Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
Small Solar Renewable Energy Projects Permit Regulation [9 VAC 15 ‑ 60]
Action 2019 Amendments Solar PBR
Comment Period Ended on 6/26/2019


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6/26/19  8:51 am
Commenter: John Hutchinson, Shenandoah Valley Battlefields Foundation

Regulatory Advisory Panel 2019 Amendments Solar PBR

Dear Ms. Minor: 


I would like to become a member of the Regulatory Advisory Panel 2019 Amendments Solar PBR.  Requested information is provided below. 


Name:                                              John D. Hutchinson, V

Address:                                          P.O. Box 897. S.Congress Street, New Market, Va. 22844

Phone number:                             540.292.0396

Email address:                     

Organization I represent:             Shenandoah Valley Battlefields Foundation

CommentID: 72728

6/26/19  9:40 am
Commenter: Nikki Rovner, The Nature Conservancy

Regulatory Advisory Panel

Ms. Major,

The Nature Conservancy requests representation on the Regulatory Advisory Panel for the Solar Permit By Rule.  Specifically, we request a seat for:

Judy Dunscomb, Senior Conservation Scientist

The Nature Conservancy

652 Peter Jefferson Parkway, Suite 190
Charlottesville, VA 22911

(434) 951-0573

Thank you,

Nikki Rovner


CommentID: 72730

6/26/19  10:37 am
Commenter: Mark Coombs, American Battlefield Trust

RAP for the Small Renewable Energy Projects (Solar) PBR

Ms. Major,


Good morning!


The American Battlefield Trust formally requests representation on the Regulatory Advisory Panel for the Small Renewable Energy Projects (Solar) Permit by Rule. 


Contact information — inclusive of personal addresses — for primary and alternate representatives of the Trust is provided immediately below:




Adam Gillenwater

State and Local Relations Manager, American Battlefield Trust

1529 27th Street NW

Washington, DC 20007

(202) 367-1861, ext. 7211




Mark Coombs

Deputy Director of Government Relations, American Battlefield Trust

8117 Bainbridge Road

Alexandria, VA 22308

(202) 367-1861, ext.7224


(Please note that the Trust’s organizational mailing address is 1156 15th Street NW, Suite 900, Washington, DC 20005.)


The Trust would look forward to representing the battlefield preservation community alongside John Hutchinson and our partners at the Shenandoah Valley Battlefields Foundation.


Many thanks for your consideration.




Mark P. Coombs
Deputy Director of Government Relations, American Battlefield Trust
1156 15th Street NW, Suite 900 | Washington, DC 20005
p) 202-367-1861 x7224 | (e)


AMERICAN BATTLEFIELD TRUST  |  Preserve. Educate. Inspire.


Visit us online at

CommentID: 72734

6/26/19  11:48 am
Commenter: Jim Orrell; Stantec Consulting Services Inc.

Amendments to the Solar PBR

Ms. Major,

As you know Stantec is currently representing several developers with projects in the PBR process.  A couple of areas of concern from them are:

  • Are there ways that the process could be more streamlined?  Could this be based on project size or whether a federal permit action is required?
  • Will there be requirements imposed related to pollinators?  I think you heard some of these concerns voiced at the stakeholder meeting yesterday. I am not under the impression that the developers are against the concept but the upfront cost and the unknowns of doing it for the entirety of these large sites raises issues that still need to be worked through. 

I would like to be considered to participate on the Regulatory Advisory Panel, to discuss these points and more, as you work through the revisions to the rule.  My contact information is: 

Jim Orrell, 5209 Center Street, Williamsburg, VA 23188, (757)220-6869;


CommentID: 72737

6/26/19  6:51 pm
Commenter: Rene' Hypes, Department of Conservation and Recreation-Natural Heritage

DCR-Natural Heritage Comments for Solar Permit by Rule

The Department of Conservation and Recreation's Division of Natural Heritage's (DCR) mission is conserving Virginia's biodiversity through inventory, protection, and stewardship.  Natural heritage resources are defined as the habitat of rare, threatened, or endangered plant and animal, unique or exemplary natural communities, and significant geologic formations.

Please find below the following DCR Solar Permit by Rule (PBR) recommendations and comments:

* As part of the PBR application, DCR requests a map identifying the array layout, buffer areas, fencing, grid interconnect infrastructure including battery storage, access roads, etc. to aid in the review of the solar project.

* Based on desktop reviews and on site surveys, DCR recommends avoidance, minimization and mitigation of impacts to documented natural heritage resources within proposed solar projects. DCR may recommend field surveys for natural heritage resources based on nearby documented occurrences or intersection of the project footprint with predicted suitable habitat (PSH) models developed by DCR for rare, threatened and endangered species.

* DCR recommends the development of an invasive species management plan for proposed solar projects and the planting of Virginia native pollinator plant species that bloom throughout the spring and summer, to maximize benefits to native pollinators. DCR recommends planting these species in at least the buffer areas of the planned facility, and optimally including other areas within the project site. Guidance on plant species can be found here:

* Based on the proposed planting plan, DCR recommends the completion of a cost analysis of planting native plants including pollinators species compared to the long-term maintenance of turf grass. As part of that analysis, DCR also recommends the completion of the solar scorecard as part of the PBR application.

* When C1 (Outstanding ecological integrity) or C2 (Very High ecological integrity) cores as identified in the Virginia Natural Landscape Assessment ( are intersected by a proposed solar facility, prior to timber harvest an investigation of these forest fragmentation impacts is warranted. DCR can conduct a formal fragmentation analysis upon request. This analysis would estimate direct impacts to cores and habitat fragments and indirect impacts to cores.

Thank you for the opportunity to provide comments for this regulatory action. 



S. Rene' Hypes

Natural Heritage Project Review Coordinator

CommentID: 72759

6/26/19  7:11 pm
Commenter: Rene' Hypes

DCR-Natural Heritage Requests Membership on the Solar Advisory Panel

DCR-Natural Heritage requests membership on the Solar PBR Advisory Panel. 

Rene' Hypes, Natural Heritage Project Review Coordinator 

600 East Main Street, 24th Floor

Richmond, Virginia 23219




CommentID: 72763

6/26/19  10:23 pm
Commenter: Joe Lerch, Virginia Association of Counties

Regulatory Advisory Panel

The Virginia Association of Counties request to serve on the regulatory advisory panel for the review and revision to the PBR regulations.

CommentID: 72767