SW1210503_Response To Comments_20210730

July 28, 2021
Stormwater Permit No. SW 1210503
Hot Springs Microgrid
Madison County, NC
Plan Reviewer
Jim Farkas
DEMLR Stormwater Program
512 N Salisbury St, 6th floor
Raleigh, NC 27604
Civil Engineering
Jeff Ruppert
SEI Engineering
39845 Matthews Lane
Paonia, CO 81428
0 SEI Engineering
Engineering a World Powered by Sotar Ent: ay
EPC Contractor
Jonathan Nicolosi
United Renewable Energy
5895 Shiloh Road Suite 104
Alpharetta, GA 30005
In response to DEMLR correspondence on June 18, 2021:
Stormwater Permit No. SW 1210503
ATTN: Jim Farkas
Per the provided ground lease agreement, it appears as though the Permittee/Property
Owner relationship may be better defined as "Lessee" rather than "Developer"
Section III, lc). If this is a lessee relationship, you will need to provided
documentation showing the legal relationship between Duke Energy Progress, LLC
and the Permittee, United Renewable Energy, LLC..
Document provided by EPC Contractor and included in this submittal.
2. Please clarify the project area for this project (Section IV, 7). Per the Application, it
appears as though the entire property area is being covered under this permit
however, the plans appear to indicate the area to be permitted as a smaller subset of
the total property area. You can use either the entire property area or an appropriate
subset of the total property area/a user -defined area (such as a Limit of Disturbance,
the area to be leased, etc...), it just needs to be consistent throughout the submission..
Project area to being evaluated is the Limits of Disturbance at approximately 15.8
acres total.
3. For projects with existing BUA you are allowed to exclude the existing BUA from
project density calculations per 15A NCAC 02H .1003(1)(b) (Section IV, 8).
BUA areas include only the area within the Limits of Disturbance.
39845 Mathews Lane Paonia, CO 81428
970-527-3920 1 [e-mail] I www.seisolarpros.com

4. Typically, low -density projects only have a single drainage area, the entire project
area, however in situations where part of the project area drains to one classified
surface water and the other portion of the project area drains to a different classified
surface water (such as this project), then the low -density project would have two
drainage areas that add up to the entire project area. Please revise Section IV, 9 & 10
to account for this..
Section IV, 9 & 10 have been updated with two drainage areas.
As mentioned above, for low -density projects, the "drainage area" listed in the table
in Section IV, 10 refers to the entire project area (or portion of the entire project area
for projects that drain to multiple receiving waters). Due to this fact, there should not
be an off -site component to the drainage area (since the drainage area corresponds to
the project area)..
Off -site drainage area has been removed.
6. Please include the existing BUA (if applicable) within the drainage area (project area)
in the table in Section IV, 10.
Not applicable.
7. The BUA associated with the proposed solar farm project should not be classified as
"Future" BUA since this BUA is what is currently being permitted (Section IV, 10).
"Future" BUA refers to BUA that will be built at some future time after the project to
be permitted is complete (for example, a Phase 2). The proposed BUA should be
broken down, as much as possible, into one of the predefined impervious area types
and should correspond to the information in the plans.
"Future" BUA incorrectly filled, has been removed.
Since there are no off -site components to a low -density drainage area, the off -site
impervious area determination is not required (Section IV, 11).
Application has been updated to state "No off -site drainage area is being considered
for post -construction."
9. Please complete and provide both a Supplement-EZ Form and an O&M Agreement
Form (Section V & Section VI, 3). Both of these forms can be found at the following
address: https:Hdeq.nc.gov/about/divisions/energy-mineral-land-resources/energy-
mineral-land-permit-guidance/stormwater-bmp-manual. Solar farms have additional
operation and maintenance requirements when compared to a "typical" low -density
project. These requirements are outlined in Part E-6 of the Stormwater Design
Manual and can be incorporated into the O&M Agreement Form via a "User Defined
SCM" (see attached example from a different solar farm project).
Both forms have been provided with this resubmittal.
10. Please provide a detailed narrative describing the stormwater treatment that will be
used on this site (Section VI, 5). This is typically provided in a stormwater
39845 Mathews Lane Paonia, CO 81428
970-527-3920 1 [e-mail] I www.seisolarpros.com

management report and would describe what is being done to meet the stormwater
requirements (both low -density requirements and solar farm specific requirements)
Please see sheet CO.1.
11. Please provide project density calculations for this project (Section VI, 7).
Please see sheet C4.0 for project density calculations.
12. Please dimension the extents of the project area using bearings and distances in the
main set of plans (Section VI, 8i). This is needed in order to determine the extent of
the permit coverage area.
Please see sheet C3.0 for bearing and distance of the limits of construction which was
used to determine the project area of approximately 15.8 acres.
13. Please delineate the on -site wetlands in the main set of plans or provide a note in the
plans that there are no wetlands located on -site (Section VI, 8m). Please also identify
the individual that made this determination.
There are no wetland on -site of the project per USACE Brandee C. Boggs.
Supporting documentation submitted.
14. Please indicate the drainage area divide (differentiating between the portion of the
project area that drains to the French Broad River and Spring Creek) for this project
in the main set of plans (Section VI, 8o).
Please see sheet C3.1 for drainage area divide.
15. Please provide the property deed for this property (Section VI, 10).
Document provided by EPC Contractor and included in this submittal.
16. Please provide official documentation showing the title and position of Frankie
Jenkins and that the Property Owner, Madison Manufacturing Company, is in good
standing with the Secretary of State (Section VI, 11).
Document provided by EPC Contractor and included in this submittal.
17. In order for the solar panel areas to be considered as pervious area, all of the items
listed in Part E-6 of the Stormwater Design Manual must be met:
E-6 recommendations have been added to the stormwater narrative. Please see sheet
C0.1
a. Avoid Compaction of Soils — A note should be placed in the plans/sequence
of construction indicating that subsoil compaction is to be minimized during
& after construction.
b. Disconnect Runoff — Please indicate in the plans that the disconnection length
between rows of solar panels is sufficiently large (It appears as though it is).
Since most of this site contains slopes that are steeper than 8%, you will need
39845 Mathews Lane Paonia, CO 81428
970-527-3920 1 [e-mail] I www.seisolarpros.com

to provide some manner of maintaining sheet flow and for dissipating energy
at the drip edge of each row of panels.
c. Avoid Concentration of Stormwater — This appears to be met per the plans but
should be discussed in the stormwater narrative.
d. Minimize Use of Herbicides & Fertilizers — This will be covered in the O&M
Agreement but can also be included on the plans.
e. Plant Mix of Warm & Cool Season Grasses — Please ensure that the proposed
grass contains a mixture of warm and cool season grasses.
f. Limit Vertical Clearance to <= 10 Feet — Please indicate this on the plans.
This can be shown on a solar panel detail.
18. Provide pdfs of all revisions, 2 hardcopies of revised plan sheets, 1 hardcopy of other
documents, and a response to comments letter briefly describing how the comments
have been addressed.
a. a. Pdfs must be uploaded using the form at:
https:Hedocs.deq.nc.gov/Forms/SW-Supplemental-Upload
Very Respectfully,
W ir?� ��— —
Jeff Ruppert, P.E.
Principal
39845 Mathews Lane Paonia, CO 81428
970-527-3920 1 [e-mail] I www.seisolarpros.com