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AQ-02 · Matrix · Aquatic Resources

Rating
2Impacts likely but may be easily resolved
Why
Impact likely
Worst case
Not above the rating
Evidence
Reported
Cited claims
4
Requirements
1
Requests
2

Rating

2Impacts likely but may be easily resolved

The rule

Code computed the rating from the assessor's inputs:

impact_likely=yes -> 2

Set by the rule

Decision
Released
Evidence state
Reported · desktop, consultant or developer record

Revision

Not revised.

The five inputs

  • Present: yes

    FEMA FIRM panel 18999C0150D maps Zone A (100-year floodplain) along Sugar Run (C-265b2e4481); the mapped floodplain runs through the site center (C-1ebafa9bbc).

    Cites C-265b2e4481, C-1ebafa9bbc

  • Extent: core

    Mapped floodplain is about 300 feet wide through the center of the site (C-1ebafa9bbc), following Sugar Run, which bisects the Project Area north to south (C-b2682b602a).

    Cites C-1ebafa9bbc, C-b2682b602a

  • Avoidable: yes

    A band about 300 feet wide (C-1ebafa9bbc) within a 1,356-acre project is a small share of buildable land; arrays and equipment can be sited outside it, with only collection lines or roads crossing, the consultant recommending HDD for Sugar Run crossings (C-5a22a97656).

    Cites C-1ebafa9bbc, C-5a22a97656

  • Pathway: standard

    Zone A is a mapped flood hazard area, so a local floodplain development permit (F-NFIP) applies to any crossings or work (C-265b2e4481). No floodway is documented, so an individual no-rise pathway is not established. The state floodway permit S-04 is unverified.

    Cites C-265b2e4481

  • Impact likely: yes

    The floodplain crosses the center of the site (C-1ebafa9bbc), and a typical build needs road and collection-line crossings of Sugar Run (C-b2682b602a, C-5a22a97656), so permitting and crossing work are likely even if arrays avoid it.

    Cites C-1ebafa9bbc, C-b2682b602a, C-5a22a97656

Comments

FEMA FIRM panel 18999C0150D maps Zone A (100-year floodplain) along Sugar Run. The mapped floodplain is approximately 300 feet wide through the center of the site. No FIRM panel or floodplain administrator correspondence is in the data room.

Critique

Verdict
upheld
Suggested direction for the rating
same
Summary

Assessment is largely supported: Zone A, a 300-ft width through the site center, and likely crossings. Minor issues: the 'small share of buildable land' claim has no quote support, the data-room comment is inconsistent, HDD is a stream measure rather than a floodplain one, and the DNR drainage-area trigger is unconfirmed.

Critic model
Luminol

Issues

  1. Severity minor · Kind unsupported_statement

    Avoidable rationale says a 300-ft band is a 'small share of buildable land' and arrays can be sited outside it. No cited quote gives floodplain length or area. A 300-ft band bisecting the site north to south may split the layout and constrain access. Site layout or GIS overlay would settle it.

    Cites C-1ebafa9bbc, C-5a22a97656

  2. Severity minor · Kind overstatement

    The comments say 'No FIRM panel or floodplain administrator correspondence is in the data room', yet the assessment cites a FIRM panel number from the consultant report. The wording is inconsistent. The FIRM panel itself is absent, but the panel number is reported.

    Cites C-265b2e4481

  3. Severity minor · Kind unsupported_statement

    The rationale reads the HDD recommendation as a floodplain crossing measure. The quote refers to collection line crossings of Sugar Run (the stream), not the floodplain. The memo also recommends avoiding all delineated features, which does not mention roads. The claim about road crossings is judgment, not quoted evidence.

    Cites C-5a22a97656

  4. Severity minor · Kind missing_next_step

    The agency list includes Indiana DNR Division of Water, but S-04 is unverified and no floodway is documented. The Sugar Run drainage area is not documented either, so the 1+ sq mi trigger is unestablished. The next steps should say to confirm the drainage area and the floodway status.

    Cites C-265b2e4481

Checks

  • Passed

    rating_has_evidence · blocking

  • Passed

    presence_is_evidenced · not blocking

  • Passed

    counter_evidence_considered · not blocking

  • Passed

    numbers_grounded · not blocking

  • Passed

    agencies_grounded · not blocking

  • Passed

    cutoff_respected · blocking

  • Passed

    critic_not_refuted · blocking

Evidence (4)

Each claim the row cites: the statement in the assessor's words, then the quote the engine found on the page.

Wetland and Stream Delineation Report May2023

C-1ebafa9bbc · Page 4 of 4 · DR-0005

Open the claim, C-1ebafa9bbc

The mapped floodplain is approximately 300 feet wide through the center of the site.

Quote check Exact · Placed verbatim · The quote occurs on the page exactly as written. · Read as native

SYNTHETIC TEST FIXTURE - FICTIONAL PROJECT Floodplain FEMA FIRM panel 18999C0150D maps Zone A (100-year floodplain) along Sugar Run. Quote starts. The mapped floodplain is approximately 300 feet wide through the center of the site. Quote ends.

The outline marks where the quote begins on the page.

Page 4 of Wetland and Stream Delineation Report May2023
  1. C-1ebafa9bbc

    The mapped floodplain is approximately 300 feet wide through the center of the site.

    Quoted from page 4
    The mapped floodplain is approximately 300 feet wide through the center of the site.

    Wetland and Stream Delineation Report May2023 · DR-0005 · Page 4 · 2023-05-22

    Source map_or_figure · Claim type extent · Polarity presence · Confidence high · Quote check exact, 100 of 100

  2. C-265b2e4481

    FEMA FIRM panel 18999C0150D maps Zone A (100-year floodplain) along Sugar Run.

    Quoted from page 4
    FEMA FIRM panel 18999C0150D maps Zone A (100-year floodplain) along Sugar Run.

    Wetland and Stream Delineation Report May2023 · DR-0005 · Page 4 · 2023-05-22

    Source map_or_figure · Claim type presence · Polarity presence · Confidence high · Quote check exact, 100 of 100

  3. C-5a22a97656

    Consultant recommends avoiding all delineated features and using horizontal directional drilling for collection line crossings of Sugar Run.

    Quoted from page 2
    We recommend avoidance of all delineated features; collection line crossings of Sugar Run should use horizontal directional drilling (HDD).

    Wetland and Stream Delineation Report May2023 · DR-0005 · Page 2 · 2023-05-22

    Source consultant_memo · Claim type recommendation · Polarity neutral · Confidence high · Quote check exact, 100 of 100

    Cited by AQ-01 · Filed under AQ-01

  4. C-b2682b602a

    Sugar Run, a perennial stream, bisects the center of the Project Area from north to south.

    Quoted from page 2
    Sugar Run, a perennial stream, bisects the center of the Project Area from north to south.

    Wetland and Stream Delineation Report May2023 · DR-0005 · Page 2 · 2023-05-22

    Source field_study · Claim type presence · Polarity presence · Confidence high · Quote check exact, 100 of 100

    Cited by AQ-01, EC-02 · Filed under AQ-01

Requirements and permits

The requirements the assessor tied to this row, by level. Each quote from dated law is shown with its source.

Engine 0.1.0, which made this run, wrote no timelines or citations of law.

Federal

  • Floodplain development permit

    F-NFIP · Local floodplain administrator (NFIP community), FEMA

    Applicability
    Conditional
    Instrument
    National Flood Insurance Program (44 CFR Parts 59-60) and local flood damage prevention ordinance
    Trigger
    Equipment, fill or structures in a mapped flood hazard area.
    Description

    Development within a FEMA Special Flood Hazard Area requires a local floodplain development permit; floodway encroachment needs a no-rise analysis.

    Verification
    PACK_PENDING_QUALIFIED_REVIEW
    Source
    pack:federal
    In the permit matrix
    F-NFIP

Also in the permit matrix for this row: S-04

Information requests

  • IR-ecff39a0bd · Medium priority

    Provide the fema firm panel or flood-zone determination for the project area, or confirm none exists.

    Missing evidence
    FEMA FIRM panel or flood-zone determination
    Consequence
    Floodplains is rated on partial evidence without it.
    Blocks the decision
    No
    Raised by
    completeness
  • IR-89f116c01d · Medium priority

    Provide the local floodplain administrator correspondence or ordinance for the project area, or confirm none exists.

    Missing evidence
    Local floodplain administrator correspondence or ordinance
    Consequence
    Floodplains is rated on partial evidence without it.
    Blocks the decision
    No
    Raised by
    completeness

Next steps

  • Obtain FIRM panel and confirm whether a regulatory floodway is mapped.
  • Site arrays and equipment outside Zone A; use HDD for Sugar Run crossings.
  • Consult local floodplain administrator and Indiana DNR on permits.

Agencies

  • FEMA
  • Local floodplain administrator (NFIP community)
  • Indiana DNR Division of Water

Cost and impact

Impact
C, S
Potential cost level
L
Why

Siting arrays outside the floodplain limits exposure to crossing design and a floodplain development permit.

Impact: C = cost, S = schedule. Potential cost level: L, L-M, M, M-H, H (relative to a utility-scale solar budget).

Lumerian Labs 2026