Provided atthe mertung 7.A. ID.  9/18/24 Tami St. Germain  636 Gurley Drive Norwood, CO 81423 970/708-8600 September 18, 2024  To: San Miguel County Board of County Commissioners  Irespectfully offer the following comments and submission to the agenda for the San Miguel County (SMC) Board of County Commissioners (BOCC) meeting to discuss adoption of the Amendment to the SMC Land Use Code (LUC)under. Article 6 Natural Resources - Solar Energy  Systems  GENERAL COMMENTS  A. Discrepancies in the zone map language  Inr reviewing the SMC. Advanced Viewer ARCGIS mapping tool available at Advanced Viewer] San Miguel County CO, it has come to my attention that there are some discrepancies (or perhaps my own confusion) about the zone districts and/or terminology used toi identify various zones.  The current draft regulations include the following: LLarge-Scale Solar Energy Systems a. Forestry,Agriculure, and Open b. Heavy Commercial C. Low Intensity Industrial (not on zoning maps) d. Public (Telluride and Norwood) e.V West End II. Medium-Scale Solar Energy Systems a. Forestry, Agriculture and Open (Telluride) b. Heavy Commercial (Telluride and Norwood) c.Low) Intensity Industrial (not on zoning maps) d. Public (Telluride) e. Wright's Mesa Light Industrial f.V Wright'sl Mesa Rural Agriculture g. West End g. Community Housing  Low. Intensity. Industrial is not on1 the 2018 zoning map (Document Center . San Miguel County, CO-CivicEngage smmiguelcoumoycsoy) or on the Advanced Viewer under "County Zoning". However, there is a layer on the Advanced Viewer titled "Future Wright's Mesa", under which there are areas in Norwood identified as Wright's Mesa. Light Industrial. Is this the same as "Low Intensity Industrial"? Ifnot, where on the zoning map is Low Intensity Industria!?    B. Community-based siting and size  I'vel heard many voice the opinion that large-scale should be permitted in the West End. There are many public comment letters appended to the agenda packet for today's meeting that include such language. I've heard many make this statement, but so far, no residents oft the West End. Perhaps they have been making comments, Id don'tknow. But iti is not the general consensus; ;Icompletely disagree with this opinion. Ifyou' re not from an area, I don't think you need to be making comments that could adversely affect that area. Let them speak for themselves. Ihighly recommend either noti including the West End on large-scale, or get more input from the residents oft the West End. As it stands, it doesn't seem that the West End has been given much voice. I know there was one meeting in Egnar, butI I don't know how much other outreach has been done in Ibelieve that if we truly want to be locally and globally responsible, communities should take on the burden of managing for their energy consumption and doing their part to meet county/satehationwide goals. Ialso believe that a solar facility ought to fit the community in Iattended the Solar Happy Hour hosted by EcoAction Partners, on August 29, and based on some oftheir data, I've worked up a chart ofs solar facility size (acreage) that would: fit the communities ofSMC. According to information presented in that meeting, the entirety of SMC energy solar needs could be met on 300-400 acres. Consulting the US Census data for population centers in the  the zone district.  population and energy consumption.  county, the break down looks like this:  Table 1.Solar facility acreage needs per community in San Miguel County.  CENSUS CENTERS San Miguel County acre/individual Telluride Mountain Village Norwood  POPULATION POWER ACREAGE NEEDED  NEEDED*  8072  300-400 acres (per EcoAction (August 29,  2024 Solar Happy Hour 96.45-1 130.35 46.77-63.2 19.8-26.75 Elder property = 13 County 13.4-18.1 7.29-9.85 2.70-3.65 1.41-1.9 187.81-253.80 110.85-149.80  Using a simple division of population into acreage needed, yields a factor of0.037-0.05  2607 1264 535  Gravel mine =3 30i in SMC; 60 in Montrose  Placerville Ophir Egnar Sawpit subtotal Remaining unincorporated or dispersed population community.  362 197 73 38 5076 2996  *Calculations and acreage needs would need to include data regarding power needed per  2  s6pepra    This is a very simplistic chart, buti it provides a general idea of! how much SMC needs. Split That said, I want to reiterate that siting of solar facilities should prioritize previously impacted areas. Our natural areas are too precious to exploit and squander for the industry profit. There'sa need toi identify optimum siting. Ifwe're going to be responsible for our own power, and its seems that micro-grids have been mentioned and there seems tol be some agreement that this would be a good way to go, then Ii introduce a couple examples. EMPHASIS ON EXAMPLE. Iam not saying this is where toj put anything, but these are examples of previously impacted sites that would incur no additional impact or might even improve ifused for a solar facility, and they Inl Norwood, there are a couple tracts that have been severely degraded and represent ideal examples of area that would be excellent candidates for solar facilities. 1)The property adjacent to the SMC transfer station (-13 acres) used to be a salvage yard. The land is already impacted and is next to an existing solar array. 2)According to the Advanced Viewer, there is a SMC-owned parcel at the top ofl Norwood Hill that appears to be part ofa gravel mine. Using google Earth, the mine Again, I am not speaking for the landowners and there's al lot that goes into leasing properties, but these parcels present features that make them ideal for development such as solar. The retired Nucla electric plant would also be a great site. The infrastructure is already there. C. Global responsibility, natural capital and ecosystem services  amongst the communities, the acreage figures are not SO onerous.  encompass enough acreage as identified in the chart above.  appears to be about 30 acres in SMC, and about 60 in Montrose. COUNTY  During the August 29 Solar Happy Hour, a comment was made that as global citizens, SMC needs to do its part ini this global crisis and we can do so by exporting electricity. Whilel I understand the intent and spirit oft that comment, I want toj point out that SMC does contribute to the global community. Not only do we export consumables such as agricultural products, but we provide extraordinary benefit ini non-consumables through our eco-tourist industry, including hunting, fishing, camping and other outdoors pursuits, not to mention the winter sports economy. But beyond that, our most valuable export is in our natural resources. Natural resources around the planet provide ecosystem services-1 by contributing to clean air, clean water, soils biome and productivity, as well as carbon sequestration. In their natural state these open areas provide natural The fact that the Review Criteria (Sections 6-204 and 6-206) in the draft regs include reclamation, implies that the land has an inherent value as it is and that once the project is done, we want to reclaim the value of the land. If wel know there is inherent value in an area, why would we: first allow it to be destroyed only to attempt--30-40: years down the road- to "reclaim" it? So, in the gesture to "reclaim" is admission of the values lost, readily traded via policy and platform fora temporary alleged gain. It's highly questionable as to who is gaining, when you think of the front- end environmental costs of resource extraction, the direct costs ofhabitat loss from infrastructure, and the current end-game strategy, or lack thereof, as how to deal with the wastes. It's hardly green. But I digress. And I realize that there has been language added to the draft regs that prioritizes previously impacted areas, and I do thank the BOCC and P&Z for listening to me repeat We will not regret preserving the natural resources of SMC. We will not regret being "THAT COUNTY" that implements regs that ensure the residents that live here, the countless visitors who  capital.  myselft these many times.  SiGman 4109124  3    enjoy them, and the global community that gains from our resources can continue to benefit from  these resources.  SPECIFIC COMMENTS TOT THE DRAFT REGULATIONS Begin comments on the September 18, 2024, draft solar regulations: more of] land. Why isn't there a cap on large-scale systems? 6-202 D. Waiver of application materials.  Below are passages from the draft regulations. Editorial marks are in red. Comments are in blue. Large-scale - A Solar Energy System consisting of solar arrays occupying thirty (30) acres or  This section gives the Planning Director power of determining the relevance of application materials and also for making the decision to waive the materials. Such actions should not be the sole decision ofa single person. There should be a decision between the Planning Department  consented to by at least one member of the BOCC.  6-203 J. Terrestrial Plants Impact Assessment and Mitigation  II. a. Changes to habitat of reiemstorendangeirpeieefeemsem-plant species listed as threatened or endangered under the Endangered Species Act, listed on the Rare Plant List from the Colorado Natural Heritage Program, or otherwise listed as species of concern 6-203 O. Visual Quality Impact Assessment I. Map and description of the existing scenic rural landscape within a minimum of one (1) mile ofthe outer perimeter of the Large-Scale Solar The one-mile distance seems arbitrary. The distance ought to be determined by the topography and landscape; impacts beyond one mile ought to be considered where topography allows aj project to be seen more than a mile away. This is also inconsistent with the visual distance requirement of5 miles under the Telluride R-1 School District LUC 5-2102. ..no portion of any structure shall be allowed to extend above any ridgeline such that the subject development could be viewed from  by a federal or state agency.  Development...  five miles away..."  Section 6-204 Review Criteria for Large-Scale Solar Energy Systems  The following review criteria apply to the review of a permit application for Large Scale Solar Development. The County shall take into account the impacts of construction, operation,  decommissioning and reclamation,... 6-204 C. Site Design Review Criteria  II. Setbacks. Fencing or other enclosures, solar panels, equipment, and structures shall be set back an minimum oftwo-hundred (200) feet from all property lines and one quarter (VA) mile from a Colorado designated Scenic Byway. Setbacks may be increased or decreased during the review and evaluation of the application. Criteria should not allow for reducing setbacks, or the rationale for  reducing setbacks needs to be elaborated.  5) Gepmmi slela4  4    6-204 O. Noise, Dust, Fumes, Vibration, and Odor  6-204 P. Glare and Glint birds, wildlife, or persons.  The Large-Scale Solar Development will not : create an unreasonable attractive nuisance for "Unreasonable attractive" is a subjective term. Howi is this measured or determined? Ift these items are the responsibility oft the applicant, then does the review process assess validity oft the data? Section 6-205Application Materials for Medium-Scale Solar Energy Systems The application shall include, at a minimum, the information and materials specified ini this Section 6-205 and shall address beth the construction,and operation, decommissioning and  reclamation oft the :  6-205 D. Property Rights, Permits, and Approvals  IV. Copies of any draft or final environmental assessments or impact statements prepared for the  Medium-Scale Solar Development. 6-206 N. Glare and Glint birds, wildlife, or persons.  6-206 M. Noise, Dust, Fumes, Vibration, and Odor  thel Medium-Scale Solar Development will not create an unreasonable attractive nuisance for "Unreasonable attractive" is a subjective term. How is this measured or determined? Ift these items are the responsibility oft the applicant then does the review process assess validity ofthe  data?  Thank you for considering these comments.  SHbmmain 916a4