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PE-03 · Matrix · Additional Permitting

Rating
2Impacts likely but may be easily resolved
Why
Impact likely
Worst case
Not above the rating
Evidence
Reported
Cited claims
11
Requirements
1
Requests
1

Rating

2Impacts likely but may be easily resolved

The engine shows this rating as 2

The rule

Code computed the rating from the assessor's inputs:

impact_likely=yes -> 2

Set by the rule

Decision
Released with flags
The engine's reasons
  • Agencies not in the register or the evidence: USEPA, USACE
Evidence state
Reported · desktop, consultant or developer record

Worst case

The same rule on the worst case gives no rating above the point.

Scenario

The determination or a layout change takes the crossing outside NWP 14 without notification, so a pre-construction notification is needed; the Corps would then consult SHPO and tribes under Section 106, and no tribal consultation has yet taken place.

Step still pending
Preliminary jurisdictional determination and final layout
Inputs in the worst case
Extent peripheral · Avoidable partly · Pathway standard · Impact likely yes
The rule on the worst case
worst case (impact_likely=yes -> 2) not above the point
Claims that make it plausible
C-8deff0ea95, C-f5449d6a0d, C-336bf30d1a

Revision

First verdict
weakened
First critique

Category 2 is reasonable, and the agencies fit. One major issue: the claim that HDD bores need no permit absent frac-out is not in the cited quote. Several minor points: the SPCC trigger is unverified, the parcel number is not in the quote, avoidability is stated with too much certainty, and the worst-case Section 106 link rests on judgment.

Revised once after the first critique. Rating unchanged.

The five inputs

Comments

No federal land, funding or loans are involved. Main transformer holds about 14,000 gallons of mineral oil, so the substation needs an SPCC plan. One access road crossing of an ephemeral stream is expected under a USACE nationwide permit. The collection easement crosses a Calder Gathering Company gathering line and requires a written crossing agreement.

Critique

Verdict
upheld
Suggested direction for the rating
same
Summary

The assessment is largely supported by its cited quotes. The SPCC, NWP 14 and crossing-agreement inputs are reasonable, and the federal-nexus absence is handled correctly. Only minor issues: unsupported labels (S-4, Parcel 7), a slightly speculative worst-case mechanism, and a few missing next steps.

Critic model
Luminol

Issues

  1. Severity minor · Kind unsupported_statement

    The labels 'S-4 road crossing' and 'Parcel 7 collection easement' do not appear in any cited quote. C-441acfa155 says only 'one access road crossing'. C-d257ecfe8e and C-f23d5887f3 name no parcel. Cite a source or drop the labels.

    Cites C-441acfa155, C-d257ecfe8e, C-f23d5887f3

  2. Severity minor · Kind overstatement

    The worst case says a preliminary jurisdictional determination or a layout change could take the crossing outside NWP 14 without notification. A PJD assumes jurisdiction and does not by itself change NWP eligibility. The trigger is a larger impact or a layout change. The Section 106 consultation chain is plausible, but the cited claims do not show it.

    Cites C-8deff0ea95, C-f5449d6a0d, C-336bf30d1a

  3. Severity minor · Kind missing_next_step

    Next steps do not mention confirming the Section 401 water quality certification or other Ohio EPA conditions for NWP use. They also do not mention OPSB as the state coordinating agency, which is absent from the agencies list. Neither is clearly evidenced in the cited claims.

    Cites C-441acfa155

  4. Severity minor · Kind unsupported_statement

    'No friction is documented' for SPCC and crossing agreements rests on silence. It is not evidence that routine processing will occur. C-d257ecfe8e does show the crossing carries a clearance requirement.

    Cites C-d257ecfe8e, C-e571f3a9eb

Checks

  • Passed

    rating_has_evidence · blocking

  • Passed

    presence_is_evidenced · not blocking

  • Passed

    counter_evidence_considered · not blocking

  • Passed

    numbers_grounded · not blocking

  • Failed

    agencies_grounded · not blocking

    Agencies not in the register or the evidence: USEPA, USACE

  • Passed

    cutoff_respected · blocking

  • Passed

    critic_not_refuted · blocking

Evidence (11)

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.

  1. No federal land, funding or federal loan program is involved.Tamsin Ridge Solar and Storage Project - Project Description · Page 1Exact
  2. The May 8, 2023 draft layout avoids all five wetlands and keeps the ODNR buffers.Wetland and Stream Delineation Report - Tamsin Ridge Solar and Storage Project · Page 3Exact
  3. The S-4 access road crossing is the only planned fill: about 40 linear feet of ephemeral channel (0.02 acre) under NWP 14.Wetland and Stream Delineation Report - Tamsin Ridge Solar and Storage Project · Page 3Exact
  4. A USACE nationwide permit is expected for one access road crossing of an ephemeral stream.Tamsin Ridge Solar and Storage Project - Project Description · Page 1Exact
  5. Parcel 7 has a gathering pipeline crossing.Parcel Schedule 2023-07-14 · Page 1Exact
  6. Cross ephemeral stream S-4 with the East Block access road on a culvert under Nationwide Permit 14, with impacts expected below 0.1 acre.Wetland and Stream Delineation Report - Tamsin Ridge Solar and Storage Project · Page 1Exact
  7. A preliminary jurisdictional determination should be requested before the OPSB application is filed.Wetland and Stream Delineation Report - Tamsin Ridge Solar and Storage Project · Page 1Exact
  8. The easement crosses the Calder Gathering Company natural gas gathering line, requiring the grantee to obtain a written crossing agreement and keep required clearance.Underground Collection Line Easement Agreement - Parcel 7 · Page 1Exact
  9. Main power transformer holds about 14,000 gallons of mineral oil, so the substation needs an SPCC plan under 40 CFR Part 112.Stormwater, Floodplain and Drainage Memo - Tamsin Ridge Solar and Storage Project · Page 2Exact
  10. The centerline crosses the Calder Gathering Company gathering line at about station 9+40 and a farm lane at station 14+05.Underground Collection Line Easement Agreement - Parcel 7 · Page 2Exact
  11. If a Corps permit with pre-construction notification is needed, the Corps will consult the SHPO and tribes under Section 106; no tribal consultation has taken place yet.Cultural Resources Literature Review and Phase I Archaeological Survey - Tamsin Ridge · Page 3Exact

Tamsin Ridge Solar and Storage Project - Project Description

C-01ec477e4b · Page 1 of 1 · DR-0001

Open the claim, C-01ec477e4b

No federal land, funding or federal loan program is involved.

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

Northfold Energy Partners, LLC - Confidential Tamsin Ridge Solar and Storage Project Project Description, Revision 3. Prepared by Northfold Energy Partners, LLC. June 12, 2023. 1. Overview The Tamsin Ridge Solar and Storage Project (the Project) is a proposed 120 MW (AC) solar photovoltaic generating facility of approximately 168 MW (DC) with a co-located 60 MW / 240 MWh battery energy storage system (BESS). Northfold Energy Partners, LLC is developing the Project through its project company, Tamsin Ridge Solar, LLC. The Project is in Harrison Township, Carroll County, Ohio, west of State Route 43 and about 4 miles northwest of the Village of Carrollton. 2. Site The Project Area covers approximately 1,140 acres on 14 parcels held by 9 landowners. The fenced area is approximately 780 acres, in a West Block and an East Block separated by the Sallow Creek valley. Land cover is cropland and hay with woodlots along Sallow Creek and on reclaimed surface-mined ground in the East Block. An existing 138 kV transmission line crosses the West Block, and natural gas gathering pipelines cross Parcels 5, 7 and 10. There are 23 residences within 1,000 feet of the fence. 3. Facility Single-axis trackers; 40 central inverters of 3.0 MW each; a 34.5/138 kV project substation and the BESS yard (about 6 acres, 60 lithium iron phosphate enclosures) on Parcel 5; underground 34.5 kV collection lines; about 9 miles of gravel access roads; perimeter fencing; and an operations building. Modules carry a hail impact rating and the trackers have an automatic hail stow mode. Structures are designed for an ASCE 7-16 basic wind speed of 115 mph and a 20 psf ground snow load. 4. Interconnection PJM queue position AH1-931; the interconnection request was submitted on September 24, 2021. The point of interconnection is the proposed Tamsin Ridge 138 kV switching station on the Transmission Owner's Vesper Hill-Ardley 138 kV line, reached by a 0.4-mile 138 kV gen-tie line. PJM issued the Feasibility Study report on April 14, 2022. The position is now in PJM's transition to its reformed interconnection process, and the next study phase has not started. 5. Permitting and schedule The Project needs a certificate of environmental compatibility and public need from the Ohio Power Siting Board (OPSB). The pre-application conference with OPSB staff was held on March 21, 2023, and the county public meeting required by ORC 303.61 was held on May 11, 2023. The OPSB application is planned for the third quarter of 2023, construction from the first quarter of 2025, and commercial operation in December 2026. Quote starts. No federal land, federal funding or federal loan program is involved. Quote ends. A U.S. Army Corps of Engineers nationwide permit is expected for one access road crossing of an ephemeral stream. 6. Site control Option-to-lease agreements cover 12 parcels, a recorded collection line easement covers Parcel 7, and Parcel 11 is not yet under agreement (see the Option and Lease Summary and the Parcel Schedule).

This document has no page picture (only PDF and image documents have one).

  1. C-01ec477e4b

    No federal land, funding or federal loan program is involved.

    Quoted from page 1
    No federal land, federal funding or federal loan program is involved.

    Tamsin Ridge Solar and Storage Project - Project Description · DR-0001 · Page 1 · 2023-06-12

    Source developer_document · Claim type absence · Polarity absence · Confidence high · Quote check exact, 100 of 100

  2. C-13ca79b38e

    The May 8, 2023 draft layout avoids all five wetlands and keeps the ODNR buffers.

    Quoted from page 3
    The draft layout dated May 8, 2023 avoids all five wetlands and keeps the ODNR buffers.

    Wetland and Stream Delineation Report - Tamsin Ridge Solar and Storage Project · DR-0013 · Page 3 · 2023-05-22

    Source developer_document · Claim type other · Polarity neutral · Confidence high · Quote check exact, 100 of 100

    Cited by AQ-01 · Filed under AQ-01, PE-02, PE-03

  3. C-336bf30d1a

    The S-4 access road crossing is the only planned fill: about 40 linear feet of ephemeral channel (0.02 acre) under NWP 14.

    Quoted from page 3
    about 40 linear feet of ephemeral channel (0.02 acre), within NWP 14 without pre-construction notification.

    Wetland and Stream Delineation Report - Tamsin Ridge Solar and Storage Project · DR-0013 · Page 3 · 2023-05-22

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

    Cited by AQ-01, EG-01 · Filed under AQ-01, EG-01, PE-03

  4. C-441acfa155

    A USACE nationwide permit is expected for one access road crossing of an ephemeral stream.

    Quoted from page 1
    A U.S. Army Corps of Engineers nationwide permit is expected for one access road crossing of an ephemeral stream.

    Tamsin Ridge Solar and Storage Project - Project Description · DR-0001 · Page 1 · 2023-06-12

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

    Cited by AQ-01, EC-01 · Filed under AQ-01, PE-03

  5. C-6f25b5bd2e

    Parcel 7 has a gathering pipeline crossing.

    Quoted from page 1
    Recorded easement; not leased; gathering pipeline crossing

    Parcel Schedule 2023-07-14 · DR-0005 · Page 1 · 2023-07-14

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

    Filed under EN-01

  6. C-8b50a6949e

    Cross ephemeral stream S-4 with the East Block access road on a culvert under Nationwide Permit 14, with impacts expected below 0.1 acre.

    Quoted from page 1
    under Nationwide Permit 14; impacts are expected to be below 0.1 acre.

    Wetland and Stream Delineation Report - Tamsin Ridge Solar and Storage Project · DR-0013 · Page 1 · 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, PE-02, PE-03

  7. C-8deff0ea95

    A preliminary jurisdictional determination should be requested before the OPSB application is filed.

    Quoted from page 1
    Request a preliminary jurisdictional determination before the OPSB application is filed.

    Wetland and Stream Delineation Report - Tamsin Ridge Solar and Storage Project · DR-0013 · Page 1 · 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, PE-03

  8. C-d257ecfe8e

    The easement crosses the Calder Gathering Company natural gas gathering line, requiring the grantee to obtain a written crossing agreement and keep required clearance.

    Quoted from page 1
    Grantee will obtain that company's written crossing agreement and keep the clearance it requires.

    Underground Collection Line Easement Agreement - Parcel 7 · DR-0003 · Page 1 · 2022-11-03

    Source public_record · Claim type constraint · Polarity presence · Confidence medium · Quote check exact, 100 of 100

    Cited by EN-01, PE-05 · Filed under EN-01, PE-03, PE-05

  9. C-e571f3a9eb

    Main power transformer holds about 14,000 gallons of mineral oil, so the substation needs an SPCC plan under 40 CFR Part 112.

    Quoted from page 2
    The main power transformer holds about 14,000 gallons of mineral oil, so the substation needs a Spill

    Stormwater, Floodplain and Drainage Memo - Tamsin Ridge Solar and Storage Project · DR-0019 · Page 2 · 2023-06-05

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

    Cited by EN-04 · Filed under EN-04, PE-03

  10. C-f23d5887f3

    The centerline crosses the Calder Gathering Company gathering line at about station 9+40 and a farm lane at station 14+05.

    Quoted from page 2
    The centerline crosses the Calder Gathering Company gathering line at about station 9+40 and a farm lane at

    Underground Collection Line Easement Agreement - Parcel 7 · DR-0003 · Page 2 · 2022-11-03

    Source public_record · Claim type extent · Polarity presence · Confidence medium · Quote check exact, 100 of 100

    Filed under EN-01, PE-03, PE-05

  11. C-f5449d6a0d

    If a Corps permit with pre-construction notification is needed, the Corps will consult the SHPO and tribes under Section 106; no tribal consultation has taken place yet.

    Quoted from page 3
    no tribal consultation has taken place yet.

    Cultural Resources Literature Review and Phase I Archaeological Survey - Tamsin Ridge · DR-0008 · Page 3 · 2023-06-30

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

    Cited by CU-01 · Filed under CU-01, PE-03

Requirements and permits

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

Federal

  • Spill Prevention, Control and Countermeasure (SPCC) Plan

    F-SPCC · U.S. Environmental Protection Agency

    Applicability
    Conditional
    Instrument
    Oil Pollution Prevention, 40 CFR Part 112
    Trigger
    Substation and inverter transformers holding oil above the threshold.
    Description

    Required where aggregate aboveground oil storage capacity exceeds 1,320 gallons (counting containers of 55 gallons or more, including oil-filled transformers) and a discharge could reach navigable waters.

    Typical timeline

    For a facility that becomes operational after 10 November 2011, the Plan must be prepared and implemented before operations begin (40 CFR 112.3(a)(1)). Typical: 2 to 6 weeks to prepare the Plan once oil-filled equipment volumes are known (basis: practice, not stated in the sources).

    As of the cut-off

    As of the cut-off: A facility that becomes operational after this date must prepare and implement its SPCC Plan before it begins operations (40 CFR 112.3(a)(1)). (2011-11-10)

    Verification
    PACK_PENDING_QUALIFIED_REVIEW
    Source
    pack:federal
    In the permit matrix
    F-SPCC
    Legal basis: 3 quotes from dated law
    Quoted from the law, page 1
    facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products, which due to its location, could reasonably be expected to discharge oil in quantities that may be harmful, as described in part 110 of this chapter, into or upon the navigable waters of the United States

    Source 40CFR112 · page 1 · version 2023-08-01

    Cited for requirement and trigger

    In force from 2021-05-25 to 2026-10-07

    eCFR versioner: 40 CFR part 112, same text on 2021-10-15, 2022-05-20, 2022-09-12, 2023-04-22, 2023-08-01 and on every amendment date between them; amendment dates 2016-12-28, 2018-02-07, 2019-10-22, 2019-12-23, 2020-04-21, 2020-06-22, 2021-05-25

    May be cited on the cut-off date.

    Quoted from the law, page 1
    The aggregate aboveground storage capacity of the facility is 1,320 U.S. gallons or less of oil. For the purposes of this exemption, only containers with a capacity of 55 U.S. gallons or greater are counted.

    Source 40CFR112 · page 1 · version 2023-08-01

    Cited for trigger: 1,320 gallon threshold

    In force from 2021-05-25 to 2026-10-07

    eCFR versioner: 40 CFR part 112, same text on 2021-10-15, 2022-05-20, 2022-09-12, 2023-04-22, 2023-08-01 and on every amendment date between them; amendment dates 2016-12-28, 2018-02-07, 2019-10-22, 2019-12-23, 2020-04-21, 2020-06-22, 2021-05-25

    May be cited on the cut-off date.

    Quoted from the law, page 1
    If such a facility (excluding oil production facilities) becomes operational after November 10, 2011, and could reasonably be expected to have a discharge as described in § 112.1(b), you must prepare and implement a Plan before you begin operations.

    Source 40CFR112 · page 1 · version 2023-08-01

    Cited for timeline: Plan before operations

    In force from 2021-05-25 to 2026-10-07

    eCFR versioner: 40 CFR part 112, same text on 2021-10-15, 2022-05-20, 2022-09-12, 2023-04-22, 2023-08-01 and on every amendment date between them; amendment dates 2016-12-28, 2018-02-07, 2019-10-22, 2019-12-23, 2020-04-21, 2020-06-22, 2021-05-25

    May be cited on the cut-off date.

Also in the permit matrix for this row: F-NEPA, OH-DECOM, OH-DAM, OH-FIRE, OH-BLDG

Information requests

  • IR-09b3f986d4 · Medium priority

    Provide the evidence of federal land, funding or permits for the project area, or confirm none exists.

    Missing evidence
    Evidence of federal land, funding or permits
    Consequence
    Other is rated on partial evidence without it.
    Blocks the decision
    No
    Raised by
    completeness

Next steps

  • Confirm SPCC applicability, including discharge-to-navigable-waters trigger, and prepare the plan.
  • Obtain the Calder Gathering crossing agreement and confirm clearances.
  • Request a preliminary jurisdictional determination, confirm NWP 14 eligibility, and confirm how OPSB process coordinates USACE and Section 106 steps.

Agencies

  • USEPA
  • USACE
  • Calder Gathering Company

Cost and impact

Impact
C
Potential cost level
L
Why

Plan preparation, one nationwide permit verification and a crossing agreement with clearance requirements are small costs against a utility-scale budget.

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