April 27, 2020 Ms. Tanowa Troupe

52 East Gay Street P.O. Box 1008 Columbus, Ohio 43216-1008

614.464.6400 | www.vorys.com

Founded 1909

Michael J. Settineri Direct Dial (614) 464-5462 Direct Fax (614) 719-5146 Email [email protected]

April 27, 2020

Ms. Tanowa Troupe, Secretary Docketing Division Ohio Power Siting Board 180 E. Broad Street, 11th Floor Columbus, OH 43215

Re: 19-1823-EL-BGN Big Plain Solar, LLC

Dear Ms. Troupe:

Accompanying this letter are hard copies of an application by Big Plain Solar, LLC for a Certificate of Environmental Compatibility and Public Need for the Madison Solar Farm, a 196 megawatt solar-powered electric generation facility to be located in Madison County, Ohio. The original application was electronically filed.

In accordance with Rule 4906-2-04 of the Ohio Administrative Code, I would like to make the following declarations:

Name of the applicant:

Big Plain Solar, LLC c/o First Solar, Inc. 11757 Katy Freeway, Suite 400 Houston, TX 77079

Name and location of the proposed facility:

Madison Solar Farm Fairfield and Oak Run Townships Madison County, Ohio

Name of the authorized representatives:

Michael J. Settineri MacDonald W. Taylor Vorys, Sater, Seymour and Pease LLP 52 East Gay Street Columbus, Ohio 43215 614-464-5462 [email protected] [email protected]

Notarized Statement:

See attached Affidavit of Kathryn Arbeit Officer of Big Plain Solar, LLC

The facility construction and operation schedule presented in the second pre-application notification letter filed February 14, 2020 has been revised. Specifically, as described in the attached application, construction of the facility is now expected to commence in the second quarter of 2022, and the facility is anticipated to be in service in the second quarter of 2023.

Very truly yours,

/s/ Michael J. Settineri

Michael J. Settineri Attorney for Big Plain Solar, LLC Enclosure

4/24/2020 35265287 V.2

APPLICATION TO THE OHIO POWER SITING BOARD

FOR A CERTIFICATE OF ENVIRONMENTAL COMPATIBILITY AND PUBLIC NEED FOR THE Madison Solar Farm Fairfield and Oak Run townships, Madison County Case No. 19-1823-EL-BGN April 2020

Prepared by: Big Plain Solar, LLC 11757 Katy Freeway, Suite 400 Houston, Texas 77079 Contact: Karl Pierce, Director of Project Development Tel: 281.509.6264

With Assistance From: Environmental Design & Research, Landscape Architecture, Engineering & Environmental Services, D.P.C. 217 Montgomery Street, Suite 1000 Syracuse, New York 13202 Contact: Ben Brazell Tel: 315.471.0688

TABLE OF CONTENTS 4906-4-01 PURPOSE AND SCOPE...... 1 (A) REQUIREMENTS FOR FILING CERTIFICATE APPLICATIONS ...... 1 (B) WAIVERS ...... 1 4906-4-02 PROJECT SUMMARY AND APPLICANT INFORMATION ...... 2 (A) PROJECT SUMMARY ...... 2 (1) General Purpose of the Facility ...... 2 (2) Description of the Facility ...... 2 (3) Description of the Suitability of the Site for the Proposed Facility ...... 3 (4) Project Schedule ...... 3 (B) APPLICANT INFORMATION ...... 3 (1) Plans for Future Generation Capacity at the Site ...... 3 (2) Description of Applicant and Operator ...... 3 4906-4-03 PROJECT DESCRIPTION AND SCHEDULE ...... 5 (A) PROJECT AREA DESCRIPTION ...... 5 (1) Geography and Topography Map ...... 5 (2) Area of All Owned and Leased Properties ...... 5 (B) DETAILED DESCRIPTION OF PROPOSED FACILITY ...... 6 (1) Description Details for the Project ...... 6 (2) Description of Major Equipment ...... 7 (3) Need for New Transmission Lines ...... 11 (4) Project Area Map ...... 11 (C) DETAILED PROJECT SCHEDULE ...... 12 (1) Schedule ...... 12 (2) Construction Sequence ...... 13 (3) Impact of Critical Delays ...... 14 4906-4-04 PROJECT AREA SELECTION AND SITE DESIGN ...... 16 (A) PROJECT AREA SELECTION ...... 16 (1) Description and Rationale for Selecting Study Area...... 16 (2) Map of Study Area ...... 17 (3) List and Description of all Qualitative and Quantitative Siting Criteria ...... 17 (4) Description of Process by Which Siting Criteria Were Used ...... 18 (5) Description of Project Area Selected for Evaluation ...... 19 (B) FACILITY LAYOUT DESIGN PROCESS ...... 19

Big Plain Solar, LLC 19-1823-EL-BGN Table of Contents – Page ii

(1) Constraint Map ...... 19 (2) Criteria Used to Determine Site Layout and Comparison of Alternative Site Layouts ...... 20 (3) Description of Number and Type of Comments Received ...... 22 4906-4-05 ELECTRIC GRID INTERCONNECTION ...... 23 (A) CONNECTION TO THE REGIONAL ELECTRIC GRID ...... 23 (B) INTERCONNECTION INFORMATION ...... 23 (1) Generation Interconnection Request Information ...... 23 (2) System Studies ...... 24 4906-4-06 ECONOMIC IMPACT AND PUBLIC INTERACTION ...... 25 (A) OWNERSHIP ...... 25 (B) CAPITAL AND INTANGIBLE COSTS ...... 25 (1) Estimated Capital and Intangible Costs by Alternative ...... 25 (2) Cost Comparison with Similar Facilities ...... 26 (3) Present Worth and Annualized Capital Costs ...... 26 (C) OPERATION AND MAINTENANCE EXPENSES ...... 27 (1) Estimated Annual Operation and Maintenance Expenses ...... 27 (2) Operation and Maintenance Cost Comparisons ...... 27 (3) Present Worth and Annualized Operation and Maintenance ...... 27 (D) COST OF DELAYS ...... 28 (E) ECONOMIC IMPACT OF THE PROJECT ...... 28 (1) Construction and Operation Payroll ...... 29 (2) Construction and Operation Employment ...... 29 (3) Local Tax Revenues ...... 30 (4) Economic Impact on Local Commercial and Industrial Activities ...... 31 (F) PUBLIC RESPONSIBILITY ...... 31 (1) Public Interaction ...... 32 (2) Liability Insurance ...... 32 (3) Roads and Bridges ...... 33 (4) Transportation Permits ...... 36 (5) Decommissioning ...... 37 4906-4-07 COMPLIANCE WITH AIR, WATER, SOLID WASTE, AND AVIATION REGULATIONS ...... 39 (A) PURPOSE ...... 39 (B) AIR ...... 39 (1) Preconstruction ...... 39

Big Plain Solar, LLC 19-1823-EL-BGN Table of Contents – Page iii

(2) Plans to Control Air Quality During Site Clearing and Construction ...... 40 (3) Plans to Control Air Quality During Facility Operation ...... 41 (C) WATER ...... 41 (1) Preconstruction ...... 41 (2) Construction ...... 42 (3) Operation ...... 44 (D) SOLID WASTE ...... 46 (1) Preconstruction ...... 46 (2) Construction ...... 46 (3) Operation ...... 46 (4) Licenses and Permits ...... 47 (E) COMPLIANCE WITH AVIATION REGULATIONS ...... 47 (1) Aviation Facilities List and Map ...... 47 (2) FAA Filing Status and Potential Conflicts ...... 47 4906-4-08 HEALTH AND SAFETY, LAND USE, AND ECOLOGICAL INFORMATION ...... 48 (A) HEALTH AND SAFETY ...... 48 (1) Equipment Safety and Reliability ...... 48 (2) Probable Impacts due to Failures of Pollution Control Equipment ...... 49 (3) Noise ...... 50 (4) Water Impacts ...... 54 (5) Geological Features Map ...... 57 (6) Prospects of High Winds in the Area ...... 61 (7) Blade Shear ...... 61 (8) Ice Throw ...... 61 (9) Shadow Flicker ...... 61 (10) Radio and Television Reception...... 61 (11) Radar Interference ...... 62 (12) Navigable Airspace Interference ...... 62 (13) Communication Interference ...... 62 (B) ECOLOGICAL IMPACT ...... 62 (1) Ecological Resources in the Project Area ...... 62 (2) Construction Impacts ...... 76 (3) Operation Impacts ...... 87 (C) LAND USE AND COMMUNITY DEVELOPMENT ...... 88

Big Plain Solar, LLC 19-1823-EL-BGN Table of Contents – Page iv

(1) Land Use ...... 88 (2) Wind Farm Parcel Status Map ...... 98 (3) Setback Waiver ...... 98 (4) Land Use Plans ...... 98 (D) CULTURAL AND ARCHAEOLOGICAL RESOURCES ...... 106 (1) Landmarks of Cultural Significance Map ...... 106 (2) Impact to Landmarks and Mitigation Plans ...... 107 (3) Impact to Recreational Areas and Mitigation Plans ...... 107 (4) Visual Impact ...... 110 (E) AGRICULTURAL DISTRICT IMPACTS ...... 114 (1) Agricultural Land and Agricultural District Land Map...... 114 (2) Potential Impacts and Proposed Mitigation ...... 114 4906-4-09 REGULATIONS ASSOCIATED WITH WIND FARMS ...... 119 LITERATURE CITED ...... 120

Big Plain Solar, LLC 19-1823-EL-BGN Table of Contents – Page v

TABLES

Table 06-1. Estimated Capital and Intangible Costs ...... 26 Table 06-2. Criteria for Vehicles Without Special Hauling Permits ...... 37 Table 08-1. Typical Construction Equipment Sound Levels During Construction ...... 50 Table 08-2. Threatened and Endangered Plant Species in Madison County...... 67 Table 08-3. Federal and State-Listed Species with Potential Presence in the Project Area...... 68 Table 08-4. Impacts to Ecological Communities ...... 78 Table 08-5. Wetland and Stream Impacts ...... 80 Table 08-6. Structures Within 1,500 feet of a PV Panel ...... 89 Table 08-7. Parcels Within 1,500 feet of a PV Panel ...... 91 Table 08-8. Structures Within 250 Feet of an Associated Facility ...... 94 Table 08-9. Parcels Within 250 Feet of an Associated Facility ...... 95 Table 08-10. Impact Assumptions ...... 96 Table 08-11. Land Use Impacts ...... 97 Table 08-12. Population Trends ...... 104 Table 08-13. Population Projections ...... 105 Table 08-14. Recreational Areas Within a Ten-Mile Radius of the Facility ...... 108 Table 08-15. Impacts to Agricultural Land Uses ...... 115 Table 08-16. Impacts to CAUV Land ...... 116

Big Plain Solar, LLC 19-1823-EL-BGN Table of Contents – Page vi

FIGURES

Figure 03-1: Geography and Topography Figure 03-2: Aerial Photography Figure 04-1: Constraints Figure 08-1: Drinking Water Resources Figure 08-2: Existing Features Figure 08-3: Ecological Features Figure 08-4: Delineated Resources Figure 08-5: Land Use Figure 08-6: Cultural Resources Figure 08-7: Agricultural Resources

Big Plain Solar, LLC 19-1823-EL-BGN Table of Contents – Page vii

EXHIBITS

Exhibit A. Preliminary Site Design Exhibit B. PV Panel User Guides Exhibit C. Madison Solar BMP Examples Exhibit D. Solar Resources of Ohio Exhibit E. Route Evaluation Exhibit F. Groundwater, Hydrogeological and Geotechnical Desktop Document Review Report Exhibit G. Socioeconomic Report Exhibit H. Existing Conditions Background Sound Survey and Noise Impact Assessment Exhibit I. Habitat Assessment Exhibit J. Public Comment Matrix Exhibit K. Vegetative Management Plan Exhibit L. Generation Interconnection Feasibility Study Report Exhibit M. Generation Interconnection System Impact Study Report Exhibit N. Complaint Resolution Plan Exhibit O. Draft Decommissioning Plan Exhibit P. Spill Prevention and Response Plan Exhibit Q. Federal Aviation Administration Consultation Exhibit R. Emergency Action Plan Exhibit S. Preliminary Geotechnical Report Exhibit T. Visual Resources Assessment

Big Plain Solar, LLC 19-1823-EL-BGN Table of Contents – Page viii

COMMONLY USED ACRONYMS and ABBREVIATIONS

bgs Below Ground Surface CAUV Current Agricultural Use Value dba Decibels A-Weighted EPA Environmental Protection Agency FAA Federal Aviation Administration FEMA Federal Emergency Management Agency GIS Geographic Information System GPS Global Positioning System GW Gigawatt HHEI Headwater Habitat Evaluation Index kV Kilovolt kW Kilowatts MW Megawatt NPDES National Pollutant Discharge Elimination System NREL National Renewable Energy Laboratory NRHP National Register of Historic Places OAC Ohio Administrative Code ODOT Ohio Department of Transportation ODNR Ohio Department of Natural Resources OPSB Ohio Power Siting Board ORAM Ohio Rapid Assessment Method ORC Ohio Revised Code PV Photovoltaic QHEI Qualitative Habitat Evaluation Index SWP3 Stormwater Pollution Prevention Plan USDA United States Department of Agriculture USGS United States Geological Survey VRA Visual Resource Assessment

Big Plain Solar, LLC 19-1823-EL-BGN Table of Contents – Page ix

4906-4-01 PURPOSE AND SCOPE

(A) REQUIREMENTS FOR FILING CERTIFICATE APPLICATIONS

Big Plain Solar, LLC (hereafter referred to as the Applicant) is proposing to construct the Madison Solar Farm (Facility), a solar-powered electric generation facility located in a rural portion of Madison County. The Applicant is an affiliate of First Solar, Inc. The materials contained herein and attached hereto constitute the Applicant’s submittal (Application) for a Certificate of Environmental Compatibility and Public Need (hereafter referred to as the Certificate), prepared in accordance with Section 4906.06 of the Ohio Revised Code (ORC). This Application was prepared in accordance with Chapter 4906-4 of the Ohio Administrative Code (OAC), Certificate Applications for Electric Generating Facilities.

This Application has been prepared by the Applicant, with support from Environmental Design & Research, Landscape Architecture, Engineering, & Environmental Services (EDR) of Syracuse, New York. EDR has 20 years of experience with siting and permitting renewable electric generation facilities.

(B) WAIVERS

The Ohio Power Siting Board (OPSB) may, upon an application or motion filed by a party, waive any requirement of this chapter other than a requirement mandated by statute. By motion filed separate from this Application, the Applicant is requesting waivers, in whole or in part, from the provisions of OAC Rule 4906-4-08(A)(3)(c), Rule 4906-4-08(A)(5)(c) and Rule 4906-4-08(D)(2)-(4).

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-01 – Page 1

4906-4-02 PROJECT SUMMARY AND APPLICANT INFORMATION

(A) PROJECT SUMMARY

The Applicant is proposing to construct the Facility in a rural portion of Madison County. The Facility will consist of photovoltaic (PV) panels, access roads, electric collection cables, a collection substation, a laydown area for construction staging, and inverters. The energy generated at the Facility will deliver power through a generation interconnection transmission (gen-tie) line from the collection substation to the proposed Point of Interconnect (POI) switchyard, located adjacent to the existing Beatty – London 138 kilovolt (kV) transmission line. The gen-tie line and POI switchyard will be the subject of a separate application to the OPSB.

(1) General Purpose of the Facility

The general purpose of the Facility is to maximize energy production from available solar resources in order to deliver clean, renewable electricity to the Ohio bulk power transmission system to serve the needs of electric utilities and their customers. The electricity generated by the Facility will be transferred to the transmission grid operated by PJM Interconnection, LLC (PJM) for sale at wholesale or under a power purchase agreement.

(2) Description of the Facility

The Facility will be located on 2,438 acres of leased private land in Fairfield and Oak Run townships, Madison County (Project Area). The Facility will occupy approximately 1,200 acres of the larger, overall Project Area. The Facility will have a nameplate capacity of 196 megawatts (MW) and will consist of PV panels, collection lines, access roads, inverters, and a collection substation. The Facility is expected to operate with an average annual capacity factor of 24%, generating an average annual total of approximately 407 gigawatt-hours (GWh) of electricity each year. The preliminary Facility layout is provided on Figure 03-2, and further detailed in Exhibit A. A detailed description of the Facility, including each Facility component, is provided in Section 4906-4-03(B) of this Application.

The Facility layout presented in this application is considered preliminary and represents a typical 30% design. By solar industry standards, a 30% design includes a general site boundary of the project, location of module racking, and the relative location of inverters and medium voltage transformers. All of these features, and fencing, collection line locations, laydown yards and access roads are depicted in Exhibit A. A final Facility design will be submitted prior to construction and will include the quantity of electrical cables, cable length, trenching locations, and more features that will be determined by Facility and environmental constraints. Additionally, final Facility design will include makes and models of Facility components, which is dictated by

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-02 – Page 2

the then-available technology, and market conditions. Panel technology is rapidly advancing, both from a cost and performance perspective, which requires final panel selection to occur close to the commencement of construction. If the Applicant were to select a panel model (or models) prior to certificate issuance, both the panel and resulting design would be obsolete well before project financing and the start of construction. Accordingly, once a panel model is selected, final engineering of the Facility will be completed to: identity the final locations of the panels, select and locate inverters, and adjust other components including piles, collection lines and roads.

(3) Description of the Suitability of the Site for the Proposed Facility

The Project Area site selection analysis concluded that the site presented herein meets all the factors necessary to support a viable solar energy facility. The proposed site possesses strong solar resources, manageable access to the bulk power transmission system, sufficiently low population density, positive feedback from landowners and local officials, highly compatible land-use characteristics, and few environmentally sensitive areas.

(4) Project Schedule

Acquisition of land and land rights began in April 2017 and will continue through June 2020. Public informational meetings were held on October 22, 2019 and March 4, 2020, to facilitate public interaction with the Applicant and expert consultants, and included information on the Applicant, visual/aesthetics, ecological studies, and solar technology. Final designs are expected to be completed in the fourth quarter 2021. Construction is anticipated to begin in the second quarter 2022 and be completed within 15 months, at which point the facility will be placed in service. Additional information about the project schedule is provided in Section 4906-4-03(C)(1) of this Application.

(B) APPLICANT INFORMATION

(1) Plans for Future Generation Capacity at the Site

The Applicant has no future plans for additional capacity at this site. This point of interconnection has a maximum capacity of 196 MW.

(2) Description of Applicant and Operator

Big Plain Solar, LLC, a wholly-owned subsidiary of First Solar, Inc., will construct and operate the proposed Facility. Founded in 1999, First Solar is a leading global provider of photovoltaic systems, and has established

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-02 – Page 3

28 utility-scale solar farms in the U.S. Additionally, First Solar is responsible for shipping enough PV modules worldwide to create 20 gigawatts (GW) of power, demonstrating their financial stability and manufacturing success. First Solar’s expanded manufacturing footprint in the United States, which represents over $1 billion in cumulative investment and directly created approximately 500 new jobs, makes it the largest solar manufacturer in America and the Western Hemisphere.

First Solar has a strong local presence with the operation of an extensive solar panel manufacturing facility in Perrysburg Township in Northwest Ohio, employing 1,350 in diverse manufacturing and engineering roles. First Solar recently began production of new PV modules at a manufacturing facility in Lake Township, Ohio, near the existing manufacturing in Perrysburg, Ohio.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-02 – Page 4

4906-4-03 PROJECT DESCRIPTION AND SCHEDULE

(A) PROJECT AREA DESCRIPTION

The following sub-sections provide information on the Project Area’s geography, topography, population centers, major industries, and landmarks.

(1) Geography and Topography Map

Figure 03-1 depicts the geography and topography of the Project Area, and the surrounding area within a 2- mile radius. This mapping was developed using the “ESRI World Topographic Map,” which consists of data from the U.S. Geological Survey (USGS), U.S. Environmental Protection Agency (EPA), U.S. National Parks Service (NPS), and Garmin. Among other information, Figure 03-1 shows the following features:

(a) The Proposed Facility (b) Population Centers and Administrative Boundaries (c) Transportation Routes and Gas and Electric Transmission Corridors (d) Named Rivers, Streams, Lakes, and Reservoirs (e) Major Institutions, Parks, and Recreation Areas

(2) Area of All Owned and Leased Properties

A total of 2,438 acres of private property are owned and/or under lease within the Project Area. The Project Area is comprised of 25 separate properties.

Approximately 1,215 acres of land will be disturbed during construction. Much of this disturbance will be temporary and subject to restoration activities at the end of Facility construction. Following restoration, the permanent operating footprint of the Facility will be approximately 1,168 acres of built facilities, or approximately 48% of total leased lands.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 5

(B) DETAILED DESCRIPTION OF PROPOSED FACILITY

(1) Description Details for the Project

(a) Type and Characteristics of Generation Equipment Equipment for the Facility includes PV modules, a racking system, and inverters to convert electrical output from DC to AC. The PV panels proposed for this Facility are thin-film panels, mounted on single- axis trackers. The panels will move along one axis and will be installed in linear arrays. Based on the total generating capacity of 196 MW, the Applicant anticipates using approximately 800,000 solar panels. The panels will operate continuously but will not produce electricity during nighttime hours. The annual net capacity factor for the Facility is anticipated to be 24%, a value calculated by PlantPredict. PlantPredict is a modeling software designed for utility scale solar projects which accounts for environmental conditions (e.g., weather, albedo), design considerations (e.g., type of inverter and tracking parameters), and power losses (e.g., soiling loss). Accounting for a total generating capacity of 196 MW and an annual capacity factor of 24%, the Facility will generate approximately 407 GWh of electricity each year.

Heat rate is not applicable to solar energy facilities.

(b) Turbine Dimensions This section is not applicable to the Facility.

(c) Fuel Quantity and Quality Solar panels generate electricity without burning fuels. Therefore, this section is not applicable to the Facility.

(d) List of Pollutants Emissions and Quantities Solar panels generate clean, emission-free electricity without releasing airborne pollutants. Therefore, this section is not applicable to the Facility.

(e) Water Requirement, Source, and Discharge Information Solar panels generate electricity without the use of water. Therefore, no water is treated or discharged, and this section is not applicable to the Facility.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 6

(2) Description of Major Equipment

As previously indicated, the Facility consists of approximately 800,000 PV panels. In addition to the PV panels, the Facility will include up to approximately 13.4 miles of access roads, up to approximately 12.5 miles of buried 34.5 kV electrical collection cable, up to approximately 1.6 miles of overhead 34.5 kV collection cable, a collection substation, a temporary laydown yard for construction staging, and approximately four pyranometers.

The primary steps for Facility construction include the following: (1) securing the perimeter of the areas in which construction will occur, (2) installation of storm-water and erosion control measures, (3) clearing vegetation where necessary, (4) minor earthwork or grading where necessary, (5) construction of access roads, and (6) installation of equipment such as pilings, racking, panels, inverters, pyranometers, the substation, and fencing to secure the site.

(a) Solar Modules and Racking System Once access roads are complete, construction of PV modules will commence. Since most of the site is relatively flat, minimal grading is anticipated for the installation of PV arrays. The PV modules will be secured on a single-axis tracker racking system supported on metal piles that will be driven into the ground to a depth between five and nine feet. Depth will be confirmed upon a final geotechnical study. Pile driving activities will occur in several stages: (1) preparing the site, (2) setting and driving lower pile, (3) setting middle pile, (4) welding of joint, (5) driving middle pile, (6) setting upper pile, (7) welding joint, and (8) driving upper pile. Pile driving negates the need for excavation for PV module installation.

Single-axis tracker designs vary by manufacturer, but generally consist of a series of mechanically linked horizontal steel support beams known as torque tubes, with a drive train system usually located in the center of the rows, dividing the array into two sides. The number of rows within a tracker block is typically limited by the drive system’s ability to move multiple torque tube assemblies. This row design is also determined by the amount of the desired solar output to the inverters. Rows would be aligned north to south and the PV panels would pivot, tracking the sun’s motion from east to west throughout the day. The panels will be a maximum of 12 feet from the ground when tilted to their highest position and will be surrounded by fence, likely a chain link fence, but may be modified based on conversations with adjacent landowners. Additional information regarding dimensions and materials for some solar panels under consideration are provided in Exhibit B, which is submitted under confidential seal.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 7

(b) Fuel, Waste, Water, and Other Storage Facilities PV panels generate electricity without the use of fuel or water, and without generating waste. Therefore, the proposed Facility does not include any significant facilities for fuel, waste, water, or other storage facilities. However, it is anticipated that contractors will be utilizing temporary fuel tanks at the laydown yard for truck re-fueling during the construction phase.

(c) Fuel, Waste, Water, and Other Processing Facilities PV panels generate electricity without the use of fuel or water, and without generating waste. Therefore, the proposed Facility does not include any fuel, waste, water, or other processing facilities.

(d) Water Supply, Effluent, and Sewage Lines No Facility components will use measurable quantities of water or discharge measurable quantities of wastewater.

(e) Associated Electric Transmission and Distribution Lines and Gas Pipelines The Facility will include the installation of a short gen-tie line. This gen-tie line will run overhead from the collection substation to the POI switchyard and will tap into the existing Beatty-London 138 kV Transmission Line. Both the gen-tie line and POI switchyard will be the subject of a separate application to the OPSB and are not addressed in detail in this application. There are no electric distribution lines or gas pipelines associated with the Facility.

(f) Electric Collection Lines (Buried and Overhead) The Facility transformers will raise the voltage up to 34.5 kV, the same voltage level as the collection system. From the transformer, cables will join to form the electrical collection system and route to the generating step-up transformer. Collection cables will be either buried or run overhead through the Project Area. A total of 12.5 miles of buried collection line will be installed for the Facility. Direct burial of underground collection lines will be done with a trencher wherever possible. A trencher uses a large blade or “saw” to easily excavate an open trench, generally 24 to 36 inches wide, where geologically suitable. Cables will be buried to depths between 36 inches and 48 inches. This installation requires only minor clearing and surface disturbance up to 15 feet wide for the installation machinery and access.

Installation of buried collection lines in an open trench will be used in areas where the previously described direct burial methods are not practicable. Areas appropriate for open trench installation will be

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 8

determined at the time of construction and may include areas with unstable slopes, excessive unconsolidated rock, standing or flowing water, and/or suspected drainage tiles. Open trench installation is generally performed with a backhoe and results in a disturbed trench approximately 48 inches deep. However, the overall temporary footprint of vegetation and soil disturbance will average 15 feet in width, due to machinery dimensions and backfill/spoil pile placement during installation. In agricultural areas, all topsoil within the work area will be stripped and segregated from excavated subsoil. Replacement of spoil material will occur immediately after installation of the buried collection lines. Subgrade soil will be replaced around the cable, and topsoil will be replaced at the surface. Any damaged tile lines will be repaired, and all areas adjacent to the open trench will be restored to original grades and surface condition. Restoration of these areas will be completed through seeding and mulching of all exposed soils, or by other appropriate farming methods in active agricultural fields.

In addition to buried collection lines, approximately 1.6 miles of overhead collection line (excluding the gen-tie line) will be used for the Facility in select locations to minimize impacts to waterbodies and drainage tiles. Overhead collection lines will be supported by 60-foot tall wood pole structures. Localized grading may be required at pole sites. These wood structures will extend into the ground for approximately nine to 12 feet. After installation of the poles, conductor stringing and terminations will be performed.

(g) Substations, Switching Substations, and Transformers Each solar field will have a network of electric lines and associated communication lines that collect the electric power from the various arrays and transmit it to a centralized location at combiner boxes. Power from the combiner boxes will be transmitted through a series of related electrical components including a DC-to-AC inverter, a medium voltage transformer that will increase the voltage to 34.5 kV, and a cabinet of power control electronics. The inverter, medium voltage transformer and power control electronics will be mounted on a skid or concrete pad.

Once the power is raised at the transformer, collection lines will deliver power to the collection substation, where an additional voltage step up from 34.5 kV to 138 kV will occur. The collection substation will be located in the central-northern portion of the Project Area, north of Big Plain Circleville Road and southwest of the intersection of McGuire Road and Hume Lever Road, in Fairfield Township.

Prior to construction of the collection substation, erosion and sediment control features such as silt fencing will be installed (see Exhibit C). Given the flat topography in the Project Area, limited grading is

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 9

anticipated. Following the installation of erosion and sediment control features, topsoil will be stripped and stored, the site will be graded as necessary, and gravel will be installed for the concrete pad. After site preparation, permanent erosion and sediment control features will be installed and topsoil will be replaced and re-seeded. The collection substation will be approximately 300 feet by 300 feet in size, will contain concrete foundations for large equipment, and will be enclosed by a chain link fence. Additional features of the collection substation include dead-end support structures for overhead collection lines, circuit breakers, surge arrestors, insulators, and a lightning mast.

Once the voltage is stepped up to 138 kV, electricity will be delivered through a gen-tie line to the POI switchyard. Both the POI switchyard, and the gen-tie line linking the collection substation to the POI switchyard, will be the subject of a separate filing to OPSB.

(h) Pyranometer The Facility will include approximately four pyranometers, which will be mounted to the PV racking system.

(i) Access Roads The Facility will require the construction of new access roads within the Project Area. The location of access roads is provided in Figure 03-2, which displays the preliminary Facility layout. The total length of access roads within the Project Area is approximately 13.4 miles. The roads will be gravel-surfaced and typically 20 feet in finished width.

Wherever feasible, existing roads and farm drives will be upgraded for use as Facility access roads in order to minimize impacts to active agricultural areas, natural communities, and wetland/stream areas. Where existing roads or farm drives are unavailable or unsuitable, new gravel-surfaced access roads will be constructed. Road construction will involve topsoil stripping and grubbing of stumps, as necessary. Any grubbed stumps will be removed, chipped, or buried. Stripped topsoil will be stockpiled along the road corridor for use in site restoration. Following removal of topsoil, subsoil will be graded, compacted, and surfaced with gravel or crushed stone at a depth to be determined on a case-by-case basis. A geotextile fabric or grid will be installed beneath the road surface if necessary, to provide additional support. To the extent practicable, local sources will be used to obtain gravel and other construction materials that may be needed in support of Facility construction.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 10

During construction, access road installation and use could result in temporary soil disturbance of a maximum width of 25 feet. Once construction is complete, temporarily disturbed areas will be restored, including removal of excess road material and rocks greater than 12 inches, and returned to their approximate pre-construction contours.

(j) Construction Laydown Areas One laydown yard is proposed for the Facility, located along Big Plain Circleville Road, just east of its intersection with Glade Run Road. The laydown yard will be located on privately owned land and will accommodate material and equipment storage, parking for construction workers, and construction management trailers.

The site will be equipped with temporary erosion and sediment control methods such as silt fencing, stripped of topsoil, and covered with gravel. The laydown yard will be approximately 16 acres and is depicted on Figure 03-2. The laydown yard is a temporary area that will be removed upon completion of Facility construction.

(k) Security, Operations, and Maintenance Facilities or Buildings No operations and maintenance (O&M) building is proposed as part of the Facility; therefore, this section is not applicable.

(l) Other Pertinent Installations There are no additional Facility components beyond those already described in the previous subsections of 4906-4-03(B)(2).

(3) Need for New Transmission Lines

The Facility will require the use of a short gen-tie line. The gen-tie line will transmit energy from the collection substation to the POI switchyard, and ultimately to the existing Beatty – London 138 kV circuit. Both the gen- tie line and POI switchyard will be the subject of a separate filing to the OPSB.

(4) Project Area Map

A layout of all Facility components is illustrated on Figure 03-2. Prepared at a 1:12,000 scale, Figure 03-2 illustrates the following features:

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 11

(a) Aerial Photograph Mapping was developed using ESRI World Imagery aerial photographs map service.

(b) The Proposed Facility A layout of Facility components, as discussed above in Section 4906-4-03(B)(2), is provided in Figure 03-2.

(d) Property Lines Property line data was obtained from the Madison County Auditor’s Office website.

(1) Schedule

A Gantt-style chart is presented below, illustrating major activities and milestones including:

(a) Acquisition of Land and Land Rights Acquisition of land and land rights began in April 2017 and will continue through June 2020.

(b) Wildlife Surveys/Studies Ecological surveys/studies began in 2017 and were completed in 2019.

(c) Receipt of Grid Interconnection Studies Grid interconnection studies were initiated in 2017. Two sets of interconnection studies were prepared for this Facility (see Section 4906-4-05). The Feasibility Studies were issued in February 2017 and January 2018. The System Impact Studies were issued in October of 2017 and 2018.

(d) Preparation of the Certificate Application Preparation of the Application occurred in fall 2019 and winter 2020 and public informational meetings were held on October 22, 2019 and March 4, 2020, at the Fairfield Township Hall.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 12

(e) Submittal of the Application for Certificate This Application was officially submitted in the second quarter of 2020.

(f) Issuance of the Certificate It is anticipated that the Certificate will be issued in the fourth quarter of 2020.

(g) Preparation of the Final Design It is expected that final designs and detailed construction drawings will be completed as early as the first quarter of 2021, after the final panel model is selected.

(h) Construction of the Facility Construction is anticipated to begin in the second quarter of 2022 and be completed in 15 months.

(i) Placement of the Facility in Service The Facility will be placed in service upon completion of construction, anticipated for the second quarter of 2023.

(2) Construction Sequence

Project construction is anticipated to proceed in the following sequence, with multiple activities being performed concurrently: • Securing perimeter of the areas in which construction will occur; • Installation of storm-water and erosion control measures; • General clearing of the Project Area, particularly at PV arrays, access roads, laydown yards, and substation locations; • Minimal grading for access roads, PV arrays, laydown yards and substation areas; • Construction of access roads; • Installation of piles for support of PV modules; • Installation of PV modules; • Installation of the electrical collection system; • Construction and installation of substation; • Installation of inverters; • Facility commissioning and energization;

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 13

• Final grading and drainage; and • Restoration activities.

Although minimal grading is expected, graded areas will be smoothed, compacted, and freed from irregular surface changes, and sloped to drain. Final earth grade adjacent to equipment will be below the finished floor slab and sloped away from the structure to maintain proper drainage. Slopes of embankments shall be protected against rutting and scouring during construction in a manner similar to that required for excavation slopes. Site grading will be compatible with the general topography and use of adjacent properties, right-of- way, setbacks, and easements.

Construction of PV module foundations, assembly, access road construction, and installation of collection lines are described above in Section 4906-4-03(B)(2).

Once construction is complete, temporarily disturbed areas will be restored, including removal of excess road material, de-compaction, and rock removal in agricultural areas, and returned to their approximate preconstruction contours. Exposed soils in the Project Area will be stabilized by seeding, mulching, and/or plantings.

(3) Impact of Critical Delays

Critical delays may have material, adverse effects on Facility financing, including the Applicant’s ability to timely acquire racking, inverters or transformers. Such delays may push the in-service date back. In addition, considerable costs would be incurred if the delays prevented the Facility from meeting deadlines for federal incentive programs such as the Investment Tax Credit for Solar.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-03 – Page 14

Estimated Project Schedule November-16 February-17 May-17 August-17 November-17 February-18 May-18 August-18 November-18 February-19 May-19 August-19 November-19 February-20 May-20 August-20 November-20 February-21 May-21 August-21 October-21 January-22 April-22 July-22 October-22 January-23 April-23 July-23 October-23 January-24

Land Rights

Wildlife Surveys/Studies

Receipt of Grid Interconnection Studies

Preparation of Application

Submittal of the Application

Issuance of the Certificate

Preparation of the Final Design

Construction of the Facility

Placement of the Facility in Service

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-04 – Page 15

4906-4-04 PROJECT AREA SELECTION AND SITE DESIGN

The selection of appropriate sites for a solar-powered electric generation facility is constrained by numerous factors that are essential considerations for the Facility to operate in a technically and economically viable manner. This section describes the general site selection process, along with associated siting constraints and requirements.

(A) PROJECT AREA SELECTION

(1) Description and Rationale for Selecting Study Area

Availability/quality of solar resource and proximity to the bulk power transmission system are the initial screening criteria evaluated in the site selection process for any solar power project. The Applicant’s initial evaluation was based on publicly available data, such as National Renewable Energy Laboratory’s (NREL’s) “U.S. National Solar Radiation Database,” along with site visits and capacity analysis for nearby transmission lines.

Exhibit D depicts solar resources in Ohio using data obtained from the NREL National Solar Radiation Database (NREL, 2017). The data suggests a suitable solar resource in the southwestern region of Ohio, including Madison County. Adequate access to the bulk power transmission system is also an important siting criterion, as the system must be able to accommodate the interconnection and accept and transmit power from the Facility. As depicted in Figure 04-1, existing bulk transmission lines are located within the vicinity of the Facility in Madison County.

Land use in Madison County is primarily agricultural and characterized by open spaces suitable for hosting a utility-scale solar power project. Site visits to the area provided visual verification that the study area is dominated by agricultural use, and therefore is compatible with solar project development.

Proximity to major transportation routes is another consideration in identifying a site for the Facility. Located approximately eight miles southwest of the City of Columbus and approximately four miles southeast of the City of London, the Project Area is situated south of Interstate (I) 70, and north of I-71. Additional state routes lie in the vicinity of Project Area. State Route (SR) 665 is north of the Project Area and SR 56 is southwest of the Project Area. These major roads provide accessibility to the Project Area for construction equipment and staff.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-04 – Page 16

(2) Map of Study Area

Multiple sites within a larger study area were not considered for the development of the Facility. Various constraints and requirements, many of which are outlined below, limit the amount of suitable area for a solar development project. See sections 4906-4-03(A)(3-5) and (B) below for further details. See Figure 03-1 for a map of the Project Area and geographical setting.

(3) List and Description of all Qualitative and Quantitative Siting Criteria

The Applicant does not have the unfettered ability to locate projects in any area or on any parcels of land; facilities can only be sited on private property where the landowner has agreed to allow such construction. Moreover, private landowner agreements limit the use of land to a solar power project, and as such, do not allow for the siting of other alternative energy production facilities (e.g., wind, hydro, biomass, or fossil fuel). Accordingly, other power generation technologies are not reasonable alternatives, and do not warrant consideration in this Application.

Siting criteria used for the selection of a particular area to host a viable solar power project, such as the Facility proposed herein, include a number of factors and requirements, which are presented below: • Adequate solar resource- the Applicant determined through an initial screening process utilizing a statewide solar resource map (see Exhibit D), and subsequent on-site measurements, that the Project Area has an adequate solar resource. • Adequate access to the bulk power transmission system- the Applicant determined that the existing transmission infrastructure was adequately accessible from the standpoints of proximity and ability of the system to accommodate the interconnection, as well as the ability to accept and transmit the power from the Facility at a reasonable cost. This determination was made through an initial internal preliminary assessment and subsequent interconnect requests filed with PJM. See Section 4906-4- 05 of this Application for additional detail. • Willing land lease participants and host communities- the Applicant obtained private lease agreements, which constitute contiguous area of land necessary to support the Facility. See Section 4906-4-06(A) of this Application for additional detail. In addition, the Applicant has engaged local and state stakeholders and the local community to educate and share information. • Site accessibility- the Project Area is served by an existing network of public roads, which will facilitate component delivery, construction, operation, and maintenance activities (for Route Evaluation Study, see Exhibit E).

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-04 – Page 17

• Appropriate geotechnical conditions- the Applicant determined that significant geotechnical constraints are not anticipated for planned construction of the Facility (Exhibit F). • Distance from airports- the proposed Facility is sited over five miles from airports. See Section 4906- 4-07(E) of this Application for additional detail on aviation facilities. • Limited residential development- the Project Area has a low population and residential development density compared to surrounding areas and statewide averages. Areas with limited residential development generally have more available space for siting a solar facility once constraints, related to shading, setbacks, and sound levels, are taken into account. See Section 4906-4-08(C)(3)(e) and Exhibit G of this Application for additional detail on demographics in the vicinity of the Project Area. For additional information on noise, see Section 4906-4-08(A)(3) and Exhibit H of this Application. • Compatible land use – the Project Area is predominantly rural agricultural, which is compatible with the proposed Facility. See Section 4906-4-08(C) of this Application. • Limited sensitive ecological resources – the proposed Facility is not expected to result in significant adverse impact to ecological resources. See Section 4906-4-08(B) and Exhibit I of this Application. • Cultural resources – the proposed Facility is not expected to physically impact any identified existing cultural resources. For additional information on cultural resources, see Section 4906-4-08(D) and Exhibit I of this Application.

No particular weighting value was assigned to any of the above criteria. Once the Applicant determined that the Project Area was suitable for development of a solar power facility, various siting factors and constraints were identified and evaluated in order to appropriately site Facility components. These efforts are discussed in detail below in 4906-4-04(B).

(4) Description of Process by Which Siting Criteria Were Used

As noted above, the selection of possible sites for development of solar power facilities is constrained. Projects must be located in areas with adequate solar resource and situated in locations that can accommodate land use and environmental restrictions imposed by local, state, and federal laws. Additionally, projects must be near electric transmission lines with sufficient unused capacity, in order to accept energy from the facility. Once a project area has been selected and given the nature of the generation technology (solar panels), there is the ability to alter PV panels and other component locations with no additional impact and within the confines of the private agreements obtained by the Applicant and other site constraints. The Facility layout design process is described below in 4906-4-04(B).

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-04 – Page 18

(5) Description of Project Area Selected for Evaluation

Based on the criteria listed in Section 4906-4-04(A)(3) of this Application, the Project Area site selection analysis concluded that the site presented herein meets all the factors necessary to support a viable solar energy facility. The proposed site possesses strong solar resources, manageable access to the bulk power transmission system, sufficiently low population density, positive feedback from landowners and local officials, highly compatible land-use characteristics, and few environmentally sensitive areas.

(B) FACILITY LAYOUT DESIGN PROCESS

The Applicant has identified the Project Area and conducted preliminary design work in order to prepare a Facility layout. The current preliminary Facility layout was designed to reduce impacts to forested areas, wetland, and streams, as well as visual impacts, to the greatest extent practicable, while still achieving the targeted net capacity of 196 MW. It is important to note that panel technology is rapidly advancing in cost and performance, which necessitates selecting the final panel model close to the commencement of construction. If the Applicant were required to select a panel model (or models) prior to certificate issuance, both the panel and resulting design would be obsolete well before Project financing and the start of construction. Accordingly, once a panel model is selected, final engineering and design of the Project will be completed to: identity the final locations of the panels, select and locate inverters, and adjust other components including piles, collection lines and roads. The Applicant commits to provide the final Facility layout to the Board’s Staff at least 60 days prior to the start of construction, which will include panel model, panel layout, and the final location of other ancillary components. The final Facility layout will: (1) not alter the boundaries of the Project Area, (2) comply with the Project setbacks set forth in this Application, and (3) not create any additional material adverse impact.

(1) Constraint Map

A constraint map of the Project Area showing public roads, utility corridors, streams, wetlands, residences, property lines, and internal setbacks defined by the Applicant is included as Figure 04-1. This illustrative graphic cannot appropriately show all the site-specific constraints and considerations, such as minimizing tree clearing and impacts to wetlands and surface waters, landowner preferences, and noise considerations (primarily collection substation transformers), all of which further limit siting alternatives within the participating parcels.

In addition to siting the layout within the constraints discussed above, numerous expert analyses and field studies have been conducted to ensure that the PV panel arrays are sited so as to minimize environmental

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-04 – Page 19

impacts to the maximum extent practicable, while still allowing for a successful project. The pertinent studies and analyses are attached hereto as Exhibits and discussed in various sections of this Application.

(2) Criteria Used to Determine Site Layout and Comparison of Alternative Site Layouts

The siting of project components within a given project area is governed by site-specific factors, including land use constraints, agricultural constraints, noise constraints, floodplain, wetland and stream constraints, and landowner considerations. Once it was determined that the general project location was adequate, the Applicant worked with various consultants to conduct detailed assessments, which identified and defined the siting factors and constraints discussed below. Through the use of geographic information system (GIS) tools and consultant assessments, the Applicant performed numerous layout design iterations to develop the Facility layout as presented and described in this Application. The constraints used in designing the Facility layout are discussed in additional detail below.

Land Use Constraints The Facility is sited primarily in a rural, agricultural setting with some residential development. To avoid impacts to local roads and residences, the Applicant has developed internal setbacks. PV panels will be sited at least 50 feet from a non-participating parcel and access roads will be sited at least five feet from a non- participating parcel.

Agricultural Constraints Agriculture is the dominant land use within the Project Area. Therefore, the Applicant has designed the Facility footprint in order to minimize impacts to active agricultural land. These efforts included site-specific investigations in order to place PV panel arrays and access roads in a way that minimizes temporary disturbance and permanent loss of active agricultural land to the maximum extent practicable. Furthermore, the Facility will promote the long-term economic viability of the affected farms by supplementing the income of participating farmers. For additional information on agricultural land, see Section 4906-4-08(E) of this Application.

Noise Constraints No existing national, state, county, or local laws specifically limit noise levels produced by solar energy facilities in the Project Area. Solar facilities are only operational during daytime hours which alleviates traditional nighttime noise constraints. A project’s collection substation is the primary source of operational noise for a utility-scale solar facility, and will produce some operational noise during nighttime hours as the transformers will remain energized. The inverters and transformers that are part of a solar panel array will

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-04 – Page 20

produce no noise during nighttime hours and minimal noise during daylight hours. Accounting for these constraints, the Facility layout is designed to minimize noise impacts to nearby residences. For additional information on noise, see Section 4906-4-08(A)(3) and Exhibit H of this Application.

Floodplain Location Portions of the Project Area are located within the 100-year floodplains surrounding Deer Creek and Glade Run. However, PV panels, access roads, the collection substation, and laydown yard are all sited outside the 100-year floodplains. For additional information on floodplains, see Section 4906-4-08(A)(4).

Wetland and Stream Constraints Federal and state law discourages development in wetlands and streams, and advocates that such impacts be avoided or minimized. Section 404 of the Clean Water Act established a program to regulate the discharge of dredged or fill material into waters of the United States, including wetlands. As described by the U.S. EPA (2019), the basic premise of the program is that no discharge of dredged or fill material may be permitted if: (1) a practicable alternative exists that is less damaging to the aquatic environment, or (2) the nation’s waters would be significantly degraded. In other words, an applicant must show that it has, to the extent practicable:

• Taken steps to avoid wetland impacts, • Minimized potential impacts on wetlands and streams, and • Provided compensation for unavoidable impacts, if required by the terms of the permit.

In order to avoid and minimize impacts to waters of the U.S. and wetlands, on-site investigations were conducted to establish the locations of streams and wetlands, and Facility components were sited in an effort to avoid impacts to these resources to the maximum extent practicable. PV panel installation is not considered a significant impact because PV panels are supported by steel pilings that are directly embedded and not considered fill. For all identified stream and wetland crossing points, appropriate construction techniques will be used to avoid and minimize impacts to the extent practicable. As a result, the vast majority of stream impacts will be temporary in nature. For additional information on estimated wetland and stream impacts, see Section 4906-4-08(B)(2)(a) and Exhibit I of this Application.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-04 – Page 21

Landowner Considerations The Applicant has and will continue to meet with various participating landowners to review the Facility footprint on their respective parcel(s). Among other things, these meetings often involve field analysis to ensure that Facility components are sited in a manner that minimizes impacts to any site features of importance to the landowner. Additionally, the Applicant designed the Facility to minimize the number of PV panels located near non-participating residences.

(3) Description of Number and Type of Comments Received

Written and oral comments were received at the two public informational meetings. Exhibit J contains each public comment received by the Applicant, a response addressing the comment, and the corresponding application section where additional information can be found. The public comments generally focused on public safety, Facility decommissioning, use of farmland, herbicide use, setbacks, and ecological impacts. These issues are addressed in this Application. Air quality benefits are discussed in Section 4906-4-07(B); economic benefits are discussed in Section 4906-4-06(E); herbicide use is discussed in Section 4906-4-07(C) and Exhibit K; setbacks are discussed in Section 4906-4-08(C)(2); and potential impacts to wildlife are discussed in Section 4906-4-08(B).

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-04 – Page 22

4906-4-05 ELECTRIC GRID INTERCONNECTION

(A) CONNECTION TO THE REGIONAL ELECTRIC GRID

In order to interconnect new generation to the electric transmission grid, the Facility owner must obtain approval from PJM Interconnection (PJM). PJM is a regional transmission organization (RTO) that coordinates the movement of wholesale electricity in all of Ohio and all or parts of surrounding states. The interconnection process includes completion of studies by PJM that determine the transmission upgrades required for a project to interconnect to the PJM grid reliably. These studies are completed in a series. The Feasibility Study, the System Impact Study, and the Facilities Study are designed, respectively, to provide developers with increasingly more refined information regarding the scope of required upgrades, completion deadlines, and implementation costs.

The proposed Facility will connect to the American Transmission Services Inc. (ATSI) transmission system along the Beatty – London 138 kV line. The interconnection would require the installation of a new 138 kV 3-breaker ring on the London – Beatty line and loop in connection for the Beatty – London line to ensure interconnection to the AC1-078 generation substation. The Applicant will obtain all necessary permits and land for the new transmission facilities and will be responsible for construction costs. ATSI will own and operate the new substation components. As noted in other sections of this Application, the gen-tie connection from the collection substation to the POI, and the POI switchyard, will be submitted to the OPSB through a separate application.

(B) INTERCONNECTION INFORMATION

(1) Generation Interconnection Request Information

The Applicant is utilizing two PJM queue positions to interconnect the Facility. The first queue position, AC1- 078, is for 176 MW of energy, with 66 MW of that as capacity. The queue name is Beatty – London 138 kV, and the queue date is September 30, 2016.

The second queue position is an uprate to the first position. Queue AD1-081 is for 20 MW of energy, with 13.2 MW of that as capacity. The queue name is Beatty – London 138 kV, and the queue date is September 5, 2017.

The combined capacity of the two queue positions is 196 MW of energy with 79.2 MW of that as capacity. The website for the PJM queue is https://www.pjm.com/planning/services-requests/interconnection- queues.aspx. The queue positions for this project can be found by entering the queue positions into the “Queue/OASIS ID” search field.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-05 – Page 23

(2) System Studies

(a) Feasibility Study AC1-078 – PJM issued the Generation Interconnection Feasibility Study Report for Queue Project AC1- 078 (AC1-078 Feasibility Study) in February 2017. The AC1-078 Feasibility Study evaluated the project for 176 MW of energy, with 66 MW of that as capacity. The AC1-078 Feasibility Study did not identify new network impacts. Additional details on potential issues, along with network upgrades that could alleviate these concerns, are described in greater detail in the AC1-078 Feasibility Study (Exhibit L).

AD1-081 – PJM issued the Generation Interconnection Feasibility Study Report for Queue Project AD1- 081 (AD1-081 Feasibility Study) in January 2018. This report evaluated the project as a 20 MW uprate to Queue AC1-078, with 13.2 MW of that as capacity. The potential issues, along with network upgrades that could alleviate these concerns, are described in greater detail in the AD1-081 Feasibility Study (Exhibit L).

(b) System Impact Study AC1-078 – PJM issued the Generation Interconnection System Impact Study Report for Queue Project AC1-078 (AC1-078 System Impact Study) in October 2017. This report evaluated the project for 176 MW of energy, with 66 MW of that as capacity. The potential issues, network upgrades, and approximate cost allocations are described in greater detail in the AC1-078 System Impact Study (Exhibit M).

AD1-081 – PJM issued the Generation Interconnection System Impact Study Report for Queue Project AD1-081 (AD1-081 System Impact Study) in November 2018. This report evaluated the project as a 20 MW uprate to Queue AC1-078, with 13.2 MW of that as capacity. The potential issues, network upgrades, and approximate cost allocations are described in greater detail in the AC1-078 System Impact Study (Exhibit M).

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-05 – Page 24

4906-4-06 ECONOMIC IMPACT AND PUBLIC INTERACTION

(A) OWNERSHIP

The Applicant will construct, own, and operate all structures and equipment associated with the Facility. As depicted on Figure 03-2, limited portions of the 34.5 kV electrical collection lines will be located within public road rights-of-way where the collection line route crosses Big Plain Circleville Road (County Road [CR] 4) from one participating parcel to another. The Applicant continues to meet with property owners and is in the process of obtaining the necessary leases and waivers. At this time, approximately 90% of all property required for the Facility is under easement or lease agreement. Parcels anticipated to be under a lease or easement agreement at the time of Facility construction are identified as participating parcels for the purposes of this Application. The proposed Facility will not change the ownership status of such rights-of-way. All other components of the Facility will be located entirely on privately-owned land, and voluntary lease and easement agreements between the Applicant and private landowners will accommodate the Facility. The proposed Facility and associated lease agreements are not expected to change the ownership status of private lands within the Project Area, with the possible exception of land purchased for the POI switchyard, for which the Applicant may either lease land or purchase associated land.

The Applicant is a wholly-owned subsidiary of First Solar. Founded in 1999, First Solar has developed, financed, engineered, constructed, and operated large-scale PV power plants around the world, totaling 17 gigawatt (GW) of solar energy worldwide. Headquartered in Arizona, First Solar has been a strong developer in the United States, creating solar facilities in the following states: California, Arizona, Nevada, New Mexico, and Texas. As described above in Section 4906-4-02(B)(2), First Solar already has a large beneficial economic impact on Ohio, with its manufacturing facilities located in Northwest Ohio directly employing hundreds of Ohioans and resulting in indirect economic benefits to the state.

(B) CAPITAL AND INTANGIBLE COSTS

(1) Estimated Capital and Intangible Costs by Alternative

The total estimated capital and intangible costs of the Facility could range between approximately $ ____ and

$ _____ ($ _____/kWAC - $ _____/kWAC). These costs are broken out in Table 06-1 below, which assumes a cost value in the approximate middle of the estimated range.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 25

Table 06-1. Estimated Capital and Intangible Costs Description Cost Tangible Costs Panels (including transportation and $ _____ installation) Civil and Electrical Work $ _____ Other $ _____ Total Tangible Costs $ _____ Intangible Costs Development/Management $ _____ Insurance $ _____ Legal/Other $ _____ Total Intangible Costs $ _____ Total $ _____ Cost per kWAC $ _____

As describe in Section 4906-4-04, the Applicant has not proposed alternative project areas. Therefore, no cost comparison between alternatives is available.

(2) Cost Comparison with Similar Facilities

Installed project costs compiled by the U.S. Department of Energy’s Lawrence Berkeley National Laboratory (Berkeley Laboratory) in September 2018 indicate that the capital costs of the Facility are in line with recent industry trends. The Berkeley Laboratory compilation shows that capacity-weighted average installed costs

in 2017 averaged roughly $2,000/kWAC (Bolinger and Seel, 2018).

By way of further comparison, installed solar project costs in the midwestern region in 2017 had a median of

around $1,900/kWAC (Bolinger and Seel, 2018). These costs are slightly higher than the average cost estimated for the Facility, which could be attributed to locational and system size differences. However, the estimated cost of the Facility is not substantially different from other Facilities completed by affiliates of the Applicant. The costs of solar energy facilities recently completed by affiliates of the Applicant in Georgia

averaged around $ _____ per kWAC.

(3) Present Worth and Annualized Capital Costs

Capital costs will include development costs, construction design and planning, equipment costs, and construction costs. The costs will be incurred within a year or two of start of construction. Therefore, a present worth analysis is essentially the same as the costs presented in Section 4906-4-06(B)(1) of this Application ($ ____ to $ ____). As alternative project areas and facilities were not considered in this Application, the capital cost information in this section is limited to the proposed Facility.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 26

(1) Estimated Annual Operation and Maintenance Expenses

For the first two years of commercial operation, staffing is estimated to be $ ___ per year. O&M costs are estimated at $ ____ per year, including staffing costs.

(2) Operation and Maintenance Cost Comparisons

O&M costs are a significant component of the overall cost of solar projects but can vary widely between facilities. The Berkeley Laboratory has compiled O&M cost data for 39 installed utility-scale solar power

projects in the United States, totaling 806 MWAC of capacity, with commercial operation dates of 2011 through 2017. In general, facilities installed more recently have incurred lower O&M costs. Specifically, capacity-

weighted average O&M costs for projects constructed in 2011 equal $31.6/kWAC-year. The O&M costs

dropped to $16/kWAC-year for projects installed in 2015, and to $15.8/kWAC-year for projects installed in the 2017 (Bolinger and Seel, 2018). According to the Berkeley Laboratory, this decrease could be the result of utility companies capturing economies of scale as their solar operations grow over time.

The O&M costs for the Facility are estimated to be approximately $ ___/kWDC-year, depending on the maturity of the project each year of its life cycle. These estimated O&M costs exclude any other ongoing expenses related to environmental monitoring, property taxes, land royalties, reverse power, and insurance. These costs will be consistent with the average costs compiled by the Berkeley Laboratory, as described above. The O&M costs for the Facility will be consistent with O&M costs at other solar energy facilities developed by

affiliates of the Applicant, which averaged approximately $ ___ /kWDC-year in the United States.

(3) Present Worth and Annualized Operation and Maintenance

The annual O&M costs itemized in Section 4906-4-06(C)(1) will be subject to real and inflationary increases. Therefore, these costs are expected to increase with inflation after the first two years. The net present value of the operation and maintenance costs per kW, assuming a 30-year Facility life, and inflation rate of ___%

and a ___% discount rate, is between $ ___ /kWAC and $ ___/kWAC. As alternative project areas and facilities were not considered in this Application, the O&M cost information in this section is limited to the Facility.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 27

(D) COST OF DELAYS

Monthly delay costs would depend on various factors. If the delay were to occur in the permitting stage, the losses would be associated with the time value of money resulting from a delay in the timing of revenue payments. This is estimated to be about $ ___ per month on average for the first year. If the delay were to occur during construction, costs would include lost construction days and those associated with idle crews and equipment. This is estimated to be approximately $ ___ to $ ___ per month.

There could also be penalties associated with failing to meet a delivery deadline under a potential Power Purchase Agreement. In addition, significant losses would be incurred if the delays prevented the Facility from meeting deadlines to qualify for the existing federal Investment Tax Credit. Prorating these delay costs monthly would not be meaningful, as the lost opportunity is triggered at a single deadline and does not accrue over time.

(E) ECONOMIC IMPACT OF THE PROJECT

Information provided in this section was obtained from the “Socioeconomic Report,” prepared by EDR (see Exhibit G). The proposed Facility is anticipated to have local and statewide economic benefits. Solar power development, like other commercial development projects, can expand the local, regional, and statewide economies through both direct and indirect means. Income generated from direct employment during the construction and operation phases of the project is used to purchase local goods and services, creating a ripple effect throughout the state and county. To quantify the local economic impacts of constructing and operating the Facility, the Photovoltaics Job and Economic Development Impact (JEDI) model (version PV12.23.16) was used, which was created by the NREL, a branch of the United States Department of Energy (USDOE). The JEDI model requires project-specific data input such as year of construction, size of project, module, and location, and calculates the impacts described above using state-specific multipliers. These multipliers account for the change in jobs, earnings, and output likely to occur throughout the local, regional, and statewide economy as a result of project-related expenditures. The most currently available 2017 IMPLAN multipliers for the state of Ohio were used during the time of analysis (IMPLAN, 2019). The multipliers are paired with industry standard values such as wage rates and data reflecting local personal spending patterns to calculate on-site, supply chain, and induced impacts (USDOE NREL, 2017). This model allows impacts to be estimated for both the construction and operation phases of the proposed development.

Applying input assumptions of varying levels of confidence, the JEDI model allows users to estimate the jobs, earnings, and economic development impacts from solar power generation projects for both the construction and operation phases (USDOE NREL, 2017). These economic development impacts include earnings and related

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 28

economic outputs from onsite jobs, local revenue and supply chain jobs, and induced jobs (see Part IV of Exhibit G for a description of impacts and indicators).

(1) Construction and Operation Payroll

Based upon JEDI model computations, it is anticipated that construction of the proposed Facility will directly generate employment of an estimated 534 full-time employee (FTE) on-site construction and project development positions with a projected wage rate of $21.39 per hour and 45.6% employer payroll overhead. The JEDI model estimated a total of $34.6 million for annual earnings of the 534 on-site construction jobs. The present worth of construction payroll, over the course of the first year of construction, is estimated to total $23.76 million. Module trade and supply chain industries could in turn generate an additional 252 jobs over the course of Facility construction. In addition, Facility construction could induce demand for 168 jobs through the spending of additional household income. The total impact of 954 new jobs could result in up to approximately $61.3 million of earnings, assuming a 2021 construction start and wage rates consistent with statewide and nationwide averages. The estimated national wage rate for solar photovoltaic installers is $22.12 per hour (U.S. Bureau of Labor Statistics, 2018). Local employment will primarily benefit those in the construction trades, including laborers and electricians. Facility construction will also require workers with specialized skills, such as panel assemblers, specialized excavators, and high-voltage electrical workers. It is anticipated that many of the highly-specialized workers will come from outside the area and will remain only for the duration of construction.

Based upon JEDI model computations, the operation and maintenance of the proposed Facility is estimated to generate 11 direct FTE jobs (e.g., two direct hires and nine contracted jobs) with estimated annual earnings of approximately $0.8 million. Wage rates for the direct operational employees are projected to be $21.39 per hour with 45.6% employer payroll overhead, consistent with Ohio state averages, which are estimated to be approximately $22 per hour for installation, maintenance, and repair occupations (U.S. Department of Labor, 2018). The present worth of operations payroll, over the course of the first year of operation, is estimated to total $476,055.

(2) Construction and Operation Employment

Demand for new jobs associated with the Facility will be created during both the initial construction period and the years following construction, in which the Facility is in operation. The money injected into the statewide economy through the creation of these jobs will have long-term, positive impacts on individuals and businesses in Ohio as it ripples through the economy.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 29

Jobs that will be created by the proposed Facility will include workers who will be directly employed to construct and subsequently operate and maintain the solar farm. A total of 534 FTE construction and 11 FTE operations jobs will be created. All operation jobs, and at least 80% (approximately 427) of the construction jobs, will be filled by Ohio residents. In addition, other jobs will be created that play a supportive role. The increased wealth from jobs and spending will have a ripple effect in the local economy, thereby creating the need for additional jobs in the area as the wages of local workers go towards supporting households and local businesses.

Module manufacturing and supply chain industries could in turn generate an additional 252 jobs over the course of Facility construction. In addition, Facility construction could induce demand for 168 jobs through the spending of additional household income. Based on the results of the model, the total impact of potentially 954 new jobs could result in up to $61.3 million of earnings, assuming a 2021 construction schedule and wage rates consistent with statewide and national averages.

Operations and maintenance should also generate new jobs in other sectors of the economy through supply chain impacts and the expenditure of new and/or increased household earnings. Increased employment demand throughout the supply chain is estimated to result in approximately 4 jobs with annual earnings of approximately $0.2 million. In addition, it is estimated using the JEDI model and NREL data that 10 jobs with associated annual earnings of $0.6 million will be induced through the increased household spending associated with Facility operations. In total, while in operation, this Facility is estimated to generate demand for 25 jobs per year with annual earnings of approximately $1.6 million. Total economic output could also increase by an estimated $3.3 million as a result of Facility operations and maintenance.

(3) Local Tax Revenues

The proposed Facility will have a significant positive impact on the local tax base, including local school districts and other taxing districts that service the area where the proposed Facility is to be located. Taxing districts within the Project Area include two townships (Fairfield and Oak Run) in Madison County, and one school district (Madison-Plains Local School District).

Solar energy projects in the state of Ohio can be exempted from tangible personal property and real property tax payments if they meet certain conditions. If an applicant is granted exemption from taxation for any of the tax years 2011 through 2023, the Qualified Energy Project will be exempt from taxation for tax year 2024 and all ensuing years, as long as the property was placed into service before January 1, 2024. The amount of

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 30

Payment In Lieu Of Taxes (PILOT) to be paid annually to the County treasurer is assessed per MW of nameplate capacity, with the rate of $7,000/MW. County commissioners may require an additional $2,000/MW service payment payable to the County treasurer. Assuming an aggregate nameplate capacity of 196 MW, the increase in local tax revenues will be at least $1.372 million annually for the Facility, and up to $1.764 million annually, including the possible additional service payment.

(4) Economic Impact on Local Commercial and Industrial Activities

Solar power development can expand the local economy through ripple effects. Ripple effects stem from subsequent expenditures for goods and services made by first-round income from the development. A direct effect or impact arises from the first round of buying and selling. Direct effects include the purchase of inputs from local sources, the spending of income earned by workers, annual labor revenues, and the income effect of taxes. These direct effects can be used to identify additional, subsequent rounds of buying and selling for other sectors and to identify the effect of spending by local households. The indirect effect or impact is the increase in sales of other industry sectors in the region, which include further round-by-round sales. The induced effect or impact is the expenditure generated by increased household income resulting from direct and indirect effects. The total effect or impact is the sum of the direct, indirect, and induced effects.

The proposed Facility will have a beneficial impact on the local economy. In addition to jobs and earnings, the construction of the Facility is expected to have a positive impact on economic output, a measurement of the value of goods and services produced and sold by backward-linked industries. Economic output provides a general measurement of the amount of profit earned by manufacturers, retailers, and service providers connected to a given project. The value of economic output associated with Facility construction is estimated in the “Socioeconomic Report” to be $123.3 million. Between workers’ additional household income and industries’ increased production, the impacts associated with the Facility are likely to be experienced throughout many different sectors of the statewide economy.

(F) PUBLIC RESPONSIBILITY

In presenting the Facility to the public, the Applicant has presented the maximum extent of the Facility. As described above, changes to the current Facility layout may occur as Facility design progresses but any such changes will not alter the maximum extent of the Facility, will not require the leasing of additional properties, and would not impact new property owners or create additional impacts for existing adjacent property owners.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 31

(1) Public Interaction

The Applicant has and will continue to make general information about solar power and specific information about the proposed Facility available to community members, elected officials, the media, and local civic organizations. Information has been shared through, among other activities, local public informational meetings held at Fairfield Township Hall on October 22, 2019, from 6:00 PM to 8:00 PM and March 4, 2020, from 6:00 PM to 8:00 PM; official Board of Trustee and Planning Board meetings; and presentations to the Madison-Plains school district leaders, Soil and Water Conservation District, and Oak Run and Fairfield townships. Prior to the local public information meetings, notices were sent out via first class mail and circulated in the Madison Messenger. Notice for the October 22, 2019 meeting was mailed on September 28, 2019 to landowners and published in the Madison Messenger on October 13, 2019. Notice for the public informational meeting held on March 4, 2020 was mailed to landowners on February 10, 2020 and published in the Madison Messenger on February 23, 2020. Representatives of the Applicant have been responsive to questions and requests by local media and will continue to be responsive.

A complaint resolution procedure will be implemented to ensure that any complaints regarding Facility construction or operation are adequately investigated and resolved. Once construction begins, a hotline will be set up to receive and formally document all complaints, which will then be investigated by onsite Facility staff. At least seven days prior to the start of construction, the Applicant will notify affected property owners and tenants of the approved Complaint Resolution Plan and other sources of information about the Facility. A Complaint Resolution Plan is attached hereto as Exhibit N. Any updates to the Complaint Resolution Plan will be provided to Staff before construction begins.

(2) Liability Insurance

The Applicant will acquire and maintain throughout the term of the Facility, at its sole cost, insurance against claims and liability for personal injury, death, and property damage arising from operation of the Facility. The insurance policy or policies will insure the Applicant to the extent of their interests. The limits of the insurance policy described will, at a minimum, insure against claims of $1,000,000 per occurrence and $2,000,000 in the aggregate. In addition, the Applicant shall acquire and maintain throughout the construction operation, and decommissioning period, at its sole cost, Umbrella Coverage against claims and liability for personal injury, death, and property damage arising from the operation of the Facility. The limits of the excess liability insurance will, at a minimum, insure against claims of $10,000,000 per occurrence and $10,000,000 in the aggregate.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 32

(3) Roads and Bridges

Information provided in this section was obtained primarily from the “Route Evaluation Study” prepared by Hull & Associates, Inc. (Hull), attached hereto as Exhibit E. The study identifies probable delivery and transportation routes to the Project Area, evaluates existing characteristics of the roadways and bridges, describes the anticipated impacts to roads and bridges from construction vehicles and equipment delivery, and identifies mitigation measures to address potential impacts. Specific to constraints, the “Route Evaluation Study” identifies roadway limitations for load, pavement width, pavement condition, and overhead restrictions.

Construction/Delivery Vehicles: During the construction phase of the Facility, impacts to local traffic are anticipated to be minimal. Construction traffic will consist of standard construction equipment and hauling trucks to deliver Facility components. Most Facility components will be delivered to the Project Area using flatbed or tractor-trailer vehicles and multi-axle dump trucks. In addition, typical automobiles and pickup trucks will be used to transport construction staff and for other incidental truck trips. Most of the vehicles will be of legal weight and dimensions; however, some overweight/oversized (OW/OS) vehicles will be required for the delivery of some components like the switchgear or transformer for the substation. OW/OS vehicles are special hauling vehicles with unique lengths, widths, heights, and weights depending on the component being transported.

The transportation provider (i.e., hauling contractor) delivering the Facility components will further evaluate all primary, secondary, and tertiary roadways prior to construction as part of the Special Hauling Permit process or pursuant to any Road Use Maintenance Agreement (RUMA). A Special Hauling Permit is required for vehicles and/or loads that exceed the legal maximum dimensions or weights specified by Special Hauling Permit Section of the Ohio Department of Transportation (ODOT). Each overweight or oversized vehicle must receive a separate Special Hauling Permit from ODOT for hauling across state routes and from those counties, townships, and municipalities whose roadways will be affected, as set forth in ORC 4513.34. The specifications of the Special Hauling Permit depend on the characteristics of the vehicle, its cargo, and the duration of the delivery schedule. See Section 4906-4-06(F)(4) below for further discussion on transportation permits.

Delivery Route: Delivery routes have not been finalized, but it is likely that the delivery of Facility components to the Project Area will be from the south by way of Interstate 71 and SR 56 or from the north by way of the same routes. The majority of the Project Area will be accessed using Big Plain Circleville Road (CR 4), with other recommended routes, including Glade Run Road (CR 70) and Hume Lever Road (Township Road [TR] 70), used less frequently. Within the Project Area, several county and township roads and new gravel access

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 33

roads will likely be used for transportation. Roads surrounding the Project Area experience limited levels of traffic, so significant changes to traffic levels are not anticipated. In order to manage traffic during construction, a Traffic Management Plan will be prepared and shared with local law enforcement, schools, and local landowners, outlining management procedures.

Hull conducted a visual analysis of bridges and culverts along potential transportation routes for the Facility to identify hazardous conditions. No load restriction signs were posted for bridges along the proposed transport routes. Two bridges, one along Big Plain Circleville Road (ODOT Bridge No. 4930053) and one along Glade Run Road (ODOT Bridge No. 4932269) were recorded as showing signs of deterioration in the concrete structure; however, bridge abutments and deck surfaces appeared in good condition. Culverts along Hume Lever Road, Glade Run Road, McGuire Road, and West Jefferson Kiousville Road were described as showing signs of stressed pavement; however, the overall condition of these roads was categorized between ‘good’ (i.e., pavement appears stable with minor cracking) and ‘fair’ (i.e., pavement appears stable but may have a high amount of cracking, especially at the pavement edge; potholes may be present). No additional culverts were identified in the “Route Evaluation Study” as having structural issues.

During the “Route Evaluation Study,” Hull investigated the state routes for height limitations. Along the potential routes, permanent structures that cross over roads and restrict clearance for oversized loads such as bridges and overpasses were not identified. Additionally, no overhead cables deemed obstructive were identified along routes. If an overhead feature presents an obstruction, utility providers can temporarily or permanently raise the cable and/or move the poles. Cables are not anticipated to be a limiting feature for road usage.

Impacts and Mitigation: Impacts to traffic levels are anticipated to be minimal as a result of the construction and operation of the Facility. Current traffic levels on local roads surrounding the Project Area are generally low. As previously stated, a Traffic Management Plan will be prepared which outlines procedures used to manage traffic during construction. Increased traffic during the operation of the Facility is not anticipated.

Impacts to road conditions are anticipated to be minimal. All construction equipment and vehicles will meet current legal dimensions and weights, except for a few oversized and overweight (OS/OW) vehicles required for transporting switchgear and transformer components for the substation. Those OS/OW vehicles will require the use of a Special Hauling Permit. During the construction phase, roads will be monitored for deterioration to ensure they are safe for local traffic. If damage to roadways occurs, it will be repaired, and all

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 34

such improvements will be first approved by the relevant public authority and identified in any RUMAs or Final Transportation Routing Plan.

Prior to construction, the selected transportation provider will obtain all necessary permits from ODOT, the Madison County Engineer, and any affected townships (see Section 4906-4-06(F)(4) below for further discussion on transportation permits). All public upgrades that may be required to accommodate construction vehicles will be identified as part of the Final Transportation Routing Plan, or any RUMAs, based on the routes selected. The following mitigation techniques may be utilized to avoid or minimize transportation-related impacts and/or to provide long-term improvement to the local road system:

Insufficient Roadway Width • Rerouting over-width vehicles to wider roadways.

Insufficient Vertical Clearance • Temporarily relocating overhead utility lines and poles. • Rerouting over-height vehicles to roadways with sufficient vertical clearance.

Poor Pavement Condition or Insufficient Pavement Durability • Roadside drainage improvement. • Pavement patching. • Replacing pavement prior to construction (may include subgrade improvements). • Replacing pavement during or after construction if damaged by construction traffic (may include subgrade improvements). • Rerouting heavy-loaded vehicles to avoid insufficient pavement.

Insufficient Cover over Drainage Structures • Adding temporary gravel and/or asphalt cover over structures. • Using bridge jumpers to clear structures. • Repairing structures during or after construction if damaged by construction traffic. • Rerouting heavy-loaded vehicles to avoid structures.

Poor Structure Condition • Replacing structure during or after construction if damaged by construction traffic. • Using bridge jumpers to clear structures.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 35

• Rerouting heavy-loaded vehicles to avoid structures.

Inadequate Bridge Capacity • Using bridge jumpers to clear bridges. • Rerouting heavy-loaded vehicles to avoid bridges.

Insufficient Roadway Geometry • Rerouting over-sized vehicles to avoid insufficient roadway geometry. • Profile adjustments to roadways with insufficient vertical geometry. • Permanent or temporary plan adjustments to roadways with insufficient horizontal geometry.

Based on information collected during the “Route Evaluation Study” field investigation, delivery vehicle assumptions, and information available from ODOT, suitable infrastructure exists via primary and secondary roads to transport the Facility components to the Project Area. Once a final Facility layout is complete and final vehicle characteristics are determined, transportation plans will be finalized with the Madison County Engineer. Construction plans will be prepared if necessary, for any roadway or intersection improvements in accordance with any RUMAs or the Final Transportation Routing Plan. All work on public roads will be coordinated and approved by the appropriate public authority prior to construction.

(4) Transportation Permits

Prior to construction, the selected transportation provider will obtain all necessary permits from ODOT, the Madison County Engineer, and township officials. A minimal number of permits are anticipated for the construction and operation of this Facility due to the limited number of OS/OW vehicles proposed for use and the lack of road improvements for transportation purposes. Although no damage is anticipated, as discussed above, if any public roads are damaged by actual construction or construction-related traffic, the Applicant will restore the roadway consistent with any RUMAs, and permit conditions.

ODOT Special Hauling Permits are required when loads exceed legal dimensions or weights. Transportation of switchgears and transformers for the substations will require Special Hauling Permits for a variety of criteria. Each vehicle must receive an individual Special Hauling Permit from the ODOT Central Office, as the specifications of the permit depend on the characteristics of the vehicle, its cargo, and duration of the delivery schedule. Table 06-2 presents the criteria for vehicles not requiring a Special Hauling Permit.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 36

Table 06-2. Criteria for Vehicles Without Special Hauling Permits State State Highway Vehicle Highway Limit with Special Characteristic Limit Hauling Permit Width of vehicle, 8.5 feet None inclusive of load Height of vehicle, 13.5 feet None inclusive of load Length of vehicle, inclusive of load 85 feet None and bumpers Total Weight of 80,000 vehicle with 3 or None pounds more axels

Based on the criteria in Table 06-2, construction of the Facility will require Special Hauling Permits based on the height and weight for a few components.

In addition to coordinating with state, county, and township authorities to obtain transportation permits, the Applicant will also coordinate with appropriate authorities for temporary or permanent road closures, lane closures, road access restrictions, and traffic control necessary for construction and operation of the proposed facility. There are locations along the identified routes where component delivery vehicles and construction traffic will cross into opposing lanes of traffic. Maintenance of traffic will be addressed with the assistance of law enforcement officers, escorts, and/or flaggers. Final transportation plans will be provided to the government agencies prior to the start of the Project, and all road work will be coordinated with the appropriate regulatory agency prior to construction.

(5) Decommissioning

Utility-scale solar facilities typically have a life expectancy of 30 to 40 years. If panels or ancillary equipment were to fail before the useful lifetime of the Facility, they will be replaced with operational components. However, if not upgraded, or if large solar arrays are non-operational for an extended period of time, such that there is no expectation of their returning to operation, they will be decommissioned. The Applicant’s plan for decommissioning is comprised of two primary components: removal of Facility components/improvements and financial assurance. Each of these is described in additional detail below.

Removal of Facility Improvements At the termination of the lease, the Applicant will dismantle and remove Facility components and above-ground property owned or installed by the Applicant. Below-ground structures, such as buried interconnect lines, will

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 37

be removed to a minimum depth of 36 inches. Any underground infrastructure installed at a greater depth will remain in place. If necessary, the Applicant will re-grade disturbed areas, restoring slopes and contours to their original grade, to the extent possible. Upon request of the landowner, the Applicant may consider allowing roads, foundations, buildings, structures, or other improvements to remain in place. However, the Applicant will not be obligated to leave any components or improvements and will only consider such action so long as it does not violate any permits or legal requirements.

Financial Assurance The Applicant, through this application, is committing to provide financial assurances for Facility decommissioning and reclamation. Specifically, six months prior to the beginning of the tenth year of each lease’s term, the Applicant will retain an independent demolition contractor with solar experience to provide a good faith estimate of the total cost to decommission the Facility including restoring any changes made to the property (the Reclamation Estimate). The Reclamation Estimate will not include an offset for the salvage vale of the Facility. No later than the beginning of the tenth year of each lease’s term, the Applicant will deliver to the property owner a payment bond or a letter of credit issued by a credit worthy bonding company or financial institution, as applicable, in an amount equal to one hundred ten percent (110%) of the Reclamation Estimate, less any other financial assurance that the Applicant has provided to any government agency for restoration of the property covered by the lease.

A draft decommissioning plan is provided as Exhibit O. An updated plan will be provided to OPSB Staff prior to construction.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-06 – Page 38

4906-4-07 COMPLIANCE WITH AIR, WATER, SOLID WASTE, AND AVIATION REGULATIONS

(A) PURPOSE

This section provides environmental data regarding air, water, and solid waste in terms of current site conditions, potential impacts of the proposed Facility, and any proposed mitigation measures. The Applicant will comply with regulations for air and water pollution, solid and hazardous wastes, and aviation.

(B) AIR

(1) Preconstruction

(a) Ambient Air Quality PV panels generate electricity without releasing pollutants into the atmosphere. Therefore, air quality background information is not required for the proposed Facility.

(b) Air Pollution Control Equipment PV panels generate electricity without releasing pollutants into the atmosphere. Therefore, air pollution control equipment is not required for the proposed Facility.

(c) Air Quality Standards and Limitations In accordance with Section 111 of the Clean Air Act Extension of 1970, the U.S. EPA established New Source Performance Standards (NSPSs) to regulate emissions of air pollutants from new stationary sources. The OAC does not contain any NSPS regulations for the Project Area beyond those promulgated at the federal level. These standards apply to a variety of facilities including landfills, boilers, cement plants, and electric generating units fired by fossil fuels. Because PV panels generate electricity without releasing pollutants into the atmosphere, NSPSs do not apply to the proposed Facility.

The Clean Air Act, as amended by the Clean Air Act amendments of 1990, requires the U.S. EPA to set NAAQSs (40 CFR part 50) for pollutants considered harmful to public health and the environment. As described above, the closest monitoring station is in Franklin County.

All new sources of air emissions in Ohio are required to obtain a Permit to Install (PTI) for Title V facilities, or a Permit to Install and Operate (PTIO) for non-Title V facilities. Because PV panels generate electricity without releasing pollutants into the atmosphere, the proposed Facility will not require a PTI or PTIO.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 39

Administered by the U.S. EPA, the Acid Rain Program was established by the Clean Air Act Amendments

of 1990 to reduce emission of SO2 and nitrous oxide (N2O) through regulatory and market-based approaches. Because PV panels generate electricity without releasing pollutants into the atmosphere, the proposed Facility will not require an acid rain permit.

Prevention of Significant Deterioration (PSD) applies to new major sources of pollutants, and/or major modifications at existing sources for pollutants that are located in an attainment area or unclassifiable with the NAAQSs. The proposed Facility will not be a major source of any pollutants. Therefore, PSD does not apply.

(d) List of Required Air Pollution Permits PV panels generate electricity without releasing pollutants into the atmosphere. Therefore, the Applicant will not need any air pollution permits for the proposed Facility.

(e) Air Quality Map The proposed Facility is a renewable energy project that will not produce any air pollution. Therefore, an air quality map is not required for the proposed Facility.

(f) Compliance with Permits and Standards As indicated above, PV panels generate electricity without releasing pollutants into the atmosphere. Therefore, no air pollution permits are required. However, fugitive dust rules adopted pursuant to the requirements of ORC Chapter 3704 may be applicable. The Applicant will control fugitive dust using several practices, as described in Section 4906-4-07(B)(2).

(2) Plans to Control Air Quality During Site Clearing and Construction

Best management practices will be utilized and implemented to minimize the amount of dust generated by construction activities. The extent of exposed or disturbed areas on the site at any one time will be minimized and restored or stabilized as soon as possible. Water or a dust suppressant such as calcium carbonate will be used to suppress dust on unpaved roads (public or agricultural roads, as well as Facility access roads) as needed throughout the duration of construction activities. Any unanticipated construction-related dust problems will be identified and immediately reported to the construction manager and contractor. In addition, all construction vehicles will be maintained in good working condition to minimize emissions from construction- related activities.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 40

(3) Plans to Control Air Quality During Facility Operation

The proposed Facility is a renewable energy project that will not produce any air pollution. In fact, the Facility may lead to improvements in air quality by reducing the need for traditional energy systems that negatively contribute to air pollution. Therefore, this requirement does not apply to the proposed Facility.

(1) Preconstruction

(a) List of Required Permits to Install and Operate the Facility Prior to the start of construction, the Applicant will obtain the following permits: • The Ohio National Pollutant Discharge Elimination System (NPDES) construction storm water general permit, Ohio EPA Permit No. OHC000005 • An individual permit or nationwide permit under Section 404 of the Clean Water Act, (if necessary) • A Water Quality Certification from the Ohio EPA (if necessary) • An Ohio Isolated Wetland Permit (if necessary)

(b) Water Quality Map The Facility will not discharge water or waste into streams or water bodies, nor will Facility operation require the use of water for cooling or any other activities. Furthermore, the Facility will add only small areas of impervious surface, primarily for the substation, and will have a negligible effect on surface water runoff and groundwater recharge. Therefore, measurable impacts on the quality of surrounding water resources are not anticipated. Since there are no bodies of water likely to be affected by the proposed Facility, this section is not applicable.

(c) Description of Water Monitoring and Gauging Stations As described above in Section 4906-4-07(C)(1)(b), there are no bodies of water likely to be significantly affected by the proposed Facility. Therefore, this section is not applicable.

(d) Existing Water Quality of Receiving Stream The Facility will not discharge water or waste into streams or water bodies. Therefore, there will be no receiving streams and this section is not applicable.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 41

(e) Permit Application Data The Facility will not discharge any water. Therefore, this section is not applicable.

(2) Construction

(a) Water Quality Map As described above in Section 4906-4-07(C)(1)(b), measurable impacts on the quality of surrounding water resources are not anticipated. Since there are no bodies of water likely to be affected by the proposed Facility, this section is not applicable.

(b) Quantity/Quality of Construction Runoff The proposed Facility will not result in wide-scale conversion of land to impervious surfaces. While PV panels themselves are impervious, they are disconnected from the ground surface so rain can runoff the panel and fall onto the pervious underlying surface. The collection substation and access roads are the only source of impervious surfaces within the Facility and are anticipated to generate minimal runoff. Therefore, no significant changes to the rate, make-up, or volume of storm water runoff are anticipated.

Construction of the proposed Facility will have minimal, localized impacts to groundwater. Site-specific studies are ongoing to determine the extent of grading required for the Facility. Soil compaction from the use of construction equipment could limit the efficiency of surface water infiltration to groundwater. When soils are compressed, pore spaces within the soil are decreased, which reduces water percolation. Construction of access roads will result in minor increases in storm water runoff that otherwise would have infiltrated into the ground at the road locations.

Additionally, as a result of accidental discharge of petroleum or other chemicals during construction, pollutants have the potential to impact groundwater. Such discharges could occur in the form of leaks from fuel and hydraulic systems, or as more substantial spills that could occur during refueling of vehicles or other accidents. As described below, a Spill Prevention and Response Plan has been prepared which outlines procedures to be implemented to prevent the release of hazardous substances into the environment (Exhibit P).

(c) Mitigation As described above, construction of the proposed Facility is not anticipated to have any significant impacts to water quality. However, the following mitigation measures will be taken to ensure that impacts

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 42

to groundwater, surface waters, and wetlands are avoided or minimized to the maximum extent practicable during Facility construction.

As mentioned in Section 4906-4-07(C)(1)(a), the Facility will require a NPDES Construction Storm Water General Permit (OHC000005) from the Ohio EPA. This permit is required for all construction sites disturbing 1.0 or more acres of ground. To obtain this permit, the Applicant will develop a Storm Water Pollution Prevention Plan (SWP3) and file a Notice of Intent (NOI) letter with the Ohio EPA at least 21 days prior to the commencement of construction activities.

The SWP3 will address all minimum components of the NPDES permits and conform to the specifications of the Rainwater and Land Development manual, which describes Ohio’s standards for storm water management, land development, and urban stream protection (ODNR, 2006). The SWP3 will identify potential sources of pollution that may reasonably be expected to affect the quality of storm water discharges associated with construction activities. If applicable, the SWP3 will clearly identify all activities that will be authorized under Section 401 of the Clean Water Act and be subject to an anti-degradation review. The SWP3 will also describe and ensure the implementation of best management practices that reduce pollutants in storm water discharges during construction.

In addition to the SWP3, a Spill Prevention and Response Plan was prepared and outlines procedures to be implemented to prevent the release of hazardous substances into the environment. This plan outlines requirements for vehicle fueling, spill kits, hazardous material storage, and spill response procedures. Any spills will be reported in accordance with federal and Ohio EPA Division of Emergency and Remedial Response regulations.

Topsoil removal and de-compaction will occur in agricultural areas, which constitute most of the Facility footprint. These practices will also mitigate any potential impacts that soil compaction could have on infiltration of rain and snowmelt, thereby further reducing any potential impact to groundwater recharge. The construction footprint will be minimized by delineating the work area in the field prior to construction and adhering to work area limits during construction. These measures will limit potential impacts of soil compression on normal infiltration rates.

On-site investigations were conducted to establish the locations of streams and wetlands, and Facility components were sited to avoid impacts to these resources to the maximum extent practicable. Impacts to surface waters have been minimized through the use of overhead collection lines and feature

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 43

avoidance. Equipment restrictions, herbicide use restrictions, and erosion and sediment control measures will also be utilized to reduce adverse impacts to water quality, surface water hydrology, and aquatic organisms. In addition, vegetation clearing along stream banks and in wetland areas will be kept to a minimum. For more information on mitigation measures to protect wetlands and surface water see Section 4906-4-08(B)(2)(b).

(d) Changes in Flow Patterns and Erosion As a result of the limited impacts discussed in Section 4906-4-07(C)(2)(b) and the mitigation measures discussed above in Section 4906-4-07(C)(2)(c), changes to flow patterns are not anticipated.

(e) Equipment for Control of Effluents Facility operation will not involve the discharge of effluents into streams or water bodies. Therefore, this section is not applicable.

(3) Operation

(b) Water Pollution Control Equipment and Treatment Processes The Facility will not require any water pollution control equipment or treatment processes. Therefore, this section is not applicable.

(c) NPDES Permit Schedule As mentioned above, Facility construction will require an Ohio NPDES construction storm water general permit, Ohio EPA Permit No. OHC000005. The Applicant anticipates full and complete compliance with this permit. The NOI and associated fee for the Construction Activities General Permit will be filed at least 21 days prior to commencement of construction activities.

(d) Quantitative Flow Diagram As explained in the following sub-sections, flow diagram information is not applicable to the proposed Facility.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 44

(i) Sewage The proposed Facility will not generate any sewage.

(ii) Blow-down This section is not applicable, as PV panels do not utilize blow-down equipment.

(iii) Chemical and Additive Processing The proposed Facility will not require the use of chemical and/or additive processing. Therefore, this section is not applicable.

(iv) Wastewater Processing The proposed Facility will not process or generate wastewater. Therefore, this section is not applicable.

(v) Run-off and Leachates from Fuels and Solid Wastes The Facility is not expected to generate any run-off or leachates. Therefore, this section is not applicable.

(vi) Oil/water Separators This section is not applicable because the Facility will not utilize any oil/water separators.

(vii) Run-off from Soil and Other Surfaces Following completion of construction, temporarily impacted areas will be stabilized and restored to their preconstruction condition. Facility operation will not result in further soil disturbance, aside from occasional repair activities. Therefore, this section is not applicable.

(e) Water Conservation Practices Aside from very limited quantities of water that may be used for the occasional cleaning of solar panels, no on-site Facility components requiring water sources, such as an office space, are planned for the Facility. In addition, a study supported by the NREL demonstrates that water use is lower for PV panels than other generation technologies (Meldrum, et al., 2013). Therefore, water conservation practices are not applicable.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 45

(D) SOLID WASTE

(1) Preconstruction

(a) Nature and Amount of Solid Waste The Applicant is not aware of any debris or solid waste within the Project Area that would require removal for Facility development.

(b) Plans for Waste Removal No waste removal is necessary or planned for Facility development.

(2) Construction

(a) Nature and Amounts of Solid Waste during Construction Facility construction will generate minimal solid waste, primarily plastic, wood, cardboard and metal packing materials, construction scrap, and general refuse. The amount of construction waste generated will be minimal.

(b) Methods for Storage and Disposal of Solid Waste during Construction Construction waste will be collected from PV panel installation sites and other Facility work areas and disposed of in dumpsters located at the laydown yard. A private contractor will empty the dumpsters on an as-needed basis and dispose of the refuse at a licensed solid waste disposal facility. Waste materials will be recycled when possible. Used oil, used antifreeze, and universal waste, if any, will be handled, managed, and disposed of in accordance with federal, state, and local regulations.

(3) Operation

(a) Nature and Amounts of Waste Facility operation will not result in significant generation of debris or solid waste.

(b) Methods for Storage and Disposal of Waste As described above, Facility operation will not result in generation of debris or solid waste. Therefore, this section is not applicable.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 46

(4) Licenses and Permits

Facility operation will not require acquisition of waste generation, storage, treatment, transportation, and/or disposal licenses or permits.

(E) COMPLIANCE WITH AVIATION REGULATIONS

(1) Aviation Facilities List and Map

There are no public or private use airports, helicopter pads, or landing strips within five miles of the proposed Facility. Therefore, this section is not applicable.

(2) FAA Filing Status and Potential Conflicts

The Federal Aviation Administration (FAA) conducted an aeronautical study for structures that will support overhead collection lines, which will stand 60 feet tall. These are the tallest features of the Facility. The FAA can issue two types of determinations, one that identifies a hazard and another that identifies no hazard. The FAA issued determinations of no hazard for the Facility on September 18, 2019 (Exhibit Q).

Given that no airports, helicopter pads, or landing strips are located within 5 miles of the Facility, impacts from glare are not anticipated. Moreover, solar facilities are located at major airports, including a 33-panel array at the John Glenn Columbus International Airport, a 20 MW ground-mounted array at the Indianapolis International Airport, and the 159,200-panel, 12 MW Wyandot Solar Farm in Upper Sandusky, Ohio that straddles the runway of the Wyandot County Airport.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-07 – Page 47

4906-4-08 HEALTH AND SAFETY, LAND USE, AND ECOLOGICAL INFORMATION

The Applicant has used worst-case impact area assumptions for all project components; therefore, as detailed project design decisions are finalized, these impact calculations will remain the same or decrease.

(A) HEALTH AND SAFETY

(1) Equipment Safety and Reliability

(a) Major Public Safety Equipment To prevent unauthorized entrance to the Project Area, safety measures will be employed during the construction and operation phases. During Facility construction, temporary, highly-visible mesh fencing will be used around Facility components and staging and storage areas. Signage will be utilized around the Project Area during construction, warning of the potential dangers within the site and discouraging entrance by the public. Personnel exposed to public vehicular traffic shall be provided with and shall wear warning vests or other suitable reflective or high-visibility garments. Similar signage will be utilized at the Facility during operation, along with perimeter fencing. During operation, security at the Facility will be maintained by a combination of perimeter security fencing, controlled access gates, electronic security systems, and potentially remote monitoring. Though the public will not have open access to the Facility, once construction is complete, the Facility may be available for guided tours at specific times.

(b) Equipment Reliability Equipment reliability is an important criterion when selecting solar equipment. The Applicant will only select reliable, certified equipment for all Facility components, including but not limited to PV modules, inverters, racking systems, wiring, and transformers. All equipment will follow applicable industry code(s) (e.g., Institute of Electrical and Electronics Engineers [IEEE], National Electric Code [NEC], National Electrical Safety Code [NESC], American National Standards Institutes [ANSI]).

The Applicant is advantageously positioned compared to other solar development companies because it is a wholly-owned subsidiary of First Solar, Inc., which develops, manufactures, and sells PV modules and is a global leader in PV energy. Due to the solar industry’s rapid innovation cycles, PV technology relies on independent laboratory-accelerated testing protocols to determine the suitability and performance of modules in the field. First Solar modules are tested to multi-stress variables via third party extended module reliability certifications (e.g., Thresher, Long Term Sequential, Atlas 25+). The results from these tests prove First Solar’s module technology to be a best-in-class product on the market

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 48

backed by a 25-year module warranty. Reliability certifications are all publicly available on First Solar’s solar module datasheets accessible on First Solar’s official website (http://www.firstsolar.com/Modules/Series-4 and http://firstsolar.com/en/Modules/Series-6). The PV modules used for the Facility may be produced by First Solar; however, there may be modules from another manufacturer ultimately utilized.

(c) Generation Equipment Manufacturer’s Safety Standards and Setbacks Exhibit B, for which the Applicant has requested confidential treatment through a motion of protective order, includes user guides for two PV modules under consideration for the Facility, First Solar’s Series 4 and Series 6 modules. These manuals include module specifications, installation information, and safety aspects. While the manuals do not include setbacks, internal setbacks, defined by the Applicant, are discussed in Section 4906-4-08(C)(2) of this application.

(d) Measures to Restrict Public Access The public does not have access to the private land on which the Facility is located; hence, the public would only encounter the proposed Facility by trespassing. However, to further restrict public access, a 9-foot chain link security fence will be constructed around the Facility. During operation, security of the Project Area will be maintained by a combination of perimeter security fencing, controlled access gates, electronic security systems, and potentially remote monitoring. Additionally, “No Trespassing” and “High Voltage Equipment” signs will be placed around the fence perimeter, warning the public of the potential hazards within the fenced Project Area.

(e) Fire Protection, Safety, and Medical Emergency Plans The Applicant has met with Madison County Emergency Services, including local fire and EMS officials, to discuss safety plans and training protocol. The Facility will contain 9-1-1 boxes at each entrance, allowing emergency personnel to enter the site. An example Emergency Action Plan is included as Exhibit R. This plan will be finalized based on ongoing coordination with Madison County Emergency Services and will be submitted to OPSB Staff prior to Facility construction.

(2) Probable Impacts due to Failures of Pollution Control Equipment

Solar panels generate electricity without combusting fuel or releasing pollutants into the atmosphere. Therefore, this section is not applicable.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 49

(3) Noise

Hessler Associates, Inc. (Hessler) was retained by the Applicant to evaluate potential noise impacts from the proposed Facility (see Exhibit H). The study consists of 3 phases: (1) a background sound level survey, (2) modeling of future sound levels for the substation transformer and inverters, and (3) analysis of potential sound levels during construction.

(a) Construction Noise Levels at the Nearest Property Boundary Noise from construction activities associated with the Facility is likely to temporarily constitute a moderate, unavoidable impact at nearby residents adjacent to the Project Area. However, typical sources of noise during construction of a solar facility only includes the installation of the mounting posts for the panel racks, some trenching, and road building. Construction activities for a solar facility, and resulting sound levels, are minimal compared to conventional fossil fuel projects, which would require extensive earthwork and concrete pouring, lasting for a period of months. Table 08-1 estimates sound levels from construction equipment based on the construction phase and distance from such activities. Distances in the table below are representative of the typical distance between construction activities and the nearest residences and guidelines from the U.S. Department of Transportation and Federal Highway Administration.

Table 08-1. Typical Construction Equipment Sound Levels During Construction Typical Estimated Estimated Estimated Sound Maximum Total Maximum Total Maximum Total Equipment/Phase Level at 50 Level at 50 Level at 500 Level at 4,000 Feet1 (dBA) Feet (dBA) Feet2 (dBA) Feet3 (dBA) Dozer (Earthmoving Phase) 85 85 63 38 Front End Loader (Earthmoving 80 85 63 38 Phase) Grade (Earthmoving Phase) 85 85 63 38 Backhoe (Earthmoving Phase) 80 85 63 38 Vermeer PD10 Pile Driver 84 84 62 37 (Pile Driving Phase) Flatbed Truck (Material Delivery and 84 84 62 37 Installation Phase) 1 A standard testing distance according to the Federal Highway Administration. 2 A distance of 500 feet generally represents the nearest approach of any construction activity to neighboring homes. This provides an estimate of the worst-case scenario. 3 A distance of 4,000 feet represents anticipated sound levels experiences with construction near the center of the Facility.

Sound levels from construction equipment (including pile driver and earth moving equipment) at the nearest non-participating property boundaries may be temporarily produced at levels as high as 85 dBA

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 50

for a very short duration and only during daytime construction hours. As construction moves away from the property boundary, sound levels will decline. Concrete pump trucks and servicing mixers, required for installation of the substation, are another source of sound during the construction phase. This equipment typically produces a sound level of about 82 dBA at 50 feet. The nearest residence is located over 3,200 feet from the substation location and would experience a sound level of 38 dBA or less. The process of laying concrete for the substation will also be short-lived (likely for one or two days).

Note that construction activities in general, when occurring at the interior of the Project Area, are anticipated to result in a sound level of 40 dBA at the Facility’s perimeter. Some noise may be audible at longer distances, particularly during the concrete delivery and the pile-driving phase. During construction, it may be possible to hear metallic impact sounds for some distance. This sound will be short-lived and would proceed quickly (a period of days or weeks) in any one area of the Project Area. No blasting is anticipated for the construction of this Facility.

(b) Operational Noise Levels at the Nearest Property Boundary (i) Operational noise from generation equipment Operational noise levels were modeled for the transformer and inverters, using the preliminary layout (see Exhibit H). Final models for this equipment have yet to be decided, so conservative, typical models used in solar facilities were chosen for the analysis. Using empirically-derived algorithms from the “Electric Power Plant Environmental Noise Guide” published by Edison Electric Institute in 1984, sound power levels were estimated for a 127/168/210 MVA transformer unit. The predictive sound power level for the modeled transformer is 103 dBA. However, this estimate is likely high given that the algorithms from the EEI study are 40 years old and modern technology has advanced greatly during that time. When comparing EEI predictive sound levels to those measured at operating facilities, sound levels measured at operating facilities are approximately 6 dB lower than the calculated EEI value.

A representative inverter model, the 2700kVA TMEIC Model PVH-L2700GR-EG, was used to estimate inverter sound levels. A field survey was conducted at another facility developed by First Solar to quantify sound emissions produced by inverters. Incremental walkaway measurements were taken out to a maximum distance of 100 meters (328 feet). At 30 meters (98 feet), the inverter buzz, while still subjectively identifiable, dropped to a faint level of 25 dBA. The predictive sound power level from the modeled example inverter at 100% load was conservatively calculated at 79 dBA.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 51

The representative inverter and transformer sound power levels were then used to model the noise impact of the Facility. Results of this analysis indicate that the possibility of any disturbance is extremely low.

Inverters will be internally placed, typically between arrays of solar panels, which help to dampen noise impacts. Sound levels at one non-participating property boundary may be at or above 35 dBA based on inverter sound modeling performed by Hessler; however, this area contains a dirt road and some agricultural land and will likely have minimal impacts to that landowner. Sound levels at the remaining non-participating property boundaries are anticipated to be less than 35 dBA. Additionally, all potentially sensitive receptors are generally expected to experience negligible sound levels of approximately 30 dBA or less, levels similar to a library or quiet bedroom (See Plot 1 in Exhibit H).

Sound contours were also modeled for the collection substation transformer. At the nearest non- participating parcel, the sound level produced by the substation transformer is estimated between 45 and 50 dBA. However, this value quickly dissipates when moving away from the substation. According to Hessler, the nearest residence is located well outside the 35 dBA contour, therefore, minimal sound impacts from the substation are anticipated at nearby residents (see Plot 1 of Exhibit H).

(ii) Processing equipment There is no processing equipment associated with this Facility. Therefore, this section is not applicable.

(iii) Associated road traffic Transportation noise during Facility construction is addressed above in Section 4906-4-08(3)(a). Once operational, the proposed Facility will not significantly contribute to traffic on local roads. Post- construction traffic will be associated with operations personnel traveling to and from the Facility site and will not be a significant source of noise.

(c) Location of Noise-Sensitive Areas within One-Mile of the Facility Hessler mapped noise-sensitive receptors, including all residences within the immediate vicinity of the Facility, as well as A-weighted sound emissions during normal operation. Sound emission contours are illustrated for the inverters and substation (Plot 1 of Exhibit H). A 35-dBA sound contour is displayed to

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 52

show the sound level equivalent to the existing background sound level. Sound levels less than 40 dBA are regarded as largely insignificant and rarely result in any kind of complaint or disturbance. No potentially sensitive receptors located adjacent to the Facility were identified as experiencing sound levels at or above 35 dBA.

According to the OAC Section 4906-4-08(A)(3)(c), the Application must indicate the location of any noise- sensitive areas within one mile of the Facility, and the operational noise level at each habitable residence, school, church, and other noise-sensitive receptors under both day and nighttime operations. Receptors adjacent to the Facility are predicted to receive sound levels at 35 dBA or less which is equal to that of the background sound level measured at the site. When moving further away from the Facility, that sound level will continue to decrease and will become indistinguishable from ambient noise levels. As such, noise levels at receptors up to one mile away from the Facility would not experience any sound from the Facility and are not included in the Application. The Applicant has submitted a request for waiver to allow for a more limited identification of receptors.

(d) Mitigation of Noise Emissions during Construction and Operation Although noise emissions during construction and operation of the Facility are anticipated to be minor, mitigation measures will include the following:

• Implementing best management practices for sound abatement during construction, including use of appropriate mufflers, proper vehicle maintenance, and limiting hours of construction to daylight hours, unless there is a compelling reason to work beyond those hours. It is anticipated that the work would be completed in 8- to 10-hour shifts, for a total of five shifts per week (Monday–Friday) with the possibility of up to seven shifts per week when necessary. • Notifying landowners of construction commencement.

In addition, if adverse noise impacts are identified from the construction or operation of the Facility, a complaint resolution procedure will be used to ensure that any complaints are adequately investigated and resolved. A Complaint Resolution Plan is attached hereto as Exhibit N.

(e) Pre-construction Background Noise Study Long-term sound level monitoring was carried out at the site from September 29 through October 7, 2019, at two different locations (Position 1 and Position 2) within the Project Area (see Exhibit H). Microphones were fixed to metal posts at a standard height of approximately 1.2 meters (4 feet) above grade and

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 53

covered by windscreens. Weather conditions over the survey period were generally mild, dry, and conducive to the survey, with some periodic moments of high winds which adversely affected readings on September 29, October 3, October 4, and October 6. These periodic moments are shown graphically in the sound assessment but were omitted when averaging calculations. Sound level data was collected using a Norsonic N-140 octave band frequency analyzer and Rion NL-22 sound monitor. The Norsonic N-140 is an ANSI Type 1 precision, 1/3 octave band frequency analyzer used at the primary measurement location along with the Rion NL-22, which is an ANSI Type 2 environmental sound monitor.

Data were summarized into 10-minute increments over the 7-day survey period. A variety of statistical sound levels were recorded, such as minimum, average (Leq), maximum, and the residual sound level (L90). The residual sound level, or L90 percentile level, captures the quietest (not necessarily consecutive) one-minute period of the ten-minute internal, making it a conservative measure of background sound level.

Position 1 included a frequency monitor and a sound level monitor, while Position 2 only used a sound level monitor. A frequency monitor measures high-frequency natural sounds heard on-site, such as insect noise, which can then be eliminated to provide the most conservative estimate of noise levels. Seasonal noise, like those from insects in the summer and fall, are not reflective of year-round noise levels, which is why sound levels were further analyzed by the frequency monitor to eliminate data above 1000 Hz. The L90 measurement at Position 1 was 25 dBA during daytime and 20 dBA during nighttime. Position 2 served as a comparison test location and did not have the frequency monitor. Sound levels recorded at Position 2 were similar to Position 1, so it was assumed that weighted sound levels at Position 2 would also be within the same range as Position 1.

(4) Water Impacts

Hull & Associates, Inc. conducted a desktop review of available hydrogeology and geotechnical information for the proposed Facility, attached as Exhibit H. Information was summarized from available online databases and/or documents produced by the following federal, state, and local agencies: the Federal Emergency Management Administration (FEMA); the USGS; the U.S. Department of Agriculture (USDA); the ODOT District 6; the Ohio EPA; the Ohio Department of Agriculture (ODA); the Ohio Department of Natural Resources (ODNR); the Ohio State University Agricultural Extension Office; the Madison County Health Department; and the Office of the Madison County Engineer.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 54

(a) Impacts to Public and Private Water Supplies from Construction and Operation The Project Area lies within rural areas of Fairfield and Oak Run townships. Consequently, the majority of the residents in the vicinity of the Project Area rely upon private wells for potable water. No source water protection areas (SWPAs) were identified within the Project Area. The closest SWPA is located approximately 6 miles south of the Project Area. The principal groundwater source for the majority of the Project Area is two unconsolidated aquifers, the Bloomingburg Complex Aquifer and New Holland Complex Aquifer. Groundwater yields for these two aquifers typically range from 3 to 10 gallons per minutes (gpm). Additional aquifers underlying the Project Area include Deer Creek Alluvial Aquifer, London Complex Aquifer, and New Holland Ground Moraine Aquifer. Figure 7 of Exhibit F depicts aquifers and well locations based on information provided by ODNR, Ohio EPA, and the Madison County Health Department.

Hull conducted a well survey within the Project Area (Exhibit F). The survey was mailed property owners identified as participating at the time the survey was initiated. A total of six surveys were mailed and four were returned. Of the four respondents, two indicated having no wells, one respondent was not aware of wells on the property, and one respondent identified two wells on their property. None of the respondents indicated residential connection to a municipal water supply, so it is assumed that wells on these properties provide potable water to residences. The two identified wells were constructed pre- 1955, have a diameter of 4 inches, and were drilled to a depth of 90 and 120 feet below ground surface (bgs) (Hull, 2019). These wells were constructed with steel casing and completed in an overburden sand and gravel unit. Depth to water for the two identified wells is unknown (Hull, 2019). The survey also asked respondents whether they had experienced problems with their well related to poor yield or lowered water table and therefore needed to drill a new well. None of the respondents indicated the need to drill a new well based on problems with their existing well.

Although the exact location of each potable well cannot be determined with the information received to date, it is assumed that potable water wells are near each residence. Therefore, construction and operation of the Facility is not anticipated to result in any significant native impact to property owner’s wells (Hull, 2019).

(b) Impacts to Public and Private Water Supplies from Pollution Control Equipment Failures Solar panels generate electricity without combusting fuel or releasing pollutants into the atmosphere. Therefore, this section is not applicable.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 55

(c) Water Resources Map Figure 08-1 depicts existing aquifers and water wells that may be directly affected by the proposed Facility. No source water protection areas were found in the vicinity of the Facility, and therefore, none are mapped on Figure 08-1. The water resources mapping was developed from publicly available data from ODNR’s Division of Water Resources.

(d) Compliance with Local Water Source Protection Plans Ohio’s Source Water Assessment and Protection Program, also known as “Wellhead Protection” and “Drinking Water Source Protection,” assists communities with protecting their sources of drinking water from contamination. SWPAs, as defined and approved by Ohio EPA for the protection of drinking water sources, were evaluated in the “Groundwater Hydrogeological and Geotechnical Desktop Document Review Summary Report” prepared by Hull (see Exhibit F). Environmental regulatory programs within the Ohio EPA, as well as other regulatory agencies such as the Ohio Bureau of Underground Storage Regulations, have adopted regulations that restrict specific activities within SWPAs. These activities include concentrated animal feeding operations, sanitary, industrial or residual waste landfills, land application of biosolids, and voluntary brownfield cleanups. The restrictions typically apply to SWPAs relying on groundwater as their drinking water source.

No SWPAs were identified in the immediate vicinity of the Project Area. The nearest downstream Ground Water Protection Area is located approximately 6 miles south of the Project Area. Hull (2019) reviewed a range of programs which have adopted rules related to the presence of SWPAs and have concluded that construction of the proposed solar energy facility will not constitute an activity that would be restricted within either a surface water or groundwater SWPA.

(e) Prospects of Floods in the Area A floodplain is flat land adjacent to a stream or river that experiences occasional or periodic flooding. For regulatory purposes, the floodplain is divided into two areas, based on water velocity: the floodway and the flood fringe. The floodway includes the channel and the portion of the adjacent floodplain required to pass the 100-year flood without increasing flood heights. Typically, this is the most hazardous portion of the floodplain where the fastest flow of water occurs. Due to the high degree of hazard, most floodplain regulations require that proposed floodway developments do not block the free flow of flood water, as this could dangerously increase that water's depth and velocity. The flood fringe is the remaining portion of the floodplain, outside of the floodway, that usually contains slow-moving or standing water. Development in the fringe will not normally interfere as much with the flow of water. Therefore, floodplain regulations

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 56

for the flood fringe typically allow development to occur but require protection from floodwaters through flood proofing so that water cannot enter the structure (ODNR, 2019a).

Surface water flow within the Project Area is generally to the south. The entire Project Area is located within the Ohio River Drainage Basin. Surface water bodies within the Project Area include several small streams, tributaries, ditches, and ponds. The streams generally flow from the north to the south. The majority of surface water in the Project Area flows to Deer Creek and Glade Run, both of which bisect the western portion of the Project Area. Surface water then flows into Deer Creek Lake to the Scioto River, and ultimately reaches the Ohio River.

Information on floodplains in the vicinity of the Project Area was obtained from ODNR and FEMA, as part of the “Groundwater Hydrogeological and Geotechnical Desktop Document Review Summary Report” prepared by Hull (2019) and attached hereto as Exhibit F. Areas adjacent to Deer Creek and Glade Run fall within a 100-year floodplain and are located in the Project Area. Most Facility components will be sited outside the floodplain, except for collection lines which may be installed either underground or overhead. Therefore, impacts to the Facility from flooding are not anticipated.

(5) Geological Features Map

Figure 8-2 depicts the geological features of the Project Area, as well as topographic contours, existing oil and gas wells, and injection wells. As previously discussed, Hull prepared a desktop review of available hydrogeological and geotechnical information in the vicinity of the Project Area, which is attached hereto as Exhibit F.

(a) Geologic Suitability Existing Conditions The Project Area lies entirely within the Darby Plain District of the Southern Ohio Loamy Till Plain Region of the Till Plains Section of the Central Lowland Physiographic Province. The Darby Plain District is characterized by surface loamy till, flat-lying ground moraine, boulder belts, broad floodplains, and buried valleys. Elevations in this region range from 750 to 1,100 feet above mean sea level (amsl), with moderately low relief up to approximately 25 feet locally (Hull, 2019).

The surface topography within the Project Area is the result of ice-deposited Wisconsin water-lain, ground, and recessional moraines with localized areas of glacial outwash and loess depositions. Till and

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 57

loess deposits are underlain by Ordovician and Silurian-age carbonate rocks and calcareous shales (Hull, 2019).

Depth to bedrock within the Project Area was obtained from the ODNR database of water well drilling logs. The ODNR water well logs indicate that, during well drilling of domestic wells in the Project Area, bedrock was encountered at depths ranging from 102 to 186 feet bgs, with shallower depths found in the southern portion of the Project Area. According to information obtained from ODNR, Division of Geological Survey, no karst features are located in the immediate vicinity of the Project Area. The nearest mapped karst feature, an inactive sink, is located approximately 4.5 miles northwest of the Project Area (see Figure 4 in Exhibit F).

According to the USDA NRCS Web Soil Survey, depth to the water table within the majority of the Project Area ranges from less than one foot to over 6.5 feet (USDA NRCS, 2020). Preliminary test pits were excavated within potential solar panel array fields at depths ranging from eight to nine feet bgs. Groundwater seepage was encountered at three test pits at depths ranging from four to 5.5. feet; however, no measurable groundwater was observed upon completion of excavation operations. Fluctuations in perched and long-term groundwater levels are anticipated due to seasonal variations and prolonged periods of rainfall.

A review of geologic and seismic information was conducted by Hull for the Project Area. Seismic information was obtained from the ODNR, Division of Geological Survey. No epicenters lie within the Project Area. The nearest seismic event occurred in 2013 in Pickaway County, Ohio and consisted of a 2.0-magnitude earthquake with an epicenter approximately 15 miles southeast of the Project Area. No faults were identified in the Project Area; however, two small, unnamed faults are located two miles southeast and six miles to the southwest.

Site Suitability Based on their experience with earthwork in the region, Hull (2019) indicates that conventional, steel- driven or helical piles may be suitable foundational supports for solar modules. This was also supported by the Preliminary Geotechnical Report conducted by G2 consultants (Exhibit S). However, this assumption will need to be confirmed by a final geotechnical exploration and evaluation for each solar site. A geotechnical engineer will evaluate subsurface conditions within the Project Area to determine appropriate foundations for module support, review foundation designs and site soil compatibility, and approve work prior to the construction of foundation components.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 58

Additional test borings will be conducted prior to construction to confirm and refine the information presented in Exhibit F and facilitate final foundation design and engineering. The locations of test borings will be identified by the geotechnical engineer and will be performed at various solar array locations to the proposed depth or competent bedrock, whichever is encountered first (Hull, 2019).

(b) Soil Suitability Existing Conditions Hull examined soils properties in the Project Area using the USDA Soil Conservation Service Soil Survey of Madison County. Soil surveys furnish surface soil maps and provide general descriptions and potentials of the soil to support specific uses and can be used to compare the suitability of large areas for general land uses. Surface soils in the vicinity of the Project Area are comprised primarily of Crosby- Lewisburg silt loam (approximately 38% of the Project Area) and Kokomo silty clay loam (approximately 20% of the Project Area). The remainder of the Project Area is covered by various gravel, silt, and clay loams (see Figure 8 of Exhibit F). Soil survey information indicates that Crosby silt loams have 2 to 6% slopes, a water capacity of approximately 5.7 inches, a depth to water table range of 0.5 to 2.0 feet bgs, low to moderately-high permeability, and are somewhat poorly drained. Lewisburg silt loam soils have slopes of 2 to 6%, a low water capacity (approximately 3.3 inches), a depth to water table range of 0.5 to 2.0 feet bgs, moderately-low to moderately-high permeability, and are moderately well drained. Kokomo silty clay loam soils have 0 to 2% slopes, high water capacity (9.0 inches), depth to water table range of 0 to 6 inches, moderately-low to moderately-high permeability, and are very poorly drained. See Exhibit F for additional information.

Site Suitability To maintain soil stability during construction, adequate surface water run-off drainage will be established and properly controlled at the Project Area to minimize any increase in the moisture content of the subgrade material. Positive drainage of each construction site will be created by gently sloping the surface toward drainage swales. It should be noted that sub-grade soils are subject to shrinking and swelling due to variation in seasonal moisture contents, and consideration should be given during constructability reviews to determine how best to deal with potential moisture fluctuations (Hull, 2019).

Based on a review of the soil survey information and Hull’s experience with earthwork in the area, the soils on-site are anticipated to be suitable for grading, compaction, and drainage when each solar array is prepared, as discussed in Appendix C and D of the Exhibit F.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 59

Site Restoration Construction may involve limited topsoil stripping. Stripped topsoil will be stockpiled appropriately for use in site restoration. Additionally, soil disturbed during trenching activities will be sidecast adjacent to the trench. Any limited areas with soil disturbance or removal will be restored with native soil.

(c) Plans for Test Borings A Preliminary Geotechnical Investigation has been conducted in the Project Area by G2 Consulting Group and includes a description of subsurface and site conditions, as well as the methodology and results of test pits and laboratory soil testing. Bedrock was not encountered during borings, so information on rock quality and percent recovery were not included in the report. Results of this study can be found in Exhibit S. Additional borings will likely be required as the Facility layout finalizes. Therefore, to the extent required, the Applicant is requesting a waiver to allow for the submittal of layout-specific soil boring plans.

Future test borings will likely follow the steps outlined in the Generalized Geotechnical Exploration Work Plan, attached as Appendix D to Exhibit F. This work plan describes the planned site reconnaissance, drilling, sampling, geotechnical laboratory testing, and report to be prepared.

After the geotechnical engineer has reviewed all available desktop information, s/he will determine the number of borings to be drilled for the initial geotechnical investigation. The locations of test borings will be at solar array locations and will extend to the proposed depth of piles or competent bedrock, whichever is encountered first. Split-barrel sampling of soil will be performed in accordance with American Society for Testing and Materials (ASTM) D1586 for each boring in increments of 2.5 feet to the depth of 10 feet, and at 5-foot intervals below 10 feet to the final depth of the borings. In all the borings, Standard Penetration Test (SPT) data will be developed and representative samples preserved. Water observations in the boreholes will be recorded during and at the completion of drilling. A truck-mounted drill rig will be used to perform the borings, unless unfavorable weather conditions make the site inaccessible, in which case an ATV-mounted drill rig will be used. All borings will be backfilled at the completion of drilling with bentonite chips and drill cuttings (Hull, 2019).

A laboratory testing program will be established by the geotechnical engineer based on the observations made during the drilling activities and experience. All samples will be classified in the laboratory based on the visual-manual examination (ASTM D 2488), Soil Classification System, and the laboratory test results. Formal boring logs will be prepared using field logs and laboratory classifications. For a limited

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 60

number of samples considered to be representative of the foundation materials encountered by the borings across the Project Area, laboratory testing will include moisture content, particle-size analyses, and Atterberg limits. Unconfined compression and consolidation tests will be performed if low strength and/or highly compressible cohesive soils are encountered, as deemed necessary by the geotechnical engineer. All laboratory testing will be performed in accordance with ASTM or other specified standards. A report will be prepared documenting the findings of the borings and laboratory testing, including subsurface soil properties, static water levels, rock quality descriptions, percent recovery, and depth and description of bedrock contact (Hull, 2019). This report will be provided to OPSB Staff prior to commencement of Facility construction.

(6) Prospects of High Winds in the Area

The Facility will be engineered and installed to withstand typical high-wind occurrences. The Facility design factors in wind speeds, which are based on building code wind speed maps. First Solar facilities, including the Facility, are designed using Risk Category I maps and are based on the maximum expected three-second gust from the building codes.

(7) Blade Shear

Given the nature of the Facility, this section is not applicable.

(8) Ice Throw

Given the nature of the Facility, this section is not applicable.

(9) Shadow Flicker

Given the nature of the Facility, this section is not applicable.

(10) Radio and Television Reception

The Applicant is not aware of any research conducted to date that indicates utility-scale solar generation facilities interfere with communication systems. PV arrays generate weak electromagnetic fields (EMFs) during the day that dissipate at short distances. These EMFs are “generated in the same extremely low frequency (ELF) range as electrical appliances and wiring found in most homes and buildings” (MDER, 2015). In a study of three solar projects in Massachusetts, electric field levels measured along the boundary of each project did not exceed background levels (Massachusetts Clean Energy Center, 2012). Accordingly, the

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 61

Applicant does not anticipate interference with radio or television reception due to weak electric fields produced by the proposed solar facility.

(11) Radar Interference

As stated above, solar facilities produce weak EMF signals that quickly dissipate off-site. Additionally, according to the FAA, PV systems represent little risk of interfering with radar transmission due to their low profile (Lawrence and Magnotta, 2018). As a result, the Facility is not anticipated to interfere with radar communication systems.

(12) Navigable Airspace Interference

Due to the low profile of the Facility, where the tallest structure will be the overhead collection line support structures, with a height of approximately 60 feet, impacts to navigable airspace are not anticipated. Final engineering design will confirm the tallest structure for final impacts. Notwithstanding the low profile of the Facility, the FAA issued determinations of no hazard for the Facility on September 18, 2019 (Exhibit Q). FAA consultation revealed that Facility poles for overhead collection lines, as located in the design, do not exceed obstruction standards and were not deemed a hazard to air navigation.

(13) Communication Interference

Interference in microwave communication signals occurs when the line-of-sight between two microwave transmitters is blocked (Polisky, 2005). Microwave communication interference is a common concern in development of a wind facility due to the presence of large structures. However, components of this Facility are low in profile with the tallest structure being the overhead collection lines. Due to the lack of tall structures that may interfere with the line-of-sight of microwave transmitters, interference with microwave communications from the Facility is not anticipated.

(B) ECOLOGICAL IMPACT

(1) Ecological Resources in the Project Area

In support of this Application, Westwood Professional Services (Westwood) completed on-site ecological surveys and prepared a “Habitat Assessment Report,” attached hereto as Exhibit I.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 62

(a) Ecological Resources Map Figure 08-3 shows the proposed Facility and ecological features within 0.5-mile of the Project Area. This map was developed using ESRI ArcGIS Online “World Topographic Map” map service. Figure 08-3 shows the following features:

(i) The proposed Facility, including the preliminary layout, and Project Area boundary (ii) Undeveloped or abandoned land such as wood lots or vacant tracts of land subject to past or present surface mining activities (iii) Wildlife areas, nature preserves, and other conservation areas (iv) Surface bodies of water (v) Highly erodible soils and steep slopes

(b) Field Survey and Map of Vegetative Communities and Surface Waters within 100 Feet of Construction Vegetative Communities Vegetative communities were mapped by Westwood using aerial imagery, and later field-verified for all areas within 100 feet of Facility components. Four communities were identified: agricultural fields, grass/pasture/hay/swales, woodlands, and vegetated fencerows. Agricultural fields are the most prevalent vegetative community within 100 feet of the Facility. Vegetation in agricultural fields consists of soybeans and corn, witchgrass (Panicum capillare), yellow foxtail (Setaria pumila), giant foxtail (Setaria faberi), barnyard grass (Echinochloa crus-galli), and orchardgrass (Dactylis glomerata). Woodlands are the second most-dominant vegetative community within 100 feet of the Facility. Vegetation in the woodland communities includes white oak (Quercus alba), multiflora rose (Rosa multiflora), winter creeper (Euonymus forunei), shagbark hickory (Carya ovata), Morrow’s honeysuckle (Lonicera morrowii), bur oak (Quercus macrocarpa), American elm (Ulmus americana), and green ash (Fraxinus pennsylvanica). Grass/pasture/hay/swale communities were observed in small quantities within 100 feet of the Facility. Vegetation in these communities consists of Kentucky bluegrass (Poa pratensis), smooth brome (Bromus inermis), yellow foxtail, red clover (Trifolium pratense), daisy fleabane (Erigeron strigosus), and cereal rye (Secale cereale). Vegetated fencerow communities were also observed in small quantities within 100 feet of the Facility. Most fencerows were un-vegetated, with sparse stands of trees. Tree species in the vegetated fencerow communities include green ash, hackberry (Celtis occidentalis), red mulberry (Morus rubra), and red oak (Quercus rubra).

Wetland and Stream Delineations

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 63

Westwood conducted parcel-wide wetland delineations which spanned the entire Project Area as well as some outlying, adjacent areas (hereafter known as the Lease Area). Delineations were conducted in accordance with the 1987 U.S. Army Corps of Engineers (USACE) Wetlands Delineation Manual and the USACE Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Midwest Region. Wetland and stream data samples and boundaries were mapped with sub-meter accuracy Global Positioning System (GPS) equipment.

Wetland qualitative assessments were completed by Westwood utilizing the Ohio EPA’s Ohio Rapid Assessment Methods (ORAM). The ORAM assessment was developed to determine the ecological “quality” and level of function of a wetland in order to meet requirements under Section 401 of the Clean Water Act. Wetlands are scored on the basis of hydrology, upland buffer, habitat alteration, special wetland communities, and vegetation communities. Each of these subject areas is further divided into subcategories under ORAM v5.0 resulting in a score that ranges from 0 (low quality and high disturbance) to 100 (high quality and low disturbance). Based on these scores, there are three possible categories to which wetlands may be assigned:

• Category 1 – Lowest value category. Wetlands in this category are generally limited to small, low-diversity wetlands and wetlands with a predominance of non-native invasive species. The designation of ‘Category 1’ is assigned to wetlands whose ORAM scores fall between 0 and 29.9. Wetlands whose ORAM scores fall between 30 and 34.9 fall in a scoring ‘gray area,’ and additional testing is needed to determine whether they belong in ‘Category 1’ or Category 2.

• Category 2 – Middle value category. Wetlands in this category are of moderate diversity but do not contain rare, threatened or endangered species. They are generally degraded but are capable of restoring some of the lost functionality and attaining a higher value. Most wetlands in Ohio are expected to fall into this category. Wetlands designated as ‘Category 2’ have ORAM scores between 35 and 59.9. Wetlands whose ORAM scores fall between 60 and 64.9 in a scoring ‘gray area,’ and additional testing is needed to determine whether they belong in Category 2 or Category 3.

• Category 3 – Highest value category. Wetlands in this category have high levels of diversity, a high proportion of native species, and/or high functional values. The designation ‘Category 3’ is assigned to wetlands whose ORAM scores fall between 65 and 100.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 64

A total of 87 wetlands covering 94.1 acres were identified within the Lease Area. The majority of the delineated wetlands (n=78) were identified as emergent, followed by forested (n=6). The remaining wetlands were a mix of multiple types, including emergent and forested characteristics. In general, wetlands in the surveyed area exhibit characteristics as expected given their position in an agriculturally- dominated landscape. A majority of the wetlands were of low quality, often dominated by Pennsylvania smartweed (Persicaria pensylvanica), yellow nutsedge (Cyperus esculentus), and various sedge species (Carex spp.). Forested wetlands typically occurred in isolated woodlots, surrounded by cropland. Delineated wetlands and vegetative communities within 100 feet of Facility components are mapped in Figure 08-4 at a scale of 1:12,000.

Westwood (2019) evaluated and classified streams according to the Ohio EPA’s Qualitative Habitat Evaluation Index (QHEI) scoring method, and the Primary Headwater Habitat Evaluation Form (HHEI). Both methods yield a numerical score for the section of streams evaluated, which Westwood used to estimate the probable aquatic habitat use of each stream.

The QHEI assessment was used for streams with a drainage area greater than 1 square mile, or pools with depths greater than 15.75 inches. This assessment examines a number of stream characteristics and yields a score ranging from 0 to 100 reflecting the quality of habitat present in a stream. According to the Ohio EPA, a score of 60 typically indicates a stream has the physical characteristics needed to support diverse macroinvertebrate and fish populations (Ohio EPA, 2006). Scores of 43 to 60 indicate streams with fair habitat quality for aquatic species. Scores less than 43 typically indicate a poor habitat quality. The HHEI assessment is used to predict stream quality on streams with a drainage area less than 1 square mile. The method scores streams on a range of 0 to 100 based on physical characteristics. Streams that score less than 30 are predicted to have little to no potential for supporting aquatic life. Conversely, streams with a score of 70 or greater exhibit moderately to highly diverse communities (Ohio EPA, 2012).

A total of 38 waterbodies were delineated in the Lease Area. Of these, the majority were identified as ephemeral (n=27), followed by perennial (n=5) and intermittent (n=5). Overall stream quality was characterized as fair to poor within the Lease Area, with 2 streams having a QHEI score less than 60 and 30 streams having an HHEI score less than 30. Only 3 streams were evaluated by a QHEI assessment due to their drainage area. The QHEI score for the remaining stream was 67.5. HHEI scores for the remaining streams range from 46 to 64. Based on these scores, it can be assumed that streams within

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 65

the Lease Area are of moderate to low quality and are unlikely to support diverse aquatic life. Additional information on delineated streams can be found in Appendix B of Exhibit I.

(c) Literature Review of Plant and Animal Life within 0.25 Mile of Construction This section provides the results of a literature survey of the plant and animal life within at least 0.25 mile of the Project Area. The literature survey is broken into two sections: (i) for plant and (ii) for animals.

(i) Aquatic and Terrestrial Plants A review of plant resources within 0.25 mile of the Project Area boundary focuses on species of commercial or recreational value, and species designated as endangered or threatened. This information was compiled through review and analysis of existing data sources, including National Audubon Society, ODNR, Ohio EPA, NatureServe, USDA NRCS, and USGS.

Species of Commercial or Recreational Value Agricultural impacts, including impacts to crops and other commodity plants, are addressed in Section 4906-4-08(E). Aside from crops, there are no other plant species of commercial or recreational value known within 0.25 mile of the Project Area boundary.

Threatened and Endangered Species Based on ODNR records for state-listed species, there are eight threatened and one endangered plant species known to occur in Madison County (ODNR, 2016a). The status and generalized habitat requirements for each of these species are summarized below in Table 08-2. None of the species below are federally listed.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 66

Table 08-2. Threatened and Endangered Plant Species in Madison County Ohio Scientific Name Common Name General Habitat1 Status2 Carex bicknellii Bicknell’s Sedge open sandy soils, dry or wet T Cuscuta glomerata glomerate dodder prairies and fens E Leiberg’s panic Dichanthelium leibergii wet prairies, open woods and meadows T grass wet, shady swamps, floodplains, borders Iris brevicaulis leafy blue flag T of rich woods, shores moist to dry, open to semi-open prairies, Juncus interior inland rush meadows, clearings, roadsides, fallow T fields, clearings wet woods, low thickets, meadows, Melanthium virginicum bunchflower T swales, savannas, fen habitats Rorippa aquatica lake cress shores of ponds or quiet waters T Silene regia royal catchfly prairies, open woods T Sporobolus heterolepis prairie dropseed dry to moist calcareous soils, full sun T 1 General Habitat Source: ODNR’s Rare Plants of Ohio (ODNR, 2019b) 2 E=Endangered, T=threatened

As shown above, over half of the state-listed plant species that are found in Madison County occur in wetland habitats, which have been avoided during Facility siting to the extent practicable. Furthermore, Facility components are almost entirely sited within actively cultivated fields that do not provide appropriate habitat conditions for the state-listed plant species that occur in uplands.

(ii) Aquatic and Terrestrial Animals Animal resources within 0.25 mile of the Project Area were identified through review and analysis of existing data sources, including North American Breeding Bird Survey, Audubon Christmas Bird Count, American Society of Mammologists, NatureServe, Ohio Aquatic Gap Analysis Program, and ODNR field guides and data. These various sources of information have been synthesized and are presented below for birds, mammals, reptiles, amphibians, aquatic species, commercial species, and recreational species. Each of these discussions identifies the potential presence of species designated as endangered or threatened in accordance with the U.S. and Ohio threatened and endangered species list. Table 08-3 provides a summary of listed species with potential presence in the Project Area. See Section 4906-4-08(B)(1)(d) below for discussion of field surveys conducted on site.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 67

Table 08-3. Federal and State-Listed Species with Potential Presence in the Project Area. Scientific Name Common Name Listing1 Birds Circus cyaneus northern harrier S-E Grus canadensis sandhill crane S-T Fulica americana American coot S-SC Cistothorus palustris marsh wren S-SC Accipiter striatus sharp-shinned hawk S-SC Mammals Myotis sodalis Indiana bat S-E, F-E Myotis lucifugus little brown bat S-SC Eptesicus fuscus big brown bat S-SC Perimyotis subflavus tri-colored bat S-SC Lasiurus cinereus hoary bat S-SC Lasiurus borealis red bat S-SC Condylura cristata star-nosed mole S-SC Peromyscus maniculatus North American deer mouse S-SC Microtus pinetorum woodland vole S-SC Amphibians and Reptiles Acris crepitans eastern cricket frog S-SC Aquatic Species Elliptio crassidens elephant-ear S-E Epioblasma rangiana northern riffleshell S-E Epioblasma triquetra snuffbox S-E Pleurobema clava clubshell S-E Quadrula cylindrical rabbitsfoot S-E Villosa fabalis rayed bean S-E Alasmidonta marginata elktoe S-SC Cyclonaias tuberculata purple wartyback S-SC Lampsilis fasciola wavyrayed lampmussel S-SC Lasmigona compressa creek heelsplitter S-SC Pleurobema sintoxia round pigtoe S-SC Ptychobranchus fasciolar kidney shell S-SC Simpsonaias ambigua salamander mussel S-SC 1 S-State-listed, F-Federally-listed; E-endangered, T-threatened, SSC- species of concern

Birds Breeding Birds: The North American Breeding Bird Survey (BBS), overseen by the Patuxent Wildlife Research Center of the USGS, is a long-term, long-scale international avian monitoring program that tracks the status and trends of North American bird populations. Each survey route is 24.5 miles long, with 3-minute point counts conducted at 0.5-mile intervals. During the point counts, every bird seen or heard within a 0.25-mile radius is recorded. The London Survey Route runs east-west through the Project Area. Data on breeding birds has been collected on this route every year from 1997 to 2012, during which a total of 84 species have been recorded. The most commonly observed

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 68

species include red-winged blackbird (Agelaius phoeniceus), common grackle (Quiscalus quiscala), American robin (Turdus migratorius), European starling (Sturnus vulgaris), and mourning dove (Zenaida macroura) (Pardieck et al, 2019). Of the species observed during breeding bird surveys, the only state-listed species observed was the northern harrier (Circus cyaneus); two individuals observed in 2005. Due to the lack of state- or federally-listed species in the Project Area, no site- specific surveys were conducted for breeding birds. Potential impacts to wildlife from construction or operation of the Facility are discussed below in Section 4906-4-08(B)(2-3).

Wintering Birds: Data from the Audubon Christmas Bird Count (CBC) provides an overview of birds that inhabit that region during early winter. Counts take place on a single day during a three-week period around Christmas, when birdwatchers comb a 15-mile (24-kilometer) diameter circle in order to count the number of bird species and individuals observed. The Big and Little Darby Creek- Darbydale count circle is centered approximately 5.5 miles northeast of the Project Area and was established in December 2017. Since then, a total of 81 species have been recorded in the Big and Little Darby Creek-Darbydale count circle (National Audubon Society, 2019). The most common wintering bird species observed were European starling, Canada goose (Branta canadensis), mallard (Anas platyrhynchos), American robin, rock pigeon (Columba livia), mourning dove, house sparrow (Passer domesticus), unidentified duck species, blue jay (Cyanocitta cristata), and northern cardinal (Cardinalis cardinalis) (National Audubon Society, 2019). The following state-listed bird species were documented between December 2017 to September 2019 in the Big and Little Darby Creek-Darbydale count circle: northern harrier (endangered); sandhill crane (Grus canadensis; threatened); American coot (Fulica americana; species of concern); marsh wren (Cistothorus palustris; species of concern); and sharp-shinned hawk (Accipiter striatus; species of concern). No federally-listed endangered or threatened bird species were recorded (National Audubon Society, 2019; ODNR, 2019c). Potential impacts to wildlife from construction or operation of the Facility are discussed below in Section 4906-4-08(B)(2-3).

Migratory Birds: The Hawk Migration Association of North America (HMANA) collects hawk count data from almost two hundred affiliated raptor monitoring sites throughout the United States, Canada, and Mexico. There are no hawk watch sites in the vicinity of the Facility (HMANA, 2019). One hawk watch site, called Conneaut Hawkwatch, is located in Ohio in the City of Conneaut, Ashtabula County. This site is approximately 300 miles northeast of the Project Area. A closer watch site called DRHW- Pointe Mouillee State Game Area, part of the Detroit River Hawk Watch, is located approximately 220 miles from the Project Area, in Berlin Charter Township, Monroe County,

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 69

Michigan. Data from Conneaut and Detroit River Hawk Watches were reviewed, but due to their distances from the Project Area and the marked differences in landform, these sites were not considered representative of conditions for migrating raptors in the vicinity of the proposed Facility. Potential impacts to wildlife from the construction or operation of the Facility are discussed below in Section 4906-4-08(B)(2-3).

Mammals The potential occurrence of mammalian species was determined through an evaluation of species range and available habitat. Data sources for this analysis included data from the American Society of Mammologists, NatureServe, and ODNR field guides. This effort suggests that approximately 40 species of mammals could occur in the area including; white-tailed deer (Odocoileus virginianus), eastern cottontail rabbit (Sylvilagus floridanus), eastern chipmunk (Tamias striatus), coyote (Canis latrans), red fox (Vulpes vulpes), raccoon (Procyon lotor), Virginia opossum (Didelphis virginiana), woodchuck (Marmota monax), eastern gray squirrel (Sciurus carolinensis), eastern fox squirrel (Sciurus niger), striped skunk (Mephitis mephitis), American beaver (Castor canadensis), common muskrat (Ondatra zibethicus), American mink (Mustela vison), long-tailed weasel (Mustela frenata), big brown bat (Eptesicus fuscus), little brown bat (Myotis lucifugus), Indiana bat (Myotis sodalis), northern long-eared bat (Myotis septentrionalis), eastern red bat (Lasiurus borealis), hoary bat (Lasiurus cinereus), tri-colored bat (Perimyotis subflavus), and a variety of small mammals such as mice, moles, voles, and shrews. Most of the mammal species likely to occur in the area are common and widely distributed throughout Ohio. However, Indiana bat is both state- and federally-listed as endangered, while the northern long-eared bat is both state- and federally-listed as threatened. Madison County is identified by the ODNR as being within the distribution range of these species (ODNR, 2016c). Several other mammal species of concern could also occur in the area, including star-nosed mole (Condylura cristata), North American deermouse (Peromyscus maniculatus), woodland vole (Microtus pinetorum), little brown bat, big brown bat, tri-colored bat, hoary bat, and eastern red bat (ODNR, 2016b; ODNR, 2016c; ODNR 2019c; NatureServe, 2019). See 4906-4- 08(B)(1)(c)(ii) for further discussion of on-site surveys and Section 4906-4-08(B)(2-3) for potential impacts to wildlife from the construction or operation of the Facility.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 70

Amphibian and Reptiles Reptile and amphibian presence in the vicinity of the Project Area was determined through review of the amphibian and reptile ODNR field guides. Based on this information, along with documented species ranges, it is estimated that 17 reptile and amphibian species could occur within 0.25 mile of the Project Area boundary. These species may include, but are not limited to common mudpuppy (Necturus maculosus), spotted salamander (Ambystoma maculatum), small-mouthed salamander (Ambystoma texanum), American toad (Anaxyrus americanus), Fowler’s toad (Anaxyrus fowleri), eastern cricket frog (Acris crepitans), spring peeper (Pseudacris crucifer), western chorus frog (Pseudacris triseriata), Cope’s gray treefrog (Hyla chrysoscelis), American bullfrog (Lithobates catesbeianus), northern green frog (Rana clamitans melanota), northern leopard frog (Lithobates pipiens), snapping turtle (Chelydra serpentina), queensake (Regina septemvittata), common watersnake (Nerodia sipedon sipedon), northern brownsnake/midland brownsnake (Storeria dekayi dekayi/Storeria dekayi wrightorum), and eastern gartersnake (Thamnophis sirtalis sirtalis) (ODNR, 2008; ODNR, 2012). The majority of species identified in Madison County are generally common and widely distributed throughout Ohio. One species of concern, the eastern cricket frog, was identified as having potential presence in Madison County. No other state- or federally-listed amphibian or reptile species were identified as occurring in Madison County.

Aquatic Species The potential occurrence of aquatic species in the vicinity of the Project Area was determined through review of the Ohio Aquatic Gap Analysis Program and ODNR data. Based on this information, it is estimated that approximately 94 species of fishes, 56 species of bivalves, and 7 species of crayfish could occur within 0.25 mile of the Project Area.

Fish species that may inhabit streams within 0.25 mile of the Project Area boundary include American brook lamprey (Lethenteron appendix), black bullhead (Ameiurus melas), fantail darter (Etheostoma flabellare), freshwater drum (Aplodinotus grunniens), ghost shiner (Notropis buchanani), golden redhorse (Moxostoma erythrurum), highfin carpsucker (Carpiodes velifer), Johnny darter (Etheostoma nigrum), least darter (Etheostoma microperca), longear sunfish (Lepomis megalotis), mooneye (Hiodon tergisus), muskellunge (Esox masquinongy), mottled sculpin (Cottus bairdi), northern hogsucker (Hypentelium nigricans), pumpkinseed (Lepomis gibbosus), redfin shiner (Lythrurus umbratilis), redside dace (Clinostomus elongatus), rainbow darter (Etheostoma caeruleum), river redhorse (Moxostoma carinatum), rockbass (Ambloplites rupestris), rosefin shiner (Lythrurus ardens), shorthead redhorse (Moxostoma macrolepidotum), skipjack herring (Alosa

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 71

chrysochloris), suckermouth minnow (Phenacobius mirabilis), tadpole madtom (Noturus gyrinus), Tippecanoe darter (Etheostoma tippecanoe), trout-perch (Percopsis omiscomaycus), variegate darter (Etheostoma variatum), yellow bullhead (Ameiurus natalis), and yellow perch (Perca flavescens). Potential impacts to wildlife from the construction or operation of the Facility are discussed below in Section 4906-4-08(B)(2-3).

Mollusk species that may occur within 0.25 mile of the Project Area boundary include black sandshell (Ligumia recta), clubshell (Pleurobema clava), creeper (Strophitus undulates), creek heelsplitter (Lasmigona compressa), cylindrical papershell (Anodontoides ferussacianus), deertoe (Truncilla truncate), elktoe (Alasmidonta marginata), elephantear (Elliptio crassidens), fatmucket (Lampsilis radiata), fawnsfoot (Truncilla donaciformis), giant floater (Pyganodon grandis), grooved fingernailclam (Sphaerium simile), kidneyshell (Ptychobranchus fasciolar), lilliput (Toxolasma parvus), long fingernailclam (Musculium transversum), mapleleaf (Quadrula quadrula), mucket (Actinonaias ligamentina), northern riffleshell (Epioblasma rangiana), Ohio pigtoe (Pleurobema cordatum), pondhorn (Uniomerus tetralasm), pink heelsplitter (Potamilus alatus), pink mucket (Lampsilis abrupta), Purple wartyback (Cyclonaias tuberculata), rabbitsfoot (Quadrula cylindrical), rayed bean (Villosa fabalis), rainbowshell (Villosa iris), round hickorynut (Obovaria subrotunda), round pigtoe (Pleurobema sintoxia), river fingernailclam (Sphaerium fabale), sheepnose (Plethobasus cyphyus), salamander mussel (Simpsonaias ambigua), snuffbox (Epioblasma triquetra), spike (Elliptio dilatata), striated fingernailclam (Sphaerium striatinum), tubercled blossom (Epioblasma torulosa), threehorn wartyback (Obliquaria reflexa), threeridge (Amblema plicata), white heelsplitter (Lasmigona complanata), wabash pigtoe (Fusconaia flava), wavyrayed lampmussel (Lampsilis fasciola), and yellow sandshell (Lampsilis teres). Potential impacts to wildlife from the construction or operation of the Facility are discussed below in Section 4906-4-08(B)(2-3).

Crayfish species that may occur within 0.25 mile of the Project Area boundary include little brown mudbug (Cambarus thomai), Ohio crawfish (Cambarus species A), paintedhand mudbug (Cambarus species B), rusty crayfish (Orconectes rusticus), Sanborn's crayfish (Orconectes sanbornii), Teays river crayfish (Cambarus sciotensis), and white river crayfish (Procambarus acutus). Potential impacts to wildlife from the construction or operation of the Facility are discussed below in Section 4906-4-08(B)(2-3).

These aquatic species are generally common and widely distributed throughout Ohio. However, the following state-listed endangered aquatic species may to occur in watersheds in the vicinity of the

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 72

Project Area: elephantear, northern riffleshell, snuffbox, clubshell, rabbitsfoot, and rayed bean (ODNR, 2016b). Additional state-listed species of concern within Madison County include least darter, river redhorse, elktoe, purple wartyback, wavy-rayed lampmussel, creek heelsplitter, round pigtoe, kidneyshell, and salamander mussel (ODNR, 2016b). A majority of the federally-listed and state-listed species predicted to occur within the Project Area are located within the Deer Creek watershed (above Oak Run, Sugar Run, and Glade Run; hydrological unit code [HUC] 05060002), which drains portions of Madison, Pickaway, and Ross Counties (Covert et al., 2007; Ohio EPA, 2013).

Commercial Species Commercial species consist of those trapped or hunted for fur. The ODNR regulates the hunting and trapping of the following furbearers in Madison County: common muskrat, raccoon, red fox, gray fox (Urocyon cinereoargenteus), coyote, American mink, Virginia opossum, striped skunk, long-tailed weasel, and American beaver (ODNR, 2019d). Each of these species is briefly described below, based on habitat and distribution data published by the ODNR (2016c, 2019e). • Common muskrat: Muskrat are abundant throughout Ohio, and prefer habitats with slow- moving water, such as creeks and wetlands. This species is likely to occur in the vicinity of the Project Area. • Raccoon: Raccoon are common statewide, occupying a wide variety of habitats near water, including forests, cropland, and developed land. Species density is low in Madison County, but the species could occur in the vicinity of the Project Area. • Red fox: Red fox are common statewide, occupying a wide variety of habitats, including forests, cropland, and developed land. Species density is low in Madison County, but the species could occur in the vicinity of the Project Area. • Gray fox: Less common in Ohio than the red fox, gray fox prefer forested and shrubland habitats, avoiding open areas. Although the Project Area is predominantly open agricultural land, this species could occur in low numbers in area woodlots and shrubland. • Coyote: Once extirpated in Ohio, coyotes are now common statewide, occupying a wide variety of habitats, including forests, cropland, shrubland, and developed land. This species has a high density in Madison County and is likely to occur in the vicinity of the Project Area. • American mink: This semi-aquatic weasel has a statewide distribution and favors forested wetlands with abundant cover. Although the Project Area is predominantly open agricultural land, this species could occur in low numbers in the area woodlands.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 73

• Virginia Opossum: Opossum are common statewide, occupying a wide variety of habitats, including forests, cropland, and developed land. Species density is low in Madison County, but it could occur in the vicinity of the Project Area. • Striped skunk: Skunk are common statewide, occupying a wide variety of habitats, including forests, cropland, and developed lands. This species is likely to occur in the vicinity of the Project Area. • Long-tailed weasel: Found in a wide variety of habitats including forests, cropland, and shrubland, this species is Ohio’s most common weasel and is likely to occur in the vicinity of the Project Area. • American beaver: Beavers are common statewide, inhabiting and modifying permanent sources of water of almost any type, particularly low gradient streams and small lakes and ponds with outlets. Species density is low in Madison County, but the species could occur in the vicinity of the Project Area.

Recreational Species Recreational species consist of those hunted as game. The ODNR regulates the hunting of the following species in Madison County: white-tailed deer, wild turkey (Meleagris gallopavo), gray squirrel, red squirrel (Tamiasciurus hudsonicus), fox squirrel, cottontail rabbit, ring-necked pheasant (Phasianus colchicus), American crow (Corvus brachyrhynchos), mourning dove, and various waterfowl (ODNR, 2019d). Each of these species are briefly described below, based on habitat and distribution data published by the ODNR (2013, 2016c, 2019e), and Christmas Bird Count (National Audubon Society, 2019).

• White-tailed deer: Deer are common statewide, occupying a wide variety of habitats, including forests, shrubland, cropland, and developed land. This species is likely to occur in the vicinity of the Project Area. • Wild turkey: Once extirpated in Ohio, this species has re-established populations statewide, and is especially common in the southern and eastern parts of the state. Wild turkey is an adaptable species that prefers mature forest habitats but live successfully in areas with as little as 15% forest cover. This species has a low population density in Madison County but could occur in the vicinity of the Project Area. • Gray, red, and fox squirrels: The fox squirrel is primarily an inhabitant of open woodlands, while the gray squirrel and the red squirrel prefer more extensive forested areas. However, all three species have adapted well to landscaped suburban areas and are often found

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 74

around structures. These tree squirrels occur throughout Ohio and are likely to occur in the vicinity of the Project Area. • Eastern cottontail rabbit: Cottontails are widespread and abundant statewide. The species prefers open areas bordered by brush and open woodlands and have adapted well to developed areas. This species is likely to occur in the vicinity of the Project Area. • Ring-necked pheasant: Although not native to North America, the pheasant is naturalized in northern and western Ohio and occupies open habitats such as agricultural landscapes and old fields. This species has been documented in the vicinity of the Project Area in the Audubon CBC. • American crow: Crows are common statewide, occupying a wide variety of habitats, including forests, cropland, shrubland, and developed land. This species has been documented in the vicinity of the Project Area in the Audubon CBC. • Mourning dove: Mourning doves are common statewide, occupying a wide variety of habitats, including cropland, shrubland, and developed land. This species was documented in the Audubon CBC. • Waterfowl: The following waterfowl game species have been recorded in the vicinity of the Project Area in the Audubon CBC: Canada goose, snow goose (Chen caerulescens), green-winged teal (Anas carolinensis), Ross’s goose (Chen rossii), mallard, American black duck (Anas rubripes), American coot, and wood duck (Aix sponsa).

(d) Results of Field Surveys for Plant and Animal Life Identified in Literature Review The literature review discussed in Section 4906-4-08(B)(1)(c) identified the potential presence of plants and animals in the vicinity of the Project Area based on previously published data. This review largely identified common species, but also indicated that some endangered, threatened, and special concern species could occur in the area. Of specific concern is the possible presence of the Indiana bat. In order to analyze the possible presence of the Indiana bat, Westwood analyzed habitat potential within the Project Area. This study was conducted in accordance with the USFWS’s 2017 Range-Wide Indiana Bat Summer Survey Guidelines and based on coordination with the local USFWS Field Office. This study is summarized below and provided in Appendix D of Exhibit I.

Westwood completed on-site habitat assessments in the Project Area for the Indiana bat on September 23, 2017, September 15, 2018, and November 19, 2019. The purpose of this study was to determine the quantity and quality of summer roosting and foraging habitat within the Project Area where potential impact may occur, as well as determine the potential effects of the Facility on Indiana bat habitat. Twelve

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 75

areas were evaluated for Indiana bat summer roost and foraging habitat, quantified, and given a ranking of ‘good,’ ‘fair’ or ‘poor’ based on criteria outlined by the USFWS’s 2017 Range-Wide Indiana Bat Summer Survey Guidelines. Criteria for this ranking is based on the following factors: vegetation density, dominant mature tree species, percent trees with exfoliating bark, size composition of live trees (diameter at breast height [dbh]), nearby water resources, and number of suitable snags.

Of the twelve areas, Westwood identified only one site (Area 1) as possessing ‘good’ habitat quality for the Indiana bat. This determination was based on the area’s close proximity to Deer Creek, 80% canopy coverage with low understory coverage, and solar availability. Three sites (Areas 2, 9, and 11) were characterized as ‘fair’ habitat due unfavorable distances from, and lack of corridor access to, water sources. The remainder of the sites were deemed unsuitable for summer roosting or foraging habitat for the Indiana bat due to dense understories, distance to water sources, and lack of suitable tree species. The Facility has been sited to avoid forested areas, so alteration or removal of large, continuous tracts of the assessed habitat is not anticipated. As a result, the Facility is not anticipated to impact Indiana bats.

No additional species-specific studies were conducted for the Facility. The Facility is sited primarily in agricultural fields which lack suitable habitat for common species and species of concern. Westwood did not identify additional wildlife species in the Project Area during field visits for wetland delineations or Indiana bat habitat assessment.

(e) Summary of Additional Ecological Impact Studies All of the ecological impact studies are discussed above in Section 4906-4-08(B)(1)(b) and (d).

(2) Construction Impacts

(a) Estimation of Impact of Construction on Undeveloped Areas, Plants, and Animals Since the Facility is located entirely on leased private land, there will be no construction-related impacts to recreational areas, parks, wildlife areas, nature preserves, or other conservation areas. Potential impacts to undeveloped areas, plants, and animals may occur during construction as a result of the installation of PV panels, access roads, and electrical interconnects; development and use of the laydown yard; and the construction of the collection substation. Anticipated impacts to these resources are discussed below.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 76

Impacts to Plants Construction activities that may result in impacts to vegetation include site preparation, earth-moving, excavation, and backfilling activities associated with construction of the laydown yard, access roads, substations, and buried electrical interconnect. These activities will result in the cutting and clearing of vegetation, the removal of stumps and root systems, and increased exposure or disturbance of soil. Along with direct loss of, and damage to, vegetation, these impacts can result in a loss of wildlife food sources and habitat, increased soil erosion and sedimentation, increased risk of colonization by non- native invasive species, and disruption of normal nutrient cycling; however, it is not anticipated that any plant species occurring in the Project Area will be extirpated or significantly reduced in abundance as a result of construction activities.

Impacts to Wildlife Species Construction-related impacts to wildlife are anticipated to be very limited. Based on the studies conducted to date, none of the construction-related impacts will be significant enough to affect local populations of any resident or migratory wildlife species. Potential impacts from construction are described below.

Incidental Injury and Mortality: Because most Facility components are sited in active agricultural land that provides limited wildlife habitat, and which currently and historically experiences frequent agricultural- related disturbances, such impacts are anticipated to be very minor.

Siltation and Sedimentation: To prevent adverse effects to water quality and aquatic habitat during construction, runoff will be managed under an NPDES construction storm water permit and the associated SWP3. An erosion and sediment control plan will be developed prior to construction that will use appropriate runoff diversion and collection devices. Also, because the majority of Facility components are being sited in active agricultural land, soil disturbance or exposure due to Facility construction will generally occur in areas already subject to regular plowing, tilling, harvesting, etc.

Habitat Loss: The Facility will be built on or adjacent to agricultural land, which generally provides habitat for only a limited suite of wildlife species. In addition, most of these areas are already subject to periodic disturbance in the form of mowing, plowing, harvesting, etc. Forest communities have largely been avoided and will experience limited construction-related disturbance. Based on the Facility layout, approximately 4.7 acres of woodland habitat will be permanently impacted by Facility construction. However, most of these impacts will be temporary (see Table 08-3).

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 77

Forest Fragmentation: As stated above, impacts to forest habitat will be largely avoided. The proposed Facility will result in minimal conversion of forest to successional community. In addition, potential impacts to forested habitat will generally occur at the edge of relatively small blocks of woodlots. This being the case, it is not anticipated that any forests will be significantly fragmented by construction of the proposed Facility.

Disturbance/Displacement: Some wildlife displacement may also occur due to increased noise and human activity as a result of Facility construction. The significance of this impact will vary by species and the seasonal timing of construction activities. Because most of the Facility occurs in agricultural land, species utilizing those habitats are most likely to be temporarily disturbed or displaced by Facility construction.

Impacts to Upland Habitat Table 08-4 quantifies impacts to ecological communities based on calculations from Westwood.

Table 08-4. Impacts to Ecological Communities Total Disturbance Temporary Permanent Impact Community1 (acres) Disturbance (acres) (acres) Agricultural 1,183.4 45.3 1,138.1 Grass/Pasture/Hay/Swale 22.6 1.1 21.5 Wooded Fencerow 4.0 0.3 3.7 Woodland 4.8 0.1 4.7 TOTAL 1,214.8 46.8 1,168.0 1 Ecological communities were digitized by Westwood using aerial imagery. Westwood then ran impact calculations based on digitized ecological communities.

Impacts to natural communities have been avoided to the extent possible. Of the 1,168.0 acres of permanent disturbance, 1,138.1 acres will occur within agricultural lands. Additional permanent impacts are anticipated to grass/pasture/hay/swale and wooded fencerow communities, totaling 21.5 acre and 3.7 acre, respectively.

Impacts to Wetland and Surface Water Habitats The proposed Facility has been designed to avoid impacting wetlands and surface waters, to the extent practicable, and to minimize such impacts where avoidance is not possible. The Facility has been sited in upland areas, currently or recently used for agricultural production. Additionally, collection lines that cross wetlands or streams have been routed overhead to further reduce potential impacts.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 78

Temporary impacts to wetlands and streams could occur during cut and fill activities for the laydown yard, access road, or trenching for underground collection lines. Impacts from cut and fill activities may also result in permanent impacts when they occur for long-term access roads, substations, and inverter pads. Wetland acreage within the Project Area totals 94.1 acres. Estimated permanent wetland impacts for the proposed Facility total 8.53 acres and are likely associated with the substation, access roads, overhead collection lines, and PV panel area. Estimated temporary wetland impacts for the Facility total 0.17 acre and are due to overhead and underground collection lines, and access roads. The Project Area contains approximately 25.8 acres of waterbodies. Estimated permanent waterbody impact for the Facility total 0.09 acre and is associated with portions of the overhead collection line. Estimated temporary stream impacts for the Facility total 0.32 acre and is associated with underground collection lines, access roads, and the proposed laydown yard. Additional details on wetland and streams impacts can be found in Table 08-5, below as well as in Appendix B of Exhibit I.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 79

Table 08-5. Wetland and Stream Impacts Wetland/Stream Wetland/Stream ORAM HHEI QHEI Anticipated Facility/ Crossing Impact Acreage or Impact Duration ID Type Score Score Score Jurisdiction Type Linear Feet (lf) WC-01 Perennial N/A 63 56 Jurisdictional Overhead Collection Permanent 0.06 ac. (55.62 lf.) Underground N/A 64 67.5 Jurisdictional WC-02 Perennial Collection Temporary 0.01 ac. (15.03 lf.) WB_06 PEM1A 9 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.09 ac. WC-06 Ephemeral N/A 15 None Jurisdictional Overhead Collection Temporary 0.00 ac. (47.47 lf.) WB_07 PEM1A 10 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.17 ac. WC-07 Ephemeral N/A 22 None Jurisdictional Laydown Yard Temporary 0.31 ac. (636.85 lf.) WB_08 PEM1A 8 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.04 ac. Underground 24 N/A N/A Jurisdictional WB_12 PEM1B Collection Temporary 0.02 ac. Underground 25 N/A N/A Non-Jurisdictional WB_13 PEM1B Collection Temporary 0.05 ac. WC-15 Ephemeral N/A 29 None Jurisdictional Portion Within Array Permanent 0.03 ac. (449.05 lf.) WC-16 Ephemeral N/A 19 None Jurisdictional Portion Within Array Permanent 0.03 ac. (271.95 lf.) WC-19 Ephemeral N/A 19 None Jurisdictional Portion Within Array Permanent 0.01 ac. (213.12 lf.) WB_20 PEM1A 9 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.15 ac. WB_21 PEM1A 10 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.56 ac. WB_22 PEM1A 22 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.30 ac. WB_23 PEM1A 8 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.09 ac. WB_24 PEM1A 20 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.08 ac. WB_25 PEM1A 13 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.10 ac. WB_28 PEM1A 21 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.15 ac. WB_29 PEM1A 25 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.17 ac. WB_30 PEM1A 20 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.09 ac. WB_31 PEM1A/B/C 32 N/A N/A Jurisdictional Access Road Permanent 0.02 ac. WB_31 PEM1A/B/C 32 N/A N/A Jurisdictional Access Road Temporary 0.01 ac. WB_31 PEM1A/B/C 32 N/A N/A Jurisdictional Portion Within Array Permanent 0.37 ac. WB_31 PEM1A/B/C 32 N/A N/A Jurisdictional Overhead Collection Permanent 0.17 ac. Underground 32 N/A N/A Jurisdictional WB_31 PEM1A/B/C Collection Temporary 0.01 ac. WB_31 PEM1A/B/C 32 N/A N/A Jurisdictional Substation Permanent 0.03 ac. WB_32 PEM1A 21 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.14 ac.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 80

Wetland/Stream Wetland/Stream ORAM HHEI QHEI Anticipated Facility/ Crossing Impact Acreage or Impact Duration ID Type Score Score Score Jurisdiction Type Linear Feet (lf) WB_43 PEM1A 25 N/A N/A Jurisdictional Overhead Collection Permanent 0.01 ac. WB_46 PEM1B/C 21 N/A N/A Jurisdictional Portion Within Array Permanent 0.05 ac. WB_47 PEM1A 27 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.05 ac. WB_48 PEM1A 21 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.11 ac. WB_49 PEM1A 20 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.08 ac. WB_56 PEM1A 10 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.26 ac. WB_60 PEM1A 32 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.13 ac. Underground 32 N/A N/A Non-Jurisdictional WB_60 PEM1A Collection Temporary 0.01 ac. Underground N/A 56 40 Jurisdictional WC-100 Perennial Collection Temporary 0.01 ac. (15.33 lf.) WC-101 Ephemeral N/A 6 None Jurisdictional Access Road Temporary 0.00 ac. (2.38 lf.) WB_101 PEM1Bf 16 N/A N/A Jurisdictional Portion Within Array Permanent 0.37 ac. WB_103 PEM1Af 19 N/A N/A Jurisdictional Portion Within Array Permanent 0.03 ac. WB_105 PEM1Af 15 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.09 ac. WB_106 PEM1Af 20 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.04 ac. WB_108 PEM1Af 17 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.49 ac. WB_109 PEM1Af 23 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.04 ac. Underground 23 N/A N/A Non-Jurisdictional WB_109 PEM1Af Collection Temporary 0.01 ac. WB_110 PEM1B 28 N/A N/A Jurisdictional Access Road Permanent 0.05 ac. WB_110 PEM1B 28 N/A N/A Jurisdictional Access Road Temporary 0.01 ac. WB_110 PEM1B 28 N/A N/A Jurisdictional Portion Within Array Permanent 0.56 ac. WB_111 PEM1Af 21 N/A N/A Non-Jurisdictional Access Road Permanent 0.03 ac. WB_111 PEM1Af 21 N/A N/A Non-Jurisdictional Access Road Temporary 0.00 ac. (106.92 sf.) WB_111 PEM1Af 21 N/A N/A Non-Jurisdictional Portion Within Array Permanent 0.11 ac. Underground 21 N/A N/A Non-Jurisdictional WB_111 PEM1Af Collection Temporary 0.00 ac. (167.86 sf.) WB_112 PEM1B 29 N/A N/A Jurisdictional Portion Within Array Permanent 1.09 ac. WB_116 PEM1Af 17 N/A N/A Non-Jurisdictional Portion Within Array Permanent 1.12 ac. Underground 17 N/A N/A Non-Jurisdictional WB_116 PEM1Af Collection Temporary 0.01 ac. WB_117 PEM1Af 20 N/A N/A Non-Jurisdictional Access Road Permanent 0.00 ac. (132.86 sf.)

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 81

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 82

(b) Description of Short-term and Long-term Mitigation Procedures To minimize Facility-related impacts on surface waters and wetlands, the Facility design was guided by the following criteria during the siting of PV panels and related infrastructure.

• Large built components of the Facility such as PV panels are sited to avoid wetlands and surface waters. • The number and overall impacts due to access road crossings are minimized by routing around wetlands and streams whenever possible, and by utilizing existing crossings and narrow crossing locations to the extent practicable. • Buried electric interconnect lines avoid crossing wetlands where possible, cross streams at existing or previously disturbed locations to the extent practicable, and utilize installation techniques that minimize construction-related impacts to surface waters. • Overhead collection lines are utilized to further avoid impact to wetlands and surface waters. • Woodlots are avoided, thereby minimizing forest fragmentation

Other on-site environmental or logistical constraints, such as stands of mature forest, landowner concerns, and other current land use, may make further avoidance of streams unfeasible. Where crossings of wetlands or surface waters are required, the Application will employ applicable best management practices. Specific mitigation procedures for protecting wetland, surface water resources, vegetation, and major species and their habitats are described below.

(i) Site restoration and stabilization of disturbed soils Following completion of construction, temporarily impacted areas will be restored to their preconstruction condition. Restoration activities are anticipated to include the following:

• Buried electrical interconnect routes will be restored to pre-construction contours as necessary and allowed to regenerate naturally. • Disturbed soils within the Facility’s fence line will be re-seeded with a low-growth, native seed mix to stabilize exposed soils and control sedimentation and erosion. • The laydown yard will be removed post-construction, followed by gravel removal and soil decompaction.

All removed material and demolition debris will be stockpiled in designated locations. Each stockpile will be transported off-site to either a recycling center, when feasible, or to an approved landfill

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 83

depending on the material type. Debris will be broken down into manageable sizes to aid in the transportation.

The objectives of reclamation and revegetation are to return the disturbed areas to approximately pre-construction use and capability. This involves the treatment of soil as necessary to preserve approximate pre-construction capability and the stabilization of the work surface in a manner consistent with the initial land use.

(ii) Frac out contingency plan No horizontal directional drilling is proposed as part of the Facility, therefore a frac out contingency plan is not included in this application.

(iii) Methods to demarcate surface waters and wetlands during construction The boundaries of jurisdictional streams and wetlands within and immediately adjacent to the construction limits of disturbance will be demarcated with highly visible flagging, staking, or fencing prior to construction. These sensitive areas will also be depicted on construction drawings. All contractors and subcontractors working on-site will be provided with training to understand the significance of the types of flagging used, and the importance of staying within defined limits of work areas, especially in and adjacent to marked sensitive resource areas such as wetlands.

(iv) Inspection procedures for erosion control measures The Applicant will seek coverage for the Facility under the Ohio EPA construction stormwater general NPDES permit. The NPDES permit requires development of a SWP3 for erosion control and stormwater management.

To avoid and minimize impacts to aquatic resources resulting from construction-related siltation and sedimentation, an approved SWP3 will be implemented. To protect surface waters, wetlands, groundwater, and stormwater quality, erosion and sediment control measures will be installed and maintained throughout site development. Such measures might include silt fence, hay bales, and/or temporary siltation basins. Best Management Practices for erosion and sedimentation control are provided in Exhibit C. The location of these features will be detailed on the construction drawings, approved by the Ohio EPA as part of the NPDES review, and reviewed by the contractor prior to construction.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 84

Erosion and sediment control measures will be inspected by a qualified individual throughout the construction phase to assure that they are functioning properly until completion of all restoration work. Disturbed areas and areas used for storage of materials that are exposed to precipitation shall be inspected for evidence of, or the potential for, pollutants entering the drainage system. Locations where vehicles enter or exit the site shall be inspected for evidence of off-site vehicle tracking. Inspections will be conducted at least once every seven calendar days, and within 24 hours after any storm event with 0.5 inch or greater of rain. This inspection frequency may be reduced to once every month if the entire site is temporarily stabilized and runoff is unlikely due to weather conditions such as snow, ice, or frozen ground.

Following each inspection, the qualified inspector will complete and sign a checklist and inspection report. At a minimum, the inspection report shall include:

• the inspection date; • names, titles, and qualifications of personnel making the inspection; • weather information for the period since the last inspection (or since commencement of construction activity if the first inspection) including a best estimate of the beginning of each storm event, duration of each storm event, approximate amount of rainfall for each storm event (in inches), and whether any discharges occurred; • weather information and a description of any discharges occurring at the time of the inspection; • locations of any BMPs that need to be maintained; and • any corrective actions recommended.

For three years following the submittal of a notice of termination form, the Applicant will maintain a record summarizing the results of the SWP3 inspections described above, including the names(s) and qualifications of personnel making the inspection, the date(s) of the inspection, major observations relating to the implementation of the SWP3, and a signed certification as to whether the facility is in compliance with the SWP3.

As described above, a duly-qualified individual will also inspect these features throughout the construction phase to assure that they are functioning properly until completion of all restoration work.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 85

(v) Measures to protect vegetation Protection of vegetation will be primarily accomplished through careful site planning. A majority of Facility components have been sited on agricultural land, thus avoiding significant impacts to successional grasslands, shrubland, forested, and wetland areas. In addition to siting, measures to protect vegetation include the identification of sensitive areas such as wetlands where no disturbance or vehicular activities will be allowed, limiting areas of disturbance to the smallest size practicable, educating the construction workforce on respecting and adhering to the physical boundaries of off- limit areas, employing best management practices during construction, and maintaining a clean work area within the designated construction sites. Following construction activities, temporarily disturbed areas will be seeded, and stabilized with mulch and/or straw if necessary, to reestablish vegetative cover in these areas. Other than in active agricultural fields, native species will be allowed to revegetate all temporarily disturbed areas.

(vi) Options for clearing methods and disposing of brush Facility construction will require clearing or permanent disturbance of approximately 1,172.1 acres of vegetation (see Table 08-3). Although more than 97% of this disturbance will occur in agricultural lands, Facility construction may require the clearing or permanent disturbance of 8.4 acres of tree stands located in wooded fencerow and woodland communities. Trees cleared from the work area will be cut into logs and either left for the landowner or removed, while limbs and brush will be buried, chipped, or otherwise disposed of as directed by the landowner and as allowed under federal, state, and local regulations. Using these methods avoids the need and movement of heavy vehicles, further limiting the impact of construction at the Project Area.

(vii) Avoidance measures for state or federally listed and protected species and their habitats To minimize impacts to wildlife species and their habitats, Facility components will be sited away from sensitive habitats, such as forestland, streams and wetlands, to the extent practicable. As a result, construction-related impacts to wildlife are anticipated to be very limited. The following avoidance measures will further reduce construction impacts to major species and their habitats:

• Forested areas will be avoided to the greatest extent practicable where Indiana bat habitat was categorized as ‘good’ (according to Westwood’s study provided as Appendix B of Exhibit I). • To prevent adverse effects to aquatic species and their habitats during construction, runoff will be managed under an NPDES construction storm water permit and the associated SWP3. An

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 86

erosion and sediment control plan will be developed prior to construction that will use appropriate runoff diversion and collection devices.

Most of the state-listed plant species found in Madison County occur in wetland habitats which, as indicated above, have been avoided during Facility siting to the extent practicable. These avoidance efforts notwithstanding, a limited amount of minor permanent and temporary surface water impact from discharge of fill material is unavoidable during construction of the Facility.

Specific mitigation measures for protecting wetlands and surface water resources will include designating no equipment access areas and restricted activity areas and employing low impact stream crossing techniques. Each of these mitigation measures is described below.

Low Impact Stream Crossing Techniques: Where crossings of surface waters are required, best management practices associated with applicable streamside activities will be implemented. The Applicant will adhere to any permit conditions pertaining to low impact stream crossing techniques, including seasonal restrictions and/or alternative stream crossing methods, such as temporary bridging and installation of crossings "in the dry." Open-bottomed or elliptical culverts may be utilized on certain streams to minimize loss of aquatic habitat and restriction of fish passage. Utilizing these techniques should avoid or minimize any adverse impacts on fish and other aquatic organisms.

(3) Operation Impacts

(a) Estimation of Impact of Operation on Undeveloped Areas, Plants, and Animals Aside from minor disturbance associated with routine maintenance and occasional repair activities, no other disturbance to plants, vegetative communities, wetlands, or surface waters are anticipated as a result of Facility operation. As previously indicated, the Facility is located entirely on leased private land. Therefore, the built Facility will not result in physical disturbance or impacts to recreational areas, parks, wildlife areas, nature preserves, or other conservation areas as identified in Section 4906-4-08(B)(1)(a).

(b) Procedures to Avoid, Minimize, and Mitigate Short-term and Long-term Operational Impacts The Applicant has sited the Facility to avoid wetlands and streams to the maximum extent practicable. Best management practices, examples of which are provided in Exhibit C, will be employed to further reduce potential impacts to those resources. Final practices will be detailed in the SWP3.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 87

Forested areas that may contain mature trees will be avoided to the maximum extent practicable, minimizing impacts of forest fragmentation and suitable wildlife habitat. In addition, tree clearing activities will take place during the winter when bats are hibernating or have migrated south, and have minimization measures to avoid direct take of bats will be implemented for all tree clearing that occurs outside of this time period. Herbicide may be used, as necessary, around fence lines; however, applications will be made by a licensed professional and will be applied in accordance to manufacturer instructions.

Direct impacts to wildlife from an operational solar facility in Ohio are low. Solar facilities do not have the same collision risk for avian and bat species as wind facilities. Additionally, the diversity in landscape, vegetation, and topography within Ohio further limits the threat of collision for avian and bat species. Since no significant operational impacts to these resources are anticipated, no mitigation measures are proposed.

(c) Post-Construction Monitoring Plans The Applicant has no plans for post-construction monitoring of wildlife impacts because no significant impacts from the construction or operation of the Facility are anticipated. The Facility does not include any large moving parts, is situated in a diverse ecosystem with plenty of water sources and will not result in environmental discharges during operation that may impact wildlife and their habitat.

(1) Land Use

(a) Land Use Map Land uses within one mile of the Facility are shown on Figure 08-5. Land use mapping was developed using parcel data obtained from the Madison County Auditor’s Office. Among other information, Figure 08-5 shows the following features:

(i) The proposed Facility, including the preliminary layout. (ii) Land use (iii) Structures (iv) Incorporated areas and population centers

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 88

(b) Structures and Property Lines Tables (i) Distance between existing structures and property lines, and the PV panels Distances between the PV panels and existing structures within 1,500 feet are shown in Table 08-6 below. Distances between the PV panels and property lines within 1,500 feet are shown in Table 08-7 below.

There are 76 structures within 1,500 feet of a PV panel. Table 08-6 presents the distance to the nearest PV panel and the lease status of the underlying parcels (i.e., participating or non-participating parcel).

Table 08-6. Structures Within 1,500 feet of a PV Panel

Lease Status of Structure Type Distance to PV Panel1 Underlying Parcel2 Agricultural 0 Participating Residence 0 Participating Storage/Shed 0 Participating Storage/Shed 129 feet Participating Storage/Shed 211 feet Participating Residence 222 feet Participating Residence 243 feet Non-Participating Residence 251 feet Participating Residence 271 feet Non-Participating Storage/Shed 272 feet Participating Storage/Shed 275 feet Participating Residence 286 feet Participating Storage/Shed 290 feet Participating Residence 294 feet Participating Residence 302 feet Participating Residence 308 feet Participating Residence 350 feet Participating Agricultural 351 feet Participating Storage/Shed 351 feet Non-Participating Storage/Shed 359 feet Participating Agricultural 386 feet Participating Residence 405 feet Non-Participating Storage/Shed 414 feet Participating

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 89

Lease Status of Structure Type Distance to PV Panel1 Underlying Parcel2 Agricultural 429 feet Participating Residence 447 feet Participating Storage/Shed 468 feet Non-Participating Residence 489 feet Non-Participating Residence 519 feet Participating Agricultural 540 feet Participating Residence 549 feet Non-Participating Storage/Shed 566 feet Participating Agricultural 569 feet Non-Participating Agricultural 585 feet Participating Agricultural 592 feet Non-Participating Residence 599 feet Participating Storage/Shed 619 feet Non-Participating Residence 629 feet Non-Participating Storage/Shed 639 feet Non-Participating Storage/Shed 648 feet Non-Participating Storage/Shed 655 feet Non-Participating Residence 667 feet Non-Participating Storage/Shed 674 feet Non-Participating Residence 713 feet Non-Participating Storage/Shed 718 feet Non-Participating Residence 726 feet Non-Participating Residence 757 feet Non-Participating Storage/Shed 775 feet Non-Participating Storage/Shed 779 feet Non-Participating Residence 823 feet Non-Participating Residence 841 feet Non-Participating Residence 865 feet Non-Participating Residence 889 feet Non-Participating Residence 935 feet Non-Participating Storage/Shed 1,027 feet Non-Participating Residence 1,049 feet Non-Participating Residence 1,055 feet Non-Participating Residence 1,072 feet Non-Participating Residence 1,073 feet Non-Participating

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 90

Lease Status of Structure Type Distance to PV Panel1 Underlying Parcel2 Storage/Shed 1,121 feet Non-Participating Agricultural 1,207 feet Non-Participating Storage/Shed 1,211 feet Non-Participating Residence 1,221 feet Non-Participating Agricultural 1,222 feet Non-Participating Residence 1,239 feet Non-Participating Storage/Shed 1,261 feet Non-Participating Storage/Shed 1,270 feet Non-Participating Storage/Shed 1,273 feet Non-Participating Residence 1,274 feet Non-Participating Storage/Shed 1,287 feet Non-Participating Storage/Shed 1,294 feet Non-Participating Agricultural 1,322 feet Non-Participating Agricultural 1,408 feet Non-Participating Residence 1,422 feet Non-Participating Storage/Shed 1,428 feet Non-Participating Storage/Shed 1,466 feet Non-Participating Agricultural 1,483 feet Non-Participating 1 Receptors with a ‘Distance to PV Panel’ equal to 0 feet represent those within an area being considered for panels. First Solar and respective landowners are in lease agreement talks. 2 Parcels anticipated to be under a lease or easement agreement at the time of Facility construction are identified as participating parcels for the purposes of this Application

There are 75 properties within 1,500 feet of a PV panel. For each of these properties, Table 08-7 presents the distance to the nearest PV panel and the lease status of the parcel (i.e., participating or non-participating).

Table 08-7. Parcels Within 1,500 feet of a PV Panel

Parcel ID Distance to PV Panel Lease Status1 07-00294.000 63 feet Non-Participating 07-00077.000 65 feet Non-Participating 07-00088.000 35 feet Non-Participating 13-00171.000 70 feet Non-Participating 13-00012.000 74 feet Non-Participating 13-00049.005 75 feet Non-Participating 07-00734.000 75 feet Participating

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 91

Parcel ID Distance to PV Panel Lease Status1 07-00116.000 79 feet Non-Participating 13-00157.008 102 feet Non-Participating 13-00045.010 103 feet Non-Participating 07-00697.001 104 feet Non-Participating 07-00354.000 107 feet Non-Participating 13-00045.003 112 feet Non-Participating 07-00706.001 117 feet Non-Participating 07-00652.000 118 feet Participating 07-00175.000 124 feet Non-Participating 07-00014.000 132 feet Non-Participating 07-00179.001 144 feet Non-Participating 07-00014.001 146 feet Non-Participating 13-00062.000 157 feet Non-Participating 07-00698.000 161 feet Non-Participating 13-00062.000 164 feet Non-Participating 13-00062.002 168 feet Non-Participating 07-00239.000 182 feet Non-Participating 13-00160.000 190 feet Non-Participating 07-00175.004 207 feet Non-Participating 07-00706.001 221 feet Non-Participating 07-00238.000 246 feet Non-Participating 13-00049.001 250 feet Non-Participating 07-00077.000 269 feet Non-Participating 07-00175.005 272 feet Non-Participating 07-00356.000 283 feet Non-Participating 13-00048.000 293 feet Participating 13-00049.002 295 feet Non-Participating 07-00537.000 296 feet Non-Participating 07-00175.002 307 feet Non-Participating 07-00322.001 329 feet Non-Participating 07-00358.000 330 feet Non-Participating 13-00045.008 339 feet Non-Participating 13-00045.006 345 feet Participating 13-00154.000 361 feet Non-Participating 13-00021.000 385 feet Non-Participating 07-00490.000 440 feet Non-Participating

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 92

Parcel ID Distance to PV Panel Lease Status1 13-00116.001 445 feet Non-Participating 13-00045.004 516 feet Non-Participating 07-00018.000 542 feet Non-Participating 07-00322.002 553 feet Non-Participating 07-00037.002 557 feet Non-Participating 07-00037.003 589 feet Non-Participating 13-00115.000 622 feet Non-Participating 07-00037.004 629 feet Non-Participating 13-00045.005 641 feet Non-Participating 13-00045.007 648 feet Non-Participating 07-00037.005 676 feet Non-Participating 13-00048.000 679 feet Participating 13-00049.004 718 feet Non-Participating 07-00037.000 758 feet Non-Participating 13-00045.009 841 feet Non-Participating 13-00045.012 873 feet Non-Participating 13-00045.002 880 feet Non-Participating 13-00160.001 922 feet Non-Participating 13-00002.000 941 feet Non-Participating 07-00275.001 953 feet Non-Participating 13-00049.003 965 feet Non-Participating 13-00045.011 973 feet Non-Participating 07-00275.004 1,044 feet Non-Participating 13-00062.001 1,066 feet Non-Participating 07-00358.002 1,085 feet Non-Participating 13-00116.000 1,164 feet Non-Participating 13-00036.009 1,230 feet Non-Participating 07-00252.000 1,238 feet Non-Participating 13-00157.000 1,261 feet Non-Participating 13-00160.000 1,304 feet Non-Participating 07-00037.001 1,310 feet Non-Participating 07-00493.000 1,360 feet Non-Participating 1 Parcels anticipated to be under a lease or easement agreement at the time of Facility construction are identified as participating parcels for the purposes of this Application

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 93

(ii) Distance between existing structures and property lines, and associated facilities Distances between associated facilities and existing structures within 250 feet are shown in Table 08-8 below. Distances between the associated facilities and property lines within 250 feet are shown in Table 08-9 below.

There are 12 structures within 250 feet of an associated Facility component including collection line, access road, laydown yard, or collection substation.

Table 08-8. Structures Within 250 Feet of an Associated Facility

Distance to Facility Closest Facility Lease Status of Structure Type Component Component Underlying Parcel1 Residence 50 feet Underground Collection Line Participating Storage/Shed 89 feet Underground Collection Line Participating Storage/Shed 101 feet Underground Collection Line Participating Residence 128 feet Underground Collection Line Non-Participating Residence 152 feet Underground Collection Line Non-Participating Residence 163 feet Access Road Non-Participating Storage/Shed 163 feet Underground Collection Line Non-Participating Residence 181 feet Access Road Non-Participating Residence 194 feet Underground Collection Line Non-Participating Storage/Shed 207 feet Underground Collection Line Non-Participating Agricultural 208 feet Underground Collection Line Participating Storage/Shed 215 feet Underground Collection Line Non-Participating 1 Parcels anticipated to be under a lease or easement agreement at the time of Facility construction are identified as participating parcels for the purposes of this Application

There are 30 parcels within 250 feet of an associated facility. This total includes 10 parcels that are within 250 feet of multiple associated facilities. For each occurrence of an associated facility within 250 feet of a property line, Table 08-9 presents the distance to the parcel boundary and the lease status of the parcel (i.e., participating or non-participating).

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 94

Table 08-9. Parcels Within 250 Feet of an Associated Facility

Anticipated Lease Parcel ID Distance Associated Facility Status1 3 feet Overhead Collection Line 07-00014.000 Non-Participating 32 feet Access Road 07-00014.001 5 feet Underground Collection Line Non-Participating 07-00037.000 22 feet Access Road Non-Participating 07-00037.002 134 feet Access Road Non-Participating 07-00037.003 70 feet Access Road Non-Participating 07-00037.004 23 feet Access Road Non-Participating 07-00037.005 22 feet Access Road Non-Participating 40 feet Access Road 07-00088.000 Non-Participating 230 feet Underground Collection Line 41 feet Underground Collection Line 07-00116.000 Non-Participating 54 feet Overhead Collection Line 67 feet Underground Collection Line 07-00175.000 71 feet Access Road Non-Participating 94 feet Overhead Collection Line 07-00238.000 49 feet Access Road Non-Participating 25 feet Access Road 07-00239.000 56 feet Underground Collection Line Non-Participating 184 feet Underground Collection Line 30 feet Access Road 07-00323.000 Participating 54 feet Underground Collection Line 129 feet Access Road 07-00354.000 Non-Participating 159 feet Underground Collection Line 07-00356.000 170 feet Access Road Non-Participating 07-00358.000 47 feet Access Road Non-Participating 07-00537.000 24 feet Access Road Non-Participating 07-00697.001 128 feet Access Road Non-Participating 07-00698.000 116 feet Access Road Non-Participating 07-00706.000 57 feet Underground Collection Line Participating 82 feet Underground Collection Line 07-00706.001 Non-Participating 90 feet Underground Collection Line 60 feet Overhead Collection Line 13-00045.003 Non-Participating 149 feet Underground Collection Line 13-00045.005 174 feet Overhead Collection Line Non-Participating 87 feet Overhead Collection Line 13-00045.006 Participating 174 feet Underground Collection Line 13-00045.010 20 feet Access Road Non-Participating

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 95

Anticipated Lease Parcel ID Distance Associated Facility Status1 13-00049.001 66 feet Overhead Collection Line Non-Participating 13-00049.002 132 feet Access Road Non-Participating 13-00062.000 180 feet Access Road Non-Participating 13-00062.002 121 feet Access Road Non-Participating 13-00160.000 7 feet Access Road Non-Participating 1 Parcels anticipated to be under a lease or easement agreement at the time of Facility construction are identified as participating parcels for the purposes of this Application

(iii) Land/lease status of the property for each structure The lease status for each structure and property within 1,500 feet of a PV panel and each structure and parcel within 250 feet of an associated facility is presented above in Table 08-8 and Table 08-9, respectively.

(c) Land Use Impacts Table 08-10 below represents the impacts assumptions used to calculate land use impacts for each Facility component.

Table 08-10. Impact Assumptions Area of Total Soil Area of Temporary Area of Permanent Disturbance (maximum area of Facility Components (fill/structures) (temporary and vegetation clearing) Disturbance permanent) Disturbance Potential Solar Field1 1,121.5 acres None 1121.5 acres 25 feet wide per linear 25 feet wide per linear 20 feet wide per linear Access Roads foot of road foot of road foot of road Buried Electrical 15 feet wide per linear 15 feet wide per linear None Collection Cables foot of cable foot of cable Overhead Electrical 50 feet per linear foot 50 feet per linear foot of None Collection Cables2 of cable cable Laydown Yard 16 acres 16 acres None Collection Substation 4 acres None 4 acres 0.32 acre Inverter Pad3 0.32 acre None

1 Permanent impacts to solar fields includes the entire area underneath the panels, since that area will experience permanent shading and will be taken out of its’ intended use for 30-40 years. 2 Overhead collection lines will maintain a ROW of 50 feet. There is an additional impact of 4 square feet per pole. The Facility will include approximately 50 poles to support overhead lines. 3 The footprint of 1 inverter pad is 300 square feet. There are 46 inverter pads proposed for the Facility

Table 08-11 presents the total, temporary, and permanent land use impacts on the land uses illustrated in Figure 08-5, in total for each land use type and by Facility component. Facility-related impacts to land

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 96

use were calculated based on the impact assumptions provided in Table 08-10 of this application and the land use codes for each parcel, provided by Madison County. In ArcGIS, Facility components were intersected with the parcel shapefiles, resulting in shapefiles of impacts to each land use associated with the respective Facility components, and then the impact areas or lengths for all Facility components were entered into a spreadsheet. For example, the impact from PV panels is considered permanent due to the permanent change of habitat below the panels due to permanent shading. This permanent loss or disturbance totals 1,121.5 acres. In addition, this land will be unavailable for other uses for the life of the Facility. All parcels containing PV panels have a land use code that indicates agricultural uses, so 1,121.5 acres of impact is to agricultural land. For linear components such as access roads and collection lines, the appropriate impact widths from Table 08-10 were multiplied by the lengths to create an area of impact. Finally, using the spreadsheet, the separate areas of impact for each Facility component were added together, resulting in the temporary, permanent, and total areas of impact associated with each component and for each land use type.

Table 08-11. Land Use Impacts

Total Disturbance Temporary Permanent Loss Land Use (acres) Disturbance (acres) (acres) Agricultural (100) PV Panel 1,121.5 0 1,121.5 Access Roads 40.5 8.1 32.4 Buried Electrical 22.7 22.7 0.0 Collection Cable Overhead Electrical 9.8 0.0 9.8 Collection Cable Laydown Yard 16.0 16.0 0.0 Collection Substation 4.0 0.0 4.0 Inverter Pads 0.3 0.0 0.3 Total 1,214.8 46.8 1,168.0

Although changes in land use are anticipated within the Project Area as a result of Facility operation, no changes are predicted outside the Project Area. The presence of the PV panels, collection substation, and other ancillary structures will result in the cumulative conversion of 1,168.0 acres of land from its current use to built facilities, which represents approximately 48% of the 2,438 acres of leased land. During Facility operation, additional impacts on land use should be infrequent and minimal. All of the impacts from Facility construction and operation will occur on agricultural land.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 97

Construction impacts will be temporary in nature and confined to the properties of participating landowners. As described in Section 4906-4-08(E)(2)(b), the Applicant has developed construction specifications for construction activities occurring partially or wholly on privately owned agricultural land. These specifications, along with special siting considerations, will minimize impacts to agricultural land uses in the Project Area.

(d) Structures That Will Be Removed or Relocated Three structures, including one residence, one barn, and one shed, may be removed for construction and operation of this Facility. The Applicant and respective landowners are currently in discussion regarding land rights and use. These discussions are ongoing as the Facility design process progresses and finalizes.

(2) Wind Farm Parcel Status Map

This requirement is not applicable to this Facility because the Facility is not a wind farm.

(3) Setback Waiver

The requirements of Section 4906-4-08(C)(3) are specifically intended for wind powered facilities. The Applicant is proposing a solar powered facility; therefore, the requirements set forth in Section 4906-4-08(C)(3) do not apply.

(4) Land Use Plans

(a) Formally Adopted Plans for Future Use of Site and Surrounding Lands Four entities within five miles of the Project have adopted comprehensive land use and economic development plans, including Madison County, Franklin County, Pleasant Township, and the City of London. Each of these are summarized below:

• 2014 Madison County Comprehensive Plan: The plan features a series of goals, objectives, and policies to guide land use decisions. The plan represents all unincorporated areas of the County, which includes the host communities for this Facility. Most of Madison County is agricultural, with some forest stands and riparian conservation areas, and a limited number of general commercial and single-family residential parcels. The primary land use goal in the plan is to “… achieve a high quality of life for residents through thoughtful land use patterns, and to respect the integrity of the natural environment while encouraging community development that meets

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 98

the social and economic needs of residents.” (Madison County Commissioners, 2014, p.10). The most relevant policies to this effect include the preservation of agricultural lands and open space, discouragement of the conversion of prime agricultural lands to non-agricultural uses, and preservation of flood plains, dense forestland, steep slopes, and stream and river corridors. The plan focuses heavily on the discouragement of suburban sprawl and related impacts, specifically sprawl resulting from the expansion of the Columbus Metropolitan Area.

With respect to environmental goals, the County maintains the following policy: “Madison County, while maintaining its autonomy over the land and use within its jurisdiction, will consider input from public and private groups in their effort to preserve and protect unique and natural areas and preserves in the county.” (Madison County Commissioners, 2014, p.59). The plan establishes multiple land use categories. One such category, the Agricultural Preservation Area, stipulates that “Areas [in this category] … should not be used for urban development or zoning changes which would allow additional rural residential development… This land is considered prime farmland and should be used as such. Uses that benefit the agricultural community should be allowed at strategic locations along the major roads.”

This Facility is compatible with the overall agricultural use of the area by providing supplemental income for existing landowners to continue existing agricultural practices. Additionally, following decommissioning of the Facility, land within the Project Area will be returned to a preconstruction state, allowing landowners to resume agricultural operations if they so choose.

• 2019 Franklin County Economic Development Strategic Plan: This strategic plan provides a roadmap for economic development work in Franklin County and focuses on business engagement and private-sector job creation. Key priorities outlined in this plan include: (1) assisting Franklin County’s preparation for anticipated job and population change, (2) promoting quality work opportunities, (3) including resident perspectives in economic development efforts, (4) reducing disparities and expanding economic inclusion for county residents, and (5) encouraging commercial activities in which entrepreneurs and small businesses from all backgrounds are able to start and grow (Hackler and Harpel, 2019).

In terms of economic development, the Facility offers an opportunity for the use of local goods and services, including but not limited to labor, equipment, and maintenance. In addition, the payments associated with land leases provide additional income for landowners, including

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 99

agricultural producers, and in doing so, improves the economic conditions for existing farming practices.

• 2009 Pleasant Township Comprehensive Plan: This plan, adopted in 2009 by the Franklin County Board of Commissioners, serves as a guide for future land use and recommendations for land use, building appearance, designation of preservation areas, and desired public improvements. The plan prioritizes rural character, safe transportation, and environmental character (Weiner et.al, 2009). The portion of the Township within five miles of the Project Area is categorized as agricultural land use. In order to preserve rural character, the plan recommends enhancing its sense of place via a variety of actions including establishing scenic byways along six roads within the township, one of which, Georgesville-Wrightsville Road, is located within five miles of the Project Area. An additional strategy of the plan is to preserve and enhance agricultural production.

While the Facility does not directly impact Pleasant Township, it is compatible with the comprehensive plan, which seeks to achieve environmental protection through the use of alternative energy sources.

• 2008 City of London Comprehensive Plan: The 2008 Comprehensive Plan Update for the City of London includes sections on Parks, Environment, Water Facilities, Transportation, Land Use, Commercial Development, Downtown, Agriculture, and Community Facilities. The City seeks to support commercial and industrial growth, particularly within key downtown areas, and to attract commercial activity through “London’s natural attractions including bike trails, parks, sports facilities, agricultural heritage, and historic buildings.” The City’s environmental goals include protecting the natural resources, soil, and water of London. Proposed objectives toward this end include a variety of green infrastructure and conservation measures (City of London, 2008).

While the Facility does not directly impact the City of London, it would not adversely affect the goals and objectives outline in the City’s comprehensive plan.

(b) Applicant’s Plans for Concurrent or Secondary Uses of the Site The Applicant has no plans for concurrent or secondary uses of the site.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 100

(c) Impact on Regional Development The regional economy surrounding the Facility is shaped in large part by the agricultural industries of Madison, Franklin, and Pickaway counties. While the area within five miles of the Project Area is predominantly rural, it includes the City of London and the village of West Jefferson. Additionally, the City of Columbus is a significant metropolitan region near the Facility. The regional context for the development of this Facility is discussed in further detail below, concentrating on five primary components: housing, commercial and industrial development, schools, transportation, and other public services and facilities. In addition, the compatibility of the proposed Facility with regional developmental goals and plans is reviewed.

Housing According to the U.S. Census Bureau’s 2013-2017 American Community Survey 5-Year Estimates (U.S. Census Bureau, 2013-2017), vacancy housing rates in Madison, Franklin, and Pickaway counties (ranging from 7.0% to 9.1%) are slightly lower than the statewide average of 10.5%. The rental vacancy rate in Madison County (2.4%) is lower than the statewide average of 5.8%, while Franklin County’s rate is comparable (5.3%) and Pickaway County (8.9%) is substantially higher than the statewide average.

Madison, Franklin, and Pickaway counties feature a median monthly gross rent level of $776, $903, and $779, respectively, all of which are above the statewide average of $764/month. Each county has a slightly lower percentage than statewide percentage (38.1%) of households whose rent accounts for more than 35% of their household income. In addition, the median housing values of all three counties are above the statewide average of $135,100 (U.S. Census Bureau, 2013-2017).

The U.S. Census Bureau estimates that 52,673 housing units within Madison, Franklin, and Pickaway counties are currently vacant (U.S. Census Bureau, 2013-2017). Given these figures, in addition to the population projections discussed in Section 4906-4-08(C)(4)(e) below, it is not expected that the development of the Facility will have a significant impact on the regional housing market. While the Facility development may not represent a boom for rental property owners, it is worth noting that the availability of vacant rental housing also indicates that the Facility should not have a destabilizing effect on current renters.

Commercial and Industrial Development The diversification of Ohio’s energy generation portfolio will have significant and positive economic impacts. At both regional and national levels, the state has a relatively high capacity for both distributed

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 101

and utility-scale solar photovoltaic systems. In a recent report, the Environmental Law & Policy Center (ELPC, 2016) indicated that Ohio has the second-highest solar capacity in the Midwest region (1,119 MW). At a national level, the Solar Foundation ranked Ohio 30th in the U.S. for installed solar capacity (The Solar Foundation, 2019a). Furthermore, there is tremendous room for growth due to an established manufacturing base and trained workforce, central location and reliable transportation infrastructure, and a diverse array of research centers and technical advisory services (ELPC, 2016).

The Environmental Law & Policy Center estimated that the State of Ohio is currently home to 207 solar power supply chain businesses, including many component and equipment manufacturers, including First Solar. Many of the state’s plastic and glass manufacturers have taken advantage of the growing demand for solar by becoming suppliers for these components and equipment. The 2018 Solar Jobs Census reports that Ohio ranks in the top seven states for solar jobs, with 7,162 workers in the solar industry (a 10% increase over 2017). Most these jobs (55%) were for installation, while the remainder were for manufacturing (29%), sales/distribution (10%), operations and maintenance (3%), and other fields (3%). Each of these solar industries, apart from manufacturing, has increased since 2017. Per the report, the $1.3 billion produced by the Ohio solar sector represented much higher growth in 2016 than the overall economy of the state, which decreased slightly (-0.02%). Madison County, where the Facility will be located, ranks 8th in the state for the number of solar jobs, with 215 jobs most recently (The Solar Foundation, 2019b).

Environment Ohio estimated that if Ohio solar increased to 10% of the State’s total energy generation portfolio by 2025, the State would have the potential to produce 25 times as much electricity from solar power as it consumes annually. To meet this target, solar installations would have to continue increasing at 52% annually (Environment Ohio, 2014). With the recent increases in its PV capacity (68% between 2013 and 2014), Ohio is on a path to achieving this target. Specific short- and long-term economic impacts of this Facility on commercial and industrial development throughout the region are described in further detail in the “Socioeconomic Report” provided as Exhibit G.

Schools The proposed Facility will have a significant positive impact on the local tax base, including local school districts that serve the area where the solar farm is to be located. However, aside from increased tax revenue for the local school districts, no significant impact on schools or school facilities is anticipated. The Facility is not expected to have significant growth-inducing effects on the surrounding locales. Local employees would be hired to the extent possible. In the event that non-resident workers are hired, it is

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 102

expected that they would commute or stay in regional transient housing or motels and would not bring families that might require additional school facilities.

Transportation System Development The region surrounding the Project Area features U.S. and Ohio highways, as well as a network of county and local roads, in addition to freight rail lines and small airports. These facilities are described in more detail below.

The primary transportation routes to the Project Area are SR 56, which runs northwest-southeast to the southwest of the Project Area, and SR 665, which runs east-west to the north of the Project Area. Though a transportation route has not been finalized for the Facility, the anticipated route of component delivery and travel will be along Interstate 71, followed by SR 56. SR 56 connects to smaller, local roads such as Big Plain Circleville Road (CR 4), which will provide access within the Project Area. The proposed Facility is not expected to cause any substantial disruption to major transportation corridors serving the Project Area, as most solar photovoltaic components and equipment are relatively small and require only relatively low impact means of transport.

Two freight rail lines operated by Norfolk Southern and Camp Chase Industrial Railroad run through the Study Area. Norfolk Southern runs east and west through the City of London in the northwest corner of the study area. Norfolk Southern has significant operations, serving nearly all metropolitan areas east of the Mississippi River, and the portion of rail extending through the Study Area is part of the NS Dayton District. The Village of West Jefferson and the City of London are the only Study Area municipalities connected to the Dayton freight rail line. The rail system is not anticipated be used for the transportation of any Facility components.

Construction and operation of the Facility will not result in any adverse impacts to the regional air transportation network. The FAA published an aeronautical study on the Facility which revealed that proposed Facility components do not exceed obstruction standards and would not be a hazard to air navigation (Exhibit Q).

Other Public Services and Facilities The Facility is not expected to have significant growth-inducing effects on the surrounding locales. Therefore, no significant impact on local public services and facilities is expected. Workers will commute to the work site on a daily basis. Local employees will be hired to the extent possible. Hiring of non-

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 103

resident workers would occur only when local residents with the required skills were not available or competitive. It is expected that non-resident workers would commute or stay in regional transient housing or motels, and not require new housing, and would not bring families that might require family healthcare or additional school facilities. The principal impact on public services in the site locale would be a temporary increase in traffic on roads leading to the Project Area, due to deliveries of equipment and materials during construction.

(d) Regional Plan Compatibility There would be no impacts to regional plans or regional growth as a result of this Facility. As discussed in Section 4906-4-08(C)(3)(a), four entities within 5 miles of the Project Area have adopted comprehensive land use plans, strategic downtown plans, and/or economic development plans. The compatibility of the Facility with those plans is discussed above in Section 4906-4-08(C)(3)(a).

(e) Current and Projected Population Data Census data reveals that local communities have experienced small population growth from 2000 to 2017. Table 08-12 presents the population trends for the State of Ohio and counties within 5 miles of the Project Area, including percent change in population numbers from 2000 to 2017. Communities within 5 miles of the Project Area have experienced small population growth over the past two decades. The 2017 population for the State of Ohio and for Madison, Franklin, and Pickaway counties is shown in Table 08-12 below. Ohio showed an overall increase in population between 2000 and 2017. Each of the counties within 5 miles of the Project Area experienced an overall increase of equal or higher magnitude over the same time period, with Franklin County experiencing the highest annual rate of population increase.

Table 08-12. Population Trends

Annual Growth Rate County 2000 Population 2017 Population (2000-2017) Madison County 40,213 43,732 +0.5% Franklin County 1,068,978 1,253,507 +1.0% Pickaway County 52,727 57,075 +0.5% State of Ohio 11,353,140 11,658,609 +0.2% Source: U.S. Census Bureau, Decennial Census, ACS 5-Year Estimates (2013-2017)

In addition to the population trends included in Table 08-12, the estimated population density in Madison County in 2019 was 95.7 persons per square mile.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 104

Table 08-13 presents population estimates for 2027 for each community within 5 miles of the Project Area. Populations within the local cities, townships, and villages experienced a mix of small increases and decreases from 2000 to 2017. Range Township had the largest decrease with 1.5%, while Fairfield Township has the largest increase with 1.4% between 2000 and 2017.

The population trends experienced by each community from 2000 to 2017 are expected to continue regardless of whether the proposed Facility is built. Over the next decade, the population within 5 miles of the Project Area is estimated to increase for jurisdictions currently undergoing population increases and decrease for the jurisdictions currently undergoing population decreases. Meanwhile, county populations are all expected to continue on the overall trend of population increase over the next decade, ranging from 5.3% and 5.0% in the more rural counties (Madison County and Pickaway County, respectively) to 10.6% in the urbanized Franklin County (see Exhibit G).

Table 08-13. Population Projections

Annual Projected Jurisdiction Projected Growth Projected Total Projected within 2000 2017 Total Rate 2027 Growth 2030 5 miles of Population Population Growth (2000- Population (2017- Population the Project (2017-2030) Area 2017) 2027) City of 8,771 10,087 0.9% 11,013 9.2% 11,308 12.1% London Darby 3,492 3,420 -0.1% 3,379 -1.2% 3,366 -1.6% Township Deer Creek 1,030 892 -0.8% 824 -7.6% 805 -9.8% Township Fairfield 1,333 1,649 1.4% 1,894 14.9% 1,974 19.7% Township Jefferson 6,935 7,241 0.3% 7,431 2.6% 7,489 3.4% Township Oak Run 514 542 0.3% 560 3.3% 565 4.2% Township Paint 565 691 1.3% 787 13.9% 819 18.5% Township Pleasant Township 7,030 6,903 -0.1% 6,830 -1.1% 6,808 -1.4% (Franklin County) Pleasant Township 3,282 3,081 -0.4% 2,972 -3.5% 2,940 -4.6% (Madison County) Range 983 735 -1.5% 633 -13.9% 605 -17.7% Township

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 105

Annual Projected Jurisdiction Projected Growth Projected Total Projected within 2000 2017 Total Rate 2027 Growth 2030 5 miles of Population Population Growth (2000- Population (2017- Population the Project (2017-2030) Area 2017) 2027) Union 1,411 1,202 -0.9% 1,101 -8.4% 1,073 -10.8% Township Village of West 4,331 4,277 -0.1% 4,246 -0.7% 4,236 -0.9% Jefferson Source: U.S. Census Bureau Decennial Census (2000), ACS 5-Year Estimates (2013-2017), population projections based on respective 2000-2017 growth rates. Note that 2000 institutionalized population numbers are not available for Union Township; however, as of 2017, the institutionalized population (specifically those residing in adult correctional facilities) for Union Township was 4,759.

Although construction employment related to the construction of the Facility will be substantial, this employment is relatively short term and is not expected to result in the permanent relocation of construction workers to the area. Therefore, the Facility is not anticipated to generate significant population growth within five miles of the Project area. The number of potential short- and long-term employment opportunities associated with the construction and operation of the Facility is discussed in further detail above in Section 4906-4-06(E)(2).

(D) CULTURAL AND ARCHAEOLOGICAL RESOURCES

(1) Landmarks of Cultural Significance Map

Figure 08-6 depicts formally adopted land and water recreation areas, recreation trails, scenic rivers, scenic routes or byways, and registered landmarks of historic, religious, archaeological, scenic, natural, or other cultural significant within 10 miles of the Project Area.

Weller & Associates, Inc. (Weller) conducted a literature review for the Cultural Resource Management Preliminary Review (Appendix E of Exhibit I). The purpose of this review was to identify known cultural resources in the vicinity of the Facility so that impacts to these resources can be minimized and so a determination could be made regarding the need for a Phase I survey in this area. Cultural resources include archaeological and historical sites, such as cemeteries, buildings, structures, objects, and districts. The literature review includes the following records obtained from Ohio Historic Preservation Office (OHPO) and the State Library of Ohio:

• National Register of Historic Places (NRHP) • NRHP Determination of Eligibility (DOE) properties • Ohio Historic Inventory (OHI)

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 106

• Ohio Archaeological Inventory (OAI) • OPHO Cultural Resources Management/contract archaeology files • Ohio Genealogical Society (OGS) cemetery files • Mills Archaeological Atlas of Ohio (1914) • SHPO USGS 7.5’ series topographic maps • Madison County atlases, histories, historic USGS 15’ series topographic map(s), and current USGS 7.5’ series topographic map(s)

Records were reviewed for a 2-mile study area around the Project Area. The review identified 86 archaeological sites, eight cemeteries, and five previously conducted Phase 1 surveys within two miles of the Project Area (Appendix E of Exhibit I). Within the Project Area, 42 archaeological sites were identified. Additional information on cultural resources can be found in Appendix E of Exhibit I. Weller’s records review also identified the presence of 13 older buildings within the Project Area. However, no OHI, NRHP, or NRHP- DOE properties were identified within two miles of the Project Area.

(2) Impact to Landmarks and Mitigation Plans

Based on these findings, Westwood and Weller both recommended additional investigation into cultural resources in the area. A Phase 1A archaeological survey and History/Architecture Investigation survey are in progress. These studies will be submitted to OPSB staff upon their completion. It is anticipated that any impacts to these sites (as well as any other sites identified during the pedestrian survey) can be avoided through careful final design of the Facility.

No previously recorded landmarks, or OHI, NRHP, or NRHP-DOE properties were identified within two miles of the Project Area in Weller’s Preliminary Cultural Resource Review (Appendix E of Exhibit I).

Potential visual impacts to previously identified cultural resources are assessed in Section 4906-4-08(D)(4) and Exhibit T. The Applicant has submitted a request for waiver from the requirement to evaluate impacts on landmarks outside of a 2-mile radius of the Project Area.

(3) Impact to Recreational Areas and Mitigation Plans

Existing scenic and recreational areas within a 10-mile radius of the proposed Facility are depicted on Figure 08-6 and listed in Table 08-14 below. Recreational areas were identified using the following resources: ODNR

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 107

Lands and Facilities online mapping (2018), ESRI StreetMap North America (2008), and ESRI ArcGIS Online map services.

Table 08-14. Recreational Areas Within a Ten-Mile Radius of the Facility Distance from Recreational Area Location Project Area Ohio to Erie Trail: Camp  Union and Fairfield, Madison County and 1.7 miles Chase Multi-Use Trail  Pleasant Township, Franklin County  Fairfield, Monroe, and Jefferson Townships, Big and Little Darby Creek Madison County 5.5 miles Wild and Scenic River  Pleasant Township, Franklin County  Darby Township, Pickaway County  Deer Creek, Sommerford, Fairfield, and Scenic Byway (US Route 40) Jefferson Townships, Madison County 5.6 miles  Prairie Township, Franklin County Sugar Maple Trail  Union Township, Madison County 1.6 miles Big Darby Creek Scenic River  Jefferson Township, Madison County 8.7 miles Area Little Darby Creek Scenic  Monroe and Jefferson Townships, Madison 5.0 miles (from River Area (multiple locations) County closest location) Madison Lake State Park  Union Township, Madison County 1.3 miles London Fish Hatchery  Union Township, Madison County 8.7 miles  Pleasant Township, Madison County Deer Creek Wildlife Area  Madison Township, Fayette County 8.8 miles  Monroe Township, Pickaway County

As listed in Table 08-14 above, nine scenic and recreational areas occur within 10 miles of the proposed Facility. Each of these recreational sites is described below, along with an assessment of potential impacts from the Facility.

The Ohio to Erie Trail is an off-street recreational trail spanning from the Ohio River in the City of Cincinnati, to Lake Erie. This large network of paved trails is comprised of smaller regional trails, like the Camp Chase Multi-Use Trail. This trail, managed by the Ohio to Erie Trail non-profit organization, began in 1991. As of 2017, the network of trails totaled 326 miles. The Camp Chase Multi-Use Trail is located approximately 1.7 miles north of the Project Area. According to the viewshed analysis, views, and therefore visual impacts, of the Facility from the Camp Chase Multi-Use Trail are unlikely (see Exhibit T for further information).

Big and Little Darby Creeks is a federally-designated scenic river unit located 5.5 miles at its closest point to the Project Area. State-listed as a scenic river in 1984, Big and Little Darby Creeks were federally-designated

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 108

as a scenic waterway in 1994 by the National Parks Service’s Rivers, Trails, and Conservation Program (ODNR, 2020a). Big Darby Creek flows from Champaign and Union counties down to the Scioto River. Little Darby Creek flows from the Lafayette-Plain City Road Bridge, downstream to the confluence with Big Darby Creek. Big and Little Darby Creeks are nationally noted for their diversity and abundance of aquatic and terrestrial plants and animals, providing habitat for 86 fish and 41 mollusk species, including 13 state-listed endangered species (ODNR, 2020a). According to the viewshed analysis, views of the Facility from those recreating along Big and Little Darby Creek are not anticipated (see Exhibit T for further information).

US-40, also known as the National Road, is a federally- and state-designated highway that extends from the Atlantic Ocean in Baltimore, Maryland to the Mississippi River in East St. Louis, Illinois. This 600-mile highway spans approximately 220 miles in Ohio. Historically, this road has served as a main east-west artery, providing both a route and market access for the Midwest in the early 19th century (Ohio History Connection, 2020). US-40 is located approximately 5.6 miles away from the Project Area at its closest point. Given the distance between the Facility and US-40, limited visibility is anticipated for those traveling along the highway.

Madison Lake State Park and Sugar Maple Trail are located approximately 1.3 and 1.6 miles from the Project Area, respectively. Both recreational features are state-owned and managed by the ONDR. The park surrounds Madison Lake and contains the sugar maple trail. This park and trail are heavily wooded. Due to the lack of surrounding area with contiguous visibility, views of the Facility from Madison Lake State Park and the Sugar Maple Trail are unlikely.

The London Fish Hatchery is located approximately 8.7 miles west of the Project Area and consists of 33 ponds covering almost 8 acres (ODNR, 2020c). This facility is open for public viewing of large adult trout and other display fish. Given the distance between the hatchery and the Project Area, no visual impacts are anticipated on those recreating at the London Fish Hatchery.

The Deer Creek Wildlife Area is located approximately 8.8 miles south of the Project Area and managed by the ODNR. This is a 4,220-acre wildlife area that contains cropland, second-growth hardwoods, and brush habitat (ODNR, 2020b). Recreational opportunities at this facility includes fishing, shooting, hunting and trapping, boating, and swimming (ODNR, 2020b). Given the distance between the wildlife area and the Project Area, no visual impacts are anticipated on those recreating at Deer Creek Wildlife Area.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 109

The Visual Resource Assessment (VRA) prepared for the proposed Facility includes photo-documentation and field review of the potential visibility of the Facility from recreational resources within the visual study area. Additional details of the VRA are provided below and in Exhibit T.

(4) Visual Impact

EDR prepared a VRA for the proposed Facility. The purpose of the VRA is to:

• Describe the visible components of the proposed Facility. • Define the visual character of the visual study area. • Inventory and evaluate existing visually sensitive resources within the visual study area. • Evaluate potential visibility of the Facility within the visual study area. • Create photographic simulations of the proposed Facility from select locations • Assess the visual impacts associated with the proposed Facility. • Describe measures considered to minimize visual impacts.

This VRA was prepared by an experienced visual resources assessment expert in accordance with the policies, procedures, and guidelines contained in established visual assessment methodologies.

OAC Section 4906-4-08(D)(4) requires the Applicant to evaluate the visual impact of a proposed generating facility from within at least a 10-mile radius. A viewshed analysis was conducted using lidar data to better understand the Facility’s area of potential effect (APE) within the 10-mile radius. The results of the viewshed analysis indicate that potential visibility of the Facility will be largely concentrated in areas within 0.5 mile of the proposed Facility components. Only small corridors of visibility will extend beyond a 2-mile radius, and no areas of potential visibility exist beyond 5 miles of the Facility. Based on the results of the viewshed analysis, it was determined that a 5-mile radius from the Project Area is an appropriate visual study area (VSA) for a detailed analysis of visual impacts. The 5-mile VSA encompasses a total of approximately 127 square miles, including the Madison County townships of Union, Deer Creek, Jefferson, Oak Run, and Range; Pleasant Township in Franklin County; and Darby Township in Pickaway County.

(a) Facility Visibility and Viewshed Analysis An analysis of Facility visibility was undertaken to identify those locations within the VSA where there is potential for the major above-ground Facility components to be seen from ground-level vantage points. This analysis included identifying potentially visible areas on viewshed maps and verifying visibility in the

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 110

field. The methodology employed for each of these assessment techniques is described in the VA. Results of the viewshed analysis are summarized below. Additional detail and results of the field verification are provided in the VA.

Viewshed Analysis Summary The viewshed analysis uses lidar data to create a digital surface model (DSM) which incorporates the screening effects of topography, structures, and vegetation. A viewshed analysis was conducted within the 5-mile VSA to determine potential panel visibility. The viewshed analysis indicates that the Facility will be screened from approximately 87.9% of the VSA by intervening landforms, vegetation, and structures. A majority of the visibility (86.1%) is significantly concentrated within the Project Area. Generally, visibility will be concentrated within the Project Area and adjacent open fields and greatly reduced at distances beyond 0.5 mile. Approximately 65% of the area between 0.5 and one mile is screened from view, while 84.5% of the VSA is screened from view at distances between one and two miles. At distances beyond two miles, the viewshed analysis suggests that a small portion of the Facility may be visible from approximately 3.6% of the area between two and five miles. However, these areas are discrete, narrow corridors of visibility that result from breaks in the hedgerows separating neighboring fields. Due to the limited portion of the Facility that would be visible, and the distance from the Facility, it is unlikely that Facility visibility within these narrow corridors would be readily noticeable to a casual viewer.

An additional viewshed was conducted to assess the visibility of the collection substation within two miles of the collection substation. Potential visibility of the substation is generally the same as was described for the solar panels. Within the 2-mile substation study area, the viewshed analysis shows a few areas where the collection substation may be visible but solar panels will be screened from view, due to the taller 58-foot structure height of the substation lightning masts compared to the maximum solar panel height. Vegetation and structures, in combination with topography, will serve to block views of the proposed substation from approximately 64.2% of the 2-mile radius study area (i.e., 35.8% of the study area is indicated as having potential visibility of the substation). This analysis indicates that views of the substation will be most available from open areas to the north extending to State Route 665 (London- Lockbourne Rd) and to the southeast across Hume Lever Road

Field Verification EDR conducted three site visits from July through October 2019. The purpose of field review was to verify the potential visibility of the Facility (as suggested by the viewshed analysis), document the type

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 111

and extent of existing visual screening, and obtain photographs for subsequent use in the development of visual simulations. Field verification generally confirmed the findings of the DSM viewshed analysis. Facility visibility was largely restricted to areas adjacent to the Facility where public roads are bordered by open agricultural fields. Field review also confirmed that hedgerows, residential structures, and agricultural buildings will screen the Facility from more distant portions of the VSA, beyond 1 mile.

Visibility of the Facility from the City of London and the Village of West Jefferson, two nearby higher density residential areas, will be fully screened by topography, homes, and landscape vegetation. In most cases, the Facility will not be visible from residences within the VSA, with the exception of approximately 30 homes along some areas of Big Plain Circleville Road, Glade Run Road, and Hume Lever Road. Visibility from these residences and roadways, during the growing season, may be limited by crop growth in the foreground agricultural fields. The combination of relatively low panel height, along with existing hedgerows, gently rolling topographic relief, and the atmospheric effects of distance, will limit visibility of the Facility from the majority of the VSA, confirming the results of the viewshed analysis.

(b) Description of Scenic Quality of Existing Landscape Landscape types within the VSA were categorized based on the similarity of various features, including landform, vegetation, water, and/or land use patterns, in accordance with established visual assessment methodologies (Smardon et al., 1988; USDA Forest Service, 1995; USDOT Federal Highway Administration, 1981; USDOI Bureau of Land Management, 1980). The USGS National Land Cover Dataset (NLCD) was used to help define the character and location of various landscape types within the VSA.

The following landscape types were identified within the VA: agricultural, forest, open space, developed, wetlands, and water. The Facility will be built almost exclusively on agricultural land, which comprises approximately 87.6% of the VSA. Agricultural land in this region typically offers long-distance views of the landscape and presents the greatest opportunity for Facility visibility. The forest landscape type, which makes up 6.9% of the VSA, also occurs adjacent to the Facility, but by its very nature, views from within forest land are typically limited by the presence of dense vegetation. Open space, which includes the Hickory Hills Golf Club, makes up approximately 3.1% of the VSA, may offer opportunities for open and long-distance views. However, the largest contiguous occurrence of this landscape type occurs over 4 miles from the Project Area, at which views from this location would be unlikely. Developed land, which makes up 1.7% of the VSA and includes the City of London, typically has limited outward views due to the presence of buildings and closely situated houses, landscaped yards, planted vegetation, utility poles,

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 112

and other visual clutter. Water and wetlands landscape types are scattered throughout the VSA and collectively make up only about 0.6% of the land area. The most notable water feature is Madison Lake and while views over open water typically allow for relatively long-distance views, the lake occurs within a river valley, which limits views to the lake shore and adjacent valley slopes.

(c) Landscape Alterations and Impact on Scenic Quality of the Landscape The Project Area and VSA can be characterized as flat, open agricultural fields. Construction and operation of the proposed Facility will result in an alteration to the existing landscape through the introduction of low-profile PV panels, where currently there are none. However, the visibility and visual impact of the Facility will be highly variable, based on landscape setting, the extent of natural screening, the presence of other man-made features in the view, and distance of the viewer from the Facility.

A majority of the landscape within the Project Area and VSA is agricultural. Development of the Facility will change the appearance of open agricultural fields, to a developed area covered by low-profile PV panels. The most notable change will be the introduction of a dark horizonal line to the existing landscape created by the PV panels. This change will be visible in the immediate vicinity of the Facility but will significantly decrease past 0.5 mile. For additional details on landscape alterations and impacts, see Exhibit T.

(d) Visual Impacts to Landmarks of Cultural Significance Twenty-six visually sensitive resources were identified within the VSA, only one of which was identified as a property of historic significance. The property of historic significance was identified as a historic bridge located 2.5 miles from the nearest PV panel in Oak Run Township. Based on the viewshed analysis, the Facility may be partially visibility from this resource. Other visually sensitive resources identified in the VA include scenic resources, public land and recreational resources, and high-use public areas. For more information on visually sensitive resources, see Exhibit T.

(e) Photographic Simulations To illustrate anticipated visual changes associated with the proposed Facility, photographic simulations of the Facility were used from five selected viewpoints to evaluate visibility, appearance, and contrast with the existing landscape, with and without vegetative mitigation. The visual simulates are included in the VA, provided in Exhibit T of this Application. Exhibit T includes a detailed discussion of each simulation.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 113

The visual simulations illustrate that visibility of the solar panels from distances between 600 and 900 feet will generally result in limited visual impacts. The above ground collection system is likely to result in visual effects from foreground viewpoints; however, these viewpoints are not readily available from public vantage points. Additionally, in certain locations, views of the Facility may be available from within 200 feet. In these locations is it likely that the proposed chain link fence, solar panels, and associated equipment will result in elevated visual impacts that could diminish the visual character of the landscape. However, in most cases significant setbacks from public rights of way from most resources within the VSA resulting in minimal visibility and visual impact.

(f) Impact Minimization Measures The Applicant has implemented a 50-foot setback for panels from adjacent, non-participating properties which serves to reduce Facility visibility. Lighting will be minimized to the greatest extent practicable using shielded lights that are directed downward. Computer-based modeling will be used to determine the most efficient and effective layout for lighting based on final Facility design. The Applicant will install vegetative material at select locations so as to provide screening of the Facility. The purpose of vegetative screening is not to completely block the project from any visibility. Instead, proposed vegetative mitigation will use the vertical elements of native plants to break up the horizontal lines created by the PV panels and fenceline. Doing so will help the Facility fall into the background vegetation rather than stand out as a foreground element. For additional detail on vegetative screening, please see the visual simulations in Exhibit T. Potential vegetation that may be used for screening efforts can be found in Appendix H of Exhibit I.

(E) AGRICULTURAL DISTRICT IMPACTS

(1) Agricultural Land and Agricultural District Land Map

Agricultural land is the dominant land use in Madison County, consisting of 262,000 acres of land. Similarly, the Project Area consists almost exclusively of agricultural land. Figure 08-7 depicts agricultural land, agricultural district land, and land enrolled in the Current Agricultural Use Value (CAUV) program, within and surrounding the Project Area.

(2) Potential Impacts and Proposed Mitigation

The Facility will be almost entirely sited on agricultural land and will take that land out of production for approximately 40 years. After the useful life of the Facility, it will be decommissioned, and the site will be restored to pre-construction conditions.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 114

(a) Acreage Impacted Table 08-15 quantifies impacts to agricultural land uses, based on the typical area of vegetation clearing column presented in Table 08-10.

Table 08-15. Impacts to Agricultural Land Uses Total Temporary Permanent Agricultural Land Use1 Disturbance Disturbance Loss (acres) (acres) (acres) Agricultural Vacant (100 or 110) 872.2 38.8 833.4 PV Panel 799.5 0.0 799.5 Access Roads 30.1 6.0 24.1 Buried Electrical Collection Cable 16.8 16.8 0.0 Overhead Collection Line 7.5 0.0 7.5 Laydown Yard 16.0 16.0 0.0 Collection Substation 2.0 0.0 2.0 Inverter Pads2 <1.0 0.0 <1.0 Cash Grain or General Farm (101 or 111) 201.6 4.9 196.7 PV Panel 190.4 0 190.4 Access Roads 5.3 1.1 4.2 Buried Electrical Collection Cable 3.9 3.9 0.0 Overhead Collection Line 0.0 0.0 0.0 Laydown Yard 0.0 0.0 0.0 Collection Substation 2.0 0.0 2.0 Inverter Pads2 <1.0 0.0 <1.0 Other Agricultural Use (199) 141.0 3.0 138.0 PV Panel 131.6 0.0 131.6 Access Roads 5.1 1.0 4.1 Buried Electrical Collection Cable 2.0 2.0 0.0 Overhead Collection Line 2.3 0.0 2.3 Laydown Yard 0.0 0.0 0.0 Collection Substation 0.0 0.0 0.0 Inverter Pads2 <1.0 0.0 <1.0 Total 1,214.8 46.8 1,168.0 1From land use codes in Madison County parcel shapefiles. 2Permanent impacts from inverter pads will be 300 square foot per inverter (0.0068 acres). For the purposes of this table, that value is represented as less than (<) 1 acre.

Table 08-16 quantifies impacts to CAUV land, based on the typical area of vegetation clearing column presented in Table 08-10. No agricultural district land occurs within the Project Area.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 115

Table 08-16. Impacts to CAUV Land Total Temporary Permanent Current Agricultural Use Value Lands1 Disturbance Disturbance Loss (acres) (acres) (acres) PV Panel 1,121.5 0.0 1,121.5 Access Roads 40.5 8.1 32.4 Buried Electrical Collection Cable 22.7 22.7 0.0 Overhead Collection Line 9.8 0.0 9.8 Laydown Yard 16.0 16.0 0.0 Collection Substation 4.0 0.0 4.0 Inverter Pads2 <1.0 0.0 <1.0 Total 1,214.8 46.8 1,168.0 1From land use codes in Madison County parcel shapefiles. 2Permanent impacts from inverter pads will be 300 square foot per inverter (0.0068 acres). For the purposes of this table, that value is represented as less than (<) 1.0 acre.

(b) Impacts on Agricultural Facilities and Practices (i) Field operations The Facility will occupy 1,168.0acres of agricultural land, taking it out of use for approximately 40 years. Therefore, plowing, planting, cultivating, spraying, aerial applications, and harvesting will be halted on the land occupied by the Facility during the lifetime of the Facility. Once the Facility has reached the end of its useful life, Facility components will be removed, and the underlying Project Area will be restored for potential agricultural use.

(ii) Irrigation Irrigation systems are not in widespread use in the Project Area. Potential interference to irrigation operations is very limited and coordination with affected landowners will alleviate potential for significant long-term disruption.

(iii) Field drainage systems While operation and maintenance of the Facility should not impact field drainage systems within the Project Area, construction of the Facility could result in impacts to drainage systems. The Facility has been designed to avoid known drainage mains to the extent practicable. As part of the mitigation measures discussed more fully below, the Applicant will work with the county and townships to identify drainage mains in the Project Area and replace the mains, which will avoid potential impacts.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 116

(iv) Structures used for agricultural operations Construction of the Facility may result in the removal of up to two agricultural structures. Conversations between the Applicant and respective landowners are ongoing as the Facility design progresses.

(v) Viability as agricultural district land No agricultural district land is located within the Project Area. Therefore, this section is not applicable.

(c) Proposed Mitigation Procedures (i) Avoidance and minimization of damage to field tile drainage systems The Applicant initiated talks with the Madison County Engineer, Madison County Commissioners, Fairfield and Oak Run township trustees, and the local Soil and Water Conservation District beginning in November of 2018 to discuss impacts to drainage tiles. The Applicant has hired an engineering consultant to draft a preliminary drainage plan for the Facility. The Applicant has provided the draft drainage plan to the Madison County Engineer and has reached a preliminary plan for facilitating drainage from non-participating parcels (as described below).

(ii) Timely repair of damaged field tile systems As part of the plan agreed to with Madison County, the Applicant will find and replace, prior to construction, drainage tile mains that facilitate the drainage of non-participating parcels. Doing so will put in place new mains throughout the Project Area in known locations. While damage to these mains as a result of subsequent construction and operation/maintenance activities is not anticipated, any of these drainage tile mains damaged during subsequent construction activities or during the period for operation and decommissioning will be identified and documented. The damage will be assessed for the potential impact on the effective drainage of the Project Area and on the drainage of neighboring areas. Since the site does facilitate the drainage of adjacent areas, any damage to the mains will be remedied expeditiously. It is anticipated that a local drain tile contractor or the farmer currently tending the land will be involved in repair activities.

(iii) Topsoil segregation, decompaction, and restoration Topsoil movement will occur during installation of foundations for the collection substation and inverters, trenching of collection lines, installation of the laydown yard, and the installation of access roads. In areas where grading is proposed, topsoil must be stripped per federal, state and/or local

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 117

environmental requirements. Topsoil depth will be based on the final Geotechnical Investigation Report, which will be provided to OPSB Staff prior to construction. Any topsoil that is to be stripped prior to site grading shall be stockpiled onsite in a manner that meets all federal, state and/or local requirements. This will be considered the amount of “temporary” topsoil displacement. Any topsoil that is displaced due to placement of gravel for material laydown and storage areas, vehicle turn‐ around areas, parking areas, etc. that are to be removed upon the completion of site construction shall be stockpiled separately. This will be considered the amount of “construction duration” topsoil displacement and will be separated from other excavated materials. such as rocks or subsoil. Potential locations and sizes of topsoil stockpiles will be decided by the contractor as needed, in coordination with the grading and restoration activities.

Gravel used for the laydown yard and any excess materials used for the temporary access roads will be removed. Upon removal, soil will be de-compacted, regraded, and stabilized with a native, low- growth seed mix. All temporary BMPs will be removed following construction. Additionally, construction debris will be removed from the site and disposed of properly.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-08 – Page 118

4906-4-09 REGULATIONS ASSOCIATED WITH WIND FARMS

The requirements of Section 4906-4-09 are specifically intended for wind powered facilities. The Applicant is proposing a solar-powered facility. Therefore, the requirements set forth in Section 4906-4-09 do not apply.

Big Plain Solar, LLC 19-1823-EL-BGN 4906-4-09 – Page 119

LITERATURE CITED

American Society of Mammologists. 2019. Mammal Species List Search. Available at: https://www.mammalogy.org/mammals-list (Accessed September 2019).

Bolinger, M. and J. Seel. 2018. Utility-Scale Solar: Empirical Trends in Project Technology, Cost, Performance, and PPA Pricing in the United States-2018 Edition. Lawrence Berkeley National Laboratory, Electricity Markets and Policy Group. September 2018. Available at: https://emp.lbl.gov/sites/default/files/lbnl_utility_scale_solar_2018_ edition_report.pdf (Accessed September 2019).

Day, M. and B. Mow. 2018. Research and Analysis Demonstrate the Lack of Impacts of Glare from Photovoltaic Modules. National Renewable Energy Laboratory (NREL). Available at: https://www.nrel.gov/state-local- tribal/blog/posts/research-and-analysis-demonstrate-the-lack-of-impacts-of-glare-from-photovoltaic- modules.html (Accessed February 2020).

City of London. 2008. Comprehensive Plan. Available from City of London Building and Zoning Department.

Covert, S.A., Kula, S.P., and Simonson, L.A. 2007. Ohio Aquatic Gap Analysis: An Assessment of the Biodiversity and Conservation Status of Native Aquatic Animal Species. U.S. Geological Survey, Open-File Report 2006-1385.

Edison Electric Institute. 1984. Electric Powel Plant Environmental Noise Guide. Edison Electric Institute. Washington D.C.

Environmental Law & Policy Center (ELPC). 2016. Ohio Solar Energy & Wind Power Supply Chain Business. Available at: http://elpc.org/newsroom/publications/ (Accessed Jan 15, 2020).

Environment Ohio Research & Policy Center (Environment Ohio). 20014. Star Power: the Growing Role of Solar Energy in Ohio. Available at http://www.environmentohio.org/sites/environment/files/reports/OH_Star_Power_v5_screen.pdf (Accessed November 2019).

ESRI. 2008. ESRI StreetMap 2008 North America.

ESRI. 2015. ESRI Street Map 2015 USA.

Hackler, D. and E. Harpel. 2019. Economic Development Strategic Plan. Prepared for Economic Development and Planning, Franklin County, Ohio by Business Development Advisors. May 2019. Available at https:// development.franklincountyohio.gov/EDP-website/media/Documents/Economic%20Development%20Strategic%20 Plan/EDSP.pdf (Accessed October 2019).

Hawk Migration Association of North America (HMANA). 2019. Hawk Watch Sites. Available at: https://www. hmana.org/ (Accessed December 2019).

Hull & Associates, Inc. (Hull). 2019. Groundwater, Hydrogeological and Geotechnical Desktop Document Review Summary Report for the Proposed Madison Solar Project Located in Madison County, Ohio; FSO002.0002.

IMPLAN Group. 2017. Understanding Multipliers. Available at https://implanhelp.zendesk.com/hc/en-us. (Accessed September 2019).

Big Plain Solar, LLC 19-1823-EL-BGN Literature Cited – Page 120

Lawrence, M. and P.W. Magnotta. 2018. Technical Guidance for Evaluating Selected Solar Technologies on Airports, Version 1.1. Federal Aviation Administration, Airport Planning and Environmental Division. April 2018; Original November 2010. FAA-ARP-TR-10-1. Available at: https://www.faa.gov/airports/environmental/policy_ guidance/media/FAA-Airport-Solar-Guide-2018.pdf (Accessed November 2019).

Madison County Commissioners. 2014. Madison County, Ohio Comprehensive Plan. Published by the Madison County Commissioners. Available at: https://sharepoint.co.madison.oh.us/publicaccess/2014%20Comprehensive %20Plan/2014/2014%20Comprehensive%20Plan%20Text%20Only.pdf (Accessed October 2019).

Massachusetts Clean Energy Center. 2012. Study of Acoustic and EMF Levels from Solar Photovoltaic Projects. December 2012, p. iv.

Massachusetts Department of Energy Resources, et al. (MDER). 2015. “Clean Energy Results: Questions and Answers, Ground-Mounted Solar Photovoltaic Systems” June 2015. “MDER Q&A,” p. 10.

Meldrum, J., S. Nettles-Anderson, G. Heath, and J. Macknick. 2013. Life Cycle Water Use for Electricity Generation: A Review and Harmonization of Literature Estimates. Environmental Research Letters 8(1): 015031.

National Audubon Society. 2019. The Christmas Bird Count Historical Results. Available at: http://netapp. audubon.org/CBCObservation/ (Accessed September 2019).

NatureServe. 2019. NatureServe Explorer: An Online Encyclopedia of Life [web application]. Version 7.1. Arlington, VA. Available at: http://explorer.natureserve.org (Accessed September 2019).

ODNR. 2006. Rainwater and Land Development: Ohio’s Standards for Stormwater Management Land Development and Urban Stream Protection. Division of Soil and Water Conservation. Third Edition. Available at: http://oilandgas.ohiodnr.gov/portals/oilgas/pdf/stormwater/RLD_11-6-14All.pdf (Accessed March 2020).

ODNR. 2008. Reptiles of Ohio Field Guide. Division of Wildlife, Publication 354 (608). July 2008. Available at: https://wildlife.ohiodnr.gov/portals/wildlife/pdfs/publications/id%20guides/pub354_Reptiles-opt.pdf (Accessed September 2019).

ODNR. 2012. Amphibians of Ohio Field Guide. Division of Wildlife, Publication 5348 (R0712). July 2012. at: https://wildlife.ohiodnr.gov/portals/wildlife/pdfs/publications/id%20guides/pub348.pdf (Accessed September 2019).

ODNR. 2013. Common Birds of Ohio CD Guidebook. Division of Wildlife, Publication 5414 (R0413). Available at: https://wildlife.ohiodnr.gov/portals/wildlife/pdfs/publications/birds%20and%20birding/pub414.pdf (Accessed October 2019).

ODNR. 2016a. State Listed Plant Species by County: Madison County. Available at: http://wildlife.ohiodnr.gov/ portals/wildlife/pdfs/species%20and%20habitats/state-listed%20species/madisonp.pdf (List created July 2016; Accessed September 2019).

ODNR. 2016b. State Listed Wildlife Species by County: Madison County. Available at: http://wildlife.ohiodnr.gov/portals/wildlife/pdfs/species%20and%20habitats/state-listed%20species/madison.pdf (Updated June 2016; Accessed September 2019).

ODNR. 2016c. Mammals of Ohio Field Guide. Division of Wildlife, Publication 5344 (R0216). Available at: http://wildlife.ohiodnr.gov/portals/wildlife/pdfs/publications/id%20guides/pub344.pdf (Accessed September 2019).

Big Plain Solar, LLC 19-1823-EL-BGN Literature Cited – Page 121

ODNR. 2018. Ohio County Distribution of Federally-Listed Threatened, Endangered, Proposed, and Candidate Species. Available at: https://www.fws.gov/midwest/endangered/lists/pdf/OhioCtyList29Jan2018.pdf (Accessed September 2019).

ODNR. 2019a. Floodplain Regulations. Division of Water Resources. Available at: http://water.ohiodnr.gov/water- use-planning/floodplain-management/regulations (Accessed November 2019).

ODNR. 2019b. Rare Plants of Ohio. Division of Natural Areas and Preserves. Available at: http://naturepreserves. ohiodnr.gov/rareplants (Accessed November 2019).

ODNR. 2019c. Ohio’s Listed Species. Division of Wildlife, Publication 5356 (R0919). Available at: http://wildlife. ohiodnr.gov/portals/wildlife/pdfs/publications/information/pub356.pdf (Accessed September 2019).

ODNR. 2019d. Ohio Hunting and Trapping Regulations 2019-2020. Division of Wildlife, Publication 5085 (R0719). July 2019. Available at: http://wildlife.ohiodnr.gov/portals/wildlife/pdfs/hunting/2019-20%20Ohio%20Hunting %20&%20Trapping%20Regulations.pdf (Accessed October 2019).

ODNR. 2019e. Species Guide Index. Division of Wildlife. Available at: http://wildlife.ohiodnr.gov/species-and- habitats/species-guide-index (Accessed October 2019).

ODNR. 2020a. Big & Little Darby Creek State and National Scenic River. Available at: http://watercraft.ohiodnr.gov/darbysr (Accessed January 2020).

ODNR. 2020b. Deer Creek Wildlife Area. Available at: http://wildlife.ohiodnr.gov/deercreekwa#tabr4 (Accessed January 2020).

ODNR. 2020c. Fisheries Management. Available at: http://wildlife.ohiodnr.gov/species-and-habitats/fisheries- management (Accessed January 2020).

ODNR. 2020d. Land and Facilities Map Server. Available at: https://gis.ohiodnr.gov/MapViewer/?config=ODNRLands (Accessed December 2019).

Ohio Environmental Protection Agency (Ohio EPA). 2006. Methods for Assessing Habitat in Flowing Waters: Using the Qualitative Habitat Evaluation Index. Division of Surface Water. Technical Bulletin EAS/2006-06-1. June 2006.

Ohio EPA. 2012. Field Evaluation Manual for Ohio’s Primary Headwater Habitat Steams. Division of Surface Water, Version 3.0. Available at: https://www.epa.state.oh.us/Portals/35/rules/PHWHManual_2012.pdf (Accessed January 2020).

Ohio EPA. 2013. Biological and Water Quality Study of the Deer Creek Watershed, 2011. March 2013. Available at: https://www.epa.ohio.gov/Portals/35/documents/DeerCr_TSD_final_2013.pdf (Accessed December 2019).

Ohio History Connection. 2020. The National Road. Available at: https://www.ohiohistory.org/preserve/state-historic- preservation-office/hpplanning/special-planning-related-initiative/national-road-recognized-as-one-of-the-nations-fin (Accessed January 2020).

Pardieck, K.L., D.J. Ziolkowski Jr., M. Lutmerding, V. Aponte, and M.-A.R. Hudson. 2019. North American Breeding Bird Survey Dataset 1966 - 2018, Version 2018.0. Available at: https://www.pwrc.usgs.gov/bbs/RawData/ (Accessed September 2019).

Big Plain Solar, LLC 19-1823-EL-BGN Literature Cited – Page 122

PJM Interconnection (PJM). 2017. Generation Interconnection Feasibility Study Report for PJM Interconnection Request Queue Position AC1-078, Beatty – London 138 kV. Available at: https://www.pjm.com/pub/planning/project- queues/feas_docs/ac1078_fea.pdf (Accessed January 2020).

PJM. 2017. Generation Interconnection System Impact Study Report for PJM Interconnection Request Queue Position AC1-078, Beatty – London 138 kV. Available at: https://www.pjm.com/pub/planning/project- queues/impact_studies/ac1078_imp.pdf (Accessed January 2020).

PJM. 2018. Generation Interconnection Feasibility Study Report for PJM Interconnection Request Queue Position AD1- 081, Beatty – London 138 kV. Available at: https://www.pjm.com/pub/planning/project- queues/feas_docs/ad1081_fea.pdf (Accessed January 2020). PJM. 2018. Revised Generation Interconnection System Impact Study Report for PJM Interconnection Request Queue Position AD1-081, Beatty – London 138 kV. Available at: https://www.pjm.com/pub/planning/project- queues/impact_studies/ad1081_imp.pdf (Accessed January 2020).

Polisky, L.E. 2005. White Paper: Identifying and Avoiding Radio Frequency Interference for Wind Turbine Facilities. Prepared for Comsearch, Ashburn Virginia. March 2005.

Rogers, J.A., C.K. Ho, A. Mead, A. Miller, M. Beben, G. Drechsler. 2015. Evaluation of Glare as a Hazard for General Aviation Pilots on Final Approach. Federal Aviation Administration, Office of Aerospace Medicine. DOT/FAA/AM- 15/12. July 2015. Available at: https://www.faa.gov/data_research/research/med_humanfacs/ oamtechreports/2010s/ media/201512.pdf (Accessed October 2019).

Smardon, R.C., J.F. Palmer, A. Knopf, K. Grinde, J.E. Henderson, and L.D. Peyman-Dove. 1988. Visual Resources Assessment Procedure for U.S. Army Corps of Engineers. Instruction Report EL-88-1. Department of the Army, U.S. Army Corps of Engineers. Washington, D.C.

The Solar Foundation. 2019a. Ohio Solar Jobs Census 2018. Available https://www.thesolarfoundation.org/solar-jobs- census/factsheet-2018-oh/ (Accessed November 2019)

The Solar Foundation. 2019b. National Solar Jobs Census 2018. Available at https://www.thesolarfoundation.org/wp- content/uploads/2020/02/Solar-Jobs-Census-2018-1-1.pdf (Accessed November 2019).

U.S. Census Bureau, 2000. Decennial Census, General Population Data. Available at: http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml (Accessed November 2019).

U.S. Census Bureau. 2013-2017. American Community Survey County – Household, Population and NAICS Characteristics (web database portal). Available at: http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml (Accessed November 2019).

U.S. Department of Agriculture (USDA) National Forest Service. 1995. Landscape Aesthetics, A Handbook for Scenery Management. Agricultural Handbook 701. Washington D.C.

USDA Natural Resources Conservation Service. 2020. Web Soil Survey Database. Available at: https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm.

U.S. Department of Energy (USDOE) National Renewable Energy Laboratory (NREL). 2017. Jobs and Economic Development Impact (JEDI) model release PV12.23.16. (Accessed from NREL in November 2017).

Big Plain Solar, LLC 19-1823-EL-BGN Literature Cited – Page 123

USDOE NREL National Solar Radiation Database. 2017. U.S. State Solar Resource Maps. Available at https://www.nrel.gov/gis/solar.html (Accessed January 2020)

U.S. Department of Labor (USDOL) Bureau of Labor Statistics. 2018. May 2018 State Occupational Employment and Wage Estimates Ohio. Available at https://www.bls.gov/oes/current/oes_oh.htm#47-0000 (Accessed November, 2019).

United States Department of Transportation (USDOT), Federal Highway Administration. 1981. Visual Impact Assessment for Highway Projects. Office of Environmental Policy. Washington, D.C.

U.S. EPA. 2019. “Permit Program under CWA Section 404.” Section 404 of the Clean Water Act. Available at: https://www.epa.gov/cwa-404/permit-program-under-cwa-section-404 (Accessed April 2020).

Weiner, B., L. Clayton, D. Keithey, B. Mark, and E. Yablonsky. 2009. Pleasant Township Comprehensive Plan. Adopted by the Franklin County Board of Commissioners on June 9, 2009. Available at: https:// development.franklincountyohio.gov/EDP-website/media/Documents/Planning_Zoning/Land%20Use%20Planning/ CommunityPlans/Pleasant%20Township%20Comprehensive%20Plan/PlanDocuments/PleasantTwpPlanfullweb.pdf (Accessed November 2019).

Big Plain Solar, LLC 19-1823-EL-BGN Literature Cited – Page 124 This foregoing document was electronically filed with the Public Utilities

Commission of Ohio Docketing Information System on

4/27/2020 11:44:04 AM in

Case No(s). 19-1823-EL-BGN

Summary: Application Narrative electronically filed by Mr. Michael J. Settineri on behalf of Big Plain Solar, LLC