Comprehensive Plan Amendment Zoning Change Proposal

Royal Slope Solar LLC Grant County, Washington 1. Provide a detailed statement of what is proposed to be changed and why:

Royal Slope Solar LLC (Applicant) proposes to amend the Grant County Comprehensive Plan and Zoning Map. Applicant proposes to change the zoning of thirty-two parcels (totaling 2,988 acres) in western Grant County south of State Highway 26 and to the northeast of Wanapum Dam (See Maps in Appendix B). The proposed change would rezone twenty parcels currently zoned as Rural Remote (RRem) and twelve parcels currently zoned as Agriculture (Ag) to Rural Resource (RRes). These parcels and acreage amounts are identified in Figures 1 and 2. Applicant does not propose any text changes to the Unified Development Code. The application responses follow the order of those shown in the Grant County Comprehensive Plan Amendment application form.

The proposed Comprehensive Plan Amendment would support new business opportunities for existing landowners, capitalize on Grant County’s unique natural resource setting, and provide economic development dollars for the local community. In particular, the Rural Resource zoning designation would provide land-use flexibility for landowners and the County to consider partaking in the solar energy economy in some locations, while continuing agricultural production in others. This approach is consistent with the County’s policies, including economic goals to support rural diversification and land use innovation in the natural resource sector (Grant County Comprehensive Plan Goal ED 1-7). Additionally, it follows the County’s goals of encouraging public health, safety and general welfare without unduly jeopardizing private property rights through development of a system of coordinated plans (Grant County Comprehensive Plan Goal LU-2.1).

The Rural Resource designation, as described in the Grant County Master Plan (see page 116 of the Grant County Comprehensive Plan), is an innovative land-use designation for over 295,000 acres of rural areas in the County. The Rural Resource designation includes areas that may not be as suitable for intensive and productive farming as Agricultural lands, but where some agricultural use can occur with land management. Oftentimes, these areas are not prime farmland and are outside the Columbia River Basin Project (as is the case for the requested rezone). The Rural Resource land use designation is designed to support the agricultural economy of Grant County through complementary land uses, such as utility infrastructure, which makes it an exceptional designation for guiding potential infrastructure additions near the Vantage substation.

The proposal is needed to support business opportunities on private lands in Grant County. The existing landowners have entered into necessary land agreements with a private company for a potential project. Long-term development plans, enabled by the approval of this amendment, would also support increased economic development and job creation for surrounding local communities and stakeholder groups, boosting the overall economic vitality of Grant County.

Figure 1 and Figure 2 identify the acreage amounts and parcel numbers proposed for rezone.

1 Figure 1: Acres proposed for Rezone Existing Zoning Acreage Rural Remote 1301 Agriculture 1687

Figure 2: Parcel Numbers proposed for Rezone

Existing Zoning Rural remote Agriculture 150234003 150362001 150232000 150234013 150361000 150231000 150234014 150234005 150229000 150234000 150234006 150228000 150234004 150234009 150230000 150234012 150234010 150247000 150234015 150234001 150248000 210563000 150234007 150246000 150358001 150234008 150246001 150356001 150234011 210562000 150234002 150248001

2. Provide a statement of anticipated impacts to be caused by the change, including geographic area affected and issues presented:

This Comprehensive Plan Amendment application, as directed by the Grant County Code and Washington State Environmental Policy Act, is a non-project action. The application addresses the merits of the zone change generally and does not commit landowners to a specific use or impact. Without a proposed action, the proposal does not have direct impacts. However, there are changes in land use policy that should be considered when determining potential indirect impacts of a zone change.

The Grant County Code considers new projects through zoning designations where types of uses are categorized as authorized, discretionary, conditional, or prohibited. For a non-project land-use action, like the proposed Comprehensive Plan Amendment, potential impacts are limited to those actions that were not allowed previously. The application does not consider uses subject to a Conditional Use Permit because those uses may be considered and denied by County officials on a case-by-case basis and warrant a separate SEPA process.

Accordingly, there are twenty-four new land uses that would be authorized in areas rezoned from Rural Remote to Rural Resource. These new land uses are largely related to agricultural activities (as identified in Figure 3). Of the twenty-four new land uses that would be allowed in the Rural Resource zone, half are related to agriculture activities and the remainder target natural resources and utility uses (such as fairgrounds, wireless communication facilities, and outdoor event spaces). As expanded upon in Section

2 3, these complementary land uses may help facilitate agriculture-related activities on more productive lands nearby. All uses would be fully contained within respective parcels subject to a new zoning designation.

The Grant County Code would consider “new” land use as those identified as permitted use or discretionary use. Any land use would be required to abide by all development standards, including for noise, visuals, and impacts to adjacent uses. Grant County has a robust development and building code for protecting property rights and the wellbeing of the public.

Figure 3: Changes in Land Use Permissions between Rural Remote and Rural Resource

Use Code in Rural Use Code in Rural Effect on permissibility Use Remote Resource Reclamation of Mineral Extraction Sites A C More procedure, tighter restriction Emergency Service Facilities A D More performance restrictions Assembly Facilities C A Less procedure, less restriction County Fairgrounds C A Less procedure, less restriction Feedlots, farm oriented C A Less procedure, less restriction Religious Assembly Facilities C A Less procedure, less restriction Agriculturally-Related Industrial Uses C D Allowed, with less procedure Commercial Communication Facilities C D Allowed, with less procedure Veterinary Clinic, Hospital C D Allowed, with less procedure Wireles Communication Facilities C D Allowed, with less procedure Asphalt and Concrete Batch Plants, Permanent C P No longer allowed Golf Courses C P No longer allowed Major Campgrounds C P No longer allowed Recycling Center C P No longer allowed Roadside retail sales stands, agricultural products, permanent C P No longer allowed Water Ski Lakes C P No longer allowed Roadside retail sales stands, agricultural products, Seasonal D A Fewer performance restrictions Un-named Transportation Uses D C Less procedure, less restriction Community Parks D P No longer allowed Agricultural processing P A Allowed, with limted restrictions Agricultural product visitor and retail sales facilities P A Allowed, with limted restrictions Government offices P A Allowed, with limted restrictions Mobile homes P A Allowed, with limted restrictions Nursery, wholesale P A Allowed, with limted restrictions Retail sales of agricultural products P A Allowed, with limted restrictions Automotive service and repair P C Allowed, with more procedure and restrictions Bed and breakfast inns P C Allowed, with more procedure and restrictions Biosolids, Municipal Sewage Sludge, or Septage Utilization or Disposal P C Allowed, with more procedure and restrictions Day care, type 2 P C Allowed, with more procedure and restrictions Eating establishment P C Allowed, with more procedure and restrictions Livestock sales yard P C Allowed, with more procedure and restrictions Major utility developments P C Allowed, with more procedure and restrictions Storage and sale of fertilizer, pesticides, herbicides and soil sterilants P C Allowed, with more procedure and restrictions Storage and treatment of sewage sludge and septage P C Allowed, with more procedure and restrictions Agricultural equipment storage, sales, repair and rental services P D Allowed, with performance restrictions Feedlots, commercial P D Allowed, with performance restrictions Livestock maintenance P D Allowed, with performance restrictions Nursery, retail P D Allowed, with performance restrictions On-site storage and treatment of hazardous or dangerous waste P D Allowed, with performance restrictions Outdoor events, temporary P D Allowed, with performance restrictions Outdoor festivals, temporary P D Allowed, with performance restrictions Slaughter, packing, and rendering facilities P C Allowed, with more procedure and restrictions Commercial Communication Facilities C D Allowed, with less procedure Nursery, wholesale P A Allowed, with limited restrictions A - Authorized Use C - Conditional Use D - Discretionary Use P - Prohibited Use

3 For the change of zoning from Agriculture to Rural Resource, there are no changes to authorized, discretionary, or conditional uses as presented in the 2018 Comprehensive Plan. Accordingly, 1687 acres would see no changes in allowable land uses. The Grant County Comprehensive Plan makes clear that the Rural Resource zone is a designation that does not preclude or deter agriculture but allows for a more expansive vision of the natural resource-based economy to include other potential uses. Transferring lands from Agricultural to Rural Resource will maintain development densities, but better address and allocate other suitable land uses. There are minor changes to setbacks, but these design standards would not have a substantive impact on the environment or land-uses in this portion of the County.

Finally, please see a completed Grant County SEPA Checklist for the proposed Comprehensive Plan Amendment application included in Appendix D.

3. Explain why the existing comprehensive policies should not continue to be in effect or why existing policies no longer apply:

- Rural Remote (RRem) designation: The Rural Remote designation is applied to areas of Grant County to indicate remoteness or limited development opportunity (See page 97 of the 2018 Grant County Comprehensive Plan Update). The primary land uses in these areas are resource- oriented activities, such as farming and mineral extraction. The parcels proposed for rezone have a significant development opportunity due to proximity to major infrastructure, including high-voltage transmission lines, interstates, and State highways. The Rural Resource designation would allow property owners to potentially capitalize on these opportunities, while maintaining restrictions and procedures to keep land uses focused on natural resources. Most of the new authorized uses in the Rural Resource zone would be related to agricultural production (see Figure 3), which supports business opportunities for farmers. Any other types of uses, such as major utility infrastructure, would be subject to a Conditional Use Permit process and the associated public process.

- Agricultural (Ag) designation: The permitted, discretionary, and conditional uses in the Agricultural zone are consistent with those in the Rural Resource zone. The Rural Resource zone, however, may afford current property owners with greater flexibility in land management and the ability to diversify current operations. By expanding the vision in these areas to a broader natural resource economy, the Rural Resource zone provides multiple sources of revenue for landowners and the County, while retaining rural land uses. The Rural Resource zone would not preclude or deter regional agricultural production in the area. Instead, it would allow the current landowners to direct agricultural production to the most productive and economical portions of their property, while considering compatible development actions elsewhere.

In 2018, Grant County reviewed all Agriculture designations as part of its Comprehensive Plan update. As part of that exercise, 295,400 acres of land in the Agricultural zone was transferred to the Rural Resource zone in order to better meet the needs of the County and integrate State policies for resource lands. The criteria for evaluating inclusion in the Agricultural land-use designation was based upon three factors: urban growth, production capability, and long-term commercial significance.

4 o “The land is not characterized by urban growth.” (WAC 365-190-050a): All parcels meet this criterion. o “The land is used or capable of being used for agricultural production.” (WAC 365-190- 050b): All parcels meet this criterion as they are currently irrigated by a family farm operation. However, public maps show that much of the proposal area requires substantial management to be farmed. The following constraints and difficulties exist for agricultural production on this land located outside the Columbia Basin Project: ▪ Hazards of water erosion ▪ Surfaces must be sloped to drain while minimizing concentrated flows to reduce runoff ▪ Hazards of soil blowing ▪ Shallow bedrock ▪ Limitations on soil tillage ▪ Impacts from soil pulverization due to substratum and erodible soil ▪ Low annual precipitation ▪ Limitations on timing of seedings ▪ Columbia River Basalt underlies the Loess at most locations and typically consists of fresh to moderately weathered, hard, fractured basalt. The spacing of fractures generally varies from several inches to several feet. Activities are limited at a shallow distance ▪ Alfalfa productivity is considered low for non-irrigated Alfalfa Hay based on NRCS o “The land has long-term commercial significance.” (WAC 365-190-050c): This criterion has multiple factors, which indicate that the parcels currently designated as Ag would be better classified as RRes.

▪ i. The classification of prime and unique farmland soils as mapped by the Natural Resources Conservation Service

The proposal parcels currently zoned as Agricultural do not contain prime farmland and do not provide property owners with significant commercial opportunities compared with other portions of their ownership profile or other parcels within Grant County. As depicted in the figure below, there is no prime farmland and less than twenty five percent of cropland is farmland of unique importance. Per NRCS policy, unique farmlands are those that are particularly adept at growing a single type or variety of crop. However, in the case of the proposal area, areas identified as unique farmland do not demonstrate superior farming conditions or receive special land use management. In fact, much of the unique farmland is not farmed either because it’s outside of crop circles or it is used for other uses, such as material laydown areas.

5 Red area: not prime or unique farmland Blue area: unique farmland

▪ ii. The availability of public facilities, including roads used in transporting agricultural products

Parcels currently zoned as Agricultural are outside of the Columbia Basin Project Farm Units, which is the direct beneficiary of water diversion projects along the Columbia River. As depicted in Figure 15 in the Mapfolio of the Grant County Comprehensive Plan, the proposal area does not have as many Columbia Basin Project Canals nearby compared with other agricultural areas in the County. The land in this portion of the County does not have superior roads or access compared with other portions of Grant County, which generally has a wide network of farm roads throughout rural areas. Internal roads in the proposal area are not maintained by the County and therefore, must be maintained by the private landowner. Finally, there is a major network of electrical transmission lines in the area, which can support several uses, including agricultural operations.

6 ▪ iii. Tax status, including whether lands are enrolled under the current use tax assessment under chapter 84.34 RCW and whether the optional public benefit rating system is used locally, and whether there is the ability to purchase or transfer land development rights

Not applicable.

▪ iv. Availability of public services

The internal roads in the proposal area do not receive maintenance by the County. The area is outside Columbia Basin Farm Units. While the property may receive ancillary benefits from water diversion projects, it is not formally identified by US Bureau of Reclamation. The area receives equivalent public services as other rural areas in the County, including fire and emergency services.

▪ v. Relationship or proximity to urban growth areas The proposal area is outside of a UGA.

▪ vi. Predominant parcel size

The parcels range from 87 acres to 326 acres.

▪ vii. Land use settlement patterns and their compatibility with agricultural practices

The vicinity of the proposal area is used for agriculture production or is left vacant under management by federal agencies. The area has a substantial network of transmission lines to the south and west.

▪ viii. Intensity of nearby land uses

Federal land to the south is vacant and nearby private lands primarily host agricultural facilities and farms.

▪ ix. History of land development permits issued nearby

There is a large network of transmission lines that terminate at the Vantage Substation. These high-voltage lines are owned by different utilities and operate at voltages ranging from the distribution level to 500-kV.

▪ x. Land values under alternative uses

7 Given the substantial network of electrical infrastructure, a land use alternative that incorporates electricity generation resources and agriculture may be valuable to the landowner and County.

▪ xi. Proximity to markets

Larger regional markets for agriculture include Moses Lake and Ellensburg. The proposal area sits alongside infrastructure making up the Mid-C wholesale energy market.

Applicant concurs with the County that the proposal area has sufficient land and water availability for irrigation, but respectfully encourages the County to consider the long-term commercial significance of irrigated areas. As depicted on page 8 of this application, majority of the land is not identified as farmland of statewide importance or prime farmland. In addition, much of the land is described as “suitable with management” based on NRCS data and the parcels are not within the Columbia Basin Project. Applicant has found geotechnical constraints for a wide variety of land uses based on on-site fieldwork. Accordingly, applying the Rural Resource zone to the proposal area is also in line with the County’s approach to Rural Resource designations in the latest Comprehensive Plan update.

4. Provide a statement of how the proposed amendment complies with the community vision statements, goals, objectives and policies found in the comprehensive plan:

The proposal complies with vision statements applicable to the site-specific Comprehensive Plan Amendment application:

- Promote a healthy, diversified, and sustainable local and regional economy by supporting existing local businesses and agri-tourism, making prudent infrastructure investments, and encouraging new business that is compatible with and complementary to the community.

The Rural Resource zone is an appropriate zoning designation for supporting and diversifying the natural resource sector of the Grant County economy. Its application to the proposal area is appropriate so that the County can consider new, private investments in the local economy and ways to enhance existing infrastructure. The Rural Resource zone is compatible with and complementary to this portion of the County as there is a significant presence of high-voltage electrical infrastructure, which points to the County’s leadership on energy development in the region.

- Protect and preserve the natural beauty, rural character, and variety of lifestyles that define the community.

The Rural Resource zone targets rural industry and natural resource-based land-uses. This application can further the rural character in the area and can help support diverse land-uses and lifestyles.

8 - Protect and conserve agricultural resources, and prevent inappropriate conversion of prime agricultural lands.

The proposal area does not overlap with prime agricultural lands.

- Manage growth effectively to prevent inappropriate or premature conversion of undeveloped land and to minimize incompatible land uses and the cost of public and private services.

The proposal area is in a commercially significant location due to existing electrical development surrounding the Vantage substation and Wanapum Dam.

- Promote open, responsive, and accountable local government that works to create a true sense of community and to create democratic processes on all levels.

The Rural Resource zone allows for public engagement at the project-level through the Conditional Use Permit process.

Please see Appendix C for Applicant responses to Grant County goals and policies.

5. Provide a statement of how capital facilities and transportation elements support the proposed amendment:

The Grant County Code defines capital facilities as “physical structures or facilities owned or operated by a government entity which provides or supports a public service or improvements included in a capital budget” (See Grant County Code Chapter 25.02). Public infrastructure plays a key role in the Applicant’s request to rezone identified properties to the Rural Resource designation. This portion of the County has an extensive network of high-voltage transmission lines operated by local and regional utilities. Additionally, the proposal area has easy access to state highways as well as Intersate-90. The existing zoning is not conducive to considering opportunities that build off of previous investments by utilities and governmental entities in local capital facilities.

6. Provide a statement of how the proposed amendment affects the implementation of the unified development code (Titles 22, 23, 24, 25 of Grant County Code) and what changes to the unified development code are necessary to bring them into compliance with the comprehensive plan:

The amendment facilitates implementation of the Unified Development Code and Washington Growth Management Act by designating resource lands in rural portions of Grant County. The proposed amendment requires site-specific map updates and does not require text changes to Grant County policy.

9 7. Has the proposal been subject to any public review prior to submittal? Is so describe the review that was provided

On November 14. 2019, Applicant attended a pre-application conference with Grant County Development Services (see Appendix E). Additionally, Applicant has met with stakeholders in the County, including Port of Royal Slope and the Grant County Economic Development Council.

The following sections apply exclusively to policy changes and UGA Boundary changes only 8. For Comp Plan and UDC Text or policy changes only, please provide specific suggested new language and indicate which section of the comp plan or UDC the new language should be located: 9. Provide a detailed statement of how the urban growth area (UGA) boundary complies with the comprehensive plan land use designation (See Chapter 4 of the comp plan): 10. UGA Amendments must be supported and dependent on criteria set forth in the Growth Management Act (GMA) such as population forecasts, allocated urban populations, existing urban densities, infill opportunities, availability of adequate public facilities and sufficient service capacity, proximity to natural resource lands and critical areas. Please provide all necessary evidence and support for the proposed amendment relevant to these requirements: 11. Describe the presence (or absence) of all urban public services including domestic water, sanitary sewer, storm drainage, transportation infrastructure and services, fire protection, school/educational services 12. If the urban public services listed above are not currently available please describe how the proposed amendment will be able to provide these services in an efficient, timely, and economically feasible manner: 13. Describe the intended development of the site (specifically including discussion about anticipated density and intensity) and how the intended development will be compatible with contiguous development within the UGA: 14. If the proposal includes resource lands, demonstrate the following: a change in circumstances pertaining to the comprehensive plan, or a change in circumstances beyond the control of the property owner pertaining to the subject site; or an error in initial design; or new (updated) information on the resource land or critical area status:

15. Describe the historic use of the site and surrounding properties:

Land use in the proposal area includes a utility corridor for overhead transmission lines owned by BPA, Grant County PUD, Pacific Power, and Avista. Historically, the proposal area has either been used for agriculture or left vacant. The area currently zoned as Rural Remote was converted around 2005. The area currently zoned as Agriculture was converted before 2000. The proposal area is on the outer fringe of a family-owned farm operation, which continues to be in operation. The surrounding parcels not owned by the family operation have historically been left vacant and are under ownership and management by the US Bureau of Reclamation.

Applicant has also heard about the historical and cultural significant of the Columbia basin to the region’s indigenous tribes. Applicant fully intends to include the relevant tribal entities in the environmental and cultural impact studies of the proposal area during any future project-level permitting processes.

16. Describe the population density of the surrounding area:

The area surrounding the proposed parcels is zoned primarily as Rural Remote and Agriculture. The Agricultural designation allows for one dwelling per 40 acres. The closest residential area is the town of Beverly located approximately 4.5 miles to the south. The federal lands surrounding the parcels do not host residential areas or population centers.

17. Describe existing soil conditions and the suitability of the soil for on-site septic disposal:

10 Please find a geotechnical report included in Appendix F. There are no active faults, mapped landslides, or areas of liquefaction. The proposed Comprehensive Plan Amendment would not result in the creation of on-site septic disposal. Please see Section 19 for a discussion on agricultural production.

18. Describe the sources of domestic and irrigation water availability at the site:

Water for the site comes from existing water rights held by the landowner.

19. Describe the land’s suitability for agricultural uses/activities

The land in the proposal area is currently irrigated and farmed primarily for alfalfa. All parcels are located outside official Columbia Basin Project Farm Units. The land is not prime farmland as depicted on page 428 of the 2018 Grant County Comprehensive Plan Amendment. There are no lands of statewide or local importance or lands under the Conservation Reserve Program.

Source: 2018 Grant County Comprehensive Plan Update

11 The land on the eastern portion of the zone change request currently zoned as Rural Remote was converted in 2005. As indicated in the Geotechnical Report (Appendix E), there are soil conditions that can present challenges for agriculture, including bedrock and cobble. The report states that Columbia River Basalt is present at shallow depths across most of the site. In many locations, the land requires substantial management to be suitable for agriculture. Given these challenges, the landowner has expressed interested in exploring other economic opportunities in order to support agricultural land uses elsewhere in its more productive land portfolio within Grant County. Please also see page 5 and 6 for a discussion of resources and constraints.

20. Describe any known archaeological or cultural resources on the site:

The area has generally not been surveyed for cultural or historic resources. There are no properties or resources included on the National Register of Historic Places. However, the Vantage to Columbia No. 1 Transmission Line on the western portion of the proposal area has been determined to be eligible for the National Register by Washington Department of Archaeology and Historic Preservation.

In 2016, a multi-agency effort was completed to study potential impacts from a new high-voltage transmission line: Vantage to Pomona Heights 230-kV. The construction of this line has not been completed. However, the federal Environmental Impact Statement considered archaeological and cultural resources in the vicinity of the Vantage substation (located to the southwest of the proposed rezone). No resources were identified around the substation area that would change the design or preclude development of a new transmission line.

Grant County and the State of Washington may require field surveys or other actions in the case of a project-level permitting action at the identified location.

21. Describe any other known critical areas (wetlands, steep slopes, fish and wildlife conservation areas, etc.) on the site:

There is overlap with the following critical areas and the proposal area:

- Geologically hazardous areas: The northwest portion of the site is identified as having high erosion due to inland dune features. The proposed Comprehensive Plan Amendment would not result in identifiable impacts to this area. Moreover, as stated in the Grant County Comprehensive Plan (see page 227), some land use activities may be appropriate on geologically concerning areas based on professional opinion of a licensed engineer and review by Grant County Development Services.

- Fish and wildlife areas: Portions of the proposal area are identified as Priority Habitat Areas by the WA Department of Fish and Wildlife. From a desktop review, this appears to be primarily related to the inland dunes (described previously) and plant species that specialize in this type of terrain. The proposed rezone would not impact these species or inhibit Grant County’s ability

12 to help conserve or provide development stipulations to assist in biological protections. A report on inland dunes in Washington is included in Appendix G.

22. Describe any and all public services and utilities available at the site:

The following utilities operate high-voltage transmission lines that run through the Vantage Substation (located to the southwest of the parcels identified for zone change): Grant PUD, BPA, Pacific Power, and Avista. Roads within the proposal area are not maintained by the County. The area is outside of the Columbia Basin Project official farm units.

23. Provide the names of all abutting property owners: - US Bureau of Reclamation - Parrish Stakkeland - WA Department of Natural Resources - Debra K Thaemert - State of Washington Department of - Michael Brown, Brown Boy Feed Transportation (highway) - Snoqualmie Village Summit

Comprehensive Plan Amendment Criteria Approval Required for all Amendments 1. The change would benefit public health, safety, and welfare:

No major land use changes are expected to take place until the Conditional Use Permit stage (see Figure 3 describing changes to authorized uses from proposal). Therefore, the proposed change would benefit the Grant County public by supporting the business environment in the County. The Rural Resource zone allows for continued agricultural production within the proposal area, while giving landowners and businesses an opportunity to propose development ideas to Grant County decision-makers. The rezone does not present health, safety, or welfare concerns to Grant County communities or citizens.

2. The change is warranted because of changed circumstances or because of a need for additional property in the proposed land use designation:

Market conditions for the energy sector have changed drastically within the region and the State of Washington. The cost of solar technology has dropped significantly and utilities across Washington have created plans that include large procurements of new, low-carbon energy generation projects.

The zone change would allow for a conditional use permit to consider if new land in the area is appropriate for additional utility infrastructure. By allowing the option for a CUP process for new solar energy projects in these areas, Grant County can play an even more significant and diversified role in the renewable energy economy, as well as provide direction on siting and design elements.

3. The change is consistent with criteria for land use designations specified in the Comprehensive Plan:

13 The Grant County Comprehensive Plan specifies the following for Rural Resource lands:

“The purpose of this designation is to identify areas that have some agricultural opportunities in a rural setting. Such areas are those that are not as suitable for intensive +6 farming as Agricultural Resource lands, but some agricultural use can occur with land management. The primary land uses in these areas include, but are not limited to grazing, mineral extraction, limited dryland agriculture, open space, and residential. The maximum density is one dwelling unit per 40 acres. Lands are typically too far from the urban area to enable cost-effective provision of public services. Such areas require on- site water and sewer service, may be outside of fire service, or have other site constraints. They may be outside existing main road networks and distant from existing utilities.” Grant County Comprehensive Plan pg. 98.

The area meets criteria for land use designations as the proposal targets opportunities with natural resources and infrastructure associated with the Vantage Substation. The proposal would not require additional public services. The land has geotechnical constraints for certain land uses and agricultural production requires management. Major investment opportunities underline the need to designate the area as a Rural Resource zone.

4. The change will not be detrimental to uses or property in the immediate vicinity of the subject property:

The Rural Resource designation is applied widely throughout Grant County. Land uses in the Rural Resource zone many times mirror those in the Agricultural zone. Moreover, Grant County has a robust code and decision-making process to minimize or eliminate impacts from future projects issued within the Rural Resource designation. No impacts to neighboring parcels or general vicinity have been identified.

5. The change has merit and value for the community as a whole

The Rural Resource designation has adequate safeguards for protecting the Grant County community, while also providing procedures to consider and partake in a wide spectrum of natural resource- oriented, business opportunities. New projects considered under the Rural Resource designation may grow the local tax base and create new local jobs.

6. The change, if granted, will not result in a group or property owners enjoying privileges and opportunities than those enjoyed by other property owners in the vicinity where there is no substantive difference in the properties themselves that justifies different designations:

The change would not unfairly benefit property owners at the site of the proposed rezone beyond what exists on the ground currently. The private land in the proposed rezone is closest to the Vantage Substation. This Substation and associated electrical infrastructure provide major business opportunities

14 for local property owners interested in participating in the energy sector, partnering with energy companies, and supporting utility operations.

7. The benefits of the change will outweigh any significant adverse impacts of the change:

As discussed in question 3, there are no readily identifiable impacts from the proposed change in zoning. Washington’s SEPA classifies comprehensive plans (and changes made thereto) as “non-project actions” that involve policies, plans, and programs rather than a site-specific project (see Grant County Comprehensive Plan page 242). Majority of new authorized uses are land uses related to agricultural production and Grant County has robust policy and public process for considering new projects and land-uses in the Rural Resource zone.

8. The change is consistent with the purpose and intent of the comprehensive plan and the requirements of the GCC Titles 22, 23, 24, and 25:

Affirmed. Please see Appendix D for Applicant responses to Grant County Goals and Policies listed in the Comprehensive Plan. The application address Title 24 of the Grant County Code by including a SEPA Checklist and identification of any Critical Areas and Cultural Resource Lands. The proposal area does not overlap with Shorelines of the State of Washington or FEMA-identified floodplains.

9. The change complies with all or other applicable criteria and standards of Chapter 25.12:

Application includes all materials and requirements listed for Comprehensive Plan Amendments in Chapter 25.12.

Zone change criteria for approval required for all amendments which include a zone change 1. The proposed rezone will not be contrary to the intent or purposes and regulations of the Grant County Code or the Comprehensive Plan

The Rural Resource designation is applied throughout Grant County. As part of the 2018 Comprehensive Plan Update, the County elected to change a considerable amount of rural land to the Rural Resource zone. These lands were identified as not being the County’s most valuable or productive farmlands, but where some agriculture may still take place and where there might be other natural resource opportunities. The proposed zone change in this application is also consistent with this line of thinking since the parcels are outside Columbia Basin Project Farm Units and is not identified as prime farmland. Moreover, application of the Rural Resource designation can be an effective tool for meeting economic goals listed in the Comprehensive Plan.

2. The suitability of the property in question for the uses allowed under the proposed zoning district:

15 Existing uses on the property are centered around agricultural production. These uses could continue, while also giving the County and landowners an opportunity to consider other natural resource-based projects on a case-by-case basis. This could include a suite of different uses, including major utility infrastructure, that could take advantage of the network of existing electrical infrastructure in Grant County.

3. The compatibility of the proposed zone changes and uses allowed under the proposed zoning district with neighboring land uses:

Majority of the land surrounding the identified parcels are vacant or used for agriculture. The Rural Resource designation, which does not require ample County services or changes to public infrastructure, would remain compatible with those land uses.

4. The proposed rezone can be served by adequate facilities including access, fire protection, water, stormwater control, sewage disposal

The rezoned area would not require or result in additional public services, like the ones identified above. Public services serving this area of the County would continue normally planned operations.

5. That substantial changes exist to warrant an amendment to the current zoning district:

The State of Washington and the US Government have passed legislation that support new business activities near existing transmission infrastructure. In recent years, new renewable energy generation technology has proved to be both economical in rural areas and compatible with a wide variety of land uses. The Rural Resource is a unique zoning designation that would allow for current land use activities to continue, while also giving Grant County a chance to consider ways of diversifying the natural resource sector of its economy. By rezoning the proposal area, the County will be updating its Comprehensive Plan to reflect changed conditions in the utility and natural resource sector.

6. That public need exists for the proposed rezone, including that additional land for a particular purpose is required in consideration of the amount already provided by the official zoning map for the current zoning district and the proposed zoning district:

Rural Resource lands can target a number of different land-uses focused on natural resources. The land near the Vantage Substation (which is a sizable electrical substation not only in the County but in the State of Washington broadly) is a unique opportunity to consider projects that take advantage of previous investments in this area. To the knowledge of the Applicant, there is not a private parcel currently zoned as Rural Resource with superior access to the Mid-C Electrical Market.

7. The proposed rezone will not result in significant adverse impacts on the human or natural environments that cannot be mitigated by conditions of approval

16 Correct, there are not substantial differences in allowable uses between existing zoning and the proposed Rural Resource designation. Grant County has a robust process for considering future project actions through its Conditional Use Permit process.

8. The cumulative impact of additional requests for like actions will not produce significant adverse effects to the environment that cannot be mitigated

No additional changes are proposed as part of the Comprehensive Plan Amendment application. The Rural Resource zone is compatible with adjacent land-use designations and existing land uses. The zone change will not result in additional parcels requesting similar treatment as all lands to the east are in the Columbia Basin Project and/or have prime farmlands.

9. The pedestrian and vehicular traffic associated with the rezone will not be hazardous to existing and anticipated traffic in the neighborhood

No changes to traffic flows are anticipated as part of the requested change.

10. The proposed zoning district does not include any allowable use of activity that would result in the siting of an incompatible use adjacent to an airport or airfield (RCW 36.70):

Not applicable.

17 Appendices

A. Comprehensive Plan Amendment Application B. Maps C. Responses to Goals and Objectives D. SEPA Checklist E. Pre-Application Memo F. Geotechnical Report G. Relevant Site Report pertaining to Critical Areas

18 Appendix A Comprehensive Plan Amendment Pre-Application Overview Scope: Applicant proposes a change of zoning for 32 parcels in Grant County totaling 2988 acres. Existing Zoning: Parcels are currently zoned as Rural Remote and Agricultural Proposed Zoning: Rural Resource Current land use: agricultural and undeveloped open space; electrical transmission infrastructure; road network Purpose: Royal Slope Solar LLC, authorized agent of parcels identified below, proposes to amend site-specific zoning for 32 parcels subject to the Grant County Comprehensive Plan. Rezoning the identified parcels will support business objectives of existing landowners and help meet the goals of the Grant County Comprehensive Plan. A Rural Resource designation for these parcels would support a range of commercial endeavors that utilize natural and commercial features of the land, including adjacent electrical infrastructure near the Wanapum Dam. As stated in the 2018 Comprehensive Plan: “The GMA recognizes the importance of resource lands by requiring counties to “classify, designate and conserve” them as “resource lands of long-term commercial significance.” The GMA recognizes the vital role these resource lands play in defining the quality of life in Grant County and seeks to avoid their irrevocable loss. Within each of these designations, the primary and preferred uses will be the growing, managing, harvesting or extracting, and processing of natural resources.” Parcel Numbers:

- 150358001 - 150234007 - 150234004 - 150229000 - 150362001 - 150234008 - 150234012 - 150247000 - 150361000 - 150234011 - 150234015 - 150248000 - 150234005 - 150234002 - 150232000 - 150246000 - 150234006 - 150234003 - 150231000 - 150248001 - 150234009 - 150234013 - 150356001 - 150246001 - 150234010 - 150234014 - 150228000 - 210562000 - 150234001 - 150234000 - 150230000 - 210563000 Parcel Descriptions:

Meridian Township Range Section Legal description (approx.) Acreage

Willamette 17N 23E 33 NE4, E2SE4 232

Willamette 17N 23E 34 N2S2, NW4, E2NE4 399

Willamette 17N 23E 03 ALL 640

Willamette 16N 23E 02 W2, NE4 493

Willamette 16N 23E 01 ALL 595

Willamette 16N 23E 12 N2, SE4, N2SW4 567 Willamette 17N 23E 27 PT-S2SW4, PT-SWSE4 22 Existing Zoning Purpose:

- Agricultural: The purpose of the Agricultural zoning district (AG) is to provide land for continued farming activities, conserve agricultural land, and reaffirm agricultural use, activities and operations as the primary use of the zoning district. The zoning district is composed mainly of lands with highly productive soil that is generally suited to crop agriculture, agricultural related industries, livestock maintenance, existing public irrigation facilities and potential future expansion of the Columbia Basin Irrigation Project. Grant County Code 23.04.560(a).

- Rural Remote: The purpose of the Rural Remote (RRem) zoning district is to differentiate from the higher density rural land use to reflect the area's remoteness and/or limited opportunity for development, to provide land for very low density, single- and two-family residential development. Rural remote areas are generally not suitable for intensive farming and are generally not attractive for residential development. Rural Remote zoning district is intended: (1) to provide opportunities for resource-oriented activities (farming and mineral extraction); (2) to be sensitive to the site’s physical characteristics and protect critical areas; (3) to provide opportunities to create open space corridors; (4) to enable efficient road and utility systems; (5) to provide for recreational uses and facilities. The Rural Remote zoning district is not intended to create demands for urban levels of service. Grant County Code 23.04.350(a). Proposed Zoning Purpose:

- Rural Resource: The purpose of this designation is to identify areas that have some agricultural opportunities in a rural setting. Such areas are those that are not as suitable for intensive farming as Agricultural Resource lands, but some agricultural use can occur with land management. The primary land uses in these areas include, but are not limited to grazing, mineral extraction, limited dryland agriculture, open space, and residential. The maximum density is one dwelling unit per 40 acres. Lands are typically too far from the urban area to enable cost-effective provision of public services. Such areas require on-site water and sewer service, may be outside of fire service, or have other site constraints. They may be outside existing main road networks and distant from existing utilities. Grant County Code 23.04.570(a). Other Existing Grant County Designations

- With overlap of proposed parcels: Grassland land cover, undeveloped land and irrigated agriculture land use, and Critical Areas (Priority Habitat of the State of Washington and Erosion Hazards)

- Without overlap of proposed parcels: Grant County Farm Units, Shorelines of the State, Irrigation Districts, Urban Growth Areas, Incorporated City Limits, Black Sand Irrigation District, Quincy Groundwater Subarea, Wellhead protection area, Colombia Basin Project Canals, County-identified Fuel Pipeline, ORV Recreation Areas, Research Natural Area, Game Range

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H 24 Source: Esri, DigitalGlobe, GeoEye, EarthstarST Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community Coyan Rd Figure 4 Proposed Rural Resource Zone Commercial (Rural) Master Planned Resort Residential, High Density Rural Residential 1 Major Road Zoning Map Proposal Comprehensive Plan Commercial (Urban) Open Space Residential, Low Density Rural Resource Local Street Royal Slope Agricultural Service Center Hanford Federal Reserve Open Space (Urban) Residential, Medium Density Shoreline Development F Regional Setting Agriculture Dryland Solar LLC Industrial (Rural) Port of Moses Lake Residential, Suburban Urban Reserve Grant County, Washington Agriculture (Irrigated) Industrial (Urban) Public Facility (Urban) Rural Community Urban Reserve (Rural)25 12.5 0 25 Miles

Agriculture Rangeland Master Planned Industrial Recreational Development Rural Remote Interstate Issued: 1/17/2020 Appendix C Goal Policy Applicant Response LU-1.1 Development permits should be processed in a timely and fair manner to ensure predictability. LU-1.2 Communications between the County and citizen groups should be facilitated by providing information on programs, regulations, and development projects impacting various areas of the Applicant has met with County for a pre‐application requests and look forward LU-1: Establish an effective public involvement system in the land County. to supporting Devlopment Services in any outreach activities related to the use planning and decision making process. LU-1.3 The County should provide for public involvement early and continuously throughout the Comprehensive Plan Amendment application. process of developing and amending plans and regulations and should use a variety of public participation and information strategies in keeping with adopted public participation policies.

LU-2.1 Prevent regulations that create undue adverse economic impacts or unnecessarily restrict the use of private property. LU-2.2 The Comprehensive Plan should guide the County's physical development and the preparation of the County's sub-area plans, comprehensive plans of incorporated cities, and plans for special services, functions, or issues. Goal LU-2: Encourage public health, safety, and general welfare LU-2.3 The Comprehensive Plan should establish the framework of goals and policies for future without unduly jeapordizing private property rights, to develop a developments in UGAs and rural areas. system of coordinated plans that direct the County's physical LU-2.4 Sub-area plans can be developed to identify the area-specific land use and transportation development. plans for geographic sub-areas of the County. Sub-area plans may accommodate unique features or The Rural Resource zone is an innovative land use designation that supports needs of a discrete portion of the rural area, or areas of more intense rural development. private development, responsible use of natural resources, and economic growth in a rural areas of the County.

LU-2.5 Develop agreements between the County and incorporated cities for consistency and certainty about how the area will be planned and developed in the future. The agreements should be prepared and used according to the following principles: 1. The future land use pattern and transportation systems identified in these agreements should be honored as development in the County and annexations to the cities take place. 2. These agreements should provide for phasing of development and the orderly extension of city services and annexations. LU-3.1 Legal lots of record with residential development rights that exist on the effective date of this Comprehensive Plan should retain their development rights, provided the following remain true:

Goal LU-3: Recognize development approvals that have not yet 1. Public health or safety is not threatened. been constructed or acted upon, when they do not threaten public 2. The scope of the non-conforming use or inconsistent land development, land activity, and/or land Not applicable. health and safety. use does not expand. LU-3.2 The continuing validity of variances, special use permits, Planned Unit Developments, and conditional use permits that were approved prior to the effective date of this Comprehensive Plan should be evaluated on an individual basis. LU-4.1 The Grant County Comprehensive Plan should be reviewed, evaluated, and revised Application of the Rural Resource designation to this portion of the County Goal LU-4.1: Support a Comprehensive Plan that is adaptable to periodically and as changing circumstances require. maintains focus on natural resources and agricultural production, and also changing conditions yet promotes certainty, and maintain the LU-4.2 Consistency, understanding, and efficiency of the permitting process should be promoted. allows the County to adapt to changes in the energy and utility sectors. Comprehensive Plan through County programs and regulations.

LU-5.1 The Open Space land use designations should support the following goals: 1. Protect streams, stream corridors, wetlands, natural shorelines, and aquifers. 2. Protect soil resources. 3. Protect unique, diverse, or critical wildlife and native plant habitat. 4. Promote conservation principles by example or by offering educational opportunities. Goal LU-5: Conserve or enhace important natural, cultural, historic, The proposed Rezone does not overlap with existing Open Space land use 5. Enhance the values and functions of parks, wildlife preserves, nature conservancies or sanctuaries, o and scenic resources. designations. 6. Enhance recreational opportunities and public accress to open spaces. 7. Preserve scenic vistas and historic, cultural, and archaeological sites. LU-5.2 The County should inventory Open Space lands and define those to conserve. The county should consider development of a comprehensive parks, open space, and recreation plan to identify, evaluate, and designate additional appropriate open space. LU-6.1 The County should support public and private land trusts in acquiring conservation easements that provide open space attributes, consistent with the intents of property owners. LU-6.2 The County should support the conservation of unique environmental features through the use of cluster subdivisions and planned unit developments. If the proposal area is rezoned to the Rural Resource designation, existing Goal LU-6: Encourage open space conservation. LU-6.3 The County should support the retention of open space and open space corridors through the landowners and the County have the flexibility to incorporate open space into use of education and incentives, such as transfer of development rights, density bonuses, cluster land uses and future project actions. development, and acquisition of easements. LU-6.4 The County should support the conservation of Open Space and Agricultural Resource lands through enrollment in the County's open space taxation program. LU-7.1 Grant County should identify and protect riverine and other riparian corridors, floodplains, lakes, and rivers as essential elements of open space corridors through establishment of reasonable Goal LU-7: Identify and protect open space corridors within and setbacks and buffers. The proposal area does not have riverines, riparian corridors, floodplains, between UGAs. These corridors should include trails and other lands lakes, or rivers. The proposal area is outside Shoreline designations and is on a useful for recreation, while emphasizing wildlife habitat, and LU-7.2 Grant County should support the incorporation of greenbelts into subdivision design as bluff above the Columbia River, which provides a natural buffer and setback. connection of critical areas, where feasible. common open space. LU-7.3 Encourage provision of neighborhood parks and play areas within new developments in the unincorporated portions of UGAs. Goal LU-8: Promote coordination among the County, State, cities, LU-8.1 Coordinate with Grand County PUD on recreational and tourism facilities in Grant County. Grant County Public Utility District (PUD), and other appropriate Not applicable. jurisdictions in order to protect linked greenbelts, parks, and open LU-8.2 Link County open space corridors with those of adjacent jurisdictions where viable. spaces. UR-1.1 Provide urban governmental services within UGAs prior to or concurrent with development.

UR-1.2 Reduce the unit cost of urban public services by requiring urban density development within UGAs and rural densities outside the UGAs. Goal UR-1: Encourage urban growth within designated UGAs. Not applicable. UR-1.3 Encourage urban infill where possible to avoid sprawl and leapfrog development thereby conserving fringe open lands.

UR-1.4 Encourage growth in areas already characterized by urban growth that have existing urban- level public services and facilities consistent with adopted plans and interlocal agreements. UR-2.1 Designation of UGAs should be consistent with the following general goals: 1. Discourage the inappropriate conversion of undeveloped land into sprawling, lowdensity development. 2. Provide efficient and appropriate public services.

3. Protect significant cultural and natural resources, environmentally-sensitive areas, and rural lands. 4. Encourage a clear distinction between urban and rural lands. 5. Support variety, choice, and balance in living and working environments. 6. Promote a variety of residential densities.

7. Include sufficient vacant and buildable land to meet residential, industrial, and commercial needs.

8. Consider citizen preferences for inclusion in a UGA, based on broad-based community interests. UR-2.2 Designation of UGAs should be consistent with the following specific criteria: 1. Urban services should be provided by cities within UGAs. 2. Urban services should generally not be provided outside UGAs. Goal UR-2: Designated UGAs should cumulatively provide the area 3. Lands included within UGAs should either be already characterized by urban growth or adjacent The proposal area does not include or affect UGAs. The Rural Resource and densities sufficient to permit the urban growth that is projected to such lands. designation is an appropriate zone for areas outside of urban centers. to occur in the County over the succeeding 20 years. 4. Land within a UGA should not contain areas designated for long-term agricultural resource use. 5. UGAs should provide a balance of residential, commercial, industrial, and public lands and open space. 6. Natural features and cultural resources should be used to define boundaries. 7. Each city should have the anticipated financial capability to provide the services andfacilities needed to serve the UGA over the planning period. 8. Provision of urban services must be economically feasible in a UGA. UR-2.3 Residential development in the unincorporated portions of UGAs should occur at densities such that an average density of four units per acre is maintained throughout the unincorporated portions of the UGA. Minimum residential density should be one unit per two acres.

UR-2.5 The County should coordinate with each incorporated city as designated in this Comprehensive Plan regarding the location and expansion of UGA boundaries. UR-2.6 Encourage commercial and industrial development to locate in well-defined centers throughout the urban areas suitable to their type of business and the population they will serve.

UR-3.1 Designate Urban Reserve areas adjacent to UGAs where appropriate to preserve the opportunity for efficient transition from rural to urban land uses if and when needed.

UR-3.2 Urban Reserve areas should abut a UGA and should not generally include designated agricultural resource lands. Resource lands included within an Urban Reserve area should be limited Goal UR-3 Provide for an orderly, phased transition from rural to in size to less than 500 acres. Not applicable. urban uses within and adjacent to UGAs. UR-3.3 In designating Urban Reserve areas, consideration should be given to the efficiency and economic feasibility with which the Urban Reserve area can be provided with urban services in the future, and the efficiency and economic feasibility with which the area can be urbanized. UR-3.4 In designating Urban Reserve areas, consideration should be given to the expressed desires of property owners. UR-4.1 Infilling should be encouraged in areas already characterized by urban growth that have the capacity, and provide public services and facilities to serve urban development. UR-4.2 Land use plans within UGAs should recognize neighborhood character and support variety and choice in living and working environments.

UR-4.3 Overall residential densities in UGAs should be high enough to support efficient public services and provide for housing choices. UR-4.4 Industrial and commercial development of all types may occur in UGAs, particularly the larger and more intensive types of development that require higher levels of public services and Goal UR-4: The County's designated UGAs should concentrate facilities. Within the UGAs around the incorporated cities, the industrial and larger commercial urban-level residential, commercial, and industrial developments in a development should take place inside the cities themselves in order to support their roles as the No changes to UGAs are proposed. way that ensures livability and orderly transition of land from County economic centers of their areas. to city. UR-4.5 A variety of densities and housing types should be provided in UGAs. UR-4.6 The highest levels of public services and facilities should be provided in UGAs, but may be provided at lesser levels in the UGAs that do not contain an incorporated city within their boundaries. Some services and facilities may only be provided after areas incorporate or are annexed to adjacent cities. These urban services and facilities may include sanitary and storm sewers; police and fire protection; paved streets with curbs, sidewalks, and street lights; and public transit and bicycle paths. Other services may include community and neighborhood parks, government offices, libraries, medical facilities, manned fire stations, and control. UR-5.1 Cities and the County should support reasonable annexations of areas within UGAs that are contiguous to an existing UGA or city limits and includes or has plans for necessary public facilities. A proposal is considered reasonable if, unless otherwise agreed to by the city and County, it contains the following conditions: 1. Includes all adjacent roadways 2. Is contiguous to the existing city limits. 3. Provides for efficient provision of emergency services without conflict between providers. 4. Conforms with current regulations. 5. Does not deliberately exclude less desirable properties. UR-5.2 Annexations of unincorporated islands within a UGA should be actively encouraged and creation of new unincorporated islands should be discouraged. UR-5.3 Cities may require an annexation commitment as a condition of utility service within designated UGAs. UR-5.4 New city incorporations should provide adequate facilities and services for urban growth consistent with the Comprehensive Plan. UR-5.5 Cities and the County should jointly develop annexation agreements which define policies, Goal UR-5: The County’s annexations and UGA expansion including sharing of revenue of annexation reimbursement for capital projects developed by the processes should evaluate impacts on Countyland use, traffic County, maintenance of infrastructure, inclusion of roads and streets, and other issues. The proposal does not include an annexation or expansion of UGAs. circulation, public services and facilities, fiscal impacts, and integrity and continuity of service areas and boundaries. UR-5.6 Cities intending to expand their UGAs should demonstrate that the expansion area can and will be served in an economically feasible manner by municipal sewer and water systems. UR-5.7 Expansion of a UGA boundary should be allowed when either of the following conditions are present: 1. There is insufficient land within the existing UGA to permit the urban growth that is forecast to occur in the succeeding 20 years. 2. An overriding public interest is shown for moving the UGA boundary in order to gain apublic benefit related to protecting public health, safety, and welfare; or enabling more effective, efficient provision of sewer or water service. UR-5.8 Areas for any UGA expansion should be contiguous to an existing UGA boundary.

UR-5.9 Reductions in any UGA boundary should ensure that sufficient land will remain within the reduced UGA to permit the urban growth that is forecast to occur in the succeeding 20 years. UR-5.10 Expansion or reductions in any UGA should take into consideration the presence of natural resource lands and critical areas.

UR-5.11 The designation of or change to UGAs should be consistent with the Grant County CWPP. Goal UR-6: Recognize the transitional nature of agricultural uses UR-6.1 Recognize the right to farm and farm use as a legitimate activity within a UGA prior to within UGAs. conversion of property to urban use. Not applicable. RU-1.1 Land uses related to farming, mining, rural residential development, tourism, outdoor recreation, and other open space activities are preferred in rural areas. RU-1.2 Residential use near designated long-term agricultural resource areas should be developed in a manner that minimizes potential conflicts and reduces unnecessary conversion of resource land. Mechanisms such as clustering, buffering, and deed notification should be used. RU-1.3: Provide RU-1.3 Provide for a variety of rural densities to support the following goals: 1. Maintain rural character, farming, and mining. 2. Buffer natural resource lands. 3. Retain open space. 4. Minimize the demand and cost of public infrastructure improvements. 5. Provide for future UGA expansion if needed. The Rural Resource zone proposed is a fitting designation for the proposal 6. Allow rural property owners reasonable economic opportunities for the use of their land. area. The closest UGA is over 10 miles from the area (Royal City). Given the fh l d h ld l Goal RU-1: Encourage rural development that maintains the rural RU-1.4 The amount of development in rural areas should be limited through density requirements remoteness of the site, land use activities should target natural resources in character of the land and protects theland and water resources that protect and maintain existing rural character, natural resource lands, open space, critical areas, order to comply with the Grant County Comprehensive Plan. The Rural required by natural resource-based economic activities, fish and significant cultural resources, and water resources. Resource zone does not allow for land use activities that would permanently wildlife habitats, rural lifestyles, outdoor recreation, and other open remove land from the natural resource‐based economy, such as residential RU-1.5 Rural lands should provide sites for homes, while at the same time provide protection of the space. resource land from encroachment of more intensive residential activity. areas or commercial centers. There is a low residential density currently on the property and this would be maintained through application of the Rural RU-1.6 Within rural areas, proposed new residential development should not negatively affect farm activities. Farm activities should be allowed if they are operating in a reasonable manner and within Resource design standards and permitting requirements. applicable regulations.

RU-1.7 Buffers should be provided between the residential uses and the natural resource based uses. RU-1.8 Residential development adjacent to farm and mineral resource activities should be designed in a manner which minimizes potential conflicts and reduces unnecessary conversion of these resource lands. RU-1.9 Residential development in areas designated as Shoreline Development should be conducted so as to protect water quality of adjacent water bodies. Development standards, including performance requirements and mitigation measures, should be in accordance with the shoreline development regulations. RU-2.1 Provide rural area designations that meet one or more of the following criteria: 1. Areas not designated for urban growth or resource lands of long-term commercial significance and where a possibility exists for less intensive agricultural utilization

2. Areas not needed during the next 20 years to provide land for population or employment growth 3. Areas that provide a buffer between resource activities and potentially incompatible land uses 4. Areas where the open-space character of the land is to be protected for scenic qualities, significant cultural resources, recreational activities, and environmental functions 5. Areas where significant environmental constraints make the area generally unsuitable for urban Goal RU-2: Rural areas should generally be developed at low levels development The Rural Resouce zone meets the criteria for rural area designations. In of intensity so that demands will not be created for high levels of 6. Areas where existing and future uses do not typically require urban-level services and facilities addition, the proposal area may have a possibility of less intensive agricultural public services and facilities. Existing areas of more intense and where such services and facilities are not readily available or expected to be available during the utilization due to soil and geotechnical constraints. development should be acknowledged and maintained. next 20 years. RU-2.2 Residential development in rural areas should be provided on lands that can physically support it without requiring urban services. Densities should be low enough to discourage urban sprawl. RU-2.3 Designated Urban Reserve lands should be considered as “joint planning areas” subject to a joint planning process between the County and the affected city or cities intended to resolve issues regarding potential land uses. RU-2.4 The County may develop and consider a clustering program for residential development in rural lands using density incentives, transfer of development rights, planned unit developments, and long platting procedures. RU-3.1 Limited areas of more intense rural development (LAMIRD) should be provided on land exhibiting existing intense patterns of development and lifestyle preferences. Mixed-use areas comprised of high-density residential, small-scale industries and businesses, and public facilities may be located in rural areas that meet the following criteria: 1. Where historic, unincorporated communities with an existing mix of higher density land uses already exists, and where some new adjacent residential, commercial, and industrial development is Goal RU-3: Promote the continuation and enhancement of the expected to continue to occur. No changes to the LAMRID designation to the northwest of the proposal area is existing rural activity centers in order to preserve their multi-use 2. Where soil conditions are able to handle the cumulative long-term impacts of on-site sewage proposed. function to serve the rural community of Grant County. disposal without adverse impacts to ground and surface waters. 3. Additional undeveloped land may be included in these areas to allow for limited growth. This designation provides for the infill, development, or redevelopment of lands within the boundaries established. RU-3.2 Provide "Rural Areas of More Intensive Development" designations consistent with the Grant County Future Land Use Map. RU-4.1 Home-based occupations and cottage industries should be allowed throughout the rural area provided they do not adversely affect the surrounding residential uses. Site-specific standards should be considered through the permitting process. RU-4.2 Industrial uses in rural areas (other than small scale home-based industries) should generally be those appropriate for location in rural areas, such as the following examples: 1. Independent contracting services 2. Industries related to and dependent on natural resources of agriculture and minerals 3. Industries requiring large secluded areas away from population centers and not requiring urban Goal RU-4: Provide for continued existing and new small-scale services. The Rural Resouce zone would allow for the County to consider new uses commercial and industrial developments outside UGAs that are 4. Commercial recreational uses related to natural resources in this area of the County. Land uses authorized compatible with and continue to preserve, maintain, and enhance the under the Rural Resource zone would not require additional urban or public RU-4.3 New rural commercial uses should be permitted within appropriate “Limited areas of more vital rural and agricultural uses in the County. services (see Comp. Plan Amendment application). intense rural development (LAMIRD)” designated areas. Rural commercial uses should be limited in size to serve the areas in which they are located.

RU-4.4 Recreational/tourist and highway-oriented commercial facilities may be located within a natural resource designation or a rural designation if, at a minimum, the following criteria are met: 1. The location of the facility would not adversely impact the natural resource production in the area. 2. The facility is of size and scale for their intended use and the surrounding area. 3. The use does not require extension of urban services. RU-5.1 Allow related processing facilities, limited direct resource sales, and limited natural resource support services that support natural resource activities and are not harmful to the long term natural resource. RU-5.2 Natural resource support services to be located within the rural land designations should The Rural Resource zone allows for a Conditional Use Permit process that maintain the rural character of the area and be permitted through a conditional use process. Such uses serves as a tool for the County to consider how to support new natural Goal RU-5: Support and facilitate agricultural and mineral should be directly related to natural resource enhancement, production, or utilization. Such uses resource acitivites that are not harmful to the resource or other uses. Changing productions. should generally not require extension of urban governmental services. If particular urban services the zoning of the proposal area would not result in an extension of urban are necessary, conditions should be established to ensure that urban growth will not occur in adjacent governmental services. rural or resource lands. RU-5.3 The siting of a major industrial development outside of a UGA should comply with the criteria contained in RCW 36.70A.367 and this Comprehensive Plan. RU-6.1 The siting of a fully contained community or master planned resort outside of a UGA should Goal RU-6: Provide for the siting of Fully Contained Communities comply with the criteria contained in RCW 36.70A.350 and 360, as applicable, and this Not applicable. and Master Planned Resorts. Comprehensive Plan. RU-7.1 Public spending priorities for facilities, services, and utilities within rural areas should be primarily to maintain or upgrade existing facilities, services, and utilities to serve existing development at rural service level standards. New facilities, services, roads, and utilities that support planned rural growth should be allowed at rural service level standards. RU-7.2 Road services and utility standards should be consistent with rural densities and uses. RU-7.3 Urban governmental services should not be extended to or expanded in rural areas except in those limited circumstances shown to be necessary to protect basic public health and safety and the environment and when such services are financially supportable at rural densities and do not permit Goal RU-7: Assure that the provision of public facilities, services, urban development. The Rural Resource rezone request targets private development and would not roads, and utilities are consistent with rural character and lifestyles. result in any additional public‐funded services. RU-7.4 Residential sewage generated from rural development should be treated via individual onsite septic systems, or other method approved by the Grant County Health Officer. Community systems or de-centralized treatment systems may be used in Rural Villages and Rural Communities. Municipal sewer collection and/or treatment systems should only be extended outside the boundary of a UGA in response to an identified public health hazard. RU-7.5 The County should promote wise use of public funds in rural areas by allowing service providers to establish rural facility and service standards that are consistent with rural densities and uses.

RE-1.1 Identify, classify, and designate Agriculture Land of Long-Term Commercial Significance. RE-1.2 Pursuant to RCW 58.17.310, the County should require Irrigation District and USBR As part of the 2016 Grant County Comprehensive Plan planning effort, Grant approval of all proposed land divisions of Designated Irrigated Agricultural Lands within an County reconsidered the Agricultural designation of thousands of acres of land. Irrigation District. The County should notify said Irrigation Districts and USBR of proposed Through this process, the County looked specifically at long‐term commercial subdivisions and should adopt subdivision standards that incorporate the approval requirements of significance for agriculture. Areas were removed from the Agricultural these agencies. designation that require additional land management to be productive (such as RE-1.3 Residential uses adjacent to farms should be developed in a manner that minimizes rocky soils per NRCS), are not identified as statewide or locally important, are unnecessary conversion of farmland. not prime, or are not currently farmed. The proposal area has a number of RE-1.4 In order to reduce development pressure on Designated Agricultural Lands areas, future these features, which may warrant the inclusion of lands zoned as Agricultural Goal RE-1: Preserve Agriculture Lands of Long-Term Commercial development in the County should be directed toward designated areas of more intense development to be rezoned as Rural Resoure. Additionally, it would expand the vision of the Significance. where existing and planned services can more easily accommodate growth. natural resource economy to include other uses that can support the RE-1.5 Prohibit “spot rezoning” of non-agricultural uses on Designated Agriculture Lands. agricultural economy. The proposed designation should not be considered as RE-1.6 Support and encourage the maintenance of agricultural lands Agricultural Current Use "spot rezoning", since agricultural production can continue on Rural Resource Classification property tax classification pursuant to Chapter 84.34 RCW. Commercial farmland lands and the County retains a focus on natural resoures in this area. The new owners should be encouraged to retain their lands in commercial farm production and enroll their designation can be land in available agriculture tax programs. considered an innovative zoning technique that fits RCW 36.70A.177(1) as RE-1.7 The County discourages the establishment or expansion of utility local improvement being designed to encourage the agricultural economy. The County retains districts, or sewer, water, or PUDs on designated agricultural lands which result in the imposition of land‐use decion‐making capacity on future projects affecting agricultural uses assessments, rates, or charges on designated agricultural land. on Rural Resource lands. RE-1.8 Support the continued designation and use of agricultural lands for agricultural activities to maintain the viability of the agricultural economy in the County. RE-2.1 Maintain a “Right-to-Farm” Ordinance and apply its provisions to all Designated Agricultural Lands. RE-2.2 Residential uses in designated rural areas adjacent to Designated Agricultural Lands should be developed in a manner that minimizes potential conflicts and reduces unnecessary conversion of farmland.

RE-2.3 Anticipated conflicts between a proposed new or modified land use and existing agricultural activities should be mitigated by the newer proposed use prior to issuance of development permits. RE-2.4 The primary use of any parcel on Designated Agricultural Lands should be agricultural production and related processing and agricultural support services. Residential uses in these areas should recognize that the primary use of the land may impact residential uses such as noise, odor, dust, smoke, glare, pests, rodents, and spraying of chemicals. Residential uses should be located in areas where such impacts can be avoided. Any impacts between agricultural lands and non‐agricultural uses is best Goal RE-2: Mitigate conflicts between agricultural and non- contemplated at the project‐level. As stated in the Grant County RE-2.5 Require setbacks and buffers as part of new, non-agricultural development proposals on agricultural land uses in designated agricultural resource lands. Comprehensive Plan, the new Rural Resource designation can preserve lands lands within or adjacent to Designated Agricultural Lands. Such buffer areas should be of sufficient for rangeland uses and agricultural production opportunity areas. size to protect Designated Agricultural Lands from the impacts of incompatible development and to mitigate against the effects of agricultural operations on adjacent land uses. Such buffers should occur on the non-agricultural parcel for which a development right or permit is being sought. RE-2.6 The Grant County Zoning Ordinance should address new residential developments within 200 feet of a boundary of Designated Agricultural Lands.

RE-2.7 In order to reduce development pressure on farm and rural areas, future development should be directed toward areas of more intense development where existing and planned services can more easily accommodate growth. Outside these areas, densities should remain low. RE-2.8 Encourage efficient agricultural operations and production methods that are based on sustainable agricultural and best management practices. RE-2.9 Impacts from public festivals (e.g., fairs, rodeos) conducted on or adjacent to Designated Agricultural Lands should be mitigated. RE-3.1 Designated Agricultural Lands should be used for commercial agricultural and agricultural support services, and limited residential development having a maximum density of one dwelling Goal RE-3: Provide for reasonable, limited use of Designated unit per forty acres. Agricultural Lands that are compatible with Not applicable. the long-term production of agricultural products. RE-3.2 One residential unit may be allowed on any parcel of less than forty acres within Designated Agricultural Lands, provided that the parcel was created legally prior to adoption of this Comprehensive Plan. RE-4.1 In Designated Agricultural Lands, allow agricultural processing facilities, limited direct farm sales, and limited agricultural support services that support local agricultural activities that are not detrimental to the long-term agricultural use.

RE-4.2 Promote agri-tourism related uses on agricultural lands and on Agricultural Service Centers. RE-4.3 Allow for agricultural support services in Designated Agricultural Lands if there are no reasonable alternatives for siting agricultural support services, including industrial and commercial uses, and if agricultural production activities are not undermined. The following guidelines should be considered for approving requests for siting agricultural support services on Designated Agricultural Lands: 1. The use does not substantially detract from agricultural production on site or in the area 2. The use is directly related to agricultural enhancement or production 3. The proposed site is located or of such size that traffic and other impacts can be mitigated by application of design criteria The Rural Resource designation allows for land‐uses targeting the natural Goal RE-4: Facilitate a healthy, diverse, and competitive RE-4.4 Permit on-farm enterprises including, but not limited to, direct marketing of unprocessed and resource economy. Authorized uses in this zone include agricultural and non‐ agricultural industry. value-added agricultural products and agricultural support businesses, to allow farmers to agricultural uses. supplement the farm income, improve the efficiency of farming, and provide employment for farm family members. RE-4.5 Consider development of incentives for continued agricultural resource use, including but not limited to the following: 1. Promoting economies of scale through cooperative resource management and marketing for small landowners 2. Developing expedited permit review processes for agricultural-related activities that involve development approvals 3. Support voluntary stewardship actions on agricultural lands, including habitat restoration, resource management plans that include “best management practices,” and conservation strategies 4. Establishing incentives for consolidation of non-conforming and non-buildable lots 5. Requiring subdivision site designs to minimize conflicts with nearby agricultural activities RE-5.1 Encourage the voluntary donation of conservation easements or other development restrictions to the County or a qualified, private non-profit organization for the purpose of preserving the perpetual agricultural use of the Designated Agricultural Lands where development of legally The Rural Resource zone does not bar conservation easements. The property is Goal RE-5: Promote innovative planning and land use techniques to subdivided land would promote incompatible residential development. not enrolled in the Conservation Reserve Program (CRP) and does not conserve agricultural land. RE-5.2 The County may develop and consider a clustering program for residential development in currently have any conservation easements within the proposal area. Designated Agricultural Lands consistent with the development regulations. RE-5.3 Support the County’s VSP to maintain the viability of agriculture and to protect and enhance critical areas.

RE-6.1 Commercial quality mineral resource deposits are recognized as non-renewable resources and identified, classified, and designated as Mineral Lands of Long-term Commercial Significance. RE-6.2 Recognize sites holding valid surface mining permits from DNR as Designated Mineral Lands. Goal RE-6: Mineral resource lands of long-term commercial Not applicable. Grant County retains authority to regulate mining activities in significance should be preserved in order to encourage an adequate RE-6.3 Designate sufficient mineral lands to ensure a 50-year supply of aggregates, sands, gravels, the Rural Resource zone. resource base for long-term use. and rock based on appropriate criteria, including: 1. Quality of the resource 2. Volume of resource 3. Topographic characteristics of the site 4. Compatibility with land use patterns in the area 5. Proximity to urban and rural development and markets RE-7.1 Residential uses in designated rural areas adjacent to Designated Mineral Lands should be developed in a manner that minimizes potential conflicts with mineral extraction operations. RE-7.2 Anticipated conflicts between a proposed new or modified land use and existing mineral extraction activities should be mitigated by the newer proposed use prior to issuance of development permits.

Goal RE-7: Mitigate conflicts between mining and other land uses Not applicable. Grant County retains authority to regulate mining activities in RE-7.3 The primary use of any parcel on Designated Mineral Lands should be mineral extraction and in designated mineral resource lands. the Rural Resource zone. related processing. Residential uses near these areas should recognize that the primary use of the land may have impacts such as noise, dust, glare, vibrations, and truck traffic. RE-7.4 Appropriate setback and buffer requirements should be required as part of new, nonmining development proposals on lands within or adjacent to Designated Mineral Lands. RE-7.5 Designated Agriculture Lands should not be used for mining purposes unless they can be restored to their original agricultural production capacity as mining occurs. Goal RE-8: Provide for reasonable, limited use of Designated RE-8.1 Designated Mineral Lands should be used for commercial mining and mining support Not applicable. Grant County retains authority to regulate mining activities in Mineral Lands that are compatible with the long-term production of services, and limited residential development having a maximum density of one dwelling unit per the Rural Resource zone. mineral products. forty acres. RE-9.1 Extraction industries should not adversely impact the following resources: 1. Adjacent or nearby land uses 2. Significant cultural or archaeological resources Goal RE-9: Ensure public health and safety and minimize off-site 3. Fish and wildlife habitat Not applicable. Grant County retains authority to regulate mining activities in disturbances associated with mining operations, including noise, 4. Air and water quality the Rural Resource zone. dust, glare, vibrations, and truck traffic. 5. Community aestherics and reclamation 6. Public health and safety RE-9.2 Require new or expanded mineral resource operations to minimize and mitigate adverse impacts of mineral-related activities on surrounding affected uses. RE-10.1 Mineral extraction, processing, and reclamation activities should not negatively affect or endanger surface and groundwater flows and quality. RE-10.2 Reclamation of mineral extraction sites should occur consistent with best management Goal RE-10: Ensure that water quality protection standards practices, DNR reclamation requirements, and other requirements as the site is being mined. The site associated with mining operations comply with best management should be reclaimed for appropriate future use and should blend with the adjacent landscape and Not applicable. practices. contours.

RE-10.3 Mineral processing waters should not be discharged to natural streams without adequate water quality treatment to meet all discharge standards of state and federal jurisdictions. ED-1.1 Facilitate the creation and retention of family wage jobs that meet the needs and demands of Grant County residents. ED-1.2 Encourage business investment as a means to provide job opportunities for Grant County residents.

ED-1.3 Make necessary public infrastructure investments in transportation, water and sewer, The Rural Resource zone is an innovative land use designation that supports telecommunications, and other utilities to leverage private investments that ultimately create jobs. private development responsible use of natural resources and economic private development, responsible use of natural resources, and economic ED-1.4 Encourage diverse job options and entrepreneurial opportunities. Goal ED-1: Encourage diverse employment opportunities that diversification in rural areas of the County. Through Conditional Use satisfy the socioeconomic needs of Grant ED-1.5 Encourage educational opportunities for residents of all ages to develop and upgrade skills permitting, the County has an opportunity to consider a wide array of natural County residents. required for employment, advancement, and entrepreneurship. resouce‐based projects and new economic drivers, including major utility ED-1.6 Work cooperatively with the Grant County Economic Development Council, Big Bend infrastructure. This approach supports the business environment in Grant Community College, and other local jurisdictions to address employment needs consistent with County and allows for stakeholder and public involvement in the process. county-wide regional policies. ED-1.7 Encourage and accommodate home-based businesses and cottage industries that are consistent with the character of adjoining properties and neighborhoods.

ED-1.8 Cooperate with education providers and employers in developing facilities and programs meeting a continuum of educational needs at the K-12, college, and continuing education levels. ED-2.1 Public service providers in Grant County should provide those services and facilities The Rural Resource zone allows for utility and public services through the necessary to support a high quality of life and attract business investment. Conditional Use Permit process. By rezoning the proposal area to the Rural Resource zone, Grant County can consider how it meets its goals of facilitating Goal ED-2: Encourage economic growth through planning and private investment, fostering a healthy business community, and furthering its development of the region's public services and facilities' capacity. reputation as a leader in energy and natural resource‐based sectors. The ED-2.2 Review land use and permitting procedures to assure that regulatory processes are County can also take advantage of past infrastructure investments at the understandable, predictable, and can be accomplished within reasonable time periods in a manner that meets or exceeds state statutory requirements. proposal area. ED-3.1 Encourage a range of commercial retail and service businesses to meet local resident needs and serve visitors to Grant County. ED-3.2 Plan for a diversity of ready-to-build sites with sufficient support infrastructure and services needed to meet the demand for industrial land for the duration of the planning period. ED-3.3 Encourage low-cost, easily accessible, state-of-the-art telecommunications services throughou Given the existing newtork of major infrastructure projects, the land near the Goal ED-3: Ensure an adequate supply of commercial and industrial ED-3.4 Facilitate the retention and expansion of existing local businesses and start-up of new Vantage Substation may be an appropriate location for new and innovative sites to provide opportunity for new and expanding businesses to businesses particularly those that provide family wage job opportunities and operate in compliance land‐uses focused on natural resources. The Rural Resource zone can expand locate or remain in Grant County. with applicable regulatory requirements. the vision for the area to include a variety of uses that support the County's ED-3.5 Industrial sites designated under this Comprehensive Plan should be protected from rural economy. encroaching incompatible uses. ED-3.6 Jurisdictions in Grant County should regularly update inventories of land utilization, land demand, and suitable available properties for residential, industrial, commercial, public facility, and agricultural uses. Goal ED-4.1 Focus business recruitment and development on firms that will diversify the local economy and can effectively serve state, national, Pacific Rim, and other global markets from a Grant Goal ED-4: Preserve the strength of the existing agricultural Applying the Rural Resource zone to the proposal area may be an effective way County location. industry while diversifying the local economy by strengthening of diversifying the rural economy through new land‐uses. The Rural Resource Goal ED-4.2 Encourage high value-added resource based products and businesses. manufacturing and promoting producer services and other basic zone is a flexible land‐use designation that may allow private landowners to Goal ED-4.3 Encourage the establishment of industrial parks and other light manufacturing facilities industries. pursue agricultural uses in some areas and other compatible uses in others. and provide zoning of facilities engaged in producer services, including computer, health services, and telecommunications.

ED-5.1 Promote visitor opportunities that are compatible with or complement the character and Goal ED-5: Maximize the positive economic impact of tourism and existing uses of natural resource lands and critical areas or the rural lifestyles of Grant County. The Rural Resource zone will not detract from tourism or recreation in Grant ED-5.2 Support local jurisdiction efforts to improve and market visitor services. recreational development. County. ED-5.3 Visitor facilities should be sited at locations that can be served with necessary public infrastructure and that are compatible with neighboring uses. ED-5.4 Provide for siting and development of Master Planned Resorts. ED-6.1 Encourage development of human and social service facilities that create job opportunities, meet community needs, and maintain Grant County’s quality of life. The Rural Resource zone may be an effective designation for attracting Goal ED-6: Improve Grant County’s economy by supporting efforts business investment, which in turn, can increase the local tax base and provide to improve human and social services. ED-6.2 Support development and maintenance of human and social service facilities including, but not limited to, health care, education, transportation, and other services for persons with special social services for the citizens and communities of Grant County. needs. ED-7.1 Encourage commercial and industrial developments that incorporate innovative and/or The Rural Resource zone can advance innovative land uses that are based in experimental applications and demonstrate an ability to conserve natural resources and/or protect or Goal ED-7: Promote economic growth that conserves natural enhance environmental quality. the natural resource sector. Advances in technology across multiple sectors resources and open spaces, maintains environmental quality and allow for both protection of natural resources as well as new business rural character, and enhances the overall quality of life. opportunities within the County. The proposal area is a commercially signicant ED-7.2 Long-term commercially significant natural resource lands or lands in urban settlements area for utilities and the energy sector. should be protected from encroachment from conflicting uses. H-1.1 Land use should not prohibit government-assisted housing, housing for low-income families, farmworker housing (including federal programs such as H-2A), single family housing, manufactured housing, and residential care facilities. H-1.2 Encourage a variety of housing densities and types within rural areas, such as detached single family housing, cluster housing, duplexes, and a residence in conjunction with commercial uses within areas of more intense development. H-1.3 U.S. Department of Housing and Urban Development (HUD)-compliant manufactured Goal H-1: Meet the housing needs of the existing and projected housing should be permitted in the same manner as site built housing. population, including rental and purchase opportunities for all H-1.4 Local development standards and regulations should be evaluated to reduce factors that add to Not applicable to the Rural Resource zone. income levels, as well as housing to support temporary agricultural housing costs. The following are strategies for consideration: labor. 1. Review regulations to find those that cause excessive costs and determine if they can be revised, replaced, or eliminated. 2. Make regulations and permit processing more predictable, to remove some uncertainty for both builders and lenders.

H-1.5 The County should work with the cities to accommodate low- and moderate-incomefamilies, recognizing that affordable housing is best located within urban areas due to the greater accessibility to transportation systems, jobs, support services, shopping, and businesses. H-2.1 Promote a variety of residential land use densities on rural and urban lands. Goal H-2: Encourage the provision of housing in a wide range of costs, with emphasis on housing units for low- and moderate-income Not applicable to the Rural Resource zone. households; also encourage housing for the special needs H-2.2 Encourage residential care facilities and other group homes serving special needs populations. populations. H-2.3 Any proposed County housing programs/assistance should be financed through federal, state, or private sources rather than from funds raised through local taxes.

H-3.1 Conserve existing housing stock in the County through code enforcement, appropriate zoning, Goal H-3: Preserve the existing housing stock to the extent and the possible participation in federal, state, and regional rehabilitation programs. Not applicable to the Rural Resource zone. practicable. H-3.2 The County should encourage the preservation and rehabilitation of historic structures through the adoption of building code amendments for historic structures.

T-1.1 Provide sufficient travel lane capacity based on industry standards for safe vehicular travel in major corridors.

T-1.2 Support expanding and maintaining air, rail, and surface freight handling facilities as required to attract and accommodate economic growth. Support a county-wide transportation network, which integrates all modes of transportation into an efficient system. Goal T-1: Provide safe and efficient access to land while T-1.3 Consider the needs of agricultural and other resource-based lands and activities when planning Rural Reource zone will not change the transportation network in this portion maintaining the integrity of transportation systems. for and building road improvement projects. of the County. T-1.4 Adopt standards that channel traffic where possible to local or collector roadways connecting T-1.5 Developments should have adequate access and circulation for all public service vehicles. T-1.6 Maintain compatible street and road standards among Grant County jurisdictions.

T-1.7 Coordinate with relevant organizations for special event traffic management and to minimize the disruption of normal use of transportation facilities during special events and festivals. T-2.1 Specify the standards for LOS in the Transportation Element. T-2.2 The County should determine the need for public facilities based in-part on the adopted standards for LOS, the demand, and the inventory of existing serviceable facilities. T-2.3 Evaluate the transportation facilities periodically. Goal T-2: Establish LOS for transportation facilities and identify Rural Reource zone will not change the transportation network in this portion improvements needed to serve the existing and future population. of the County. T-2.4 Factors such as Comprehensive Plan policies, the County’s priorities, LOS, and the project selection criteria of funding agencies should be considered for transportation improvements.

T-2.5 Special purpose districts providing transportation facilities and services should conduct at least a basic level of transportation planning consistent with this Comprehensive Plan. T-3.1 Land use should determine the types and levels of transportation facilities to be provided within the unincorporated County. Land use and transportation goals and decisions should be integrated with one another and coordinated with adjacent jurisdictions.

T-3.2 Future land use projections based on County and jurisdiction comprehensive plans should Goal T-3: The transportation system should complement the land be used to identify and provide for adequate rights-of-way and other possible The transportation facilties in this area can support natural resource‐based use and rural areas element of the Grant County Comprehensive improvements. land‐use activities. Plan. T-3.3 Ensure the compatibility between land use activities and transportation facilities and services. T-3.4 Incorporate standards within the land development regulations to ensure that new development and redevelopment provide adequate transportation facilities within and adjacent to such development. T-4.1 Work with other jurisdictions to plan multi-jurisdictional projects necessary to meet shared transportation needs (including right-of-way preservation and purchase).

T-4.2 Each city should be responsible for identifying any standard and specification above County standards to be applied to transportation improvements within UGA boundaries. T-4.3 For County-funded road improvement projects within UGA boundaries, the County will be responsible for funding only those improvements to meet County standards. All other costs Goal T-4: The transportation system should be coordinated with associated with the improvements necessary to meet city standards should be the responsibility of the neighboring cities and other transportation providers. city. Not applicable. T-4.4 Upon annexation of an unincorporated area within UGA boundaries, the County and city should consider the fiscal impacts of providing service, including, but not limited to, the value of investments in infrastructure made. T-4.5 Work with the WSDOT, the Quad County Regional Transportation Planning Organization (QUADCO), and through other appropriate avenues to ensure that appropriate investments are made in the state transportation system to ensure the adequacy of the overall transportation system of the County. T-5.1 Promote bicycle and pedestrian facilities, wherever reasonable, to provide access between Goal T-5: The transportation system should provide mobility for all schools, recreation areas, business areas, public facilities, and activity centers. citizens regardless of age, handicap, Not applicable. or income. T-5.2 Provide public transit service in urban areas, rural residential areas, and other areas of the County when potential demand and public or private support justifies it. T-6.1 New developments should be prohibited unless transportation improvements to accommodate the impacts of development or funding strategies for such improvements are made concurrent with the development or will be financially planned to be in place within 6 years.

T-6.2 The peak period volumes generated by such development should be used as the primary measurement in establishing the proportionate share of street improvements which a proponent will be required to assume. T-6.3 If the County is faced with transportation funding shortfalls, alternative mechanisms, such as the following, should be considered to balance revenues and public facility needs, such as increased revenue through bonds, rates, taxes, and decreased demand for public services: 1. Increase revenues through use of bonds, new or increased user fees or rates, new or increased taxes, regional cost sharing, or voluntary developer funds. Goal T-6: The costs of transportation improvements associated with 2. Decrease LOS standards if consistent with GMA Goals. new development should be within the County’s funding capacity 3. Reprioritize projects to focus on those related to concurrency. Not applicable. and equitably assigned to the developer and County. 4. Decrease the cost of the facility by changing project scope or finding less expensive alternatives. 5. Decrease the demand for the public service. This could involve instituting measures to slow or direct population growth or development, for example, developing only in areas served by facilities with available capacity until funding is available for other areas, or by changing project timing and phasing. 6. Revise the Comprehensive Plan's Land Use and Rural Areas elements to change types or intensities of land use as needed to match the amount of transportation facilities that can be provided. T-6.4 A "working reserve" fund balance is desired to be maintained in the County Road Fund for emergencies, unanticipated safety upgrades, or similar County road needs. T-6.5 The County may wish to consider the fiscal impacts of road maintenance services, especially snow removal and sanding, through the adoption of service routes prioritized using land use density as a consideration. T-7.1 Incorporate the Six-Year Transportation Improvement Program into the County’s Capital Goal T-7: Establish a systematic process for reviewing and updating Facilities Plan by reference. Evaluate proposed transportation improvement projects annually and Not applicable. the Transportation Improvement Program. prepare a proposed Transportation Improvement Program. T-7.2 Encourage public involvement in transportation facilities planning. CF-1.1 Specify the standards for LOS in this Comprehensive Plan.

CF-1.2 Determine the need for public facilities based on the adopted standards for LOS, the demand, Goal CF-1: Establish LOS for public facilities and determine what and the inventory of existing serviceable facilities. capital improvements are needed in order to achieve and maintain CF-1.3 Prioritize and evaluate capital facilities annually. Not applicable. the standards for existing and future populations. CF-1.4 Priorities for capital improvements should be consistent with this Comprehensive Plan. CF-1.5 Provide non-capital alternatives to achieve and maintain the adopted standard for LOS. Non- capital alternatives may be programs, strategies, or methods other than traditional physical capital projects, such as telecommuting as an alternative to commuting to work and natural drainage in managed flood basins as an alternative to diking.

CF-2.1 The Capital Facilities Plan should integrate all of the County's capital project resources (grants CF-2.2 The estimated costs of all needed capital improvements should be consistent with the current s CF-2.3 Assess additional operations and maintenance costs associated with the acquisition or develop CF-2.4 Existing and future development should both pay for the costs of needed capital improvement CF-2.5 Capital improvements financed by County enterprise funds, such as solid waste, should be fina 1. Debt to be repaid by user fees and charges and/or connection or capacity fees for enterprise services 2. Current assets, including reserves, equity or surpluses and current revenue, including grants, loans, donations, and interlocal agreements 3. A combination of debt and current assets

CF-2.6 Capital improvements financed by non-enterprise funds should be financed from either current assets, debt, private sources, or a combination thereof. Financing decisions should consider which funding source or combination of sources will be: 1) most cost-effective; 2) consistent with prudent asset and liability management; 3) appropriate to the useful life of the improvement; and 4) the most efficient use of the County’s ability to borrow funds. CF-2.7 Efficient and joint use of facilities should be encouraged with neighboring governments and private citizens through such measures as interlocal agreements and negotiated use of privately and publicly owned lands or facilities (such as open space, stormwater facilities, or government buildings). Goal CF-2: The costs of proposed County-owned capital facilities CF-2.8 Regional funding strategies should be explored for capital facilities to support should be within the County's funding capacity and equitably comprehensive plans developed under the GMA. Not applicable distributed between users and the County in general. CF-2.9 Agreements should be developed between the County and cities for transferring the financing of capital facilities in the UGAs to the cities when they annex the contributing lands. CF-2.10 Special purpose districts providing public facilities and services should conduct at least a basic level of capital facilities planning consistent with this Comprehensive Plan. CF-2.11 Public utility services should be provided at the lowest possible cost, but take into account both construction and operation and maintenance costs. CF-2.12 New public utility services should provide adequate growth capacity and avoid expensive remedial action. CF-2.13 Finance capital facilities within the County’s financial capacity. If the County is faced with capital facility funding shortfalls, any combination of the following strategies should be used to balance revenues and public facility needs: 1. Increase revenues through use of bonds, new or increased user fees or rates, new or increased taxes, regional cost sharing, or voluntary developer funds. 2. Decrease LOS standards if consistent with GMA Goals. 3. Reprioritize projects to focus on those related to concurrency. 4. Decrease the cost of the facility by changing project scope or finding less expensive 5. Decrease the demand for the public service or facility. This could involve instituting measures to slow or direct population growth or development, for example, developing only in areas served by facilities with available capacity until funding is available for other areas or by changing project timing and phasing.

6. Revise the Comprehensive Plan's Land Use and Rural Areas elements to change types or intensities of land use as needed to match the amount of capital facilities that can be provided. CF-3.1 Land use decisions as identified in the comprehensive plans of the County and cities should be the determinants of development intensity rather than public utility decisions and public utility planning. Goal CF-3: Public facilities and services should be provided CF-3.2 Review the plan and zoning regulations where land use plans and zoning regulations conflict Grant County retains authority to regulate utilities in the Rural Resource commensurate with planned development intensities without unduly with long-range plans for public utilities. designation. impacting current service levels. CF-3.3 Extension of services and construction of public capital facilities should be provided at levels consistent with development intensity identified in this Comprehensive Plan. CF-3.4 Public utility services within UGAs and areas of more intense development should be phased outward from the urbanizing core in order to promote infilling. CF-4.1 Conduct major rehabilitation work on the Grant County Courthouse and other significant Goal CF-4: Operate and maintain facilities in a manner that will historic buildings owned by the County in reasonable conformance with state and ensure their longevity, provide for user access and safety, and foster federalrequirements. Not applicable. user respect and care for resources and facilities.

CF-5.1 Impacts on water resources, drainage systems, natural habitat, significant cultural resources, Goal CF-5: Public entities and utility providers should mitigate geologically hazardous areas, other sensitive areas and transportation systems should be considered The Grant County code and Rural Resource zone have sideboards to protect adverse impacts on the environment andother public facilities. and adverse impacts avoided or mitigated. sensitive areas through design requirements and project‐level permitting.

CF-6.1 Work with cities, Grant PUD, state and federal agencies, and other local governments to coordinate park needs throughout the County and to identify regional funding strategies. Goal CF-6: Coordinate planning of parks, trails, and natural preserves with other local, state, and federal government within the CF-6.2 Acquisition of parks, paths, trails, and preserves should occur in a coordinated manner, Not applicable. County to serve all residents of the County. within an overall plan that identifies priorities, funding sources, and a timetable for acquisition. CF-6.3 Cooperate with other public agencies to share public facilities for park and year-round recreation use by County residents.

CF-7.1 LOS standards must be realistic and attainable. LOS standards should be based on the following criteria: 1. Consideration of national, state, and professional standards for the applicable space Goal CF-7: County government facilities should consider efficient 2. Applicable federal and state laws Government facilities in the Rural Resource zone are permitted under the use of public resources, convenient access to residents, and adaptive 3. Cost effectiveness and consideration of the ability of the County to fund ongoing costs of Conditional Use Permit process and will be considered at the project‐level. re-use of historic buildings. CF-7.2 Efficiency in design and use should be a goal for new facility development. Building design and function must promote flexibility to accommodate a variety of uses and interior spatial changes. CF-7.3 Consider adaptive reuse of historic buildings when feasible. CF-8.1 Where the size of a single proposed development warrants, the developer should identify at the first stage of project review proposed school sites meeting school district standards such as topography, acreage requirements, location, and soil quality. Such sites should be dedicated for Goal CF-8: Work with school districts to ensure that new school school use. No project actions are proposed as part of the proposed Comprehensive Plan facilities are coordinated with growth Amendment application. and their impacts on roads and neighboring uses are considered. CF-8.2 Where practical, schools should be located along non-arterial roads, or should include frontage and off-site improvements needed to mitigate the impacts of pedestrian and vehicular traffic. Availability of sewer and water facilities should also be considered in siting schools, as well as location in areas not subject to safety hazards. U-1.1 Coordination with utility service providers about future plans, population forecasts, and relevant data as available. U-1.2 Encourage the location of necessary utility facilities within existing and planned transportation and utility corridors. U-1.3 Coordinate land use planning with the planning activities of electrical, telephone, and cable Major utility infrastructure is permitted through the Conditional Use Permit Goal U-1: Ensure that necessary energy and communication providers for existing and future facilities. process in the Rural Resource zone. This process gives Grant County facilities and services are available to support current and future U-1.4 New city-provided utility service area boundaries should not be extended beyond their Development Services and decision‐making authorities purview over if/how development. associated UGA unless to address a public health safety concern. utility infrastructure may move forward in the proposal area. U-1.5 Encourage energy conservation by informing citizens of available Bonneville Power Administration conservation programs. U-1.6 Encourage improvement and extension of telecommunication services, including the entrance of new qualified providers, throughout the County. U-2.1 Electric power substations should be reasonably sited, designed, and buffered. U-2.2 Encourage implementation of resource conservation practices and best management practices du U-2.3 Work cooperatively with surrounding municipalities in the planning and development of multi- jurisdictional utility facility additions and improvements. U-2.4 Where practical, utilities should be encouraged to place facilities underground and The proposal area includes and is adjacent to a major network of electrical encourage the reasonable screening of utility meter cabinets, terminal boxes, pedestals, and infastructure. For this reason, there are opportunities to meet goals for Goal U-2: Minimize impacts associated with the siting, transformers in a manner reasonably compatible with the surrounding environment. minmizing impacts, while supporting utility business endeavors. Major utility development, and operation of utility services and facilities on U-2.5 Where possible, the joint use of transportation rights-of-way and utility corridors should be infrastructure is permitted through the Conditional Use Permit process in the adjacent properties, significant cultural resources, and the natural encouraged, provided that such joint use is consistent with limitations as may be prescribed by Rural Resource zone. This process gives Grant County Development Services environment. applicable law and prudent utility practice. and decision‐making authorities purview over if/how utility infrastructure may U-2.6 The County should maintain updated County ordinances for regulating use of rights-of-way by move forward in the proposal area. utilities to ensure compliance with applicable state and federal laws.

U-2.7 Develop mechanisms to notify interested utilities of road maintenance, upgrades, and new construction to facilitate coordination of public and private utility trenching activities. U-3.1 The extension and sizing of distribution system components should be consistent with the Goal U-3: Maintain consistency, compatibility, and concurrency Comprehensive Plan. No project actions are proposed as part of the proposed Comprehensive Plan between utility providers. Amendment application. U-3.2 Coordinate between plat approvals, building permit approvals, and availability of utilities. U-4.1 Agreements should be developed with private utility providers and public agencies as required to facilitate the following activities:

Major utility infrastructure is permitted through the Conditional Use Permit 1. Joint use of utility corridors and public rights-of-way process in the Rural Resource zone. This process gives Grant County 2. Coordination between this Comprehensive Plan and utility capital facility plans Goal U-4: Coordinate and encourage timely, safe, cost-effective, and Development Services and decision‐making authorities purview over if/how 3. Timely notices of new road construction and maintenance of existing roads with utility reliable installations of utility systems through improved permit utility infrastructure may move forward in the proposal area. The area, construction activities procedures, joint use of utility corridors, and interlocal agreements. 4. Coordinated permit applications and meetings to include all necessary utilities affected colocated with electrical infrastructure associated with Vantage Substation, by related projects may be a suitable location for meeting goals of Grant County Comprehensive Plan. 5. Coordination of land acquisition, land use, and enhancement of utility corridors where appropriate, for pedestrian and equestrian trails and wildlife corridors U-4.2 New facility designs should include joint usage where possible. U-4.3 Processing of utility permits should be done in a timely and cost-effective manner. U-5.1 Utility providers should avoid placement of facilities in areas designated as environmentally sensitive or critical areas unless no feasible alternative exists and only after a site assessment and mitigation plan has been approved under the provisions of Grant County’s Resource Lands and Major utility infrastructure is permitted through the Conditional Use Permit CAO. process in the Rural Resource zone. This process gives Grant County Development Services and decision‐making authorities purview over if/how Goal U-5: Site utility facilities in conformance with the Land Use utility infrastructure may move forward in the proposal area. The area, Element. U-5.2 Utility facilities should be permitted in all land use designations as necessary when and where colocated with electrical infrastructure associated with Vantage Substation, utility franchises exist and if they are in compliance with this Comprehensive Plan. may be a suitable location for meeting goals of Grant County Comprehensive U-5.3 Siting of wireless technologies should minimize the visual and noise impacts and use existing Plan. sites and structures where possible, adequate setbacks, and appropriate buffering and landscaping.

U-6.1 Allow sewer systems in designated UGAs. They should be allowed in rural areas only to address identified health hazards or water quality problems in areas of existing development. U-6.2 The County should be the primary sewer system provider in unincorporated rural areas where sewer systems are being provided.

Goal U-6: Provide public water and sewer systems in rural areas Rezoning the proposal area to the Rural Resource zone will not result in U-6.3 In unincorporated areas inside the UGAs around cities, the cities should be the primary water only to address public health problems. changes to water providers in the area. and sewer provider. As exceptions, the County could provide sewers in this area on an interim basis if the cities are unable to provide the service or to protect water quality. U-6.4 In order to resolve documented health hazards, safety, or pollution problems in areas of existing rural development, the County may serve as the water utility owner, or develop a proactive assistance program focused on keeping small distribution systems in private ownership. U-7.1 Practice integrated and efficient management of solid waste in accordance with the Washington State waste management priorities, with adequate resources to manage solid wastes safely, efficiently, and equitably while recognizing local conditions.

U-7.2 Provide for solid waste disposal services at a publicly or privately owned and operated, legally permitted disposal facility, either within Grant County or at a location remote from the County, in the Goal U-7: Manage the solid waste system in a manner that cost- most cost-effective manner possible. Environmental and economic impacts should be considered and Rezoning the proposal area to the Rural Resource zone will not result in effectively preserves the environment and protects the public health. balanced when determining disposal practices. changes to waste disposal in the area.

U-7.3 Provide a recycling program with goals of reducing or recycling the County's waste stream as defined in the 2008 Grant County Solid Waste Management Plan Update and subsequent amendments. Reducing per capita waste consumption should be supported through educational and legislative efforts that are directed towards changing consumer and industrial practices. EPF-1.1 Implement requirements for siting essential public facilities through relevant development EPF-1.2 The County should not exclude the siting of essential public facilities, provided that any Goal EPF-1: Establish a process and siting criteria for Essential The Comprehensive Plan Amendment applicatioon does not include essential 1. Meet existing federal, state, and County land use regulations, development standards, Public Facilities that complies with this public facilities. Any project‐level permitting review would take place at the 2. Conform to this Plan Comprehensive Plan. Conditional Use Permit stage. 3. Address all SEPA provisions and environmental issues, including concurrency of EPF-1.3 Siting of essential public facilities should be done with public participation.

EPF-2.1 The County should obtain or secure (e.g., by obtaining a right of first refusal for desired Goal EPF-2: Identify and provide adequate, well-located public property) sites needed for County public facilities as early as possible in the development of an area, lands for public purposes, including to ensure that the facilities are well-located to serve the area and to minimize acquisition costs. Not applicable. essential public facilities. EPF-2.2 The County should support regional coordinating efforts in identifying shared needs for lands for public purposes to maximize the efficient use of public capital resources. NS-1.1 Wetland areas should be identified and delineated by the development applicant and reviewed by the County prior to development. NS-1.2 Consider accepting written determinations, delineations, and mitigation plans only from the U.S. Army Corps of Engineers, Ecology, the Natural Resources Conservation Service (NRCS), or a qualified critical areas professional. Consider requiring that mitigation plans for unavoidable wetland impacts to be based on a wetland functional assessment. NS-1.3 Wetlands should be protected from alterations due to land use changes that may create adverse impacts to the wetland consistent with the Resource Lands and CAO. Per Washington and Federal GIS sources, the proposal area does not have wetland areas. If wetlands are found following future inventories, the Rural Goal NS-1: Wetlands should be protected for the important NS-1.4 Rely on wetland ratings from Washington State Wetlands Rating system for Eastern Resource zone would not prevent Grant County from implementing wetlands ecological functions they provide. Washington. NS-1.5 Whenever feasible, innovative techniques that enhance a wetland and promote it as a useful, protections at the project level. New authorized uses permitted under the functioning part of the development should be encouraged, such as conservation practices under the Rural Resource zone are consistent with ongoing land‐uses. County’s VSP program, along with other applicable programs. NS-1.6 Support wetland preservation strategies and efforts, such as establishing and maintaining wetland banking, wetland protection and enhancement through conservation practices, and other measures. NS-1.7 Wetland protection and enhancement strategies should be coordinated with appropriate local, state, and federal agencies and private conservation organizations to take advantage of both technical and financial assistance and to avoid duplication of efforts. NS-2.1 Identify critical groundwater supply areas, aquifer recharge areas, and areas with a high groundwater table and/or unconfined aquifers that are used for potable water. NS-2.2 Encourage cluster developments that implement shared community sewage disposal systems instead of dispersed individual septic systems. NS-2.3 Incorporate best management practices concerning waste disposal, fertilizer use, pesticide use, and stream corridor management in agricultural activities, including commercial and hobby type activities, consistent with the County’s VSP implementation strategies. NS-2.4 Fertilizer and pesticide management practices of schools, parks, golf courses, and other Goal NS-2: Areas demonstrated to be critical aquifers and/or which recreational or institutional facilities that maintain large landscaped areas should be evaluated at the play a crucial role in recharging groundwater supplies should be time of development in relation to best management practices. Existing facilities are strongly The area does not overlap with critical groundwater/aquifer recharge areas. preserved to protect potable water sources. encouraged to also incorporate best management practices. NS-2.5 Within aquifer recharge areas, divisions of land and subsequent developments should be evaluated for their impact on groundwater quality.

NS-2.6 Development that could substantially and negatively impact the quality of an aquifer should not be allowed unless it can be demonstrated that these negative impacts can be mitigated. NS-2.7 The installation of underground fuel or storage tanks within a known critical recharge area should be prohibited. Installation in any other areas should be subject to applicable federal, state, and local regulations. NS-3.1 Frequently flooded areas should be identified and mapped. NS-3.2 The natural flood storage function of floodplains should be preserved where practicable through applicable programs, practices, and planning processes. NS-3.3 Protect floodplains by locating roads and structures above the flood level. Where filling is allowed, development should mitigate impacts, such as the existing flood storage capacity and fish Goal NS-3: Frequently flooded areas that are known to be critical and wildlife habitat lost to filling. parts of the natural drainage system should be protected by adopting The proposal area does not overlap with FEMA floodplains. Compatibility with NS-3.4 Encourage growth and development compatible with natural drainage features, and policies and regulations to prevent potential alterations and drainage features can be considered during future project‐level permits. discourage alteration of natural drainage features. obstructions to those areas. NS-3.5 Encourage control of erosion at its source as a means of controlling water pollution, flooding, and habitat damage downstream.

NS-3.6 Development in frequently flooded areas that poses a threat to human health and property by reason of flooding, unsanitary conditions, or other hazards should be limited and/or mitigated.

NS-4.1 Require documentation of probable significant adverse impacts from geologically hazardous areas identified during the review of a development application, which fully addresses potential impacts and identifies alternative mitigation measures to eliminate or minimize the impacts. NS-4.2 Grading and clearing for both private developments and public facilities or services should be limited to the minimum necessary to accomplish engineering design, with reclamation of disturbed areas being a top priority. The area overlaps with areas that are susceptible to erosion. Design features NS-4.3 To minimize blowing soil during development, appropriate water and mulch material should and avoidance approaches at the project‐stage can meet Grant County policies Goal NS-4: Take appropriate measures to either avoid or mitigate be required on any areas without a vegetative cover, as indicated in an approved erosion control plan. to minimize impacts. The Rural Resource zone does not present risk or hazard significant risks to public and private property and to public health NS-4.4 To maintain the natural integrity of landslide hazard areas, protect the environment, and to Grant County property or to the general public. Local, state, and federal and safety that are posed by geologically hazardous areas. protect the public health and safety, an adequate buffer of existing vegetation should be maintained around all sides of landslide hazard areas. policies provide adequate protections for uses permitted under the Rural Resource zone. NS-4.5 Development on steep slopes should prevent damage to property and public safety and environmental degradation. NS-4.6 In areas subject to erosion, native ground cover should be retained or replaced after construction, special construction practices should be used, and allowable site coverage may need to be reduced to prevent erosion and sedimentation. Limitations on the time when site work can be done may also be appropriate. NS-4.7 Protect and enhance critical areas through agricultural conservation practices that maintain soil on agricultural lands in higher erosion risk areas. NS-5.1 Identify critical fish and wildlife habitat conservation areas within the County. NS-5.2 Consider the impacts of new development on the quality of land, wildlife, and vegetative resources as part of the environmental review process, and require appropriate mitigating measures. Such mitigation may involve the retention and/or enhancement of habitats. NS-5.3 Encourage the preservation of blocks of habitat and the connections between them, as well as the restoration of lost and damaged fish habitat. The proposal area has minimal overlap with wildlife areas identified in the NS-5.4 Encourage proper riparian management that maintains existing riparian habitat and is Grant County Comprehensive Plan. The area does overlap with priority habitat Goal NS-5: Protect fish and wildlife habitat areas as an important consistent with conservation practices implemented under VSP. areas identified by WDFW. However, land uses permitted under the Rural natural resource, particularly in regard to their functions and NS-5.5 Land uses adjacent to naturally occurring water bodies and other fish and wildlife habitat Resource zone do not present additional impacts beyond existing land use economic, ecological, aesthetic, and quality of life values. areas should not negatively impact the habitat areas. If a change in land use occurs, adequate buffers activities. Project‐level impacts and design requirements will be considered should be provided to the habitat areas. through the Conditional Use Permit process.

NS-5.6 Activities allowed in fish and wildlife habitat conservation areas and open space should be consistent with the species located there, and in accordance with all applicable state andfederal regulations and/or best management practices for the activity regarding that species. NS-5.7 Support implementation of conservation practices on agricultural lands through the VSP that protect and enhance fish and wildlife habitat conservation areas. Goal NS-6: Privately-held certificates of water right should be recognized as an important natural resource and protected, to the No policies outlined for this goal Not applicable. extent practicable, through County planning decisions, which encourage continued use for rural activities. NS-7.1 The County should attempt to limit potential damage, dangers, or public costs associated with inappropriate land development by reasonable regulation of and application of uniform surface water and erosion control standards.

NS-7.2 New development activities, including site designs and construction practices, should make provisions for surface water and erosion and sedimentation control during and after construction. NS-7.3 Consistent and appropriate implementation of physical aspects of land alteration should be encouraged.

Goal NS-7: Development should be conducted in a manner that The Comprehensive Plan Amendment applicatioon does not include project NS-7.4 Land uses compatible with the preservation of natural vegetation should be encouraged. protects surface and groundwater quality and habitat, prevents actions.. Any project‐level permitting review would take place at the NS-7.5 Public improvements and private developments should not alter natural drainage systems chronic flooding from stormwater runoff, maintains natural stream Conditional Use Permit stage. The Rural Resource zone meeets the Goals and without acceptable mitigating measures that limit the risk of flooding or negative impacts to water hydrology, and protects aquatic resources. Policies of NS‐7. quality. NS-7.6 Natural surface water storage sites that help regulate streamflows and/or recharge groundwater should be preserved and their water quality protected. NS-7.7 Surface water runoff from development adjacent to steep slopes, ravines, or bluffs should be routed so it does not cause erosion or landslides. Runoff should be sufficiently diffused so that flows do not create erosion. NS-7.8 Natural stream channels should be preserved, protected, and enhanced for their hydraulic, ecological, and aesthetic functions through development regulations, land dedications, easements, acquisition, and other means. NS-8.1 Support efforts to secure long-term, sustainable water supplies that are consistent with the Grant County Comprehensive Land Use Plan or the comprehensive land use plans of the municipalities within Grant County.

NS-8.2 Encourage water reuse, conservation, and responsible stewardship through the development of voluntary conservation programs, educational outreach, and alterations to current water policy that provide incentives for common sense approaches to stewarding water resources.

NS-8.3 Support increasing water storage by increasing capacity in existing reservoirs, developing new aboveground water storage capacity, and the development of storage capacity through aquifer storage and recovery, enhanced water recharge, and other groundwater management strategies. NS-8.4 Support groundwater management strategies that permit the responsible development of Goal NS-8: Conserve, maintain, and manage existing ground and groundwater resources, while protecting the long-term sustainability of aquifers. surface water resources to meet existing and future water supply NS-8.5 Encourage water management practices that will allow and provide incentives for reclaiming needs for cities, farms, industry, and rural growth. water resources that retain economic and recreational resources. Such practices include reclaiming waters used for food processing to irrigate crops or reclaiming wastewater to support industrial uses and developed open spaces, such as parks or golf courses. NS-8.6 Encourage voluntary conservation of water resources through xeriscape (low water use landscape plantings) and other low water use methods.

NS-8.7 Encourage water marketing (the trading of water rights as commodities) providing thereare sufficient controls in place to protect the basic needs of Grant County citizens and industries. NS-8.8 Support the Water Conservancy Board in reviewing and facilitating the transfer of water rights and approving water right change applications. NS-8.9 Support selective continued issuance of new water rights from groundwater sources where new water rights will not impair existing rights and are consistent with the long-term sustainability of The Comprehensive Plan Amendment applicatioon does not change water uses aquifers. in the area. Any project‐level permitting review would take place at the NS-8.10 Endorse responsible stewardship of municipal water supplies. Conditional Use Permit stage. NS-8.12 Work to identify opportunities for water conservation on County property and at County facilities. NS-8.13 Encourage the use of irrigation water for non-potable uses in housing units, parks, and other developed lands within water service areas. NS-8.14 Acknowledge that municipal governments and other water utilities, as applicable, are the best long-term water supply service providers within designated UGAs. NS-8.15 Consider existing public or private water purveyors first when the need arises for a rural domestic water supplier. NS-8.16 Look to Satellite Management Agencies first for assistance with operations and management of failing or troubled water systems throughout the County. Encourage an increase in the number of approved Satellite Management Agencies in the County.

NS-8.17 Public and private purveyors, along with exempt wells operated by individual households, adequately provide for water needs in rural areas of the County. The County will not seek to become a residential water purveyor except where mandated by the state under RCW 43.70.195. NS-8.18 Recognize that new rural water right permit exempt wells in the unconfined aquifer are junior to senior surface water rights, and may have potential for impairment. As applicable, support implementing mitigation strategies to offset impacts from exempt wells that allow for continued growth and development. NS-8.19 Provide for future reservations, water banks, or other dedicated rural water supply sources necessary to support continued rural growth in unincorporated areas of the County. NS-8.20 Encourage efforts to secure long-term water supplies to support the County’s strong and diverse agriculture economy. NS-8.21 Encourage the continued development of water transfers and changes to meet changing agricultural production needs. NS-9.1 Prohibit developments that have the potential for significant individual or cumulative impacts on ground and surface water quality or, alternatively, site and design developments to avoid or mitigate such impacts. NS-9.2 Protect surface and groundwater quality as a resource essential to the public health, safety and welfare, economic growth, and prosperity of Grant County. Goal NS-9: Protect and enhance surface and groundwater water NS-9.3 Support development and management of County-owned storm water systems that protect The Rural Resource zone has adequate protections for protecting surface and quality for human health, drinking water supply, and to meet water surface and groundwater quality consistent with local conditions. groundwater quality. quality standards. NS-9.4 Support the Grant County Health District to develop and implement septic tank and drain field standards that protect surface and groundwater quality and human health. NS-9.5 Encourage educational programs and voluntary efforts of agricultural producers, processors, irrigation districts, and municipal users to responsibly manage return flows to improve surface and groundwater quality. NS-10.1 Encourage use of the Columbia River and its reservoirs as a key element in ensuring longterm availability of water supply, power generation, and flood control and support for population Not applicable. GOAL NS-10: Support continued multi-purpose uses of the growth, agricultural production, industry, fisheries, and economic development. Columbia River. NS-10.2 Support water resource policy decisions based on defensible science to meet the needs of people and fish and wildlife. NS-11.1 Support strategies that improve flows for anadromous fish and other fish and wildlife during all types of water years on the Columbia River and other applicable streams in Grant Goal NS-11: Protect and enhance surface water resources to support County. The Rural Resource zone has adequate protections for protecting surface and rivers, streams, and wetlands that support fish and wildlife species groundwater quality. and associated habitats. NS-11.2Promote a balanced response to listings of threatened and endangered species that provides improved conditions for species maintenance and recovery, while maintaining and allowing sustainable development of water resources for economic growth. NS-12.1 Identify known, recorded archaeological, cultural, and historic resources. NS-12.2 Develop a local process for evaluating the significance of historic, cultural, and archaeological resources. NS-12.3 Preserve areas that contain valuable historical or archaeological sites of federal, state, tribal, Goal NS-12: Identify, preserve, and protect historic, cultural, and or local significance. Maintain and enforce provisions to the Resource Lands and CAO requiring archaeological resources found to be significant by recognized local, No historic, cultural, or archaelogical sites are known to be on site. conditioning of project approval on findings made by a professional archaeologist for development state, or federal processes. activities on sites of known cultural, historical, or archaeological significance. NS-12.4 Prior to demolition, moving, or alteration to any designated historic, cultural, and archaeological landmark, ensure that due consideration is given to its preservation or, at a minimum, documentation of its historic, cultural, or archaeological value. Goal NS-13: Protect life and property in rural and resource areas of NS-13.1 The County should prepare an implementation plan for fire safety, fire prevention for rural Not applicable. the County from fire hazards. and resource lands, and development standards. Goal NS-14-A: Support water-oriented uses to maximize the NS-14.1 Ensure healthy, orderly economic growth by allowing those economic activities that will be positive economic impact of tourism and an asset to the local economy, and for which the adverse effects on the quality of the shoreline and recreational development. surrounding environment can be mitigated. NS-14.2 Develop, as an economic asset, the recreation and tourism industry along shorelines in a manner that will enhance public enjoyment. NS-14.3 Give preference to economic activities, which either leave natural or existing shoreline Goal NS-14-B: Preserve existing agricultural industry with features such as trees, shrubs, grasses, and wildlife habitat unmodified, or which modify them in a sensitivity to the environment and aesthetic character that way that enhances human awareness and appreciation of the shoreline and other natural and non- incorporates low impact technologies and provides opportunities for natural surroundings. Prohibit the introduction of invasive plant species along shorelines and public enjoyment of the shoreline. encourage the removal of noxious and invasive weeds and trees. NS-14.4 Encourage new water-dependent, water-related, and water-enjoyment economic development in priority order. The Rural Resource zone supports an economy based on natural resources. NS-14.5 Ensure that any economic activity taking place along the shoreline operates without causing Future project actions will be considered at the project‐stage. The Conditional irreparable harm to the quantity of the site’s environment or adjacent shorelands. Use Permit process is an appropriate vehicle for considering balanced land‐ Goal NS-14-C: Promote economic growth that conserves natural NS-14.6 Where possible, developments are encouraged to incorporate low impact development use, design features, and impact minimization. resources and open spaces, and maintains environmental quality and techniques into new and existing projects and integrate architectural and landscape elements that rural character. recognize the river environment. NS-14.7Require non-water-oriented commercial or recreational developments provide forecological restoration and public access as appropriate.

NS-14.8 Assure that commercial and agricultural uses will not result in a net loss of shoreline ecological functions or have significant adverse impacts on navigation, recreation, and public access. NS-14.9 Promote water-oriented commercial uses in shoreline areas that support recreation and NS-14.10 Maintain current agricultural uses as a major economic strength of the County. NS-14.11 Protect current agricultural land uses of long-term commercial significance and provide for NS-14.12 Support implementation of conservation practices on agricultural lands that protects Goal NS-15-A: Implement a public access system that increases the NS-15.1 Ensure that developments, uses, and activities on or near the shoreline do not impair or amount and diversity of public access consistent with private detract from the public’s access to the water. Where practicable, public access to the shoreline should property rights, public safety, and the natural shoreline’s character. be enhanced (Existing SMP policy (5)(A)). NS-15.2 Design public access such that it provides for public safety and minimizes potential impacts to private property and individual privacy (Existing SMP policy (5)(B)).

NS-15.3 Locate, design, manage, and maintain public access and recreation facilities in a manner that protects shoreline ecological functions and processes and public health and safety. NS-15.4 Encourage federal, state, and local governments to enhance existing shoreline properties in Grant County for public access and recreational use.

NS-15.5 Identify opportunities for public access on publicly owned shorelines. Preserve, maintain, and enhance public access afforded by shoreline street ends, public utilities, and rights-ofway. NS-15.6 Provide physical and visual public access in the shoreline jurisdiction in association with the following uses when feasible: residential developments with five or more dwellings; commercial development; and public agency recreational development. Not applicable. The Rural Resource zone does not change public access or Goal NS-15-B: Provide opportunities and space for diverse forms of NS-15.7 Provide public access and interpretive displays as part of publicly funded restoration recreation activities in the proposal area. water-oriented recreation in Grant County shoreline areas. projects where significant ecological impacts are addressed. NS-15.8 Allow for passive and active shoreline recreation that emphasizes location along shorelines in association with the County's and other public agencies' parks, recreation, wildlife habitat, and open space plans. NS-15.9 Encourage a variety of compatible recreational experiences and activities to satisfy the County's diverse recreational needs. NS-15.10 Give water-dependent recreation priority over water-enjoyment recreation uses. Give water- enjoyment recreational uses priority over non-water-oriented recreational uses. NS-15.11 Integrate and link recreation facilities with linear systems, such as walking trails, bicycle paths, easements, and scenic drives when feasible. NS-15.12 Promote non-intensive recreational uses that avoid adverse effects to the natural and CBP- enhanced hydrology of aquatic systems, do not contribute to flood hazards, and avoid damage to the shoreline environment through modifications such as structural shoreline stabilization or native vegetation removal. NS-16.1 Provide safe, reasonable, and adequate circulation systems to shorelines where routes will minimize adverse effects on unique or fragile shoreline features and existing ecological systems, while contributing to the functional and visual enhancement of the shoreline (Existing SMP policy (3)(A)). NS-16.2 Within the shoreline jurisdiction, locate land circulation systems that are not shoreline oriented as far from the land-water interface as practicable to reduce interference with either natural shoreline resources or other appropriate shoreline uses (Existing SMPpolicy (3)(B)). NS-16.3 Allow for maintenance and improvements to existing roads and parking areas. Allow for necessary new roads and parking areas where other locations outside of shoreline jurisdiction are not feasible. NS-16.4 Plan and develop a circulation network that is compatible with the shoreline environment, and respects and protects ecological and aesthetic values in the shoreline of the state as well as private property rights. Goal NS-16: Implement multi-modal transportation improvements NS-16.5 Include in circulation system for pedestrian, bicycle, equestrian, and public transportation that provide for mobility and access and that minimize adverse where appropriate. Circulation planning and projects should support existing and proposed shoreline Not applicable. impacts on the shoreline environment. uses that are consistent with the SMP. NS-16.6 Promote existing transportation corridors for reuse for water-dependent uses or public access when they are abandoned.

NS-16.7 Encourage relocation or improvement of those circulation elements that are functionally or aesthetically disruptive to the shoreline, public waterfront access, and ecological functions. NS-16.8 Plan parking to achieve optimum use. Where possible, parking should serve more than one use (e.g., recreational use on weekends and commercial uses on weekdays). NS-16.9 Encourage low-impact parking facilities, such as those with permeable pavements and bioswales. NS-16.10 Encourage trail and bicycle paths along shorelines in a manner compatible with the natural character, resources, and ecology of the shoreline. NS-16.11 Encourage the linkage of shoreline parks, recreation areas, and public access points with linear systems, such as hiking paths, bicycle paths, easements, and/or scenic drives.

NS-17.1 Maintain areas within the shoreline jurisdiction with unique attributes for specific long-term uses, including agricultural, commercial, industrial, residential, recreational, and open space uses. NS-17.2 Ensure that proposed shoreline uses are distributed, located, and developed in a manner that will maintain or improve the health, safety, and welfare of the public when such uses occupy shoreline areas. NS-17.3 Ensure that activities and facilities are located on the shorelines in such a manner as to retain or improve the quality of the environment. NS-17.4 Ensure that proposed shoreline uses do not infringe upon the rights of others, upon the rights of private ownership, upon the rights of the public under the Public Trust Doctrine or federal navigational servitude, and treaty rights of Indian tribes. NS-17.5 Minimize the adverse impacts of shoreline uses and activities on the environment during all phases of development (e.g., design, construction, management, and use). NS-17.6 Provide a comprehensive shoreline environment designation system to categorize Grant County's shorelines into environments based upon their primary characteristics to guide their use and management. NS-17.7 Designate properties as Natural to protect and restore those shoreline areas that are Goal 17-A: Encourage shoreline development that recognizes Grant relatively free of human influence or that include intact or minimally degraded shoreline functions The proposal area does not overlap with Shorelines identified in the Grant County's natural and cultural values and the unique aesthetic that are sensitive to potential impacts from human use. Natural areas should be managed consistent County Comprehensive Plan or designated by the State of Washington. qualities offered by its variety of shoreline environments. with the policies in Section 24.12.120 of the SMP.

NS-17.8 Designate properties as Shoreline Residential to accommodate higher-density residential development and recognize existing and proposed land uses. This designation is appropriate for residential uses on lands with zoning classifications for detached and attached residential. NS-17.9 Assign appropriate environment designations for agricultural land uses of long-term commercial significance for which adverse environmental effects can be mitigated. NS-17.10 Assign appropriate environment designations for preservation of wildlife habitat areas, natural resources, and public agency operations. NS-17.11 Designate properties within each environment designation based on the designation criteria in SMP Section II, Article II.

NS-17.12 This Comprehensive Plan recognizes the importance of agriculture in Grant County and supports its continued economic viability. This plan allows for ongoing agricultural activities and should protect agricultural lands from conflicting uses such as intensive or unrelated residential, industrial, or commercial uses, while also maintaining shoreline ecological functions and processes. NS-17.13 New agricultural development should be conducted in such a manner as to assure no net loss of shoreline ecological functions and processes. Goal 17-B: Grant County recognizes and protects the functions and NS-17.14 Maintain a vegetative buffer between agricultural lands and water bodies or wetlands, values of the shoreline environments of statewide and local along with voluntary conservation practices that can be implemented under the VSP and other significance. For shorelines of state-wide significance, protection and applicable programs. management priorities are to: NS-17.15 Conversion of agricultural uses to other uses should comply with all policies and 1. Recognize and protect the state-wide interest over local interest regulations for non-agricultural uses. 2hlhfhhli 2. Preserve the natural character of the shoreline NS-17.16 Aquaculture is a water-dependent use and, when consistent with control of pollution and 3. Provide long-term over short-term benefit avoidance of adverse impacts to the environment and preservation of habitat for resident native 4. Protect the resources and ecology of shorelines species, is a preferred use of the shoreline (Washington Administrative Code [WAC] 173-26- 5. Increase public access to publicly owned areas of shorelines 241(3)(b)). 6. Increase recreational opportunities for the public in shoreline areas NS-17.17 Give preference to aquaculture operations that minimize environmental impacts through use of fewer visible structures or less extensive substrate and vegetation modifications.

NS-17.18 Aquaculture should not be allowed in areas where it would degrade water quality, result in a loss of shoreline ecological function, impair navigation, or conflict with other waterdependent uses. NS-17.19 Design aquaculture facilities to minimize nuisance odors and noise, as well as visual impacts on surrounding shoreline development. NS-17.20 The rights of treaty tribes to aquatic resources within their usual and accustomed areas should be addressed through the permit review process. Direct coordination between the applicant/proponent and the tribe should be encouraged. NS-17.21 Locate and design boating facilities so that their structures and operations will be compatible with the area affected, such as environmental conditions, shoreline configuration, access, and neighboring upland and aquatic uses. NS-17.22 Require restoration activities when substantial improvements or repair to existing boating facilities is planned. NS-17.23 Boating facilities that minimize the amount of shoreline modification are preferred. NS-17.24 Boating facilities should provide physical and visual public shoreline access and provide for multiple uses, including water-related use, to the extent compatible with shoreline ecological functions and processes and adjacent shoreline use. NS-17.25 Boating facilities should be located and designed to avoid adverse effects upon riverine and nearshore processes such as erosion, littoral or riparian transport, and accretion, and should, where feasible, enhance degraded, scarce, and/or valuable shore features including accretion shoreforms. NS-17.26 Location and design of boating facilities should not unduly obstruct navigable waters and should avoid adverse effects to recreational opportunities such as fishing, shellfish gathering, pleasure boating, commercial aquaculture, swimming, beach walking, picnicking, and shoreline viewing. NS-17.27 To the extent feasible, limit the use of breakwaters, jetties, groins, weirs, or other similar structures to those projects providing ecological restoration or other public benefits. These structures should avoid and minimize significant ecological impacts. Impacts which cannotbe avoided should be mitigated. NS-17.28 Dredging and dredge material disposal should avoid and minimize significant ecological impacts. Impacts which cannot be avoided should be mitigated. NS-17.29 Design and locate new shoreline development to avoid the need for dredging. NS-17.30 Limit dredging and dredge material disposal to the minimum necessary to allow for shoreline restoration, flood hazard reduction, and maintenance of existing legal moorage and navigation. Dredging to provide for new navigation uses is prohibited. NS-17.31 Allow dredging for the primary purposes of flood hazard reduction only as part of a longterm management strategy consistent with an approved flood hazard management plan.

NS-17.32 Ensure that dredging operations are planned and conducted in a manner that will minimize interference with navigation and that will lessen adverse impacts to other shoreline uses. NS-17.33 Limit fill waterward of the ordinary high water mark to support ecological restoration or to facilitate water-dependent or public access uses. NS-17.34 Allow fill consistent with floodplain regulations upland of the ordinary high water mark provided it is located, designed, and constructed to protect shoreline ecological functions and ecosystem-wide processes, including channel migration, and is the minimum necessary to implement an approved project. NS-17.35 Locate, plan, and permit in-stream structures only when consistent with the full range of public interests, ecological functions and processes, and environmental concerns, with special emphasis on protecting and restoring priority habitats and species. NS-17.36 Locate mining facilities outside shoreline jurisdictions whenever feasible. NS-17.37 Do not allow mining in any location waterward of the ordinary high water mark. NS-17.38 Design and locate mining facilities and associated activities to prevent loss of ecological function. Give preference to mining uses that result in the creation, restoration, or enhancement of habitat for priority species. NS-17.39 Protect water bodies from sources of pollution, including but not limited to, sedimentation and siltation, chemical and petrochemical use, and spillage and storage/disposal of mining wastes and spoils.

NS-17.40 Mining operations should be located, designed, and managed so that other appropriate uses are not subjected to substantial or unnecessary adverse impacts from noise, dust, or other effects of the operation. The operator may be required to implement measures such as buffers, limited hours, or other mitigating measures for the purpose of minimizing adverse proximity impacts. NS-17.41 Moorage associated with a single-family residence is considered a water-dependent use provided that it is designed and used as a facility to access watercraft, and other moorage facilities are not available or feasible. Moorage for water-related and water enjoyment uses or shared moorage for multifamily use should be allowed as part of a mixed use development or where it provides public access. NS-17.42 New moorage, excluding docks accessory to single family residences, should be permitted only when the applicant/proponent has demonstrated that a specific need exists to support the intended water-dependent or public access use. NS-17.43 As an alternative to continued proliferation of individual private moorage, mooring buoys are preferred over docks or floats. Shared moorage facilities are preferred over single user moorage where feasible, especially where water use conflicts exist or are predictable. New subdivisions of more than two lots and new multifamily development of more than two dwelling units should provide shared moorage where feasible. NS-17.44 Docks, piers, and mooring buoys, including those accessory to single family residences, should avoid locations where they will adversely impact shoreline ecological functions or processes, including currents and littoral drift.

NS-17.45 Moorage should be spaced and oriented in a manner that minimizes hazards and obstructions to public navigation rights and corollary rights thereto such as, but not limited to, fishing, swimming, and pleasure boating, as well as private riparian rights of adjacent land owners. NS-17.46 Moorage should be restricted to the minimum size necessary to meet the needs of the proposed use. The length, width, and height of piers and docks should be no greater than that required for safety and practicality for the primary use.

NS-17.47 Pile supports are preferred over fills because piles do not displace water surface or aquatic habitat and are removable and thus more flexible in terms of long-term use patterns. Floats may be less desirable than pile structures where aquatic habitat or littoral drift are significant. NS-17.48 The use of buoys for small craft moorage is preferred over pile or float structures because of lesser long-term impact on shore features and users; moorage buoys should be placed as close to shore as possible to minimize obstruction to navigation. NS-17.49 Piers and docks should be constructed of materials that will not adversely affect water quality or aquatic plants and in the long term. NS-17.50 New pier and dock development should be designed so as not to interfere with lawful public access to or use of shorelines. Developers of new piers and shared moorage should be encouraged to provide physical or visual public access to shorelines whenever safe and compatible The proposal area does not overlap with Shorelines identified in the Grant with the primary use and shore features. County Comprehensive Plan or designated by the State of Washington.

NS-17.51 Shoreline recreational development should be given priority for shoreline location to the extent that the use facilitates the public’s ability to reach, touch, and enjoy the water's edge, to travel on the waters of the state, and to view the water and the shoreline. Where appropriate, such facilities should be dispersed along the shoreline in a manner that supports more frequent recreational access and aesthetic enjoyment of the shoreline for a substantial number of people. NS-17.52 Recreational developments should facilitate appropriate use of shoreline resources while conserving them. These resources include, but are not limited to: accretion shoreforms, wetlands, soils, groundwater, surface water, native plant and animal life, and shore processes. NS-17.53 Recreational facilities should be a combination of active and passive types. Location of such facilities should consider the ecological function and sensitive nature of the shorelines in order to avoid adverse impacts. For example, wildlife and habitat preservation areas with sensitive shoreline natures should have low impact recreational uses. NS-17.54 Recreational developments and plans should provide the regional population a varied and balanced choice of recreation experiences in appropriate locations. Public agencies should coordinate their plans and activities to provide a wide variety of recreational opportunities without needlessly duplicating facilities. NS-17.55 Encourage the linkage of shoreline parks, recreation areas, and public access points with linear systems, such as hiking paths, bicycle paths, easements, and/or scenic drives. NS-17.56 When feasible, recreation facilities should incorporate public education regarding shoreline ecological functions and processes, the role of human actions on the environment, and the importance of public involvement in shoreline management. Opportunities incorporating educational and interpretive information should be pursued in design and operation of recreation facilities and nature trails. NS-17.57 Locate and design recreational developments to preserve, enhance, or create scenic views and vistas in accordance with Section 24.12.260, Public Access of the SMP.

NS-17.58 Consider single-family residential development as a priority use only when developed in a manner consistent with the control of pollution and prevention of damage to the natural environment. NS-17.59 Locate and construct residential development in a manner that assures no net loss of shoreline ecological functions. NS-17.60 Ensure the overall density of development, lot coverage, and height of structures is appropriate to the physical capabilities of the site and consistent with the Comprehensive Plan. NS-17.61 Ensure new residential development provides adequate buffers or open space from the water to protect or restore ecological functions and ecosystem-wide processes, to preserve views, to preserve shoreline aesthetic characteristics, to protect the privacy of nearby residences, and to minimize use conflicts. NS-17.62 Make adequate provisions for services and infrastructure necessary to support residential development. NS-17.63 Design and locate residential development to preserve existing shoreline vegetation, to control erosion, and to protect water quality. NS-17.64 Design and locate new residences so that shoreline stabilization will not be necessary to protect the structure. The creation of new residential lots should not be allowed unless it is demonstrated the lots can be developed without the following criteria: 1. Constructing shoreline stabilization structures (such as bulkheads) 2. Causing significant erosion or slope instability 3. Removing existing native vegetation within shoreline buffers NS-17.65 Include provisions for shoreline vegetation restoration or enhancement, fish and wildlife habitat enhancement, and low impact development techniques in projects located within shoreline jurisdiction, where feasible, along with conservation practices implemented under the VSP. NS-17.66 Encourage and facilitate implementation of projects and programs included in the SMP Shoreline Restoration Plan. NS-17.67 Locate and design new development, including subdivisions, to eliminate the need for new shoreline modification or stabilization.

NS-17.68 Design, locate, size, and construct new or replacement structural shoreline stabilization measures to minimize and mitigate the impact of these modifications on the County's shorelines. NS-17.69 Give preference to non-structural shoreline stabilization measures over structural shoreline stabilization, and give preference to soft structural shoreline stabilization over hard structural shoreline stabilization. NS-17.70 Allow location, design, and construction of riprap and other bank stabilization measures primarily to prevent damage to existing development or to protect the health, safety, and welfare of Grant County residents. NS-17.71 Encourage fish-friendly shoreline design during new construction and redevelopment by offering incentives and regulatory flexibility. NS-17.73 Allow for utility maintenance and extension with criteria for location and vegetation restoration as appropriate.

NS-17.74 Plan, design, and locate utility facilities to minimize harm to shoreline functions, preserve the natural landscape, and minimize conflicts with present and future planned land and shoreline uses while meeting the needs of future populations in areas planned to accommodate growth. NS-17.75 Do not permit new non-water-oriented primary utility production and processing facilities, or parts of those facilities, such as power plants, solid waste storage or disposal facilities within shoreline jurisdiction unless no other options are feasible. Primary utility facilities, such as wastewater treatment plants and including expansion of existing facilities, should be located in shoreline jurisdiction only if no practical upland alternative or location exists. Such facilities and expansions should be designed and located to minimize impacts on shoreline ecological functions, including riparian and aquatic areas, and to the natural landscape and aesthetics. Public health and safety should be the highest priority for the planning, development, and operation of primary utility facilities.

NS-17.76 Locate utility transmission facilities for the conveyance of services, such as power lines, cables, and pipelines, outside of shoreline jurisdiction where feasible. Where permitted within shoreline jurisdiction, such facilities should be located within existing or approved road crossings, rights-of-way and corridors, or in such a way as to minimize potential adverse impacts on shoreline areas. Joint use of rights-of-way and corridors in shoreline areas should be encouraged. NS-17.77 Locate new utility facilities so as not to require extensive shoreline protection works. NS-17.78 Locate utility facilities and corridors to protect scenic views from public parks and trails. Whenever possible, such facilities should be placed underground, or alongside or under bridges. NS-17.78 Whenever possible, such facilities should be placed underground, or alongside or under NS-17.79 Design utility facilities and rights-of-way to preserve the natural landscape and to minimize conflicts with present and planned land uses. NS-17.80 Allow nonconforming existing legal uses and structures to continue in accordance with the SMP. Residential structures and appurtenant structures that were legally established and are used for a conforming use, but that do not meet standards for the following should be considered a conforming structure: setbacks, buffers, or yards; area; bulk; height; or density. NS-17.81 Allow alterations of nonconforming structures, uses, and lots in consideration of historic development patterns, when occupied by preferred uses, and when consistent with public safety and other public purposes. NS-17.82 Encourage transitions from nonconforming uses to conforming uses. NS-17.83 Allow for nonconforming structures to expand when they do not increase the nonconformity according to SMP requirements. NS-17.84 Allow for existing roads, driveways, and utility lines to continue and expand when they do not increase the nonconformity according to SMP requirements. NS-17.85 Consider the objective of no net loss of ecological function to guide review of proposed expansions or other changes to nonconforming uses and new development on nonconforming vacant lots. This objective may be addressed in an area-wide manner consistent with the SMP cumulative impacts analysis.

NS-18.1 Develop and implement management and voluntary conservation practices that will ensure a sustained yield of renewable resources of the shorelines while preserving, protecting, enhancing, and restoring unique and nonrenewable shoreline resources, environments, or features. NS-18.2 Reclaim and restore areas that are biologically and aesthetically degraded to the greatest extent feasible.

NS-18.3 Preserve scenic vistas, aesthetics, fisheries and wildlife habitat, and other critical areas. NS-18.4 Protect shoreline processes and ecological functions through regulatory and nonregulatory means that may include acquisition of key properties, conservation easements, regulation of development within shoreline jurisdiction, voluntary conservation practices, and incentives to private property owners to encourage ecologically sound design and implementation of best land management practices. Goal 18: Protect the natural and CBP-enhanced hydraulic, NS-18.5 Protect and manage shoreline-associated wetlands, including maintenance of sufficient The proposal area does not overlap with Shorelines identified in the Grant hydrologic, and habitat functions, and scenic as well as recreational volumes of surface and subsurface drainage into wetlands, to sustain existing vegetation and wildlife County Comprehensive Plan or designated by the State of Washington. values of Grant County's shorelines. habitat. NS-18.6 Work with other jurisdictional agencies in the region and with the private sector to deal effectively with regional and watershed-wide natural environment issues and the protection, preservation, and enhancement of all shorelines as fish and wildlife habitat. NS-18.7 Manage development to avoid risk and damage to property and loss of life from geological conditions. NS-18.8 Regulate development within the 100-year floodplain to avoid risk and damage to property and loss of life from geological conditions. NS-18.9 Prohibit the introduction of invasive plant species along shorelines, and encourage the removal of noxious and invasive weeds and trees. NS-18.10 Protect, enhance, and maintain healthy vegetation consistent with the local climate and nature of shoreline. NS-18.11 Enhance and restore areas that are biologically and aesthetically degraded to the greatest extent feasible while maintaining appropriate use of the shoreline. Goal 19A: Identify, preserve and protect historic, cultural, and NS-19.1 Identify, protect, preserve, and restore important archeological, historical, and cultural sites archaeological resources found to be significant by recognized local, located in shorelands. state, or federal processes.

NS-19.2 Encourage educational projects and programs that foster a greater appreciation of the The non‐project proposal will not impact archaelogical, historical, or cultural importance of shoreline management, maritime activities, environmental conservation, and maritime sites. history. Goal 19B: Encourage educational and scientific projects and programs that foster a greater appreciation of the importance of NS-19.3 Prevent public or private uses and activities from destroying or damaging any site having shoreline management, water-oriented activities, environmental historic, cultural, scientific, or educational value without appropriate analysis andmitigation. NS-20.1 Manage development proposed within floodplains and floodways consistent with the NS-20.1 Shoreline Management Act, the Federal Emergency Management Agency (FEMA) standards, and the Critical Areas Regulations for frequently flooded areas contained within the SMP. NS-20.2Work with cities and towns and state and federal agencies to deal effectively with regional Goal 20: Protect public safety within rivers' and creeks' floodways flooding issues. The proposal area does not overlap with FEMA floodplains. Compatibility with and floodplains and protect natural systems by preserving the flood drainage features can be considered during future project‐level permits. storage function of floodplains. NS-20.3 Control stormwater runoff in a manner consistent with low impact development practices which use natural detention, retention, and recharge techniques to the maximum extent possible. NS-20.4 Prohibit any development within the floodplain which would individually or cumulatively cause any increase in the base flood elevation beyond FEMA standards. NS-21.1 Shoreline uses should be located and designed to respect private property rights, maintain privacy of private property, be compatible with the shoreline environment, protect ecological Goal 21: Recognize and protect private property rights in shoreline functions and processes, and protect aesthetic values of the shoreline. Not applicable. uses and developments consistent with the public interest. NS-21.2 Public access to the shoreline such as trails, bikeways, or roads should consider privacy when locating them near privately-owned properties. Appendix D Permit Number: ______

Grant County Development Services P.O. Box 37 - 264 West Division Avenue Ephrata, WA 98823 (509) 754-2011 Ext 2501

TYPE OF PERMIT(S) YOU ARE APPLYING FOR (check all that apply) *SEE FEE SCHEDULE FOR APPLICATION FEE AMOUNT*

 Administrative Interpretation  Binding Site Plan  Conditional Use Permit  Discretionary Use Permit

 Planned Unit Development  Plat Alteration  Preliminary Subdivision  Reasonable Use Exception

 SEPA Short Subdivision  Site Plan Review  Utility Easement Extinguishment & Alt.

 Variance  Zone Change  Final Subdivision/Short Subdivision

APPLICANT INFORMATION APPLICANT

MAILING ADDRESS

PHONE NUMBER EMAIL ADDRESS

NAME, ADDRESS AND PHONE NUMBER OF PROPERTY OWNER(S), IF OTHER THAN APPLICANT

AGENT INFORMATION AUTHORIZED AGENT

MAILING ADDRESS

PHONE NUMBER EMAIL ADDRESS

PROJECT SITE INFORMATION SITE ADDRESS

ASSESSOR TAX PARCEL NUMBER(S) SITE SIZE (acres or sq. ft.)

SECTION TOWNSHIP RANGE FARM UNIT BLOCK

ZONING CLASSIFICATION COMPREHENSIVE PLAN DESIGNATION

- 1 - I acknowledge that:

1. The information, plans, maps and other materials submitted on and with this application are, to the best of my knowledge, a true and accurate representation of this proposal; 2. This application shall be subject to all additions to and changes in the laws, regulations and ordinances applicable to the proposed development until a determination of completeness has been made pursuant to GCC 25.04.160; 3. Grant County does not guarantee success of this permit application, and/or the issuance of an affirmative notice of action. The County's assistance to the applicant/owner does not preclude the need to address impacts raised by the public or by other federal, state or local agencies; 4. Project correspondence will be sent to the identified project agent, and may be sent to applicant. Failure to notify applicant does not constitute a procedural deficiency; 5. If the applicant is not the owner of the real property which is the subject of the permit application, this application and acknowledgment shall also be executed by each owner; 6. All persons executing this acknowledgment in a representative capacity shall be personally liable and hereby personally guarantee payment of all fees, expenses and costs required by this application; 7. If the applicant, representative and/or owner fail to respond to a request by the Department to submit additional information, or the applicant, representative and/or owner request, orally or in writing, that further processing be suspended or postponed, and if such failure to respond or requested suspension/postponement exceeds 90 days, the application shall be considered abandoned and all proposed development, uses and activities shall only be further considered in the submission of a new application and fees; 8. This application does not constitute approval of the proposed development activity and it is acknowledged that additional permit applications and approvals may be necessary to conduct specific activities and 9. Owner’s signature serves as authorization for Agent/Applicant to act on my behalf.

DATED: Applicant/Agent

Applicant/Agent

DATED: Owner

Owner

FOR STAFF USE ONLY:

Application Type: ______Fee Paid: ______

Application Type: ______Fee Paid: ______

Application Type: ______Fee Paid: ______

Sub-Total: ______

Subdivision & BSP - Proposed Number of Lots: ______Fee Per Lot: ______Sub-Total: ______

Intake By: ______Receipt #______TOTAL: ______

- 2 - Grant County Development Services P.O. Box 37 - 264 West Division Avenue Ephrata, WA 98823 (509) 754-2011 Ext. 2501

SEPA Checklist

The following information must be present to be accepted at the counter. Incomplete submittals will not be accepted.

Missing Counter Submittal Requirements Items Complete

  Completed Master Application (Signed & all parcel numbers included)

  Pre-Application Summary (If applicable)

  Complete SEPA Checklist

Site Plan (Consistent with GCC 23.04.140(f)(2)) or Other Land Use Permit   Plans, 5 copies

  Reproducible Site Plan at 11”x17”

  Applicable Fees

Counter Review By: ______

NOTE! The above required information is necessary to start the application review. Additional information/materials may be required during the course of project review.

Revised 04/11/2017 Grant County Development Services P.O. Box 37 - 264 West Division Avenue Ephrata, WA 98823 (509) 754-2011 Ext 2501

Grant County Development Services ENVIRONMENTAL CHECKLIST

SEPA Fee $300 RCW 197-11-960 (Fee Chg 5/09) *************************************************************************************************

Purpose of Checklist: The State Environmental Policy Act (SEPA), chapter 43.21C RCW, requires all governmental agencies to consider the environmental impacts of a proposal before making decisions. An environmental impact statement (EIS) must be prepared for all proposals with probable significant adverse impacts on the quality of the environment. The purpose of this checklist is to provide information to help you and the agency identify impacts from your proposal (and to reduce or avoid impacts from the proposal, if it can be done) and to help the agency decide whether an EIS is required.

Instructions for Applicants: This environmental checklist asks you to describe some basic information about your proposal. Governmental agencies use this checklist to determine whether the environmental impacts of your proposal are significant, requiring preparation of an EIS. Answer the questions briefly, with the most precise information known, or give the best description you can.

You must answer each question accurately and carefully, to the best of your knowledge. In most cases, you should be able to answer the questions from your own observations or project plans without the need to hire experts. If you really do not know the answer, or if a question does not apply to your proposal, write "do not know" or "does not apply." Complete answers to the questions now may avoid unnecessary delays later.

Some questions ask about government regulations, such as zoning, shoreline, and landmark designations. Answer these questions if you can. If you have problems, the governmental agencies can assist you.

The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The agency to which you submit this checklist may ask you to explain your answers or provide additional information reasonably related to determining if there may be significant adverse impact.

Use of checklist for non-project proposals: Complete this checklist for non-project proposals, even though answers may be "Does not apply." IN ADDITION, complete the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (PART D)

For non-project actions, the references in the checklist to the words "project," "applicant," and "property or site" should be read as "proposal," "proposer," and "affected geographic area," respectively.

“TO MEET CURRENT AND FUTURE NEEDS, SERVING TOGETHER WITH PUBLIC AND PRIVATE ENTITIES, WHILE FOSTERING A RESPECTFUL AND SUCCESSFUL WORK ENVIRONMENT.” STAFF USE ONLY

Fee: $300 GRANT COUNTY ENVIRONMENTAL CHECKLIST

For photocopying purposes please fill this form out in black ink or type. Thank you.

A. BACKGROUND

1. Name of proposed project, if applicable:

2. Applicant's Name: ______Address: ______Phone number(s) ______Tax Parcel Number ______Section ______Township ______Range ______

3. Contact person/agent (if applicable) Name: ______Address: ______Phone number(s) ______

4. Date checklist prepared:

5. Agency requesting checklist:

6. Proposed timing or schedule (including phasing, if applicable):

7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes explain.

8. List any environmental information you know that has been prepared, or will be prepared, directly related to this proposal.

9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes explain.

10. List any government approvals or permits that will be needed for your proposal, if known.

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11. Give a brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page.

12. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist.

TO BE COMPLETED BY APPLICANT:

B. ENVIRONMENTAL ELEMENTS 1. EARTH

a. General description of the site (check one): [ ] flat, [ ] rolling, [ ] hilly, [ ] steep slopes, [ ] mountains, [ ] other (describe):

b. What is the steepest slope on the site (approximate percent of slope)?

c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? f you know the classification of agricultural soils, specify them and note any prime farmland.

d. Are there surface indications or history of unstable soils in the immediate vicinity? If so describe.

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e. Describe the purpose, type, and approximate quantities of any filling or grading proposed. Indicate source of fill.

f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe.

g. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt or buildings?).

h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any.

2. AIR a. What types of emissions to the air would result from the proposal (i.e., dust, automobile odors, industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate quantities if known.

b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe.

c. Proposed measures to reduce or control emissions or other impacts to air, if any.

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3. WATER a. Surface: 1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream or river it flows into.

2) Will the project require any work over, in, or adjacent to (within 200 feet) of the described waters? If yes, please describe and attach available plans.

3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material.

4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known.

5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan.

6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge.

b. Ground: 1) Will ground water be withdrawn, or will water be discharged to ground water? Give general description, purpose, and approximate quantities if known.

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2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: Domestic sewage; industrial, containing the following chemicals; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve.

c. Water Runoff (including storm water): 1) Describe the source of runoff (including storm water) and method of collection and disposal, if any (include quantities, if known). Where will this water flow? Will this water flow into other waters? If so, describe.

2) Could waste materials enter ground or surface waters? If so, generally describe.

d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any.

4. PLANTS a. Check or circle types of vegetation found on the site:

__ deciduous tree: alder, maple, aspen, other ___ shrubs evergreen tree: fir, cedar, pine, other ___ grass crop or grain ___ pasture wet soil plants: Cattail, buttercup, bullrush, other water plants: water lily, eelgrass, milfoil, other other types of vegetation

b. What kind and amount of vegetation will be removed or altered?

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c. List threatened or endangered species known to be on or near the site.

d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any.

5. ANIMALS a. Check any birds and animals which have been observed on or near the site or are known to be on or near the site:

Birds: [ ] hawk [ ] heron [ ] eagle [ ] songbirds [ ] other: Mammals: [ ] deer [ ] bear [ ] elk [ ] beaver [ ] other: Fish: [ ] salmon [ ] trout [ ] herring [ ] shellfish [ ] other: [ ] bass

b. List any threatened or endangered species known to be on or near the site.

c. Is the site part of a migration route? If so, explain.

d. Proposed measures to preserve or enhance wildlife, if any.

6. ENERGY AND NATURAL RESOURCES a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc.

b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe.

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c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any.

7. ENVIRONMENTAL HEALTH a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe.

1) Describe special emergency services that might be required.

2) Proposed measures to reduce or control environmental health hazards, if any.

b. Noise

1) What type of noise exists in the area which may affect your project (for example: traffic, equipment, operation, other)?

2) What types and levels of noise would be created by or associated with the project on a short-term or long-term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come from the site.

3) Proposed measures to reduce or control noise impacts, if any.

8. LAND AND SHORELINE USE a. What is the current use of the site and adjacent properties?

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b. Has the site been used for agriculture? If so, describe.

c. Describe any structures on the site.

d. Will any structure be demolished? If so, what.

e. What is the current zoning classification of the site?

f. What is the current comprehensive plan designation of the site?

g. If applicable, what is the current shoreline master program designation of the site?

h. Has any part of the site been classified as an "environmentally sensitive" area? If so, specify.

i. Approximately how many people would reside or work in the completed project?

j. Approximately how many people would the completed project displace?

k. Proposed measures to avoid or reduce displacement impacts, if any.

l. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any.

9. HOUSING a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low- income housing.

b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low income housing.

c. Proposed measures to reduce or control housing impacts, if any.

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10. AESTHETICS a. What is the tallest height of any proposed structures(s), not including antennas; what is the principal exterior building material(s) proposed?

b. What views in the immediate vicinity would be altered or obstructed?

c. Proposed measures to reduce or control aesthetic impacts, if any.

11. LIGHT AND GLARE a. What type of light or glare will the proposal produce? What time of day would it mainly occur?

b. Could light or glare from the finished project be a safety hazard or interfere with views?

c. What existing off-site sources of light or glare may affect your proposal?

d. Proposed measures to reduce or control light and glare impacts, if any.

12. RECREATION a. What designated and informal recreational opportunities are in the immediate vicinity?

b. Would the proposed project displace any existing recreational uses? If so, describe.

c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any.

13. HISTORIC AND CULTURAL PRESERVATIONS a. Are there any places or objects listed on, or proposed for, national, state, or local preservation registers known to be on or next to the site? If so, generally describe.

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b. Generally describe any landmarks or evidence of historic, archaeological, scientific, or cultural importance known to be on or next to the site.

c. Proposed measures to reduce or control impacts, if any.

14. TRANSPORTATION a. Identify public streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any.

b. Is site currently served by public transit? If not, what is the approximate distance to the existing street system? Show on site plans, if any.

c. How many parking spaces would the completed project have? How many would the project eliminate?

d. Will the proposal require any new roads or streets, or improvements to existing roads or streets, not including driveways? If so, generally describe (indicate whether public or private).

e. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe.

f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur.

g. Proposed measures to reduce or control transportation impacts, if any.

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15. PUBLIC SERVICES a. Would the project result in an increased need for public services (for example: fire protection, police protection, health care, schools, other)? If so, generally describe.

b. Proposed measures to reduce or control direct impacts on public services, if any.

16. UTILITIES a. Check utilities currently available at the site: [ ] electricity, [ ] natural gas, [ ] water, [ ] refuse service, [ ] telephone, [ ] sanitary sewer, [ ] septic system, [ ] other:

b. Describe the utilities that are proposed for the project, the utility providing the service, and the general construction activities on the site or in the immediate vicinity which might be needed.

C. SIGNATURE

The above answers are true and complete to the best of my knowledge. I understand that the lead agency is relying on them to make its decision.

Date Submitted:______

Signature: ______

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TO BE COMPLETED BY APPLICANT

D. SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (do not use this sheet for project actions)

Because these questions are very general, it may be helpful to read them in conjunction with the list of the elements of the environment.

When answering these questions, be aware of the extent the proposal, or the types of activities likely to result from the proposal, would affect the item at a greater intensity or at a faster rate than if the proposal were not implemented. Respond briefly and in general terms.

1) How would the proposal be likely to increase discharge to water; emissions to air; production, storage, or release of toxic or hazardous substances; or production of noise?

Proposed measures to avoid or reduce such increases are:

2) How would the proposal be likely to affect plants, animals, fish, or marine life?

Proposed measures to protect or conserve plants, animals, fish, or marine life are:

3) How would the proposal be likely to deplete energy or natural resources?

Proposed measures to protect such resources to avoid or reduce impacts are:

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4) How would the proposal be likely to use or affect environmentally sensitive areas or areas designated (or eligible or under study) for governmental protection; such as parks, wilderness, wild and scenic rivers, threatened or endangered species habitat, historic or cultural sites, wetlands, flood plains, or prime farmlands?

Proposed measures to protect such resources or to avoid or reduce impacts are:

5) How would the proposal be likely to affect land and shoreline use, including whether it would allow or encourage land or shoreline uses incompatible with existing plans?

Proposed measures to avoid or reduce shoreline and land use impacts are:

6) How would the proposal be likely to increase demands on transportation or public services and utilities?

Proposed measures to reduce or respond to such demand(s) are:

7) Identify, if possible, whether the proposal may conflict with local, state, or federal laws or requirements for the protection of the environment.

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Appendix E

Appendix F

REPORT C OVER PAGE

Geotechnical Engineering Report ______

Royal Slope Solar Project Grant County, WA September 20, 2019 Terracon Project No. 81195048

Prepared for: Royal Slope Solar, LLC and JSI Construction Group, LLC Boulder, CO

Prepared by: Terracon Consultants, Inc. Mountlake Terrace, Washington

REPORT C OVER L ETTER TO SIGN September 20, 2019 Royal Slope Solar, LLC, c/o JSI Construction Group, LLC 1710 29th Street, Suite 1068 Boulder, CO 80301

Attn: Eli Johnson – Senior Civil Engineer P: (720) 838-2307 E: [email protected]

Re: Geotechnical Engineering Report Royal Slope Solar Project Range 23 East, Township 16 North Grant County, WA Terracon Project No. 81195048

Dear Mr. Johnson:

We have completed the Geotechnical Engineering services for the above referenced project. This study was performed in general accordance with Terracon Proposal No. P81195048 dated May 2, 2019. This report presents the findings of the subsurface exploration and provides recommendations concerning geotechnical aspects of the proposed solar power development of the site.

We appreciate the opportunity to be of service to you on this project. If you have any questions concerning this report or if we may be of further service, please contact us.

Sincerely, Terracon Consultants, Inc.

Chad T. McMullen, P.E. David A. Baska, P.E., Ph.D. Project Engineer Principal

Reviewed by: Jon Sheng, P.E., Senior Principal

Terracon Consultants, Inc. 21905 64th Ave. W, Suite 100 Mountlake Terrace, WA 98043 P (425) 771 3304 F (425) 771 3549 www.terracon.com

REPORT TOPICS

REPORT SUMMARY ...... II INTRODUCTION ...... 1 SITE CONDITIONS ...... 3 PROJECT DESCRIPTION ...... 5 SUBSURFACE CONDITIONS ...... 6 GEOTECHNICAL CHARACTERIZATION ...... 8 GEOTECHNICAL OVERVIEW ...... 9 CONTRIBUTORY RISK COMPONENTS ...... 12 EARTHWORK ...... 15 SHALLOW FOUNDATIONS ...... 20 CONCRETE SLABS ...... 22 DEEP FOUNDATIONS ...... 24 SEISMIC CONSIDERATIONS ...... 28 LIQUEFACTION ...... 29 PAVEMENTS ...... 30 FROST CONSIDERATIONS ...... 33 CORROSIVITY ...... 34 GENERAL COMMENTS ...... 36 FIGURES ...... 37 ATTACHMENTS ...... 38

Note: This report was originally delivered in a web-based format. For more interactive features, please view your project online at client.terracon.com.

ATTACHMENTS EXPLORATION AND TESTING PROCEDURES PHOTOGRAPHY LOG SITE LOCATION AND EXPLORATION PLANS EXPLORATION RESULTS SUPPORTING INFORMATION Note: Refer to each individual Attachment for a listing of contents.

Responsive ■ Resourceful ■ Reliable i Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

REPORT SUMMARY

2 Topic 1 Overview Statement ■ The project includes erection of photovoltaic panels, inverters, transformers, cabling, and other equipment to generate up to 300 megawatts (mW) of solar power, plus connection to the existing power grid. The project site is generally within the boundaries of Sections 1, 2, 3, and 4 of Range 23 East, Township 16 North and Sections 33 and 34 of Range 23 East and Township 17 North. The site includes about 3,000 acres of real estate and is located approximately Project 10 miles west of Royal City, WA. Of the 3,000 acres, approximately 1,480 Description acres (gross area) of PV arrays are distributed across the site. ■ The approximate center of the project site is located at the following coordinates: latitude: 46.9099° Longitude: -119.9187° ■ Depending on economic feasibility and technical considerations, not all portions of the site may be developed to the full 300mW capacity; partial development of the site, or development in phases is possible. ■ Loess: The site is overlain by a relatively uniformly-graded fine sand with silt to silty fine sand (wind-blown loess) to variable depth: in some places, this soil layer is less than a foot deep, while in other places it is present to depths of more than 21.5 feet (the maximum depth explored). This soil can be expected to provide adequate lateral and axial resistance to pile foundations supporting PV arrays and other site equipment, and pile sections can readily be driven in this soil layer, without drilling. Accumulations of loess sufficient to allow “ a driving-only” approach to pile installation (i.e. on the order of 6 to 8 feet) are generally present only in the northwest part of the project site. ■ Basalt: Columbia River Basalt underlies the Loess at most locations and Geotechnical typically consists of fresh to moderately-weathered, hard, fractured basalt. The Characterization spacing of fractures generally varies from several inches to several feet. Where weathered, penetration of up to 1 or 2 feet may be possible during pile driving, although damage to the pile toe is likely. The aerial extent of weathered basalt is very unpredictable; where un-weathered basalt is present; pile refusal will be immediate. Drilling will generally be necessary to install piles where basalt is expected within the planned depth of pile installation. Alternative foundations for supporting arrays – such as ballasted or anchored frames – could take advantage of the high bearing capacity of rock. ■ Flood Sand and Gravel: Missoula Flood Deposits were encountered in isolated locations in the northwestern and extreme western parts of the project site and consist of sandy gravel and gravelly sand. Earthwork associated with the project will likely consist primarily of grading to develop array access roads and primary roads, plus minor cutting and filling for Earthwork laydown and staging areas. ■ Access roads into array areas can generally be surfaced with native materials, provided that traffic will be infrequent and temporarily impaired access is

Responsive ■ Resourceful ■ Reliable ii Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

acceptable during relatively brief “dry-out” periods following wet weather. Primary roads should be gravel surfaced, at a minimum. ■ Following stripping and disposal of a thin organic-bearing top layer, native soils can generally be reused for minor filling. The bearing capacity of such fill will be relatively low. ■ Within the depths expected to necessary for site grading, we do not expect that soils suitable for re-use as structural fill will be encountered. Structural fill will need to be imported. ■ Near surface soils are susceptible to erosion by stormwater runoff. Finished surfaces should be sloped to drain while minimizing concentrated flows. Ditches should be interrupted by rock dikes or similar BMPs to reduce stream energy and the potential for erosion and transport of eroded sediments. ■ Where not protected by vegetation or other cover, near-surface soils are susceptible to erosion by wind. Consideration should be given to PV panel array siting and detailing in order to avoid accelerated wind speeds at the ground surface and an increase in wind erosion; a combination of vegetation, wind fences, and other management strategies can be employed to reduce the potential for erosion and transportation of wind-blown sediment. ■ Grading can be accomplished with conventional heavy earthmoving equipment and construction techniques. Where basalt is within the depth of excavation, we expect that in most places the upper 1 to 2 feet of basalt can be ripped with a heavy dozer; one or more passes may be necessary to accomplish this. For deeper cuts, special techniques (including blasting) may be necessary. Estimates of rippability could be made with supplemental field measurements of the subsurface shear-wave velocities in specific locations.

Shallow foundations bearing on native subgrade could be used to support equipment and minor buildings Shallow ■ Allowable bearing pressure = 2,500 lbs/sq ft (spread and wall footings) Foundations ■ Expected settlements: < 1-inch total, < 2/3-inch differential ■ Detect and remove zones of fill as noted in Earthwork Panel arrays will be supported on small H-piles or C-piles. Transformers, inverters, and other equipment in the photovoltaic fields may also be supported on these piles. ■ Piles can be driven to full depth only where the “Loess” or “Flood Deposit” soil types is present along most or all of the planned pile embedment length. Pile refusal should be anticipated to occur within 0 to 1 feet of the top of the Columbia River Basalt subsurface unit. The Depth to Excavation Refusal Deep map in the Figures section has been developed as a result of test pit Foundations exploration; this figure may be interpreted as an approximate predictor of the depth-to-driving-refusal during pile installation. ■ Pre-drilling of undersize holes (“pilot holes”) could allow several additional feet of penetration below the top of the basalt layer – sizing of these pilot holes should be determined during installation of test piles as part of a pre- construction study.

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■ Where additional pile penetration into basalt is necessary, or the potential for damage of pile flanges during installation is not acceptable, oversize drilling of pilot holes should be used, and piles should either be driven into backfill placed in the pilot holes or the piles should be grouted in place. 1. If the reader is reviewing this report as a pdf, the topics above can be used to access the appropriate section of the report by simply clicking on the topic itself. 2. This summary is for convenience only. It should be used in conjunction with the entire report for design purposes.

Responsive ■ Resourceful ■ Reliable iv Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

INTRODUCTION Geotechnical Engineering Report Royal Slope Solar Project Range 23 East, Township 16 North Grant County, WA Terracon Project No. 81195048 September 20, 2019

INTRODUCTION

This report presents the results of our subsurface exploration and geotechnical engineering services performed for the proposed Royal Slope Solar project to be located at Range 23 East, Township 16 North in Grant County, WA. The purpose of these services is to provide information and geotechnical engineering recommendations relative to:

■ Subsurface soil conditions and groundwater conditions of the project site. ■ Subsurface exploration procedures, and location of explorations. ■ Exploration logs and results of laboratory testing. ■ A feasibility statement of the proposed development of the site. ■ Generalized contributory risk components including: geologic concerns, corrosion hazard, excavation hazards, expansive soil hazards, slope hazards, drivability difficulty for foundation piles. ■ A discussion of the site geology, faulting, and seismicity, and geologic hazards. ■ Recommended foundation options and engineering design parameters, including L-Pile parameters tabulated for structural design purposes, and preliminary pile embedment depths ■ Discussion of settlement potential and shrink/swell. ■ Recommended construction procedures and quality control measures related to foundations and earthwork. ■ Grading recommendations and surface drainage considerations. ■ Utility trenching and backfilling recommendations. ■ Presentation of thermal resistivity test results in graphical form. ■ Preliminary on-site roadway subgrade preparation and section recommendations for gravel-surfaced on-site roads. ■ A statement regarding the potential for frost heave of the site soils.

The geotechnical engineering scope of services for this project included the advancement of 10 soil borings and 40 test pits to depths ranging from approximately 5 to 21.5 feet and less than a foot to 10.5 feet below existing site grades, respectively. Selected soil samples collected during exploration activities were subsequently subjected to laboratory testing, which included

1 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048 geotechnical index tests, thermal resistivity tests, and corrosion testing. The exploration scope also included the collection of large-array field electrical resistivity measurements. The field exploration procedures are described in detail in the Exploration Procedures section

Maps showing the project site and exploration locations are shown in the Site and Exploration Plans section. Boring and test pit logs are included in the Exploration Results section of this report, along with a Depth to Excavation Refusal map. The results of the laboratory testing performed on soil samples obtained from the site during the field exploration are included on the boring and test pit logs and as separate graphs in Exploration Results, as are the results of thermal conductivity laboratory testing and corrosion testing.

2 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

SITE CONDITIONS

The following description of site conditions is derived from our site visit in conjunction with the field exploration and our review of publicly available geologic and topographic maps. Item Description The project site is generally within the boundaries of Sections 1, 2, 3, and 4 of Range 23 East, Township 16 North and Sections 33 and 34 of Range 23 East and Township 17 North. The site includes about 3000 acres. The site is located approximately 10 Parcel Information miles west of Royal City, WA. The approximate center of the project site is located at the following coordinates: latitude: 46.9099° Longitude: -119.9187° (See Site and Exploration Plans) The site comprises roughly 3,000 acres and is comprised largely of irrigated crop circles and un-irrigated scrub land. Some portions of the site were previously used for irrigated agriculture but are no longer used and are Existing returning to native vegetation. Several dirt roads are present on the site improvements provide access to irrigation equipment and other aspects of site activities. An irrigation canal bisects the southeastern portion of the project site and supplies a portion of the water used by some of the central pivots. Other irrigation pivots are supplied by several wells and supply pipe located across the site. Irrigated areas – the locations of which are largely evident on the Exploration Plan consist of a variety of commodity crops including timothy, alfalfa, and mint. Unirrigated areas consist primarily of native bunchgrasses and sagebrush. Parts of the southeastern portion of the site are more heavily Current Ground Cover vegetated, presumably due to greater soil moisture associated with being located downhill from a leaky irrigation canal system. Parts of the site – notably the northern and northwestern portions – include areas of bare or very sparsely vegetated sand. Wind transport of these sands occurs during periods of high wind. Primary access to the site from the west is made from State Route 243 at milepost 17. Access from the east is made via State Route 26 and County Road 13 SW. Minor additional access drives along the northern margin of the site can be made via State Route 26. Several dirt roads are present within the Site Access site, as discussed above; these roads provide 2WD access. Over-land 4WD access is possible within much of the site during dry conditions. Impassable areas likely exist following extended periods of wet weather. In areas where bare or nearly bare sand present, access is likely possible only with tracked equipment or specialized low-pressure “balloon tire” equipment.

3 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

Item Description Topography across much of the site is generally flat to rolling, with slopes becoming greater to the west and north. Along the western site margin, basalt Existing Topography shelf outcrops and steeper slopes are present; this portion of the site is along the crest of the Columbia River canyon.

4 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

PROJECT DESCRIPTION

Our initial understanding of the project was provided in our proposal and was discussed during project planning. A period of collaboration has transpired since the project was initiated, and our final understanding of the project conditions is as follows:

Item Description ■ The project includes construction of a solar power generation facility with a capacity of up to 300 megawatts. Photovoltaic (PV) panels will be mounted on horizontal single-axis trackers in arrays supported on steel H-piles or C-piles. ■ Under a full build-out scenario, PV array blocks with a gross area (including access aisleways) of approximately 1,480 acres would be developed over a total project site totaling roughly 3,000 acres. ■ Inverters and transformers would be located at multiple locations near PV array blocks – typically this equipment is supported on piles, Project Description spread footings, or concrete equipment slabs. ■ Underground cabling will likely be used to connect PV arrays and inverters with a substation facility (see below). ■ A substation facility and transmission lines would be utilized to tie into existing transmission lines that transit the western edge of the proposed project site. Location and layout of the substation has not been determined; however, a substation would likely include an Operations and Maintenance building, laydown yard, transformers, circuit breakers, switches, busbars, and related equipment. ■ PV array blocks are expected to generally conform to existing topography. Inverters and transformers in the array blocks, plus buried cabling is also expected to conform with existing topography. ■ Access roads within the site may require minor fills or cuts, depending Finished Construction upon routing. For discussion purposes we assume cuts and fills of Grades less than 2 feet below/above existing grades would be needed for post-construction access roads. ■ Depending upon the substation layout, greater amounts of cut or fill may be necessary for construction of various substation elements. Below-Grade Structures None anticipated Free-Standing Retaining None anticipated Walls Pavements Gravel-surfaced access roads

Responsive ■ Resourceful ■ Reliable 5 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

SUBSURFACE CONDITIONS

Mapped Geology

Published geologic mapping indicates the shallow subsurface conditions of wind-blown silty fine sand and fine sand with silt (a.k.a. “loess”) being present across most of the site. Isolated outcrops of basalt are mapped in the northern half of the project site, plus more extensive bands of basalt are mapped in the western third of the site. Sands and gravels associated with catastrophic flooding are not mapped on site, though regional geologic history suggests they are present in isolated pockets at a scale too small for published geologic mapping. Bare and sparsely vegetated “dune sand – active” is included on published geologic mapping. Large-scale dunes are not evident on aerial photography and were not encountered during our site visits. During our site visits, small-scale rippling and other evidence of current wind-transport processes was observed at some locations in the northwestern part of the project site. We have not encountered any geological literature discussing annual dune migration rates, volumes of sand, or similar information that indicates the activity of mapped dunes in the area.

The mapped geology is generally consistent with the subsurface units we encountered during site exploration. While basalt bedrock is mapped in many locations of the project site, this mapping would mislead the reader to conclude that basalt is exposed at the ground surface. It is not; in most locations basalt is covered by wind-blown loess. Loess is the surface soil of primary concern with respect to water and wind erosion management.

Soil and Rock Conditions

The soil and rock conditions encountered during subsurface exploration are described below:

Loess: The site is underlain by a relatively uniformly-graded, wind-deposited fine sand with silt, to a silty fine sand. This soil deposit is present to a widely variable depth: in some places, this soil layer is less than a foot deep, while in other places it is present to depths of more than 21.5 feet (the maximum depth explored). Except for in the northwest portion of the site, the depth of this loess is typically 3 to 4 feet or less (although isolated pockets of deeper loess were encountered). In much of the northwestern portion of the site, the depth of the loess extends to 10 feet or more. This soil is readily excavated.

Columbia River Basalt underlies the loess at most locations and typically consists of fresh to moderately-weathered, hard, closely fractured basalt. The spacing of fractures generally varies from several inches to a foot. Using a large wheeled backhoe, excavation of less than a foot up to 2 about feet was possible during exploration. Where encountered during exploration drilling, penetration into the basalt was highly variable: where fractures in the basalt were closely-spaced, advancement on the order of 15 to 17 feet into the basalt was possible with auger-drilling -- with

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significant effort. Elsewhere, auger refusal was encountered and use of a coring method was necessary to advance the borehole.

Flood Sand and Gravel: Catastrophic flood deposits were encountered in isolated locations in the western part of the project site, which consist primarily of sandy GRAVEL and gravelly SAND; cobbles may also be present. This unit was encountered in isolated locations only in the western and northwestern portion of the project site, along the crest of the Columbia River canyon and a side canyon north of the project site. Borings were augured through this soil unit with moderate effort. Where encountered, advancement through this soil unit was possible during test pit excavation without much difficulty.

Caliche: Although not a distinct soil unit, a zone of strong caliche cementation was encountered in many test pits at a typical depth of 2 to 5 feet below the existing ground surface and which typically resulted in refusal during test pit excavation. Auger drilling through this zone was typically possible where the caliche zone was present within loess. Where caliche was present at the top of the Columbia River Basalt, rock fragments included a caliche rind which generally increased the difficulty of excavation or contributed to excavation refusal.

Groundwater Conditions

Groundwater was not encountered in any of the explorations. Variations in soil moisture can be expected to vary somewhat depending on season and on irrigation practices.

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GEOTECHNICAL CHARACTERIZATION

We have developed a general characterization of the subsurface conditions based upon our review of the subsurface explorations, laboratory data, geologic setting and our understanding of the project. This characterization, termed GeoModel, forms the basis of our geotechnical calculations and evaluation of site preparation and foundation options. Conditions encountered at each exploration point are indicated on the individual logs. The individual logs can be found in the Exploration Results section of this report. As noted in General Comments, the characteriza- tion is based upon widely spaced exploration points across the site, and variations are likely.

As part of our analyses, we identified the following model layers within the subsurface profile. For a more detailed view of the model layer depths at each boring location, refer to the boring logs.

Model Layer Layer Name General Description Loess Light tan to brown, fine SAND with silt to silty fine SAND, loose to medium dense. Wind-blown deposit, typically weakly cemented, 1 although isolated zones of stronger cementation are occasionally encountered (see caliche, below) Caliche Yellowish white to light tan mildly calcareous cemented zone within the loess or Columbia River Basalt; where encountered, typically 2 several feet below the ground surface. Dense to very dense, generally strongly cemented, difficult to excavate Catastrophic Brown to gray rounded fluvial SAND and GRAVEL and a silty 3 Flood Deposits sandy matrix, medium dense to very dense. Brown to gray black BASALT, typically moderately weathered, generally closely jointed and diced angular blocks on the order of Columbia River 4 several inches to up to a foot or more, generally difficult to Basalt excavate. May include zone of caliche cementation at top of rock unit

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GEOTECHNICAL OVERVIEW

We consider development of the photovoltaic generation project to be technically feasible from a geotechnical standpoint.

PV Array Foundations: H-piles and C-piles may be used to support the photovoltaic arrays and related equipment. In general, installation of piles using impact driving alone will generally be possible only where Loess or Catastrophic Flood Sand & Gravel deposits are present to sufficient depth; that is along most of the planned embedment length of a given pile. We expect that once Columbia River Basalt is encountered, pile refusal will typically occur within 12 inches or less of additional driving. Columbia River Basalt is present at fairly shallow depths across much of the site, we expect that drilling will be necessary to install piles at most locations where basalt is expected within the anticipated embedment length of the piles. In northwestern portions of the site, Columbia River Basalt was encountered at much greater depth, and installation of piles by driving alone can be expected to be generally feasible in this northwestern area. In the Figures section we present a graphical summary of these refusal observations on the Depth to Excavation Refusal map. We anticipate that these excavation refusal depths will generally correspond with refusal depths for driven piles installed without the benefit of pre-drilling. We present our analysis of pile foundations and their installation in the Pile Foundations section of this report.

Site Development and Grading: Development of site roads is feasible and is expected to require generally minor grading. Site grading, such as will be necessary for construction of array access roads and for preparation of a substation yard, can be completed using conventional earthmoving equipment. Columbia River Basalt should be expected to be encountered at the planned subgrade elevation at some locations where this rock unit is particularly shallow. Basalt will also likely be encountered in many locations where utility installation will occur. We expect that large excavators with ripping teeth will generally be capable of advance a foot or two into the basalt, although areas may exist where unweathered rock or areas of widely-spaced rock joints may refuse excavation. Trenchers – if used – may require special tooling and technique to advance trenches where shallow rock is expected. Where basalt is located well below the depth of utilities, use of cable plows may be successful. The Depth to Excavation map provides an indication as to where certain utility installation techniques are more likely or less likely to be successful. Additional site preparation recommendations, including subgrade improvement and fill placement, are provided in the Earthwork section. Additional field investigation including shear-wave velocity measurement could be used to both determine the depth to basalt at selected array locations and to estimate the “rip-ability”of the basalt based upon dozer selection manuals.

Seismic Considerations: Low to moderate-intensity ground shaking can be expected at the site during a design-level earthquake. Due to the absence of saturated, granular soils, liquefaction

Responsive ■ Resourceful ■ Reliable 9 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048 is not expected to present a risk at the site. Seismically-induced landsliding, and other geologic hazards associated with earthquake shaking are expected to be low.

Slopes and Landslide Hazards: Chapter 24.08.500 of the Grant County Code defines slope and landslide hazard areas. Based upon GIS mapping presented by Grant County, portions of the project site meet or exceed slopes of 30-percent; however, most of these locations correspond with basalt rock outcrops and all are stable. The majority of the project site includes slopes of less than 15 percent. Geologic mapping does not indicate the presence of active or past slides, and we did not observe evidence of land-sliding during our field exploration. Lidar-based slope inclinations are shown on the Slope Mapping – Grant County G.I.S. in the Figures section. PV arrays and related equipment will be supported on small-size piles bearing at depth. We do not expect these foundations to have an appreciable impact on site slopes. Where situated on or near slopes which exceed grades of 15 percent or more, equipment with higher concentrated loads -- or loads supported by shallow foundations -- may require slope stability analyses to determine impacts to slopes. Unless otherwise demonstrated by slope stability analysis, shallow foundations supporting equipment or buildings, or yards where heavy equipment may be stored or staged should be set back from any slope crest of 15 feet, plus a distance of: a) a distance equal to the height of the slope, or b) beyond a line extending 1½ H:1V upwards from the base of the slope (whichever is greater). Erosion Hazards: Erosion hazards are discussed in Chapter 24.08.500 of the Grant County Code and are relevant to civil design of the site. Erosion mitigation can be expected to be an on- going maintenance aspect for this development.

Water Erosion: Loess – which is present at the ground surface across nearly all of the project site -- is erodible and susceptible to sediment transport by stormwater runoff when flow velocities are high. However, grades across much of the project site are gentle, and so the Natural Resources Conservation Service (NRCS) characterizes undisturbed soils across the majority of the project site as having slight to moderate potential for erosion by stormwater. Where disturbed as a result of road-building, grading, utility burial, and similar activities, the susceptibility of these soils increase somewhat. The NRCS water-erosion susceptibility characterizations for the site are included on the NRCS Water Erosion Hazard maps (2 pages), including non-disturbed (off- road/off-trail) and post-grading (road/trail) conditions. Areas where higher susceptibility is mapped by the NRCS generally coincide with steeper slopes. Provided that high stormwater velocities are prevented by dispersion of flows, by good grading design, and through prevention or interruption of concentrated flows, the water erosion potential in steeper areas can be effectively mitigated. During construction, measures should be implemented to provide temporary erosion control of the exposed subgrade. Permanent erosion control will be necessary once construction is complete. In general, soil disturbing activities such as the construction of on-site roads and yards should be reduced where practical by promoting and maintaining vegetation in low-traffic areas,

Responsive ■ Resourceful ■ Reliable 10 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048 protecting native subgrade in higher traffic areas with gravel surfacing, and managing stormwater flows to reduce the flow velocity and tributary areas of concentrated stormwater runoff.

Wind Erosion: Surficial soils within most of the project site are characterized by the Natural Resources Conservation Service (NRCS) as being highly susceptible to wind erosion. As indicated on the NRCS Wind Erosion Hazards figure, soils across the site are primarily characterized as having high to severe potential for erosion by wind. During field work in noncultivated areas we observed occasional scour, small ripples, and other evidence of wind erosion and transport of fine surficial soil. We did not observe these features in areas under current or recent cultivation. Non-cultivated (and never-irrigated) areas of the northwest portion of the project site are where wind erosion and transportation effects are most obvious; aerial photography indicates the development of minor dunes here (though this area is outside the planned development footprint). The placement of PV panel arrays should carefully consider local aerodynamic effects around panels (especially beneath panels), and whether panel orientations (including certain tracker conditions) may accelerate air veloci- ties at the ground surface. Increased airspeed around PV panels could lead to an increase in erosion and transportation of dry, fine soils encountered near the ground surface. In areas that currently are irrigated, changes in surface soil moisture due to a cessation of irrigation may in- crease the wind erosion susceptibility of surface soils. To some extent, the erosion potential of wind can be mitigated with vegetation, careful siting and detailing of PV panel arrays and ori- entations, the use of wind-break fencing, and other mitigation tools. Where panels will be sited in locations where crop cultivation will cease, careful selection and establishment of veg- etation should be considered so a “bare earth” condition is not created. Other aspects of project development -- such as installation of buried cables, roads, construction of laydown yards, control buildings, and similar components – have a lesser potential to increase air speeds at the ground surface; however, wherever grading will expose fine, dry soil, there is the potential for wind erosion and sediment transport. This increased potential should be mitigated through the use of permanent non-erodible surfacing (such as gravel roadway surfaces) or by restoration of vegetation following construction. Although wind erosion and sediment transport can be mitigated through prudent design, removal of wind-blown sand, placement and modifi- cation of wind-break fencing, and similar practices are likely to be an ongoing maintenance consideration for operation of the facility.

NRCS Water Erosion Hazards and NRCS Wind Erosion Hazards maps are included in the Figures section

Additional discussion of risks associated with project development are presented in the Contributory Risk Components section.

The General Comments section provides an understanding of the report limitations.

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CONTRIBUTORY RISK COMPONENTS

ITEM DESCRIPTION In our opinion, the site should be suitable for the proposed solar development. Additional exploration should be performed to further explore the site as part of a design-level study. Additionally, a full-scale pile load testing (PLT) program should be completed as the project design Suitability Statement progresses. The results of a full scale PLT program in conjunction with soil exploration results will allow refinement of pile performance during application of design loads, possibly allowing a reduction in embedded pile lengths. A PLT will also provide a better indication as to pile drivability, and allow recommendations to be developed for pilot-hole sizing. Saturated soils were not encountered; as such, foundation soils are not Liquefaction prone to liquefaction We anticipate very little grading will be required. On-site materials that are Grading used as fill or backfill will likely require moisture conditioning (additions of moisture) prior to re-compaction as common fill. Groundwater is not present within the depths of our explorations. Based upon nearby well records, groundwater is expected to be well below the Groundwater depth of site improvements and is unlikely to be impacted by site development. On-site infiltration of stormwater runoff is likely feasible; however, this should be confirmed during later design. Surficial soils are susceptible to erosion Site Drainage and water transport where exposed to high stream velocity. Erosion can be mitigated through proper grading and drainage provisions. Based on laboratory testing for electrical resistivity and chemical properties, the site soils have a low likelihood for promoting sulfate or chloride attack of Corrosion Hazard concrete. However, based upon soil pH and laboratory resistivity measurements there is a risk of corrosion of steel ranging from mild to severe. Corrosion protection of steel will be necessary. Based on the results of our explorations and our experience with geology in the vicinity of the project site, difficult excavation conditions may be encountered during construction where shallow basalt rock is expected. Excavation Hazards Excavation of loess and sands/gravels will require less effort. Excavations will require bracing, sloping, and/or other means comply with federal and state standards for worker safety – design of bracing or sloping will depend upon the soil conditions revealed during excavation. Expansive Soils Expansive soils are not present at the project site. Most of the site is gently rolling to relatively level, with grades flatter than 15 Slope Hazards percent. Along the western and northwestern margins of the project site steeper slopes are present; much of these consist of narrow bands or

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ITEM DESCRIPTION outcrops of basalt bedrock. These slopes meet some of the criteria developed by Grant County for steep slopes. No sloughing, slumping, seeps, or other evidence of previous or current slope instability are suggested by geologic mapping, aerial photography, or our site observations. PV array blocks, roads, or other potential slope-disturbing activities associated with the proposed site development are not in proximity to these slopes. Recommendations for slope setbacks and slope stability analysis are presented in the Geotechnical Overview section. Sloughing could occur during construction along excavations or open trenches; otherwise, slope instability is not a significant site risk. Water: Surficial soils are characterized by the NRCS as having generally low to moderate susceptibility to erosion and transportation by stormwater where grades are gentle; these classifications become moderate to severe as slopes become steeper. With proper site design to flatten grades and reduce the concentration of stormwater flows, erosion due to stormwater runoff can be effectively mitigated. Erosion due to stormwater runoff is discussed in greater detail in the Geotechnical Overview.

Wind: Nearly all surficial soils at the project site are characterized by the Erosion Hazards Natural Resources Conservation Service (NRCS) as being highly or severely susceptible to wind erosion. Area of the northwest portion of the project site are where active wind erosion and transportation effects are most obvious; aerial photography indicates the development of minor dunes here. The placement of PV panel arrays should carefully consider local aerodynamic effects around panels. Areas taken out of cultivation may become more susceptible to wind erosion once irrigation stops. The wind erosion potential of site surficial soils can be largely mitigated with vegetation, careful siting and detailing of PV panel arrays and orientations, the use of wind-break fencing, and other mitigation tools. Wind erosion is discussed in greater detail in the Geotechnical Overview. At nearly all locations within central and southeastern portions of the project site, the presence of shallow basalt will result in driving refusal prior to reaching the embedment depths necessary to provide lateral capacity of Anticipated Pile piles supporting PV arrays. Pilot holes will be necessary to drive piles to Drivability required embedment depths. Full-scale load testing should be competed during later design to refine pile sections, required embedment depths, and to determine appropriate pilot hole sizing. Wildfire is common in central Washington. System components that are vulnerable to damage from wildfire – such as PV panel arrays located a few Wildfire feet above the ground surface – should consider vegetation and vegetation management options that accommodate the wind-erosion hazards discussed above without increase fire risks or fire intensity.

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ITEM DESCRIPTION Because a network of wells and irrigation pipes exist across much of the project site, there may be options to provide emergency fire suppression in the design of PV panel arrays.

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EARTHWORK

We expect that conventional earthwork can be employed to develop the project. Loess will be encountered at the ground surface across the entire project site. This soil unit can be excavated and graded with conventional earthmoving equipment. With adequate care and preparation, this soil can provide adequate subgrade performance. Loess is present to only shallow depth in portions of the project site, and Columbia River Basalt rock is likely to be encountered in deeper excavations into the subgrade. Conventional earthmoving equipment such as large excavators equipped with toothed buckets, bulldozers equipped with rippers, and chain-style and wheel-style trenchers can generally be expected to be adequate for shallow cuts into the top of the Columbia River Basalt; however, effort required for earthwork in this subsurface material can be highly variable and typically becomes much greater with increasing depth. The use of cable plows for installation of buried conduits or cabling is likely practical only where basalt will not be encountered within the depth of trenching.

Near-surface soils should be expected to have moderate moisture sensitivity, which means they are subject to degradation with exposure to moisture, particularly with repeated traffic. To the extent practical, earthwork should be performed during the summer and fall due to the shorter duration of precipitation and increased drying potential associated with these seasons. This does not necessarily preclude performing earthwork during other times of the year; however, increased remedial measures due to wet and soft or otherwise unsuitable conditions should be expected if earthwork is performed during other times of year. During the winter, fill material should not be placed, and no fill should be placed upon a frozen subgrade.

We do not expect groundwater or wet running soils to be encountered during pile installation or earthwork activities. During excavation, surficial soils should be considered a Class C material for the purposes of bracing and shoring of excavations, as defined by the Washington Department of Labor and Industry.

All excavations greater than 4 feet in depth much be either sloped or braced. Maintenance of worker safety and stable excavation conditions is entirely the responsibility of the Contractor. As such, the Contractor must comply with applicable local, state and federal safety regulations, including the current OSHA Excavation and Trench Safety Standards to provide stability and safe working conditions.

Site Preparation

Within the PV arrays, impacted soils will be largely limited to the immediate vicinity of piles supporting the arrays, plus soils disturbed by construction access into the array blocks. In these areas, vegetation can be mown, but disturbance of soils should be limited to an amount practical

Responsive ■ Resourceful ■ Reliable 15 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048 to allow pile installation and panel erection. Additional site preparation will be necessary within the footprint of roads, foundations, laydown yards, inverter foundations, and similar areas. In these areas, all existing vegetation and organic-bearing soil should be removed.

Prior to placement of fill, gravel surfacing, or construction of foundations, the exposed subgrade should be proofrolled with an adequately loaded vehicle such as a fully-loaded tandem-axle dump truck. The proof-rolling should be performed under the observation of the Geotechnical Engineer. Areas excessively deflecting under the proof-roll should be delineated by the Geotechnical Engineer and repaired by the Contractor. Excessively wet or dry material should either be removed, or moisture conditioned and recompacted.

Fill Material Types

Fill required to achieve design grade should be classified as Structural Fill and General Fill. Structural Fill is material used below foundations and pavements. General fill is material used to achieve grade outside of these areas, including road fills of 2 feet or less. Earthen materials used for structural and general fill should meet the following material property requirements:

Acceptable Location for Fill Type Recommended Materials Placement

9-03.9(1) Ballast1, 2 Beneath and adjacent to structural Structural Fill slabs, foundations, and pavement 1, 2 9-03.9(3) Crushed Surfacing Base Course subgrades Road grade filling, utility trench General Fill Section 9-03.14(3) Common Borrow1, 2, 3 backfill beyond structure foundations 1. WSDOT Standard Specifications 2. Structural Fill and Common Fill should consist of approved materials free of organic matter and debris. Frozen material should not be used, and fill should not be placed on a frozen subgrade. A sample of each material type should be submitted to the Geotechnical Engineer for evaluation prior to use on this site. 3. Provided that organic-bearing topsoil is stripped and disposed of elsewhere, site-derived excavation spoils – including Loess – are likely to meet that requirements for Common Borrow and could be used for the General Fill applications described above. However, localized areas of higher fines content material could make this material particularly moisture sensitive, and require additional care and judgement in its use as fill.

Fill Compaction Requirements

Structural and general fill should meet the following compaction requirements.

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Item Structural Fill General Fill 8 inches or less in loose thickness when heavy, self-propelled compaction equipment is used Maximum Lift Same as Structural fill Thickness 4 to 6 inches in loose thickness when hand- guided equipment (i.e. jumping jack or plate compactor) is used Minimum 95% of max. below foundations and floor slabs Compaction and within 1 foot of road subgrade elevation. 92% of maximum dry 1 92% of max. around foundations; or for fill more density Requirements than 1 feet below finished pavement subgrade Water Content As required to achieve min. Typically within 2% of optimum Range 1 compaction requirements 1. Maximum density and optimum water content as determined by the modified Proctor test (ASTM D 1557).

Buried Utility Construction

Buried electrical conductors will be installed within the project site – primarily between PV array blocks and the substation location. Where basalt is not expected within the depth of installation, placement of conductors could be accomplished through the use of a cable plow and direct burial of conduit or cable. Following cable placement, the soils disturbed by plowing should be compacted with a heavy, self-propelled vibratory roller to improve the in-place density of the soil and improve its thermal conductivity. The in-place thermal conductivity of backfill around conductors should be periodically documented during construction to evaluate whether design assumptions are being met.

Where Columbia River Basalt is likely to be present within the installation depth of buried cables or other conduits, a chain-type or wheel-type trencher equipped with rock teeth could be used for trenching, or trenches could be advanced with an excavator. The trench bottom should be prepared as recommended by the cable manufacturer, including removal of sharp projections in the trench floor and sides and removal of sharp or oversize materials (such as broken basalt fragments) in the backfill pile (alternatively, import backfill could be used). The cable and backfill should then be placed as recommended by the cable supplier. A heavy, self-propelled vibratory roller should be used to compact trench backfill in order to improve its thermal conductivity. The in-place thermal conductivity of backfill around conductors should be periodically documented during construction to evaluate whether design assumptions are being met.

Other buried utilities are not anticipated for the project.

Grading and Drainage

The Loess soil unit is susceptible to erosion. To the extent practical, vegetation within the PV arrays should be retained during construction and then maintained over the life of the facility to

Responsive ■ Resourceful ■ Reliable 17 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048 stabilize surface soils and reduce the occurrence of erosion. Where vegetation cannot be retained, such as within the substation yard and within the footprint of frequently travelled on-site roads, a layer of Crushed Surfacing Base Course should be used to protect the underlying native subgrade; this layer is also necessary for structural considerations.

Site grades should be established such that stormwater runoff is directed away from foundation, roadway, and yard subgrades to prevent ponding and reduce increases in the water content of the subgrade. Drainage features alongside roads should be interrupted with check dams or other BMPs to reduce water velocity and reduce erosion and transport of surficial soils during storm events.

Earthwork Construction Considerations

Upon completion of filling and grading, care should be taken to maintain the subgrade water content prior to construction of foundations, slabs, or roadways. Construction traffic over the completed subgrades should be avoided. The site should also be graded to prevent ponding of surface water on the prepared subgrades or in excavations. Any water that collects over, or adjacent to, construction areas should be promptly removed. If the subgrade freezes, desiccates, saturates, or is disturbed, the affected material should be removed, or these materials should be scarified, moisture conditioned, and re-compacted prior to construction. All these processes should be observed by Terracon.

At a minimum, excavations should be performed in accordance with OSHA 29 CFR, Part 1926, Subpart P, “Excavations” and its appendices, and in accordance with any applicable local, and/or state regulations. Construction site safety is the sole responsibility of the contractor who controls the means, methods, and sequencing of construction operations. Under no circumstances shall the information provided herein be interpreted to mean Terracon is assuming responsibility for construction site safety, or the contractor's activities; such responsibility shall neither be implied nor inferred.

Construction Observation and Testing

The earthwork efforts should be monitored under the observation of the Geotechnical Engineer. Monitoring should include documentation of adequate removal of vegetation and top soil, proof- rolling and mitigation of areas delineated by the proof-roll to require mitigation.

Each lift of compacted fill should be tested, evaluated, and reworked as necessary until approved by the Geotechnical Engineer prior to placement of additional lifts. Each lift of fill should be tested for density and water content.

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In areas of foundation excavations, the bearing subgrade should be evaluated by the Geotechnical Engineer. In the event that unanticipated conditions are encountered, the Geotechnical Engineer could recommend mitigation options.

In addition to the documentation of the essential parameters necessary for construction, the continuation of the Geotechnical Engineer into the construction phase of the project provides the continuity to maintain the Geotechnical Engineer’s evaluation of subsurface conditions, including assessing variations and associated design changes.

Wet Weather Earthwork

The near-surface soils have variable fines content based on our visual observations and lab testing and are considered moisture sensitive. The soils will exhibit moderate to high erosion potential and may be transported by running water. Silt fences, prevention of concentrated and high-velocity runoff flows, and other best-management practices will be necessary to control erosion and sediment transport during construction.

The suitability of soils used for structural fill depends primarily on their grain-size distribution and moisture content when they are placed. As the fines content (the soil fraction passing the U.S. No. 200 Sieve) increases, soils become more sensitive to small changes in moisture content. Soils containing more than about 5 percent fines (by weight) cannot be consistently compacted to a firm, unyielding condition when the moisture content is more than 2 percentage points above or below optimum. Optimum moisture content is the moisture content at which the maximum dry density for the material is achieved in the laboratory by the ASTM D1557 test procedure.

If inclement weather or in situ soil moisture content prevents the use of on-site material as structural fill, we recommend importing granular fill containing less than 5 percent by weight passing the U.S. No. 200 sieve, based on the fraction passing the U.S. No. 4 sieve.

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SHALLOW FOUNDATIONS

If the site has been prepared in accordance with the requirements noted in Earthwork, the following design parameters are applicable for shallow foundations.

Design Parameters – Compressive Loads

Description Spread Footing Wall Footing Net allowable bearing pressure 1,2 ◼ Granular levelling course over native soil 2,500 psf 2,500 psf Minimum dimensions 24 inches 18 inches Minimum embedment below finished grade 3 24 inches 24 inches Approximate static total settlement from foundation <1 inch <1 inch loads for condition specified4 Estimated static differential settlement from About 2/3 of total settlement foundation loads4 Allowable passive pressure 5 ◼ Compacted structural fill 300 pcf (equivalent fluid unit weight) Ultimate coefficient of sliding friction6 0.35 1. The maximum net allowable bearing pressure is the pressure in excess of the minimum surrounding overburden pressure at the footing base elevation. An appropriate factor of safety has been applied. These bearing pressures can be increased by 1/3 for transient loads unless those loads have been factored to account for transient conditions. Assumes that exterior grades are relatively level adjacent to the structure. 2. A “levelling” course of between 4 and 6 inches of CSBC should be placed and compacted as described in Earthwork atop a prepared native subgrade 3. For frost protection and to reduce the effects of seasonal moisture variations in the subgrade soils. For perimeter footing and footings beneath unheated areas. For sloping ground, maintain depth below the lowest adjacent exterior grade within 5 horizontal feet of the structure. 4. Differential settlements are as measured over a span of 50 feet. 5. Use of passive earth pressures require the sides of the excavation for the spread footing foundation to be nearly vertical and the concrete placed neat against these vertical faces or that the footing forms be removed and compacted Structural Fill be placed against the vertical footing face. 6. Can be used to compute sliding resistance where foundations are placed on suitable soil/materials. Should be neglected for foundations subject to net uplift conditions.

Foundation Construction Considerations

As noted in Earthwork, the footing excavations should be evaluated under the observation of the Geotechnical Engineer. The base of all foundation excavations should be free of water and loose soil, prior to placing concrete. Concrete should be placed soon after excavating to reduce bearing soil disturbance. Care should be taken to prevent wetting or drying of the bearing materials during

Responsive ■ Resourceful ■ Reliable 20 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048 construction. Excessively wet or dry material or any loose/disturbed material in the bottom of the footing excavations should be removed/reconditioned before foundation concrete is placed.

If unsuitable bearing soils are encountered at the base of the planned footing excavation, the excavation should be extended deeper to suitable soils, and the footings could bear directly on these soils at the lower level or on lean concrete backfill placed in the excavations. This is illustrated on the sketch below.

Over-excavation for structural fill placement below footings should be conducted as shown below. The over-excavation should be backfilled up to the footing base elevation, with Structural Fill placed and compacted as recommended in the Earthwork section.

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CONCRETE SLABS

Design parameters for equipment pads and floor slabs assume the requirements for Earthwork have been followed. Specific attention should be given to positive drainage away from the concrete slab and positive drainage of the native subgrade and the aggregate base layer.

Concrete Slab Design Parameters

Item Description

Minimum 6 inches of 9-03.9(3) Crushed Surfacing Base Course 3 Slab Support 1 Compacted to at least 95% of maximum dry density (ASTM D 1557) Estimated Modulus of ■ 150 pounds per square inch per inch (psi/in) for point loads Subgrade Reaction 2 1. Concrete slabs-on-grade should be structurally independent of building footings or walls to reduce the possibility of floor slab cracking caused by differential movements between the slab and foundation. Equipment slabs adjacent to other foundations should be structurally isolated in a similar fashion. 2. Modulus of subgrade reaction is an estimated value based upon our experience with the subgrade condition, the requirements noted in Earthwork, and the slab support layer as noted in this table. It is provided for point loads. For large area distributed loads the modulus of subgrade reaction would be lower. 3. WSDOT Standard Specification

The use of a vapor retarder is recommended beneath interior concrete slabs on grade that will be finished with moisture sensitive or impervious coverings, or when the slab will support equipment that is sensitive to moisture. When conditions warrant the use of a vapor retarder, the slab designer should refer to ACI 302 and/or ACI 360 for procedures and cautions regarding the use and placement of a vapor retarder.

Saw-cut control joints should be placed in the slab to help control the location and extent of cracking. For additional recommendations refer to the ACI Design Manual. Joints or cracks should be sealed with a water-proof, non-extruding compressible compound specifically recommended for heavy duty concrete pavement and wet environments.

Where floor slabs are tied to perimeter walls or turn-down slabs to meet structural or other construction objectives, our experience indicates differential movement between the walls and slabs will likely be observed in adjacent slab expansion joints or floor slab cracks beyond the length of the structural dowels. The Structural Engineer should account for potential differential settlement through use of sufficient control joints, appropriate reinforcing or other means.

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Floor Slab Construction Considerations

On most project sites, the concrete slab subgrades are established early in the construction phase. However, as construction proceeds, the subgrade may be disturbed due to utility excavations, construction traffic, desiccation, rainfall, etc. As a result, the concrete slab subgrade may not be suitable for placement of concrete and corrective action will be required.

We recommend the concrete slab subgrade be rough graded and then thoroughly proof rolled with a loaded tandem axle dump truck according to the recommendations in Earthwork prior to fine grading. Particular attention should be paid to high traffic areas that were rutted and disturbed, and to areas where backfilled trenches are located. Areas where unsuitable conditions are found should be repaired by removing and replacing the affected material with properly compacted fill.

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DEEP FOUNDATIONS

General Piling Recommendations

Steel piles (C- or H-sections) are considered suitable for support of the proposed solar arrays. However, due to the presence of relatively shallow Columbia River Basalt across much of the project site we anticipate that installation of piles using driving alone will not be possible at many locations. Instead, under-sized drilled pilot holes will likely be necessary to advance piles to design depths where shallow basalt is present. An alternative to under-sized pilot holes is over- sized pilot holes followed by grouting of the piles – although more expensive, this alternative may be necessary where refusal of the piles would otherwise be encountered, or where damage to the pile flanges (as a result of driving in rock) is not acceptable.

For the purpose of preliminary estimation by the project team, we recommend that the Depth to Excavation Refusal map presented in the Figures section be considered as a preliminary guide as to the likely depths of refusal for driven piles. Based upon a likely minimum required depth of embedment of 5 feet for piles supporting PV arrays, the southeastern and the main (central) portions of the proposed project site will likely require drilling of pilot holes at nearly every pile location. The northwest portion of the project site is the only part of the project site where a “driving only” approach can be used for pile installation at most pile locations due to an accumulation of Loess and Flood Sand & Gravel greater that the anticipated pile embedment depths.

Preliminary Axial Capacity of Piles

We present preliminary axial pile capacities for the pile and subsurface conditions below.

Southeast and Central Portions of the Project Site – Pile Driven Into Under-Size Pilot Hole Typical Soil Profile: Loess over shallow Columbia River Basalt Layer (feet) Allowable Skin Friction (psf) Allowable End Bearing (psf) 0-3 (Loess) 200 -- 3+ (Basalt) 1000 10,000

Northwest Portion of the Project Site – “Driving Only” Pile Installation Typical Soil Profile: greater than 10 feet of Loess and Flood Sand & Gravel Layer (feet) Allowable Skin Friction (psf) Allowable End Bearing (psf) 10+ (Loess plus Sand & Gravel) 400 4,000

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The design capacity of a single driven pile is a function of several factors including the engineering properties of the subsurface soils size, the type of pile, and the amount of “interference fit” between the pile and an under-sized pilot hole. In particular, this latter consideration can have a great impact upon the actual the uplift capacity of a pile driven into a pilot hole. The most effective means of verifying pile capacities for either tension or axial loads is through pile load tests. We strongly recommended that a test pile program be undertaken as design progresses in order to refine the compression and tension capacity of piles at the project site.

The axial tensile (pull-out) capacity can be developed from skin friction acting on the “box perimeter” of a pile (the perimeter of its rectangular outside dimensions), The axial compressive capacity can be developed from skin friction plus end bearing of the plug. For piles installed in a drilled boring backfilled with concrete, the allowable friction values above can be increased by 150 percent, and the perimeter may be taken as the product of the drilled diameter and pi. The end bearing value above assumes that the piles are embedded a minimum of 5 feet. A minimum factor of safety of 2.0 has been incorporated into the allowable values presented above.

Piles should have a minimum center-to-center spacing of at least 3 times their flange width or drilled boring diameter to avoid group reduction effects. Using the parameters above, piles can be expected to settle less than a 1/2-inch during their service life.

Preliminary Lateral Capacity of Piles

The parameters in the following tables can be used for a preliminary analysis of the lateral capacity of steel piles supporting PV arrays and other equipment. These values may be used to estimate initial determinations of pile size/section and embedment depth on a pile-by-pile basis.

Southeast and Central Portions of the Project Site – Pile Driven Into Under-Size Pilot Hole Typical Soil Profile: Loess over shallow Columbia River Basalt Effec. Effective p-y Cohesion Soil Modulus Strain Depth Unit Friction model (psf) (pci) Factor E50 Weight Angle (deg.) Sand (pcf) 0-3 (Reese) 100 32 50 90 --

Massive 3+ Rock 150 - see note - - see note - - see note - - see note -

Note: The following parameters should be used for L-Pile modelling of basalt rock at the project site: Uniaxial compressive strength: 1,500 psi Geologic Strength Index (GSI): 50 Hoek-Brown Material Index: 25 Intact Rock Modulus: (software default value ) Poisson’s Ratio: 0.25 Rock Mass Modulus: 42,000 psi

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Northwest Portion of the Project Site – “Driving Only” Pile Installation Typical Soil Profile: greater than 10 feet of Loess and Flood Sand & Gravel Effec. Effec. p-y Cohesion Soil Modulus Strain Depth Unit Friction model (psf) (pci) Factor E50 Weight Angle (deg.) Sand (pcf) 0-10+ (Reese) 100 32 50 90 --

We strongly recommended that a test pile program be undertaken as design progresses in order to refine the lateral capacity of piles at the project site.

Preliminary Pile Embedment Estimate

PV array blocks typically use a variety of pile shapes and pile embedment depths due to different loads that must be resisted on a pile-by-pile basis. For example, piles that are interior to an array block typically carry relatively low compression, uplift, lateral loads, while piles near the exterior of the block carry additional loads due to higher wind loading and the weight of tracker motors. In addition, applied moments at motor locations impart a moment into the supporting pile.

Estimated loads and moments on piles are specific to the panel system manufacturer. Our understanding is that a panel system has not been selected by JuWi and the loads that will be imparted to piles at various array positions (interior, exterior, motor) have not been determined. However, based upon typical loadings for array interior and array exterior piles (plus piles supporting motor loads and moments) on similar projects in similar ground conditions, we anticipate that the following preliminary pile embedments are appropriate for this site:

Soltec Typical Pile Embedment Depth Typical Factored Loads (ft) Pile Type Southeast and Compression Uplift Shear Moment Northwest Site Central Site (kips) (kips (kips) (k-ft) Location Locations Exterior (no motor) 2 to 2.5 0.5 to 1.5 1.5 to 3 0.2 to 0.4 7 9 Exterior 3 to 4 0.5 to 1.5 1.5 to 3 15 to 25 9 11 (with motor) Interior 1.5 to 2 0.144 0.5 to 1 0.2 to 0.4 5 7 (no motor) Interior 1.5 to 2.5 0.088 0.5 to 1 10 to 25 7 9 (with motor)

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The estimated embedment depths above are intended to assist the owner in roughly evaluating construction costs and viability for the proposed project. Note that recommended pile sections have not been stated in the table above; selection of pile sections would need to include an L-pile analysis using the soil model properties stated in the previous section, plus design pile loads. Ultimately the design of pile foundations for the solar panel racking system will depend on a number of factors including the actual structural loading conditions, the structural serviceability requirements, anticipated corrosion losses, a more detailed understanding of the lateral soil response (as observed through pile load testing), and other factors where complete and final information is not available at this time. We expect that the results of a full-scale pile load test program could demonstrate more favorable geotechnical parameters and, consequently, a more economic final design for the racking system foundations.

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SEISMIC CONSIDERATIONS

The seismic design requirements for buildings and other structures are based on the Seismic Design Category. Site Classification is required to determine the Seismic Design Category for a structure. The Site Classification is based on the upper 100 feet of the site profile defined by a weighted average value of either shear wave velocity, standard penetration resistance, or undrained shear strength in accordance with Section 20.4 of ASCE 7-16.

Description Value

ASCE 7-16 Site Classification1,2 C3 Site Latitude 46.90556 Site Longitude -119.91614 4 0.435 g SS – Short Period Spectral Acceleration, Site Class B 4 0.177 g S1 – 1-Second Period Spectral Acceleration, Site Class B 4 1.3 Fa – Short Period Site Coefficient 4 1.5 Fv –1-Second Period Site Coefficient PGA - Peak Ground Acceleration4 0.193 g 4 1.207 FPGA – Peak Ground Acceleration Site Coefficient 1. Seismic site classification in general accordance with subsurface descriptors presented in ASCE 7-16. 2. ASCE 7-16 requires a site profile extending to a depth of 100 feet for seismic site classification. Borings were extended to a maximum depth of 21 ½ feet. The site properties below the boring depth to 100 feet were estimated based on our experience and knowledge of geologic conditions of the general area. 3. Site Class C applies to any profile having a subsurface profile that can be characterized as “very dense soil and soft rock” 4. These values were obtained using online seismic design maps and tools provided by the Applied Technology Council (https://hazards.atcouncil.org/), which utilizes earthquake hazard data developed by the USGS.

Surface-Fault Rupture

The hazard of damage from on-site fault rupture is low, based on review of the USGS Earthquake Hazards Program Quaternary Faults and Folds Database available online (http://earthquake.usgs.gov/hazards/qfaults/map). The closest mapped fault is approximately 1½ miles to the west of westernmost extent of the project site, on the opposite side of the Columbia River. This fault is interpreted to have last ruptured within the past 130,000 years.

Seismically Induced Landsliding

Based upon the location of project components, site topography, and soil conditions, seismically- induced slope instability is unlikely at the site.

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LIQUEFACTION

Liquefaction is the phenomenon where saturated soils develop high pore water pressures during seismic shaking and lose their strength characteristics. This phenomenon generally occurs in areas of high seismicity, where groundwater is shallow and loose granular soils or relatively non- plastic fine-grained soils are present. Based on the site geology and subsurface groundwater conditions, the risk of liquefaction of the site soils is very low and does not present a design consideration for this site.

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PAVEMENTS

Permanent Access Roadways

Permanent access roadways for this project are expected to consist of aggregate surfaced roads over prepared subgrade. It is our understanding that aggregate surfaced roadway design for construction purposes will be performed by others. We have provided an aggregate surfaced roadway design based on maintenance pick-up truck traffic after construction.

Pavement designs are provided for the traffic conditions and pavement life conditions as noted in Project Description and in the following sections of this report. A critical aspect of pavement performance is site preparation. Pavement designs, noted in this section, must be applied to the site, which has been prepared as recommended in the Earthwork section.

Aggregate Surfacing

Evaluation of the access roadway section thicknesses for the project has been based on the procedures outlined in the 1993 Guideline for Design of Pavement Structures by the American Association of State Highway and Transportation Officials (AASHTO) for low volume design.

Based upon AASHTO criteria, central Washington is located within Climatic Region V of the United States. This region is characterized as being dry, with freeze-thaw cycling occurring during the winter. The thaw condition occasionally results in short term periods of nearly saturated subgrade soil moisture conditions, if the thaw cycle is preceded by snowfall. Typically, however, soil conditions are generally dry. Local drainage characteristics of proposed pavement areas are considered to be good.

The soil data is based upon conditions encountered from the borings, test pits, and some variation should be expected between the exploration locations. These analyses and resulting roadway sections should be considered preliminary, subject to evaluation using actual design traffic loadings.

We assumed an allowable 18-kip equivalent single-axle load (ESALs) of 2,000 for low level and 5,500 for medium level traffic. Based on Figure 4.3, Design Chart for Aggregate-Surfaced Roads Considering Allowable Rutting, 1993 Guide for Design of Pavement Structures by AASHTO, an estimated CBR value of 15, an elastic modulus of the aggregate base course of 30,000 psi, and an allowable rut depth of 1.5 inches, the ranges of roadway thicknesses listed on the following page can be considered for preliminary planning purposes.

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Aggregate Pavement Section Crushed Surfacing Base Course Thickness (in), Pavement Thickness Options Low Level Traffic Medium Level Traffic Unreinforced subgrade with separation 4 6 geotextile 1, 2

1Native subgrade soils should be prepared as described in the Earthwork section

2A woven or non-woven separation geotextile meeting the criteria presented in Table 3 of Section 9-33.2(1) of the WSDOT Standard Specifications should be installed atop the prepared native subgrade to reduce the migration of fines into the aggregate layer and extend the pavement’s functional life.

Roadway Drainage

Positive surface drainage of the roadway and subgrade should be provided and maintained. The roadway should be sloped to provide surface water drainage at all times. Water should not be allowed to remain within the roadway section and subgrade soils. In addition, the subgrade soils should be prepared in accordance with the Earthwork section of this report.

The following recommendations should be considered at minimum:

■ Site grading at a minimum 2% grade away from the roadways and laydown areas ■ The subgrade surfaces have a minimum ¼ inch per foot slope to promote proper surface drainage ■ Consider appropriate edge drainage and ditches/culverts

Roadway Maintenance

We emphasize that gravel surfaced roadways, regardless of the section thickness or subgrade preparation measures, will require on-going maintenance and repairs to keep them in a serviceable condition. When potholes, ruts, depressions or yielding subgrades develop they should be addressed as soon as practical in order to avoid major repairs. The roadways should be carefully reevaluated at the time of the use by heavy equipment or critical component delivery for evidence of disturbance or excessive rutting. Roadway reevaluation should include proof rolling immediately prior to use by heavy or critical equipment, particularly after a rainfall event. If disturbance and/or excessive wetting have occurred, roadway areas should be reworked, moisture conditioned (if necessary), and properly compacted as indicated in this report. To the extent that it is practical, avoiding heavy loads during periods of snowmelt or following heavy rainfall can extend the effective life of gravel surfacing and reduce on-site roadway maintenance costs.

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Failure to make timely repairs will result in more rapid deterioration of the roadways, making more extensive repairs necessary.

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FROST CONSIDERATIONS

Site soils have low moisture content and normally do not experience frost heave; however the soils on this site could be frost susceptible if provided with ready access to moisture – a condition which could be created without adequate drainage provisions around footings, slabs, and other impervious surfaces resulting from site development. Provided that concentrations of soil moisture can be avoided through use of grading and dispersion of runoff away from slabs and foundations, frost heave can otherwise be prevented.

As discussed in the Shallow Foundations section, footings should be placed a minimum of 24 inches below finished grade for frost-heave protection.

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CORROSIVITY

Corrosion testing was performed on 15 samples recovered from test pits distributed across the project site. The results of corrosion testing are included in the Exploration Results section.

Soluble Sulfate and Chloride

Results of soluble sulfate testing indicate samples of the on-site soils tested possess negligible sulfate concentrations when saturated, as classified in accordance with Table 4.2.1 of the ACI Design Manual. Similarly, chloride concentrations are negligible, according to Table 4.3.1 of that manual. Cement Type I or I/II are appropriate at the project site for concrete in contract with native soils; special sulfate-resistant cement is not necessary.

Corrosion of Steel

Testing indicates the soils have relatively high pH – typically between 8 and 9. Soils with pH in this elevated range can promote elevated corrosion rate of steel.

The resistivity measured on saturated soil samples tested in the laboratory ranged between 572 to 9,700 ohm-centimeter. Those resistivity results indicate the soil profile has mild to very high corrosive potential to buried steel or iron objects. The test results in southeast and central portions of the project site exhibited the highest corrosion potential (“high” to “very high”), while soils from the northwest portion of the site exhibited lower corrosion potential of steel (“mild” to “high”). Evaluation of the resistivity test results follows the guidelines of J.F. Palmer, “Soil Resistivity Measurements and Analysis”, Materials Performance, Volume 13, January 1974. The table below outlines the guidelines for soil resistivity versus corrosion potential.

Corrosion Potential of Soil on Steel SOIL RESISTIVITY (ohm-cm) CORROSION POTENTIAL 0 to 1,000 Very High 1,000 to 2,000 High 2,000 to 5,000 Moderate > 5,000 Mild

Corrosion protection for buried steel can vary from encasing the steel in a protective cover to providing cathodic protection. Based on our experience with solar projects, hot dipped galvanization is usually employed for corrosion protection for steel in contact with soils at these

Responsive ■ Resourceful ■ Reliable 34 Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048 types of projects. We recommend a corrosion consultant be retained to provide specific corrosion recommendations for the project.

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GENERAL COMMENTS

Our analysis and opinions are based upon our understanding of the project, the geotechnical conditions in the area, and the data obtained from our site exploration. Natural variations will occur between exploration point locations or due to the modifying effects of construction or weather. The nature and extent of such variations may not become evident until during or after construction. Terracon should be retained as the Geotechnical Engineer, where noted in this report, to provide observation and testing services during pertinent construction phases. If variations appear, we can provide further evaluation and supplemental recommendations. If variations are noted in the absence of our observation and testing services on-site, we should be immediately notified so that we can provide evaluation and supplemental recommendations.

Our Scope of Services does not include either specifically or by implication any environmental or biological (e.g., mold, fungi, bacteria) assessment of the site or identification or prevention of pollutants, hazardous materials or conditions. If the owner is concerned about the potential for such contamination or pollution, other studies should be undertaken.

Our services and any correspondence or collaboration through this system are intended for the sole benefit and exclusive use of our client for specific application to the project discussed and are accomplished in accordance with generally accepted geotechnical engineering practices with no third-party beneficiaries intended. Any third-party access to services or correspondence is solely for information purposes to support the services provided by Terracon to our client. Reliance upon the services and any work product is limited to our client, and is not intended for third parties. Any use or reliance of the provided information by third parties is done solely at their own risk. No warranties, either express or implied, are intended or made.

Site characteristics as provided are for design purposes and not to estimate excavation cost. Any use of our report in that regard is done at the sole risk of the excavating cost estimator as there may be variations on the site that are not apparent in the data that could significantly impact excavation cost. Any parties charged with estimating excavation costs should seek their own site characterization for specific purposes to obtain the specific level of detail necessary for costing. Site safety, and cost estimating including, excavation support, and dewatering requirements/design are the responsibility of others. If changes in the nature, design, or location of the project are planned, our conclusions and recommendations shall not be considered valid unless we review the changes and either verify or modify our conclusions in writing.

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FIGURES

Contents: Depth to Excavation Refusal Slope Mapping -- Grant County G.I.S. NRCS Water Erosion Hazards (2 pages) NRCS Wind Erosion Hazards

Responsive ■ Resourceful ■ Reliable DEPTH TO EXCAVATION REFUSAL MAP Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

Typical test pit location depth of diggable soils exceeds the backhoe/excavator reach

Typical test pit location indicating depth of excavation refusal

DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES IMAGERY PROVIDED BY GOOGLE EARTH SLOPE MAPPING – GRANT COUNTY G.I.S. Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

EXHIB IT D 11X17 L AND SC APE

Approximate PV array footprints

DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES MAP EXCERPTED FROM GRANT COUNTY ONLINE INTERACTIVE MAPPING TOOL: http://grantcountywa.maps.arcgis.com/apps/webappviewer

NRCS WATER EROSION HAZARDS Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

EXHIB IT E 11X17 L ANDSC APE

Off-Road/Off-Trail Water Erosion Risk: “Slight” erosion risk – green “Moderate” erosion risk – yellow “Severe” erosion risk -- red

DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES MAP EXCERPTED FROM NRCS ONLINE INTERACTIVE MAPPING TOOL: https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx NRCS WATER EROSION HAZARDS Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

Road/ Trail Water Erosion Risk: “Slight” erosion risk – green “Moderate” erosion risk – yellow “Severe” erosion risk -- red

DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES MAP EXCERPTED FROM NRCS ONLINE INTERACTIVE MAPPING TOOL: https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx NRCS WIND EROSION HAZARDS Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

MAP 1 11X17 L AND SC APE

Wind Erosion Risk: Low erosion risk – green, blue Moderate to high erosion risk – yellow, orange Severe erosion risk -- red

DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES MAP PROVIDED BY MICROSOFT BING MAPS

ATTACHMENTS

Responsive ■ Resourceful ■ Reliable Geotechnical Engineering Report Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

EXPLORATION AND TESTING PROCEDURES

Field Exploration

As part of our scope of services, we advanced exploration borings and test pits to collect soil samples and observe subsurface conditions in order to understand the engineering characteristics of the project site subsurface. Our explorations included 10 borings advanced to depths of up to 21½ feet below existing grades and 40 test pits advanced to depths of up to 12 feet below existing grades. Our field activities also included the collection of field resistivity measurements with arrays centered at four locations. These field activities are discussed below.

Exploration Layout and Elevations: The layout of borings, test pits, and center points of in-situ electrical resistivity arrays was provided by the JuWi. Coordinates were obtained with a handheld GPS unit (estimated horizontal accuracy of about ±10 feet) and approximate elevations were obtained by interpolation from Google Earth. If elevations and a more precise boring layout are desired, we recommend borings be surveyed following completion of fieldwork.

Exploration Borings: Borings were advanced with a track-mounted rotary drill rig using hollow stem auger drilling techniques. Borings were completed between June 4 and June 5, 2019. Where auger refusal was encountered within 10 feet from ground surface, a modified rock coring method was used from the depth of refusal to advance the boring up to 5 feet into the rock. In several borings, the closely-fractured basalt and allowed advancement of augers (despite high SPT blow counts), and coring was not necessary.

Soil samples were obtained at 2½ to 5-foot intervals depending on boring location, depth, and observed soil conditions. Samples were obtained using a standard 2-inch outer diameter split-barrel sampling spoon. At each sample depth, the spoon was driven into the ground by a 140-pound automatic hammer falling a vertical distance of 30 inches. The number of blows required to advance the sampling spoon the last 12 inches of a normal 18-inch penetration was recorded as the Standard Penetration Test (SPT) resistance value. The SPT resistance values, also referred to as N-values, are indicated on the boring logs at the test depths. Boring logs are included in the Exploration Results section.

All borings were backfilled upon completion in accordance with Washington State Department of Ecology requirements.

Exploration Test Pits: Test pits were excavated using a rubber-tired backhoe equipped with a toothed bucket across the majority of the site. Some of the test pits were advanced using a small a tracked excavator due to their more difficult access conditions. Test pits were advanced between May 28 and May 31, 2019. Grab samples were obtained at various intervals at the discretion of the

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Terracon field representative, with bulk sampling performed at 14 of the 40 test pits. In some test pits, in-place density measurements were made using a nuclear densometer and ASTM Method D 6938. All density measurements were made within the top 3-feet of the soil profile. Results of these tests are included on selected test pit logs. Test pit logs are included in the Exploration Results section.

Upon completion of each test pit exploration, spoils generated during digging were placed back into the test pit excavation with periodic tamping by the backhoe/excavator bucket (no greater degree of compaction is implied) to reestablish the original surface grade.

Field Electrical Resistivity Testing: Field measurement of soil resistivity was performed at 4 locations across the site. The locations of these tests is shown in the Site Location and Exploration Plans section. Field measurements of soil resistivity were performed in accordance with ASTM Test Method G 57, and IEEE Std. 81, using the Wenner Four-Electrode Method. The soil resistivity measurements were made using a recently calibrated MiniRes 9 earth resistivity testing device. An incrementally increasing “a” spacing between 2 to 500 feet was used for this these measurements. The “a” spacing is generally considered to be the depth of influence of the test. Two full-length test arrays oriented at right angles to each were performed at array locations “A,” “B,” “C,” and “D,”.

Results of the soil resistivity measurements performed are presented in the following table. It should be noted that electrical resistivity will vary somewhat throughout the year due to seasonal and agricultural shifts changes in soil moisture.

Array ID & “a” spacing Measured Average Orientation (feet) Resistance Resistivity (ohms) (ohm-m) 2 142.3 546 4 48.2 370 8 17.9 275 15 10.7 307 25 8.5 407 Array A 50 5.6 536 North-South 100 3.6 690 200 2.0 766 300 1.359 781 500 0.938 889 2 137.4 527 4 47.6 365 8 17.4 267 15 10.5 302 Array A 25 8.5 407 East-West 50 5.7 546

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100 3.5 671 200 1.890 724 300 1.344 772 500 0.901 863 2 17.2 67 4 8.7 67 8 8.2 126 15 7.1 204 Array B 25 5.9 283 Northeast-Southwest 50 4.7 450 100 3.3 632 200 1.680 644 300 1.049 603 500 0.4613 442 2 15.0 58 4 10.8 83 8 8.2 126 15 6.9 198 Array B 25 5.8 278 Northwest-Southeast 50 4.8 460 100 3.2 613 200 1.710 655 300 1.021 587 500 0.481 461 2 16.4 63 4 9.5 73 8 7.1 109 15 4.8 138 25 2.8 134 Array C 50 1.8 172 North-South 100 1.450 278 200 1.070 410 300 0.843 484 500 0.559 535 2 15.7 60 4 9.5 73 8 7.0 107 15 4.7 135 Array C 25 3.1 148 East-West 50 1.9 182 100 1.353 259

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200 1.125 431 300 1.8692 500 500 0.498 477 2 38.4 147 4 16.4 126 8 10.4 160 15 5.9 169 Array D 25 3.7 177 North-South 50 1.9 182 100 1.307 250 200 0.972 372 300 0.795 457 500 0.5688 545 2 41.4 159 4 17.9 137 8 10.4 160 15 6.1 175 Array D 25 3.7 177 East-West 50 1.9 182 100 1.30 249 200 1.010 387 300 0.814 468 500 0.518 496

Laboratory Testing

The project engineer reviewed the field data and assigned laboratory tests to understand the engineering properties of the various soil and rock strata, as necessary, for this project. Procedural standards noted below are for reference to methodology in general. In some cases, variations to methods were applied because of local practice or professional judgment. Standards noted below include reference to other, related standards. Such references are not necessarily applicable to describe the specific test performed. A limited number of the tests listed below were performed on soil samples obtained during site exploration.

■ ASTM D2216 Standard Test Methods for Laboratory Determination of Water (Moisture) Content of Soil and Rock by Mass

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■ ASTM D6913 Standard Test Methods for Particle-Size Distribution (Gradation) of Soils Using Sieve Analysis ■ ASTM D1557 Test Methods for Laboratory Compaction Characteristics of Soils Using Modified Effort (56,000ft-lbf/ft3) ■ ASTM D1883 Standard Test Method for CBR (California Bearing Ratio) of Laboratory- Compacted Soils

The laboratory testing program included examination of soil samples by an engineer. Based on the material’s texture and plasticity, we described and classified the soil samples in accordance with the Unified Soil Classification System.

Rock classification was conducted using locally accepted visual and manual identification practices for engineering purposes; petrographic analysis may reveal other rock types. Rock core samples typically provide an improved specimen for this classification. Boring log rock classification was determined using the Description of Rock Properties.

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PHOTOGRAPHY LOG

Deep loess soil, TP-35 Deep loess soil, TP-27

Typical caliche-coated basalt at refusal, TP-3

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Insert picture here and adjust sizing as needed.

Typical caliche-cemented gravel over basalt bedrock, TP-10

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Contents: Site Location Plan Exploration Plan - Borings and Electrical resistivity Arrays Exploration Plan - Test Pits

Responsive ■ Resourceful ■ Reliable SITE LOCATION Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

MAP 1 L ANDSC APE

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DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES MAP PROVIDED BY MICROSOFT BING MAPS

EXPLORATION PLAN – BORINGS & ELECTRICAL RESISTIVITY ARRAYS Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

MAP 1 1 1X17 LANDSCAPE

“NORTHWEST” PORTION OF SITE

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“CENTRAL” PORTION OF SITE “SOUTHEAST” PORTION OF SITE

DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES IMAGERY PROVIDED BY GOOGLE EARTH EXPLORATION PLAN – TEST PITS Royal Slope Solar Project ■ Grant County, WA September 20, 2019 ■ Terracon Project No. 81195048

MAP 2 1 1X17 LANDSCAPE

Note to Preparer: This is a large table with outside borders. Just click inside the table above this text box, then paste your GIS Toolbox image.

When paragraph markers are turned on you may notice a line of hidden text above and outside the table – please leave that alone. Limit editing to inside the table. The line at the bottom about the general location is a separate table line. You can edit it as desired, but try to keep to a single line of text to avoid reformatting the page. EXPLORATION RESULTS

Contents: Test Pit Logs (TP-1 through TP-40) Boring Logs (B-1 through B-10) Grain Size Distribution Results Moisture Density Relationships CBR Results Corrosion Testing Results Thermal Resistivity Testing Results TEST PIT LOG NO. TP-01 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9061° Longitude: -119.8965° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light tan to yellowish brown, moist to dry, loose, (LOESS) 1 DD = 109.5pcf M% = 4.6% 3.0 2 3.5 SAND WITH SILT (SP-SM), light tan to yellowish white, dry, very dense, strong 7 cementation, refusal Test Pit Refusal in Caliche at 3.5 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. DD = In-place dry density %M = In-place moisture content Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-29-2019 Test Pit Completed: 05-29-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-02 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9218° Longitude: -119.9489° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS 1 SAND WITH SILT (SP-SM), tan to yellowish brown, dry, 0.8 4 1.0 (LOESS) BASALT, moderately fractured, moderately weathered, (COLUMBIA RIVER BASALT) Test Pit Refusal at 1 Foot

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-31-2019 Test Pit Completed: 05-31-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-03 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9119° Longitude: -119.8964° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), tan to yellowish brown, moist to dry, loose, (LOESS)

1

3.5 4 3.7 BASALT, moderately fractured, moderately weathered, (COLUMBIA RIVER BASALT) Test Pit Refusal at 3.7 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-29-2019 Test Pit Completed: 05-29-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-04 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9056° Longitude: -119.8768° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine grained, gray tan to brown, moist to dry, loose, (LOESS) 1 DD = 96.1pcf W% = 4.7% 2.8 4 3.0 BASALT, moderately fractured, moderately weathered, caliche rind around the surface of rock fragments (COLUMBIA RIVER BASALT) Test Pit Refusal at 3 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-29-2019 Test Pit Completed: 05-29-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-05 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.898° Longitude: -119.8858° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), tan to brown, moist to dry, loose, (LOESS)

1

4.1 4 4.4 BASALT, moderately fractured, moderately weathered, caliche rind around the surface of rock fragments (COLUMBIA RIVER BASALT) Test Pit Refusal at 4.4 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-29-2019 Test Pit Completed: 05-29-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-06 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8979° Longitude: -119.8771° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS POORLY GRADED SAND (SP-SM), with silt and trace gravel, gray to yellowish tan, 1 1.2 dry, 4 1.4 (LOESS) BASALT, moderately fractured, moderately weathered, caliche rind around the surface of rock fragments (COLUMBIA RIVER BASALT) Test Pit Refusal at 1.4 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-28-2019 Test Pit Completed: 05-28-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-07 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8924° Longitude: -119.8812° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SILTY SAND (SP-SM), tan brown, dry, loose, 1 (LOESS)

2.0 CALICHE, light tan brown to light yellowish white, dry, very dense, trace HCl reaction, 2 contains gravel- and cobble-size basalt fragments 3.3 Test Pit Refusal at 3.3 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-28-2019 Test Pit Completed: 05-28-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-08 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.89° Longitude: -119.8872° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), tan to yellowish tan, moist, loose, (LOESS)

1 becomes gravelly with depth 3.2 2 3.5 CALICHE, light tan to yellowish white, dry, strong cementation, digging refusal Test Pit Refusal at 3.5 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-28-2019 Test Pit Completed: 05-28-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-09 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8911° Longitude: -119.8954° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SILTY SAND (SM), brown to light brown, moist, loose, (LOESS)

1

3.5 BASALT, light gray to gray brown, moderately fractured, very close fracture spacing, 4 moderately weathered, (COLUMBIA RIVER BASALT) 5.2 5 Test Pit Refusal at 5.2 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-28-2019 Test Pit Completed: 05-28-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-10 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8849° Longitude: -119.8959° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS 1 0.5 SAND WITH SILT (SP-SM), fine sand, tan to light brown, dry, medium dense, (LOESS) 6 3 GRAVEL (GM), with silt and sand, tan to gray, dry, dense, 2.2 (OUTBURST FLOOD DEPOSIT) DD = 119.0pcf M% = 5.5% 4 2.5 BASALT, dark gray to brownish black, moderately fractured, very close fracture spacing, highly weathered, (COLUMBIA RIVER BASALT) Test Pit Refusal at 2.5 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. DD = In-place dry density %M = In-place moisture content Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-28-2019 Test Pit Completed: 05-28-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-11 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8864° Longitude: -119.8858° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SILTY SAND (SM), brown to light brown, moist, loose, (LOESS) 1 9

3.0 4 BASALT, light gray to gray brown, damp, slightly fractured to moderately fractured, 4.0 moderately weathered, increasing excavation difficulty to termination depth (COLUMBIA RIVER BASALT) Test Pit Refusal at 4 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-28-2019 Test Pit Completed: 05-28-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-12 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9105° Longitude: -119.8836° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), tan to yellowish tan, moist, loose, (LOESS) 1

2.5 4 3.0 BASALT, brown to gray, moist to dry, moderately fractured, moderately weathered, caliche rind around rock particles, refusal at terminated depth (COLUMBIA RIVER BASALT) Test Pit Refusal at 3 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-29-2019 Test Pit Completed: 05-29-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-13 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9061° Longitude: -119.8858° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, tan to yellowish tan, moist to dry, loose, (LOESS) 11 1

3.1 4 3.5 BASALT, brown to gray, dry, very dense, moderately fractured, moderately weathered, basalt fragments with caliche rind at terminated depth (COLUMBIA RIVER BASALT) Test Pit Refusal at 3.5 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-29-2019 Test Pit Completed: 05-29-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-14 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9056° Longitude: -119.9161° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SILTY SAND (SM), tan to yellowish tan, moist to dry, loose, 1 (LOESS) 1.6 4 1.8 BASALT, moderately fractured, moderately weathered, very difficult to excavate (COLUMBIA RIVER BASALT) Test Pit Refusal at 1.8 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-15 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8991° Longitude: -119.9098° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light tan to tan brown, dry to moist, loose, (LOESS)

1

5 6.0 2 6.2 CALICHE, very dense, very strong caliche cementation horizon of overlying sand with silt, very difficult to excavate Test Pit Refusal at 6.2 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-16 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9172° Longitude: -119.9445° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, tan gray to yellowish tan, moist to dry, loose, 1 (LOESS)

2.0 2.7 SILTY GRAVEL (GM), gray to brown, moist to dry, medium dense, 3 (OUTBURST FLOOD DEPOSIT) 3.8 SAND (SP), gray tan to dark gray, moist, loose, 4 4.0 (COLUMBIA RIVER BASALT) BASALT, dark gray, moist, moderately fractured, moderately weathered Test Pit Refusal at 4 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-17 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8841° Longitude: -119.8777° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), with cobbles near surface, fine sand, tan to light brown, 1 dry, loose, (LOESS) 1.9 13 2 2.5 CALICHE, light tan to yellowish white, dry to moist, dense, very strong caliche cementation within overlying sand with silt soil described above DD = 101.2pcf Test Pit Refusal at 2.5 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. DD = In-place dry density

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-28-2019 Test Pit Completed: 05-28-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-18 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8982° Longitude: -119.8943° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, tan to brown, moist to dry, loose, moist; sidewalls dense (LOESS) 1

3.8 2 4.0 4 CALICHE, light tan to yellowish white, dry, strong caliche cementation of sand with silt 4.2 unit described above BASALT, brown to gray, dry, moderately fractured, moderately weathered, caliche rinds surrounding basalt rock fragments (COLUMBIA RIVER BASALT) Test Pit Refusal at 4.2 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-29-2019 Test Pit Completed: 05-29-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-19 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8887° Longitude: -119.8761° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, tan brown, dry, loose, 1 (LOESS)

2.0 2 2.4 CALICHE, light tan brown to light yellowish white, dry, strong caliche cemented mixture 4 2.6 of soil above and basalt rock fragments below BASALT, light brown to brown, moderately fractured, moderately weathered, (COLUMBIA RIVER BASALT) Test Pit Refusal at 2.6 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-28-2019 Test Pit Completed: 05-28-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-20 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.899° Longitude: -119.9271° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), with basalt gravel, fine sand, brown to dark brown, moist, medium dense, 1 (LOESS) DD = 134.4pcf 9 W% = 5.8% 2.3 4 2.8 BASALT, brown, moist, moderately fractured, moderately weathered, (COLUMBIA RIVER BASALT) Test Pit Refusal at 2.8 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. DD = In-place dry density %M = In-place moisture content Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-21 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9049° Longitude: -119.9374° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SILTY SAND (SP-SM), with angular basalt gravel, brown to orangey brown, dry, loose, 1 (LOESS) 1.5 4 2.0 BASALT, moderately fractured, moderately weathered, (COLUMBIA RIVER BASALT) Test Pit Refusal at 2 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-22 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9245° Longitude: -119.9368° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS 1 0.6 SAND WITH SILT (SP-SM), fine sand, tan, dry, loose, 2 4 0.8 (LOESS) DD = 96.1pcf BASALT, moderately fractured, moderately weathered, difficult excavation W% = 4.7% (COLUMBIA RIVER BASALT) Test Pit Refusal at 0.8 Foot

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. DD = In-place dry density %M = In-place moisture content Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-23 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9192° Longitude: -119.9358° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light tan to yellowish tan, moist to dry, loose, (LOESS) 1

3.0 POORLY GRADED SAND (SP), medium to coarse sand, dark tan to gray tan, moist to dry, medium dense, (OUTBURST FLOOD DEPOSIT) 5.0 SILTY SAND (SM), light tan, moist to dry, medium dense 5 3 6.5 POORLY GRADED SAND (SP), medium to coarse sand, dark tan to gray tan, moist to dry, medium dense

9.0 Test Pit Terminated at 9 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-24 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9213° Longitude: -119.933° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS 1 0.4 SAND WITH SILT (SP-SM), fine sand, light tan to yellowish tan, dry, loose, 4 0.5 (LOESS) BASALT, moderately fractured, moderately weathered, very difficult excavation (COLUMBIA RIVER BASALT) Test Pit Refusal at 0.5 Foot

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-25 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9272° Longitude: -119.9215° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light tan to yellowish tan, moist to dry, loose, (LOESS)

1

5.0 5 5.5 SILT (ML), with sand, tan brown, moist, medium dense, (OUTBURST FLOOD DEPOSIT) SAND (SP), gravel and cobbles throughout, gray, moist, medium dense

3

9.5 Test Pit Terminated at 9.5 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-31-2019 Test Pit Completed: 05-31-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-26 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9242° Longitude: -119.9231° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, brown, moist, loose, (LOESS) DD = 97.1pcf 10 W% = 8.1% 1

4.5 WELL GRADED SAND WITH GRAVEL (SW), dark brown to brown gray, moist, 5.5 medium dense, 5 (OUTBURST FLOOD DEPOSIT) POORLY GRADED SAND WITH SILT (SP-SM), brown, moist, medium dense

3

10.0 4 10.5 orange to brown, moderately fractured, moderately weathered, 10 (COLUMBIA RIVER BASALT) Test Pit Terminated at 10.5 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. DD = In-place dry density %M = In-place moisture content Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-31-2019 Test Pit Completed: 05-31-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-27 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9277° Longitude: -119.926° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), trace gravel, gray to tan, moist, loose, (LOESS)

1 becoming medium dense 5

becomes massive, no visible stratification

10.0 Test Pit Terminated at 10 Feet 10

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-31-2019 Test Pit Completed: 05-31-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-28 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9203° Longitude: -119.9225° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, brown tan to yellowish tan, moist to dry, loose, (LOESS) 1

2.2 4 2.3 BASALT, moderately fractured, moderately weathered, caliche rind around rock fragments (COLUMBIA RIVER BASALT) Test Pit Refusal at 2.3 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-29 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9194° Longitude: -119.9261° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light tan to yellowish tan, moist to dry, loose, (LOESS) 1

3.0 2 CALICHE, strong caliche cementation of sand with silt soil unit above, very difficult 4.0 excavation Test Pit Refusal at 4 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-31-2019 Test Pit Completed: 05-31-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-30 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9265° Longitude: -119.933° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light tan to light yellowish gray, dry, loose, becomes slightly siltier with depth (LOESS)

1 5

10.0 Test Pit Refusal at 10 Feet 10

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-31-2019 Test Pit Completed: 05-31-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-31 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9113° Longitude: -119.9354° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), with organics, dark brown to brown, moist, loose, (LOESS)

1

4.5 SAND (SP), dark brown to black, moist, medium dense, (OUTBURST FLOOD DEPOSIT) 5

3

9.0 Test Pit Refusal at 9 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-32 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9127° Longitude: -119.9254° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS Loess (SP-SM), light tan to yellowish tan-gray, moist to dry, loose, (LOESS)

DD = 88.9pcf 4 W% = 6.9%

1 sands and silts in alternating layers between about 4-6-feet 5

10.0 Test Pit Terminated at 10 Feet 10

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. DD = In-place dry density %M = In-place moisture content Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-33 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9265° Longitude: -119.9457° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS POORLY GRADED SAND WITH SILT (SP-SM), fine sand, tan, dry to moist, loose, (LOESS)

1

3.5 SAND (SP), fine to coarse grained, dark gray, (OUTBURST FLOOD DEPOSIT) 5

3 becoming gravelly and cobbly

10.0 Test Pit Terminated at 10 Feet 10

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING TEST PIT LOG NO. TP-34 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9274° Longitude: -119.9405° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), with organics, fine sand, brown to light tan brown, moist to dry, loose, (LOESS)

1 5

becomes siltier

10.0 Test Pit Terminated at 10 Feet 10

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-31-2019 Test Pit Completed: 05-31-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-35 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9229° Longitude: -119.9425° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS POORLY GRADED SAND WITH SILT (SP-SM), dark brown, moist, loose, 8 (LOESS) DD = 86.8pcf W% = 5.9%

1 5

9.0 Test Pit Terminated at 9 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. DD = In-place dry density %M = In-place moisture content Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-31-2019 Test Pit Completed: 05-31-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-36 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9083° Longitude: -119.9299° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS POORLY GRADED SAND WITH SILT (SP-SM), with organics, fine sand, dark black brown to brown, moist, loose to medium dense, 1 (LOESS)

2.5 4 2.8 BASALT, black gray, moist, moderately fractured, moderately weathered, (COLUMBIA RIVER BASALT) Test Pit Refusal at 2.8 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-37 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9054° Longitude: -119.9224° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS POORLY GRADED SAND WITH SILT (SP-SM), with organics, fine sand, dark black 1 brown to brown, moist to dry, loose, (LOESS) 1.8 4 BASALT, black gray, moderately fractured, moderately weathered, difficult to excavate 2.6 (COLUMBIA RIVER BASALT) Test Pit Terminated at 2.6 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-38 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9021° Longitude: -119.9336° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS POORLY GRADED SAND WITH SILT (SP-SM), fine sand, brown to dark brown, moist, loose, (LOESS) 1

4.0 4 4.2 BASALT, dark brown, moderately fractured, moderately weathered, difficult to excavate

(COLUMBIA RIVER BASALT) Test Pit Refusal at 4.2 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-39 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9117° Longitude: -119.9074° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS 1 SAND WITH SILT (SP-SM), fine sand, tan to light yellowish tan, moist to damp, loose, 1.0 (LOESS) 4 1.2 BASALT, light brown, moist, moderately fractured, moderately weathered, difficult excavation

(COLUMBIA RIVER BASALT) Test Pit Refusal at 1.2 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TEST PIT LOG NO. TP-40 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9042° Longitude: -119.9289° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light brown to light yellowish tan, moist to dry, loose, (LOESS)

1 becomes medium dense 5

10.0 Test Pit Terminated at 10 Feet 10

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual.

Advancement Method: See Exploration and Testing Procedures for a Notes: description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Test Pit backfilled with soil cuttings upon completion. Google Earth

WATER LEVEL OBSERVATIONS Test Pit Started: 05-30-2019 Test Pit Completed: 05-30-2019

Excavator: CASE 580 Backhoe Operator: 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING BORING LOG NO. B-1 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9116° Longitude: -119.9209° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light brown to tan, dry, loose, (LOESS)

1

3.2 BASALT (GW), dark brown gray to black, moderately fractured, moderately weathered, oxidization along weathered joint faces, rock and gravel-size fragments recovered in each sample taken, difficult drilling (COLUMBIA RIVER BASALT) 5 6-20-50/3"

50/3"

10 100/6"

4

15 50/3"

20.1 20 Boring Terminated Dat 20.1 Feet R A F T 50/1"

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-04-2019 Boring Completed: 06-04-2019

Drill Rig: CME 850 track rig Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 BORING LOG NO. B-2 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8983° Longitude: -119.8835° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SM), fine sand, light brown to tan, dry, loose, weak cementation, (LOESS)

1

12-50/5" 4.0 switch to core-barrel at 4 ft following auger refusal BASALT, dark brown to black, moderately fractured, moderately weathered, no recovered core pieces exceeding 4-inches, RQD ~ 0 5 (COLUMBIA RIVER BASALT) 4

7.5 Coring Terminated at 7.5 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA/ single 5-foot run core tube description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-05-2019 Boring Completed: 06-05

Drill Rig: Diedrich D-120 Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 BORING LOG NO. B-3 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9059° Longitude: -119.8866° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS 1 0.5 SAND WITH SILT (SM), light brown to tan, dry, loose, (LOESS) BASALT, dark brown to black, moderately fractured, moderately weathered, no recovered core pieces exceeding 4-inches; RQD ~ 0 (COLUMBIA RIVER BASALT) 4

5.0 Coring Terminated at 5 Feet 5

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA/ single 5-foot run core tube description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-05-2019 Boring Completed: 06-05

Drill Rig: Diedrich D-120 Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 BORING LOG NO. B-4 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9066° Longitude: -119.8977° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), fine sand, light brown to tan, dry, loose, (LOESS) 1

3.1 10-12-50/2" BASALT, dark brown gray to black, dry, weathered vesicular bedrock, oxidization along weathered joint faces, powdered matrix due to boring efforts

(COLUMBIA RIVER BASALT) 5 12-50/5"

50/2"

10 50/2"

4

cuttings gravelly, drilling exceptionally rough

15 12-50/5"

20.4 rock fragments in sample tip 20 50/4" Boring Terminated Dat 20.4 Feet R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-05-2019 Boring Completed: 06-05-2019

Drill Rig: Diedrich D-120 Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 BORING LOG NO. B-5 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.8856° Longitude: -119.8777° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS 1 0.5 SAND WITH SILT (SP-SM), light brown to tan, dry, loose, (LOESS) 2 CALICHE, white to tan-white, dry, very dense, strong caliche cementation of overlying 2.0 sand with silt soil unit BASALT, dark brown to black, slightly fractured to moderately fractured, moderately weathered, approxiamtely 3.3-feet of rock core recovered; approximate RQD 46%

(COLUMBIA RIVER BASALT) 4 5

7.0 Coring Terminated at 7 Feet

D R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA/ single 5-foot run core tube description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-05-2019 Boring Completed: 06-05

Drill Rig: Diedrich D-120 Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 BORING LOG NO. B-6 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9026° Longitude: -119.9347° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS 1 SAND WITH SILT (SP-SM), fine sand, light brown to tan, dry, loose, 0.8 (LOESS) GRAVEL (GW), with silty sand, gray to dark tan, dry to moist, very dense, rock and rounded gravel fragments in all recovered samples

(OUTBURST FLOOD DEPOSIT) 11-50/5"

5 50/6"

10-33-43 N=76

10 19-50/6" 3

15 20-50/1"

19.5 MICACEOUS SILTY SAND (SM), trace rounded gravel, light gray with tan, dry to moist, medium dense, 20 9-11-14 (OUTBURST FLOOD DEPOSIT) D R A F T N=25 21.5 Boring Terminated at 21.5 Feet

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-04-2019 Boring Completed: 06-05-2019

Drill Rig: CME 850 track rig Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING BORING LOG NO. B-7 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9015° Longitude: -119.9145° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), light brown to tan, dry, loose, (LOESS)

1

3.2 15-21-50/4" BASALT, gray to dark brown, dry, moderately to extremely fractured, moderately weathered, (COLUMBIA RIVER BASALT) 5 50/2"

50/5"

10 50/4"

4

15 50/4"

20.4 20 50/4" Boring Terminated Dat 20.4 Feet R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-05-2019 Boring Completed: 06-05-2019

Drill Rig: Diedrich D-120 Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 BORING LOG NO. B-8 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.92° Longitude: -119.9444° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SP-SM), light brown to tan, dry, loose, (LOESS) 1

3.0 7-6-7 SAND (SW), trace silt, medium to coarse sand, gray with multicolored grains, moist, N=13 medium dense, (OUTBURST FLOOD DEPOSIT) 5 trace fine gravel and rock fragments 4-7-8 N=15

4-7-15 trace fine gravel and rock fragments N=22

10 trace silty fine sand layering 4-5-11 N=16

3

15 trace fine gravel and rock fragments 4-7-15 N=22

20 7-8-10 D R A F T N=18 21.5 Boring Terminated at 21.5 Feet

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-04-2019 Boring Completed: 06-04-2019

Drill Rig: CME 850 track rig Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING BORING LOG NO. B-9 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9264° Longitude: -119.9454° WATER RESULTS DEPTH (Ft.) FIELD TEST GRAPHIC LOG MODEL MODEL LAYER CONTENT (%) WATER LEVEL SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SM), fine sand, light brown to tan, dry, loose, (LOESS)

1

3.3 3-3-4 SAND (SP), trace silt, tan brown to tan gray, moist, medium dense, N=7 (OUTBURST FLOOD DEPOSIT) 5 4-9-12 becomes finer sand N=21

8-9-10 trace fine gravel and rock fragments N=19

10.3 10 SAND (SW), trace silt, gray with multicolored grains, 3-5-8 (OUTBURST FLOOD DEPOSIT) N=13

3

15 trace silty fine sand layering 3-5-8 N=13

20 7-7-8 D R A F T N=15 21.5 Boring Terminated at 21.5 Feet

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-04-2019 Boring Completed: 06-04-2019

Drill Rig: CME 850 track rig Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID SEPARATED IF FROM ORIGINAL REPORT.GEO SMART ROYAL LOG-NO WELL 81195048 SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 BORING LOG NO. B-10 Page 1 of 1 PROJECT: Royal Slope Solar Project CLIENT: JuWi Americas, Inc. Boulder, Colorado SITE: 10 Miles West of Royal City, R23E, T16N Grant County, Washington

LOCATION See Exploration Plan

Latitude: 46.9241° Longitude: -119.923° WATER RESULTS DEPTH (Ft.) DEPTH FIELD TEST FIELD GRAPHIC LOG GRAPHIC MODEL LAYER MODEL CONTENT (%) CONTENT WATER LEVEL WATER SAMPLE TYPE DEPTH OBSERVATIONS SAND WITH SILT (SM), fine sand, brown, moist, loose, (LOESS)

1 4-4-4 N=8

5.5 5 4-4-4 SILTY SAND (SM), dark brown, wet, medium dense, N=8 (OUTBURST FLOOD DEPOSIT)

rock fragments in shoe and sampler 4-5-15 N=20

10 4-6-9 11.0 N=15 WELL GRADED GRAVEL (GW), with silty sand, orangey brown to tan, moist, very dense

3

15 50/6"

20.2 silty sand matrix becomes drier at 20-feet 20 50/2" Boring Terminated Dat 20.15 Feet R A F T

Stratification lines are approximate. In-situ, the transition may be gradual. Hammer Type: Automatic

Advancement Method: See Exploration and Testing Procedures for a Notes: HSA description of field and laboratory procedures used and additional data (If any). See Supporting Information for explanation of Abandonment Method: symbols and abbreviations. Boring backfilled with Auger Cuttings and Bentonite Google Earth

WATER LEVEL OBSERVATIONS Boring Started: 06-05-2019 Boring Completed: 06-05-2019

Drill Rig: Diedrich D-120 Driller: Holocene 21905 64th Ave W, Ste 100 Mountlake Terrace, WA Project No.: 81195048 THIS BORING LOG IS NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GEO SMART LOG-NO WELL 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR SLOPE LOG-NO WELL 81195048 ROYAL GEO SMART FROM ORIGINAL REPORT. IF SEPARATED LOG IS NOT VALID THIS BORING GRAIN SIZE DISTRIBUTION ASTM D422 / ASTM C136 U.S. SIEVE OPENING IN INCHES U.S. SIEVE NUMBERS HYDROMETER 4 2 1 1/2 3 6 10 16 30 50 100 200 6 3 1.5 3/4 3/8 4 8 14 20 40 60 140 100

95

90

85

80

75

70

65

60

55

50

45

40

PERCENT FINER BY WEIGHT 35

30

25

20

15

10

5

0 100 10 1 0.1 0.01 0.001 GRAIN SIZE IN MILLIMETERS GRAVEL SAND COBBLES SILT OR CLAY coarse fine coarse medium fine

Boring ID Depth USCS Classification WC (%) LL PL PI Cc Cu TP-01 3 - 3.5 Sandy SILT, trace fine gravel (ML) 7 TP-10 0 - 1.3 Gravelly SAND with silt (SP-SM) 6 TP-11 1 - 2 Silty fine SAND, trace gravel (SM) 9 TP-13 0 - 1.5 Silty fine SAND with gravel (SM) 11 TP-17 0 - 3 Silty, gravelly SAND (SM) 13

Boring ID Depth D100 D60 D30 D10 %Cobbles %Gravel %Sand %Silt %Fines %Clay TP-01 3 - 3.5 50 0.092 0.0 5.9 39.9 54.2 TP-10 0 - 1.3 50 3.233 0.394 0.0 34.2 54.9 10.8 TP-11 1 - 2 37.5 0.208 0.107 0.0 8.5 71.0 20.5 TP-13 0 - 1.5 37.5 0.194 0.106 0.0 9.6 72.3 18.1 TP-17 0 - 3 63 1.661 0.137 0.0 33.2 54.5 12.3

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GRAIN SIZE: USCS-2 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR 81195048 SLOPE USCS-2 ROYAL GRAIN SIZE: FROM ORIGINAL REPORT. VALID IF SEPARATED NOT ARE TESTS LABORATORY GRAIN SIZE DISTRIBUTION ASTM D422 / ASTM C136 U.S. SIEVE OPENING IN INCHES U.S. SIEVE NUMBERS HYDROMETER 4 2 1 1/2 3 6 10 16 30 50 100 200 6 3 1.5 3/4 3/8 4 8 14 20 40 60 140 100

95

90

85

80

75

70

65

60

55

50

45

40

PERCENT FINER BY WEIGHT BY FINER PERCENT 35

30

25

20

15

10

5

0 100 10 1 0.1 0.01 0.001 GRAIN SIZE IN MILLIMETERS GRAVEL SAND COBBLES SILT OR CLAY coarse fine coarse medium fine

Boring ID Depth USCS Classification WC (%) LL PL PI Cc Cu TP-20 1 - 2 Fine SAND with silt and gravel (SP-SM) 9 1.06 2.99 TP-22 0 - 0.5 Fine SAND with silt (SP-SM) 2 0.99 2.11 TP-26 0 - 3 Fine SAND with silt (SP-SM) 10 1.05 2.63 TP-32 0 - 5 Silty fine to medium SAND, trace gravel (SM) 4 TP-35 0 - 1 Fine SAND, trace of silt (SP) 8 1.06 2.09

Boring ID Depth D100 D60 D30 D10 %Cobbles %Gravel %Sand %Silt %Fines %Clay TP-20 1 - 2 100 0.248 0.147 0.083 6.5 19.2 66.3 7.9 TP-22 0 - 0.5 37.5 0.16 0.11 0.076 0.0 0.9 89.7 9.3 TP-26 0 - 3 50 0.2 0.126 0.076 0.0 7.2 83.3 9.5 TP-32 0 - 5 50 0.433 0.122 0.0 5.7 73.6 20.7 TP-35 0 - 1 16 0.213 0.152 0.102 0.0 0.0 95.4 4.6

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. GRAIN SIZE:ROYAL USCS-2 SLOPE 81195048 SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 MOISTURE-DENSITY RELATIONSHIP ASTM D698/D1557

135 Source of Material Composite TP-10-17-26 @ 0 feet Description of Material Fine SAND with silt 130 Remarks:

125 Test Method ASTM D698 Method C TEST RESULTS 115.4 PCF 120 Maximum Dry Density Optimum Water Content 13.4 % Percent Fines % ATTERBERG LIMITS 115 LL PL PI

110

105 DRY DENSITY, pcf DENSITY, DRY

100

95

90

85

ZAV for G

ZAV for G 80 ZAV for Gs = 2.8

s = 2.7

s = 2.6

75 0 5 10 15 20 25 30 35 40 45 WATER CONTENT, %

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. ROYAL COMPACTIONV2 81195048 SLOPE - SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 MOISTURE-DENSITY RELATIONSHIP ASTM D698/D1557

135 Source of Material TP-01 @ 3 - 3.5 feet Description of Material Sandy SILT, trace fine gravel 130 Remarks:

125 Test Method ASTM D698 Method B TEST RESULTS 111.0 PCF 120 Maximum Dry Density Optimum Water Content 14.2 % Percent Fines 54.2 % ATTERBERG LIMITS 115 LL PL PI

110

105 DRY DENSITY, pcf

100

95

90

85

ZAV for G

ZAV for G 80 ZAV for Gs = 2.8

s = 2.7

s = 2.6

75 0 5 10 15 20 25 30 35 40 45 WATER CONTENT, %

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. COMPACTION - V2 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR - SLOPE COMPACTION V2 81195048 ROYAL FROM ORIGINAL REPORT. VALID IF SEPARATED NOT ARE TESTS LABORATORY MOISTURE-DENSITY RELATIONSHIP ASTM D698/D1557

135 Source of Material TP-11 @ 1 - 2 feet Description of Material Silty fine SAND, trace gravel 130 Remarks:

125 Test Method ASTM D698 Method C TEST RESULTS 117.4 PCF 120 Maximum Dry Density Optimum Water Content 11.0 % Percent Fines 20.5 % ATTERBERG LIMITS 115 LL PL PI

110

105 DRY DENSITY, pcf

100

95

90

85

ZAV for G

ZAV for G 80 ZAV for Gs = 2.8

s = 2.7

s = 2.6

75 0 5 10 15 20 25 30 35 40 45 WATER CONTENT, %

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. COMPACTION - V2 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR - SLOPE COMPACTION V2 81195048 ROYAL FROM ORIGINAL REPORT. VALID IF SEPARATED NOT ARE TESTS LABORATORY MOISTURE-DENSITY RELATIONSHIP ASTM D698/D1557

135 Source of Material TP-13 @ 0 - 1.5 feet Description of Material Silty fine SAND with gravel 130 Remarks:

Test Method ASTM D698 Method B 125 TEST RESULTS Uncorrected Maximum Dry Density PCF107.5 109.3 PCF 120 Corrected Maximum Dry Density Uncorrected Optimum Water Content 14.6 % Corrected Optimum Water Content %13.9 Percent Fines 18.1 % 115 Fraction > 9.5mm size 7.4 % ATTERBERG LIMITS

110 LL PL PI

105 DRY DENSITY, pcf

100

95

90

85

ZAV for G

ZAV for G 80 ZAV for Gs = 2.8

s = 2.7

s = 2.6

75 0 5 10 15 20 25 30 35 40 45 WATER CONTENT, %

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. COMPACTION - V2 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR - SLOPE COMPACTION V2 81195048 ROYAL FROM ORIGINAL REPORT. VALID IF SEPARATED NOT ARE TESTS LABORATORY MOISTURE-DENSITY RELATIONSHIP ASTM D698/D1557

135 Source of Material TP-20 @ 1 - 2 feet Description of Material Fine SAND with silt and gravel 130 Remarks:

Test Method ASTM D698 Method B 125 TEST RESULTS Uncorrected Maximum Dry Density PCF108.4 118.7 PCF 120 Corrected Maximum Dry Density Uncorrected Optimum Water Content 14.6 % Corrected Optimum Water Content %11.6 Percent Fines 7.9 % 115 Fraction > 9.5mm size 22.5 % ATTERBERG LIMITS

110 LL PL PI

105 DRY DENSITY, pcf

100

95

90

85

ZAV for G

ZAV for G 80 ZAV for Gs = 2.8

s = 2.7

s = 2.6

75 0 5 10 15 20 25 30 35 40 45 WATER CONTENT, %

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. COMPACTION - V2 81195048 ROYAL SLOPE SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 TERRACON_DATATEMPLATE.GDT COPYV2.GPJ - LAB-BULK SOLAR - SLOPE COMPACTION V2 81195048 ROYAL FROM ORIGINAL REPORT. VALID IF SEPARATED NOT ARE TESTS LABORATORY MOISTURE-DENSITY RELATIONSHIP ASTM D698/D1557

135 Source of Material TP-22 @ 0 - 0.5 feet Description of Material Fine SAND with silt 130 Remarks:

125 Test Method ASTM D698 Method C TEST RESULTS 98.4 PCF 120 Maximum Dry Density Optimum Water Content 16.8 % Percent Fines 9.3 % ATTERBERG LIMITS 115 LL PL PI

110

105 DRY DENSITY, pcf DENSITY, DRY

100

95

90

85

ZAV for G

ZAV for G 80 ZAV for Gs = 2.8

s = 2.7

s = 2.6

75 0 5 10 15 20 25 30 35 40 45 WATER CONTENT, %

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. ROYAL COMPACTIONV2 81195048 SLOPE - SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 MOISTURE-DENSITY RELATIONSHIP ASTM D698/D1557

135 Source of Material TP-32 @ 0 - 5 feet Description of Material Silty fine to medium SAND, trace 130 gravel Remarks:

125 Test Method ASTM D698 Method B TEST RESULTS 120.6 PCF 120 Maximum Dry Density Optimum Water Content 11.8 % Percent Fines 20.7 % ATTERBERG LIMITS 115 LL PL PI

110

105 DRY DENSITY, pcf DENSITY, DRY

100

95

90

85

ZAV for G

ZAV for G 80 ZAV for Gs = 2.8

s = 2.7

s = 2.6

75 0 5 10 15 20 25 30 35 40 45 WATER CONTENT, %

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. ROYAL COMPACTIONV2 81195048 SLOPE - SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 MOISTURE-DENSITY RELATIONSHIP ASTM D698/D1557

135 Source of Material TP-35 @ 0 - 1 feet Description of Material Fine SAND, trace of silt 130 Remarks:

125 Test Method ASTM D698 Method C TEST RESULTS 100.7 PCF 120 Maximum Dry Density Optimum Water Content 15.9 % Percent Fines 4.6 % ATTERBERG LIMITS 115 LL PL PI

110

105 DRY DENSITY, pcf DENSITY, DRY

100

95

90

85

ZAV for G

ZAV for G 80 ZAV for Gs = 2.8

s = 2.7

s = 2.6

75 0 5 10 15 20 25 30 35 40 45 WATER CONTENT, %

PROJECT: Royal Slope Solar Project PROJECT NUMBER: 81195048

SITE: 10 Miles West of Royal City, R23E, 21905 64th Ave W, Ste 100 CLIENT: JuWi Americas, Inc. T16N Mountlake Terrace, WA Boulder, Colorado Grant County, Washington LABORATORY TESTS ARE NOT VALID IF SEPARATED FROM ORIGINAL REPORT. ROYAL COMPACTIONV2 81195048 SLOPE - SOLAR - LAB-BULK COPYV2.GPJ TERRACON_DATATEMPLATE.GDT 8/9/19 CBR (California Bearing Ratio) OF LAB COMPACTED SOILS (ASTM D 1883) CLIENT: Terracon PROJECT: Royal Slope Solar Project SAMPLE ID: TP-10/17/26 PROJECT NO: 2012-045 T12 Sampled By: Client Tested By: DW Date Sampled: N/A Date Received: 7/30/2019 Date Tested: 8/1/2019

Material Description: Olive brown, silty SAND (SM) Sample Location: TP-10, TP-17, TP-26 Composite Sample

Compaction Standard: D698 X D1557 Condition: X Soaked for 96 hrs Unsoaked Max. Dry Density: N/A pcf @ N/A % M.C. with 0 % scalped-off on the 3/4" sieve

Trial 1 Trial 2 Trial 3 Dry Density (pcf) 118.1 112.8 107.1 Percent Compaction N/A N/A N/A Moisture before Compaction (%) 9.4 9.4 9.4 Moisture after Compaction (%) 9.4 9.4 9.4 Percent Swell (initial ht = 7") 0.1 0.1 0.0 Moisture, after Soaking (%) 13.6 15.3 18.2 Moisture, Top 1", after Soak (%) 14.2 16.1 16.4 Surcharge Weight (lbs) 10 10 10 CBR at 0.1" Penetration 68.7 30.2 6.8 CBR at 0.2" Penetration 68.7 31.0 7.1 CBR Value 68.7 31.0 7.1

1800

118.1 1600 112.8 1400 107.1 1200

1000

800 Stress (psi) Stress 600

400

200

0 0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50 Displacement (in)

80 70 60 50 40

CBR 30 20 10 0 100 105 110 115 120 125

Dry Density (pcf)

REVIEWED BY: FIGURE: CBR (California Bearing Ratio) OF LAB COMPACTED SOILS (ASTM D 1883) CLIENT: Terracon PROJECT: Royal Slope Solar Project SAMPLE ID: TP-11 PROJECT NO: 2012-045 T12 Sampled By: Client Tested By: DW Date Sampled: N/A Date Received: 7/30/2019 Date Tested: 8/1/2019

Material Description: Dark olive brown, silty SAND (SM) Sample Location: TP-11

Compaction Standard: D698 X D1557 Condition: X Soaked for 96 hrs Unsoaked Max. Dry Density: N/A pcf @ N/A % M.C. with 0 % scalped-off on the 3/4" sieve

Trial 1 Trial 2 Trial 3 Dry Density (pcf) 118.9 111.6 107.0 Percent Compaction N/A N/A N/A Moisture before Compaction (%) 7.0 7.0 7.0 Moisture after Compaction (%) 7.0 7.0 7.0 Percent Swell (initial ht = 7") 0.1 0.1 0.1 Moisture, after Soaking (%) 12.7 15.0 17.1 Moisture, Top 1", after Soak (%) 14.4 15.2 17.1 Surcharge Weight (lbs) 10 10 10 CBR at 0.1" Penetration 29.8 7.0 4.3 CBR at 0.2" Penetration 29.8 6.2 4.2 CBR Value 29.8 7.0 4.3

700

118.9 600 111.6

107.0 500

400

300 Stress (psi) Stress

200

100

0 0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50 Displacement (in)

35 30 25 20 15 CBR 10 5 0 100 105 110 115 120 125

Dry Density (pcf)

REVIEWED BY: FIGURE: CBR (California Bearing Ratio) OF LAB COMPACTED SOILS (ASTM D 1883) CLIENT: Terracon PROJECT: Royal Slope Solar Project SAMPLE ID: TP-22 PROJECT NO: 2012-045 T12 Sampled By: Client Tested By: DW Date Sampled: N/A Date Received: 7/30/2019 Date Tested: 8/9/2019

Material Description: Olive brown, poorly graded SAND with silt (SP-SM) Sample Location: TP-22

Compaction Standard: D698 X D1557 Condition: X Soaked for 96 hrs Unsoaked Max. Dry Density: N/A pcf @ N/A % M.C. with 0 % scalped-off on the 3/4" sieve

Trial 1 Trial 2 Trial 3 Dry Density (pcf) 99.6 94.8 91.9 Percent Compaction N/A N/A N/A Moisture before Compaction (%) 12.8 12.8 12.8 Moisture after Compaction (%) 12.8 12.8 12.8 Percent Swell (initial ht = 7") 37.7 39.3 39.0 Moisture, after Soaking (%) 19.7 23.3 24.8 Moisture, Top 1", after Soak (%) 20.6 22.2 24.4 Surcharge Weight (lbs) 10 10 10 CBR at 0.1" Penetration 15.1 5.5 5.2 CBR at 0.2" Penetration 19.5 8.1 7.3 CBR Value 19.5 8.1 7.3

500

99.6 450 94.8 400 91.9 350

300

250

Stress (psi) Stress 200

150

100

50

0 0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50 Displacement (in)

25

20

15

CBR 10

5

0 85 87 89 91 93 95 97 99 101 103 105

Dry Density (pcf)

REVIEWED BY: S. Greene FIGURE: 3 CBR (California Bearing Ratio) OF LAB COMPACTED SOILS (ASTM D 1883) CLIENT: Terracon PROJECT: Royal Slope Solar Project SAMPLE ID: TP-35 PROJECT NO: 2012-045 T12 Sampled By: Client Tested By: DW Date Sampled: N/A Date Received: 7/30/2019 Date Tested: 8/9/2019

Material Description: Olive brown, poorly graded SAND with silt (SP-SM) Sample Location: TP-35

Compaction Standard: D698 X D1557 Condition: X Soaked for 96 hrs Unsoaked Max. Dry Density: N/A pcf @ N/A % M.C. with 0 % scalped-off on the 3/4" sieve

Trial 1 Trial 2 Trial 3 Dry Density (pcf) 100.9 97.8 93.5 Percent Compaction N/A N/A N/A Moisture before Compaction (%) 11.9 11.9 11.9 Moisture after Compaction (%) 11.9 11.9 11.9 Percent Swell (initial ht = 7") 38.6 39.0 38.8 Moisture, after Soaking (%) 19.0 21.1 23.6 Moisture, Top 1", after Soak (%) 19.4 20.7 23.0 Surcharge Weight (lbs) 10 10 10 CBR at 0.1" Penetration 19.1 13.3 4.7 CBR at 0.2" Penetration 21.8 15.7 6.4 CBR Value 21.8 15.7 6.4

500

100.9 450 97.8 400 93.5 350

300

250

Stress (psi) Stress 200

150

100

50

0 0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50 Displacement (in)

25

20

15

CBR 10

5

0 85 87 89 91 93 95 97 99 101 103 105

Dry Density (pcf)

REVIEWED BY: S. Greene FIGURE: 4 CHEMICAL LABORATORY TEST REPORT Project Number: 81195048 Service Date: 07/23/19 750 Pilot Road, Suite F Report Date: 08/08/19 Las Vegas, Nevada 89119 Task: (702) 597-9393 Client Project Juwi Solar, Inc. Royal Slope Solar Project Boulder, Colorado

Sample Submitted By: Terracon (81) Date Received: 7/19/2019 Lab No.: 19-0841

Results of Corrosion Analysis

Sample Number Sample Location TP-8 TP-12 TP-15 TP-16 Sample Depth (ft.) 3.2-3.5 2.5-3.0 6.0-6.2 2.0-3.0

pH Analysis, AWWA 4500 H 8.17 8.98 8.20 8.03

Water Soluble Sulfate (SO4), ASTM C 1580 101 63 212 102 (mg/kg)

Sulfides, AWWA 4500-S D, (mg/kg) Nil Nil Nil Nil

Chlorides, ASTM D 512, (mg/kg) 48 90 25 10

Red-Ox, AWWA 2580, (mV) +688 +693 +685 +683

Total Salts, AWWA 2540, (mg/kg) 1613 2296 595 291

Resistivity (Saturated), ASTM G 57, (ohm-cm) 970 766 4414 6936

Moisture Content, ASTM D 2216, (percent %) 7.0 6.2 6.1 5.8

Analyzed By: Trisha Campo Chemist

The tests were performed in general accordance with applicable ASTM, AASHTO, or DOT test methods. This report is exclusively for the use of the client indicated above and shall not be reproduced except in full without the written consent of our company. Test results transmitted herein are only applicable to the actual samples tested at the location(s) referenced and are not necessarily indicative of the properties of other apparently similar or identical materials. CHEMICAL LABORATORY TEST REPORT Project Number: 81195048 Service Date: 07/23/19 750 Pilot Road, Suite F Report Date: 08/08/19 Las Vegas, Nevada 89119 Task: (702) 597-9393 Client Project Juwi Solar, Inc. Royal Slope Solar Project Boulder, Colorado

Sample Submitted By: Terracon (81) Date Received: 7/19/2019 Lab No.: 19-0841

Results of Corrosion Analysis

Sample Number Sample Location TP-19 TP-21 TP-23 TP-25 Sample Depth (ft.) 2.0-4.6 1.5-2.0 0.0-3.0 3.0-4.0

pH Analysis, AWWA 4500 H 8.41 8.63 8.66 8.80

Water Soluble Sulfate (SO4), ASTM C 1580 271 113 31 105 (mg/kg)

Sulfides, AWWA 4500-S D, (mg/kg) Nil Nil Nil Nil

Chlorides, ASTM D 512, (mg/kg) 265 50 25 25

Red-Ox, AWWA 2580, (mV) +692 +686 +682 +687

Total Salts, AWWA 2540, (mg/kg) 2968 292 319 512

Resistivity (Saturated), ASTM G 57, (ohm-cm) 572 4462 8730 3201

Moisture Content, ASTM D 2216, (percent %) 11.7 4.6 4.2 2.1

Analyzed By: Trisha Campo Chemist

The tests were performed in general accordance with applicable ASTM, AASHTO, or DOT test methods. This report is exclusively for the use of the client indicated above and shall not be reproduced except in full without the written consent of our company. Test results transmitted herein are only applicable to the actual samples tested at the location(s) referenced and are not necessarily indicative of the properties of other apparently similar or identical materials. CHEMICAL LABORATORY TEST REPORT Project Number: 81195048 Service Date: 07/23/19 750 Pilot Road, Suite F Report Date: 08/08/19 Las Vegas, Nevada 89119 Task: (702) 597-9393 Client Project Juwi Solar, Inc. Royal Slope Solar Project Boulder, Colorado

Sample Submitted By: Terracon (81) Date Received: 7/19/2019 Lab No.: 19-0841

Results of Corrosion Analysis

Sample Number Sample Location TP-28 TP-30 TP-31 TP-33 Sample Depth (ft.) 1.0-2.0 3.0-4.0 2.0-3.0 2.0-3.0

pH Analysis, AWWA 4500 H 8.93 8.08 8.17 8.69

Water Soluble Sulfate (SO4), ASTM C 1580 47 40 99 43 (mg/kg)

Sulfides, AWWA 4500-S D, (mg/kg) Nil Nil Nil Nil

Chlorides, ASTM D 512, (mg/kg) 28 33 25 25

Red-Ox, AWWA 2580, (mV) +685 +683 +680 +685

Total Salts, AWWA 2540, (mg/kg) 504 314 267 321

Resistivity (Saturated), ASTM G 57, (ohm-cm) 4220 9652 4947 9700

Moisture Content, ASTM D 2216, (percent %) 7.0 4.4 8.4 1.8

Analyzed By: Trisha Campo Chemist

The tests were performed in general accordance with applicable ASTM, AASHTO, or DOT test methods. This report is exclusively for the use of the client indicated above and shall not be reproduced except in full without the written consent of our company. Test results transmitted herein are only applicable to the actual samples tested at the location(s) referenced and are not necessarily indicative of the properties of other apparently similar or identical materials. CHEMICAL LABORATORY TEST REPORT Project Number: 81195048 Service Date: 07/23/19 750 Pilot Road, Suite F Report Date: 08/08/19 Las Vegas, Nevada 89119 Task: (702) 597-9393 Client Project Juwi Solar, Inc. Royal Slope Solar Project Boulder, Colorado

Sample Submitted By: Terracon (81) Date Received: 7/19/2019 Lab No.: 19-0841

Results of Corrosion Analysis

Sample Number Sample Location TP-36 TP-37 TP-39 Sample Depth (ft.) 0.0-2.5 0.0-1.7 1.0-1.2

pH Analysis, AWWA 4500 H 8.86 7.81 8.49

Water Soluble Sulfate (SO4), ASTM C 1580 110 124 64 (mg/kg)

Sulfides, AWWA 4500-S D, (mg/kg) Nil Nil Nil

Chlorides, ASTM D 512, (mg/kg) 38 28 45

Red-Ox, AWWA 2580, (mV) +688 +683 +685

Total Salts, AWWA 2540, (mg/kg) 782 413 1002

Resistivity (Saturated), ASTM G 57, (ohm-cm) 1940 2425 3201

Moisture Content, ASTM D 2216, (percent %) 9.8 7.3 6.2

Analyzed By: Trisha Campo Chemist

The tests were performed in general accordance with applicable ASTM, AASHTO, or DOT test methods. This report is exclusively for the use of the client indicated above and shall not be reproduced except in full without the written consent of our company. Test results transmitted herein are only applicable to the actual samples tested at the location(s) referenced and are not necessarily indicative of the properties of other apparently similar or identical materials.

21239 FM529 Rd., Bldg. F Cypress, TX 77433 Tel: 281-985-9344 Fax: 832-427-1752 [email protected]

August 9, 2019

Terracon Consultants, Inc. 21905 64th Ave. West., Ste 100 Mountlake Terrace, WA 98043 Attn: Chad McMullen, P.E.

Re: Thermal Analysis of Native Soil Samples Royal Solar Farm Project – Royal City, WA (Project No. 81195048)

The following is the report of thermal dryout characterization tests conducted on the eight (8) soil samples from the referenced project sent to our laboratory.

Thermal Resistivity Tests: The samples were tested at the ‘optimum’ moisture content and at 90% of the maximum dry density provided by Terracon. The tests were conducted in accordance with the IEEE standard 442-2017. The results are tabulated below and the thermal dryout curves are presented in Figures 1 & 2.

Sample ID, Description, Thermal Resistivity, Moisture Content and Density

Thermal Resistivity Moisture Dry Soil Description Sample ID (°C-cm/W) Content Density (Terracon) Wet Dry (%) (lb/ft3) TP-1 Light Brown Silty Fine Sand 80 277 14 100 TP-10/17/26 Light Brown Fine Sand w/ silt and 86 275 13 104 combined gravel TP-11 Light Brown Fine Sand w/ Silt 76 233 11 106 TP-13 Tan Fine Sand w/ Silt 85 289 14 98 TP-20 Fine Sand w/ Silt 82 300 12 107 TP-22 Fine Sand w/ Silt 100 426 17 89 TP-32 Light Tan Fine Sand w/ Silt 84 283 12 108 TP-35 Brown Fine Sand w/ Silt 95 383 16 106

COOL SOLUTIONS FOR UNDERGROUND POWER CABLES THERMAL SURVEYS, CORRECTIVE BACKFILLS & INSTRUMENTATION

Serving the electric power industry since 1978

Comments: The thermal characteristic depicted in the dryout curves apply for the soils at their respective test dry density.

Please contact us if you have any questions or if we can be of further assistance.

Geotherm USA

Nimesh Patel

2

3

4

SUPPORTING INFORMATION

Contents: General Notes Unified Soil Classification System Description of Rock Properties Seismic Design Ground Motions (code-based) Note: All attachments are one page unless noted above.

GENERAL NOTES DESCRIPTION OF SYMBOLS AND ABBREVIATIONS Royal Slope Solar Project Grant County, Washington Terracon Project No. 81195048

SAMPLING WATER LEVEL FIELD TESTS N Standard Penetration Test Water Initially Resistance (Blows/Ft.) Encountered Water Level After a (HP) Hand Penetrometer Grab Specified Period of Time Rock Core Sample Water Level After (T) Torvane a Specified Period of Time Standard (DCP) Dynamic Cone Penetrometer Penetration Water levels indicated on the soil boring logs are Test the levels measured in the borehole at the times indicated. Groundwater level variations will occur UC Unconfined Compressive over time. In low permeability soils, accurate Strength determination of groundwater levels is not possible with short term water level (PID) Photo-Ionization Detector observations.

(OVA) Organic Vapor Analyzer

DESCRIPTIVE SOIL CLASSIFICATION Soil classification is based on the Unified Soil Classification System. Coarse Grained Soils have more than 50% of their dry weight retained on a #200 sieve; their principal descriptors are: boulders, cobbles, gravel or sand. Fine Grained Soils have less than 50% of their dry weight retained on a #200 sieve; they are principally described as clays if they are plastic, and silts if they are slightly plastic or non-plastic. Major constituents may be added as modifiers and minor constituents may be added according to the relative proportions based on grain size. In addition to gradation, coarse-grained soils are defined on the basis of their in-place relative density and fine-grained soils on the basis of their consistency.

LOCATION AND ELEVATION NOTES Unless otherwise noted, Latitude and Longitude are approximately determined using a hand-held GPS device. The accuracy of such devices is variable. Surface elevation data annotated with +/- indicates that no actual topographical survey was conducted to confirm the surface elevation. Instead, the surface elevation was approximately determined from topographic maps of the area.

STRENGTH TERMS RELATIVE DENSITY OF COARSE-GRAINED SOILS CONSISTENCY OF FINE-GRAINED SOILS BEDROCK (More than 50% retained on No. 200 sieve.) (50% or more passing the No. 200 sieve.) Density determined by Standard Penetration Consistency determined by laboratory shear strength testing, Resistance field visual-manual procedures or standard penetration resistance Descriptive Term Standard Penetration or Descriptive Unconfined Compressive Standard Standard Descriptive (Density) N-Value Term Strength Penetration Penetration or N-Value Term or N-Value Blows/Ft. Blows/Ft. (Consistency) Qu, (tsf) Blows/Ft. (Consistency) Very Loose 0 - 3 Very Soft less than 0.25 0 - 1 < 20 Weathered Loose 4 - 9 Soft 0.25 to 0.50 2 - 4 20 - 29 Firm Medium Dense 10 - 29 Medium Stiff 0.50 to 1.00 4 - 8 30 - 49 Medium Hard Dense 30 - 50 Stiff 1.00 to 2.00 8 - 15 50 - 79 Hard Very Dense > 50 Very Stiff 2.00 to 4.00 15 - 30 >79 Very Hard Hard > 4.00 > 30

RELATIVE PROPORTIONS OF SAND AND GRAVEL RELATIVE PROPORTIONS OF FINES Descriptive Term(s) of Percent of Descriptive Term(s) of Percent of other constituents Dry Weight other constituents Dry Weight Trace <15 Trace <5 With 15-29 With 5-12 Modifier >30 Modifier >12 GRAIN SIZE TERMINOLOGY PLASTICITY DESCRIPTION Major Component of Sample Particle Size Term Plasticity Index Boulders Over 12 in. (300 mm) Non-plastic 0 Cobbles 12 in. to 3 in. (300mm to 75mm) Low 1 - 10 Gravel 3 in. to #4 sieve (75mm to 4.75 mm) Medium 11 - 30 Sand #4 to #200 sieve (4.75mm to 0.075mm High > 30 Silt or Clay Passing #200 sieve (0.075mm) UNIFIED SOIL CLASSIFICATION SYSTEM

UNIFIED SOIL C L ASSIFIC ATION SYST EM Soil Classification A Criteria for Assigning Group Symbols and Group Names Using Laboratory Tests Group B Symbol Group Name Cu  4 and 1  Cc  3 E GW Well-graded gravel F Clean Gravels: Gravels: Less than 5% fines C Cu  4 and/or [Cc<1 or Cc>3.0] E GP Poorly graded gravel F More than 50% of coarse fraction Fines classify as ML or MH GM Silty gravel F, G, H retained on No. 4 sieve Gravels with Fines: Coarse-Grained Soils: More than 12% fines C Fines classify as CL or CH GC Clayey gravel F, G, H More than 50% retained

on No. 200 sieve Clean Sands: Cu  6 and 1  Cc  3 E SW Well-graded sand I Sands: Less than 5% fines D Cu  6 and/or [Cc<1 or Cc>3.0] E SP Poorly graded sand I 50% or more of coarse fraction passes No. 4 Fines classify as ML or MH SM G, H, I Sands with Fines: Silty sand sieve More than 12% fines D Fines classify as CL or CH SC Clayey sand G, H, I

PI  7 and plots on or above “A” CL Lean clay K, L, M Inorganic: line J Silts and Clays: PI  4 or plots below “A” line J ML Silt K, L, M Liquid limit less than 50 Liquid limit - oven dried Organic clay K, L, M, N Fine-Grained Soils: Organic:  0.75 OL Liquid limit - not dried Organic silt K, L, M, O 50% or more passes the PI plots on or above “A” line CH Fat clay K, L, M No. 200 sieve Inorganic: Silts and Clays: PI plots below “A” line MH Elastic Silt K, L, M Liquid limit 50 or more Liquid limit - oven dried Organic clay K, L, M, P Organic:  0.75 OH Liquid limit - not dried Organic silt K, L, M, Q Highly organic soils: Primarily organic matter, dark in color, and organic odor PT Peat A Based on the material passing the 3-inch (75-mm) sieve. H If fines are organic, add “with organic fines” to group name. B If field sample contained cobbles or boulders, or both, add “with cobbles I If soil contains  15% gravel, add “with gravel” to group name. or boulders, or both” to group name. J If Atterberg limits plot in shaded area, soil is a CL-ML, silty clay. C Gravels with 5 to 12% fines require dual symbols: GW-GM well-graded K If soil contains 15 to 29% plus No. 200, add “with sand” or “with gravel with silt, GW-GC well-graded gravel with clay, GP-GM poorly gravel,” whichever is predominant. graded gravel with silt, GP-GC poorly graded gravel with clay. L If soil contains  30% plus No. 200 predominantly sand, add D Sands with 5 to 12% fines require dual symbols: SW-SM well-graded “sandy” to group name. sand with silt, SW-SC well-graded sand with clay, SP-SM poorly graded M sand with silt, SP-SC poorly graded sand with clay. If soil contains  30% plus No. 200, predominantly gravel, add “gravelly” to group name. 2 N (D 30 ) PI  4 and plots on or above “A” line. E Cu = D60/D10 Cc = O PI  4 or plots below “A” line. DxD 10 60 P PI plots on or above “A” line.

F If soil contains  15% sand, add “with sand” to group name. Q PI plots below “A” line. G If fines classify as CL-ML, use dual symbol GC-GM, or SC-SM. DESCRIPTION OF ROCK PROPERTIES

ROCK VER SION 1 WEATHERING Term Description Unweathered No visible sign of rock material weathering, perhaps slight discoloration on major discontinuity surfaces. Slightly Discoloration indicates weathering of rock material and discontinuity surfaces. All the rock material may be weathered discolored by weathering and may be somewhat weaker externally than in its fresh condition. Moderately Less than half of the rock material is decomposed and/or disintegrated to a soil. Fresh or discolored rock is weathered present either as a continuous framework or as corestones. Highly More than half of the rock material is decomposed and/or disintegrated to a soil. Fresh or discolored rock is weathered present either as a discontinuous framework or as corestones. Completely All rock material is decomposed and/or disintegrated to soil. The original mass structure is still largely intact. weathered All rock material is converted to soil. The mass structure and material fabric are destroyed. There is a large Residual soil change in volume, but the soil has not been significantly transported. STRENGTH OR HARDNESS Uniaxial Compressive Description Field Identification Strength, psi (MPa) Extremely weak Indented by thumbnail 40-150 (0.3-1) Crumbles under firm blows with point of geological hammer, can be Very weak 150-700 (1-5) peeled by a pocket knife Can be peeled by a pocket knife with difficulty, shallow indentations Weak rock 700-4,000 (5-30) made by firm blow with point of geological hammer Cannot be scraped or peeled with a pocket knife, specimen can be Medium strong 4,000-7,000 (30-50) fractured with single firm blow of geological hammer Specimen requires more than one blow of geological hammer to Strong rock 7,000-15,000 (50-100) fracture it Very strong Specimen requires many blows of geological hammer to fracture it 15,000-36,000 (100-250) Extremely strong Specimen can only be chipped with geological hammer >36,000 (>250) DISCONTINUITY DESCRIPTION Fracture Spacing (Joints, Faults, Other Fractures) Bedding Spacing (May Include Foliation or Banding) Description Spacing Description Spacing Extremely close < ¾ in (<19 mm) Laminated < ½ in (<12 mm) Very close ¾ in – 2-1/2 in (19 - 60 mm) Very thin ½ in – 2 in (12 – 50 mm) Close 2-1/2 in – 8 in (60 – 200 mm) Thin 2 in – 1 ft. (50 – 300 mm) Moderate 8 in – 2 ft. (200 – 600 mm) Medium 1 ft. – 3 ft. (300 – 900 mm) Wide 2 ft. – 6 ft. (600 mm – 2.0 m) Thick 3 ft. – 10 ft. (900 mm – 3 m) Very Wide 6 ft. – 20 ft. (2.0 – 6 m) Massive > 10 ft. (3 m) Discontinuity Orientation (Angle): Measure the angle of discontinuity relative to a plane perpendicular to the longitudinal axis of the core. (For most cases, the core axis is vertical; therefore, the plane perpendicular to the core axis is horizontal.) For example, a horizontal bedding plane would have a 0-degree angle. ROCK QUALITY DESIGNATION (RQD) 1 Description RQD Value (%) Very Poor 0 - 25 Poor 25 – 50 Fair 50 – 75 Good 75 – 90 Excellent 90 - 100 1. The combined length of all sound and intact core segments equal to or greater than 4 inches in length, expressed as a percentage of the total core run length. Reference: U.S. Department of Transportation, Federal Highway Administration, Publication No FHWA-NHI-10-034, December 2009 Technical Manual for Design and Construction of Road Tunnels – Civil Elements DESCRIPTION OF ROCK PROPERTIES

ROCK VER SION 2 WEATHERING Fresh Rock fresh, crystals bright, few joints may show slight staining. Rock rings under hammer if crystalline. Rock generally fresh, joints stained, some joints may show thin clay coatings, crystals in broken face show Very slight bright. Rock rings under hammer if crystalline. Rock generally fresh, joints stained, and discoloration extends into rock up to 1 in. Joints may contain clay. In Slight granitoid rocks some occasional feldspar crystals are dull and discolored. Crystalline rocks ring under hammer. Significant portions of rock show discoloration and weathering effects. In granitoid rocks, most feldspars are Moderate dull and discolored; some show clayey. Rock has dull sound under hammer and shows significant loss of strength as compared with fresh rock. All rock except quartz discolored or stained. In granitoid rocks, all feldspars dull and discolored and majority Moderately severe show kaolinization. Rock shows severe loss of strength and can be excavated with geologist’s pick. All rock except quartz discolored or stained. Rock “fabric” clear and evident, but reduced in strength to strong Severe soil. In granitoid rocks, all feldspars kaolinized to some extent. Some fragments of strong rock usually left. All rock except quartz discolored or stained. Rock “fabric” discernible, but mass effectively reduced to “soil” Very severe with only fragments of strong rock remaining. Rock reduced to “soil”. Rock “fabric” no discernible or discernible only in small, scattered locations. Quartz Complete may be present as dikes or stringers. HARDNESS (for engineering description of rock – not to be confused with Moh’s scale for minerals) Cannot be scratched with knife or sharp pick. Breaking of hand specimens requires several hard blows of Very hard geologist’s pick. Can be scratched with knife or pick only with difficulty. Hard blow of hammer required to detach hand Hard specimen. Can be scratched with knife or pick. Gouges or grooves to ¼ in. deep can be excavated by hard blow of point Moderately hard of a geologist’s pick. Hand specimens can be detached by moderate blow. Can be grooved or gouged 1/16 in. deep by firm pressure on knife or pick point. Can be excavated in small Medium chips to pieces about 1-in. maximum size by hard blows of the point of a geologist’s pick. Can be gouged or grooved readily with knife or pick point. Can be excavated in chips to pieces several inches Soft in size by moderate blows of a pick point. Small thin pieces can be broken by finger pressure. Can be carved with knife. Can be excavated readily with point of pick. Pieces 1-in. or more in thickness can be Very soft broken with finger pressure. Can be scratched readily by fingernail. Joint, Bedding, and Foliation Spacing in Rock 1 Spacing Joints Bedding/Foliation Less than 2 in. Very close Very thin 2 in. – 1 ft. Close Thin 1 ft. – 3 ft. Moderately close Medium 3 ft. – 10 ft. Wide Thick More than 10 ft. Very wide Very thick 1. Spacing refers to the distance normal to the planes, of the described feature, which are parallel to each other or nearly so. Rock Quality Designator (RQD) 1 Joint Openness Descriptors RQD, as a percentage Diagnostic description Openness Descriptor Exceeding 90 Excellent No Visible Separation Tight 90 – 75 Good Less than 1/32 in. Slightly Open 75 – 50 Fair 1/32 to 1/8 in. Moderately Open 50 – 25 Poor 1/8 to 3/8 in. Open Less than 25 Very poor 3/8 in. to 0.1 ft. Moderately Wide

1. RQD (given as a percentage) = length of core in pieces 4 Greater than 0.1 ft. Wide inches and longer / length of run

References: American Society of Civil Engineers. Manuals and Reports on Engineering Practice - No. 56. Subsurface Investigation for Design and Construction of Foundations of Buildings. New York: American Society of Civil Engineers, 1976. U.S. Department of the Interior, Bureau of Reclamation, Engineering Geology Field Manual.

8/7/2019 ATC Hazards by Location Hazards by Location

Search Information

Coordinates: 46.90556, -119.91614

Elevation: ft

Timestamp: 2019-08-07T14:48:49.494Z

Hazard Type: Seismic

Reference ASCE7-16 Document: Map dataRepor ©2019t a map Google error Risk Category: I

Site Class: C MCER Horizontal Response Spectrum Design Horizontal Response Spectrum

Sa(g) Sa(g)

0.50 0.30 0.40

0.30 0.20

0.20 0.10 0.10

0.00 0.00 0 5 10 15 Period (s) 0 5 10 15 Period (s)

Basic Parameters

Name Value Description

SS 0.435 MCER ground motion (period=0.2s)

S1 0.177 MCER ground motion (period=1.0s)

SMS 0.566 Site-modified spectral acceleration value

SM1 0.266 Site-modified spectral acceleration value

SDS 0.377 Numeric seismic design value at 0.2s SA

SD1 0.177 Numeric seismic design value at 1.0s SA

Additional Information

Name Value Description

SDC C Seismic design category

Fa 1.3 Site amplification factor at 0.2s

Fv 1.5 Site amplification factor at 1.0s

CRS 0.91 Coefficient of risk (0.2s)

https://hazards.atcouncil.org/#/seismic?lat= 46.90556&lng=-119.91614&address= 1/2 8/7/2019 ATC Hazards by Location

CR1 0.896 Coefficient of risk (1.0s)

PGA 0.193 MCEG peak ground acceleration

FPGA 1.207 Site amplification factor at PGA

PGAM 0.233 Site modified peak ground acceleration

TL 16 Long-period transition period (s)

SsRT 0.435 Probabilistic risk-targeted ground motion (0.2s)

SsUH 0.478 Factored uniform-hazard spectral acceleration (2% probability of exceedance in 50 years)

SsD 1.994 Factored deterministic acceleration value (0.2s)

S1RT 0.177 Probabilistic risk-targeted ground motion (1.0s)

S1UH 0.198 Factored uniform-hazard spectral acceleration (2% probability of exceedance in 50 years)

S1D 0.78 Factored deterministic acceleration value (1.0s)

PGAd 0.832 Factored deterministic acceleration value (PGA)

The results indicated here DO NOT reflect any state or local amendments to the values or any delineation lines made during the building code adoption process. Users should confirm any output obtained from this tool with the local Authority Having Jurisdiction before proceeding with design.

Disclaimer

Hazard loads are provided by the U.S. Geological Survey Seismic Design Web Services.

While the information presented on this website is believed to be correct, ATC and its sponsors and contributors assume no responsibility or liability for its accuracy. The material presented in the report should not be used or relied upon for any specific application without competent examination and verification of its accuracy, suitability and applicability by engineers or other licensed professionals. ATC does not intend that the use of this information replace the sound judgment of such competent professionals, having experience and knowledge in the field of practice, nor to substitute for the standard of care required of such professionals in interpreting and applying the results of the report provided by this website. Users of the information from this website assume all liability arising from such use. Use of the output of this website does not imply approval by the governing building code bodies responsible for building code approval and interpretation for the building site described by latitude/longitude location in the report.

https://hazards.atcouncil.org/#/seismic?lat= 46.90556&lng=-119.91614&address= 2/2 Appendix G WASHINGTON NATURAL HERITAGE PROGRAM Report 2007-05 Natural Heritage Conservation Strategyfor BureauofLandManagement, Inland SandDunes Washington State Rex Crawford,Ph.D. Ryan D.Haugoand Spokane, WA Lisa A. Hallock Prepared for Prepared by June 2007 TABLE OF CONTENTS Disclaimer Executive Summary List of Tables and Figures I. Introduction...... 2 A. Goal B. Scope C. Management Status II. Classification and Description...... 6 A. System B. Community types III. Ecology...... 9 A. Range, Distribution, and Abundance B. Community Type Summaries C. Obligate and Rare associated species D. Trends E. Demography F. Ecological Considerations IV. Conservation...... 21 A. Threats B. Conservation Objective C. Selection of Management Areas D. Management Area Requirements V. Research, Inventory, and Monitoring Opportunities...... 28 VI. Adaptive Management...... 29

Acknowledgments...... 30 References...... 31 Appendices Appendix I: Photographs (Figures 4-19, 21-30) Appendix II: Current and Historical Dune System Extent Appendix III: Classification Methodology of Plant Community Types Appendix IV: EO specs for PNW Inland Sand Dune Ecological System Appendix V: Ecological System Occurrence Ranks and Descriptions Appendix VI: NatureServe Ecological System Definition Appendix VII: Vascular Plant List Appendix VIII: ArcPublisher GIS Information Disclaimer

This Conservation Assessment was prepared for the Bureau of Land Management by the Washington Natural Heritage Program in order to compile information on Washington State inland sand dunes. This assessment does not represent a management decision by the U.S. Bureau of Land Management. Although the best available scientific information was used in preparation of this document, it is expected that new information will arise. In the interest of adaptive management and scientific inquiry, any additional or new information that will assist in conservation of Washington State inland sand dunes, should be provided to the Bureau of Land Management and Washington Natural Heritage Program. Executive Summary

This report follows the May 2006 draft “Conservation Strategy Format” at the request of the Bureau of Land Management. This format applies to species and populations and was adapted here to apply to an ecological system. Individual format section headings were modified to apply to ecological systems rather than species.

Classification Washington inland sand dunes are classified as the Inter-Mountain Basins Active and Stabilized Dune ecological system in the IESC (NatureServe 2006). A terrestrial ecological system is a group of plant communities (associations) that tend to co-occur within landscapes with similar ecological processes, substrates, and/or environmental gradients (Comer 2003).

Management Status Ecological systems are not designated for protection under any federal legislation. However, a number of federal and state listed species are provided habitat by the Inter- Mountain Basins Active and Stabilized Dune ecological system in Washington. These species are discussed in this document.

The 2005 State of Washington Natural Heritage Plan identifies the Pacific Northwest Inland Sand Dune Ecological System as a Priority 1 feature for inclusion in the statewide system of natural areas (http://www.dnr.wa.gov/nhp/refdesk/plan/index.html). Nine plant and four animal species that are dune system-associated are listed as priority species.

One plant species (Northern wormwood) and one animal species (Washington ground squirrel) are candidates for listing under the federal Endangered Species Act. Two animal species have been identified by the USFWS as species of concern. Six animal species associated with dune habitats have been listed as Washington Candidate species (WDFW 2006) because of rarity or declining populations.

Two plant associations within Washington’s inland sand dune systems are recognized by NatureServe: Ponderosa pine/antelope bitterbrush/Indian rice grass (G1: globally critically imperiled) and sand lyme-grass association (G2: globally imperiled).

Range and Distribution of Washington State Inland Sand Dunes The Inter-Mountain Basins Active and Stabilized Dune ecological system is described from Colorado, Idaho, Nevada, Oregon, Montana, and Wyoming. In Washington, inland dune systems are currently found in 13 counties across the Columbia Plateau in eastern Washington with a total extent of 106,953 acres.

Threats The total extent of Washington inland sand dune systems has declined approximately 76% from the early 1970s, primarily due to agricultural conversion, reservoir flooding and dune stabilization. Currently, the major threats to the sand dune ecological system in Washington are stabilization by invasive species, agricultural conversion including

effects from adjacent irrigation, off-road vehicle (ORVs) use, intentional sand dune stabilization, conversion to residential lots, mining activities and livestock grazing.

Management Eight areas are recognized as having significant conservation value: Hanford Central Dunes (USFWS), Juniper Dunes Wilderness (BLM), Delight Dunes, Wanapum and Wanapum North Dunes (BOR), Wahluke Dunes (USFWS), Hanford Black Sand Dunes (USDOE), Sentinel Butte Dunes (BLM), and Wakefield Dunes. These areas warrant special management attention to protect and retain their conservation values. Management should promote a range of dune functional stages to maintain species diversity. Long-term management must address the projected trajectory and rate of migration of individual dune systems and the effects of surrounding landscape conditions and dune use. Short-term management must address exotic plant species invasion and on- site activities, such as ORV use, that influence whole system functioning and alter/destroy rare species habitat.

Research, Inventory, and Monitoring Opportunities Research Priorities: 1. Invasive species impact and control 2. Restoration of dune systems 3. Rare species demographics, especially distribution 4. Complete floristic sampling of plant communities and their seral and environmental relationships to complete International Vegetation Classification descriptions. 5. The range of fire effects in sand dune systems, particularly addressing the response of annual exotic plant abundance, sand movement and stabilization

Inventory – and rare plants have been identified as high priority for inventory. Information on small mammals would also be beneficial. The sand dune systems listed in the Management Areas section are the highest priority for inventory. An inventory on the Hanford Central Dunes and Juniper Dunes is needed to verify classification of the sand lyme-grass association, CEGL001563, (Leymus flavescens) and to determine its extent.

Monitoring Opportunities – Sand dunes are considered sensitive indicators of climate change because they reflect overall moisture balance, degree of vegetation cover, and wind patterns. Establishing a monitoring system for sand dune field rate of movement and stabilization/destabilization with climate change will inform management of dune species and whole dune systems. Dune systems are a confined, limited resource and are targeted for recreational use. Monitoring of recreational impacts, use levels, and public demand for recreational dune “resources” is needed. List of Figures

Figure 1. Current extent of inland sand dunes...... 1 Figure 2. Sand dune site names featured in report...... 4 Figure 3. Sand dune terminology...... 7 Figure 20 Current and historical (∼1970) extent of inland sand dunes...... 19

The following figures are contained in Appendix I Figure 4. Longitudinal dune (Frenchman Coulee Dunes, Grant County). Figure 5. Barchan dunes, a type of transverse dune (Sand Hollow North Dunes, Grant County). Figure 6. Parabolic dunes, aerial view (Moses Pothole North Dunes, Grant County). Figure 7. Climbing dune (Frenchman Coulee Dunes, Grant County). Figure 8. Open/Migrating dunes (Wahluke Dunes, Grant County). Figure 9. Anchored dune (Sand Hollow South Dunes, Grant County). Figure 10. Stabilized dunes (Juniper Dunes Wilderness, Franklin County). Figure 11. Fine scale vegetation mosaic (Hanford Black Sand Dunes, Grant County). Figure 12. Bugseed community type (Corispermum sp.) (Wanapum Dunes, Grant County). Figure 13. Russian thistle – Jim Hill mustard community type (Salsola kali-Sisymbrium altissimum) Sand Hollow South Dunes, Grant County). Figure 14. Veiny dock community type (Rumex venosus) (Beverly South Dunes, Grant County) Figure 15. Indian ricegrass – Lemon scurfpea association (Psoralidium lanceolatum – Achnatherum hymenoides) (Vantage Bridge Dunes, Grant County). Figure 16. Gray rabbitbrush – Green rabbitbrush – Snow buckwheat community type (Ericameria nauseosa – Chrysothamnus viscidiflorus – Eriogonum niveum) (Sentinel Butte Dunes, Grant County). Figure 17. Wyoming big sagebrush – Anelope bitterbrush community type (Artemisia tridentata ssp. wyomingensis – Purshia tridentata). Figure 18. Needle-and-threadgrass community type (Hesperostipa comata) (Frenchman Coulee Dunes, Grant County). Figure 19. Ponderosa pine/Antelope bitterbrush/Indian ricegrass association (Pinus ponderosa/Pushia tridentate/Achnatherum hymenoides) (Wakefield Dunes, Colville Fed. Tribes Land, Okanogan County). Figure 21. Dune stabilized by cheatgrass (foreground; Wahluke Dunes, Grant County). Figure 22. Dune fragmentation due to agricultural conversion and water inundation (Moses Lake Dunes near Potholes Reservoir, Grant County). Figure 23. Bare ground between plants on native anchored dune (Mattawa West Dune, Grant County). Figure 24. Invasive stabilized dunes (West Richland Dunes, Benton County). Figure 25. Agricultural conversion (Sand Hollow South Dunes, Grant County). Figure 26. Dune conversion to orchard. Drifting sand sign still remains (Mattawa West Dunes, Grant County). Figure 27. Irrigation run-off altering migrating dune front (aerial view) (Wanapum Dunes, Grant County).

Figure 28. ORV use (Moses East ORV Dunes, Grant County). Figure 29. Line of hay bales used to slow sand movement (Sand Hollow South Dunes, Grant County). Figure 30. Tree row to slow sand movement (Mattawa West Dune, Grant County).

List of Tables

Table 1. Rare plant species associated with Washington sand dune habitats...... 5 Table 2. Rare or declining animal species associated with Washington sand dune habitats ...... 5

I. Introduction

A. Goal

The goals of this Conservation Strategy are (1) to summarize existing and new information regarding the ecology of inland sand dune systems in Washington, including threats to this habitat and its associated species, and (2) to identify management strategies for the conservation of these systems. The majority of dune systems that once occurred in eastern Washington have been converted to agriculture, urban development and/or been inundated by water. The remaining sand dunes are vulnerable to conversion and/or stabilization by exotic annual species that alter the unique flora and fauna associated with this habitat. Additionally, damming of the Columbia River has ended the natural process of sand deposition that results in dune formation and perpetuation. If conservation actions are not taken, Washington’s inland dune ecological systems and their associated species may be lost in the foreseeable future.

B. Scope

The geographic scope of this strategy is dune systems in the Columbia Plateau Ecoregion of Washington State (Fig. 1). This strategy may have application to dune areas in other portions of the Columbia Plateau. This report addresses only eolian dunes, that is, sands worked by wind. Gravel bars and coarse alluvial sand deposits, such as those at Crescent Bar in Kitittas County, which superficially resemble eolian sand dune systems but function differently and support different plant associations and associated species, are not covered by this report. We are confident that all significant extant eolian sand dune systems, that is, individual or portions of historical dune fields, are captured in this report. Small isolated sand dunes, especially those that have been stabilized by vegetation, may have been missed by our methods.

Dune systems were located using geology maps (Schuster et al. 1997, Stoffel et al. 1991), Washington County Soil Survey Information (US Dept. of Agriculture Soil Conservation Service), USGS 7.5 minute topographic maps, Department of Natural Resources orthophotos, and personal observations. For ease of reference, each sand dune system was given a name (Fig. 2). Knowledge compiled from all of Washington’s inland sand dune systems is included in this report for comparison purposes and to present a range of conservation opportunities for dune habitats and associated species.

This strategy summarizes existing knowledge about sand dune systems in eastern Washington. Literature on the ecology of North American inland sand dunes is limited (Chadwick and Dalke 1965, Bowers 1982, Smith 1982) and often focused on specific areas such as the White Sands National Monument, New Mexico and Great Sand Dunes National Park, Colorado. Within Washington, the literature on inland dunes focuses primarily on the geomorphology and origin of individual dune systems (Gaylord and Stetler 1994, Gaylord et al. 1991, 1997, 1998, 2001, Petrone 1970, Bandfield et al. 2002) or mentions dunes as isolated features on the landscape (Washington County Soil Surveys). Daubenmire (1970) provides a brief, generalized overview of the ecology of

2 eastern Washington sand dunes. Much of the information included in this report has been generated by the Washington Department of Natural Resources’ Natural Heritage Program (WNHP) biologists and is unique to this report. To fully understand this system, additional floral and faunal surveys are necessary. Threats identified in this report are based upon the field observations of Natural Heritage field personnel. Additional threats may be identified with time and additional surveys. This report includes site-specific management recommendations, as well as statewide concerns. Uncertainty and inference are acknowledged where appropriate.

C. Management Status

The 2005 State of Washington Natural Heritage Plan identifies the Pacific Northwest Inland Sand Dune Ecological System as a Priority 1 feature for inclusion in the statewide system of natural areas (http://www.dnr.wa.gov/nhp/refdesk/plan/index.html). Nine plant and four animal species that are dune associated are listed as priority species (Tables 1 & 2). The Washington Department of Fish and Wildlife (WDFW) has also expressed interest in designating inland sand dunes as a Priority Habitat.

Tables 1 and 2 identify the federal status, global and state rank, Natural Heritage Plan priority, and state status for each of the species of concern. The tables also indicate whether each is a sand dune or sandy soil obligate or facultative species. Of the plant and animal species included in Tables 1 and 2, note that one plant species (Northern wormwood) and one animal species (Washington ground squirrel) are candidates for listing under the federal Endangered Species Act. Two animal species have been identified by the USFWS as species of concern. Six animal species associated with dune habitats have been listed as Washington Candidate species (2006 listing) because of rarity or declining populations.

It is also important to note that new discoveries continue to take place in these habitats. species, new to science, continue to be described from the Hanford Central and Wahluke dune systems (Soll 1999, Zack et al. 2003).

There are also two plant associations recognized in the International Vegetation Classification (IVC) that are of conservation concern within Washington’s inland sand dune systems. The Ponderosa pine/antelope bitterbrush/Indian rice grass (Pinus ponderosa / Purshia tridenata / Achnatherum hymenoides) association, ranked as critically imperiled globally (G1), is found in a single location in Washington. The sand lyme-grass association (Leymus flavescens), ranked as globally imperiled (G2), is tentatively recognized in Washington at the Hanford Central Dunes and perhaps at Juniper Dunes.

3

Table 1. Rare plant species associated with Washington sand dune habitats.

NH Plan Federal Active sand Plant Species Common Name NH Rank Priority State Status Sandy soil Status dunes (2005) Artemisia borealis var. Northern wormwood Candidate G5T1S1 1 Endangered Facultative Facultative wormskioldii

Astragalus geyeri Geyer's milk-vetch G4S1 2 Threatened Obligate Obligate

Astragalus kentrophyta Species of Possibly Possibly Thistle milk-vetch G5TXSX Facultative Obligate var. douglasii Concern extirpated extirpated

Calyptridium roseum Rosy pussypaws G5S1 2 Threatened Obligate

Naked-stemmed evening Camissonia scapoidea G5S1 3 Sensitive Obligate? primrose Possibly Possibly Corispermum pallidum Pale bugseed GHSH Facultative Obligate extirpated extirpated

Cryptantha leucophaea Gray cryptantha G2G3S2S3 3 Sensitive Obligate Obligate

Possibly Possibly Eriogonum maculatum Spotted buckwheat G5SX Facultative extirpated extirpated Gilia leptomeria Great Basin gilia G5S1 2 Threatened Facultative (=Aliciella leptmeria) Loeflingia squarrosa var. Loeflingia G5T4? 2 Threatened Facultative squarrosa

Mimulus suksdorfii Suksdorf's monkey flower G4S2 3 Sensitive Facultative

Nicotiana attenuata Coyote tobacco G4S2 3 Sensitive Obligate

Table 2. Rare or declining animal species associated with Washington sand dune habitats.

NH Plan Federal Sandy Animal Species Common Name NH Rank Priority State Status Status habitat use (2005) Cicindela columbica Columbia River Tiger Beetle G2SH Candidate Obligate Bufo woodhousii Woodhouse's Toad G5S3 3 Monitor Facultative Sand dune Sceloporus graciosus Sagebrush Lizard SC G5S3 3 Candidate obligate Dipodomys ordii Ord's Kangaroo Rat G5S4 Monitor Obligate Lemmiscus curtatus Sagebrush Vole G5S3 3 Monitor Facultative Onychomys leucogaster Grasshopper Mouse G5S3 Monitor Obligate Spermophilus townsendi Townsend's Ground Squirrel SC G4S3 Candidate Facultative townsendi Spermophilus washingtoni Washington Ground Squirrel C G2S2 1 Candidate Facultative Lepus californicus Black-tailed Jackrabbit G5S2S3 Candidate Facultative Lepus townsendii White-tailed Jackrabbit G5S2S3 Candidate Facultative

5 II. Classification and Description A. Sand dune geomorphology and origin Formation of sand dunes requires a supply of well-sorted fine or medium grained (0.125- 0.5 mm) sand and wind (eolian) transport. The wind moves the sand grains by saltation (bouncing) along the surface. Sand accumulates when wind passes from a rough surface to a smooth one (e.g., sand patch), flows over a depression and/or encounters a permeable obstacle such as a shrub. Dunes accumulate (accrete) sand during strong winds and lose sand during gentle winds until they reach a critical size. Once this size is attained, sand is trapped under all wind conditions due to aerodynamic factors that result in sand being dropped at the leeward margin of the dune instead of being carried off the dune (Smith 1982).

Sand dunes in sub-arid to semi-arid regions support vegetation if wind stress is not too great. The vegetation cover is related to the amount of annual rainfall and rate of evapo- transpiration. The amount of vegetation cover responds dramatically to climate related changes (Gaylord and Stetler 1994, Helm 2003). The mobility of sand dunes is related to the power of the wind and inversely related to the amount of vegetation cover (Hacks 1941). Long periods of increased precipitation and persistent presence of vegetation may lead to covering of the sand surface with litter and/or microphytic crust, soil formation and partial to complete stabilization of the dunes. In contrast, periods of drought will result in conditions unfavorable to vegetation and can reinitiate the mobility of the sands (Lancaster 1988).

Four simple dune types have been observed in Washington. The following descriptions are from Smith (1982) using Hacks’ (1941) scheme that defines dune-form as a function of three variables: wind, sand supply and vegetation. Dune terminology is presented in Figure 3. Longitudinal dunes form when there is a small to moderate supply of sand, much wind and little vegetation (Fig. 4). These dunes are long in proportion to width and symmetrical in cross section. Transverse dunes form when there is a copious sand supply, little to moderate wind and little vegetation. Barchans are a subset of this dune type limited to areas with hard surfaces and limited sand supply (Fig. 5). Parabolic or U- shaped dunes form when there is a moderate supply of sand, wind and vegetation (Fig. 6). These dunes are “U” shaped with arms that trail the dune. Vegetation encroaches on the arms and is essential for their development. The deflation plane is more slowly colonized by plants. The slip face remains free to advance. Climbing dunes climb the windward side of hills as sand sheets (Fig. 7). Dune systems are described as “complex” if they have more than one type of simple dune present in the system.

Inland sand dune systems contain three different functional stages: 1) open/migrating, 2) anchored, and 3) stabilized. These stages differ primarily in the amount of sand movement on the dune surface and movement of the dune itself. The open/migrating stage has large areas of open active surface sand and the dune migrates with the effective wind direction (Fig.8). Unstable slip faces (lee slopes) often form. Vegetation cover is minimal. Anchored dunes have active sands present on the dune surface, but movement / migration of the dune as a whole is inhibited by vegetation (Fig. 9). This stage often

6 occurs on the trailing arms of migrating parabolic dunes and on vegetated sand sheets. Stabilized dunes lack active sands. The dune surface is sealed with vegetation, cryptobiotic crusts, or volcanic ash (Fig. 10). The anchored and stabilized stages are considered either “native” or “exotic” based on the dominant (>50% of relative cover) vegetation.

Figure 3. Sand dune terminology

Effective wind direction

Crest

Slipface Stoss (windward) slope

Leeward slope Deflation plane

Direction of dune migration

Published research on the origins of Washington’s inland sand dunes addresses the geomorphic development of the Hanford Site sand dunes (Gaylord et al. 1991, Gaylord and Stetler 1994), Smith Canyon dune field (Gaylord et al. 2001), Juniper Dunes (Gaylord et al. 1997, 1998) and the Moses Lake dune field (Petrone 1970, Bandfield et al. 2002). These extensive sand dune systems formed from alluvial sediments derived from the Missoula floods. Extensive reworking of these deposits by wind produced widespread Holocene (and possibly late Pleistocene) eolian deposits (Gaylord and Stetler 1994, Gaylord et al. 2001, Banfield et al. 2002, Dalman et al. 2005). Alluvial sources may have provided a minor contribution to the Hanford dunes (Gaylord et al. 1991). Other extensive sand deposits, such as those found west of Walla Walla, are most likely also glacial outburst flood-derived sands (Gaylord et al. 2001). Dune field activity and migration was slowed in the Columbia Basin approximately 3,900 years ago when cooler, moister conditions resulted in expansion of basin vegetation (Gaylord et al. 2001). Prior to the damming of the Columbia and Snake rivers, sand was transported and deposited annually by the rivers to form sand bars. Dune fields occurring along both rivers were later fed by deflation of these fluvial sand deposits.

In recent times, changes in the volume of non-vegetated dune sands are related to natural and anthropogenic influences. Gaylord and Stetler (1994) found a well-defined eolian-

7 climatic relationship for non-vegetated sand volume vs. precipitation, wind speed, and temperature at the Hanford Site. Non-vegetated dune volumes decreased in the years 1948-1964 and 1978-1987 and increased during 1965-1977 (Gaylord and Stetler 1994). Change in non-vegetated dune volume also occurs due to other variables that influence the surface, such as livestock grazing or anthropogenic impacts such as off-road vehicle use.

B. International Ecological Systems Classification (IESC) A terrestrial ecological system is a group of plant communities (associations) that tend to co-occur within landscapes with similar ecological processes, substrates, and/or environmental gradients (Comer 2003). Washington inland sand dunes are classified as the Inter-Mountain Basins Active and Stabilized Dune ecological system in the IESC (NatureServe 2006). This dune ecological system, however, is described primarily from studies in Idaho, Montana, Wyoming and Colorado and does not fully represent the vegetation variation found in Washington inland sand dunes. The contents of this report will be submitted to NatureServe and used to update the classification and description of the Inter-Mountain Basins Active and Stabilized Dune ecological system and the component plant associations (Appendix VI). In this document, the ecological system is the basis for mapping and conservation assessment.

C. Plant Communities Based on a classification of variable-sized reconnaissance plots (n = 294) from twenty- eight inland Washington dune fields, we have described seven distinct plant community types (Appendix III). These types represent potential changes to the International Vegetation Classification (IVC) of Washington inland sand dune plant communities (NatureServe 2006, Grossman et al. 1998). Because this is not a full, floristic classification strictly following IVC guidelines, however, our community types are not necessarily association-level groupings. Vascular plant names used in naming and describing ecological communities generally follow Kartez (1999). Appendix (VII) lists plants used in the text and encountered during dune assessment.

8 III. Ecology

A. Range and Distribution of Washington State Inland Sand Dunes Dune systems are currently found in 13 counties across eastern Washington with a total extent of 106,953 acres (Fig. 1). A majority of systems are either wholly or partially on federally owned lands. Hanford Central Dunes (35,504 acres) in Benton County, Juniper Dunes (15,029 acres) in Franklin County, Saddle Mountain Lake Dunes (5,993 acres) in Grant Count and Moses Potholes North Dunes (5,932 acres) in Grant County are currently the largest extant systems in Washington.

B. Plant Community Type Summaries Sand dunes are by nature highly dynamic systems and patterns of plant species composition are closely related to the processes of sand erosion, deposition and dune migration and stabilization (Chadwick and Dalke 1965). These processes may occur rapidly, leaving legacies from previous vegetation types. While repeating patterns of vegetation are observed and allow the identification of community types, they are often present in a spatially complex, fine-scale mosaic (Fig. 11). The boundaries between community types range from distinct to highly blurred (Easterly and Salstrom 1997). Our community types are, however, closely related to the successional processes of dune vegetation and stabilization and often have strong affinities to particular positions within a dune system.

Earlier descriptions of vegetation on Washington inland sand dunes contain several discrepancies with our community types. Both Daubenmire (1970) and the description for the IVC Antelope bitterbrush / Indian ricegrass association (NatureServe 2006) note the presence and importance of sand lyme-grass (Leymus flavescens) in Washington, similar to the St. Anthony dunes in Idaho (Chadwick and Dalke 1965). However, during our field surveys sand lyme-grass was found only on the dunes of the central Hanford Site and reported at Juniper Dunes. This is tentatively recognized as the sand lyme-grass association, CEGL001563.

Harris (1954) surveyed dune environments stabilized by water in the Moses Lake pothole region noting willow (Salix sp.) along the crests and wetland species in the inter-dunes. These dunes were considered converted and, therefore, not included in our surveys.

Several dune systems across inland Washington had unique species compositions that were not captured by our community types. The Beverly Dunes along Crab Creek have overridden salt flats, introducing typically non-dune vegetation, such as black greasewood (Sarcobatus vermiculatus), into the dune field. As described by Daubenmire (1970), open savannas of western juniper (Juniperus occidentalis) with abundant curly bluegrass (Poa secunda) characterize stabilized sections of Juniper Dunes in Franklin County. Delight Dunes in Adams County, contained multiple woody tree and shrub species not found on dunes elsewhere in Washington, including black cottonwood (Populus balsamifera ssp. trichocarpa), common chokecherry (Prunus virginiana), kinnikinnick (Arctostaphylos uva-ursi), and western serviceberry (Amelanchier alnifolia).

9 Other vegetation anomalies at Delight Dunes included the presence of common scouring rush (Equisetum hymenale) on open, active stoss slopes and of Idaho fescue (Festuca idahoensis) on stabilized dunes.

Bugseed community type Corispermum sp. community type

This community type (n = 7) was represented on the sparsely vegetated stoss slopes of active dunes. The native, annual Bugseed was the only species present in these locations and with minimal cover (avg. ~ 6%). Our field sampling found Bugseed only on dunes in the Wahluke Unit of the Hanford Reach National Monument and above the Wanapum Dam along the Columbia River. However, because of the delayed phenology of Bugseed, its presence in other locations may not have been recorded (Fig. 12). Delayed phenology also limited consistent identification in the field, C. villosum is the most likely species.

Russian thistle – Jim Hill mustard community type Salsola kali – Sisymbrium altissimum community type

Most common on the dunes of western Grant County, this community type (n = 25) was found on smaller dunes (< 1.5m height) in the process of being stabilized by exotic species. Exotic species dominated with an average exotic species cover of ~ 47%. Along with Russian thistle (Salsola kali misapplied Salsola tragus) and Jim Hill mustard, other common species included tarweed fiddleneck (Amsinkia lycopsoides) and the exotics cheatgrass (Bromus tectorum), and common ragweed (Ambrosia artemisiifolia). Native Indian ricegrass (Achnatherum hymenoides) was occasionally present. The dominant exotic species are commonly found across the Columbia Plateau and are not limited to dune sand substrates. Often, this community type appeared related to the introduction of water into dune systems from adjacent irrigation systems. While native species appear to be excluded by Russian thistle and Jim Hill mustard, both are annual species and the amount of inter-annual variation in their abundance on active dunes is not known (Fig. 13).

Veiny dock community type Rumex venosus community type

Located primarily on the lee slopes and crests of larger active dunes, this community type (n = 22) is typified by the dominance of the native perennial veiny dock. Total vegetation cover averaged ~ 35%, typically with very few exotic species. On dune crests lemon scurfpea (Psoralidium lanceolatum) was common and Indian ricegrass was occasionally present along with veiny dock. While this type is found across the range of Washington inland dunes, it is limited to systems with active sand erosion and deposition. Harris (1954) and Daubenmire (1970) both noted the abundance of veiny dock on the slip faces of active dunes. Although veiny dock forms extensive clones, its lack of permanent above ground structure suggests only a minor impact on dune stabilization (Fig. 14).

10 Indian ricegrass - Lemon scurfpea association Achnatherum hymenoides - Psoralidium lanceolatum

This community type (n = 44) was commonly found on both the crests and the actively eroding upper and lower stoss slopes of dunes across inland Washington. Lemon scurfpea - Indian ricegrass commonly represents the initial colonization and anchoring of open, migrating dunes by perennial native species (Fig. 15). Similar to the veiny dock type, total vegetation cover averages ~ 35% with very few exotic species. Lemon scurfpea - Indian ricegrass is distinguished by the absence of both veiny dock and of woody shrub species. Although with low cover, thick-spiked wheatgrass (Elymus lanceolatus) and cheatgrass were also commonly present. Whiteleaf phacelia (Phacelia hastata) was occasionally found and may represent a transition to the Grey rabbitbrush – Green rabbitbrush – Snow buckwheat (Ericameria nauseosa – Chrysothamnus viscidiflorus – Eriogonum niveum) type. A Lemon scurfpea - Indian ricegrass type was recognized in Washington State by Johnsgard (1956). This type is likely the same as the Indian ricegrass-Lemon scurfpea association (CEGL001650) as listed in NatureServe (2006) in Idaho, Utah, Wyoming and Colorado.

Grey rabbitbrush – Green rabbitbrush – Snow buckwheat community type Ericameria nauseosa – Chrysothamnus viscidiflorus – Eriogonum niveum community type

Grey rabbitbrush, green rabbitbrush, and snow buckwheat, the first woody shrub species to establish following dune anchoring by herbaceous species define this community type (n = 109). Widely distributed across Washington inland dune fields, this type was commonly found on both anchored and stabilized sand plains, inner-dune areas and around blowouts. Grey rabbitbrush was the most common shrub species, while green rabbitbrush and snow buckwheat were occasionally found independent of grey rabbitbrush. With increased sand stabilization total vegetation cover averaged ~ 61% in contrast to herbaceous-dominated community types. The average cover of exotic species (~ 28%) also increased, primarily cheatgrass. Indian ricegrass, lemon scurfpea and thick- spiked wheatgrass were common but had reduced cover beneath the shrubs. Overall species diversity was increased with species such as pale evening-primrose (Oenothera pallida), sand-dune penstemon (Penstemon acuminatus), whiteleaf phacelia, Carey's balsamroot (Balsamorhiza careyana), turpentine wavewing (Pteryxia terebinthina), Columbia cut-leaf (Hymenopappus filifolius), thread-leaf fleabane (Erigeron filifolius) and prairie junegrass (Koeleria macrantha). This type was described but not identified by Easterly and Salstrom (1997) and is similar to the Cheatgrass – Green rabbitbrush zone of Johnsgard (1956) (Fig. 16).

Wyoming big sagebrush – Antelope bitterbrush community type Artemisia tridentata ssp. wyomingensis - Purshia tridentata community type

Establishment of the Wyoming big sagebrush – antelope bitterbrush community type (n = 59) represents a late stage in the process of dune stabilization across Washington State inland sand dunes (Fig. 17). Wyoming big sagebrush – antelope bitterbrush was typically

11 found on sand plains trailing behind active dunes, on stabilized sand sheets and in stable inner-dune areas. However, in fully stabilized dune fields, this community type was often widely distributed, irrespective of location within the dune field. As a broad, alliance level grouping, diversity of both shrub and herbaceous species varied considerably. Throughout the range of this community type, green rabbitbrush was common while other shrubs such as grey rabbitbrush,snow buckwheat, grey ball sage (Salvia dorrii), and spiny hopsage (Grayia spinosa) were occasionally present. Total vegetation cover was the highest of all dune community types (avg. ~ 67%). Along with Indian ricegrass, curly bluegrass was common in the understory. While many of the other native herbaceous species frequent in the grey rabbitbrush – green rabbitbrush – snow buckwheat type were occasionally present, overall species diversity was often limited and cover of exotic cheatgrass was very high. Moving away from active dune systems, the Wyoming big sagebrush – antelope bitterbrush type often grades to very low diversity communities dominated by Wyoming big sagebrush / cheatgrass.

Needle-and-threadgrass community type Hesperostipa comata community type

The needle-and-threadgrass community type (n = 8) was infrequently found on sand plains trailing behind active dunes and in stable inner-dune areas. This community type may represent a transition away from dune sand substrates towards the surrounding underlying soils. Although intermixed with the Wyoming big sagebrush – antelope bitterbrush type, shrub cover was minimal and total vegetation cover (avg. ~ 50%) was dominated by needle-and-threadgrass. Cheatgrass was occasionally present, but overall exotic cover was very low. Together, the Wyoming big sagebrush – antelope bitterbrush and needle-and-threadgrass community types are superficially similar to Daubenmire’s (1970) and NatureServe (2006) Wyoming big sagebrush / needle-and-threadgrass and antelope bitterbrush / needle-and-threadgrass associations. Within Washington inland dune systems, however, needle-and-threadgrass is rarely the dominant understory species beneath Wyoming big sagebrush or antelope bitterbrush, differentiating the Wyoming big sagebrush – antelope bitterbrush community type and needle-and-threadgrass community types (Fig. 18).

Ponderosa pine/Antelope bitterbrush/Indian rice grass association (CEGL000196) Pinus ponderosa / Purshia tridentata / Achnatherum hymenoides association

This IVC association was not included in our reconnaissance plots but has been identified on a single dune system in Okanogan County on the Colville Indian Reservation (Wakefield Dunes). First described by Clausnitzer and Zamora (1987), this type is characterized by a tree cover of ponderosa pine and a low diversity understory dominated by antelope bitterbrush with sparse Indian ricegrass. The site’s current condition was verified by observation from the highway. Known only from two other sites, one in Oregon and one in California, this association has a global rarity rank of G1 – critically imperiled (Fig. 19).

12 Sand lyme-grass association (CEGL001536) Leymus flavescens association

This IVC association was not included in our reconnaissance plots but has been tentatively identified at Hanford Central Dunes based on the presence of sand lyme-grass. It may occur at Juniper Dunes as well. According to NatureServe (2007), this is a pioneer plant association occurring on all but the most actively eroding or depositing areas of slowly moving sand dunes. Sand lyme-grass and Indian ricegrass are the principle pioneer species on these dunes. It is documented only from Idaho on the St. Anthony Sand Dunes RNA and reported in the Columbia Basin of Oregon and Washington. More intensive evalulation is needed to verify this occurrence.

C. Rare and declining plant and animal species

Species associated with these systems are adapted to deal with shifting sand, extreme temperature changes and low moisture content. The rare plant and animal species addressed here are primarily associated with the anchored and semi-stabilized habitats of the sand dune system. Many of the rare plant species require some active surface sand. They do not, however, have the special modifications necessary to withstand winds and shifting sands that blow away seeds, bury seedlings and abrade plants; traits necessary to colonize the bare eroded portions of dunes. Pale bugseed (Corispermum pallidum) may be an exception. For most animals, the bare or eroded portions of sand dunes provide little forage or shelter. These areas, however, do appear to provide habitat to some insect species. Unidentified insects and beetle tracks, as well as the dune-obligate tenebrionid beetle, Eusattus muricatus, were commonly observed in this habitat type (Hallock, pers. ob.).

Plants - Twelve rare plant species are associated with the active sands or sandy soils of Washington’s inland sand dunes. Status information is listed in the Management Status section. The information that follows is from the Field Guide to Washington’s Rare Plants (http://www.dnr.wa.gov/nhp/refdesk/fguide/htm/fgmain.htm) and WNHP database information.

Northern wormwood (Artemisia borealis var. wormskioldii) – This species is known from the sand dune field near Beverly and the Miller Island Dunes where plants occur at the river-sand dune interface. Both occurrences are on federal lands. Whether or not the species is actually dependant on sandy soils or persists in the presence of sand is unknown. Conservation of the species, however, depends on protection of the sandy habitats. Soil compaction and direct damage from recreational vehicle use and weed invasions have been identified as threats to this species. Additional inventory is recommended for the area between the John Day and Priest Rapids dams and between Rock Island and Wanapum dams.

Geyer's milk-vetch (Astragalus geyeri) – This species is disjunct in Washington, occurring only in Grant County. It occurs in the depressions of mobile or stabilized dunes, sandy flats, and valley floors. It can persist with a high cover of annual weedy

13 plants like cheatgrass, Russian thistle and Jim Hill mustard. It occurs on BLM’s Sentinal Butte Dunes in the Beverly area and the Wahluke Dunes on the USFWS Hanford Monument. Threats include agricultural conversion, damage from recreational vehicles and grazing. Recommended inventory includes systematic surveys of all suitable habitats throughout the Columbia Basin.

Thistle milk-vetch (Astragalus kentrophyta var. douglasii) – This species has not been documented in Washington since 1883 and may be extirpated. Barneby (1964) lists the historical locations as being within or near the Great Bend of the Columbia River, southeastern Washington or perhaps adjoining Oregon. He suggested that this species occurred on sandy ground, on dunes or on eroded riverbanks at low elevations. The WNHP recommends an intensive search for this species to verify its status.

Rosy pussypaws (Calyptridium roseum) – Recent Washington occurrences are known only from sand dunes (Hanford Black Sand Dunes) in the central portion of the Hanford Site, Benton County. These two occurrences are disjunct from the rest of the species’ range in Oregon and California. The occurrences were found in low swales in sandy soils that support sagebrush at elevations from 520 to 530 ft. (158 to 161 m). Additional inventory of sandy sites in Benton County is recommended by the WNHP.

Naked-stemmed evening primrose (Camissonia scapoidea) – Only two occurrences have been documented in Washington. Both occurrences are on sandy, gravelly sites near the Wanapum Dam on the Yakima Training Center, Kittitas County. The known occurrences are not associated with active sand dunes but do occur on unstable sandy substrates. This suggests that sand dunes may provide appropriate habitat. Additional inventory is needed to determine the full extent of this species in Washington and the significance of sand dune habitat for the species.

Pale bugseed (Corispermum pallidum) – This species is endemic to Washington’s Grant and Douglas counties. It is known from four historical occurrences documented from 1893 to 1963. No extant populations are known. Historical occurrences were described as coming from sandy sagebrush plains in drifting sand and dry sand at elevations of 948- 1312 ft. (300-400 m). The WNHP initiated surveys for this species in 2005 without success. Additional surveys are necessary to confirm the status.

Gray cryptantha (Cryptantha leucophaea) – This species is a regional endemic, known from the Columbia and lower Yakima rivers in the western Columbia Basin, and from Wenatchee, Washington to The Dalles, Oregon. Gray cryptantha occurs on sandy substrate along the Columbia River within the Columbia Basin physiographic province. It occurs on the stabilized portions of sand dunes but requires bare ground and surface active sands. Twenty occurrences are documented on dunes in Grant, Benton, Franklin, Kittitas and Klickitat counties. The majority of occurrences are on federal lands. Additional surveys are required to determine the complete distribution of this species.

14 Spotted buckwheat (Eriogonum maculatum) – This species occurs in sandy to heavy soils. In Washington, it is known only from an 1884 occurrence in Yakima County. The species was not detected during a survey in the historical vicinity in 1981.

Great Basin gilia (Gilia leptomeria) – The Washington occurrences in Grant, Benton and Franklin counties are disjunct by hundreds of miles from the rest of the species’ range. It occurs on gravelly bluffs, sandy swales and on caliche at elevations 143 – 347 m (470- 1140 ft.). The species depends on the extreme dryness of these sites and the lack of competition from other species. Only six recent occurrences are known in Washington. Three of these are associated with sand dunes on the Hanford Site: one in the Vernita Bridge area and the others on the dunes at the Wahluke Unit above the Columbia River (Vernita Bridge Dunes and exotic stabilized portions of the historical Wahluke Dunes). Threats to this species include ground disturbing activities and competition from weedy species. More surveys are needed for this species in Grant, Benton and Franklin counties, as well as the surrounding counties where appropriate habitat occurs.

Loeflingia (Loeflingia squarrosa var. squarrosa) -The Washington population is disjunct from the nearest known sites in California by 800 miles. In Washington, known occurrences are limited to a small geographic area in northern Benton County. These occurrences are in low swales within sandy areas. The elevation of the populations in Washington is between 122 and 152 m (400 and 500 ft.). One of the four Washington element occurrences is associated with the sand dunes located north of Gable Mountain (Hanford Black Sand Dunes).

Suksdorf's monkey-flower (Mimulus suksdorfii) – Washington is on the periphery of the species’ range where few extant occurrences are known. The species has been collected and/or observed in Benton, Chelan, Grant, Kittitas, Klickitat, and Yakima counties. Some level of substrate disturbance appears to be necessary for this species. It occurs on the Hanford Black Sand Dune north of Gable Mountain. The primary threat is ground disturbances that result in exotic species invasions.

Coyote tobacco (Nicotiana attenuata) – In Washington, Coyote tobacco has a scattered distribution, with recent occurrences known from Douglas, Grant, Kittitas, Klickitat, and Yakima counties. Historical sites are known from Chelan and Franklin counties. It occurs in dry, sandy bottom lands, dry rocky washes, and in other dry open places that are prone to periodic natural disturbances. Elevation ranges from 122 to 3048 m (400 to 10,000 ft). None of the known recent occurrences are on sand dunes. Historical occurrences appear to have been associated with the sand dunes in the Dallesport area, Klickitat County; sand dunes northeast of the confluence of the Snake and Columbia rivers; on the historical sand dunes of the Satus-Mabton area, Yakima County; and on sand dunes in the Vantage area, Kittitas and Grant counties. The WNHP recommends a systematic inventory for this species throughout eastern Washington. Threats to this species include all ground disturbing activities, herbicide spraying (for occurrences near roads), and invasion of exotic species into the habitat.

Vertebrate species – The following nine vertebrate species are rare or declining in Washington primarily due to habitat loss and alteration. Three species are sandy soil

15 obligates: Sagebrush Lizards occur almost exclusively on or in the vicinity of sand dunes. The remaining species utilize sand dune habitat (facultative users) in parts of their ranges. Status information is listed in the Management Status section.

Woodhouse’s Toad (Bufo woodhousii) – The Washington distribution is limited to the Snake and Columbia rivers (Hallock and McAllister 2005). Distribution on the Columbia River is from the Hanford Site near Vernita Bridge to the John Day Dam (Hallock and McAllister 2005). The significance of sand dune habitat for Woodhouse’s Toads in Washington has not been examined. They are documented to occur in the Juniper, Walla Walla Flats, Patterson Slough and Saddle Mountain Lake sand dunes (Hallock, unpubl. data, WDFW herp database). The toads are present in areas where annual grasses have stabilized the sand (ex. Patterson Slough) (Hallock pers. ob.). Breeding site conditions also play a significant role in determining distribution.

Sagebrush Lizard (Sceloporus graciosus) – In Washington, this species occurs in the Columbia Plateau Ecoregion. Occurrences are patchy. A study in Oregon found Sagebrush Lizards limited to habitats that had sandy soils (Green 2001). Recent surveys (1995-2004) in Washington found Sagebrush Lizards associated with sand dune habitats (Hallock, unpubl. data). They are documented on 26 of the historical sand dune systems mapped from 1970s orthophotos including the largest systems (Hallock, unpubl. data, WDFW herp database). Anecdotal observations suggest that the lizards may decline or be extirpated in sand dune habitats where invasive annual grasses dominate the ground cover (Hallock, pers. ob.).

Ord’s Kangaroo Rat (Dipodomys ordii) – The species is limited to the central Columbia Basin where it occurs in Walla Walla, Frankin, Benton (Johnson and Cassidy 1997) and lower Grant County (Gitzen et al. 2001). The species is expanding its range northward in Washington (Johnson and Cassidy 1997, Gitzen et al. 2001). They are restricted to loose, sandy soils in habitats with sparsely vegetated ground (Dalquest 1948). This species has been trapped in habitats where cheatgrass (Bromus tectorum) dominates the ground vegetation. The burrows at these sites, however, are restricted to sandy eroded road cuts (Verts and Carraway 1998). Research is underway at University of Calgary (by D. Bender and D. Gummer) to determine if living in roadsides makes the kangaroo rats more vulnerable to predators and parasites than those living in undisturbed habitats. Ord’s Kangaroo Rats occur in five of the historical sand dune systems: Juniper, Page, Walla Walla Flats, Beverly and Wanapum (WDFW Heritage database).

Sagebrush Vole (Lemmiscus curtatus) – This species occurs in scattered, short sagebrush (Artemisia spp.) with sparsely grassed understory on dry, loose soils (Dalquest 1948, Johnson and Cassidy 1997). It has been trapped in the Juniper and Hanford Central sand dunes (WDFW Heritage database).

Grasshopper Mouse (Onychomys leucogaster) – This species prefers open areas of sand and avoids heavy cover (Dalquest 1948, Verts and Carraway 1998). It has been documented in five of the historical sand dune systems: Juniper, Walla Walla Flats, Wahluke, Hanford Central and Moses Lake. Older museum records have low precision

16 making it more difficult to associate some of the records with specific dunes. These records are from the Wanapum, Paterson Slough and Yakima dune (= Satus-Mabton area) areas (WDFW Heritage database).

Townsend’s Ground Squirrel (Spermophilus townsendi townsendi) – This species occurs on the Hanford Central dune. The rest of the occurrences are not associated with sand dunes (WDFW Heritage database).

Washington Ground Squirrel (Spermophilus washingtoni) – This species occupies a variety of shrub-steppe habitats including sandy places (Dalquest 1948). It occurs on the Juniper and Page sand dunes (WDFW Heritage database).

Black-tailed Jackrabbit (Lepus californicus) – This species occupies a variety of shrub- steppe habitats (Johnson and Cassidy 1997). It has been observed on the Juniper, Wanapum, Hanford Central, Crow Butte, Sand Spring, Moses Lake, West Richland 36 and Mattawa West dunes (WDFW Heritage Database).

White-tailed Jackrabbit (Lepus townsendii) – This species occupies a variety of shrub- steppe habitats (Johnson and Cassidy 1997). It has been observed in the Juniper Dunes system (WDFW Heritage database).

Insects – surveys conducted on the Hanford Central and Wahluke dunes in the last decade have found invertebrate fauna distinct from other areas of the Hanford Site and likely many of the dune taxa are limited outside the Hanford Site (Zack et al. 2003). At least four species new to science have been discovered. Further inventory of the dune habitats on the Hanford Site is recommended, as are surveys of other sand dune systems (R. Zack, pers. comm.). Entomological surveys of sand dunes in other states have found unique, often endemic groups of beetles (Coleoptera), true bugs (Hemiptera), and grasshoppers and crickets (Orthoptera) (Rust 1986).

Moths and Butterflies - Order Four new species of were discovered on Hanford Central and Wahluke dunes including species of Arenoscythris (Scythrididae) and Copablepharon () (Zack et al 2003). Wahluke and Hanford Central dunes each had a unique species of Arenoscythris. These species fly only a few inches over the substrate. The fact that distinct species were found on each dune suggests that ecological separation of these dunes may have been for an extended period of time (Zack et al. 2003). The noctuid , Protogygia comstocki (Noctuidae), was collected for the first time in Washington since the 1950s at the Wahluke dune. This may represent one of the few remaining populations in Washington (Zack et al. 2003). Other species of interest may be found with additional survey work (Zack et al. 2003).

Beetles - Order Coleoptera Columbia River Tiger Beetle (Cicindela columbica) – The historical range of this species includes Idaho, Washington and Oregon. Extant occurrences are known only from Idaho. In Washington, the species occurred on sandbars and dunes along the banks of the

17 Columbia River (Freitag 1999). Surveys in 1995 along the Columbia and Snake rivers failed to detect this species (Bartels 1995). Habitat loss in many areas resulted from dam construction. Systematic surveys in all suitable habitats on the Columbia and Snake rivers is needed to determine if any populations persist in Washington.

Bees, Wasps and Ants - Order Hymenoptera Perdita similis pascoensis is a rare Columbia Basin endemic bee collected once in 1904 at Pasco, Washington, Franklin County (Tepedino and Griswold 1995). The habitat type was Pinyon-Juniper Woodland. The only remaining Juniper woodland on sand in Washington is on Juniper Dunes. Other juniper stands are located in Klicktat County. Tepedino and Griswold (1995) recommend that this species should be a very high research priority.

Columbia Basin sand dunes have a rich and distinctive bee fauna (Tepedino and Griswold 1995). Tepedino and Griswold (1995) recommend that this habitat be given priority for surveys because they are areas of species richness with high degrees of endemism and because significant threats from recreational vehicle use reduce floral resources and destroy nest sites. The sand dunes serve as pollinator reservoirs important for floral maintenance on adjacent lands (Tepedino and Griswold 1995).

Bees collected at the Hanford Site in 2002-2003 are still being processed (Zack et al. 2003). New records and rare species are expected (Pabst 1994). The fact that wild bees are the most common Hymenopterans at the site was significant in comparison to most areas where the introduced honeybee is most common (Zack et al. 2003).

D. Trends

The total extent of inland sand dune systems has declined from approximately 448,177 acres in the early 1970s to 106,953 ac by 2006, a loss of 76% (Appendix II). Dune systems wholly or partially on federal lands experienced a similar degree of loss, decreasing 78% from an historical extent of 422,217 total acres to a current extent of 93,589 acres (Fig. 20).

Historically, the largest individual systems included the Hanford Central Dunes (94,011 ac) in Benton County, the Juniper Dunes (95,681 ac) in Franklin County and the Moses Lake Dunes (128,116 ac) in Grant county. Significant dune systems or concentrations of smaller systems were also located in Walla Walla County (39,261 ac), northwestern Franklin County (46,796 ac), southeastern Grant County (18,914 ac) and southern Benton County (5,811 ac).

Approximately 35% of the loss detected in 2006 was due to stabilization by exotic species (Fig. 21); the rest was primarily due to agricultural conversion, development, and flooding behind reservoirs (Fig. 22). Prior to this project’s “historical” baseline of the early 1970s dune stabilization was an objective of land managers, however, the extent of these efforts is not known.

18

While the Central Hanford Dunes (38% loss), Juniper Dunes (84% loss) and Moses Lake Dunes (79% loss) all experienced significant declines, they still represent the largest inland dune systems in eastern Washington. Large portions of the historical Moses Lake dune field have been flooded behind O’Sullivan Dam in Grant County. Hanford Central is the only remaining system that has not been fragmented by agricultural conversion, urban development or water inundation although it is increasingly becoming isolated by those same factors.

Within individual dune systems, there is a trend toward an overall decrease in the amount of active dune area and number of active dunes. The result is an abundance of the Grey rabbitbrush – Green rabbitbrush – Snow buckwheat and the Wyoming big sagebrush – Antelope bitterbrush community types with understories increasingly dominated by cheatgrass (Bromus tectorum). Few, diverse, “late successional” dune communities were observed with native bunchgrasses. In addition to inundation, water from adjacent irrigation is also increasing damage to dune systems. Raised water tables allows invasion of wetland and moist site plant species between open dunes that effectively isolates them as a functioning ecological dune system.

E. Demography No relevant information for Washington sand dune ecological systems “demography” exists. Few studies addressing demographic issues for Washington’s sand dune-obligate species have been conducted. A common western North American dune-obligate tenebrionid beetle, Eusattus muricatus occurs in Washington. Britten and Rust (1996) studied E. muricatus in the Great Basin and Mojave Deserts to develop a conservation strategy for sand dune-obligate organisms (Britten and Rust 1996). Fragmentation and isolation of sand dune systems will likely continue in Washington State, affecting species population sizes, dispersal, and genetic characteristics.

F. Other Ecological Considerations To our knowledge, the work presented here is the first attempt to summarize information about the flora, fauna and ecology of Washington’s inland sand dunes. The ephemeral nature and natural isolation of sand dune habitats may allow for rapid natural selection of sand dune-obligate species and populations (Rust 1986). Additional surveys for rare plants and animals, particularly insects, will most likely produce more species whose life history is restricted to sand dune environments.

Knowledge of fire effects on sand dune systems in Washington is limited to observation and extrapolation from other areas. In general, fires initiate eolian activity by reducing vegetation cover and its anchoring or stabilizing influence on sand stability (http://www.fs.fed.us/database/feis/). Burzlaff (1962) suggests that lack of fire leads to stabilization of dunes at the Nebraska sandhills. The degree and amount of blowing sand and dune movement following a fire depends on season, intensity and size of fire and reaction of vegetation. Vegetation response generally depends on climate, topography, soil moisture, site condition, timing of fire, propagule availabiity and severity of wind and blowing sand. Typically, fire in shrubsteppe ecosystems increases annual exotic plant abundance (Brown et al. 2000) which could have negative impacts on dune function.

20

IV. Conservation

A. Threats

1. Stabilization by invasive species At this time, invasive species, primarily cheatgrass, are the greatest threat to sand dune systems in Washington. Sand dunes are dynamic systems that respond to climatic change (Gaylord and Stetler 1994, Helm 2003). The vegetated portions of dune systems increase during years with high precipitation and decrease during drought years. Increased native vegetation may not lead to complete stabilization, rather it creates anchored dunes with bare soil remaining between plants and some sand movement continues on the surface (Fig. 23). Cheatgrass invasion can completely alter these dynamic fluctuations by achieving densities that stop sand movement (Fig. 24). The cheatgrass can then increase to the point where it dominates the understory or forms dense mats of litter. Additional moisture from irrigation and other human sources facilitates these invasions.

2. Agriculture Agricultural conversion continues to represent a significant threat to Washington inland sand dune systems (Fig. 22, 25). Until the 1970s, dune fields were not considered suitable for agriculture (Washington county soil survey information, US Department of Agriculture). The 1957 Walla Walla County Soil Survey (p. 61) lists Active dune land; Hezel-Quincy complex, eroded; Quincy fine sand, 30 to 60 percent slopes, eroded; and Qunicy-Duneland complex as “soils and land types that are too sandy for use other than recreational, watershed, wildlife habitat, or other nonagricultural uses.” Changes in technology and the availability of water for irrigation have made dune lands suitable for agriculture. Today, irrigated crops on sandy soils and duneland include small grain, potatoes, corn, alfalfa and grasses (1987 Grant County Soil Survey). Sand dune habitat in the Mattawa area (Mattawa West dunes) is being converted to orchards (Fig. 26). “Virgin sandy land”, isolated from established fruit orchards, is in demand for growing fruit rootstock (Lawyer Nursery Inc. Winter 2003-Spring 2004 newsletter).

Effects from adjacent irrigation are also significant. Higher moisture causes an increase in vegetation cover and alters the flora and dynamic patterns of sand movement. The result can be an increase in weedy species such as cheatgrass, Russian thistle, and Jim Hill mustard. In some areas, irrigation water flows through dunes causing erosion and transporting sand away from the dune (for example, Sand Hollow and Beverly dunes) (Fig. 27). Irrigation water can raise water tables to form ponds and wetlands within the dune system (for example, Moses Lake Dunes). Wetland species quickly invade these sites and may including trees and shrubs such as Russian-olive (Elaeagnus angustifolia) and willows (Salix spp.).

3. Off-road vehicles (ORVs) ORV use is a threat to many of the sand dune systems. On the semi-stabilized and anchored portions of sand dune systems, ORV use damages and destroys vegetation and seedlings (Fig. 28). This can lead to increased erosion and compaction that may alter

21 vegetation, eliminating habitat for wildlife and plant species. The biological impact of off-road vehicle use on Washington’s sand dune-associated species has not been studied. Intensive ORV use has been repeatedly cited in petitions to the US Fish and Wildlife Service (USFWS) and Bureau of Land Management (BLM) as a threat to rare endemic sand dune plant and animal species in other western states (for example, Andrew’s Dunes Scarab, Peirson’s milkvetch, Sand Mountain Pallid Blue Butterfly). The oft cited study by Luckenbach and Bury (1983) concluded that ORV activities in the Algodones Dunes (Imperial County, California) were highly detrimental to dune biota. Ecological impacts on insect, lizard and rodent species included removal of food and shelter, destruction of burrow systems and direct mortality. In Washington, unsanctioned ORV use was widespread wherever it was not prevented. Efforts are needed to determine the effects of ORV use on sand dune biota, resolve how these effects can be minimize and engage ORV enthusiasts in conservation efforts. Areas of Beverly, Moses Lake, and Juniper dunes allow designatec ORV use.

4. Intentional sand dune stabilization For this conservation assessment, no attempt was made to determine the extent of where intentional stabilization was applied. Accounts concerning areas that were stabilized from the 1940s – 1960s such as “Grand Dalles” in the Dallesport area, were found during the project but were not verified. Schwendiman (1977) notes that Volga,” a strain of Mammoth wildrye, (Elymus giganteus Vahl), selected for its vigor and rapid vegetative growth, was used to stabilize inland migrating sands in Washington since 1964. It was used by the Army Engineers, the Bureau of Reclamation, Soil Conservation Districts, and State Game Departments (now Washington Department of Fish and Wildlife). Recent attempts to deter sand movement were currently observed at two dune systems (Vernita Bridge and Wanapum North dunes). Hay bales were present adjacent to agricultural fields to block sand migration from the Sand Hollow South sand dune (Fig. 29). Tree rows were planted on private property adjacent to the Priest Rapids wildlife area (Mattawa West dune) (Fig. 30), and else where on this dune system, presumably to slow sand movement.

5. Conversion to residential lots Residential properties are present on the Moses Lake, Mattawa West and Desert Aire sand dunes. During these surveys, unconverted lots were also for sale. Landscaping around these homes typically includes sand stabilizing trees, and other non-native plants and often lawns.

6. Mining activities The mining operation at the Avery Dune covers most of the historical (1970s) extent of the dune. A Department of Transportation borrow pit was present at the northeast end of the Sand Hollow South Dune. The amount of sand removed, if any, is unknown.

7. Livestock grazing – Historically, the main issue regarding livestock grazing on sand dunes has been concern that poor grazing practices or overgrazing would lead to erosion (Washington State County Soil Surveys). The ecological impact of livestock grazing on Washington’s sand dunes has not been directly addressed. Livestock may be vectors for

22 exotic plants species and overgrazing on adjacent shrub-steppe ecosystems may increase exotic species propagule pressure into dune systems. Other areas of investigation may include impact on rare plants, crushing of vertebrate and insect burrows and changes in shrub structure as it relates to shelter for native animals avoiding mid-day heat.

B. Conservation Objective – The Washington Natural Heritage Program recommends the following conservation objectives: 1) minimize or halt conversion or permanent damage to sand dune habitats on federal and state owned lands, 2) protect sand dune sites of significant conservation value and manage them for their unique features; 3) protect the associated rare plant and animal species from threats; 4) initiate research addressing sand dune stabilization by exotic species; and 5) address landscape level relationships and connectivity between these systems.

C. Selection of Management Areas – The following eight sand dune systems have been identified as having significant conservation value. The significance value is a combination of ecological condition, system size and landscape setting, as well as the presence and condition of rare species. This methodology is detailed in Appendix IV - Element Occurrence specifications for the PNW Inland Sand Dune Ecological System. Appendix V provides detailed information on Ecological Occurrence Ranks and Descriptions.

Hanford Central Dunes County: Benton Location: T12N R25E sec 23-25; T12N R26E sec 19-30, 32-36; T12N R27E sec 13- 36; T12N R28E sec 7-9, 15-23, 26-35 ; T11N R26E sec; 1-3, 11-12, T11N R27E sec 3-7 Ownership: US Fish and Wildlife Service (Federal)

Conservation significance: The Hanford Central Dunes is the largest remaining sand dune system in Washington and the only one that has not been fragmented other than a powerline corridor. Natural processes are intact and the overall species diversity is high. To our knowledge, human disturbance over the last 70 years has been limited primarily to researchers.

Rare species: Coyote tobacco (Nicotiana attenuata), dwarf evening-primrose (Camissonia pygmaea), Thompson’s sandwort (Aremaria franklinii var. thompsonii), gray cryptantha (Cryptantha leucophaea), Sagebrush Lizard (Sceloporus graciosus), Black-tailed Jackrabbit (Lepus californicus), Townsend’s Ground Squirrel (Spermophilus townsendi townsendi), Grasshopper Mouse (Onychomys leucogaster). Recently three new species of moths were discovered on Central Hanford including species of Arenoscythris (Scythrididae) and Copablepharon (Noctuidae) (Zack et al. 2003).

Issues: Stabilization by cheatgrass is occurring in some areas of the dune. If the most recent (February 2007) US Fish and Wildlife Preferred Alternative for the Hanford Monument is implemented, portions of the Hanford Central Dunes will be open to the public for the first time since the Hanford Site was established.

23 Recommendations: We recommend a baseline inventory be conducted previous to allowing public access. Regular monitoring of the plant communities and rare species should take place at least every five years to determine the impact that public access has on the site and to review management options. Due to the size, ecological condition, and landscape context of this dune system, the site meets the criteria for Research Natural Area designation and should therefore be evaluated for its potential as an RNA. The Washington Natural Heritage Program will pursue this with the U.S. Fish and Wildlife Service.

Juniper Dunes Wilderness County: Franklin Location: T10-11N, R31-32 Ownership: Bureau of Land Management (Federal)

Conservation Significance: Juniper Dunes is a very large dune system where natural processes are intact and the overall species diversity is high. This is the only dune system in Washington with Juniper Woodlands.

Rare species: Gray cryptantha (Cryptantha leucophaea), Sagebrush Lizard (Sceloporus graciosus), Black-tailed Jackrabbit (Lepus californicus), White-tailed Jackrabbit (Lepus townsendi), Washington Ground Squirrel (Spermophilus washingtoni), Grasshopper Mouse (Onychomys leucogaster), Ord’s Kangaroo Rat (Dipodomys ordii).

Issues: Within the area burned by the 1990s fire, lowlands exhibited very high exotic species cover (cheatgrass, Russian thistle and Jim Hill mustard) while uplands tended to remain stabilized by native grasses (curly bluegrass and Indian ricegrass). ORV use is permitted outside the wilderness area. The sands are apparently migrating to the northeast and will eventually move onto private property.

Recommendations: Retain wilderness and Juniper Forest ACEC designation and update management plan to ensure future viability incorporating future dune migration. Conduct an inventory for a possible occurrence of the G2 (globally imperiled) sand lyme-grass association.

Delight Dunes County: Adams Location: T15N, R34E, sec 11, 14, 15, 21, 22, 23 Ownership: Private

Conservation significance: The vegetation at Delight Dunes is extremely diverse for an active-stable inland dune ecosystem and is unique in that regard within Washington State.

Documented rare species: Sagebrush Lizard (Sceloporus graciosus)

Issues: To our knowledge, rare plant and animal species (with the exception of a brief Sagebrush Lizard survey) have not been conducted on this dune system. ORV trails are

24 present. The presence of a Great Plains sand dune grass, prairie sandreed (Calamovilfa longifolia), presumably a vestige of an old dune stabilization effort, will present unique management challenges.

Recommendation: The WNHP plans to evaluate this site as a potential Natural Area Preserve for inclusion within the statewide system of natural areas.

Wanapum and Wanapum North Dunes County: Grant Location: T16N R23E Sections 10, 11, 12, 13. Ownership: Bureau of Reclamation (Federal)

Conservation significance: This is a long, linear system of active dunes and stable sand sheets including a wide range of vegetation community types and qualities. These sand dune occurrences are in good ecological condition. The landscape context is good. Under current conditions, dune migration can continue to the southeast without causing problems on roads or agricultural lands. Wanapum North dune is of lower quality but has a gray cryptantha occurrence not identified to be present on the Wanapum Dune. These sand dunes may be important in providing connectivity for native species to the Sand Hollow and Beverly dune systems to the north and south.

Documented rare or obligate species: Gray cryptantha (Cryptantha leucophaea), Sagebrush Lizard (Sceloporus graciosus) and Black-tailed Jackrabbit (Lepus californicus).

Issues: Irrigation water moves through the northern Wanapum Dune in two places. Unsanctioned ORV use occurs on both dune systems.

Recommendations: WNHP is currently in the process of evaluating this site for possible Natural Area Preserve designation and inclusion within the statewide system of natural areas.

Wahluke Dunes County: Franklin and Grant Location: T14N R27E, sec 8-9, 11, 14-17, 21-22, 26-28, 34-36; T13N R27E sec 1-2 Ownership: US Fish and Wildlife Service (Federal), managed by Washington Department of Fish and Wildlife (State)

Conservation significance: This is a large dune system in good ecological condition with an active sand source. Overall species diversity across this system is high with most components of native diversity present. The only functional stage not present within this system was a significant amount of “native stabilized.” The landscape context is good. Sand migration is possible without causing significant issues with roads or agricultural land.

25 Rare or obligate species: Gray cryptantha (Cryptantha leucophaea), Sagebrush Lizard (Sceloporus graciosus), unique species of moth (Arenoscythris sp.) new to science and likely endemic to Wahluke dune.

Issues: Stabilization by cheatgrass and other weedy species in some areas of the dune.

Recommendations: Continued management for the natural processes and diversity of this system and a management designation for future protection. RNA designation should be considered.

Hanford Black Sand Dunes County: Benton Location: T13N R26E Sections 1, 11-12, 14; T13N R27E Sections 6-7 Ownership: United States Department of Energy, Hanford Site (Federal)

Conservation significance: The Hanford Black Sand Dunes have unique vegetation patterns not found elsewhere on Washington sand dunes. The active sands throughout the system support diverse spring annual communities. The dominance of black basalt sand suggests an origin different from Hanford Central Dunes.

Rare or obligate species: Rosy pussypaws (Calyptridium roseum), loeflingia (Loeflingia squarrosa var. squarrosa), Suksdorf's monkey-flower (Mimulus suksdorfii), Sagebrush Lizard (Sceloporus graciosus).

Issues: Stabilization by cheatgrass in some areas of the dune. The dune is bisected by a road.

Recommendations: Research Natural Area designation should be considered for this dune system. The Washington Natural Heritage Program will pursue this with the U.S. Fish and Wildlife Service.

Sentinel Butte Dunes County: Grant Location: T15N R23E Sections 10-12. Ownership: Bureau of Land Management (Federal).

Conservation significance: This is an excellent example of the climbing dune type and contains a complex pattern of vegetation related to the varying terrain. Sand migration is possible without causing significant issues with roads or agricultural land.

Rare or obligate species: Gray cryptantha (Cryptantha leucophaea), Geyer's milk-Vetch (Astragalus geyeri), Sagebrush Lizard (Sceloporus graciosus)

Issues: The rather extensive ORV use in the vegetated areas is a threat to the rare species. Stabilization due to cheatgrass invasion is occurring in some areas of the lower dune.

26 Recommendations: Consider Sentinel Slope ACEC designation and increase management for natural features associated with dune system.

Wakefield Dunes County: Okanogan County. Location: T 31N R25E Sections 4, 5, 9. Ownership: Colville Indian Reservation

Conservation significance: The Ponderosa pine/Antelope bitterbrush/Indian Rice Grass association (Pinus ponderosa / Purshia tridentata / Achnatherum hymenoides association) on this dune is globally rare (G1). Only three occurrences have been identified. The other occurrences are in Oregon.

Documented rare or obligate species: Sagebrush Lizard (Sceloporus graciosus)

Issues: Some conversion to agriculture and scattered residences have taken place at the northern end of the sand dune. A state highway bisects the dune system. Introduction of yucca (Yucca flaccida) has occurred in road cuts.

Recommendations: Consult with the Colville Nation regarding ecological significance of this dune system.

D. Management

Washington’s inland sand dunes are composed of a mosaic of open sands and vegetated communities (i.e., functional stages; Appendix III) and are dynamic in nature. Management must account for the highly dynamic nature of dune systems. Sands migrate and vegetation communities shift naturally based on climatic variation. Activities that change the amount, structure and/or composition of vegetation can alter the dynamic process of sand movement and dune migration. A sand dune can become completely devoid of vegetation or completely stabilized by vegetation. In either extreme case, the complex mosaic of community types is changed along with the rare plant and animal species associated with those habitats. Management should promote a range of dune functional stages to maintain species diversity.

Both long-term and short-term issues need to be addressed in management planning. Long-term issues include projected trajectory and rate of movement of dune systems and effects of surrounding landscape conditions and use. Short-term issues must address exotic plant invasion and on-site activities, such as ORV use, that influence whole system functioning and destroy or alter particular species’ habitat.

To conserve the natural dynamic function of the sand dune systems listed in the Management Areas section, activities that alter, damage, or destroy the vegetation should be prohibited or carefully managed.

27 V. Research, Inventory, and Monitoring Opportunities

Research Priorities: 1. Invasive species impact and control; 2. Restoration of dune systems; 3. Rare species demographics, especially distribution; 4. Complete floristic sampling of plant communities and their seral and environmental relationships to complete International Vegetation Classification; and 5) Research on the range of fire effects in sand dune systems, particularly addressing the response of annual exotic plant abundance and sand movement and stabilization.

Inventory – Insects and rare plants have been identified as high priority for inventory. Information on small mammals would also be beneficial. The sand dune systems listed in the Management Areas section are the highest priority for inventory. An inventory on the Hanford Central Dunes and at Juniper Dunes is needed to verify classification of the sand lyme-grass association, CEGL001563, (Leymus flavescens) and determine its extent in Washington.

Monitoring Opportunities – Sand dunes are considered sensitive indicators of climate change because they reflect overall moisture balance, degree of vegetation cover, and wind patterns. Establishing a monitoring system of sand dune field rate of movement and stabilization/destabilization with climate change will inform management of dune species and whole dune system. Dune systems are a confined, limited resource and are targeted for recreational use. Monitoring of recreational impacts, use levels, and public demand for recreational dune “resources” is needed.

28 VI. Adaptive Management

This conservation strategy should be revised in five years. Specifically, dune extent should be re-mapped and the general condition (weediness and rare species presence) of dune systems should be re-evaluated. More specific measures of the extent and location of dune functional stages in high conservation priority areas are needed to increase precision of detection of change in the internal dynamics of the systems. Coordinated research and monitoring by biologist and geologist or soil scientist on projected long- term fate of dunes needs to be included.

29 Acknowledgements

This study was a cooperative project of the Bureau of Land Management (BLM) and the Washington Department of Natural Resources Natural Heritage Program (WNHP). Neal Hedges and Pam Camp were the primary BLM participants in the project. The Washington Department of Fish and Wildlife provided access to the Heritage database and Reptile and Amphibian database. J. Downs (Pacific Northwest Laboratory) arranged access to the Hanford Site, provided assistance in the field and provided orthophotos of Hanford Site dunes. John Fleckenstein (WNHP) provided information and reviewed the rare animal data. Floence Caplow (formerly of WNHP) provided the initial rare plant information for this project. Joe Arnett and John Gamon (WNHP) reviewed and contributed to the rare plant information. Richard Zack, Ph.D. (Washington State University) provided information about insects. Janice Miller, Jack McMillen and Jasa Holt (WNHP) provided GIS support. John Gamon (WNHP) reviewed and provided comments that improved the report. Janice Miller created Fig. 1-2 and 20. Photographs were provided by Lisa Hallock (cover, Fig. 4, 5, 7, 9, 12, 16, 18, 23, 24, 26, 28 -30, Ryan Haugo (Fig. 8, 10, 11, 13-15, 17, 21, 25) and Rex Crawford (Fig. 19).

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