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34 <br /> 1 compaction study are required as a part of the SUP Application. Although I have been <br /> 2 told by Planning Staff that a soils map was submitted, I can find no such soils report or <br /> 3 soil compaction study anywhere in the Binks Application materials included in the <br /> 4 Hearing Agenda. There is, however, a Geotechnical Note on the Site Plan that states: <br /> 5 "A geotechnical report will be produced following SUP approval. Report will be a <br /> 6 subsurface exploration utilizing soil test borings performed with a drilling rig in <br /> 7 accordance with ASTM D 1586 utilizing hollow stem auger drilling." <br /> 8 The following is an e-mail communication regarding the soil test requirement sent from <br /> 9 Mr. Mallett of the Planning Staff to Cascade Drive resident Robert Cantwell (who <br /> 10 forwarded to me Mr. Mallett's comments). Mr. Mallett stated: <br /> 11 "Yes, a reporting of the soils is a required component. This section is meant to <br /> 12 ensure that applicants are not proposing to build on alluvial soils and soil types <br /> 13 consistent with environmentally sensitive areas (e.g. wetlands). The submitted plan <br /> 14 has limited the request to upland areas and avoided the environmentally sensitive <br /> 15 streams. They have also mapped out the soil types and environmental features on <br /> 16 the properties. Staff feels this meets the requirement below, but is by no means the <br /> 17 end point. The Geotech notes refer to the fact that they will do additional borings <br /> 18 prior to construction. The common practice for this type of project would be to bore in <br /> 19 areas that would have a potential for weight load (e.g. the service road to ensure <br /> 20 soils will support vehicles) and avoiding major subsurface rock features. " <br /> 21 <br /> 22 I have scoured the SUP Application in the Hearing Agenda for any document that <br /> 23 provides a soils report or the soils map that Mr. Mallett mentions, but have not found it. <br /> 24 My concerns are these: <br /> 25 The SUP Application Submittal Requirements are clearly stated, and requirement (d) <br /> 26 seems to plainly require a soils report and compaction study be submitted with the <br /> 27 Application (not after the SUP has been approved, as Binks proposes). I have found no <br /> 28 instance of any documentation related to soils in the Binks Application, nor have I come <br /> 29 across any provision in the UDO stating that the soils and compaction studies are an <br /> 30 optional component of the submission or that they are required conditionally, depending <br /> 31 on the nature of the site that is being developed. If I have overlooked anything in the <br /> 32 SUP Application or UDO contrary to what I have stated above I apologize, and I will <br /> 33 stand corrected. <br /> 34 A full geotechnical report should be required for this project for the following reasons. <br /> 35 This development calls for a large-scale 20 acre, 5 megawatt power installation requiring <br /> 36 the erection of 18,354 solar panels in 966 strings. Based on the site plan drawings, the <br /> 37 panels will be held up by relatively small supports along their length. The structures will <br /> 38 be subject to wind shear, soil-soaking rains and other stresses, so a full assessment of <br /> 39 soil properties is critical in order for planning staff to fully understand the site's suitability. <br /> 40 The report could well reveal soil compaction characteristics, subsurface rock features at <br /> 41 a shallow depth (as I do on my property about 125 feet away from the project boundary) <br /> 42 or other unknown but important features that would affect the Planning Staff's opinions <br /> 43 and recommendations, as well as State regulatory agency approvals. In addition, the <br /> 44 property owners affected by this project would then have an opportunity to review and <br /> 45 comment on the soil test data. <br /> 46 I therefore request that the applicants be required to submit a full soil <br /> 47 geotechnical report before the SUP is considered, and that the Commissioners <br /> 48 grant a continuance of this Hearing until after the full geotechnical report has <br /> 49 been conducted and planning staff, State regulatory agencies and adjacent <br /> 50 property owners have had a chance to review and comment on it. <br /> 51 <br />