AR25-015 Staff Decision - Laserfiche WebLink

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planned in detail. Without actual plans for construction of the BESS, there can be no conclusion about the technical and/or engineering feasibility of the proposal on any lands, let alone an proposed requirement to site the facility on high value farmland in the EFU zone. As addressed below, the applicant mentions risk of fire but does not address in detail how that risk will be mitigated. The risk of fire itself carries a cascading list of associated environmental and health impacts. As a result of a lithium fire there would be release of toxic chemicals into the air, soil and water, potential injury to first responders and citizens in the area such as respiratory issues, skin irritation, and long-term health issues. Beyond the safety issues are the environmental dangers posed by mass release of chemicals in the event of a failure of any of the batteries on site. The applicant does not address any of the technical details of these potential risks or how those risks could be mitigated. The applicant does not provide any evidence towards the feasibility of the proposed BESS to be engineered so as to mitigate the dangers inherent with BESSs. The proposed BESS is not a utility facility necessary for public service, but if it was, the proposal would not meet this criterion. 2. The proposed facility is locationally dependent. A utility facility is locationally dependent if it must cross land in one or more areas zoned for exclusive farm use in order to achieve a reasonably direct route or to meet unique geographical needs that cannot be satisfied on other lands; The applicant suggests that other substations in the area would not meet the technical and engineering feasibility criterion because they would require upgrades to the networks, capacity, or new long transmission lines. The applicant states that other locations were not suitable specifically due to requiring new overhead transmission line installation for compatibility. The applicant did not provide any evidence to support the assertion that they examined other locations in the county for compatibility with the project. The location proposed poses dangers to surrounding farmland due to soil contamination, groundwater contamination, and chemical leakage. The applicant did not provide any information about potential emergency response at the proposed location. The applicant specifically proposes an intensive use on EFU land in a rural area instead of in an urban area adjacent to one of many substations within cities in Marion County where such a use would be potentially more appropriate from an environmental and emergency response standpoint. The applicant suggests prolonging the life of the facility beyond the average 20-25 years for a BESS by frequent replacement of parts. Decommissioning requires collection of hazardous materials, and the applicant does not explain how decommissioning of the facility could be performed. The proposed BESS is not a utility facility necessary for public service, but if it was, the proposal would not meet this criterion. 3. Lack of available urban and nonresource lands; The applicant states that there are no other lands “in proximity to the Parrish Gap Substation”. A BESS requires a substation, but not the Parrish Gap Substation specifically. The map of substations submitted by FOMC shows that there are many substations in Marion County on urban and nonresource lands. The applicant did not provide information to suggest that other potential siting locations on urban or nonresource lands were considered for the proposed BESS. Evidence on the record does not support the assertion that the proposed location is due to the lack of available urban and nonresource lands. The proposed BESS is not a utility facility necessary for public service, but if it was, the proposal would not meet this criterion. 4. Availability of existing right-of-way; The proposal is for a facility that would not be appropriate to cite within a right-of-way. The proposed BESS is not a utility facility necessary for public service, but if it was, this criterion would not apply. 5. Public health and safety; and The applicant states they will comply with all local building and fire codes and that the facility does not produce any emissions or discharges. The applicant states that appropriate signage will be placed on the high voltage substation equipment. The applicant states that BESS Staff will be trained in fire prevention and fire department notification policies, furthermore staff will be required to follow those policies. The applicant does not describe the number of staff present, what hours they will be present, or what their non-emergency responsibilities will be. The applicant does not explain what the policies or procedures for these staff will be. The staff for BESSs after initial construction are generally only on site for routine inspections and maintenance, not around the clock supervision of the system. The applicant states that prior to construction they will consult with relevant first responders to ensure there are suitable procedures in place in the event of a fire or other emergency, and the resouces to provide training and demonstrations relevant to handling a fire or other emergency at the BESS facility. There is no indication that the applicant consulted with the Turner Fire District prior to applying to discuss the proposal and what may be required by the fire department. The applicant did not provide explanation of what these procedures