When planning a ground mounted PV system (vs. a roof mount), there are several environmental considerations to evaluate prior to entering a PPA. The overall size of system, landfill or Brownfield location options, wetland areas, and endangered species are all issues to assess when evaluating sites for PV arrays. While the solar developer’s engineering team typically has the resources to complete all required environmental permitting, a savvy property owner or municipal committee will want to know “fatal flaws” and/or anticipated permit requirements in advance of committing to the project. Understanding potential environmental challenges ahead of time allows for realistic cost and project timeline planning. The site owner should also confirm that the solar developer has a qualified and experienced permitting team on board.
Site Characteristics
As part of a fatal flaws or feasibility analysis, site characteristics should always be considered. Site characteristics that should always be included in any analysis include ground slope, topographic features, access to the site, path to potential interconnection point(s), existing vegetation, erosion potential and soil type. Analysis of environmental features along possible interconnection routes should be considered in addition to the array site itself.
Local Requirements
Do some research on property boundaries and easements, available mapping (wetlands, topographic, utility, endangered species), local by-laws (zoning, planning, and conservation). Information obtained from the local conservation office, Town or City Engineer, or zoning office can be included in an RFP or made available for review prior to bid.
State Requirements
A state environmental review (ie. Massachusetts Environmental Policy Act http://www.env.state.ma.us/mepa/ (MEPA)) may be required if the project meets a State’s “threshold” for review. State thresholds should be checked to see if any project characteristics exceed the threshold. If they do, a regulatory review may be required and possibly add 30-60 days minimum to the project timeline. Most states maintain a free online database of environmental resources/protected areas, historic resources and hazardous waste or Brownfields sites.
For example, if the site is a landfill, the landfill must be closed, capped and in full compliance with State regulations. A Post-Closure landfill use permit is likely required. Talk to your state Department of Environmental Protection (ie. NHDES, MADEP). Permits for post-closure landfill use can take 2-6 months.
Federal Requirements
A federal environmental review (National Environmental Policy Act http://www.epa.gov/oecaerth/basics/nepa.html (NEPA)) may be required if federal money is involved or if the project meets a federal threshold for review. As with state regulations, if any project characteristics exceed federal thresholds, they may trigger a regulatory review that will add to the project timeline.
Any site with over one acre of total land disturbance requires a National Pollutant Discharge Elimination System (NPDES) permit for erosion andstormwater pollution prevention. Easier than it sounds, this is a simple document that can be filed electronically and does not delay a project. Best practices, such as using silt fences or haybales around any open excavated areas, should be utilized.
Drafting a Request For Proposals (RFP)
Give the solar developer as much relevant information from your research as possible in the RFP, or provide a list of available resources to examine. The more information the bidder has about environmental considerations, the more competitive and accurate the bid outcome can be.
Summary
An owner’s agent can assist in identifying potential feasibility issues and evaluate proposals for a PV system. Factors to evaluate for a ground mounted system are different from a roof mounted system and include environmental considerations. Proper planning and knowing what to expect help make the bid and project phases go smoothly.
Guest Blogger: Maureen Sakakeeny, P.E., LEED AP
Principal
SAK Environmental
About SAK Environmental LLC:
SAK Environmental specializes in environmental permitting and compliance, sustainable development, and Brownfields assessment and remediation, and environmental support during construction, throughout Massachusetts and Southern New Hampshire. Our goal is to deliver technically sound advice and practical solutions enabling our clients to carry out their initiatives with confidence and peace of mind. We strive to promote sustainable development and environmentally compatible business practices to allow business, industry and community to thrive. SAK Environmental is a privately owned environmental consulting business founded in 2003 and based in North Andover, Massachusetts. For more information about SAK Environmental LLC, please visit www.sakenvironmental.com.