As an organization that currently holds easements on projects that mitigate impacts to streams and wetlands, we support this approach to offsetting impacts of solar projects. 

We support the idea of offsetting impacts in mitigation districts with the following recommendations:

1. Determining ILF fees based on the Tax Department's information regarding the value of conservation easements throughout the state is a sound approach; however, these fees should be based on specific mitigation districts rather than a statewide average. There is a significant difference in the cost of protecting a property in Loudoun County compared to Halifax County. This should be taken into account.
2. "An Applicant may propose innovative alternatives to the required mitigation." These alternatives should be made public and ultimately incorporated into the regulations. 
3. "A conservation easement shall encumber land in the same mitigation district as the area disturbed. In the event the applicant cannot locate land in the same mitigation district, the department may allow the land to be in an adjacent mitigation district." How will this be determined? This seems awfully broad. There should be specific triggers that determine whether an applicant can mitigate impacts in a neighboring district. 
4. "Easements for forest mitigation shall be consistent with the Easement Term Guidelines adopted by DOF. Easements for mitigation of prime agricultural soils shall be generally consistent with the Virginia Outdoors Foundation (VOF) easement template for Working Farm/Intensive Agriculture. Easements for mitigation of C1 or C2 forest cores shall be consistent with the VOF easement template for protection of natural areas." These templates are a good place to start, and that appears to be the intent. The term "generally consistent" should be used across the board. A list of necessary restrictions and requirements would also be helpful in order to create consistency between projects.