Solar Development on Resource Lands
1000 Friends' Farmers Advisory Committee weighs in
Below is the text of our letter to the Land Conservation and Development Commission
Dear Honorable Commissioners:
The Farmers Advisory Committee (FAC) was formed to assist 1000 Friends of Oregon in protecting, implementing and improving Oregon’s program for maintaining the agricultural land base needed for farming and ranching. The FAC is composed of commercial farmers and ranchers, and farm organization leaders. The FAC members come from all of Oregon’s agricultural regions and produce a wide variety of farm products.
In recent years, certain parts of Oregon have seen an uptick in land use applications for large-scale solar facilities on farm or rangeland. The proposed solar facilities have ranged in size from 12-acre to 300-acre facilities. In some cases, approvals are sought for multiple facilities at once, to be located on adjacent properties or in close proximity to each other. The FAC is concerned about the impacts of increasing solar development on Oregon’s agricultural lands and farm economies, and in particular, the impacts to high-value farmland.
1000 Friends of Oregon and the FAC support development of energy from non-fossil fuel sources, including wind and solar facilities. However, all energy facilities, including those for renewable energy sources, have distinct siting challenges that need to be balanced with other needs and values, including conservation of working farm and forest lands, natural resources, and wildlife habitat. Large-scale solar facilities can extend over large swaths of land, blocking or restricting sun and water, impacting the vegetation and soil beneath, restricting wildlife migration and fragmenting habitat. The increase in large-scale solar arrays on farmland can also have economic impacts on surrounding farm economies, as they can fragment available and contiguous farm and ranchland and impact land values.
Solar development should be sited at or near the point of use or within the built environment, such as on existing industrial sites and otherwise unusable space. The EPA and the American Planning Association encourage development of solar on targeted sites including brownfields, Superfund sites, RCRA sites, mining sites, landfills, abandoned parcels, parking lots and commercial/industrial rooftops, instead of on farmland and greenspace.
Oregon’s rules governing solar development should encourage and even direct solar development away from productive farmland and ranchland and towards already-impacted or otherwise unusable and undevelopable land. The current rules do not achieve that goal and are not sufficiently protective of Oregon’s productive farmland. The FAC encourages LCDC to consider amending the existing rules to allow for continued solar development in a way that minimizes conflicts with farming and protects Oregon most productive farmlands and habitats.
The FAC requests that LCDC consider the following specific changes to the existing rules:
- Require a cumulative impacts analysis for each proposed solar array proposed to determine whether that project, in combination with other nonfarm usesalready approved in the vicinity, has or will cumulatively impact the sustainability of the farm economy and the overall agricultural land base.
- Require an alternatives analysis so the applicant must show that other non-resource lands were considered and that this is the best alternative and has least impact on farmland. Cost cannot be the only consideration in why an alternative is selected.
- Reduce the amount of acreage permitted on high-value farmland to five acres unless an exception is taken, and require that if solar is to be conducted on high value farmland parcel, it can only be built as an accessory and subordinate use to active farming occurring on that parcel or tract and the energy generated is to be used onsite. Clarify and strengthen language so solar developments larger than statutory acreage limitations are actually prohibited without exception (current language allows for wiggle room: “not precluded from use as a commercial agricultural enterprise”).
- Require a bond to ensure adequate clean up and complete restoration of the site if the solar operation is terminated. Require cleanup and restoration as conditions of approval in any permit. The impacted land should be restored to has equal or better agricultural production capability than before construction of the array.
The Farmers Advisory Committee and 1000 Friends of Oregon are willing to participate in a working group or advisory committee on this issue and recommend that such working group be formed and include membership from the farming and ranching community and other farm-related entities, including the Department of Agriculture and the Soil and Water Conservation districts.
Thank you for your consideration.
 For an overview, see Union of Concerned Scientists, Environmental Impacts of Solar Power, http://www.ucsusa.org/clean_energy/our-energy-choices/renewable-energy/e.... See also, The Guardian, Solar is Booming but Solar Parks Could Have Unintended Climate Consequences, http://www.theguardian.com/sustainable-business/solar-power-parks-impact....
 See EPA Decision Tree for Siting Solar, http://www.epa.gov/renewableenergyland/docs/solar_decision_tree.pdf; and Recycling Land For Solar Energy Development, American Planning Association, www.planning.org/research/solar.
Photo: Tanner Creek Energy Solar Project on Winery