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memo <br />2of2 <br />downstream portion of the access road, and, where unavoidable, between panel rows to capture <br />water from the array and road surface. The total open space between and around the panel rows <br />(approximately 3.3 acres) is significantly greater than the BMP footprint area required, allowing for <br />optimal siting of stormwater practices (see attached exhibit). <br />The options under consideration include bioretention basins, rock trenches, and bioretention <br />swales. Because soils on the site are generally poorly drained, the practices would be installed with <br />an underdrain. This configuration allows water to filter slowly through engineered soil media <br />before being discharge to the onsite wetland. The practices will remove pollutants and slow the <br />movement of water across the landscape. <br />Additionally, open areas between the rows of the solar array will be stabilized by planting with <br />native, pollinator -friendly species. Plantings will help to both stabilize soils on the site and to <br />improve the soil capacity to infiltrate stormwater. The flow rate and volume of stormwater leaving <br />the property will be lower and the water quality will improve as a result of the proposed solar <br />installation. <br />Wetland Impacts <br />About 50% of the leased property is composed of wetland. Solar panels have been located in upland <br />areas to the extent practical, and fringe (degraded) wetland areas. Higher quality wetlands have <br />been avoided and protected. Approximately 1/4 - 1/3 of the pilings for the solar arrays will be <br />located within wetland areas (primarily degraded wetland areas). The owner is seeking area No - <br />Loss Decision from the WCA LGU (MN Rule 8420.0420 Subp.6(A)). The cumulative area of piling <br />installation is significantly less than the 0.5 acre threshold referenced in this rule. The site plan <br />does include some impacts to wetland areas for construction of the access road, but because the site <br />is relatively flat; grading impacts to adjacent wetland areas are minimal. The total area of impact <br />due to road construction is less than 0.25 acres. The owner proposes to use wetland banking credits <br />to mitigate the area of impact. Additionally, runoff from the roadway will be directed to filtration <br />BMPs to mitigate pollution and disperse flow as described above. <br />Emmons & Olivier Resources, Inc. <br />7030 6`h St. North Oakdale. MN 55128 T/ 651.770.8448 F/ 651.770.2552 www.eorinc.com <br />