Friends of Harford President, Stephanie Flasch, provided input for Bill 21-011 during the February 2, 2021 County Council Meeting. Remarks below.

RE:  FOH Supports Bill 21-001 Solar Energy with Amendments

Friends of Harford (FOH) is dedicated to advocating for responsible land use policies and practices that reduce environmental impacts. We commend the County’s legislative efforts for alternative energy initiatives.  Bill 21-001, Solar Energy, is an opportunity to enact small scale clean energy sources but must be amended to reduce negative impacts on Harford County’s landscape so the legislation is a win, win for all.

FOH reviewed solar energy best practices, HarfordNext Environmental Stewardship and Community Planning Areas chapters, plus solar energy legislation in effect in other Maryland Counties to evaluate the Solar Energy bill.  FOH requests the following amendments:

• Define Power and Regenerative Plants, Harford County’s large scale solar projects permitted in GI district.   The definition can clarify the difference between large scale solar utilities and the Community Solar Energy Generating Systems (CSEGS) as an accessory or small-scale solar development.  The language in the both definitions need to identify key differences. Development Standards B (8) allows up to 3 CSEGS on one parcel;  how  is this different from large scale solar projects?

• Change Permitted Use from a Special Development (SD) to a Special Exception (SE).  Allowing the community and adjacent property owners the ability to provide feedback on the impacts proposed to their property or community. The county has no experience with a small scale solar accessories in the designated zoning, therefore a Special Exception would at least potentially allow neighbors to help set site-specific requirements to protect themselves, or if necessary, to stop the project.  An SD denies both possibilities.

• Solar developments should not exclude Agricultural districts. Agricultural protections can be designed to address different developmental-related risks.    For example, sitings prohibited in Rural Legacy Areas, on land under conservation or preservation easement plus a two-mile buffer from designated Scenic Byways in the County.  These type of restrictions assist in preserving the local heritage, the scenic views, and protect against the detraction of events held in agricultural areas.  The addition of the Agricultural District allows a Use that does not destroy valuable land with permanent development. 

• Incorporate The Department of Natural Resources guidance on Solar Site Pollinator Habitat designations into Development Standard Section B (5) to gain benefits at the solar site and enhance habitats surrounding the site.

• Use limitation must be included.  Maximum square feet occupied on lot or a percentage of the land to ensure the size is appropriate for the districts and minimizes the impact on the communities. Similar to Use limitations sited for Accessory Use and Structures § 267-27.

• CSEGS projects should be limited to balance County initiatives with Maryland Commercial Property Assessed Clean Energy (Md-PACE) program. Harford County Code, Chapter 123 Article VIII: Clean Energy Loan Program provides incentives and opportunities for clean energy programs; solar energy sources on existing structures.

Bill 21-001, Solar Energy is a step in the right direction to enact standards for small-scale solar projects but requires amendments to reduce the long term impacts on Harford County’s landscape and communities. Thank you for your consideration for Bill 21-001 amendments.