Localities in Virginia have rejected solar farms because of concerns about "prime farmland", and losing productive cropland. Last month a project was denied because losing forty acres of farmland would "upset the agricultural balance".

Solar on rooftops and brownfields will not make a dent in the ambitious goals of the Virginia Clean Economy Act. The proposed updated rules include a restriction on building projects in C1 and C2 ecological cores. These cores include large tracts of planted pine trees that have been managed, cut, and regrown. In its description of ecological cores, the DCR touts the benefits of the ecological cores: open space, drinking water protection, carbon sequestration, economic benefits. Solar projects are consistent with all of these concepts.

The proposed rules would create unwarranted obstacles in meeting the Commonwealth's goals for the adoption of clean energy.