Aurora Distributed Solar, LLC. Solar Energy Project. Lake Pulaski IP6928/GS Date of Submission: REVISED March 2, 2016

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1 Permittee: Permit Type: Project ocation (acility) : ocket o: Permit Section: urora istributed Solar, Solar nergy Project ake Pulaski IP698/S-4-55 Site Permit Section 6. Site Plan ate of Submission: RVIS arch, 06 urora istributed Solar, ( urora ) respectfully submits this filing in compliance with Section 6. of the Site Permit. t least fourteen (4) days prior to the pre-construction meeting for each acility, the Permittee shall submit to the ommission: (a) a ready-for-construction site plan for each solar site acility to include the solar panel layouts, access roads, electrical equipment, collector and feeder lines, and other associated facilities to be constructed; (b) engineering drawings for site preparation and construction of each of the acilities; (c) a landscaping plan that describes adjacent land uses and identifies any site-specific strategies to minimize the visual impact of the acility to adjacent land uses; and (d) plans for restoration of the acility following construction. onstruction is defined under innesota Statutes, section 6.0, subdivision. The Permittee may submit a site plan and engineering drawings for one or more acilities if the Permittee intends to commence construction on certain acilities before completing the site plan and engineering drawings for other acilities. The Permittee shall document, through IS mapping, compliance with the setbacks and The acilities listed in the Project ocation (acility) category above are those that are affected by this filing. acility names correspond to acility names as presented in the Site Permit issued to urora istributed Solar, on June 0, 05.

2 site layout restrictions required by this permit, including compliance with the noise standards pursuant to innesota Rules, chapter 700. The Permittee shall describe its considerations in determining the location of any fencing." urora efiled an Overall Site Plan, engineering drawings, a onstraints ap, and a site plan narrative in compliance with Section 6. on January 7, 06 and ebruary, 06 (eocket I. os and ). urora has since revised the same to respond to comments from the innesota epartment of ommerce nvironmental Review and nalysis department. urora submits with this cover sheet: revised Overall Site Plan for the solar panel layouts, access roads, electrical equipment, collector and feeder lines and other associated facilities to be constructed at the abovementioned facility; Revised engineering drawings for the above-mentioned facility; revised onstraints ap demonstrating compliance with the setbacks and site layout restrictions required by the Site Permit, including compliance with the noise standards pursuant to innesota Rules, hapter 700. revised site plan narrative demonstrating full compliance with the requirements of the Site Permit as to this facility. plan for restoration of this site is part of urora s Stormwater Pollution Prevention Plan, which has been filed in response to Section 8.4 of the Site Permit.

3 SIT P RRTIV ontext On June 0, 05, the innesota Public Utilities ommission (the ommission) issued urora istributed Solar, (urora) a Site Permit to construct a distributed solar energy project. Since the issuance of the Site Permit, urora has continued to refine its plans, including the selection of equipment and design of the facilities. The ake Pulaski acility will be operated and maintained by urora through urora s wholly owned subsidiary ake Pulaski Solar,. urora has provided maps, diagrams, and this memorandum in compliance with the ommission s Site Permit Sections 6. (a) through (d) for the ake Pulaski acility; the maps and diagrams are referenced throughout this document. urora provides this memorandum to discuss the ake Pulaski acility s final design, the final design s overall human and environmental impacts, and the construction methods. dditional plans addressing restoration of the facility are provided in the compliance filings associated with Sections 6.4, 6.5, and 8.4 of the Site Permit. This memorandum takes into account the impacts evaluated by urora in application for a Site Permit, the innesota epartment of ommerce in their nvironmental ssessment (), and the ommission s Site Permit and associated indings of act supporting its permit decision. The ake Pulaski acility has not changed its location, facility land control or size from what was evaluated in urora s Site Permit pplication, and in the ommission s Permit. The facility development area 4 has been increased due to additional visual impact mitigation that has been added along the northeastern and eastern portions of the facility boundary to address neighboring landowner concerns. Table summarizes facility acreage and size. Table summarizes facility acreage and size. Table. rea and apacity of the ake Pulaski acility ake Pulaski acility and evelopment W- acility ontrol rea valuated for nvironmental Impacts 75.8 acres 6. acres 8.5 acility and ontrol is defined as the total area of land either owned or leased by urora for the facility acility size is defined as the facility nameplate capacity in megawatts (W) alternating current (). 4 evelopment rea is defined as the total area of land disturbed by the facility construction including any grading, tree removal or trimming, access improvements, etc.

4 Site Plan arrative Page of 6 ake Pulaski acility acility and ontrol evelopment rea urrent esign 75.8 acres 68 acres (final development area) W- 8.5 Summary of inal esign Refinements Selected quipment The ake Pulaski acility s onstraint Site Plan offers a visual depiction of the facility s design refinements. The onstruction etails provide technical drawings for the equipment. urora plans to install a single axis tracking system at the site with three inverter skids, a collection system, and a small metering and switching system. Solar rrays The solar array consists of photovoltaic modules mounted upon a tracker racking system. The specifications of the solar array comply with the Site Permit and are consistent with the environmental review. odules The modules will be polycrystalline with a silver border and a dark, sun absorbing surface with an antireflective coating. They will be 6.4 feet by. feet and designed to be installed in a landscape orientation. The array will follow the sun path in a single, horizontal axis from 45 degrees east in the morning to 45 degrees west in the evening with the maximum height of approximately 0 feet at a 45 degree tilt. Racking urora selected a tracker racking system with individual motors for each tracker row allowing more flexibility. The racking will allow for panels in a column resulting in the rotational plane of panels being just less than 0 feet in length. The racking system will have 4 rows of panels on the north south axis (the non-tracking axis) resulting in a total length of approximately 55 feet per rack or row. ach rack or row will have a drive shaft with a motor located central to the row that will slowly turn the three panel plane from east to west. The racking system will be mounted to the ground through piles driven approximately feet into the ground, the piles will have a 6 ½ foot reveal upon which the mounting bracket and drive shaft will be installed. Rows of tracking panel racks will typically be installed at 5 ½ foot intervals east to west and 0 feet north to south with some variations to accommodate topography, landscape features or other project components. Inverters Inverters will be installed on a cement pad or cement pier foundation system that will be determined based on the observations of the hydrological conditions at the inverter location. The

5 Site Plan arrative Page of 6 inverters will be contained within a neutral earth tone low gloss or semi-matte painted metal enclosure with a standard service door. The inverters will be 0 feet long, feet wide and feet tall. They will have an external cooling fan that will generate a maximum of 85 d() at a distance of meter. motion-activated, downward facing exterior light will be mounted on the inverter housing. The exterior light will be mounted approximately two feet above the inverter housing s entrance door. The inverter housing, because of its enclosed nature, will also serve as the operations and maintenance area for the facility. epending on final installation and site grade there may be a set of stairs to access the service door to the enclosure. In addition to the inverters, a S System nclosure will be installed between the inverter closest to the Point of Interconnection and the Point of Interconnection itself. The enclosure will be a neutral earth tone low gloss or semi-matte painted metal enclosure with a standard service door. The enclosure will be approximately ten feet wide by ten feet long and ten feet in height. The height of the S enclosure, including foundation, will not exceed feet above the finished ground surface. The enclosure will house the project s communication equipment, a heating and cooling system and other basic equipment required for the S system. The sound emitted from the enclosure will be limited to that which will be produced by the standard, small heating and cooling system. lectrical ollection and eeder System The electrical collection and feeder system will be predominantly underground connecting module rows to each other and to the inverters. There will be an underground feeder line running from the inverters to close to the point of interconnection where urora will mount electrical switching and metering equipment needed to meet Xcel nergy s interconnection requirements. ence The security fence surrounding the facility will consist of up to seven feet of chain link, agricultural fence attached to wooden posts topped by a one to two foot extension of monofilament cable tilted 45 degrees outward from the vertical plane of the agricultural fence portion. The agricultural fence will consist of a square or rectangular grid of woven wire. gap, approximately 7 in height, will be left open between the ground and the agricultural fence sections to allow for movement of smaller animal species into and out of the site 5. There will be gates; one gate (approximately sixteen to twenty feet wide) designed to allow vehicle entrance to the site and gate (approximately three feet wide) allowing pedestrian entrance and exit. Though not intended for regular use, the pedestrian gate will also provide emergency access in the event that the vehicle gate is inaccessible or nonfunctional. One downward facing security light mounted on a ten foot pole will be located near the vehicle entrance gate. The lighting will be used on a minimal basis for maintenance activities and security reasons. The lighting will have the ability to be activated manually or automatically by the security system. 5 R comment letter submitted on /8/05

6 Site Plan arrative Page 4 of 6 ayout The final design at the ake Pulaski acility has been modified from that which was shown in the map accompanying the Site Permit. Since the submittal of the site permit application, urora has procured more proficient panels and trackers that hold more panels per row. With the selection of a more improved inverter only inverters will be needed for the facility compared to the 8 shown in the site application drawings. With this decrease in the number of inverters the length of the access road is reduced lessening the amount of impervious road surface impacts. The changes employed from the preliminary design resulted in a shift of the panels in the solar array area allowing for less disturbance to the field delineated wetlands and provided an increase in the setback to aken venue. This increased setback allowed urora to accommodate a berm for visual screening and minimize aesthetic impacts to the nearby residences. The final design avoids placing panels and other infrastructure on areas where significant cut and fill grading would be required for use with solar panels. reating gaps in the panel array to avoid these areas results in less invasive grading activities that will help to avoid irretrievable impacts to the agricultural soils. The final design refinements allowed urora to reduce the impacts to the human and natural environment. The visual impact of the facility is reduced because of the addition of a berm and landscaping. oise impacts will be reduced as the number of inverters for the final design () is less than what is in the preliminary design (). temporary laydown area was added within the development area to accommodate construction activity. The access road in the solar facility was improved to allow access to inverters and solar panels yet keep impervious surface to a minimum. The layout of the ake Pulaski acility was reviewed for compliance with local shore land ordinances 6 and the minimum shore land standards established by the innesota epartment of atural Resources 7. Wright ounty has adopted the minimum standard for the structure setback that would apply to ake Washington for the natural ordinary high water (OW) for natural environment lake (00 feet). 8 s shown on the onstraints Site Plan the facility is located well outside of the 00 foot structure setback from the natural ordinary high water for the Washington atural nvironment ake. ased on the OW, this waterbody is located over 500 feet east of the proposed ake Pulaski Solar facility. The ake Pulaski acility complies with both the local shore land ordinances and the minimum statewide shore land standards. 6 Wright ounty s Shore land Ordinance can be accessed at the following website: (accessed on January 6, 06) 7 Statewide Shore land anagement Standards can be accessed at the following website: (accessed on October, 05) 8 Wright ounty s Shore land Ordinance Section 6.5()c it can be accessed at the following website: (accessed on January, 06)

7 Site Plan arrative Page 5 of 6 andscaping djacent and Uses and xisting Topography and cover within the immediate area of the ake Pulaski acility is dominated by cultivated crops (87 percent). The proposed facility is a cultivated parcel within a rural area. The facility avoids the developed area of uffalo to the west and the lakes to the east. The nearest homes are located northwest of the proposed facility approximately 0 feet east and 40 feet northeast of the development area. berm and landscaping will provide a buffer and visual screening along aken venue. Planned andscaping The seeding plan for the facility includes planting a no mow turf with forbs under the array and between rows of panels. Open areas inside the fenced portion of the facility, that portion of the facility site control area outside of the fenced area that had previously been farmed, and the landscaping berm will be seeded with a mixture of grasses and forbs (Prairie Seed) for soil stabilization. aintenance will include intermittent haying (or mowing provided minimum blade heights are established and the cut biomass is bagged). The seed mixes have been selected through ongoing collaboration with the innesota epartment of atural Resources. To mitigate visual impacts along aken venue and the nearby residences, a berm was added running from the southeastern to the northeastern portion of the site. s depicted on the Seeding and landscape plan, the berm will be planted with a combination of deciduous and evergreen plant and trees to provide a natural buffer and further mitigate the visual impacts of the site. The berm will also be seeded with the Prairie Seed mix as discussed above. 4 onsistency with nvironmental Review The information that follows documents consistency with and changes to the environmental information provided in the, the ommission s Site Permit process, and the ommission s indings of act supporting its permit decision for the ake Pulaski acility. If a category is not addressed herein, it can be assumed there is no change to the impact discussed in the record developed for the Site Permit. The equipment-associated footprint of the ake Pulaski acility has been refined than what was proposed in the initial design. s a result, the impacts are generally equal to or less than those discussed in the Site Permit pplication and the. The following topics are of note when considering the design refinements at the ake Pulaski acility: Solar panels have been setback back along aken venue and a berm has been added to reduce visual impacts.

8 Site Plan arrative Page 6 of 6 andscape Plan has been developed to reduce the visual impacts to the residences east and northeast of the facility, mature shrubs will be planted and provide a visual screening from the solar array and will be maintained throughout the life the project. berm was also added running from the southeastern to the northeastern portion of the site. s depicted on the Seeding and landscape plan, the berm will be planted with a combination of deciduous and evergreen plant and trees to provide a natural buffer and further mitigate the visual impacts of the site. n gricultural Impact itigation Plan has been developed in cooperation with the epartment of griculture and will be carried out during the life of the project to minimize impacts on soil for future agricultural use. The facility requires some grading to provide a level surface for the solar arrays and to install a berm along the eastern and northeastern portion of the developed area. The preliminary design for the facility anticipated grading of approximately 6.8 acres of the site during construction. ecause of the optimization of the design and the avoidance of steeper slope areas; the amount of grading is now expected to be closer to 6. acres based on the final design, even with the addition of the berm. The facility will be re-vegetated with low-growing species, as shown on the Seeding Plan. The seed mixes used to re-vegetate the facility once construction is complete are anticipated to provide better quality habitat and soil-building conditions than cultivated crops. o rare or unique natural resources were identified in the field surveys of the facility making the impacts similar to less than those described in the Site Permit pplication. The initial design presented in the included 0.4 acres of wetland impacts. These impacts have been permitted and mitigation has been accomplished. owever, the internal access roads and solar panel layout has been shifted to further minimize impacts to wetland areas within the project area. The final design of the facility meets the local shore land ordinances and the minimum shore land standards established by the innesota epartment of atural Resources. s shown on the onstraints Site Plan, the distance between the nearest home and the development area is 0 feet; in the Site Permit pplication the nearest home was 79 feet from the edge of the solar array. The addition of the landscaping berm will adequately mitigate visual impacts to that residence.

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