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PA 1300027(SA) & PA 1300066 ( .,) Solar-Use Easement January 31, 2013 Page 3 of 5 4. A recent soils test demonstrating that the characteristics of the soil significantly reduce its agricultural productivity. It is not the characteristics of the soils, but the topography of the site that limits it from being utilized like the surrounding area (orchards). The Department does not consider soil testing to be necessary to support this finding since rescission of the contact is based on the site having physical limitations. 5. An analysis of water availability demonstrating the insufficiency of water supplies for continued agricultural production. Water availability is not an issue as there are almond orchards planted on the same contract parcels. It is the topography of the site that limits it from being utilized like the surrounding area, resulting in access and drainage issues. The Department does not consider the insufficiency of water availability to be a determining r iaCtor in the rescission Of the Coltract since 'the fVllJ is on 'the Site having topographical Opugraphical pySilaf limitations. 6. An analysis of water quality demonstrating that continued agricultural production would under the best currently available management practices, be significantly reduced. Water quality is not the issue. It is the topography of the site that limits it from being utilized like the surrounding area (orchards), resulting in access and drainage issues. The Department does not consider water quality to be a determining factor in the rescission of the contract since the focus is on the site having topographical physical limitations. 7. Crop & yield Information for the past six years. The site has historically been used as grazing land. The area surrounding the portions of the site with topographic issues has recently been planted as an almond orchard. The almond orchard is relatively new and was recently harvested for the first time. Almond yields have not been determined, but the orchard areas are not proposed for rescission. Due to the historic use of the proposed project sites as grazing land, there is no crop yield information available. The Department does not consider this section to be applicable. 8. A management plan describing how the soil will be managed during the life of the easement, how impacts to adjacent agricultural operations will be minimized, how the land will be restored to its previous general condition, as it existed at the time of project approval, upon termination of the easement. During construction of the facility, no removal of on-site soils is expected. Each solar panel will sit atop a pile that is driven into the soil. The petition states that due to the small diameter of the piles, these construction activities are expected to have little impact on the existing soils conditions. Construction activities in the project areas include the clearing of weeds and grasses. Routine maintenance of the soil during the life of the easement would include clearing weeds and grasses by a line-fed trimmer or weed control sprays. The petition states that due to the fact that ground disturbance is so minimal; no erosion control plan is deemed necessary. Once the lease has expired and the project ends, the petition states that the removal activities will have little impact on the soils. The Department notes that there is no mention of decommissioning activities that include review of soils conditions or reseeding of the site if necessary. There is also some concern regarding the fact that there are topographic issues, but there is no erosion control plan associated with the soil management plan. The Department suggests that the County consider the possibility of soil erosion issues during the life of the project, an overview of revegetation of the site (if necessary) during decommissioning activities, and that this be addressed in the soil management plan prior to approval of the solar-use easement.