Alliance for the Shenandoah Valley strongly supports the draft amendments required by HB206 to advance renewable energy while protecting farm and forest land. We believe that appropriate mitigation measures will encourage solar developers to avoid our best working farms and intact forests, employ proven best management practices to minimize negative impacts to soil and water, and, if necessary, mitigate damage to natural resources.  

Alliance for the Shenandoah Valley is a nonprofit conservation organization that envisions a Shenandoah Valley sustained by farms and forests, clean streams and rivers, and thriving communities. Since 2019, Alliance staff and board have been working with local communities, local governments, and statewide partners to encourage a transition to renewable energy that complements, not conflicts with, our agricultural economy and water quality restoration efforts. 

Utility-scale projects that are thoughtfully-sited and carefully-constructed are more likely to be successful and supported by the communities in which they are located. We believe that DEQ’s proposed mitigation framework will benefit solar development by increasing the likelihood that solar developers bring forward well-sited and built projects. 

As the draft amendments move forward, we encourage DEQ to consider decreasing the size of the “mitigation district” as defined in the draft regulation. The Shenandoah River Basin is a very large land area, and farmland protection efforts, in particular, will be most effective as close to the impact as practical. Similarly, we support the provision that allows mitigation included in a siting agreement approved by a locality to satisfy the DEQ mitigation obligations. Several Shenandoah Valley counties have conservation easement authorities with farmland protection goals that are aligned with the goals of HB206. These publicly-supported land protection programs are a logical vehicle to achieve the mitigation objectives.

We applaud the legislature for adopting common sense mitigation legislation in 2022, and we thank the stakeholders and agency staff at DEQ for bringing forward a reasonable regulation. 

Thank you for the opportunity to comment.