2018.09.12 Stinson DEP Response.pdf
September 12, 2018
Mark Stinson
Massachusetts Department of Environmental Protection
West Region
436 Dwight Street
Springfield, MA 01103
RE: Northampton Community Solar Project
Park Hill Road, Northampton, MA
MADEP File Number 246-0723
Dear Mr Stinson:
Our office appreciates your time in reviewing the Northampton Community Solar Project located
on Park Hill Road in Northampton, Massachusetts. We have received your comments relative to
the above noted project delivered via email on September 10, 2018 and offer the following
responses. For ease of review, we have repeated each comment, presented below in italics,
immediately followed by our responses.
Comment 1: Several locations in the NOI narrative speak of 200 [foot] Riverfront buffer. It
should be noted the entirety of the 200 foot is a resource area.
Response 1: Our office agrees with this comment. The entirety of the Riverfront Area to the
extent of the 200-foot offset is a resource area as defined by 310 CMR 10.58.
Comment 2: As submitted, the work does not appear to comply with the Riverfront regulations
at 310 CMR 10.58(4). An alternatives analysis must be submitted for any work submitted under
the new development section of the regulations for work in Riverfront. The scope of alternatives
for a commercial project such as this is any other land which can be reasonably obtained within
the municipality.
Response 2: The attached Alternatives Analysis contains the following information relative to
site selection.
Before even approaching landowners in Northampton, Syncarpha conducted internal due
diligence related to the interconnection feasibility of regions within the City of
Northampton. Using the National Grid interconnection queue as well as three phase mapping,
they selected parcels of land that were determined to have the greatest chance of receiving an
Northampton Community Solar Project
Park Hill Road, Northampton, MA
MADEP File Number 246-0723
September 12, 2018 Page 2
interconnection service agreement from National Grid with reasonable upgrade costs. Since
solar has been so popular within the Commonwealth for the last 5 years, the grid (especially
National Grid's service territory) has become extremely saturated -- pushing many distribution
lines, feeders, and substation transformers to their absolute maximum capacities. As a result,
just because a parcel of land is located near three phase power, solar developers can no longer
automatically assume the site can be interconnected -- hence the aforementioned due
diligence. Once interconnection feasibility was determined, Syncarpha then further eliminated
sites based on certain environmental concerns. For example, they tried to avoid sites that would
require substantial grading and clearing; sites with major wetlands concerns; sites within the 100-
yr floodplain; etc.
Taking all of that into consideration, they ultimately reached out to ten (10) landowners in
Northampton via mailers and phone calls to gauge their interest in solar development. Based on
that outreach, the only landowner that was interested (and they could reach commercial terms
with) were Kenneth and John Burt, the current owners of the selected property.
Comment 3: Information on cost, existing technology (including using higher efficiency panels),
the proposed use and logistics is required. See 310 CMR 10.58(4)(c)1.
Response 3: The Alternative Analysis contains the information below on the use, panel
efficiencies, cost and available technology. The response to Comment 2, above, relates to
logistics.
The size of the PV array was originally reduced to fit within the confines of the existing meadow
and remain in areas that presented minimal risk of impacts to the resource areas. The use of 345-
watt panels provides for the use of fewer panels than the less expensive 300 to 310-watt panels
that are in use on many arrays. Panel spacing between rows has been minimized to the extent
practicable to prevent shadows on adjacent rows of panels. Any additional reduction in the space
between the rows of panels would result in shadow impacts and would reduce the efficiency of
the overall array.
The revised layout of the panel system retains the use of the 345-watt panels and does not
change the row spacing across the various locations on the overall site. The placement of the
panels in the southeast corner and the shifting of the maintenance road to the south allows for
the relocation of many panels from the resource area to the upland areas.
The use of panels that track the sun presents a significant increase in project cost ($0.05 to $0.10
per watt, or $250,000 to $500,000 for very little gain in efficiency. The reason for this is that for
locations in Massachusetts, the angle of the sun is such that the increase in efficiency is very
minor. In other parts of the country, this technology is more feasible. Another drawback to using
the tracking panels is that the installation of those systems requires a flat site, which would
require more earthwork and more overall land disturbance for the project, as well as a dramatic
Northampton Community Solar Project
Park Hill Road, Northampton, MA
MADEP File Number 246-0723
September 12, 2018 Page 3
increase in project costs. The final issue with the use of tracking panels is that the aerial
requirement for these systems is typically 1.5x to 1.75x larger than the systems that use the
stationary panels for the same power output. The overall footprint would grow dramatically to
maintain the same output. The tracking panels are typically a good choice on very large flat
locations in other parts of the United States.
Comment 4: If this is the only piece of land in Northampton that can be reasonably obtained,
then the Commission still has the ability to remove all work from the Riverfront. The purpose of
evaluating project alternatives is to locate activities so that impacts to the riverfront area are
avoided to the extent practicable. Projects within the scope of alternatives must be evaluated to
determine whether any are practicable. As much of a project as feasible shall be sited outside the
riverfront area. If siting of a project entirely outside the riverfront area is not practicable, the
alternatives shall be evaluated to locate the project as far as possible from the river. If there is a
practicable and substantially equivalent economic alternative with less adverse effects, the
proposed work shall be denied, and the applicant may either withdraw the Notice of Intent or
receive an Order of Conditions for the alternative, provided the applicant submitted sufficient
information on the alternative in the Notice of Intent.
Response 4: The alternatives analysis discusses an alternative layout that may be considered
to have less environmental impact. We have relocated many of the panels within the Riverfront
resource area and expanded the upland portions of the site to include the wooded southeast
corner. By removing the trees in that area, we can shift the panels out of the Riverfront Area and
place them in upland area. We have resubmitted a plan set with the Northampton Conservation
Commission seeking approval of the revised layout. In this case, the evaluation of the alternatives
has led to a better layout.
Comment 5: The Stormwater report cannot be used unless actual soil analysis is conducted
onsite. One cannot model stormwater without confirming actual soil type. Per Volume 3 Chapter
1 of the stormwater handbook, a Competent Soils Professional conducts a site visit to verify soil
conditions on the site. Please see Table. 2.3.1.
Response 5: The Massachusetts Stormwater Handbook defines a Competent Soils Professional
as “an individual with demonstrated expertise in soil science, including, but not limited to, a
Massachusetts Registered Professional Engineer, Engineer in Training (EIT certificate) with a
concentration in civil, sanitary or environmental engineering, or Bachelor of Arts or Sciences
degree or more advanced degree in Soil Science, Geology, or Groundwater Hydrology from an
accredited college or university.”
On January 17, 2018, I personally visited the site to conduct field reconnaissance with regards to
topography, watershed boundaries and soil conditions based on preliminary review of NRCS soils
data, aerial photography, LIDAR topographic data and surficial geology mapping. I am a
Registered Professional Engineer in the Commonwealth of Massachusetts and have been
Northampton Community Solar Project
Park Hill Road, Northampton, MA
MADEP File Number 246-0723
September 12, 2018 Page 4
responsible for performing stormwater management studies for over 25 years throughout New
England.
On May 4, 2018, I again visited the site once our office had completed preliminary modeling to
perform a field check of our assumptions. During that site visit, I performed numerous hand
augured soil explorations to confirm our assumptions within the stormwater model with regards
to Hydrologic Soil Groups.
On June 7, 2018, I returned to the site with Devin Howe from our office. Devin hold an EIT
Certificate in the Commonwealth of Massachusetts and has been working in this industry for
approximately 4 years. The purpose of that visit was to review field conditions pertaining to Park
Hill Road prior to meeting with neighbors about the project. During that site visit, we reviewed
the conditions across the meadow portion of the field where the panels are planned for
installation. I discussed the auguring process that I had undertaken during my prior visit and the
verification of the Hydrologic Soil Group assessment for the stormwater model. We also reviewed
the locations for the point of analysis.
Finally, on July 17, 2018, Devin Howe again visited the site with another colleague from our office
to collect additional data regarding Park Hill Road and the overall site hydrology. Based on these
site visits, we feel comfortable in stating that a Competent Soils Professional has conducted a site
visit.
We trust these responses have adequately addressed your comments. We look forward to
continuing to work with the Department as well as the Northampton Conservation Commission
to permit this sustainable energy project. If you have any additional questions or require
additional information, please do not hesitate to contact me at the address above or via email at
tmorey@bealsassocaites.com.
Sincerely,
Beals Associates, Inc.
Todd P. Morey, P.E.
Vice President
Enc. Alternatives Analysis
Revised Plans (via separate email)
C: Keith Akers, Syncarpha
Sarah LaValley, City of Northampton