average frequency. The associated
traffic in both construction and operations would not create congestion. Community solar
gardens are required by the City of Scandia ordinance to be compliant with any applicable local,
state and federal regulatory standards, including electric and building codes. Compliance with
these codes will insure the proper installation methods and mitigate dangers to fire and public
safety. ANCSG does not anticipate that the change in use from a mining operation to a solar
facility will alter property values. To the contrary, ANCSG anticipates that its use of the
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property will be more desirable than the other potential alternative uses for the site (i.e. housing,
farming, etc.), which would preserve, if not enhance, property values in the vicinity of the
project.
6) That the requested variance is the minimum action required to eliminate the practical
difficulty.
ANCSG has analyzed a number of design scenarios for this project. Through this design
process, ANCSG has determined that the proposed design will have the least environmental
impact of any project that may be constructed on the site that still meets market conditions, the
requirements of the tariffs it will operate under, and that still complies with the spirit of
Scandia’s Development Code. Because of the existing area of disturbance on the site and other
site constraints, ANCSG does not believe that there is a reasonable way to reduce the extent of
the requested variance.
7) Practical difficulties include, but are not limited to, inadequate access to sunlight for
solar energy systems.
ANCSG anticipates it will have adequate access to sunlight in the proposed location on the
enclosed site plan. The plan shows the required design setback to avoid shading from existing
vegetation. If, however, ANCSG was unable to obtain the requested variance and required to
construct the project in the reclaimed area of the site (assuming such construction was even
possible), the extreme grades in that area, as well as the retaining walls that would be required
for the solar gardens, would create shading such that the project would not be able to operate
normally.
Supplementary Responses to Scandia’s Review Criteria
In addition to ANCSG feedback regarding the practical difficulty criteria, the Project is also
supplying replies to the other Review Criteria set forth in Section 6.0 of the City of Sca ndia
Development Code.
One of the review criteria components in the City of Scandia Code refers to the variance terms’
adherence to the Comprehensive Plan. Below are responses to the goals laid out in the Scandia’s
Comprehensive Plan.
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Natural Resources Goal 2:
Preserve, protect, and enhance surface water quality in Scandia.
Policy 2.4: Design new development to minimize impacts on surface water,
groundwater, floodplains, steep slopes, wetlands, and other
environmentally sensitive areas.
Policy 2.5: Encourage landowners in already developed areas to improve stormwater
drainage to reduce the volume of runoff and polluted runoff
Natural Resources Goal 6: Protect and preserve native, endangered, threatened and unique
plants and animals.
Natural Resources Goal 7: Eliminate, reduce or mitigate the negative effects of invasive species
on natural areas
Policy 7.1 Encourage public and private development to landscape with noninvasive,
native species.
Response: One of the primary benefits to installation of ANCSG’s proposed project
will be to water quality. Natural Resources Goal 2 and Policies 2.4 and 2.5 support this proposal
in that ANCSG, by revegetating the site into a meadow like condition, will minimize impacts on
surface water and improve stormwater drainage on an already developed area. Further, in
accordance with Natural Resources Goals 6 and 7, the Project will also allow for the growth of
native grasses and will provide habitat for grassland birds, reptiles, mammals and other insects.
Land Use Goal 13: Allow for the safe and orderly extraction of aggregate resources now and in
the future while protecting sensitive resources on or near those properties and providing for
transitions to other uses when resource extraction is complete. Mining is limited to existing
locations.
Response: Extraction of aggregate resources on the subject property is continuing and
will continue while the project is under development. The site design ANCSG is proposing will
allow it to develop its solar project in an area of the subject property where mining is complete
while at the same time allowing Tiller Corp. to complete the extraction of resources from the
property. Additionally, after reclamation ANCSG’s site will have rejuvenated soils because of
the nitrogen and mineral replacing nature of the plantings allowing it to be restored to high
production agricultural uses. This coincides with Land Use Goal 13 as providing for transitions
to other land uses when resource extraction is complete.
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Energy Use and Systems Goal 1:
The City encourages the use of renewable, local and diverse forms of energy in order to increase
use of local resources, mitigate the local risk from fossil fuel scarcity and price increases, and
help meet Minnesota’s climate protection goals.
Response: The construction of a Community Solar Garden in the City of Scandia will
help mitigate the local risk from fossil fuel scarcity and help meet Minnesota’s climate protection
goals, as referenced in Energy Use and Systems Goal 1. Moreover, the addition of this solar
project in the City will provide a substantial source of local, renewable energy, which further
supports Energy Use and Systems Goal 1.
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