HomeMy WebLinkAbout1.00 General Application Materials_Part 4AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 29
Solar Energy facilities are low-profile, unobstructive developments with very little impact to the
surrounding lands or uses. While visible from within the property lines, neighboring parcels lack
significant viewshed of the Project given its location on a low mesa above surrounding valley property.
Further, there is little in the profile or nature of the solar array once installed that would result in
negative impacts to adjacent property, provided its quiet and emission-free operation with limited
maintenance visits by technicians. In the case of this project, the solar facility will be sited on vacant
land with plenty of distance to either nearby rights-of-way or residences. At its closest point, the solar
array will be approximately 3,400 ft, or well over a half mile, to the edge of the nearest residences to the
southeast that are not owned by Eagle Springs Organic LLC, or Ken Sack directly, the Project
landowner host.
At a distance of more than two miles to more populated parts of Silt and at an elevation nearly 250-300’
higher than the valley floor and town limits, visual impact from the installation is deemed to be
negligible. On the property, AES is proposing to install an 8ft tall, wildlife-friendly game fence around
the facility as detailed in the Site Plan in Section B2 on page PV-C.09.01. This will serve to soften the
visual impact of the installation and will present a less industrial aesthetic than standard chain link
fencing while meeting electrical code and operational safety requirements. The proposed fencing is of
the specification employed by Colorado Department of Transportation along public right-of-way in the
area, and as such will not look out of place.
Given the lack of adjacent property owners with views to the Project coupled with the arid natural
setting, this application is not proposing any additional landscaping measures beyond those
recommended in the vegetation management and reclamation plan detailed in the following section.
LANDSCAPING PLAN
Section B3
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 30
Please see the following pages for the Vegetation Management and Reclamation Plan prepared by TRC
for Eagle Springs Organic Solar.
VEGETATION MANAGEMENT AND RECLAMATION PLAN
Section B4
Vegetation
Management and
Reclamation Plan
January 30, 2023
Revised March 10, 2023
Eagle Springs Organic Solar
Project
Prepared for:
ACE DevCo NC, LLC
Prepared by:
TRC
Fort Collins, CO
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan i
Table of Contents
Acronyms and Abbreviations .......................................................................................................... iii
1.0 INTRODUCTION ............................................................................................................... 1
1.1 Purpose and Need .............................................................................................................. 1
1.2 Location ............................................................................................................................... 1
1.3 Existing Conditions.............................................................................................................. 1
1.3.1 Topography and Land Use .................................................................................... 1
1.3.2 Vegetation Communities ........................................................................................ 3
1.3.3 Noxious weeds ....................................................................................................... 3
2.0 PROPOSED CONSTRUCTION ACTIVITIES ................................................................... 1
2.1 Project Responsibilities ....................................................................................................... 3
3.0 WEED MANAGEMENT .................................................................................................... 4
3.1 Regulatory Background ...................................................................................................... 4
3.2 Integrated Weed Management ........................................................................................... 4
3.3 Treatment Methods ............................................................................................................. 6
3.3.1 Cultural Management ............................................................................................. 6
3.3.2 Mechanical Control ................................................................................................ 6
3.3.3 Chemical Control.................................................................................................... 6
4.0 SOIL MANAGEMENT ....................................................................................................... 8
5.0 RECLAMATION AND REVEGETATION.......................................................................... 8
5.1 Reclamation Objectives ...................................................................................................... 8
5.2 Reclamation Methods ......................................................................................................... 9
6.0 MONITORING AND REPORTING .................................................................................. 11
6.1 Noxious Weeds ................................................................................................................. 11
6.2 Revegetation ..................................................................................................................... 11
7.0 REPORTING ................................................................................................................... 11
9.0 REFERENCES ................................................................................................................ 12
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan ii
Tables
Table 1-1. Project Parcels ............................................................................................................................. 1
Table 1-2. Weed Species Detected in the Project Area ............................................................................... 1
Table 2-2. Responsible Parties and Their Roles and Responsibilities to be Compliant with the VMP ........ 3
Table 3-1 Recommended Herbicide Treatments for Noxious Weeds in the Project Area............................ 7
Table 5-1. Seed Mix and Application Rates (Upland Mix) ............................................................................ 9
Figures
Figure 1-1 Project Location ........................................................................................................................... 2
Figure 1-2. Vegetation Communities and Land Use in the Project Area ...................................................... 4
Figure 1-3. Noxious Weeds in the Project Area ............................................................................................ 2
Appendices
Appendix A. Site Plan
Appendix B. Colorado and Garfield County Noxious Weed
Lists
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan iii
Acronyms and Abbreviations
Notation Definition
ACE ACE DevCo NC, LLC
C.R.S. Colorado Revised Statutes
CDA Colorado Department of Agriculture
DC Direct Current
MW Megawatt(s)
Project Eagle Springs Organic Solar Project
Project Area Location of the Eagle Springs Organic Solar Project
VMP Vegetation Management Plan
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 1
1.0 Introduction
ACE DevCo NC, LLC (“ACE”, “Client”) proposes to construct and operate Eagle Springs
Organic Solar Project (Project) in Garfield County, Colorado. The proposed Project would
consist of a 16 MW Direct Current / 10 Megawatt (MW) Alternating Current / 20 Megawatt hour
photovoltaic energy generation facility on approximately 80 acres (Project Area) of which
approximately 53.9 acres will be prepared for clearing and grubbing within Project fence limits.
An additional 24.5 acres will be impacted by road improvements.
1.1 Purpose and Need
A Garfield County grading permit is required for all projects involving excavation, grading, or
earthwork construction. As part of the grading permit, Garfield County requires a revegetation
and reclamation plan to be submitted. The Vegetation Management and Reclamation Plan
(VMP) requires 4 sections: Soil Handling, Weed Management Plan, Site Revegetation and
Restoration, and Cost Estimate. This VMP comprises of three main sections: (1) weed
management; (2) reclamation and revegetation measures; and (3) monitoring, reporting, and
remedial action.
The purpose of this Vegetation Management and Reclamation Plan is to prevent and minimize
the spread of noxious weed species, minimize wind and water erosion, limit the spread of
fugitive dust, and promote native plant communities for both wildlife and visual aesthetics.
1.2 Location
The Project is located about 0.25 mile south of Interstate 70, adjacent to 5454 Co Rd 346, Silt,
CO 81652 (Township 6 South, Range 92 West, Section 18) (Figure 1-1). The Project is located
on 3 private property parcels owned by Eagle Springs Organic, LLC. The assessor parcel
numbers and acres of each parcel are listed in Table 1-1.
Table 1-1. Project Parcels
Assessor Parcel Number Acres
217917300732 230.24
217917200710 35.11
217918100691 35.15
1.3 Existing Conditions
1.3.1 Topography and Land Use
The Project Area is located on top of a hill located on the south side of the Colorado River
Valley with an elevation range of 5,560 ft to 5,620 ft above mean sea level (USGS 1983). An
existing private access road off of County Road 315 will be used to access the Project Area.
The private access road has a greater than 10 percent slope. The topography of the majority of
6S 93W6S 92WEAGLE SPRINGS PROJECT AREA
EAGLE SPRINGS MAIN SOLAR AREA
EAGLE SPRINGS ADDITIONAL SOLAR AREA
DATE:
APPROVED BY:
CHECKED BY:
DRAWN BY:PROJ. NO.:
FILE:
TITLE:
PROJECT:
AES_CLEAN_ENERGY RFBCOORDINATE SYSTEM: NAD 1983 STATEPLANE COLORADO CENTRAL FIPS 0502 FEET; MAP ROTATION: 0 -- SAVED BY: RBLAKE ON 1/18/2023, 16:09:37 PM; FILE PATH: T:\1-PROJECTS\AES\495288_AES_CLEAN_ENERGY_SILT_CO\2-APRX\AES_CLEAN_ENERGY RFB.APRX; LAYOUT NAME: AES EAGLE SPRINGS_FIG_1_PROJECT_OVERVIEW VEG REPORTJANUARY 2023
123 N. COLLEGE AVE.SUITE 370FORT COLLINS, CO 80524PHONE: 970.484.3263
F
1:24,000 1" = 2,000'
0 1,000 2,000
FEET
BASE MAP: USGS 7.5 MINUTE TOPOGRAPHIC QUADRANGLE SERIES
SILT (1983) , COLORADO, DATA SOURCES: TRC
D. DUFRESNE
E. BERGQUIST
R. BLAKE
FIGURE 1-1
495288
PROJECT OVERVIEW
ACE DEVCO NC, LLC
EAGLE SPRINGS ORGANIC SOLAR PROJECT
GARFIELD COUNTY, COLORADO
COLORADO
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 3
the Project Area on the top of the hill is characterized as relatively flat with very slight to steeper
gradients in sections.
Land use in the Project Area is primarily pasture and farmland. Land use surrounding the
Project Area is primarily for commercial and agricultural production. Rural residences, solar, oil
and gas development, and undeveloped natural areas are located in the immediate vicinity of
the Project Area. Interstate 70 is located to the north of the Project Area. The Garfield County
Airport is less than 0.5-mile to the west (Google Earth Pro 1985-2020). Two oil and gas well
sites containing several wells are within the Project Area. An electrical transmission line runs
north of the Project Area near Interstate 70. A natural gas pipeline and electric transmission line
transect a small portion of the southernmost area of the Project transecting the proposed road
(COGCC 2022; Rextag 2022).
1.3.2 Vegetation Communities
There are three vegetation communities (Shrub steppe, hay/fallow fields, and invaded
grassland) and one land use (Developed) in the Project Area (Figure 1-2). Shrub steppe is
found along the access road on the steeper slopes. Dominant species include Indian ricegrass
(Achnatherum hymenoides), bluebunch wheatgrass (Pseudoroegneria spicata), greasewood
(Sarcobatus vermiculatus), sagebrush (Artmesia tridentata), and Russian knapweed
(Rhaponticum repens).
The majority of the Project Area is hay/fallow fields. Most of the Project Area has been plowed
at some point in time. At the time of the survey, most of the fields were mowed. Species present
in and along the edges of the fields included oats (Avena sativa), tumblemustard (Sisymbrium
altissimum), flixweed (Descurainia sophia), field bindweed (Convolvulus arvensis), crested
wheatgrass (Agropyron cristatum), and kochia (Bassia scoparia).
Along the roads in the Project Area around is invaded grassland dominated by cheat grass
(Bromus tectorum), field bindweed, bluebunch wheatgrass, Russian knapweed, and yellow
sweet clover (Melilotus officinalis). Musk thistle (Carduus nutans) is present in large patches
along the road and in some of the hay/fallow fields. Douglas rabbitbrush (Chrysothamnus
viscidiflorus) is scattered along the road. The developed open space is dispersed throughout the
Project Area and consists of farming structures, a residential house, and oil wells.
There are several irrigation ditches in the Project Area. Most are overgrown with upland
species. There is a fringing wetland located on the Multa Trina Ditch which is located on the
east edge of the access road survey area. The fringing wetland was composed of canary reed
grass (Phalaris arundinacea). North and outside the Project Area on the same irrigation ditch, is
located a patch of showy milkweed (Asclepias speciosa).
1.3.3 Noxious weeds
Surveys were conducted within the Project Area boundary, August 9, 2022. Two Colorado B
listed as well as county-listed noxious weed species were documented in the Project Area.
List A noxious weed species were not observed within or near the Project Area. Russian
knapweed is found throughout the northwestern fields and along the roadways. The musk thistle
is located on the road right-of-way on the northeast corner of the Project. Colorado List C
EAGLE SPRINGS STUDY AREA
EAGLE SPRINGS MAIN SOLAR
AREA
EAGLE SPRINGS ADDITIONAL
SOLAR AREA
DEVELOPED
DITCH
HAY/FALLOW FIELDS
INVADED GRASSLAND
SAGEBRUSH STEPPE
WETLAND
DATE:
APPROVED BY:
CHECKED BY:
DRAWN BY:PROJ. NO.:
FILE:
TITLE:
PROJECT:
AES_CLEAN_ENERGY RFBCOORDINATE SYSTEM: NAD 1983 STATEPLANE COLORADO CENTRAL FIPS 0502 FEET; MAP ROTATION: 0 -- SAVED BY: RBLAKE ON 1/18/2023, 16:09:37 PM; FILE PATH: T:\1-PROJECTS\AES\495288_AES_CLEAN_ENERGY_SILT_CO\2-APRX\AES_CLEAN_ENERGY RFB.APRX; LAYOUT NAME: AES EAGLE SPRINGS_FIG_1-2_VEGETATION COMMUNITIES PRESENT IN THE PROJECT AREAJANUARY 2023
123 N. COLLEGE AVE.SUITE 370FORT COLLINS, CO 80524PHONE: 970.484.3263
F
1:12,000 1" = 1,000'
0 500 1,000
FEET
DATA SOURCES: TRC
D. DUFRESNE
E. BERGQUIST
R. BLAKE
FIGURE 1-2
495288
VEGETATION COMMUNITIES AND
LAND USE IN THE PROJECT AREA
ACE DEVCO NC, LLC
EAGLE SPRINGS ORGANIC SOLAR PROJECT
GARFIELD COUNTY, COLORADO
COLORADO
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 1
noxious weed species were noted in the Project Area but are not included in this Noxious Weed
and Vegetation Management Plan per Garfield County guidelines (see Table 3-1 and
Figure 1-2).
Table 1-2. Weed Species Detected in the Project Area
Common Name Scientific Name
Designated
Colorado Weed
List
Designated on
Garfield County
Noxious Weed
List
Occurrence
Pattern and
Location
Musk Thistle Carduus nutans B Yes
Concentrated
within fields and
along roadsides in
the Project Area
Russian knapweed Acroptilon repens B Yes
Concentrated
along the
entrance
roadsides and the
roadsides in the
Project Area
2.0 Proposed Construction Activities
Construction activities will include ground disturbing activities including grading, panel
installation, access road development, and concrete for inverters and facilities as needed.
Construction activities will be limited to the areas outlined in the site plan (Appendix B) and
permitted in the grading permit. This will include the approved right-of-way, staging areas, and
access roads. Amendments to the permit will be obtained prior to conducting further ground
disturbance.
EAGLE SPRINGS PROJECT AREA
EAGLE SPRINGS MAIN SOLAR AREA
EAGLE SPRINGS ADDITIONAL SOLAR AREA
MUSK THISTLE
RUSSIAN KNAPWEED
DATE:
APPROVED BY:
CHECKED BY:
DRAWN BY:PROJ. NO.:
FILE:
TITLE:
PROJECT:
AES_CLEAN_ENERGY RFBCOORDINATE SYSTEM: NAD 1983 STATEPLANE COLORADO CENTRAL FIPS 0502 FEET; MAP ROTATION: 0 -- SAVED BY: RBLAKE ON 1/18/2023, 16:09:37 PM; FILE PATH: T:\1-PROJECTS\AES\495288_AES_CLEAN_ENERGY_SILT_CO\2-APRX\AES_CLEAN_ENERGY RFB.APRX; LAYOUT NAME: AES EAGLE SPRINGS_FIG_1-3_NOXIOUS WEEDS OBSERVED IN THE PROJECT AREAJANUARY 2023
123 N. COLLEGE AVE.SUITE 370FORT COLLINS, CO 80524PHONE: 970.484.3263
F
1:12,000 1" = 1,000'
0 500 1,000
FEET
DATA SOURCES: TRC
D. DUFRESNE
E. BERGQUIST
R. BLAKE
FIGURE 1-3
495288
NOXIOUS WEEDS IN THE PROJECT AREA
ACE DEVCO NC, LLC
EAGLE SPRINGS ORGANIC SOLAR PROJECT
GARFIELD COUNTY, COLORADO
COLORADO
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 3
2.1 Project Responsibilities
Compliance with this VMP is contingent upon Project planning and execution of the following
roles and responsibilities.
Table 2-1. Responsible Parties and Their Roles and Responsibilities to be Compliant with the VMP
Responsible Party Responsibilities
ACE
Ensure the VMP is approved and implemented
Ensure there is proper coordination with the construction contractor,
reclamation contractor, and Garfield County
Appoint and manage a qualified licensed reclamation contractor
Construction
Contractor
Oversee all construction-related activities
Appoint wash station locations and ensure they are maintained
Ensure all vehicles and machinery are thoroughly inspected and cleaned
throughout the Project
Implement applicable pre-construction and construction phase restoration
activities (e.g., recontouring and stabilization) and impact minimization
measures
Appoint and oversee qualified subcontractors
Reclamation
Contractor
Coordinate with Garfield County to document timing and herbicide
selection for weed treatments
Weed management planning, implementation, and monitoring
Ensure all herbicide treatments are conducted by a licensed herbicide
applicator
Manage herbicide application records
Establish and maintain visual maps of past and present infestations of
noxious weeds
Annual mowing in the growing season
Reseed disturbed areas with native seed mix and monitor for up to four
years
Garfield County
Approve Eagle Springs Organic Solar Project’s VMP and other Project
management plans
Provide technical assistance if needed.
Attend annual meetings (as necessary) with ACE and the reclamation
contractor
Approve seed mixes and herbicides to be used in the Project Area
Inspect the Project Area for compliance and provide regulatory guidance
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 4
3.0 Weed Management
3.1 Regulatory Background
The Colorado state legislature adopted the Colorado Noxious Weed Act in 1992 (Colorado
Revised Statute [C.R.S] 35-5.5). The Colorado Noxious Weed Act defines Noxious Weeds as
“as determined by the commissioner [of agriculture], means those weeds which are especially
troublesome and detrimental and which may cause damage or loss to a considerable portion of
the land or livestock of a community.” The Colorado Department of Agriculture (CDA) is
responsible for the monitoring and control of noxious weeds in the state. The CDA’s maintains
the list of noxious weeds for Colorado (CDA 2022). The CDA categorizes Noxious Weeds as A-,
B-, and C-rated plants according to their current level of infestation and threat, with A-rated
being of highest concern. Additionally, there is a Watch List for noxious weeds. Colorado’s
Noxious Weed List is included as Appendix C. Generally, the categories are defined as follows.
A-Rated: Species in Colorado that are designated for eradication wherever they are
found.
B-Rated: Those species for which management is designed to eradicate, contain, or
suppress in portions of the state designated by the commissioner in order to stop their
continued spread.
C-Rated: Widespread and well-established noxious weed species for which
management is recommended but not required by Colorado. Local governments are left
to decide whether management is required and, if so, if the management strategy will be
eradication, containment, or suppression.
Watch List: Species that pose a potential threat to the agricultural productivity and
environmental values of the lands of the state. The Watch List is non-regulatory and
advisory only.
C.R.S. 35-5.5-105 states that the board of county commissioners of each county of Colorado
adopt a noxious weed management plan. Garfield County, in accordance with the Colorado
Weed Management Act, adopted a Noxious Weed Management Plan. Garfield County follows
the management strategy that the State dictates of the species on the A and B list as well as
declares plants on a county list as noxious weeds if the plant meets one or more statutorily
defined criteria (C.R.S. 35-5.5-104 (16), 35-5.5-107, and 35-5.5-108 (3)) (Garfield Count 2016).
Colorado list C species that are not included on the Garfield County Designated Noxious Weed
List will not be treated as noxious weeds. Garfield County Noxious Weed List is included as
Appendix C.
3.2 Integrated Weed Management
An integrated approach to noxious weed management is critically important to the effective
control of noxious weeds (Dewey et al. 2006, Garfield County 2016). Integrated Weed
Management is the implementation of multiple weed control measures into a focused weed
management approach and the methods included are education, preventive measures, good
stewardship, and biological, cultural, herbicide, and mechanical management (Garfield County
2016). Factors to be considered when identifying appropriate management methods include soil
type, soil stability, grade, surrounding vegetation, land use, and severity of infestation.
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 5
ACE will use an integrated noxious weed management strategy, using a combination of cultural,
mechanical, and chemical controls throughout all phases of Project implementation, as
applicable. Focus will be preventing the spread of noxious weeds as this is the most effective
measure in controlling weed infestations (Dewey et al. 2006). Appropriate species- and site-
specific treatments will take into account recommendations outlined in the Garfield County
Weed Management Plan, and provisions outlined in the landowner agreement. In addition, the
Garfield County Vegetation Manager will be consulted for any additional site-specific
recommendations. Additionally, ACE will consider the impacts of integrated weed treatments on
sensitive resources, such as special-status species and aquatic features.
The following measures will be implemented during construction and operation to minimize the
spread and establishment of noxious weeds:
Project construction and operation personnel will undergo training on the identification of
common noxious weeds in the region, weed management measures, and the
importance of prevention prior to beginning work on the Project.
Noxious weed locations will be marked prior to the start of site clearing activities.
Equipment will be thoroughly cleaned of soil and plant material prior to delivery to
reasonably ensure that noxious weeds are not introduced.
Equipment and vehicles will be regularly cleaned if working in areas that are
contaminated with noxious weeds prior to moving to uncontaminated areas.
If possible, vehicles will avoid driving through areas contaminated with noxious weeds
If erosion control devices are to be used, (ex. straw, mulch, soil, and aggregate), they
will be certified noxious weed free prior to use within the Project Area.
Stabilization and/or reclamation of disturbed ground will be implemented immediately
after construction, or as soon as practicable during construction.
Reclamation will use a county-approved native seed mix
Chemical or mechanical weed control measures may be implemented prior to
construction, during construction, following surface disturbance, or during operation
based on the noxious weed species and its associated growth habit and phenology
Ground disturbance throughout project construction, to the extent possible, will be
minimized.
Monitoring and treatment of noxious weeds will occur, where needed, in conjunction with
the revegetation and reclamation inspections for four years post-construction. Additional
seeding and herbicide treatments would occur as needed during annual inspection
events.
Monitoring and treatment of noxious weeds will occur, where needed, in conjunction with
the annual maintenance inspections.
Effective integrated weed management benefits from regular inventory of noxious weed species
in the Project Area to allow for modifications of treatment methods, documentation of new
infestations, and documentation of effectiveness of current treatment methods. Preventing the
spread of new noxious weeds into the Project Area is considered the most cost effective method
of control.
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 6
3.3 Treatment Methods
An overview of recommended control methods is detailed in the following sections. Note, weed
control methods and herbicide approvals can change so it is recommended that the reclamation
contractor continue consultation with the Garfield County Vegetation Manager to confirm the
recommended control methods at the time of treatment.
3.3.1 Cultural Management
Cultural management refers to management techniques that promote the growth of desirable
plants over noxious weeds, including maintaining optimum fertility and plant moisture status,
revegetating at optimum density and spatial arrangement, and planting species most suited to a
particular area. Cultural management techniques suggested by Garfield County include dense
seeding, fertilization, mulching, careful irrigation practices, sensible grazing regimes, and
improved land management practice (Garfield County 2016). Cultural control methods
appropriate for the Project include prevention thorough limiting disturbance and stabilizing and
restoring disturbed areas as soon as practical during construction. Competitive grasses can be
used to prevent re-introduction of musk thistle in treated areas. Grazing may be an option
depending on landowner agreements.
3.3.2 Mechanical Control
Mechanical management methods refer to physical measures that disrupt plant growth,
including mowing, chopping, tilling, burning, flooding, mulching, hand-pulling, shoveling, and
hoeing. The above mechanical management methods are more effective for annual and biennial
weeds such as musk thistle than they are for perennials such as Russian knapweed.
For musk thistle in small infestations (less than 0.5 acre) such as in the Project Area, tilling,
hoeing, and digging can be effective in treating the infestation. Mowing can reduce seed output
if conducted late in the flowering stage, but prior to seeding. If these methods are used all flower
buds and heads must be collected, bagged, and destroyed as seeds can mature and germinate
if left on the ground.
For Russian knapweed, mechanical treatments such as mowing before the plants bolt in late
May to mid-June can stress the plant and force it to use nutrient reserves stored in the root
system. However, this method would need to be used in conjunction with another method to be
effective at elimination of the infestation. As well, repeated tillage that is at least one foot deep
over three years can kill the root systems.
Although not a primary method of weed management, mechanical control may be used when
chemical control is ineffective or otherwise prohibited. Mechanical management will be used
during the construction process when existing vegetation is removed during construction or
where there are high concentrations of noxious weeds.
3.3.3 Chemical Control
Chemical weed controls refer to herbicide application to disrupt or inhibit the growth of noxious
weeds. Selection of the appropriate chemical treatment methods must take the species' life
cycle and timing of treatment into account. It is important to treat small infestations of weeds
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 7
chemically (List A and B species to be eradicated) as soon as possible (Garfield County 2016).
The application of herbicide to control noxious weeds would occur bi-annually, as needed. The
timing of herbicide application is dependent on species. All herbicide applications would comply
with applicable labels, laws, regulations, and permit stipulations. Chemical treatments would be
conducted by a licensed herbicide applicator according to individual chemical and label
requirements.
Herbicides will be applied using hand-held or backpack sprayers, utility task vehicle or truck-
mounted equipment as appropriate for the infestation and species. Spot applications would be
used preferentially to avoid non-target plants or limit contamination of sensitive resource areas
(i.e., wetlands or stream). Garfield County listed noxious weeds recommended herbicides can
be found within the Garfield County Noxious Weed Management Plan (Garfield County 2016).
Based on current guidance, the recommended herbicides for musk thistle and Russian
knapweed and the application timing are included in Table 3-1.
Table 3-1 Recommended Herbicide Treatments for Noxious Weeds in the Project Area
Noxious Weed
Species Herbicide Application Timing
Musk Thistle
Picloram (Tordon 22K)* Treat rosettes in spring
Aminopyralid
(Milestone)
Treat spring rosette to early bolting growth
stages or in fall to rosettes
Metsulfuron (Escort XP)
Treat in spring from rosette through very early
flower growth stages. (Can prevent viable
seed formation if applied no later than the first
viable flowers begin to open.)
Chlorsulfuron (Telar)
Treat in spring from rosette through very early
flower growth stages. (Can prevent viable
seed formation if applied no later than the first
viable flowers begin to open.)
Russian
Knapweed
Aminopyralid
(Milestone)
Treat in spring and summer to plants in the
bud and flowering stage and to dormant
plants in the fall.
Chlorsulfuron (Telar) Treat in spring to bud/early flower stage
and/or fall rosette.
Picloram (Tordon 22K)* Treat in spring from pre-bloom to bloom and
to fall rosettes.
* Restricted use chemical
Source: Garfield County 2016
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 8
4.0 Soil Management
The purpose of soil management is to maintain or restore the biological, chemical, and the
physical integrity of soils to allow for successful reclamation. Construction and reclamation soil
management activities include soil handling, landscape reconstruction, and erosion control.
Erosion control measures will be implemented to avoid, minimize, or mitigate effects from
surface-disturbing activities. Erosion control measures will be installed prior to and immediately
following surface disturbing activities.
Topsoil will be salvaged in areas of soil removal, such as access roads, staging areas,
permanent facilities, and turnarounds. In these areas, the topsoil will be stripped and then
stockpiled within the Project Area at the edge of the disturbed areas. Topsoil along linear
elements such as roads will be stripped and windrowed along the edge of the disturbance
areas. To the effect practical, topsoil stockpiles will be spaced apart from stockpiles of
subsurface soil to minimize mixing. Topsoil will be characterized by changes in texture, color,
and/ or consistency. Topsoil stockpiles will be designed, located, and protected to minimize
wind and water erosion, maintain stockpile stability, and limit surface disturbance. The
stockpiled topsoil will be re-spread on disturbed areas for reclamation activities. Topsoil
stockpiles will be replaced in reclaimed areas as close as practicable to their original source
area.
Reclamation will occur immediately after construction as practical based on weather and
seasonality. Topsoil will be replaced as part of the reclamation activities. Disturbed areas will be
mulched, seeded with a sterile cover crop, or otherwise temporarily covered to prevent wind and
water erosion if reclamation cannot start immediately after construction is complete.
Temporary stockpiles stored longer than 90 days will be covered with mulch and/or soil
tackifiers to assist in mitigating stockpile wind erosion and contribute organic materials. If
temporary stockpiles will be stockpiled overwinter, the stockpiles will be hydromulched, seeded
with a sterile cover crop, or covered to limit wind erosion. Erosion control measures (e.g.,
berms, straw wattles, rock socks, plastic silt fence, or ditches) will be implemented as needed to
minimize wind and water erosion.
5.0 Reclamation and Revegetation
The following measures will be employed to reclamation the Project. Erosion control measures
will be implemented to minimize or reduce sedimentation and other water erosion. Disturbed
areas will be reclaimed after construction is complete. Construction will seek to minimize
surface disturbance.
5.1 Reclamation Objectives
The goal of post-construction reclamation is to return the land to a state approximating the
preconstruction condition. The following reclamation objectives have been developed for the
Project:
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 9
Disturbed areas will be restored to natural-appearing landforms blending in with adjacent
undisturbed areas.
Establish a self-sustaining and locally native plant community in disturbed areas
Erosional features will be equal to or less than those in the surrounding area and
disturbed areas are reclaimed.
The reclaimed site shall not exhibit any of the following: large rills or gullies, head-
cuttings in drainages, or slope instability.
Noxious weed species’ cover is equal or less than that present before construction.
The post-construction vegetation must be resilient to demonstrate site stability, as
demonstrated by vigor with well-developed root systems and the ability to produce
viable seed.
Revegetated native plant densities are at least 70 percent of representative pre-
construction plant cover.
5.2 Reclamation Methods
Disturbed areas will be reseeded with the proposed seed mix in Table 5-1. The proposed seed
mix was developed based on technical guidance from the Natural Resources Conservation
Service. Species included in the seed mix were based on the native species observed on site
and in the general region, competitive native grasses to compete against the noxious weeds
present, and species that will establish quickly. ACE may consult the landowners, the
reclamation contractors, and Garfield County if the proposed species are not available at the
time of seeding. Certified noxious weed free seeds would be used for reseeding.
Table 5-1. Seed Mix and Application Rates (Upland Mix)
Common Name Scientific Name Cultivar % of Seed
Mix
Pure Live
Seed (lb/ac)*
Blue Grama Bouteloua gracilis Hachita 20 2.14
Western Wheatgrass Pascopyrum smithii Arriba 20 13.84
Galleta Grass Pleuraphis jamesii Viva 15 8.73
Indian Ricegrass Achnatherum hymenoides Nezpar 10 3.96
Thickspike Wheatgrass Elymus lanceolatus lanceolatus Critana 10 6.05
Western Yarrow Achillea millefolium occidentalis Wild 10 0.21
White Sage Artemisia ludoviciana Wild 5 0.06
White Prairie Clover Dalea candida Wild 5 1.48
Canada Wildrye Elymus canadensis Wild 5 3.54
Total 100 40
* lb/ac = pounds per acre. Assumes drill seeding and 40 PLS lbs Per Acre.
Sources: CDA 2023; Western Native Seed 2023b,.
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 10
Areas to be reseeded will be determined by the reclamation contractor. Areas that the
reclamation contractor feel would naturally regenerate may not require additional reseeding.
Seeding will be based on optimal time for the majority of the seed mix, typically fall and early
spring. Optimal seeding conditions for a native forb and grass mixture is between fall (dormant
seeding) and early spring when soil temperatures are between 50 to 80 degrees Fahrenheit
(BBB Seed 2023a, Western Native Seed 2023a, NRCS/CSU Extension 2016). For fall planting it
should be after the first hard frost and for spring planting it should be one month before the last
hard frost (BBB Seed 2023b). For Garfield County, the average first frost is between September
21- September 30 (PlantMaps 2023a) and the average last frost date is between June 11th –
June 20th (PlantMaps 2023b). Therefore, recommended seeding timeframes are between
October 1st − November 15th for fall planting or between April 15th – May 11th for early spring
planting.
Compaction eliminates natural pore spaces by removing air and destroying soil aggregates,
which precludes the movement of air, water, microbes, and nutrients throughout the soil profile.
Compacted areas as identified by the reclamation contractor will be treated to improve soil
aeration, water infiltration, and root penetration. Concurrent or prior to seeding, roughening of
the soil surface will be conducted by creating furrows or pits, which increases moisture
infiltration, captures blowing snow, and slows the surface velocity of wind and water to reduce
erosion and sedimentation.
Seeds would be drill seeded. Seeding should not be conducted during unsuitable conditions
including windy conditions or when the ground is excessively wet, frozen, snow-covered,
extremely dry, or hard. As needed to reduce wind and water erosion and/or to promote moisture
capture, reclaimed areas will be mulched with certified weed-free native grass, wood straw,
and/or live mulch. Mulch will be applied at a rate sufficient to maintain appropriate cover. Areas
to be mulched will be determined by the reclamation contractor.
Site reclamation is anticipated to be achieved within four growing seasons or when the Project
area has reached around 70 percent of pre-construction vegetation density. The reclamation
contractor would monitor revegetation progress until such time that reclamation success is
approved by the Garfield County vegetation manager.
Environmental conditions, such as drought and unseasonal temperatures, could negatively
affect revegetation attempts. The reclamation contractor will attempt strategic remedial
measures in the event of unfavorable environmental conditions. The remedial measure could
include strategic reseeding prior to precipitation events; extension of maintenance and
monitoring beyond the four growing seasons, and the potential adjustment of the performance
success criteria for drought conditions. All remedial measures will need to be approved by the
Garfield County vegetation manager. Additional watering or fertilizer is not recommended most
native species are adapted to the arid and soils conditions.
During operations, maintenance mowing will be conducted within the Project Area. Mowing may
help with weed control if it occurs prior to either noxious weed species in the Project Area
setting seed.
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 11
6.0 Monitoring and Reporting
Monitoring will be conducted annually to evaluate reclamation success, noxious weed treatment
effectiveness, and adjust reclamation and noxious weed treatments if appropriate. Monitoring
would be conducted for four years post-construction by qualified personnel.
6.1 Noxious Weeds
Noxious weed infestations will continue to be monitored annually for up to four years post-
construction. Noxious weed monitoring will be performed by qualified personnel and would
include inspections of previously treated areas and the Project Area for new occurrences to
minimize the spread and establishment of weed species. If new areas of noxious weeds are
identified, the surveyors will record the species, relative population size, and location with a
GPS. New identified noxious weed occurrences or areas that need additional treatment will be
managed by the guidelines described in Section 3. Areas that have been treated will be
inspected within 10-14 days after the implementation to determine the control method's efficacy.
If needed, additional control measures would be conducted by the reclamation contractor.
6.2 Revegetation
Areas that have been reseeded with the native seed mix will be monitored up to four years post-
construction. On each reseeded area the reclamation contractor will conduct annual reclamation
monitoring and write a report summarizing the results to submit to Garfield County. Monitoring
will begin in the first growing season after the disturbed areas have been reseeded. The Project
will achieve reclamation success if the revegetated areas reach 70 percent cover as compared
to pre-construction native vegetation as well as meet the reclamation success criteria listed in
Section 5.1.
Revegetation monitoring will consist of qualitative assessments of the progress of the reseeded
disturbed areas compared to the undisturbed surrounding areas. The undisturbed surrounding
areas that will aid in demonstrating the attainment of reclamation standards will have native
plants and similar site stability of the surrounding area. These sites will be identified by the
reclamation contractor. Garfield County will have the final approval of reclamation success.
7.0 Reporting
Herbicide application records would be submitted to the Garfield County vegetation manager by
the reclamation contractor after each weed treatment event. The herbicide application records
will include the noxious weed species to be treated, date of application, the selected herbicide
treatment, the amount of herbicide used, coordinates of treated area (s), total acreage treated,
herbicide application form, and any other information Garfield County finds pertinent.
ACE is financially prepared to implement the measures outlined in this VMP.
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 12
9.0 References
BBB Seed. (2023a). When to Plant. Accessed January 2023 at: https://bbbseed.com/wildflower-
grass-tips/when-to-plant/
BBB Seed. (2023b). Fall Planting. Accessed January 2023 at: https://bbbseed.com/wildflower-
grass-tips/fall-planting/
Colorado Department of Agriculture (CDA). (2022). Noxious Weed Species ID. Accessed
December 2022 at: https://ag.colorado.gov/conservation/noxious-weeds/species-id#b
Colorado Department of Agriculture (CDA). (2023). Plant Materials Technical Note 59: Plant
Suitability and Seeding Rates for Conservation Plantings in Colorado. Accessed January
2023 at: https://efotg.sc.egov.usda.gov/#/state/CO/search
Colorado Oil and Gas Conservation Commission (COGCC). (2022). GIS Online Mapping.
Accessed May 2022 at: https://cogccmap.state.co.us/cogcc_gis_online/ GISOnline
Mapping. Accessed May 2022 at: https://cogccmap.state.co.us/cogcc_gis_online/
Dewey, S.A., Enloe S.F., Menalled, F.D., Miller, S.D., Whitesides, R.E., and L. Johnson. 2006.
Weed Management Handbook 2006-2007: Montana, Utah, Wyoming. Accessed at:
http://www.uwyo.edu/uwe/programs/weed_management_handbook_files/weed_manage
ment_handbook.pdf
Garfield County. (2016). Garfield County Noxious Weed Management Plan. Accessed
December 2022 at: https://www.garfield-county.com/vegetation-
management/filesgcco/sites/29/2019/11/Garfield-County-Noxious-Weed-Management-
Plan-Adopted-Feb-2016.pdf
Google Earth Pro. (1985-2020). Historic aerial imagery of 39°31'40.62"N 107°41'50.13"W
Accessed July 15, 2022.
Natural Resource Conservation Service (NRCS), Colorado State University (CSU) Extension.
(2016). Grass Seeding Plan for Colorado Small Acreages. Accessed January 2023 at:
https://sam.extension.colostate.edu/wp-content/uploads/sites/2/2016/07/seeding-
plan.pdf
PlantMaps. (2023a). Colorado Average First Frost Date Map. Accessed January 2023 at:
https://www.plantmaps.com/interactive-colorado-first-frost-date-map.php
PlantMaps. (20230b). Colorado Average Last Frost Date Map. Accessed January 2023 at:
https://www.plantmaps.com/interactive-colorado-last-frost-date-map.php
Rextag. (2022). Rextag Global Energy GIS Data. Accessed May 2022 at: https://rextag.com/gis
U.S. Geological Survey (USGS). (1983). Silt, Colorado [Map], 1:24000, Topographic
Quadrangle Map, Silt, CO.
Eagle Springs Organic Solar Project January 2020, Rev March 2023
Vegetation Management and Reclamation Plan 13
Western Native Seed. (2023a). General Planting Instructions. Accessed January 2023 at:
https://www.westernnativeseed.com/planting.html
Western Native Seed. (2023b). Short Grass Prairie Seed Mixes. Accessed January 2023 at:
https://westernnativeseed.com/SGPwildflowermix.html
Appendix A. Site Plan
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WWWWW GGGGGGGGGPARCEL 1PARCEL 2PARCEL 3EAGLE SPRINGS ORGANIC, LLCAPN: 217918100691EAGLE SPRINGS ORGANIC, LLCAPN: 21791174007310EAGLE SPRINGS ORGANIC, LLCAPN: 217917300732EAGLE SPRINGS ORGANIC, LLCAPN: 217917300732EXISTINGSOLAR SITEB & B MAMM CREEK, LLCAPN: 217919100511BEDROCK RESOURCES, LLCAPN: 21791840072015' IRRIG. PIPELINE ESMTORGANIC GROWERS, LLCAPN: 21791720068730' ACCESS ESMT30' ACCESS ESMTOVERHEAD POWER LINES(HOLY CROSS)ESMT15' IRRIGATION ESMTOVERHEAD POWER LINES(HOLY CROSS)30' ELECTRICAL ESMTOVERHEAD POWER LINES(HOLY CROSS)PROCESS WATERLINE (2)GASLINE (1)PROCESS WATERLINE (2)GASLINE (1)PROCESS WATERLINE (2)GASLINE (1)EX. GRAVEL ACCESS ROAD ℄EX. LOW MAINTENANCE ROAD ℄EX. GRAVEL LOWMAINTENANCE ROAD ℄EX. GRAVEL ACCESS ROAD ℄EX. WELL PADEX. WELL PADPROCESS WATERLINE (2)GASLINE (1)EX. OUTBUILDINGEX.GREENHOUSESEX. OUTBUILDINGEX. OUTBUILDING60' USA DOE ESMT25' WIDE PIPELINE ESMT20' PIPELINE ESMT15' IRR. ESMTEX. CULVERT ℄30'R (TYP)PROPOSEDLAYDOWNAREA(176,228 SF)403'271'EX. GRAVEL ACCESS ROAD ℄20' EX. ACCESS ROAD(EX RD TO BE IMPROVED)20' ACCESS ROAD20'EX. GRAVEL ACCESS ROAD ℄EX. GRAVEL ACCESS ROAD ℄EX. GRAVEL ACCESS ROAD ℄EX. LOW MAINTENANCE ROAD ℄TO BE MOVEDEX. LOW MAINTENANCE ROAD ℄EX. WELL PADEX. GRAVEL ACCESS ROAD ℄30'R (TYP)PARCEL BOUNDARY(TYP)284.31'142.12'519.67'119.4'20' ACCESS ROAD(END OF EX. RD IMPROVEMENT - AS NEEDED)12' PERIMETER ACCESS ROAD(START EX. RD IMPROVEMENT - AS NEEDED)12' EX. PERIMETER ACCESSROAD(EX. RD IMPROVEMENT - AS NEEDED)EX. CULVERT ℄20' EX. PERIMETER ACCESS ROAD(EX. ROAD TO BE IMPROVED )20' EX. ACCESS ROAD(EX. ROAD TO BE IMPROVED)3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATE30'R (TYP)EX. ACCESS ROAD(EX. RD TO BE IMPROVED - AS NEEDED)EX. ACCESS ROAD(EX. RD TO BE IMPROVED - AS NEEDED)EX. ACCESS ROAD(EX RD IMPROVEMENT TO CONTINUETO MAMM CREEK RD- AS NEEDED)PROCESS WATERLINE (2)GASLINE (1)12' PERIMETER ACCESS ROAD(EX. FIELD RD TO BE IMPROVED )12' PERIMETER ACCESS ROAD(EX FIELD RD TO BE IMPROVED )12' PERIMETER ACCESS ROAD(START OF EX FIELD RD IMPROVEMENT )30'R (TYP)30'R (TYP)12' PERIMETER ACCESS ROAD12' PERIMETER ACCESS ROAD30'R (TYP)30'R (TYP)30'R (TYP)20' ACCESS ROAD20' ACCESS ROAD3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATE3' MAN GATEEX. LOW MAINTENANCE ROAD℄OVERHEAD POWER POLE ANDGUY WIRES(HOLY CROSS)12' PERIMETER ACCESS ROAD3' MAN GATE18.34'17'33.29'33.29'18.34'33.29'18.34'EX. CULVERT ℄PCS, BESS &SWITCHGEAR PADEX. FENCETO BE REMOVEDEX. FENCEEX. FENCEEX. FENCEEX. FENCEEX. FENCE20' EX. ACCESS ROAD(END OF EX. RD IMPROVEMENT)12' EX. PERIMETERACCESS ROAD(START EX. RDIMPROVEMENT - AS NEEDED)20' ACCESS ROAD20' ACCESS ROAD20'20'20'20'20'20'20'20'20'L2L3L4L5L6L7L8C1C2L11 C3 L13C4 L15
L16L17L18C5L20C6L22C7L24 C8L26L27 C9 L29 L30 L31EX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. CONCRETE PAD (USE UNKNOWN)111120'30'R (TYP)CULVERT AO&M SHED(20' X 8')ALBEDOMETERW/ 30' SETBACK30'R (TYP)L32L33C10L35L36
L37
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L1CURVE TABLECURVE NO.C1C2C3C4C5C6C7C8C9C10LENGTH17.47'126.20'27.20'27.20'294.83'247.33'167.97'59.92'118.94'22.13'RADIUS40.00'187.43'40.00'40.00'1000.00'200.00'600.00'300.00'300.00'60.00'DELTA25°01'28"38°34'45"38°57'33"38°57'33"16°53'34"70°51'15"16°02'24"11°26'40"22°43'00"21°07'40"Line TableLine #L1L2L3L4L5L6L7L8L11L13L15L16L17L18L20L22L24L26L27L29L30L31L32L33L35L36L37L38L39L40Length233.200123.865119.436323.266527.139503.869175.468167.850421.93736.689118.873534.00799.774272.452311.239195.521176.10228.82727.48330.95350.52759.9721693.88194.046101.993163.011138.066107.903203.748152.933DirectionN89° 34' 34.36"WN80° 53' 05.51"WN73° 21' 10.97"WN66° 28' 14.89"WN73° 40' 56.11"WN60° 52' 26.14"WN50° 50' 01.15"WN64° 27' 33.97"WN00° 00' 00.00"EN38° 57' 33.48"EN00° 00' 00.00"ES89° 59' 43.92"WN89° 59' 37.38"WN89° 59' 37.38"WS73° 06' 25.95"WN36° 02' 19.35"WN19° 59' 54.93"WN33° 01' 41.53"WN45° 51' 31.56"EN23° 08' 31.44"EN23° 08' 31.44"EN23° 06' 08.61"EN88° 00' 01.96"WN88° 00' 01.96"WN66° 52' 21.75"WN00° 00' 00.00"EN00° 00' 09.18"EN00° 00' 49.74"EN00° 00' 00.00"EN90° 00' 00.00"WOPERATED BY AESCLEAN ENERGYIN CASE OFEMERGENCY CALL:(855) 679-3553PLACE ON ALL VEHICLE ACCESS GATESDATEPROJECT TITLE:DESCRIPTIONAPV:PROJECT LOCATION:NO.KEY PLAN:PE STAMP:REVISIONS:SHEET NO:REV:SCALE AT 24" x 36":CHK:DWN:DES:DATE:PROJNUM:SHEET TITLE & DESCRIPTION:2180 South 1300 East, Suite 600Salt Lake City, UT 84106-2749(801) 679 - 3500ELECTRIC POWER ENGINEERING, INC.12600 W. COLFAX AVE, STE. C500LAKEWOOD, CO 80215(303) 431-7895 www.neieng.com0 75' 150' 225' 300'1" = 150'CIVIL SITE PLAN----PLOTTED: 3/17/2023 4:24 PMH:\Project\4000\4084.001 Eagle Springs PV_BESS_30 PCT PV_BESS_AES\4_DWGs\2_NEI\Solar\PV CIV\PV-C.03.01 CIVIL SITE PLAN.dwgXREFs: H:\Project\4000\4084.001 Eagle Springs PV_BESS_30 PCT PV_BESS_AES\4_DWGs\2_NEI\2_Sheetset References\AES Titleblock Outline.dwg; H:\Project\4000\4084.001 Eagle Springs PV_BESS_30 PCT PV_BESS_AES\4_DWGs\2_NEI\2_Sheetset References\ESPR1 - ARRAYS - 45%.dwg; H:\Project\4000\4084.001 Eagle Springs PV_BESS_30 PCT PV_BESS_AES\4_DWGs\2_NEI\2_Sheetset References\ESPR1 - EAGLE SPRINGS_REV2.dwg; ..\..\2_Sheetset References\CIVIL.dwg; ..\..\2_Sheetset References\CIVIL-CONSTRAINTS.dwg AES Titleblock 24X36 v210209
EAGLE SPRINGSORGANICSILT, CO4084.001JPDJPDBCBC2/16/23PV-C.03.01 CA 1/23/23 30% SUBMITTALB 2/16/23 30% RESUBMITTALC 3/17/23 30% RESUBMITTAL- - -- - -- - -- - -- - -PRELIMINARYNOT FOR CONSTRUCTIONFOR REVIEW & APPROVAL ONLYNGENERAL LEGENDHORIZONTAL CONTROLEXISTING FEATURESPROPOSED FEATURESLoDPROPOSED DISTURBANCE LIMITSPROPOSED SECURITY FENCEPROPOSED CONSTRUCTION LAYDOWN AREAPROPOSED EQUIPMENT PADEXISTING PARCEL LINEEXISTING FENCEEXISTING EASEMENTEXISTING POWER POLEEXISTING ROAD CENTERLINEEXISTING TREE LINEEXISTING OVERHEAD POWERPROPOSED CULVERTWEXISTING PROCESS WATERLINEGEXISTING GASLINEEXISTING STREAMPROPOSED ACCESS ROADEXISTING ROAD (TO BE IMPROVED AS NEEDED)PROPOSED ACCESS ROAD IMPROVEMENT OF EXISTING GRAVEL ROADPROPOSED ACCESS ROAD IMPROVEMENT OF EXISTING FIELD ROADKEY NOTES:PROPOSED 25' ACCESS GATE1SIGNAGE
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IPOPSFSFSFSFSFSFSFSFSFSFSFSFSFSFSFSFSFSFSFSFSFOVERHEAD POWER LINES(HOLY CROSS)ESMTOVERHEAD POWER LINES(HOLY CROSS)OVERHEAD POWER LINES(HOLY CROSS)PROCESS WATERLINE (2)GASLINE (1)PROCESS WATERLINE (2)GASLINE (1)PROCESS WATERLINE (2)GASLINE (1)EX. GRAVEL ACCESSROAD ℄EX. GRAVEL ACCESSROAD ℄EX. GRAVEL ACCESSROAD ℄EX. WELLPADEX. WELLPADPROCESS WATERLINE (2)GASLINE (1)EX. OUTBUILDINGEX.GREENHOUSESEX. OUTBUILDINGEX. OUTBUILDINGEX. GRAVEL ACCESSROAD ℄EX. GRAVEL ACCESSROAD ℄EX. GRAVEL ACCESSROAD ℄EX. GRAVEL ACCESSROAD ℄EX. GRAVEL ACCESSROAD ℄EX. WELLPADEX. GRAVEL ACCESSROAD ℄PARCELBOUNDARY(TYP)SFSFSFSFSFSFEX. CULVERT ℄EX. CULVERT ℄EX. LOW MAINTENANCE ROAD ℄SFSFSFSFSFSFEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. EPHEMERAL DITCHEX. CONCRETE PAD(USE UNKNOWN)LODPSPSPSPSPSPSPSPSPSPSLODLODLODLODLODDATEPROJECT TITLE:DESCRIPTIONAPV:PROJECT LOCATION:NO.KEY PLAN:PE STAMP:REVISIONS:SHEET NO:REV:SCALE AT 24" x 36":CHK:DWN:DES:DATE:PROJNUM:SHEET TITLE & DESCRIPTION:2180 South 1300 East, Suite 600Salt Lake City, UT 84106-2749(801) 679 - 3500ELECTRIC POWER ENGINEERING, INC.12600 W. COLFAX AVE, STE. C500LAKEWOOD, CO 80215(303) 431-7895 www.neieng.com0 75' 150' 225' 300'1" = 150'RESTORATION PLAN----PRELIMINARYNOT FOR CONSTRUCTIONFOR REVIEW & APPROVAL ONLYNGENERAL LEGENDEXISTING FEATURESPROPOSED FEATURESPROPOSED ACCESS ROADLoDPROPOSED DISTURBANCE LIMITSPROPOSED SECURITY FENCEPROPOSED EQUIPMENT PADEXISTING PARCEL LINEEXISTING FENCEEXISTING EASEMENTEXISTING POWER POLEEXISTING ROAD CENTERLINEEXISTING TREE LINEEXISTING OVERHEAD POWERWEXISTING PROCESS WATERLINEGEXISTING GASLINEEXISTING MAJOR CONTOUREXISTING MINOR CONTOUR5530PLOTTED: 3/17/2023 3:59 PMH:\Project\4000\4084.001 Eagle Springs PV_BESS_30 PCT PV_BESS_AES\4_DWGs\2_NEI\Solar\PV CIV\PV-C.06.03 RESTORATION PLAN - RESTORATION PLAN.dwgXREFs: H:\Project\4000\4084.001 Eagle Springs PV_BESS_30 PCT PV_BESS_AES\4_DWGs\2_NEI\2_Sheetset References\AES Titleblock Outline.dwg; H:\Project\4000\4084.001 Eagle Springs PV_BESS_30 PCT PV_BESS_AES\4_DWGs\2_NEI\2_Sheetset References\ESPR1 - ARRAYS - 45%.dwg; ..\..\2_Sheetset References\CIVIL.dwg; H:\Project\4000\4084.001 Eagle Springs PV_BESS_30 PCT PV_BESS_AES\4_DWGs\2_NEI\2_Sheetset References\ESPR1 - EAGLE SPRINGS_REV2.dwg; H:\Project\3800\3803.001 Northumberland Solar - IEA\Drawings\_NEI\_References\PR-PLAN.dwg; .\PV-C.03.02 CIVIL SITE PLAN.dwg; ..\..\2_Sheetset References\CIVIL-CONSTRAINTS.dwgAES Titleblock 24X36 v210209
EAGLE SPRINGSORGANICSILT, CO4084.001JPDJPDBCBC3/17/23PV-C.06.02 AA 3/17/23 30% RESUBMITTAL- - -- - -- - -- - -- - -- - -- - -SFPROPOSED SILT FENCEEXISTING DITCHNOTES1.PERMANENT STABILIZTION TO BE ACHIEVED BY GRASS SEED CONVERED WITHSTRAW AND OTHER MULCHES AND TACKIFIERS, ROLLED, EROSION CONTROLPRODUCTS WITH GRASS SEED, OR BY HYDROSEEDING.2. PERMANENT SEEDING MIX SPECIFIED IN "DRAFT_NOXWEED & RECLAMATIONREPORT_12.30.2023".3. SURVEY AND TOPOGRAPHY DATA TAKEN FROM "EAGLE SPRINGS_REV2.DWG" BYROADRUNNER SURVEY & MAPPING, INC.; DATED NOVEMBER 20, 2022.4. EPHEMERAL DITCHES SHOWN AS PROVIDED BY AES.EROSION CONTROLPERMANENT SEEDINGRIPRAPPERMANENT SEEDING MIXBMP LEGENDSFSILT FENCELODLIMIT OF DISTURBANCEPSPERMANENT SEEDING
Appendix B. Colorado and Garfield County Noxious Weed Lists
Colorado Noxious Weeds (including Watch List), effective October, 2020
(Alphabetized by scientific name)
List A Species (25)
Common Scientific
Camelthorn (Alhagi maurorum)
Giant reed (Arundo donax)
Elongated mustard (Brassica elongata)
Flowering rush (Butomus umbellatus)
Yellow starthistle (Centaurea solstitialis)
Squarrose knapweed (Centaurea virgata)
Meadow knapweed (Centaurea x moncktonii)
Rush skeletonweed (Chondrilla juncea)
Common crupina (Crupina vulgaris)
Hairy willow-herb (Epilobium hirsutum)
Cypress spurge (Euphorbia cyparissias)
Myrtle spurge (Euphorbia myrsinites)
Japanese knotweed (Fallopia japonica)
Giant knotweed (Fallopia sachalinensis)*
Bohemian knotweed (Fallopia x bohemicum)
Orange hawkweed (Hieracium aurantiacum)
Hydrilla (Hydrilla verticillata)
Dyer's woad (Isatis tinctoria)
Purple loosestrife (Lythrum salicaria)
Parrotfeather (Myriophyllum aquaticum)
African rue (Peganum harmala)
Mediterranean sage (Salvia aethiopis)
Giant salvinia (Salvinia molesta)
Tansy ragwort (Senecio jacobaea)
Medusahead (Taeniatherum caput-medusae)
List B Species (38)
Common Scientific
Absinth wormwood (Artemisia absinthium)
Diffuse knapweed (Centaurea diffusa)
Canada thistle (Cirsium arvense)
Bull thistle (Cirsium vulgare)
Chinese clematis (Clematis orientalis)
Common teasel (Dipsacus fullonum)
Cutleaf teasel (Dipsacus laciniatus)
Dame's rocket (Hesperis matronalis)
*Scientific name is correct here, and the Administrative Rule will be updated during the
next cycle (2022).
Black henbane (Hyoscyamus niger)
Hoary cress (Lepidium draba)
Dalmatian toadflax, broad-leaved (Linaria dalmatica)
Dalmatian toadflax, narrow-leaved (Linaria genistifolia)
Eurasian watermilfoil (Myriophyllum spicatum)
Bouncingbet (Saponaria officinalis)
Common tansy (Tanacetum vulgare)
List B Species Continued (38)
Common Scientific
Jointed goatgrass (Aegilops cylindrica)
Mayweed chamomile (Anthemis cotula)
Plumeless thistle (Carduus acanthoides)
Musk thistle (Carduus nutans)
Wild caraway (Carum carvi)
Spotted knapweed (Centaurea stoebe ssp. micranthos)
Spotted x diffuse knapweed hybrid (Centaurea x psammogena)
Houndstongue (Cynoglossum officinale)
Yellow nutsedge (Cyperus esculentus)
Russian-olive (Elaeagnus angustifolia)
Leafy spurge (Euphorbia esula)
Perennial pepperweed (Lepidium latifolium)
Oxeye daisy (Leucanthemum vulgare)
Yellow x Dalmatian toadflax hybrid (Linaria vulgaris x L. dalmatica)
Yellow toadflax (Linaria vulgaris)
Scotch thistle (O. tauricum)
Scotch thistle (Onopordum acanthium)
Sulfur cinquefoil (Potentilla recta)
Russian knapweed (Rhaponticum repens)
Salt cedar (T. chinensis)
Salt cedar (Tamarix. ramosissima)
Scentless chamomile (Tripleurospermum inodorum)
Moth mullein (Verbascum blattaria)
List C Species (16)
Common Scientific
Velvetleaf (Abutilon theophrasti)
Common burdock (Arctium minus)
Downy brome, cheatgrass (Bromus tectorum)
Chicory (Cichorium intybus)
Poison hemlock (Conium maculatum)
Field bindweed (Convolvulus arvensis)
Quackgrass (Elymus repens)
Redstem filaree (Erodium cicutarium)
Halogeton (Halogeton glomeratus)
Common St. Johnswort (Hypericum perforatum)
Wild proso millet (Panicum miliaceum)
Bulbous bluegrass (Poa bulbosa)
Perennial sowthistle (Sonchus arvensis)
Johnsongrass (Sorghum halepense)
Puncturevine (Tribulus terrestris)
Common mullein (Verbascum thapsus)
Watch List Species (19)
These species are not regulated by the Noxious Weed Act/Rule.
Common Scientific
Tree of Heaven (Ailanthus altissima)
Garlic mustard (Alliaria petiolata)
Common bugloss (Anchusa officinalis)
Onionweed (Asphodelus fistulosus)
Hoary alyssum (Berteroa incana L.)
Caucasian bluestem (Bothriochloa bladhii)
Yellow bluestem (Bothriochloa ischaemum)
White bryony (Bryonia alba)
Scotch broom (Cytisus scoparius)
Baby's breath (Gypsophila paniculata)
Meadow hawkweed (Hieracium caespitosum)
Yellow flag iris (Iris pseudacorus)
Garden loosestrife (Lysimachia vulgaris)
Common reed (Phragmites australis)
Himalayan blackberry (Rubus armeniacus)
Swainsonpea (Sphaerophysa salsula)
Siberian elm (Ulmus pumila)
Ventenata grass (Ventenata dubia)
Syrian beancaper (Zygophyllum fabago)
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 31
Please see the following pages for the Traffic Study prepared by Kellar Engineering in March 2023,
addressing the existing road system and driveway compliance to the Road Standards and Section 7-107.
All on-site driveway and interior road improvements are documented in the civil plan sets in Section B2.
TRAFFIC STUDY
Section B5
This document, together with the concepts and recommendations presented herein, as an instrument of service, is intended only for the
specific purpose and client for which it was prepared. Reuse of and improper reliance on this document without written authorization from
Kellar Engineering LLC shall be without liability to Kellar Engineering LLC.
Eagle Springs Organic Solar Site
County Road 315 approximately 1.3 miles south of I-70
Garfield County, Colorado
Traffic Management Study
KE Job #2023-014
Prepared for:
TRC Companies, Inc.
123 N. College Avenue, Suite 206
Fort Collins, CO 80524
Prepared by:
skellar@kellarengineering.com
www.kellarengineering.com
970.219.1602 phone
March 9, 2023
Sean K. Kellar, PE, PTOE
Eagle Springs Traffic Management Study -Page 2
1.0 Introduction
The purpose of this Traffic Management Study (Traffic Study) is to evaluate the proposed
traffic generated by the proposed Eagle Springs Organic Solar Project site for ACE DevCo
NC, LLC, located on County Road 315 (CR 315) approximately 1.3 miles south of I-70 in
Garfield County, Colorado
2.0 Proposed Development
The proposed project consists of a solar field land use on the property. The proposed
solar field would consist of a photovoltaic energy generation facility on approximately 140
acres. Access to the site is proposed from an existing low traffic volume access road off
of CR 315 on the east side of CR 315. See Figure 1: Vicinity Map and Figure 2: Site Plan.
3.0 Project Schedule
Land Use Change Permit Schedule – High Mesa Start Date End Date
Component Delivery 11/13/2023 3/28/2024
Perimeter Fence Installation 4/1/2024 4/16/2024
Solar Panel Foundation Installation 2/9/2024 4/4/2024
Solar Panel Installation 4/5/2024 5/31/2024
Transformer and Inverter Installation 3/15/24 6/3/2024
Eagle Springs Traffic Management Study -Page 3
Figure 1: Vicinity Map
Eagle Springs Traffic Management Study -Page 4
4.0 Trip Generation
Site generated traffic estimates are determined through a process known as trip
generation. Rates and equations are applied to the proposed land use to estimate traffic
generated by the development during a specific time interval. The acknowledged source
for trip generation rates is the Trip Generation Report published by the Institute of
Transportation Engineers (ITE). The ITE Trip Generation Manual does not provide
detailed data on solar field facilities. As such, Kellar Engineering was able to estimate the
weekday peak hour trip generation for the AM and PM peak hours based upon information
provided by the client and project team. The project team provided the following trip
generation data:
Trip Generation Data:
Maximum anticipated number of daily trips per day during peak period of
construction = 10 – 15 vehicles per day during peak construction 7:00 AM – 3:30
PM general hours Monday – Friday.
% of heavy vehicles during peak period of construction = 5% - 10% during first
few months of construction.
Typical anticipated number of daily trips after construction is complete = 2 – 4
trips per year depending on O&M contract details
Approximately 50% of the traffic will come from the west on I-70 and
approximately 50% of the traffic will come from the east on I-70. Traffic will exit
and use CR 315 to the project site entrance.
Based upon the above data, the project is conservatively anticipated to generate a
maximum of approximately 48 daily trips, 24 total (14 entering, 10 exiting) AM peak hour
trips, and 20 total (6 entering, 14 exiting) PM peak hour trips. See Table 1: Trip
Generation.
Eagle Springs Traffic Management Study -Page 5 Figure 2: Site Plan
Eagle Springs Traffic Management Study -Page 6 Table 1: Trip Generation Average Daily Trips AM Peak Hour Trips PM Peak Hour Trips ITE Code Land Use Size Rate Total Rate In Rate Out Total Rate In Rate Out Total N/A Solar Field * * 48 * 14 * 10 24 * 6 * 14 20 N/A = Not Available * The ITE Trip Generation Manual, 11th Edition does not provide detailed data related to the proposed use. Therefore, trip generation is based upon information obtained from the client and project team. See Section 4.0 Trip Generation for more information
Eagle Springs Traffic Management Study -Page 7
5.0 Access route and road rating
The project access route is from a ~1.25-mile southeast stretch on CR 315 originating at I-70. CR
315 then leads to a private driveway that accesses the project site. The ~1.25 mi stretch of CR
315 is a two-lane minor collector (See Table 7-107 below from the Garfield County Land Use and
Development Code Standards) with a posted speed of 35. CR 315 is paved and in good condition.
According to the County’s recent traffic volumes, CR 315 carries approximately 500 vehicles per
day. CR 315 is posted with a vehicle weight limit on the roadway of 80,000 lbs. for 5 axle vehicles
and 54,000 lbs. for 3 axle vehicles.
Eagle Springs Traffic Management Study -Page 8
Table 1 below summarizes the estimated project trips and vehicle sizes that will be expected in the
delivery, installation, and maintenance phases of the project.
Table 1: Daily Vehicle Trip Generation
Project Phase
(Time Period) Vehicle Type Estimated Gross
Vehicle Weight
Vehicles
per Day
Vehicle Trips
per Day
Delivery
[3 weeks]
Conex Containers and
Delivery Trucks 30,000-50,000 lbs. 2-4 4-8
Equipment Hauling
Trucks 20,000-40,000 lbs. 1-2 2-4
Maximum: 12
Average: 6
Installation
[Approx. 10 months]
Passenger Vehicles 2,000-10,000 lbs. 20-30 40-60
Fuel Truck 20,000-30,000 lbs. 1 2
Material Delivery Truck 20,000-30,000 lbs. 1 2
Maximum: 64
Average: 44
Maintenance
and Operations
[Ongoing]
Utility Vehicle 2,000-10,000 lbs. 1 per month
or less 0-1
Maximum: 1
Average: 0
As Table 1 indicates, most of the heavy vehicle trips expected will be in the first three weeks of the
project process. The road structure is properly equipped to handle the expected vehicle weight.
Most of this traffic is expected to travel to the project site during non-peak hour times. Most light
vehicle trips are expected during the installation process and a maximum of one trip is expected
per month after the installation. It is expected that the peak hour traffic on CR 315 will not be
negatively affected by this project.
Eagle Springs Traffic Management Study -Page 9
6.0 Conclusions
The findings of the Traffic Study are summarized below:
The proposed project is conservatively anticipated to generate a maximum of approximately
48 daily total weekday trips, 24 AM total peak hour trips, and 20 PM total peak hour trips.
See Table 1: Trip Generation
The project’s trip generation and site generated traffic is low. See Table 1: Trip
Generation.
Due to the project’s low site generated traffic, the proposed project will not create a
negative traffic impact upon the local and regional traffic system and the existing roadway
improvements are sufficient to accommodate the project’s traffic. See Section 4.0.
The anticipated number of daily trips after construction is complete is only 2 – 4 trips per
year. See Section 4.0.
Access to the project is from CR 315 starting at I-70 and leading to the private driveway
located on the project site. CR 315 is properly equipped to handle the proposed traffic
generated by the project and will stay in its current road classification. With the addition of
the project’s traffic, CR 315 is not projected to exceed 600 vehicles per day along the
project’s access route. See Section 5.0 and Table 7-107 from the Garfield County Land
Use and Development Code Standards.
Eagle Springs Traffic Management Study -Page 10
APPENDIX
Eagle Springs Traffic Management Study -Page 11
Aerial Image
Eagle Springs Traffic Management Study -Page 12
Street View (County Road 315 Access)
Sean Kellar, PE, PTOE
Principal Engineer
Education
B.S., Civil Engineering, Arizona State
University – Tempe, AZ
Registration
Colorado, Professional Engineer (PE)
Wyoming, Professional Engineer (PE)
Idaho, Professional Engineer (PE)
Arizona, Professional Engineer (PE)
Kansas, Professional Engineer (PE)
Missouri, Professional Engineer (PE)
Professional Traffic Operations Engineer
(PTOE)
Professional Memberships
Institute of Transportation Engineers
(ITE)
Industry Tenure
23 Years
Sean’s wide range of
expertise includes:
transportation plan-
ning, traffic modeling
roadway design, bike
and pedestrian facili-
ties, traffic impact
studies, traffic signal
warrant analysis, parking studies, corridor planning
and access management. Sean’s experience in both the
private and public sectors; passion for safety and ex-
cellence; and strong communication and collaboration
skills can bring great value to any project. Prior to
starting Kellar Engineering, Sean was employed at the
Missouri Department of Transportation (MoDOT) as
the District Traffic Engineer for the Kansas City
District. Sean also worked for the City of Loveland,
CO for over 10 years as a Senior Civil Engineer
supervising a division of transportation/traffic
engineers. While at the City of Loveland, Sean
managed several capital improvement projects,
presented several projects to the City Council and
Planning Commission in public hearings, and managed
the revisions to the City’s Street Standards. Sean is
also proficient in Highway Capacity Software,
Synchro, PT Vissim, Rodel, GIS, and AutoCAD.
WORK EXPERIENCE:
Kellar Engineering, Principal Engineer/President – January 2016 – Present
Missouri Department of Transportation, District Traffic Engineer, Kansas City District – June
2015 – January 2016
City of Loveland, Colorado, Senior Civil Engineer, Public Works Department – February 2005 –
June 2015
Kirkham Michael Consulting Engineers, Project Manager - February 2004 – February 2005
Dibble and Associates Consulting Engineers, Project Engineer – August 1999 – February 2004
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 32
Access and Roadways (7-107)
The designated access route as shown in the attached Traffic Memo for the Eagle Springs Organic site
will be used both during and after construction and is granted to ACE DevCo NC, LLC, as an easement
that will later to be assigned to AES Eagle Springs Organic Solar, LLC, in benefit of the Project via the
terms in the Memo of Option to Lease Agreement provided in Section A3 (see part D).
It is understood that access permits for the temporary construction access and permanent access will be
obtained from the County as required and that an Access Permit from CDOT is not required for use of
the I-70 ramps. Also, as proposed, the Eagle Springs Organic solar development delivery, installation
and operation phases are not anticipated to create adverse impacts to traffic operations or to the
pavement and roadway surfaces along public roadways in Garfield County.
Please refer to Section B5 - Traffic Study for further details on road classifications and impact analysis.
The Point of Interconnection (POI) to the Holy Cross distribution system for the Project is located on the
property along the existing three phase power line pathway and easement that provides service to an
existing solar array on the site. No additional easements are required to support the Project.
ACCESS PERMITS, EASEMENTS, AND ACCESS ROADWAY DETAILS
Section B6
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 33
Improvements Agreement Waiver
Provided that the Eagle Springs Organic Solar project is not seeking or requiring public improvements
in services as part of its development, AES respectfully requests a waiver on the Improvements
Agreement described in Article 4-203.K.
IMPROVEMENTS AGREEMENT
Section B7
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 34
Development Agreement Waiver
Provided that the Eagle Springs Organic Solar project will be built in one continuous phase beginning as
soon as October 16, 2023, with an expected completion no later than December 31st, 2024, AES
respectfully requests a waiver on the Development Agreement described in Article 4-203.J.
DEVELOPMENT AGREEMENT
Section B8
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 35
Wastewater Infrastructure Waiver
The planned solar facility will be unmanned during operation with all site monitoring during operations
being managed remotely. Scheduled visits for landscaping or equipment maintenance are expected to be
less than 6 times per year unless more visits are necessary to replace faulty equipment. As such and with
no permanent employees onsite, there is no need for permanent wastewater collection or treatment
onsite during the operational phase of the facility as it will not generate wastewater. A waiver from the
wastewater system requirements of either a public sewer system extension or onsite wastewater
treatment system as detailed in Sec 7-105. B is hereby requested.
For the construction period, AES has secured a Will Serve letter from Redi Services, LLC, for
wastewater services for personnel. For porta-johns, typically one facility is provided for every ten site
workers.
See the following pages for the Will Serve letter.
WASTEWATER PLAN
Section B9
Metcalf Excavation, Inc
150 S Columbine Court
Parachute, CO 81635
(970) 285-6301 phone
(970) 285-6305 fax
www.metcalfexcavation.com
office@metcalfexcavation.com
March 2, 2023
Will Serve Letter – Eagle Springs Organic Solar Project
– Located off of Mamm Creek Rd (CR 315), Silt, CO 81652 (39.5266, -107.6980)
Metcalf Excavation, Inc will service this project with Dust Control and other Construction water
needs.
Thanks for the opportunity to provide this service to you.
Jason Metcalf
Owner
970-216-5404
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 36
Water Distribution System Waiver
The planned solar facility will be unmanned during operations with all monitoring being managed
remotely. As such and with no permanent employees onsite, there is no need for permanent water
distribution service to the facility. Any needs for water during construction (e.g. dust suppression) will
be served by trucking in water. If the operator decides to clean the solar arrays, de-ionized water will be
required and will be trucked in for that purpose. A waiver from the distribution system requirements as
detailed in Sec. 7-105. A is hereby requested.
For the construction period, AES has secured a Will Serve letter from Metcalf Excavation, Inc. for
requisite water supply to provide for dust control and mitigation, in addition to any other needs. Water
supply amounts and frequencies for construction needs is still to be determined by the final contractor.
See the following pages for the Will Serve letter.
WATER SUPPLY PLAN
Section B10
Friday, February 24, 2023
Redi Services, LLC
2143 Airport Road, Rifle Colorado 81650
Phone (970) 625-0233
Fax (970) 625-0232
AES Clean Energy,
Will Serve Letter for Eagle Springs Organic Solar project located Off of Mamm Creek Road (CR 315),
Silt, Colorado 81650 (39.5266, -107.6980)
To whom it may concern,
Redi Services, LLC will provide Waste Management services as needed for as long as required for the
project described as Eagle Springs Organic Solar project and located off of Mamm Creek Road (CR 315),
Silt, Colorado 81650 (39.5266, -107.6980). Redi Services has sufficient personnel and resources to serve
this project and is located within Garfield County at 2143 Airport Road Rifle, Colorado 81650. All waste
streams created would be disposed of at Garfield County Landfill Located at 0075 Co Rd 246, Rifle, CO
81650. If you have any questions, please feel free to contact me.
Respectfully,
Craig Abernathy
Regional Director - Western Colorado, Wyoming, Utah, Idaho
REDI SERVICES since 1982
Safety and excellence in industrial services
2143 Airport Rd, Rifle, CO 81650
t (970) 625-0233 | c (970) 309-1234 | f (970) 625-0232
e cabernathy@RediUSA.com | RediUSA.com
Follow us: LinkedIn | Facebook
Give us your Feedback: Client Survey
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 37
Provided that a large solar facility is deemed an Industrial use in a Rural zone and would be subject to
100 foot setback requirements defined in Article 7-1001 B, AES would like to request a waiver to this
requirement given the unique site location and circumstances of the proposed Project.
Principally, all but two directly adjacent parcels to the footprint of the solar project are owned either
directly by Ken Sack or entities under his ownership in Eagle Springs Organic LLC or Organic Growers
LLC. The only exceptions being to the southwest boundary of the Project in APN 217918400720
belonging to Bedrock Resources, LLC, and APN 217919100511 belonging to B&B Mamm Creek, LLC,
neither of which host any residences on their sites and both of which are involved in resource extraction
activities. The latter only marginally touches the Project’s hosting APN of 217917300732, and is largely
located on the opposite mesa to the other side of the Mamm Creek drainage.
As proposed, the project already sits 750ft from the rental residence to the west of the Project that
belongs to Ken Sack, the landowner with whom AES has an Option to Lease Agreement in place with
his entity, Eagle Springs Organic LLC. Other residences to the south in Mamm Creek drainage, or the
north along CR 346, sit about 150-200ft below the mesa where the Project would be sited, and thus
entirely out of the viewshed and would not be affected by the Project, in addition to already being more
than 100ft from the Project’s fenced limits.
Excerpt from Civil Site Plan showing location of Project in relation to adjacent parcels not owned by Ken Sack
INDUSTRIAL USE - WAIVER REQUEST TO 7-1001 B. SETBACKS
Section B11
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 38
LUDC Article 7 Standards 1, 2 & 3 and 7-1101
7-101: Zone District Use Regulations: The Land Use Change for Eagle Springs Organic solar facility
will comply with Article 3, Zoning, and any applicable zone district use restrictions and regulations.
7-102: Comprehensive Plan and Intergovernmental Agreements: The Land Use Change is in general
conformance with the Garfield County Comprehensive Plan 2030 (GCCP) and, to the best of AES’
knowledge, complies with any applicable intergovernmental agreement. The GCCP encourages the
development of renewable energy generation resources for the benefit of individuals, communities and
the County as a whole. The proposed site is outside the Urban Growth Area for Silt CO, but within the
designated 3-mile influence area for Silt, and the proposed use appears compatible with the Medium-
High density residential (2-6+ac) future use designation while supporting Garfield County’s vision for
renewable energy in the GCCP. In terms of scale, this use is low in profile. Solar energy generation is,
by nature, a passive use of energy generation technology and is consequently low in intensity in
comparison to other uses. The facility will not be a significant source of dust, glare, noise, air or light
pollution, and will not generate heavy traffic over its expected lifetime.
As such the proposed use, at a significant distance away from the rural residences nearby, is a good fit
on this property which is also bordered by oil and gas activities, a nearby transmission line and
substation, and other vacant land. Lastly, AES estimates that the Project will generate $584,940 in sales
tax receipts during construction and another $1,275,000 in property taxes over its operation lifetime.
Please see Appendix C7 for the SolarForge Glare Study that AES performed for the site indicating that
there are no anticipated incidences of “yellow” or “green” glare from observational points to the Project.
7-103: Compatibility: Solar farms are passive facilities that operate in silence, emissions-free, and
absent of daily traffic. Provided that the property siting the Project is in an area of high-density oil and
gas operations, including on the property itself, the proposed facility would be keeping in line with the
natural resource focus of land use in the area. Furthermore, given its location several miles from the
Town of Silt on elevated land above the valley floor, there are few nearby points from which the project
is in public view.
Lastly, much of the property previously had an approved Land Use permit in resolution No. 2011-49
(MIPA-6775) for a solar power generation system on approximately 77.7 acres, but which ultimately
only occupied 4.5 acres of land once built. AES was not responsible for that development, nor its
ongoing operation, but is pleased to be able to present this latest opportunity as the latest solution to
provide Holy Cross Energy and Garfield county with a flexible clean energy resource and takes comfort
in proposing a location that received prior approval for a similar project.
NARRATIVE RESPONSE TO ARTICLE 7 STANDARDS 1, 2, 3 AND SECTION 7-1101
Section B12
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 39
7-104: Source of Water: The proposed solar facility will not require water for operation. Any water
required for construction or maintenance will be supplied by a licensed water hauler. Please refer to the
Will Serve letters provided in Sections B9 and B10 from Redi Services, LLC and Metcalf Excavation,
Inc.
7-105: Central Water Distribution and Wastewater Systems: The proposed use, as an unmanned
facility, will not require central water distribution or wastewater systems.
7-106: Public Utilities: Proximity to electrical distribution infrastructure is the prime factor in selecting
this site for the proposed use, in addition to its elevated and isolated location away dense residential
areas. There is a three-phase line operated by Holy Cross Electric on-site that will dissect the proposed
solar array areas to which the Project will interconnect. The utility will draft, and the landowner will
execute, any necessary easements for the installation and maintenance of utility equipment required for
the interconnection of the solar facilities to the power grid, such as power lines and associated
equipment. It is expected that the utility transformers and other similar equipment will be mounted
above ground on concrete pads, and that any power lines connecting the facility to the adjacent power
line will be underground. Such utility easements will not be dedicated to the public. There are no prior
legal encumbrances on the parcel that would conflict with the likely path of such easements.
Please see Appendix C8 for a Letter of Attestation from Holy Cross Energy and confirmation of
interconnection capability to their distribution system.
7-107: Access and Roadways: The subject parcel already has legal access to the proposed array areas
from I-70, Mamm Creek Road and the private drive up to Eagle Springs Organic which will adequately
and safely serve the proposed use. Improvements to the above-mentioned roads will not be necessary
and traffic generated by the construction or operation of the facility is not anticipated to cause any
significant impacts to public rights-of-way.
Please refer to Section B5 for the Traffic Study detailing this further.
7-108: Use of Land Subject to Natural Hazards: AES has conducted desktop analysis and various
studies on the land and does not believe the designated solar array areas to be subject to significant risk
from natural hazards such as floods, avalanches, landslides, or earthquakes.
7-109: Fire Protection: All equipment installed at the proposed solar facility will be new, of good
quality, UL-listed, and will meet all established testing and safety parameters, including compliance
with NFPA 855 and UL 9540. The solar facility will be primarily constructed from non-combustible
materials such as glass, aluminum and steel. Electrical fires at solar generation facilities are rare and
there are safeguards built into the system design to shut down operations should dangerous conditions be
detected. Most fire concern with solar installations of this nature comes from the possibility of the
installation being impacted by brush fires that originate elsewhere but shift to threaten the equipment.
Mitigation of fire danger will be achieved by keeping the vegetation under the arrays and within the
perimeter fence trimmed and ensuring regular maintenance of the solar generation equipment. Sufficient
AES Eagle Springs Organic Solar – Land Use Change – Major Impact permit application (4/6/2023)
AES Eagle Springs Organic Solar – Garfield County 40
space of a minimum 15 ft. will be left between the solar array perimeter and the perimeter fence to allow
for access in case of fire, and the dedicated array driveways will be able to safely accommodate fire-
fighting trucks and equipment. The local fire protection district will be provided with the gate code for
access should it be required, and AES will follow the recommendations of district staff after their review
of this application. Prior to submission, AES engaged with Fire Chief Orrin Moon to integrate his
thoughts into our designs, specifically regarding turnarounds and perimeter access for his response crew.
Furthermore, AES leverages our 24/7 Remote Operations Center (ROC) as our “supervising station”.
The ROC uses a high security communications link to our Data Acquisition System (DAS) to monitor
sites and receive alarms. Alarms related to fire suppression systems, such as high internal air
temperature and impairment or discharge of fire suppression elements, are prioritized as “Critical”.
Upon receipt of a Critical alarm, the ROC will immediately contact the Project’s respective field
services technicians via phone call, regardless of the time of day. The technicians will be equipped with
local emergency contact information through prior consultation with local first responders and, upon
receiving notification from the ROC about a fire suppression system-related alarm, will notify those
local contacts.
Please see Appendix C9 for AES’ Fire Risk Assessment report for the proposed battery storage
configuration for AES Eagle Springs Organic Solar.
Prior to operation, AES will also provide first responders with a site orientation and presentation on the
facility and provide links to third party resources should further training on firefighting around electrical
system, including PV arrays, be desired.
See Appendix C12 for the standard Operations and Maintenance Schedule planned for AES’ facilities,
detailing frequencies with which systems, componentry, and vegetation need be inspected and managed
to ensure optimal performance and reduced likelihood of system failure or fire hazard.
7-201: Agricultural Lands: There is no known adverse effects of solar installations on adjacent or
nearby lands. In fact, it is possible to conduct agricultural activities on the same footprint concurrently
with solar operations, although that is not the intention for the Project. The system operator will follow
all county regulations, if applicable, regarding the control of domestic animals; maintenance of the
perimeter fence; and road maintenance and dust control.
It is not believed that this project has any nexus with the standards for irrigation ditches described in 7-
201.E, most specifically since none of the ditches on the property belong to the jurisdiction of a formal
ditch company, rather are private in nature and belong to Ken Sack and Eagle Springs Organic LLC.
Still, AES has implemented into its designs a minimum of 20’ setback along the length of any existing
ditches in proximity to the proposed Project and access will not be impeded, where they are otherwise
not avoided entirely. All crossings will be to code and not impede hydraulic flow characteristics.
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Upon completion of construction, AES will reseed all disturbed areas with a native grass species mix
that should readily reestablish vegetative cover with proper implementation and compete against
noxious weeds.
See the Site Plan in Section B2 and the Vegetation Management and Reclamation Plan in B4 for further
detail.
7-202: Wildlife Habitat Areas:
In all, no federally listed species under the ESA were deemed to have the potential to occur in the Project
area based on habitat conditions and only one candidate for federal listing does, the Monarch butterfly.
Even there, it is only a small area of suitable habitat of showy milkweed that was observed outside the
target Project area, so the species may occur only as a transient one and candidate species are not federally
protected under the ESA. No critical habitats were identified within the Project area.
Only one state special status species was identified with the potential to occur in the Project area, the
burrowing owl, yet at the time of the field survey only one mammal burrow was located alongside the
ditch south of the existing solar array. Rabbits were observed to be the potential occupants, however, and
AES plans to have a 20’ setback from existing ditches, limiting an impact should the burrowing owl be
discovered prior to construction.
No migratory birds were observed within the Project area during the field survey, yet as suitable habitat
does exist for the burrowing owl and other birds, including raptors within and adjacent to the Project area,
AES will conduct a pre-construction survey for nesting birds to minimize impacts should ground
disturbance be planned for the primary nesting season between April 1 and August 31, and its current
schedule will avoid disturbance to burrows between March 15 and October 31 when the burrowing owls
could be present.
While Bald eagles have been observed in the two-mile vicinity of the Project area, there were
predominantly found closer to the Colorado River, Silt River Preserve, and Ponds near the Rifle Garfield
airport, but not within or close enough to the Project area to result in effects to nesting eagles at the time
of survey. No Golden eagles have been observed in a two-mile radius to the Project area. Still AES will
have its preconstruction survey include observation for these birds and their nests as a precautionary
measure.
AES consultation with CPW also determined that the Project area contains habitat for big game species,
including mule deer (Odocoileus hemionus) and Rocky Mountain elk (Cervus canadensis). Specifically,
the Project area contains severe winter range and winter concentration area for elk and mule deer. In order
to minimize disturbances on elk and mule deer, Project activities would take proscribed measures between
December 1 to April 30, such as limiting activity and traffic to between the hours of 7am and 5pm. CPW
recommends that off-site mitigation occur at a 1:1 ratio to offset the loss of functional habitat due to the
Project (CPW 2021e; CPW 2021f), and given prior collaboration on this matter for the High Mesa solar
project, AES has already received consent from CPW and agreement with Aspen Valley Land Trust
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(AVLT) to donate appropriate funds to conservation efforts in GMU42 that will help preserve big game
habitat in the area. See Appendix C13 for a copy of the agreement between AES and AVLT.
The Project is not expected to result in the death of individual special status species (federal or state listed)
but would result in the loss of some habitat, primarily for big game species. Therefore, the Project would
pursue three key impact minimization measures for protecting big game wildlife, including: (1) wildlife
exclusion fencing, (2) seasonal construction limitations, and (3) mitigation for functional habitat loss.
Please see Appendix C2 for the complete Biological Resources report detailing USFWS and CPW
consultations and analysis, including the USFWS IPaC report, CPW Threatened and Endangered Species
lists, and site photos. Please also refer to Section B4 for the revegetation plan detailing an appropriate seed
mix and application rate recommended for the Project’s location from the Natural Resources Conservation
Service (NRCS), featuring mostly Blue grama, Western wheatgrass, Indian rice grass, and Galleta grass,
among others.
7-203: Protection of Waterbodies: The facility has been designed to avoid impacts on wetland areas near
the Project area, as the only survey wetland (W-01) skirts the edge of the access way along the private
drive to the Project area and will not be disturbed or impacted. While determined to not likely be
jurisdictional, AES is also taking measures to set back from existing private ditches by 20 feet. The
construction of the solar array will not require the removal of vegetation within the setback area, or the
permanent alteration of the current surface drainage characteristics. There will be no permanent storage
of hazardous chemicals or road salt within the Project area.
Please see Appendix C1 for a formal wetland delineation of the site.
7-204: Drainage and Erosion: As detailed in the Stormwater Memo and Management Plan, the
installation of the solar arrays will disturb much of the project footprint during construction prior to
revegetation efforts and will produce 58,583 sf (1.34 acres) of impervious area which covers 1.71% of
the project site. The project will be subject to the CDPHE NPDES permit requirements, an application
for which was submitted on April 6th, 2023. Onsite drainage patterns will be maintained with exception
to minor grading related to proposed gravel roads, therefore a Drainage Report is not required per
county standards. Stormwater Management (treatment & detention) are not required because the
proposed impervious area is not expected to significantly alter stormwater quality and quantity and
existing drainage patterns are maintained. Using a grass seed mix to restore all areas of
disturbance, stormwater quality will be improved through a native seed mix. The mix will also
decrease the quantity of stormwater runoff previously experienced on site. The proposed access road
will require the installation of a culvert. Initial sizing has been provided and will be refined as the site
design develops.
For further details, please see Section B2 for the Site Plan and page C1-06 for the Drainage and Erosion
plan. Also reference Appendix C6 for the Stormwater Memo and Appendix C6a for the receipt of
submission to CDPHE. The full Stormwater Management Plan submitted to the CDPHE will be sent to
the County as a separate addendum given its size.
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7-205: Environmental Quality: The completed facility is expected to have zero negative impact to air
quality, and no permanent storage of hazardous materials will occur onsite.
7-206: Wildfire Hazards: The subject property is designated as “Low to Moderate” fire danger
according to the Wildland Fire Susceptibility provided by Garfield County. Furthermore, the facility will
consist primary of noncombustible materials such as steel, glass and aluminum and vegetation will be
maintained to reduce potential fuels and associated fire danger, in addition to providing setbacks of at
least 15’ between perimeter fencing and array locations and the siting of gravel interior and exterior
access roads near key equipment as another form of fire break. The battery storage containers include
their own fire suppression equipment as detailed in Appendix C9.
Please see the attached Wildland Fire Susceptibility Index map from Garfield County in Appendix C10.
7-207: Natural and Geologic Hazards: The proposed site is not known to be marked as a Hazard Area
for avalanche, landslide, or rockfall. Construction is not proposed in an alluvial fan area or on slopes of
20% gradient or greater, or otherwise unstable slopes, nor within any designated mudflow areas or over
any known faults. A geotechnical investigation of the area revealed a mild to moderate potential for
corrosive soils to be present onsite. All concrete slab and driven steel foundations will be designed with
sufficient protection to allow the facility to meet its design life expectations according to the native
soils’ corrosive and/or expansive properties as detailed in the geotechnical report.
Please see Appendix C11 for the Geotechnical Engineering report prepared by Terracon.
7-208: Reclamation: After construction, all disturbed areas within the site fence line will be over-
seeded with the proscribed seed mix consisting of native, low-growth plant species and established in
accordance with County standards. No major changes to the existing site topography are proposed.
Please refer to the Site Plan in section B2 and the comprehensive Vegetation Management Plan in
section B4 for more details.
7-301: Compatible Design: Project area is zoned Rural, with Rural zoning on the all sides to the North,
East, South, and West. The proposed use is considered to be low-impact both with regard to the land on
the subject parcel and to neighboring parcels. Outside of the relatively short construction period, where
some noise, fumes, and dust can be expected from the operation of construction equipment, the facility
will not be a significant source of dust, odors, gas, fumes or glare throughout its operational life.
As such, and provided that the Project is sited on an isolated mesa above and out of sight of more
populated valley bottoms and is predominantly bordered by adjacent parcels owned by Ken Sack or his
associated businesses of Eagle Springs Organic LLC and Organic Growers LLC, this application would
like to request a waiver to the minimum of 100 ft setback from property lines as otherwise required by
its categorization as an Industrial Use per 7-1001 B. This waiver would allow for the most efficient
siting of the Project and allow it to minimize its overall footprint by avoiding spilling into adjacent
agricultural fields to achieve its target capacity under contract with Holy Cross Energy.
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Please see Section B-12 - Impact Analysis for discussion of glare potential at the project location.
7-302: Off-Street Parking and Loading Standards: The proposed use of a Solar Energy System –
Large is not found in Table 7-302.A. As an unmanned facility, permanent parking is not necessary for
this use. Designated areas for parking will be identified during construction, and no street or right-of-
way shoulder parking will be permitted either during the construction or operational phases of the
project. Site design is proposed to allow for trucks delivering equipment and construction materials to
pull completely off Mamm Creek Road and onto the private road access within the Project area before
unloading. Permanent loading bays are not appropriate for this use as there is no building proposed that
could accommodate loading bays, and very few additional deliveries of equipment or materials are
anticipated during the operational life of the facility.
7-303: Landscaping Standards: AES has prepared a vegetation management plan for all disturbed
areas within the solar array fence lines, with recommendations for the planting and establishment of
ground cover depending on the season in which construction is completed. All species will be selected
as native, drought-tolerant grass species with a relatively low growth profile, to minimize the potential
for shading of the solar arrays and to minimize susceptibility to fire danger. The land in question is dry,
with significant sun exposure and very little rainfall. As such, the planting of additional trees or shrubs is
not recommended in keeping with 7-303.C, where landscaping must be consistent with the unique
ecosystem and specific environment local to the development. There is very little likelihood that such
larger vegetation would be able to establish itself or thrive in such an environment unless regularly
irrigated.
Please see Section B4 for the Vegetation Management plan.
7-304: Lighting Standards: Perimeter or security lighting is not proposed for this facility. It is likely
that each equipment pad will feature a single task light with a manual switch, to be used if maintenance
or repair to the electrical equipment is required to take place outside of daylight hours. Such task
lighting will be downcast to illuminate the electrical equipment area and will not be oriented toward
neighboring properties.
7-305: Snow Storage Standards: Given that the facility will be unmanned, with no permanent parking
and a trip frequency of less than 1 vehicle per month during operations, there is no need for snow
storage at this facility.
7-306: Trail and Walkway Standards: Due to the remote location of the proposed facility far away
from shopping parks, schools, parks, trails and greenbelts, the inclusion of trails, walkways or other
similar improvements as part of this development is not considered to be recommended or necessary.
7-1101: Solar Energy Systems: There will be signage installed at the gate and at regular intervals along
the perimeter fence of each array, warning of electrical shock hazard, as shown on the site plans and
required by 7-1101.A. The remainder of the standards discussed in 7-1101.B are for Accessory Solar
Energy Systems and do not apply to this application.
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Impact Analysis to Items in Section 4-203G
Adjacent Land Use
Adjacent lands are primarily fallow agricultural fields or hay to the immediate west and irrigated hay
fields to the east along with an existing solar power array occupying 4.5 acres. Further to the west about
¾ mile away is the Rifle-Garfield airport. There are three oil and gas extraction pads to the northwest,
north and southeast, otherwise there is only one residential property in proximity to the project area,
which is owned by Ken Sack and rented to his ranch workers. To the east along the irrigated pivot field,
are several additional greenhouse operations, and further east is a major transmission substation fed by a
large transmission line that runs just south of the Project area. The next nearest residences at similar
elevation are located nearly ¾ mile to the southwest and largely out of sight of the Project. Given the
limited residential presence, the existence of oil and gas energy production on site, transmission power
infrastructure immediately adjacent, and a regional airport, the proposed renewable energy project
should fit into the character and acceptable uses for development in this zoning district.
Site Features
The full property studied for both access and Project footprint is approximately 140 acres (of a total 257
acres comprising the subject parcels), yet the anticipated fenced area of the Project would be 53.9 acres
with 78.3 acres of disturbance when factoring potential improvements to existing access driveways. The
Project will be sited on the flat portions of the property to avoid steep areas to the north and south where
the mesa drops to the valley floors. The area proposed for hosting the Project is entirely comprised of
fallow or hayed agricultural fields. Floodplains are situated at much lower elevations below the property
and far from the Project area.
Please see Appendix C2 – Biological Resource report for more in depth description of site features.
Soil Characteristics
See the summary of soils in the Project area as excerpted from the Critical Issues Analysis and Wetland
and Waterbody Delineation Report. There are no hydric soils within the project area or areas considered
Prime Farmland without the aid of irrigation, however, soil disturbances would be minimized to the extent
possible and Best Management Practices employed to minimize soil erosion/transport and control the
spread of non-native plant species. Soil types found on site are not preventative to effective construction
and operation of the solar farm and will not be altered.
NARRATIVE RESPONSE TO IMPACT ANALYSIS (SECTION 4-203G)
Section B13
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Please see Appendix C4 – Critical Issues Analysis report and C11- Geotech Engineering report for further
detail on soils and geology at the site.
Geology and Hazards
In relation to Section 7-207, page PV-C.01.04 of the Site Plan illustrating Pre-existing Conditions in
Section B2 shows the various categories of slopes in the project area, denoting them as less than 20%,
20% - 30%, and greater than 30%. As can be seen in the site plan, no portion of the solar array or access
infrastructure will be placed in the areas greater than 20%, and therefore does not prompt applicable Slope
Development minimum requirements and standards for steeper slopes.
Furthermore, there are no significant geological features or constraints that the Project would encounter
that would prove insurmountable to appropriate engineering design and professional recommendations.
The following excerpt from the Geotech Report summarizes model layers of subsurface formations:
Please see Appendix C11 for the Geotech report for further detail on soils and geology at the site.
Groundwater and Aquifer Recharge Areas
As drainage patterns will not be altered and there is a limited change of impervious surface area to
1.34ac-acre total, or 1.71% of the 78.5 acres of expected limits of disturbance, the Project is not
expected to have any impacts to groundwater resources. There will be no on-site waste or sewage
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disposal to affect such resources, and there will be no generation of other wastes or effluents to affect
surface runoff from natural conditions.
Environmental Impacts
Flora and Fauna
As detailed in the Biological Resources report, the Project has adhered to CPUC Rule 3668 and
conducted pre-development field wildlife surveys to identify, avoid, and minimize potential impacts to
wildlife and their habitats. TRC and AES has coordinated extensively with Colorado Parks and Wildlife
(CPW) to verify conclusions on limited wildlife impact and appropriate construction practices and
mitigation approaches.
Suitable habitat occurs in the project area for the Monarch butterfly, a candidate but not yet protected
Federally listed species, as well as one state species, the burrowing owl, and migratory birds. An in-
season survey was conducted within the proposed site on August 9, 2022, but did not detect definitive
presence of either the Monarch butterfly, burrowing owl, or Bald eagle, but did determine their potential
for existence and suggested a pre-construction survey to ensure appropriate measures are taken should
they be observed prior to commencement of work. As such, the project does not anticipate impacts to
listed species. This is supported by lands history of disturbance from agricultural activities. No other
federal or state protected species have the potential to occur in the proposed site or be impacted by
project activities.
Furthermore, per CPW’s Recommendations to Avoid and Minimize Impacts to Wildlife from Land Use
Development in Colorado, and the presence within the Project area of severe winter range and winter
concentration area for elk and mule deer, AES will limit construction activities between December 1 to
April 30 to daylight hour between 7am and 5pm. The Project will also employ wildlife-friendly fencing
and has already signed a commitment to support local conservation efforts the affected game
management unit (GMU) 42 in partnership with the Aspen Valley Land Trust (AVLT).
Lastly, use of native and drought tolerant seed mixes detailed in the Vegetation Management plan
should result in improved quality of grass and plant populations at the site and a decline in invasive
weed species. The site plan does not anticipate any clearing of trees or other prominent natural
environmental features, as the prior agricultural use has already disturbed soils and native vegetation.
Please see Appendix C2 for the Biological Resources report prepared by TRC on behalf of AES and our
response to 7-202 Wildlife Habit for further analysis and conclusions on impact assessment and
avoidance.
Wetlands
The delineation of waters of the US within the project area is based on the best professional judgement
of TRC’s team of wetland delineators. The wetland delineation identified eight ephemeral ditches, one
intermittent ditch, and one Palustrine Emergent wetland (PEM) 0.15 acres in size. The sole wetland is
located outside the focus Project area and off to the side of the existing driveway approach. It will not be
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impacted by the Project. The survey and analysis do not constitute an Approved Jurisdictional
Determination, which can only be officially rendered by the USACE Regulatory Branch through the
formal review process. However, none of the aquatic features identified in the project area are believed
to be a water of the US. Please refer Section 6.0 Discussion to the formal project delineation report for
specifics pertaining to why the aquatic features are believed to be non-jurisdictional. Still, effects on
aquatic features in the project area would be avoided during construction by complete avoidance of the
one wetland and the implementation of a 20-foot setback to the man-made ephemeral ditches.
See Appendix C1 for the Delineation and Proposed Jurisdictional Determination of the US – AES Eagle
Springs Organic Solar, LLC wetland report conducted in August 2022 and published in September 2022.
Nuisance
Solar energy projects operate quietly, unmanned without daily traffic, and without emissions, water
usage, or input fuels outside of natural sunshine. As a clean, renewable energy system, there are no
emissions produced from the Project itself.
Air Quality
AES will use best practices to manage dust during construction and will secure a General Air Permit as
part of its Air Pollutant Emission Notice (APEN). The site access roads will be graveled for long-term
use, and during the eight-to-ten month construction period appropriate measures will be taking to
minimize dust from the delivery trucks and tracking of mud, when traffic will be at its peak of the
Project’s lifetime.
Glare
With regards to concerns over glare from the solar farm, the solar panels are tracking in nature, which
means that they will rotate to face the sun as it passes overhead. This factor, combined with the solar
panel’s anti-reflective coating, will minimize any reflected light (glare). Modern PV modules use a
sophisticated anti-reflective (AR) coating to nearly eliminate the reflection of sunlight off the module
face. A typical human eye reacts to light wavelengths from 390 to 700 nanometers and in that spectrum,
the AR-coated glass on a module will have a transmittance of at least 93%. Transmittance is the percent
of radiation (light) that travels through a surface. Having such a high level of transmittance is valuable
because it means that more light is traveling through the glass and onto the solar PV cells rather than
reflecting off the surface. With transmittance values higher than a body of water or a glass window
without an AR coating, the potential for glare is lower for a solar farm compared to these other surfaces.
Please see Appendix C7 for the SolarForge Glare Analysis performed specifically for the Eagle Springs
Organic project’s location, taking in several observational points adjacent to the project including homes
and roadways. ForgeSolar tools are used throughout the world by industry, academia, and military to
evaluate PV glare. Based on the R&D 100 Award-winning SGHAT technology, ForgeSolar
accommodates FAA, zoning, and other regulatory requirements.
No green or yellow category glare was detected in the analysis from any point ran in the observational
analysis. This is in large part due to the east-west tracking nature of the facility and fluctuating tilt of the
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panels so that in no instance are they ever oriented directly at any homes or road ways at discernible
heights. The location of the Project is about ¾ mile east of the Garfield-Rifle airport. AES filed Forms
7460 to comply with results from the Notice Criteria Tool for the Project, and the FAA subsequently
issued a Determination of No Hazard. AES also spoke to Brian Condie, Director of the Garfield-Rifle
Airport and provided site plans of the proposed Project on 2/3/2023 and received no feedback of
concern.
Noise
No action necessary. Installation of solar arrays create minimal amount of noise and vibrations.
Typically, the PV inverters and transformers will emit minimal noise at ~50 decibels when standing
within 10 feet, which is equivalent to a conversation level within that range. During operations the
facilities will be unmanned and will operate quietly and automatically with only infrequent maintenance
visits.
Hours of Operation
The Project once in operation, will operate 24/7 but will be unmanned and remotely monitored for
performance and alerted for necessary maintenance. Maintenance trips to the site will be no more than
once per month by a small crew of technicians, and likely even less than that frequency. During
construction, work hours will be limited to daytime hours and within 7am-7pm time frame, and
primarily on weekdays unless circumstances require weekend work. AES will comply with any working
hour restrictions that the county indicates outside of these standards conditions.
Lot Coverage
AES notes that Zone District Dimensions per Table 3-201 include a 15% Maximum Lot Coverage in
such districts and is supplying the following calculations excerpted from Appendix C6 – Stormwater
Memo demonstrate that the total coverage ratio of the Project to that of the disturbed area of the property
to be far short of the maximum lot coverage requirement.