Loading...
HomeMy WebLinkAbout1.00 General Application Materials_Part1 Wheeler Gulch Solar Project Prepared for: Prepared by: February 2023 Wheeler Gulch Solar – Executive Summary This page intentionally left blank. Wheeler Gulch Solar Project 1 Contents Pre-Application Conference Summary ................................................................................... 4 Application Form ....................................................................................................................10 Authorization Letters ..............................................................................................................13 Ownership Information – 4-203.B.a .......................................................................................18 Property Owners Within 200 feet And Mineral Owners and Lessees – 4-203.B.b ..............36 Mineral Interest owners – 4-203.B.c .......................................................................................37 Adjacent Property Owners Map- 4-203.B.d ...........................................................................40 Property Description – 4-203.B.e ...........................................................................................42 Vicinity Map – 4-203.C ............................................................................................................47 Site Plan – 4-203.D ..................................................................................................................50 Grading And Drainage Plan – 4-203.E ...................................................................................60 Landscape Plan – 4-203.F .......................................................................................................64 Impact Analysis – 4-203.G ......................................................................................................65 Traffic Study – 4-203.L ............................................................................................................72 Water Supply & Distribution Plan – 4-203.M .........................................................................79 Wastewater Management System Plan – 4-203.N .................................................................81 Floodplain Analysis – 4-203.O ...............................................................................................83 Decommissioning Plan -4-203.P .......................................................................................... 103 General Approval Standards – Article 7, Divisions 1, 2 & 3 and 7-1101 ............................ 104 Division 1. General Approval Standards ............................................................................. 104 7-101. Zone District Use Regulations ............................................................................... 104 7-102. Comprehensive Plan and Intergovernmental Agreements .................................... 104 7-103. Compatibility ......................................................................................................... 104 7-104. Source of Water .................................................................................................... 104 7-105. Central Water Distribution and Wastewater Systems ............................................ 104 7-106. Public Utilities ....................................................................................................... 104 7-107. Access and Roadways .......................................................................................... 105 7-108. Use of Land Subject to Natural Hazards ............................................................... 105 7-109: Fire Protection:...................................................................................................... 105 Division 2. General Resource Protection Standards .......................................................... 106 7-201. Agricultural Lands ................................................................................................. 106 Wheeler Gulch Solar Project 2 7-202. Wildlife Habitat Areas ............................................................................................ 106 7-203. Protection of Waterbodies ..................................................................................... 107 7-204. Drainage and Erosion ........................................................................................... 107 7-205. Environmental Quality ........................................................................................... 107 7-206. Wildfire Hazards .................................................................................................... 107 7-207. Natural and Geologic Hazards .............................................................................. 108 7-208. Reclamation .......................................................................................................... 108 Division 3. Site Planning and Development Standards ...................................................... 109 7-301. Compatible Design ................................................................................................ 109 7-302. Off-Street Parking and Loading Standards ............................................................ 109 7-303. Landscaping Standards ........................................................................................ 109 7-304. Lighting Standards ................................................................................................ 110 7-305. Snow Storage Standards ...................................................................................... 110 7-306. Trail and Walkway Standards ................................................................................ 110 Division 10. Additional Standards of Industrial Uses ......................................................... 110 7-1101: Solar Energy Systems: ........................................................................................ 110 Appendices A- Site Plans – Full Size, Scalable Set B- Storm Water Management Permit C- Biological Resources Report D- Geotechnical Report E- Impervious Surface Memo F- Wetlands Delineation Report G- Vegetation Management Plan H- Phase I Environmental Assessment Report I- Glare Analysis J- Operation & Maintenance Plan K- Cultural Resources File Search & Review L- Decommissioning Plan Wheeler Gulch Solar Project 3 Application Team Applicant: Civil Engineer: Wheeler Gulch Solar LLC, Fusion Industries Jason Eckman, Surface Regulatory Lead Gary Coons – Electrical Engineer Manager 143 Diamond Ave. 205 NW 63rd Street, S. 170 Parachute, CO 81635 Oklahoma City, OK 73116 (O) 970-285-2656 (M) 405-919-6542 (M) 720-788-8710 gcoons@fusion-ind.com jeckman@caerusoilandgas.com Applicant’s Representatives for Permitting: Geotechnical Engineer: Lakeridge Resources, LLC Granite Engineering Group, Inc. Carol Loughlin – Owner Hai Ming Lim, P.E. (M) 206-375-6754 (O) 719-716-9009 cloughlin@lakeridgeresources.com ming.lim@granite-eng.com Fish Bay Resources Dana Zentz – President 2473 Tiger Ln. Richland, WA 99352 (M) 509-954-4103 dzentz@fishbayresources.com HDR Engineering, Inc. Environmental Specialist: Melinda Lee – Land Rights Specialist HDR Engineering, Inc. 1670 Broadway Ave. Suite 3400 Katherine Garufi, Environmental Denver, CO 80202 Remediation Lead Melinda.lee@hdrinc.com 1670 Broadway Ave. Suite 3400 (O) 320-524-8376 Denver, CO 80202 (M) 720-320-8022 Katherine.Garufi@hdrinc.com Land Owner: Wildlife Biologist: Caerus Oil & Gas HDR Engineering, Inc. Jason Eckman, Surface Regulatory Lead Nathan Jones, Senior Biologist 143 Diamond Ave. 1670 Broadway Ave. Suite 3400 Parachute, CO 81635 Denver, CO 80202 (O) 970-285-2656 Nathan.Jones@hdrinc.com (M) 720-788-8710 (O) 720-365-1234 jeckman@caerusoilandgas.com Wheeler Gulch Solar Project 4 Pre-Application Conference Summary Wheeler Gulch Solar Project 5 Wheeler Gulch Solar Project 6 Wheeler Gulch Solar Project 7 Wheeler Gulch Solar Project 8 Wheeler Gulch Solar Project 9 Wheeler Gulch Solar Project 10 Application Form Wheeler Gulch Solar Project 11 Wheeler Gulch Solar Project 12 Wheeler Gulch Solar Project 13 Authorization Letters Please see the following pages for the signed and notarized Authorization Letters. Wheeler Gulch Solar Project 14 Wheeler Gulch Solar Project 15 Wheeler Gulch Solar Project 16 Wheeler Gulch Solar Project 17 Wheeler Gulch Solar Project 18 Ownership Information – 4-203.B.a Please see the following pages showing the ownership for this project. Wheeler Gulch Solar Project 19 Wheeler Gulch Solar Project 20 Wheeler Gulch Solar Project 21 Wheeler Gulch Solar Project 22 Wheeler Gulch Solar Project 23 Wheeler Gulch Solar Project 24 Wheeler Gulch Solar Project 25 Wheeler Gulch Solar Project 26 Wheeler Gulch Solar Project 27 Wheeler Gulch Solar Project 28 Wheeler Gulch Solar Project 29 Wheeler Gulch Solar Project 30 Wheeler Gulch Solar Project 31 Wheeler Gulch Solar Project 32 Wheeler Gulch Solar Project 33 Wheeler Gulch Solar Project 34 Wheeler Gulch Solar Project 35 Wheeler Gulch Solar Project 36 Property Owners Within 200 feet And Mineral Owners and Lessees – 4-203.B.b Wheeler Gulch Solar Project 37 Mineral Interest owners – 4-203.B.c Wheeler Gulch Solar Project 38 Wheeler Gulch Solar Project 39 Wheeler Gulch Solar Project 40 Adjacent Property Owners Map- 4-203.B.d Wheeler Gulch Solar Project 41 Adjacent Property Owner Information: Wheeler Gulch Solar Project 42 Property Description – 4-203.B.e Please see the following pages that describe and show the property and Lease Agreement for Wheeler Gulch Solar for this project together with the description and drawings showing the access to be used and for the easement needed to interconnect the facility to the transmission line located on the overall property. Wheeler Gulch Solar Project 43 Wheeler Gulch Solar Project 44 Wheeler Gulch Solar Project 45 Wheeler Gulch Solar Project 46 Wheeler Gulch Solar Project 47 Vicinity Map – 4-203.C Please see the following pages for the Vicinity Map for the Wheeler Gulch Solar Project together with a Vicinity Map showing the location of the provisional small contractors yard. Wheeler Gulch Solar Project 48 Wheeler Gulch Solar Project 49 Provisional Small Contractor’s Yard - Vicinity Map: Wheeler Gulch Solar Project 50 Site Plan – 4-203.D Please see the following pages for the Wheeler Gulch Solar Site Plan Set including utility locations, topography and easements which meet the requirements of Section 4-203. D. See Appendix A for the full-size set of plans. Wheeler Gulch Solar Project 51 Wheeler Gulch Solar Project 52 Wheeler Gulch Solar Project 53 Wheeler Gulch Solar Project 54 Wheeler Gulch Solar Project 55 Wheeler Gulch Solar Project 56 Wheeler Gulch Solar Project 57 Wheeler Gulch Solar Project 58 Wheeler Gulch Solar Project 59 This page intentionally left blank. Wheeler Gulch Solar Project 60 Grading And Drainage Plan – 4-203.E Please see the following pages for the Wheeler Gulch Solar Grading and Drainage Plan. These plans address the requirements of Section 4-203.E as applicable and as detailed in the stormwater management memo in Appendix B and as in compliance with the current stormwater management Permit Number COR400000, Certification Number COR400643 See Appendix A for the full-size set of plans. Wheeler Gulch Solar Project 61 This page intentionally left blank. Wheeler Gulch Solar Project 62 Wheeler Gulch Solar Project 63 Wheeler Gulch Solar Project 64 Landscape Plan – 4-203.F Due to the lack of adjacent property owners with views to the Project Site and coupled with the Site’s arid natural setting and current zoning, the Wheeler Gulch Solar respectfully requests a Waiver on the Landscape Plan requirements described in Article 4-203. F. Wheeler Gulch Solar Project 65 Impact Analysis – 4-203.G Wheeler Gulch Solar – Project Overview Caerus Operating LLC through its wholly owned affiliates, Caerus Piceance LLC (together, Caerus) and Wheeler Gulch Solar LLC (Wheeler Gulch Solar) respectfully requests the Garfield Board of County Commissioners to accept this application and, after appropriate review, to grant a Limited Impact land use permit for the construction and operation of a photovoltaic (PV) solar power generating facility (the Project). The Project is located approximately 4.0 miles northwest of Parachute at 3696 County Rd. 215, Parachute, CO 81635. The project site will occupy 53.3 acres of the total 88-acre parcel identified as Parcel Number #217133100020 by the office of the Garfield County Assessor. The Project site parcel is zoned “Resource Lands type RLGS” by Garfield County. The Project will connect with a Caerus-owned 230 kV power line that traverses the Project site. The 230 kV Caerus line is connected to Xcel Energy’s power system. The subject Parcel is owned by Caerus Piceance LLC and will be leased for the intended purpose to Wheeler Gulch Solar LLC. Caerus and Wheeler Gulch Solar request that the permit be issued in the name of Wheeler Gulch Solar LLC. The Project will be comprised of approximately 22,000 solar panels mounted on single axis tracking racks. The capacity of the Project is nominally 10 MWac. The Project will generate approximately 25,300 MWh of electricity per year. There is no utility scale battery storage of energy contemplated on the Project site at this time. Other than a metal clad switchgear enclosure that measures about 10’ wide by 10’ long and 8 feet tall, and a shipping storage container measuring no larger than 40’ long by 8’ wide and 8’ 6” tall, that will be used to store spare parts and tools, there will be no buildings erected on the site. There will be no office space or living quarters at the site. The site will have a perimeter fence as described herein. Sanitation will be provided by leased portable toilets during construction and there will be no potable water service required. Non-potable water for PV panel washing will be supplied by local contractors as needed, per the terms of the agreement described herein. Road access to the Project site from County Rd. 215 is via an existing access apron. The access roadway will include parking spaces for at least 10 vehicles. The range of activities that could be conducted at the site are fully described in the Operations and Maintenance Plan included as part of this application. All of the power produced by the Project will be consumed by Caerus to support its oil and gas production activities. 1 -Typical single axis rack mounted PV system similar to proposed Wheeler Gulch Solar Project 66 In addition to the Project site parcel, Wheeler Gulch Solar has arranged for the contingent lease and use of a small portion of nearby Assessor’s Parcel #240901300001 for short-term equipment staging and laydown during construction on an “as needed” basis. This “storage” parcel is owned by Caerus affiliate Caerus Cross Timbers LLC and is currently used as a Small Contractor’s Yard, a “by right” use in compliance with standards of the zoning code for this parcel. Wheeler Gulch included the potential utilization of this storage area during construction of the Project in its Traffic Study and Impacts Assessment, along with use of the Project site, even though use of the Small Contractor’s Yard may not ultimately be required. Need The Renewable Energy Certificates (RECs) associated with the Project output will be sold to Xcel Energy (Xcel) pursuant to a 20-year purchase and sale agreement. The Project is needed by Xcel. Xcel selected the Project for its Solar Rewards Program (REC Program). The REC Program is designed to help Xcel to attain the objectives of its Renewable Energy Plan 2022-25, including the expansion of distributed renewable energy generation in Colorado. The Project’s renewable solar electricity generation also supports achievement of Xcel’s goal to reduce greenhouse gas emissions by 80% from 2005 levels by 2030, as set forth in Colorado's Greenhouse Gas Pollution Reduction Roadmap. Operations The project will create opportunity for short term employment for about 100 workers during the 6-to-8-month construction period. Once operational, the Project will be available to generate power continuously although actual power generation only occurs during daylight hours. During the course of normal operations, the Project will not be manned. Operations and maintenance personnel will be dispatched to the Project site as needed to make repairs, perform inspections and to respond to unplanned outages of the solar generator. It should be noted that the project will be remotely monitored on a 24x7 basis. Caerus maintains a local control center in Parachute for its oil and gas operations that is continuously manned. It is planned that the Caerus control center will be contracted by the Project to provide notification in a timely manner should a weather-related incident or other unexpected event, such as damage to perimeter fencing, require personnel to be dispatched the Project site. Timeline for Development and Construction Planning and development activity for the project has been in process since late 2021. The Wheeler Gulch Solar team participated in a pre-application permit conference with Garfield County in 2022 for which the conference report is included herein. Project representatives also conferred with a number of key stakeholders during the pre-application period. These stakeholders included Colorado Parks and Wildlife, Garfield County Fire, Garfield County Public Health and Garfield County Road and Bridge. Accordingly, input received in those pre- application conferences has been considered in the design of the Project. The remainder of the key milestones planned are as follows: Description Pro-forma completion date Wheeler Gulch Solar Project 67 Submit permit application Not later than 2/10/23 Limited impact land use permit granted Not later than 5/1/23 Mobilization to site Week of 5/1/23 Site grading and preparation 6/1/23 Foundations and racking installed 7/1/23 Electrical construction 9/30/23 Solar module installation 9/30/23 Mechanical completion 10/15/23 Commercial Operation Date* 10/31/23 *Note that ongoing discussions with Xcel Energy relating to supply chain constraints for delivery of certain equipment may result in a later COD than projected. Sponsor Information Caerus Operating LLC, through its subsidiary Wheeler Gulch Solar LLC, will be initially responsible for the construction, maintenance, and operation of the Project. In order to successfully complete the Project, Wheeler Gulch LLC will contract for services with a range of specialized solar industry firms that have experience with Projects similar to what is proposed. Caerus requests that the permit be issued in the name of Wheeler Gulch Solar LLC. Wheeler Gulch Solar LLC will be the owner and operator of the Project. From an organizational perspective, Caerus Operating LLC is the ultimate corporate parent. Caerus Piceance LLC is the owner of the parcel which includes the site of the Project that will be leased to Wheeler Gulch Solar LLC. Caerus Piceance LLC is a wholly owned subsidiary of Caerus Operating LLC and Wheeler Gulch Solar LLC is a wholly owned subsidiary of Caerus Piceance LLC. Caerus Operating LLC, through its subsidiaries Caerus Piceance LLC, Caerus Energy Services LLC, and Caerus Cross Timbers LLC, has conducted broad scale business operations in Garfield County since 2013. Caerus is the second largest producer of natural gas in Garfield County and currently operates thousands of well sites and more than 12 facilities that require land use permits from the County. Current Caerus employment in Garfield County is approximately 150 individuals. Because of its current operations Caerus is well positioned to successfully construct and operate this Project once the permit is issued. As mentioned herein, Caerus will remotely monitor the project on a continuous basis and because of its oil and gas operations there is a 24x7 staffed control center that can provide immediate response to incidents that may occur at Wheeler Gulch Solar Project 68 the site from time to time. Caerus is proud of its decade-long operating record in Garfield County, including compliance with the more than 12 existing land use permits that Caerus manages. Wheeler Gulch Solar LLC looks forward to the opportunity to bring this new clean energy resource into the community. Adjacent Land Use The Project site parcel and adjacent land parcels are zoned “Resource Lands” by Garfield County and the major land uses within the study area are industrial, agricultural, and rangeland. In addition, the adjoining land on the west side hosts an oil and gas pad infrastructure area and an additional oil and gas pad is located near the southeast corner of the Project area. There are no residential properties located within the adjacent lands as shown on the Landowner Map in Section 4-203. B. Site Features The project area is in a valley within the Roan Cliffs. The host parcel is bounded by Parachute Creek on the southwestern side and County Road 215 on the northeastern side. The dominant land cover in the study area is shrub/scrub. The adjacent lands are primarily evergreen forest and developed lands with minimal lands having land cover of pasture/ hay fields, woody wetlands, barren land, and cultivated crops. (See Appendix C – Biological Resource Report for a more in-depth description of the site features.) Soil Characteristics There are no hydric soils within the project site. Soil types on the project site are conducive to effective construction and operation of the proposed solar project. Best management practices will be used to salvage topsoil and minimize soil erosion and transport. (See Appendix D for the full Soils Characteristics and Analysis of the project site.) Geology and Hazards As stated in Section 4-203.G and as detailed on the Grading and Drainage Plans in Section 4- 203.E, the pre-existing and final slope conditions show no portion of the Project site located on slopes greater than 20% and therefore do not require a Slope Development Minimum Requirement Analysis under the standards adopted by Garfield County. Groundwater and Aquifer Recharge Areas The natural drainage patterns of the site will not be materially altered, only slightly improved upon. The impacts to the site’s impervious surface area are minimal at 0.36% of the entire project site which does not result in an impact to any groundwater resources. There will be no on-site waste, sewage disposal or waste generation to affect any groundwater resources. Wheeler Gulch Solar Project 69 (Refer to Section 4-203.E for the Grading and Drainage Plan, Appendix C – Biological Resource Report, Appendix D – Geotechnical Soils Report, and Appendix F - Aquatic Resource Delineation Report for further information.) Environmental Impacts To avoid any potential impacts to the threatened or endangered fish species that inhabit the Colorado River, no disturbances to Parachute Creek will occur before or after construction. The presence of burrowing owls (a state endangered species) is possible because a white- tailed prairie dog colony was observed within the project area. Burrowing owls commonly use prairie dog burrows during the breeding season. Prior to construction planned to occur between March 15th and August 31st, burrowing owl surveys will be conducted prior to any disturbance of the study area. No bald eagle nests were identified within ½ mile of the project area. However, bald eagle nest and roost surveys will be conducted prior to construction within the study area due to the presence of mature cottonwood trees along Parachute Creek. Construction that occurs between August 31st and November 15th has the potential to impact peregrine falcons and other state- listed birds during nesting or roosting in the vicinity of the project. Therefore, should the construction schedule extend to the period between August 31st and November 15th, surveys will be conducted prior to construction to confirm that no new nests or roosts have been established or are being utilized within the study area. This project has limited potential to create a barrier that could restrict the movement of big game in the area. To minimize this potential impact, the layout of project site and exclusionary fencing therefore leaves paths for big game to travel east-west between the solar facility and neighboring facilities, on either the north or south perimeters of the project, as well as providing a large corridor running north and south on unleased portions of the host parcel adjacent to Parachute Creek. Other mitigation measures to prevent impacts to big game are discussed in the Biological Resources Report included in Appendix C2. Big game species including mule deer and elk may be temporarily disturbed or displaced by construction activity. Collisions or other direct effects are unlikely as most individuals will likely avoid the area during active construction. Wetlands A wetlands delineation study was performed by HDR on the Project site and adjoining land to the west. None of the aquatic features identified in the report provided by HDR fall within the Project boundary. Furthermore, there is additional setback established from those same features by an existing road being utilized for an adjoining oil pad site. (See Appendix F – Aquatic Resource Delineation Report for further information). Nuisance Wheeler Gulch Solar Project 70 Solar energy projects operate quietly, unmanned without daily traffic. They also operate with no emissions, water usage, wastewater, or fuels. This Project is a renewable energy system that operates as a clean, non-emissions facility. No nuisance is expected. Air Quality Wheeler Gulch Solar will use Best Management Practices to manage dust during construction. The emissions from construction activities are anticipated to be below thresholds set by the Colorado Department of Public Health and Environment (CPPHE) for Colorado’s Air Pollution Emission Notice (APEN) system. The site access roads will be graveled for long-term use. During construction of the solar facility, appropriate measures will be taken to minimize dust from the delivery trucks and tracking of mud. Glare Modern PV modules use a sophisticated anti-reflective (AR) coating to nearly eliminate the reflection of sunlight off the module. The AR coating has a transmittance of at least 93% of the sunlight that hits it. This high level of transmittance means that very little sunlight, 7% or less, gets reflected off of the surface of the module. With regards to concerns over glare from the proposed solar facility, the solar panels are tracking in nature, which means that they will rotate to face the sun as it passes overhead. This tracking minimizes any angle of reflection for the small amount of light not absorbed by the PV modules. This factor, combined with the solar panel’s anti-reflective coating, will minimize any reflected light (glare). Please reference Appendix I for the SolarForge Glare Analysis performed specifically for the Wheeler Gulch Solar project’s site location. This analysis was done taking in the locations of nearby homes and roadways. The ForgeSolar software tool is used throughout the industry, academia, and military to evaluate PV glare. Based on the ForgeSolar analysis performed, no green or yellow category glare was detected from any point analyzed. This is in large part due to the tracking nature of the facility and the fluctuation tilt of the panels so that there are no instances when the panels oriented directly at any homes or roadways. The location of project site is located far from any airports and outside of any 2-mile flight path. (See Appendix I – ForgeSolar Glare Analysis report.) Noise Installed solar arrays create a minimal amount of noise and vibrations. Typically, the PV inverters and transformers will emit minimal noise, measured at approximately 50 decibels when standing within 10 feet from the module. This is equivalent to a conversation level amount of noise within that range. Once constructed, the operation of the facility will be unmanned and will operate quietly and automatically with only infrequent maintenance visits to the site. Hours of Operation Wheeler Gulch Solar Project 71 The project, once in operation, will operate 24/7 but will be unmanned and remotely monitored for performance. The project may be altered for necessary maintenance or in the event of an emergency. Maintenance trips to the site typically will occur no more than once per month. During construction, work hours will be limited to daytime hours (7am-7pm). It’s intended for crews to primarily work on weekdays unless certain circumstances require weekend work. Wheeler Gulch Solar will comply with the Garfield County restrictions for permitted construction activities outside of normal scheduled times if construction is to occur outside of normal weekday and daylight hours. Wheeler Gulch Solar Project 72 Traffic Study – 4-203.L Please see the following pages for the Traffic Study prepared by HDR Consulting addressing the existing road systems and driveways compliance to the Road Standards and compliance with Section 7-107. All on-site driveways and interior road improvements are documented in the civil plan set provided in Section 4-203. D. Wheeler Gulch Solar Project 73 Wheeler Gulch Solar Project 74 Wheeler Gulch Solar Project 75 Wheeler Gulch Solar Project 76 Wheeler Gulch Solar Project 77 Wheeler Gulch Solar Project 78 Wheeler Gulch Solar Project 79 Water Supply & Distribution Plan – 4-203.M The proposed Solar Facility will be an unmanned facility with no full-time, permanent employees. This facility has no need for permanent water supply or distribution system during the operational phase of the facility and a Waiver for the requirement detailed in Section 4- 203.N is requested. Any needs that arise for water will be served by trucking in water. If the operator decides to clean the solar arrays and de-ionized water will is required, it will be trucked in for that purpose. For the construction period of the proposed Facility, Wheeler Gulch Solar has secured a Will Serve letter from Stallion Oilfield Services for requisite water supply services for construction activities (e.g. dust suppression). Please see the following page for the Will Serve letter. Wheeler Gulch Solar Project 80 Wheeler Gulch Solar Project 81 Wastewater Management System Plan – 4-203.N The proposed Solar Facility will be an unmanned facility with no full-time, permanent employees. Scheduled visits for landscaping, weed mitigation or equipment maintenance are expected to be less than 6 times per year, typically. This facility has no need for permanent wastewater collection or treatment onsite during the operational phase of the facility and a Waiver for the requirement detailed in Section 4-203.N is requested For the construction period of the proposed Facility, Wheeler Gulch Solar has secured a Will Serve letter from Western Colorado Waste, Inc. for wastewater services for construction personnel. Please see the following page for the Will Serve letter. Wheeler Gulch Solar Project 82 Wheeler Gulch Solar Project 83 Floodplain Analysis – 4-203.O Please refer to the following pages containing a Technical Report performed and completed by HDR as a Floodplain Analysis for Wheeler Gulch Solar Project. Wheeler Gulch Solar Project 84 Wheeler Gulch Solar Project 85 Wheeler Gulch Solar Project 86 Wheeler Gulch Solar Project 87 Wheeler Gulch Solar Project 88 Wheeler Gulch Solar Project 89 Wheeler Gulch Solar Project 90 Wheeler Gulch Solar Project 91 Wheeler Gulch Solar Project 92 Wheeler Gulch Solar Project 93