The Virginia Native Plant Society is a volunteer-led conservation 501(c)(3) organization with nearly 2000 members and is committed to conserving wild flowers and wild places. The VNPS favors regulations that will prevent or severely limit the deleterious effects of solar farms in terms of their impacts on native plant communities. These solar farms also offer the opportunity to use native plants to create habitat to support pollinators and other at-risk fauna in areas with little current conservation value.  

In regard to the completion of the Virginia Pollinator-Smart Solar Scorecard as part of the application, we note that there is no requirement for the Scorecard to be passed, nor is there any requirement currently in the regulation for native species to be planted. The current version of the PBR asks only that the developer complete the scorecard to suggest they think about incorporating native species at their site. We favor stronger regulations regarding completion of the scorecard and a requirement for planting native species.

We believe that there should be a requirement for a desktop analysis studying Ecological Cores and total avoidance of C1 and C2 cores. The ecological cores model is a product created by the Natural Heritage Program in partnership with another group, and it identifies and prioritizes areas of land (usually forested) that are 100 acres or greater into categories C1-C5.  C1s are usually places like the Dismal Swamp, GWNF, and other large tracts of land with intact natural communities and habitat for rare species.  Under no circumstance, other than to protect the immediate safety and well-being of those nearby, should these cores be permanently destroyed for “green energy.”  In the event that C1 or C2 ecological cores require impact for a solar farm, we believe mitigation that may be reasonably expected to protect an equal or larger area of similar (in habitat type and vicinity) ecological cores be mandatory. We also recommend that counties review ecological cores during their special use or conditional use permitting process. We encourage mitigation for other types of ecological cores.

In addition, we recommend that the regulations should be effective immediately upon adoption. 

Thank you for the opportunity to comment.

Nancy Vehrs

President, Virginia Native Plant Society

www.vnps.org