9VAC15-60-60. Mitigation Plan. Section E, Part 3, Table 1:

For Option 2; I support changing the Mitigation Actions Required language to the following:

“Areas with changes in grade due to cut and fill with removal and return of topsoil, decompaction of topsoil to six inches following installation, maintenance of > 75% living vegetative cover for project lifetime, and decompaction to > 24" and surface soil amendment after decommissioning.”

Rationale: The current language specifies decompaction of the subsoil (in addition to topsoil) following installation which is not feasible in many site settings following panel installation. As long as the returned topsoil is decompacted to six inches, a certain amount of improvement in the quality of the subsoil is to be expected over the operational (20 to 30 years) period due to rooting and other processes, assuming 75% living vegetation is maintained. However, the deep ripping/decompaction to > 24 inches will be essential for site decommissioning to ensure reasonable levels of soil productivity for agriculture or forestry.