STR-STH's #SmartSolar Initiative
STR-STH Vice President Deb Moshier-Dunn has been asked by CT DEEP to participate in their “Sustainable, Transparent & Efficient Practices” (STEPs) for Solar Development. She spoke on June 16th during one of the Zoom meetings held by DEEP.
CLICK HERE for STR-STH's written comments submitted as our statement to DEEP about the issues with the Solar Siting process.  LIDAR view of proposed project showing re-grading areas in dark gray and proposed water ways coming off the Site. (Credit Joel Stocker)
This map shows the proposed Site for a 45,000 solar panel installation. The dark gray areas are proposed "regrading" areas. The blue lines represent where the streams and wetlands are, including Oil Mill Brook to the left and Stony Brook to the right. Both of those trout-supporting clean Brooks drain directly into the Niantic River about 4,000 feet away. Solar installations are not "farms", they are made of glass, aluminum and concrete. There was legislation passed to try to protect core forests and prime agricultural lands in 2017. This particular proposal predates the legislation so they are proposing to clear 75 acres of core forest. STR-STH opposes the development of core forests that surround the Niantic River. Forested lands are needed to maintain the water quality of the tributaries. The Watershed is an ecosystem - all the parts need to be functioning to protect the fragile estuary called the Niantic River...
Here's the link to the CT Siting Council page that houses all of the info about the project from the solar company, the Town of Waterford and STR-STH. (You can see all the work we are doing!) https://www.ct.gov/csc/cwp/view.asp?a=2397&q=611294. CLICK HERE TO SEE OUR FINAL #SmartSolar BRIEF November 16, 2020 - Click here for a link to the article in The Day Update: November 5, 2020 Unfortunately, we don't have good news. The CT Siting Council voted 3-1 (2 abstained and 1 recused) to go forward with this ill-conceived solar project in Waterford. We have no doubt that the streams on each side of the site will be adversely impacted by this heavy development of 75 acres on a currently core forested parcel. The one Council member who voted "No" stated that as his reason for voting no. STR-STH will be putting Water Quality Monitors around the Site to monitor the effects on the surrounding streams as clear cutting and construction start. This is truly a poor decision. Update: October 30, 2020 The decision is now in the hands of the CT Siting Council. We have been notified that the decision will be made at the November 5th Council meeting. We will keep you posted! UPDATE: September 26, 2020 Our Final Brief was due on Thursday so all the evidence is in to the CT Siting Council. It is now up to the Council to decide whether or not the solar installation, as proposed, will or will not "adversely impact the environment". Our Brief details all the reasons that we believe that the currently proposed solar installation WOULD INDEED ADVERSELY IMPACT THE ENVIRONMENT, specifically, the two surrounding trout-supporting tributaries to the Niantic River Estuary (both Oil Mill and Stony Brooks). CLICK HERE TO SEE OUR FINAL BRIEF Below is the running History of #SmartSolar Initiative: UPDATE: September 10, 2020 - Click here for the Link to the Transcript of the Evidentiary Hearing of August 25th. Update August 25, 2020 - THE PUBLIC HEARING is over... longest one in history. Started in March, ended today. Watch here for the link to the Zoom meeting recording - we will post when the CSC sends it out so you may view it at your leisure. We hope our input was heard by the CT Siting Council and they will take into consideration everything we've worked so hard to get in front of them. If you know of an organization or group that would like to be heard about this installation, the record is still open for letters to be sent to the CSC until Sept 24, 2020. Email at siting.council@ct.gov or by regular mail at: Connecticut Siting Council Ten Franklin Square New Britain, CT 06051 July 22, 2020 - THE PUBLIC HEARING is continued to August 4. That's when our attorney will ask questions of the solar company. We hope to get answers about stormwater protections, and the new site plan (they keep referring to but no one has seen) as well as other issues our #SmartSolar team has found with the application. If you want to see the recorded Zoom Public Hearing from July 14, here's the link is below. The first part is the CT Siting Council asking questions of the solar company, then at the end STR-STH's attorney asks some questions, but we get to ask more on Aug 4th. https://zoom.us/rec/play/tZUoJLiurj83H9KV4gSDB6QoW9S-LKys03VM-PAEyUqzBnUHYFOnZ7QSZuOBj1n3IPS5_7id2zO_3ryr?startTime=1594745966000&_x_zm_rtaid=hEbL76bvTv6HUVU5XVAyDQ.1595440419368.8f27cb0787e713232111b4ab913e6110&_x_zm_rhtaid=282 You need to enter Password: 5m*+I29+ July 14, 2020 - THE PUBLIC HEARING is tonight July 14 at 6:30pm. There are 17 speakers signed up. (We just finished the beginning of the Evidentiary Session. STR-STH is intervenor in this Petition, so we were invited to the 1pm-5pm session to ask questions of the solar company. That portion is ongoing and will reconvene on Aug 4th.) "On February 27, 2020, the Council, pursuant to a request filed by GRE GACRUX, LLC, reopened this petition. The reopening will allow the Council to consider changed conditions. The 1:00 p.m. evidentiary session will provide the petitioner, parties, and intervenors an opportunity to cross examine positions. No public comments will be received during the 1:00 p.m. evidentiary session. Interested persons may join any session to listen, but must sign-up in advance to speak during the 6:30 p.m. public comment session. To speak at the 6:30 p.m. public comment session by computer, smartphone or tablet, please send an email to [email protected] with your name, email address and mailing address by July 7, 2020. To participate in the 6:30 p.m. public comment session by telephone, please leave a voicemail message at 860-827-2935 with your name, telephone number, and mailing address by July 7, 2020. Public comments may also be submitted to the Council by email at [email protected] or by regular mail. The 6:30 p.m. public comment session will be reserved for the public to make brief statements into the record. During the 6:30 p.m. public comment session, the petitioner will present an overview of the proposed facility. * 1:00pm to 5:00pm - The solar company will do a short presentation on the project then the CT Siting Council (CSC) will ask questions about the development's plans. The town of Waterford may have a chance to ask questions, and STR-STH may as well, but there is already a plan to have a continuation of this"Evidentiary Testimony" for the town and STR-STH to ask more questions of the solar company and ask each other questions on July 14 at 1pm (on the same Zoom link). * 6:30pm to 9:30pm - the public who have signed up to speak (by last Thursday) will be "unmuted" by the staff of the CSC when it is your turn. There are 17 people scheduled to speak for 3 minutes each. Join Zoom by the above link or call in on the above number a bit prior to 6:30pm to make sure you can be heard, and seen (if you want to be). The public who have not signed up to speak but want to hear others speak use the same directions. You will remain muted throughout the hearing. Thank you for your interest in this!! A TON of work has been done by the #SmartSolar team on behalf of the River... ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ June 14, 2020 - THE PUBLIC HEARING HAS BEEN SCHEDULED TO BE A ZOOM MEETING ON JUNE 25, 2020!! Click here for the letter from the CSC with all details on how to participate. It's a Zoom Public Hearing, or you can join by telephone. BUT!!!! TO HAVE YOUR CHANCE TO BE HEARD ABOUT THE PROPOSED SOLAR INSTALLATION OFF OIL MILL ROAD IN WATERFORD, YOU MUST LET THE CT SITING COUNCIL KNOW BY THIS THURSDAY JUNE 18th if you want to speak!! Everyone gets to speak for 3 mins. Email: [email protected] (with your name, email address and mailing address) or to attend by phone, call 860-827-2935 (leave a message with your name, telephone number, and mailing address) See below from the CT Siting Council: " To participate in the 6:30 p.m. public comment session by computer, smartphone or tablet, please send an email to [email protected] with your name, email address and mailing address by June 18, 2020. To participate in the 6:30 p.m. public comment session by telephone, please leave a voicemail message at 860-827-2935 with your name, telephone number, and mailing address by June 18, 2020. Public comments may also be submitted to the Council by email at [email protected] or by regular mail." Update May 20, 2020 - THE PUBLIC HEARING HAS BEEN SCHEDULED TO BE A ZOOM MEETING ON JUNE 25, 2020!! Stay tuned as we find out what this means and how to participate. We were notified last night... Update April 2020 - The CT Siting Council (CSC) process is ongoing. We have just submitted our Responses to the Petitioner (Greenskies) and received their answers to our Interrogatories. The Town of Waterford also asked very insightful questions in their Interrogatory to Greenskies. The answers are not good. The attorney for Greenskies motioned the CSC to make STR-STH retain an attorney. So this is getting more costly for us. BUT! Be careful what you ask for... we hired a fantastic attorney named Emily Guianquinto. She added value day 1 and has been a great addition to our #SmartSolar team of Steve Trinkaus, PE, Don Danila, and Deb Moshier-Dunn. (We have others behind the scenes helping as well. :) ) The next phase moves us into the Witness Testimony - with a date TBD by the CSC. (But we are working on it in preparation for the announced date). The Public Hearing is also TBD. Stay tuned! It remains to be seen if all of our work will make a difference in the decision of the CSC. The CSC process weighs heavily to the advantage to the Petitioner. If you would like to support us in the protection of the Watershed through the #SmartSolar initiative, please send a check to PO Box 505 Waterford, CT 06385. Also, please send us your email if we don't have it yet. We are sending out short emails with updates on all of our programs. We're sorry we are not sending out newsletters in the USPS until the Coronavirus situation is better in hand. Thank you all for your continued support!! The Day also wrote an article about the downstream landowner's lawsuit in EL [click here to go to The Day's article] April 2020: Petition #1347 with the CT Siting Council (CSC) for the Waterford Solar installation of 55,000 solar panels off Oil Mill Road had been denied "without prejudice" in December 2018 - which meant they could come back under the same Petition IF they do all the things that were specified by the Council in the denial letter. The Solar Company submitted a Motion to Re-open the Petition and the CSC allowed it - even though the stormwater issues were not resolved. STR-STH maintained our Intervenor Status and we are actively involved in the CSC process for the newly submitted plans for 45,000 solar panels on a hill between Oil Mill Brook and Stony Brook. Our engineer's review has found that this new plan WOULD ADVERSELY IMPACT THE SURROUNDING WATERSHEDS, INCLUDING THE NIANTIC RIVER. Here is the letter STR-STH submitted to the CSC asking for the Petition NOT to be reopened for a number of reasons (click below): str-sth_response_letter_v7a.docx.pdf Here's the link to the CSC Petition 1347A (the new one) with ALL the documents submitted by STR-STH and all of the parties involved: https://www.ct.gov/csc/cwp/view.asp?a=2397&q=611294 You can see the plans and where the forest will be taken down and the proximity to Oil Mill and Stony Brooks. Here's the link to the CT Siting Council Petition and all of the documents having to do with the original project (Petition 1347): https://www.ct.gov/csc/cwp/view.asp?a=2397&Q=603418&PM=1 History: We are Intervenors in CT Siting Council 1347 Petition for a Solar Power Installation in a core forest area between Oil Mill Brook and Stony Brook in Waterford. They are headwaters for the Niantic River Estuary. The run-off from such a large solar installation will adversely affect both Brooks, the Niantic River and the LI Sound. The company proposing this installation is the same one that created the wetlands & stream disaster with their installation in East Lyme on Walnut Hill Road. We brought that info to the Council and were able to ask the Petitioner questions that they answered for the Public to see. Our questions, their answers and all other input for the CSC Petition are online at the link referenced above. STR-STH is pro-solar. Just not at the cost of Water Quality for the Niantic River Watershed. #SMARTSOLAR The following is the article as we submitted it as an OpEd that was published under a different title by The Day on Sunday, September 22, 2019. IT IS STILL VERY RELEVANT TODAY (April 2020) as the Solar Company has Motioned to Reopen the Waterford Petition with the CT Siting Council. STR-STH remains an Intervenor in this Petition. [Click here for the link to The Day OpEd] Solar Array Construction in the Niantic River Watershed – Turning Native Trout Streams into Drainage Ditches. By Deb Moshier-Dunn and John P. Jasper Save the River-Save the Hills would like to inform the public about an ongoing threat to the water quality of the Niantic River and two of its major tributaries (Oil Mill Brook and Stony Brook) in Waterford. The developer of a proposed solar array installation which was "denied without prejudice" by the Connecticut Siting Council (CSC) last December largely because of the negative effects it would have on the two native trout streams on each side of it, has indicated they will be moving forward with the installation. A “denial without prejudice” allows the developer to return with another plan under the same request for proposal. We feel it is important to write this article to let the public know since no public hearing was held for this project. The public has a right to know because if this project is allowed to move forward, prospective adverse impacts will detrimentally affect not only the water quality of the adjacent brooks, but the Niantic River and ultimately the Long Island Sound as the tidal river drains directly into it. The current proposal is to install 55,000 solar panels on approximately 90 acres of hilly terrain off Oil Mill Road in Waterford, Connecticut. Installing a solar array of this size on the hilly terrain between two streams that currently support native brown and brook trout is irresponsible development. The developer already has a record of destroying a tributary to the Niantic River in East Lyme (see photo of East Lyme watershed above) resulting in a lawsuit against the developer by downstream landowners. Looking at the photographs of the devastation after sequential two-inch rain events on the Walnut Hill Road solar installation gives a daunting forecast for the proposed Waterford site which is three times the size (viz., approximately 90 acres). The CSC wisely denied the developer's petition to develop the Waterford site because it felt the project would adversely affect the environment. The hardscape of such a large array would very likely cause huge amounts of runoff on both sides of the property and the runoff needs to be treated like it would for any other large building. These are not "solar fields”, they are industrial structures made of glass, metal and concrete which are installed on soil that has been physically compacted during the installation process. As seen in at the East Lyme site, these ground-mounted solar arrays have a record of destroying water quality around them. The stormwater systems in the solar installations in East Lyme were inadequate to handle the actual volume of runoff generated. The proposed site in Waterford uses the same faulty engineering and will likely cause similar issues – on a scale three times larger than the one in East Lyme, adversely affecting two different native-trout-stream tributaries to the Niantic River. The Waterford site is a mere 4,000 feet from the Niantic River. There is no margin for error for proper stormwater mitigation. The river will suffer if this project goes forward. In 2014, the design of the solar array installation in East Lyme involved marked earth disturbance over an approximately 30-acre area. Topsoil was stripped and removed from the site and does not appear to have been replaced after mass grading was performed. Site disturbance compacted the native soils to such a degree that rainfall even from the grassed areas runs off and does not infiltrate into the soil. The engineering design incorrectly considered the solar panels in the array to be “pervious” and thus grossly underestimated the volume of runoff generated from the site. Even after completion, increased runoff volumes continue to cause adverse impacts to the stream channel morphology on the unnamed brook which runs into Cranberry Meadow Brook and ultimately the Niantic River. These same issues existed in a ground-mounted solar installation in Pomfret which has resulted in the Connecticut Department of Energy and Environmental Protection (CT DEEP) fining the developer $575,000 for non-compliance with the DEEP General Permit and the resulting destruction to wetlands by “sediments from the Site going off-site and blanketing thousands of square feet of adjoining wetlands…” (viz., CSC Consent Order COWRSW18003). A much smaller proposed solar installation in Killingworth was totally denied approval this past May with the CSC citing water quality issues as the main reason for denial. Current engineering standards used for ground-mounted solar are inadequate here because they are based on the incorrect assumption that the solar arrays are on liquid pervious sites. In most cases, however, they are not. The construction of ground-mounted solar arrays creates an impervious site and should be required to have Low Impact Development (LID) engineering to protect the surrounding wetlands and water courses. And it should not be allowed at all in a core forest surrounded by trout streams. Also, cutting 90 acres of core forest to install 55,000 solar panels - thus replacing nature's free carbon recycling and storage with hardscape, metal and glass - does NOT result in a net decrease in carbon emissions in New England. The conversion of active cropland, farm meadow, and forests to a solar array is environmentally irresponsible as these green areas are very effective carbon sinks. The vegetations takes in carbon dioxide to grow and release oxygen to the air. Carbon is sequestered in the woody material and in the soil in these areas and remain there unless disturbed for decades to millennia. In 2017 the Connecticut State Legislature passed a law that effectively bans cutting core forest to put in solar arrays. PA 17-218—SB 943 states: “The act requires the DEEP commissioner, when considering proposals received after July 1, 2017 in response to certain energy-related solicitations, to consider (1) their environmental impact, including the impact on prime farmland and core forests, and (2) the reuse of sites with limited development opportunities, such as brownfields and landfills.” Unfortunately for the Waterford forest, the developer petitioned the CSC on a request for proposal that was applied for prior to the new law. That is the only reason this proposal to cut down a core forest has been allowed to continue. We recommend that it be stopped. While the installation of solar arrays has a seemingly appealing environmental and certainly federal-tax abatement appeal, each solar panel only converts only about 26% of the sun’s energy into power every year, with this efficiency decreasing by roughly 0.5% per year. Additionally, when the lack of sunny days in Connecticut is accounted for on a yearly basis, the power generated by one of these large arrays is only 22% of the stated power output. Finally, there is currently no present method for the recycling of solar panels. Panels, with all their toxic materials, simply end up in landfills. Brook and brown trout populations are on the decline in Connecticut because of habitat destruction such as siltation caused by solar field installation. Let's protect those we have left and not turn them into drainage ditches. Let's be Smart about Solar and put solar panels where they belong - on already developed property like a large warehouse rooftop or even a landfill that's been properly capped. Let's keep the forests surrounding our rivers thriving so we can keep our rivers clean. #SmartSolar Deb Moshier-Dunn is the Vice President of Save the River-Save the Hills, Inc. John P. Jasper is a Board Member of the Niantic River Watershed Committee, and a member of both the Nitrogen Work Group and Trout Unlimited. |
See Damages to East Lyme Tributary...
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