Non-RTE Species

Read as a desk report

EC-02 · Matrix · Ecological Resources

Rating: 2Impacts likely but may be easily resolved
Why: Impact likely
Worst case: Up to3Resource is present, likely difficult to address
Evidence: Verified

Cited claims: 10
Requirements: 3
Requests: 2

Rating

2Impacts likely but may be easily resolved

up to3Resource is present, likely difficult to address

The engine shows this rating as 2-3

The rule

Code computed the rating from the assessor's inputs:

impact_likely=yes -> 2

Set by the rule

Decision

Released

Evidence state

Verified · field study or agency determination

Worst case

If what is pending at the cut-off went badly, the same rule gives a higher rating.

Scenario: Mapping places the hayfield and grassland nesting habitat within the buildable area, so grassland bird habitat is lost despite timing restrictions.
Step still pending: Habitat mapping of hayfield and grassland against the final layout, and nesting bird surveys
Inputs in the worst case: Extent core · Avoidable partly · Pathway standard · Impact likely yes
The rule on the worst case: worst case: extent=core, avoidable=partly -> 3
Claims that make it plausible: C-a6b564438f, C-86e65362cd, C-a6c169a2d9

Revision

First verdict: weakened
First critique: Point inputs and category 2 are well supported. The worst case claims hayfields cover much of the buildable area, which no claim supports and the 80-acre (7%) grassland figure undercuts. Minor gaps: truncated hawk quote, eagle window, missing survey next step.

Revised once after the first critique. Rating unchanged.

The five inputs

Present: yes
ODNR states hayfields and reclaimed mine grasslands in the eastern part of the site provide MBTA grassland bird nesting habitat (C-a6b564438f). The field survey saw bobolink and eastern meadowlark in the hayfields of Parcels 12 to 14, and red-tailed hawks nesting (C-86e65362cd). An active bald eagle nest is recorded about 0.9 mile east of the boundary (C-4108f1157c, C-fb295f9d24).
Cites C-a6b564438f, C-86e65362cd, C-4108f1157c, C-fb295f9d24
Extent: unknown
Hayfield acreage and its position relative to the buildable area are not documented. Reclaimed grassland is about 80 acres (7%) of the Project Area (C-a6c169a2d9); habitat is described only as the eastern part and Parcels 12 to 14 (C-a6b564438f, C-86e65362cd). The eagle nest is outside the site (C-4108f1157c).
Cites C-a6c169a2d9, C-a6b564438f, C-86e65362cd, C-4108f1157c
Avoidable: partly
Timing avoids nest take: clear and mow outside April 15 to July 31 (C-a6b564438f, C-76760b5938). The eagle nest is about 0.9 mile away, beyond the 660-foot buffer that applies January 15 to July 31 (C-7366342eed, C-cb44061226). Judgment for a typical build: some grassland nesting habitat will be converted to arrays, so some habitat loss remains. The draft layout clears about 38 acres of trees (C-c0e63f6881).
Cites C-a6b564438f, C-76760b5938, C-7366342eed, C-cb44061226, C-c0e63f6881
Pathway: standard
MBTA compliance by avoidance, seasonal clearing and mowing windows, and eagle buffer checks (C-76760b5938, C-cb44061226, C-4e22698f2d). The nest is about 0.9 mile away, so no eagle take permit is indicated (C-4108f1157c). F-MBTA and OH-ODNR-SOLAR apply; F-BGEPA is conditional on nest proximity.
Cites C-76760b5938, C-cb44061226, C-4e22698f2d, C-4108f1157c
Impact likely: yes
Judgment for a typical solar build: grading and fencing on hayfields and reclaimed grassland with documented nesting grassland birds is likely to disturb protected bird habitat (C-a6b564438f, C-86e65362cd). Tree clearing of about 38 acres adds disturbance of woodland bird habitat (C-c0e63f6881).
Cites C-a6b564438f, C-86e65362cd, C-c0e63f6881

Comments

ODNR identifies hayfields and reclaimed mine grasslands in the eastern site as MBTA grassland bird nesting habitat. Bobolink and eastern meadowlark were observed in Parcels 12 to 14. An active bald eagle nest lies about 0.9 mile east of the boundary. Clear and mow outside April 15 to July 31.

Critique

Verdict: upheld
Suggested direction for the rating: same
Summary: The assessment is well supported. Quotes back the presence, timing windows and eagle buffer, and extent is correctly left unknown. Minor points: the tree-clearing acreage belongs to EC-03, and the hawk-nest quote is truncated.
Critic model: Luminol

Issues

Severity minor · Kind other
The 38 acres of tree clearing (C-c0e63f6881) is used in the avoidable and impact_likely rationales. Forest clearing is rated under EC-03. The quote also says nothing about woodland bird habitat. The impact call stands on the grassland evidence alone, so drop or reword this.
Cites C-c0e63f6881
Severity minor · Kind unsupported_statement
The quote for the red-tailed hawk nesting is cut off at 'nest in', so it does not show where they nest. The rationale cannot treat it as nesting on the site or in the hayfields. The eagle nest is also outside the site, so it supports regional context, not on-site presence.
Cites C-86e65362cd, C-4108f1157c

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 (10)

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

Arrow keys move the selection. A middle-click opens the claim's own page.

ODNR Environmental Review - Tamsin Ridge Solar and Storage Project (ODNR 23-0477)

C-4108f1157c · Page 2 of 2 · DR-0011

Open the claim

The Division has a record of an active bald eagle nest about 0.9 mile east of the project boundary.

Quote check Exact · Placed verbatim · The quote occurs on the page exactly as written. · Read as ocr · OCR confidence 0.9600969870098038

ODNR 23-0477 - Tamsin Ridge Solar and Storage Project - page 2 Division of Wildlife (continued) Bald eagle. The Division has a record of an active bald eagle nest about 0.9 mile east of the project boundary. Keep tree clearing and construction more than 660 feet from the nest during the nesting season, January 15 through July 31. Bats. The northern long-eared bat and the Indiana bat are federally endangered. Coordinate tree clearing with the U.S. Fish and Wildlife Service. Cutting of potential roost trees should be limited to the October 1 to March 31 window. Two collapsed mine entries on the eastern parcels should be checked for openings that bats could use as hibernacula before any work near them. Grassland birds. Hayfields and reclaimed mine grasslands in the eastern part of the site provide nesting habitat for grassland birds protected under the Migratory Bird Treaty Act. Mow and clear outside the nesting season. This letter is valid for one year from its date. Changes to the project area or the layout should be submitted for further review. Sincerely, (signed) Environmental Review Manager, Office of Real Estate Ohio Department of Natural Resources cc: Ohio Power Siting Board staff; ODNR Division of Wildlife, District Three

This page has no position for the quote: it was found in the page text only.

Page 2 of ODNR Environmental Review - Tamsin Ridge Solar and Storage Project (ODNR 23-0477)

C-4108f1157c
The Division has a record of an active bald eagle nest about 0.9 mile east of the project boundary.
Quoted from page 2
The Division has a record of an active bald eagle nest about 0.9 mile east of the project boundary.
ODNR Environmental Review - Tamsin Ridge Solar and Storage Project (ODNR 23-0477) · DR-0011 · Page 2 · 2023-05-02
Source agency_determination · Claim type presence · Polarity presence · Confidence high · Quote check exact, 100 of 100
See it on page 2, claim C-4108f1157c
C-4e22698f2d
Service recommends scheduling vegetation clearing outside the primary nesting season where possible.
Quoted from page 1
schedule vegetation clearing outside the primary nesting season where possible.
Official Species List - Tamsin Ridge Solar and Storage · DR-0010 · Page 1 · 2023-04-12
Source agency_determination · Claim type recommendation · Polarity neutral · Confidence medium · Quote check exact, 100 of 100
Cited by EC-03 · Filed under EC-02, EC-03
See it on page 1, claim C-4e22698f2d
C-7366342eed
ODNR records an active bald eagle nest about 0.9 mile east of the East Block, beyond the 660-foot disturbance buffer.
Quoted from page 1
ODNR records an active bald eagle nest about 0.9 mile east of the East Block, beyond the 660-foot disturbance buffer.
Bat Habitat Assessment and Vegetation Survey - Tamsin Ridge Solar and Storage Project · DR-0007 · Page 1 · 2023-06-20
Source consultant_memo · Claim type presence · Polarity presence · Confidence high · Quote check exact, 100 of 100
See it on page 1, claim C-7366342eed
C-76760b5938
Mow and clear outside April 15 to July 31 to protect nesting migratory birds, and recheck eagle nest location before construction.
Quoted from page 1
mow and clear outside April 15 to July 31 to protect nesting migratory birds; recheck the eagle nest location before construction.
Bat Habitat Assessment and Vegetation Survey - Tamsin Ridge Solar and Storage Project · DR-0007 · Page 1 · 2023-06-20
Source consultant_memo · Claim type recommendation · Polarity neutral · Confidence high · Quote check exact, 100 of 100
See it on page 1, claim C-76760b5938
C-86e65362cd
Bobolink and eastern meadowlark were seen in hayfields of Parcels 12 to 14, and red-tailed hawks nest in the West Block woodlots.
Quoted from page 1
Bobolink and eastern meadowlark were seen in the hayfields of Parcels 12 to 14, and red-tailed hawks nest in
Bat Habitat Assessment and Vegetation Survey - Tamsin Ridge Solar and Storage Project · DR-0007 · Page 1 · 2023-06-20
Source field_study · Claim type presence · Polarity presence · Confidence high · Quote check exact, 100 of 100
See it on page 1, claim C-86e65362cd
C-a6b564438f
Hayfields and reclaimed mine grasslands in the eastern site provide nesting habitat for MBTA-protected grassland birds; mow and clear outside nesting season.
Quoted from page 2
Hayfields and reclaimed mine grasslands in the eastern part of the site provide nesting habitat for grassland birds protected under the Migratory Bird Treaty Act.
ODNR Environmental Review - Tamsin Ridge Solar and Storage Project (ODNR 23-0477) · DR-0011 · Page 2 · 2023-05-02
Source agency_determination · Claim type presence · Polarity presence · Confidence high · Quote check exact, 100 of 100
Filed under EC-02, EC-03
See it on page 2, claim C-a6b564438f
C-a6c169a2d9
About 80 acres (7%) of the Project Area is reclaimed surface-mined grassland.
Quoted from page 2
Reclaimed surface-mined grassland 80 7%
Bat Habitat Assessment and Vegetation Survey - Tamsin Ridge Solar and Storage Project · DR-0007 · Page 2 · 2023-06-20
Source field_study · Claim type extent · Polarity presence · Confidence medium · Quote check exact, 100 of 100
Cited by EC-03 · Filed under EC-03, EN-01
See it on page 2, claim C-a6c169a2d9
C-c0e63f6881
Forest covers about 41 acres and the draft layout clears about 38 acres of trees.
Quoted from page 1
The draft layout clears about 38 acres of trees.
Bat Habitat Assessment and Vegetation Survey - Tamsin Ridge Solar and Storage Project · DR-0007 · Page 1 · 2023-06-20
Source field_study · Claim type extent · Polarity presence · Confidence medium · Quote check exact, 100 of 100
Cited by EC-01, EC-03 · Filed under EC-01, EC-03
See it on page 1, claim C-c0e63f6881
C-cb44061226
Keep tree clearing and construction more than 660 feet from the eagle nest during January 15 through July 31.
Quoted from page 2
Keep tree clearing and construction more than 660 feet from the nest during the nesting season, January 15 through July 31.
ODNR Environmental Review - Tamsin Ridge Solar and Storage Project (ODNR 23-0477) · DR-0011 · Page 2 · 2023-05-02
Source agency_determination · Claim type recommendation · Polarity neutral · Confidence high · Quote check exact, 100 of 100
See it on page 2, claim C-cb44061226
C-fb295f9d24
Bald eagles nest in the area; avoid clearing or disturbance near active nests.
Quoted from page 1
Bald eagles nest in the area. Avoid clearing or disturbance near active nests
Official Species List - Tamsin Ridge Solar and Storage · DR-0010 · Page 1 · 2023-04-12
Source agency_determination · Claim type presence · Polarity presence · Confidence high · Quote check exact, 100 of 100
See it on page 1, claim C-fb295f9d24

Requirements and permits

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

Federal

Compliance through avoidance (no incidental take permit program)
F-MBTA · U.S. Fish and Wildlife Service
Applicability
Conditional
Instrument
Migratory Bird Treaty Act (16 U.S.C. 703-712); 50 CFR Parts 10 and 21
Trigger
Vegetation clearing or construction where migratory birds nest.
Description
Prohibits take of migratory birds, nests and eggs. Managed by clearing vegetation outside the nesting season and avoiding active nests.
Typical timeline
No permit applies, so there is no agency processing time; compliance is by avoidance. The Service's Nationwide Standard Conservation Measures call for scheduling vegetation removal outside the peak bird breeding season and, where that is not possible, nest surveys generally no more than five days before the activity.
Version of the law on the cut-off
with the Service's Nationwide Standard Conservation Measures
As of the cut-off
As of the cut-off: An FWS rule (86 FR 1134) took effect defining the Act's prohibitions as applying only to actions directed at migratory birds, so incidental take was not prohibited. (2021-03-08) FWS revoked the January 2021 rule (86 FR 54642); the Service again treats incidental take as prohibited by the Act. (2021-12-03)
Verification
PACK_PENDING_QUALIFIED_REVIEW
Source
pack:federal
In the permit matrix
F-MBTA
Legal basis: 3 quotes from dated law
Quoted from the law, page 5
The MBTA (16 U.S.C. 703-712), prohibits the taking of any migratory bird or any part, nest, or egg, except as permitted by regulation.
Source National Bald Eagle Management Guidelines 2007 · page 5 · version undated
Cited for requirement
May be cited on the cut-off date.
Quoted from the law, page 2
Stressor: Vegetation Removal Conservation Goal: Avoid direct take of adults, chicks, or eggs. Conservation Measure 1: Schedule all vegetation removal, trimming, and grading of vegetated areas outside of the peak bird breeding season to the maximum extent practicable.
Source Nationwide Standard Conservation Measures birds · page 2 · version 2022-12
Cited for trigger and avoidance timing
May be cited on the cut-off date.
Quoted from the law, page 2
Conservation Measure 2: When project activities cannot occur outside the bird nesting season, conduct surveys prior to scheduled activity to determine if active nests are present within the area of impact and buffer any nesting locations found during surveys. 1) Generally, the surveys should be conducted no more than five days prior to scheduled activity.
Source Nationwide Standard Conservation Measures birds · page 2 · version 2022-12
Cited for timeline: pre-clearing nest survey
May be cited on the cut-off date.
Eagle nest buffers; eagle incidental take permit if disturbance cannot be avoided
F-BGEPA · U.S. Fish and Wildlife Service
Applicability
Conditional
Instrument
Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d); 50 CFR Part 22 (incidental take permits at 50 CFR 22.80 since the January 2022 redesignation)
Trigger
Eagle nests or concentration areas near construction.
Description
Protects bald and golden eagles, their nests and eggs from take, including disturbance.
Typical timeline
No regulatory processing time: the Service declined to put permit issuance timeframes in the eagle regulations because the time varies enormously with the scale and complexity of the activity, any NEPA analysis and the quality of the applicant's data (81 FR 91494, response to comments). Typical: 12 to 24 months for an eagle incidental take permit; nest buffers and seasonal avoidance can remove the need (basis: practice, not stated in the sources).
Version of the law on the cut-off
50 CFR Part 22 as redesignated in January 2022
As of the cut-off
As of the cut-off: Revised eagle permit regulations took effect (81 FR 91494), including incidental take permits of up to 30 years. (2017-01-17) 50 CFR Part 22 was redesignated (87 FR 884); the permit for eagle take associated with, but not the purpose of, an activity is now 50 CFR 22.80. (2022-01-07)
Verification
PACK_PENDING_QUALIFIED_REVIEW
Source
pack:federal
In the permit matrix
F-BGEPA
Legal basis: 3 quotes from dated law
Quoted from the law, page 1
This permit authorizes take of bald eagles and golden eagles where the take is compatible with the preservation of the bald eagle and the golden eagle; is necessary to protect an interest in a particular locality; is associated with, but not the purpose of, the activity; and cannot practicably be avoided.
Source 50CFR22 · page 1 · version 2023-08-01
Cited for requirement: permit for eagle take associated with, but not the purpose of, an activity
In force from 2022-02-07 to 2024-02-11
eCFR versioner: 50 CFR part 22, same text on 2022-05-20, 2022-09-12, 2023-04-22, 2023-08-01 and on every amendment date between them; amendment dates 2016-12-16, 2017-01-17, 2020-03-26, 2020-04-02, 2022-01-07, 2022-02-07, 2024-02-12, 2024-04-12, 2024-10-17, 2024-12-31
May be cited on the cut-off date.
Quoted from the law, page 1
Disturb means to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, based on the best scientific information available, (1) injury to an eagle, (2) a decrease in its productivity, by substantially interfering with normal breeding, feeding, or sheltering behavior, or (3) nest abandonment
Source 50CFR22 · page 1 · version 2023-08-01
Cited for trigger: disturbance of eagles
In force from 2022-02-07 to 2024-02-11
eCFR versioner: 50 CFR part 22, same text on 2022-05-20, 2022-09-12, 2023-04-22, 2023-08-01 and on every amendment date between them; amendment dates 2016-12-16, 2017-01-17, 2020-03-26, 2020-04-02, 2022-01-07, 2022-02-07, 2024-02-12, 2024-04-12, 2024-10-17, 2024-12-31
May be cited on the cut-off date.
Quoted from the law, page 42
We are not including permit issuance timeframes in the regulations because the time it takes to issue a permit varies enormously depending on the scale and complexity of the activity that will result in take, the need to prepare an analysis under NEPA, the quality and completeness of the data and other information provided by the applicant
Source 81FR91494 · page 42 · version 2016-12-16
Cited for timeline: no regulatory processing time
May be cited on the cut-off date.

State

ODNR conditions for solar facilities, applied through OPSB review: environmental resource surveys, wildlife-permeable fencing, pollinator vegetation, mowing season and listed-species reporting
OH-ODNR-SOLAR · Ohio Department of Natural Resources (ODNR), whose conditions are applied through the Ohio Power Siting Board (OPSB) certificate review
Applicability
Likely
Instrument
ODNR Guidance for Proposed Solar Energy Facilities in Ohio (updated 2022-04-07), agency guidance; Ohio Solar Site Pollinator Habitat Planning and Assessment Form (version March 2018)
Trigger
Any proposed solar energy facility subject to Ohio Power Siting Board regulation, for which ODNR expects these conditions in the site development plan.
Description
ODNR's solar guidance sets conditions it expects in the site development plan of every solar facility under OPSB regulation; it is guidance applied through OPSB review, and the sources show no separate permit. Surveys: resource surveys as in ODNR's Environmental Review, delineation of wetlands and streams before the OPSB application is filed, and recommended minimum buffers of 120 feet (Category 1 and 2 wetlands) and 300 feet (Category 3). Fencing: gaps of at least 6 by 6 inches for small mammals. Vegetation: at least 70% of the developed project area in beneficial vegetation, scoring at least 80 points on the pollinator form (which rewards staggered mowing), with routine mowing limited to fall and spring; the guidance says the requirement does not apply to sites committed to alternative agricultural uses to control vegetation. Listed species found in construction: 24-hour notice to OPSB staff, ODNR's Division of Wildlife and USFWS; work halted.
Typical timeline
Before the OPSB application is filed: environmental resource surveys and delineation of wetlands and streams. During construction: notice to OPSB staff, ODNR Division of Wildlife and USFWS within 24 hours of any state or federal listed species encountered, with work that could adversely impact it halted until a course of action is agreed. During operation: routine mowing limited to fall and spring seasons, as needed.
Version of the law on the cut-off
As in force from 2023-06-13 (the library text)
As of the cut-off
As of the cut-off: OPSB adopted revised rules in OAC Chapters 4906-1 to 4906-7 that add solar-facility requirements, including small-wildlife-permeable perimeter fencing and noxious-weed control. They were subject to rehearing and JCARR review and were not in effect on 2023-08-01. (2023-07-20)
Verification
PACK_PENDING_QUALIFIED_REVIEW
Source
pack:oh.json
In the permit matrix
OH-ODNR-SOLAR
Legal basis: 8 quotes from dated law
Quoted from the law, page 1
Disclaimer: The guidance document is non-exhaustive. Project recommendations are made on a site-specific basis and may include additional considerations. It is ODNR’s expectation that the conditions below are incorporated into the site development plan for all proposed solar energy facilities in Ohio which are subject to Ohio Power Siting Board regulation.
Source ODNR guidance for proposed solar energy facilities · page 1 · version 2022-04-07
May be cited on the cut-off date.
Quoted from the law, page 1
Conduct environmental resource surveys as described in the ODNR Environmental Review process. Delineate wetlands and streams, prior to OPSB application submission.
Source ODNR guidance for proposed solar energy facilities · page 1 · version 2022-04-07
May be cited on the cut-off date.
Quoted from the law, page 1
Avoid existing wetlands and adjacent woodlands. A minimum 120-foot buffer should be maintained on Category 1 and 2 wetlands. A minimum 300-foot buffer should be maintained on Category 3 wetlands to preserve ecological integrity.
Source ODNR guidance for proposed solar energy facilities · page 1 · version 2022-04-07
May be cited on the cut-off date.
Quoted from the law, page 2
Fencing around panels should incorporate gaps or spaces of at least 6 inches x 6 inches to allow passage of small mammals.
Source ODNR guidance for proposed solar energy facilities · page 2 · version 2022-04-07
May be cited on the cut-off date.
Quoted from the law, page 2
Solar development sites are required to plant a minimum of 70% of the developed project area in beneficial vegetation, utilizing plant species as described in Attachment A (or other suitable species as approved) and follow the Ohio Solar Site Pollinator Habitat Planning and Assessment Form with a minimum score of 80 points.
Source ODNR guidance for proposed solar energy facilities · page 2 · version 2022-04-07
May be cited on the cut-off date.
Quoted from the law, page 2
Routine mowing will be limited to fall/spring seasons, as needed, to allow for natural reseeding of plantings and reduce impacts to ground-nesting birds. These requirements are intended to provide wildlife habitat, encourage water infiltration, and reduce erosion. This requirement not applicable to sites committed to alternative agricultural uses to control vegetation, as described in the vegetation management plan.
Source ODNR guidance for proposed solar energy facilities · page 2 · version 2022-04-07
May be cited on the cut-off date.
Quoted from the law, page 2
The Applicant shall contact OPSB staff, ODNR DOW, and USFWS within 24 hours if state or federal listed species are encountered during construction activities. Construction activities that could adversely impact the identified plants or animals shall be immediately halted until an appropriate course of action has been agreed upon by the Applicant, OPSB staff, and the appropriate agencies.
Source ODNR guidance for proposed solar energy facilities · page 2 · version 2022-04-07
May be cited on the cut-off date.
Quoted from the law, page 1
Planned management practices for areas designated as part of the pollinator habitat site. Check all that apply. Detailed establishment and management plan developed for site 10 points Mowing Follows OPHI mowing schedule for monarchs each year 5 points Mowing is staggered over a 2 week period 5 points
Source ODNR Ohio solar site pollinator habitat planning and assessment form · page 1 · version 2023-06-13
May be cited on the cut-off date.

Also in the permit matrix for this row: OH-ESA

Information requests

IR-c5e9053166 · Medium priority
Provide the eagle nest review or avian survey for the project area, or confirm none exists.
Missing evidence
Eagle nest review or avian survey
Consequence
Non-RTE Species is rated on partial evidence without it.
Blocks the decision
No
Raised by
completeness
IR-8469920792 · Medium priority
Provide the wildlife agency correspondence for the project area, or confirm none exists.
Missing evidence
Wildlife agency correspondence
Consequence
Non-RTE Species is rated on partial evidence without it.
Blocks the decision
No
Raised by
completeness

Next steps

Schedule clearing and mowing outside April 15 to July 31; recheck eagle nest before construction, keeping the 660-foot buffer (January 15 to July 31).
Conduct nesting bird survey and map hayfield and grassland acreage against the layout.
Coordinate with ODNR and USFWS through the OPSB process, including ODNR mowing and pollinator conditions.

Agencies

USFWS
ODNR Division of Wildlife
OPSB

Cost and impact

Impact: S
Potential cost level: L
Why: Seasonal restrictions mainly affect schedule. Cost is limited to pre-construction nest checks and seasonal mowing.

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