The Department of Conservation and Recreation's Division of Natural Heritage's (DCR) mission is conserving Virginia's biodiversity through inventory, protection, and stewardship.  Natural heritage resources are defined as the habitat of rare, threatened, or endangered plant and animal, unique or exemplary natural communities, and significant geologic formations.

Please find below the following DCR Solar Permit by Rule (PBR) recommendations and comments:

* As part of the PBR application, DCR requests a map identifying the array layout, buffer areas, fencing, grid interconnect infrastructure including battery storage, access roads, etc. to aid in the review of the solar project.

* Based on desktop reviews and on site surveys, DCR recommends avoidance, minimization and mitigation of impacts to documented natural heritage resources within proposed solar projects. DCR may recommend field surveys for natural heritage resources based on nearby documented occurrences or intersection of the project footprint with predicted suitable habitat (PSH) models developed by DCR for rare, threatened and endangered species.

* DCR recommends the development of an invasive species management plan for proposed solar projects and the planting of Virginia native pollinator plant species that bloom throughout the spring and summer, to maximize benefits to native pollinators. DCR recommends planting these species in at least the buffer areas of the planned facility, and optimally including other areas within the project site. Guidance on plant species can be found here: http://www.dcr.virginia.gov/natural-heritage/solar-site-native-plants-finder.

* Based on the proposed planting plan, DCR recommends the completion of a cost analysis of planting native plants including pollinators species compared to the long-term maintenance of turf grass. As part of that analysis, DCR also recommends the completion of the solar scorecard https://www.dcr.virginia.gov/natural-heritage/document/va-solar-site-pollinator-bird-habitat-scorecard.pdf as part of the PBR application.

* When C1 (Outstanding ecological integrity) or C2 (Very High ecological integrity) cores as identified in the Virginia Natural Landscape Assessment (https://www.dcr.virginia.gov/natural-heritage/vaconvisvnla) are intersected by a proposed solar facility, prior to timber harvest an investigation of these forest fragmentation impacts is warranted. DCR can conduct a formal fragmentation analysis upon request. This analysis would estimate direct impacts to cores and habitat fragments and indirect impacts to cores.

Thank you for the opportunity to provide comments for this regulatory action. 

Sincerely,

S. Rene' Hypes

Natural Heritage Project Review Coordinator