Preliminary Vegetation Management Plan
Crossroads Solar Grazing Center Morrow County, Ohio
Prepared for:
Crossroads Solar I, LLC 1105 Navasota Street Austin, Texas 78702
Prepared by:
Verdantas LLC
6397 Emerald Pkwy, Suite 200 Dublin, Ohio 43016
720-248-0989
Verdantas Project No: 17078
May 2025
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Tables
Table of Contents (Continued)
Table 1 NRCS Soil Map Units within the Project Area
Table 2 Fuzz & Buzz Mix – Premium – ERNMX-147
Figures
Figure 1 Project Location Map
Figure 2 Land Cover Map
Figure 3 Project Vicinity Map
Figure 4 Natural Resources Conservation Service Soils Map
Appendices
Appendix A Ohio Administrative Code 901:5-30 Invasive Plant Species and 901:5-37
Prohibited Noxious Weeds
1. Introduction
1.1 Project Overview
This Preliminary Vegetation Management Plan (“Plan”) has been prepared for the Crossroads Solar Grazing Center (“Crossroads”). Crossroads is proposing to construct a combined utilityscale solar energy and sheep grazing facility in Cardington, Lincoln, and Westfield Townships in Morrow County, Ohio (the “Project” or the “Facility”; Figure 1). The Project will use rows of groundmounted solar panels to supply up to 94 megawatts AC (MWac) of wholesale power to the existing electric grid while also providing pasture for livestock. All of the Project’s above-ground infrastructure will be located within agricultural-style fences, which also will confine the livestock and protect them from predators. The fenced area will be up to 559 acres (the “Solar & Grazing Area”) of an area totaling approximately 726 acres (the “Project Area”).
1.2 Purpose and Intent
Preservation of agriculture is of the utmost importance to Crossroads, the state of Ohio, participating landowners, and the local community. The following vegetation management recommendations and guidance were developed based on community considerations and using the following primary objectives:
Minimize land use impacts by designing, establishing, and maintaining the Facility as dual solar-agricultural land use (also known as agrivoltaics or solar grazing).
Establish a cover of dense, deep-rooted vegetation to protect soil from surface erosion and develop a soil structure that promotes water storage, uptake, and infiltration (OEPA, 2022). The Ohio EPA Guidance on Post-Construction Stormwater Management for Solar Panel Fields specifies expectations for a vegetation management plan for a facility utilizing disconnection as a means of post-construction stormwater management.
Satisfy all of the application requirements of the Ohio Power Siting Board (OPSB) for the Project related to the protection of vegetation and vegetation management, which are the following:
a. Section 4906-4-08(B)
1. (2)(a)(iv) –“A description of how such [vegetative] clearing work will be done so as to minimize removal of woody vegetation and reduce forest fragmentation.”
2. (2)(b)(i) –“Plans for post-construction site restoration and stabilization of disturbed soils, especially in riparian areas and near wetlands…”
3. (2)(b)(v) –“Methods to protect and plans for restoration of vegetation in proximity to any project facilities from damage, particularly mature trees, wetland vegetation, and woody vegetation in riparian areas.”
4. (2)(b)(vi) –“Options for disposing of downed trees, brush, and other vegetation during initial clearing for the project, and clearing methods that minimize the movement of heavy equipment and
other vehicles within the project area that would otherwise be required for removing all trees and other woody debris off site.”
5. (3)(b)(ii) –“Methods for protecting streams, wetlands, and vegetation, particularly mature trees, wetland vegetation, and woody vegetation in riparian areas.”
6. (4) –“A description of any mitigation procedures to be used during construction, operation, and maintenance of the proposed facility to minimize the impact on vegetation…”
7. (5) – “A description of anticipated actions to prevent the establishment and/or further propagation of noxious weeds identified in rule 901:5-37 of the Administrative Code during implementation of any pollinator-friendly plantings.”
b. Section 4906-4-09(A)
1. (3)(c) – “The applicant shall have a vegetation management plan. The plan must identify all areas of proposed vegetation clearing for the project, specifying the extent of the clearing, and describing how such clearing work will be done so as to minimize removal of woody vegetation. The plan must also describe how trees and shrubs around structures, along access routes, at construction staging areas, during maintenance operations, and in proximity to any other project facilities will be protected from damage. Priority should be given to protecting mature trees throughout the project area, and all woody vegetation in wetlands and riparian areas, both during construction and during subsequent operation and maintenance of all facilities; low-growing trees and shrubs in particular should be protected wherever possible within the proposed right-of-way. The vegetation management plan should also explore various options for disposing of downed trees, brush, and other vegetation during initial clearing for the project, and recommend methods that minimize the movement of heavy equipment and other vehicles within the right-of-way that would otherwise be required for removing all trees and other woody debris off site.”
2. (3)(d) – “For both construction and future right-of-way maintenance, the applicant shall limit, to the greatest extent possible, the use of herbicides in proximity to surface waters, including wetlands and along the right-of-way. Individual treatment of tall-growing woody plant species is preferred, while general, widespread use of herbicides during initial clearing or future right-of-way maintenance should only be used where no other options exist, and with prior approval from the Ohio environmental protection agency. Prior to commencement of construction, the applicant shall describe the planned herbicide use for all areas in or near any surface waters during initial project construction and/or future right-of-way maintenance.”
2. (3)(e) – “The Applicant shall prevent the establishment and propagation of noxious weeds identified in Ohio Administrative
Code Chapter 901:5-37 in the project, including its setback areas, during construction, operation, and decommissioning via procedures and processes specified and required by the project’s vegetation management plan. The Applicant shall provide annual proof of weed control for the first four years of operation, with the goal of weed eradication significantly completed by year three of operation.”
The following vegetation management recommendations and guidance were developed for the Project by Verdantas LLC (Verdantas) with the intent of establishing a cool-season pasture mix that supports sheep herds. Sheep are planned to be used as the primary form of vegetative maintenance on-site.
When designed and executed correctly, dual solar-agricultural land use can contribute to shortterm and long-term farm viability. The land is anticipated to remain in agricultural use over the lifespan of the Project by supporting lamb production. Additionally, cool-season pasture mixes in combination with sheep can benefit biodiversity, provide habitat for pollinators and wildlife, reduce soil erosion, increase soil health over time, sequester carbon, and reduce air pollution over time. The scope of this Plan is limited to the establishment and maintenance of vegetative ground cover within the fence line of the Project.
1.3 Related Plans
There are several related plans that have been developed in support of the Project that are designed to be used in conjunction with this Plan. These plans include:
▶ The Project’s agricultural soils management plan describes the recommended steps to avoid and minimize construction-related impacts to agricultural soils. This includes methods for baseline (pre-construction) soil testing, followed by periodic soil testing throughout the life of the Project. Adaptive management measures are proposed to help restore soils to original condition or better upon the decommissioning of the Project.
▶ The preliminary landscape plan developed for the Project provides for the establishment and maintenance of visual mitigation vegetation outside of the fence line within buffer areas.
▶ The drain tile assessment identifies, to the extent practicable, the location of existing agricultural drain tiles so that they can be avoided, modified, or augmented when designing and constructing the Project.
▶ The stormwater assessment explains stormwater-related requirements, describes erosion control and sediment management requirements applicable during construction, and provides a comparison of existing stormwater runoff characteristics of the Project Area to postconstruction condition stormwater runoff characteristics.
▶ The preliminary grazing plan details how sheep will be managed at the site. The plan includes considerations and details for flock characteristics, facility design, sheep nutritional and water requirements, internal parasite mitigation, and animal welfare and predation.
2. Existing Conditions, Project Infrastructure, and Plan Goals
Establishment and maintenance considerations for dual solar-agricultural land use projects are informed by evaluating existing site conditions, planned construction techniques/infrastructure, and project goals. This section provides an overview of factors that informed the development of this Plan.
2.1 Existing Site Conditions
Existing conditions, such as land use history, topography, soil conditions, hydrology, existing vegetation, and the potential for sensitive resources were reviewed. The Project Area is rural and largely characterized by medium- to large-sized farms with minimal surface water features and woodlots. The Project Area does not include any population centers, major industries, or notable landmarks, but is located approximately 1-mile south of the Village of Cardington.
Historical aerial imagery and the U.S. Geological Survey (USGS) 7.5-minute topographic quadrangle for Ashley, Ohio (1963) confirm past land use was predominantly agricultural. No signs of significant soil disturbance, like mines, pits, or major earthworks were observed on the topographic mapping or aerial imagery. Topography within the Project Area is generally flat with minor topographical changes near water courses.
Current land cover characteristics were assessed using the 2021 National Land Cover Database. Based on review of these data, the area is dominated by cultivated crops, with minor components of deciduous forest, developed open space, and low intensity development Woody wetlands, high intensity development, pasture/hay, shrub/scrub, and medium intensity development all comprise less than one percent of land cover within the Project Area (Figure 2). A field investigation confirmed the majority of the Project Area is currently used for the agricultural production of corn (Zea mays) and soybean (Glycine max).
Woodlots and fringe woody habitat are primarily scattered along field edges throughout the Project Area (Figure 3). Upland forest stands support mixed hardwood species such as northern red oak (Quercus rubra), pin oak (Quercus palustris), and common hackberry (Celtis occidentalis) The understories tended to be dominated by invasive species such as bush honeysuckle (Lonicera spp.) and multiflora rose (Rosa multiflora). Species most commonly found in upland herbaceous areas were Japanese bristlegrass (Setaria faberi), white clover (Trifolium repens), and horehound (Marrubium vulgare)
Forested wetlands support species such as American elm (Ulmus americana), pin oak (Quercus palustris), silver maple (Acer saccharinum), and black willow (Salix nigra). Reed canary grass (Phalaris arundinacea) is the most commonly encountered herbaceous species within wetlands. Reed canary grass is also commonly encountered in upland agricultural hedgerows across the Project Area. This species is identified as invasive per the Ohio Administrative Code 901:5-3001 and may require proactive management.
The U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Web Soil Survey (WSS) of Morrow County, Ohio was used to identify the soil types and hydric ratings of soils located within the Project Area. Soil physical properties, including texture, compaction, confining layers, drainage class, and nutrient availability inform what suite of plant species will establish successfully on-site. The soils are typical silt loams and silty clay loams of farmland in the region (Table 1; Figure 4). Approximately 45% of the Project Area supports predominantly hydric soils. Hydric soils are defined by the National Technical Committee for
Hydric Soils (NTCHS) as soils that formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part (Federal Register, 1994). These soils, under natural conditions, are either saturated or inundated long enough during the growing season to support the growth and reproduction of hydrophytic vegetation.
Table 1. NRCS Soil Map Units within the Project Area
Blount silt loam, ground moraine, 0 to 2 percent slopes
Gwg1B1 Glynwood silt loam, ground moraine, 2 to 6 percent slopes
silty clay loam, 0 to 2 percent
Blount silt loam, ground moraine, 2 to 4 percent slopes
Sloan silty clay loam, sandy substratum, occasionally flooded
Gwg5C2 Glynwood clay loam, ground moraine, 6 to 12 percent slopes, eroded
GaB Gallman silt loam, loamy substratum, 2 to 6 percent slopes
Nonhydric
Nonhydric
Nonhydric
Wetlands, riparian stream corridors, forested areas, the presence of special status species, and wildlife habitat are all sensitive resources that require consideration. Wetlands, forest stands, and wildlife habitat were all identified within the Project Area. Only limited tree clearing is planned for construction of the Project, as large forest stands are planned to be avoided, with clearing limited to hedgerows and isolated pockets of trees.
The Project is proposed to be primarily built on land that has been cleared and is actively maintained for agriculture. Cool-season pasture mixes are anticipated to increase biodiversity, provide pollinator support, and provide habitat for some types of wildlife (such as birds) within the Project Area.
2.2 Planned Project Infrastructure
Because the site may return to row crop production following decommissioning, strategies intended to minimize the impact of the solar infrastructure on agricultural productivity and general soil health are of the utmost consideration.
Vegetation design, installation, establishment, and maintenance must be balanced with the functioning of a utility-scale solar energy facility. This Plan is designed to flexibly address vegetation installation, establishment, and maintenance limitations that may be posed by infrastructure on-site. Considerations will be made for inter-row spacing, panel height (minimum distance from the leading edge of the panel to the ground surface), access roads, fence lines, stormwater BMPs, and other infrastructure planned to be a part of the Project.
Sheep are well-suited for solar energy facilities, with the ability to access all vegetative portions of the site at carefully-timed intervals (through rotational grazing). Infrastructure barriers to mowing (inter-row spacing, panel height, the presence of aboveground cable management systems, etc.) are not an obstacle to using sheep to manage vegetation, as they are able to freely move around above-ground systems and underneath panels. Although sheep are planned to be the primary mode of vegetation maintenance on-site, provisions for mowing when necessary are included in the Plan
2.3 Project Goal Considerations
Unique design considerations are associated with using sheep as the primary form of vegetation maintenance at a solar farm. The following BMPs are considered in this Plan:
▶ Selection of appropriate permanent seed mix that provides both stormwater management (e.g. erosion control) and forage.
▶ Close coordination with the shepherd prior to implementing vegetation strategies at the Facility, to enable the overall health and nutrition of the flock.
3. Site Preparation and Installation
This section provides guidelines for the successful installation, establishment, and maintenance of vegetation at the Facility during Project construction. Although a high-level analysis of site characteristics informed development of this Plan, it is important to acknowledge that site characteristics and conditions are anticipated to vary somewhat across the Project Area due to the scale of the project (i.e., “microclimates” will be encountered). The Plan is meant to be a living document that adapts to the establishment trajectory of the site, and as such should be updated as necessary to ensure successful outcomes.
3.1 Vegetation Protection, Avoidance, and Minimization
Project infrastructure is sited to avoid and minimize impacts to existing woody and vegetative buffers, natural vegetation, and wildlife habitat to the greatest extent feasible. Wetlands, riparian stream corridors, forest stands, buffers from adjacent properties, and other sensitive resources are recommended to be avoided during construction with the appropriate setbacks.
The Project’s final site plan will identify the limits of construction. The following vegetation-related guidance should be addressed prior to the commencement of construction:
▶ Any applicable time-of-year (TOYR) cutting or clearing restrictions, as detailed in the wildlife assessment for the Project.
• Per ODNR guidance, grasslands and marshlands (i.e. habitat for northern harrier) should be avoided between April 15 through July 31.
• Per ODNR guidance, tree cutting/clearing should only occur from October 1 through March 31.
▶ Identify, locate, and determine extent of vegetation that should be preserved within the Project Area (Vegetation Protection Areas). This could include large woodlots, woody vegetation within wetlands, existing vegetative buffers that provide screening from adjacent properties, and specimen trees (i.e. mature individuals or small groups of trees).
▶ Coordinate any construction-related constraints posed by these Vegetation Protection Areas, such as construction movement around the site, limitations for trenching, or the need to provide construction oversight.
Vegetation Protection Areas
Vegetation Protection Areas may consist of large woodlots, woody vegetation within wetlands, existing vegetative buffers that provide screening from adjacent properties, and specimen trees (i.e. mature individuals or small groups of trees). Documentation of Vegetation Protection Areas could include photographs and notes relating to pre-construction condition. Careful attention should be paid to documenting pre-existing damage to vegetation. For the most part, Vegetation Protection Areas are anticipated to be located outside of the areas that would ultimately be fenced. Once identified, Vegetation Protection Areas should be marked off with high visibility construction fencing. The fencing should be placed at least 1.5 times the drip line diameter of the vegetation being protected to prevent damage to the critical root zone through compaction.
Upon construction commencement, erosion and sediment control and vegetation protection materials should be installed according to the Project’s Storm Water Pollution Prevention Plan (SWPPP) and National Pollutant Discharge Elimination System (NPDES) permit. Vegetation Protection Areas should be avoided. Construction pathways, materials, debris, structures,
ground-disturbing activities, and foot traffic should remain outside of the Vegetation Protection Areas. If damage occurs to protected vegetation, a certified arborist should be consulted to determine if repair or replacement is needed.
Vegetation Clearing and Removal
Selective clearing and removal of vegetation should only occur within the construction limits of disturbance and only as necessary for construction and operation of the facility. For the location of expected vegetation clearing, see Figure 9 in the Project’s Application to the Ohio Power Siting Board for a Certificate of Environmental Compatibility and Public Need. The expected acreage of vegetation clearing is identified in Section 3.1.2 of the Ecological Impact Assessment prepared for the Project. Clearing may occur using a variety of methods to limit the use of heavy equipment and minimize disturbance to protected vegetation:
1. Manual clearing using hand tools such as shovels, rakes, and clippers can be used for smaller areas where there is limited access.
2. Chemical clearing using herbicides can be used to remove dense plant growth, such as for the removal of noxious weeds or invasive plants.
3. Mechanical clearing using heavy machinery can be used to quickly clear large areas, and for removing large debris like tree stumps and rocks.
Vegetation should be segregated from other types of construction debris (such as concrete and metals) and legally disposed of following all federal, state, and local guidelines.
3.2 Temporary Vegetation
During construction and subsequent maintenance activities, temporary stabilization (e.g., seeding and mulching) should be implemented to minimize soil erosion. Best management practices (BMPs) that include temporary vegetation are expected to be outlined in the Project’s SWPPP that is required as part of Ohio Environmental Protection Agency’s (Ohio EPA) General Permit for Discharges of Storm Water Associated with Construction Activity (Ohio EPA Permit No.: OHC000005).
3.3 Permanent Vegetation
The seed mix selection should focus on the primary goals of (1) maintaining permanent vegetative cover for erosion control and stormwater management, and (2) robust forage for grazing sheep. The following items should be considered:
1. Permanent vegetation needs to adequately stabilize the site for the purposes of stormwater management (OEPA, 2022).
2. Permanent vegetation needs to provide adequate forage for sheep.
3. Permanent vegetation should not interfere with the operation of the Project. For example, grasses at full stand height should not shade solar panels.
4. Permanent vegetation should be regionally appropriate and account for site-specific conditions, such as project location, slope, soil characteristics, hydrology, and other factors.
5. If feasible, native species, or non-native species with beneficial properties, should be prioritized as a part of the mix.
The shepherd (person responsible for managing vegetation on-site via flocks of sheep) should be consulted prior to final seed mix selection to ensure compatibility with the flocks. Seed mixes should be purchased from an experienced reputable supplier and be appropriately certified following state requirements. Seed certification tags should be furnished to Crossroads for review.
The Ohio State University Extension published guidance for forage as vegetation cover for utilityscale solar in Ohio and includes a list of perennial cool-season grasses and legumes (Gelley et al. 2012). The guidance should be referenced when selecting the permanent seed mix for the Site, however, it addresses species application rates and depths separately and not as a single seed mix. A good seed mix design can result in stable, weed-free permanent vegetation. High quality seed mixes include both warm and cool-season grasses; legume and non-legume forbs; annuals, biennials, and perennials; considers abiotic factors such as soil texture, pH, light requirements, slope, and aspect; and finally, considers overall cost of the mix. The Ohio EPA Guidance on Post-Construction Stormwater Management for Solar Panel Fields recommends including rapidly establishing species in the permanent seed mix or supplementing the mix with a temporary cover.
The Ernst Fuzz and Buzz Premium Mix (ERNMX-147) follows the principles of forage as vegetation cover and is suggested as an example of an appropriate seed mix selection for the Project. Inclusion of this sample mix in the Plan is not intended to indicate its final selection onsite, which should be informed based upon the considerations outlined above and in conjunction with the Ohio State University Extension Guidance. ERNMX-147 itself was developed in collaboration with professional solar shepherds from the American Solar Grazing Association (ASGA) and incorporates wildflowers to a greater degree than most cool-season pasture mixes, providing an ancillary benefit to pollinators and increasing diversity. ERNMX-147 is presented in Table 2.
Table 2 Fuzz & Buzz Mix – Premium – ERNMX-147
Table reproduced from ERNMX-147 Fact Sheet downloaded November 20, 2024. 1PLS, Seeds/SF, and Seeds/OZ are provided upon receiving quote from seed supplier.
3.4 Sequence of Events for Site Preparation and Installation
When feasible, landowners should be interviewed about herbicide treatment history on croplands. Certain residual herbicides can interfere with the ability for all or portions of the seed mix to germinate and establish. It is important to know if residual herbicides are present on-site so that alternative strategies can be adapted for these areas prior to seed mix installation.
The timing of site preparation and installation is dependent on construction schedule. Ideally, seeding for cool-season grass pasture would occur in the late summer-early fall before first frost. Alternatively, the permanent seed mix could be installed in early spring just before the last frost. The average frost-free growing season for the Project Area is mid-April through the end of October. Sources of guidance for seeding, mulching, watering, mowing, and repairing include Chapter 7 of Ohio Department of Natural Resources’ Ohio Rainwater and Land Development Manual and Ohio Department of Transportation’s (ODOT) Item 659 Seeding and Mulching.
Per Ohio EPA Guidance on Post-Construction Stormwater Management for Solar Panel Fields, if feasible, seeding should occur prior to infrastructure installation (aka: “pre-construction seeding”) as a measure to help control erosion during construction and to speed the establishment of a permanent cover post-construction. If pre-construction seeding occurs for this Project (which would be determined based on the time of year construction is set to begin), assume 20-30% of the site will need to be reseeded post-construction to establish adequate permanent vegetative cover.
Soil samples may be taken to aid the selection of potential soil amendments to ensure establishment of strong, healthy vegetation. Samples can be analyzed for pH, organic content, and macronutrient content (nitrogen, phosphorous, and potassium). Refer to the Project’s agricultural soils management plan for specific soil testing methodology on-site. Phosphorus should not be applied at the time of planting unless soil testing indicates a plant-limiting phosphorous deficiency. If tests indicate a phosphorous deficiency that will impact establishment
of vegetation, then phosphorous may be applied at the minimum recommended level prescribed in the soil test following all applicable standards, requirements, and regulations.
Areas where the soil has been compacted by construction activities are planned to be decompacted prior to placing topsoil and preparing the seed bed. The level of decompaction required should be assessed based on soil profile characteristics such as soil texture and moisture, and infrastructure constraints such as depth to buried utilities. Decompaction can be performed with a disk for shallow compaction, or a winged subsoiler or straight ripper shank for areas compacted to greater depths.
Stockpiled topsoil should be redistributed in areas that received grading. Topsoil should be placed to a minimum depth of four inches where necessary to establish ideal planting conditions.
Existing vegetation should be assessed prior to seed mix installation for weed pressure. Weed control is critical to ensure that the permanent seed mix is not outcompeted by undesirable vegetation once installed. If herbicides will be applied for weed control, then application should occur at least two weeks prior to seeding. The appropriate herbicide should be selected based on the types of weeds on-site and their growth stage. Environmental conditions such as wind, temperature, and moisture, and certain soil conditions such as PH and organic matter, should be considered when selecting the appropriate herbicide and choosing the best time of application. The current Weed Control Guide for the region can be used as a source of information to inform the correct selection (OSU CFAES, 2025). All herbicides should be applied according to label instructions. One application would likely be sufficient since the land has been recently used for crop production.
Existing vegetation that is planned to remain should be roughly mowed to just above ground surface to allow for overseeding. Existing vegetation will shade out new seedlings, so it is important to mow as close to the surface as feasible without removing the root crown. In areas where vegetation has been removed, the seedbed should be roughened prior to installation to provide good seed-to-soil contact.
A broadcast seeder or seed drill could be used to install the permanent seed mix. The key to successful germination is good seed-to-soil contact, with seeds no deeper than ¼ inch in the soil. The permanent seed mix should be applied according to seed supplier recommendations, including selection of the type of cover crop that should be installed alongside the permanent mix. Seeding rates should be adapted according to the chosen seeding method and the time of year (for example, broadcast seeding usually occurs at twice the rate of seed drilling). If broadcast seeding, a roller or light raking should be used to ensure the seed has good contact with the soil. A certified weed-free straw mulch should be applied to help the soil retain moisture, to hold seed in place, and to protect seed from predation. Once seeded, spot treatment of weeds should be completed manually or using herbicide.
4. Vegetation Maintenance
This section provides methods for short-term and long-term maintenance of vegetation upon completion of construction of the Facility.
4.1 Short-Term Maintenance Practices
4.1.1 Inspection and Maintenance of Vegetation
Newly seeded areas should be inspected periodically to ensure appropriate establishment. At a minimum, inspections should occur within six months following application, and in the spring, summer, and fall thereafter. Areas with less than 70% growth density, based on visual inspection, should be repaired or reseeded (ODNR 2006). Overseeding to repair bare spots should be completed annually between March 15 and May 15 or between September 1 and October 15 per ODOT’s Item 659 Seeding and Mulching. Areas that continue to exhibit poor germination should be assessed to determine if additional remediation practices, such as further soil amendments or greater decompaction, are necessary.
4.1.2 Invasive Weed Control, Monitoring, and Management
The Project Area should be monitored after construction, when the site is most vulnerable to colonization by invasive vegetation and noxious weeds, as defined in Ohio Administrative Code 901:5-30 and 901:5-37. The list of Invasive Plant Species, Prohibited Noxious Weeds, and some of the most common noxious weeds are included in Appendix A. Invasive species and weeds should be controlled using methods deemed appropriate for maintenance of the solar array and soil integrity (e.g., herbicide, manual removal).
4.1.3 Success Criteria
Upon completion of construction, documentation of the final permanent seed mix selection and placement of seed should be provided to Crossroads. The Project construction and development area should be permanently revegetated with the species present within the designated seed mix at a threshold of at least 70% growth density, based on visual inspection.
4.2 Long-Term Maintenance Practices
During operation, maintenance activities for the Facility are anticipated to primarily occur within and just outside of the fence line, and heavy equipment will not likely need to traverse areas of woody vegetation. As such, protective measures such as fencing or marking are not anticipated to be necessary during operation. The Applicant may preserve existing (post-construction) woody vegetation within the final leased area for the Facility, in accordance with this Plan. During operation, removal of woody vegetation within the fenced area is anticipated to be limited to new vegetative growth that could prohibit growth of desired vegetation, shade the solar panels, or otherwise interfere with the operation of the Facility.
4.2.1 First-Year Maintenance of Vegetation
The goal of the first year is to encourage establishment of the permanent seed mix by proactively treating invasive and weedy species on-site. Sheep are planned to be used as the primary mode
of vegetation management on the site; however, vegetation must be fully established such that it is well-rooted, and erosion and sediment control stabilization requirements are met prior to sheep entering the Facility. Depending on the timing of permanent seed mix installation and the climatic conditions following installation, the pasture should rest for between six months and a year for this condition to be met. If pre-construction seeding was able to occur on-site and permanent vegetation appears fully established, sheep may be introduced to the Facility any time between one to six months post-construction. Sheep can be added to the Facility earlier than these suggested timelines if they are introduced gradually (i.e. use a lower stocking rate appropriate to the establishing vegetation, with an increase in the stocking rate as the vegetation establishes over time). Refer to the Project’s preliminary grazing plan for more details regarding flock introduction.
Until sheep are introduced to the Facility and/or during the establishment period while sheep are being gradually added to the Facility, mowing may be required to control the establishment of non-native vegetation and to maintain access to the solar infrastructure. If vegetation is taller than 6 inches in the early spring, Verdantas recommends mowing should occur prior to the peak breeding season for local bird species (usually no later than May 10). Mowing should occur to a height no lower than six inches to prevent scalping of the vegetation. Subsequent mowings should occur as needed based on how quickly the stand reaches a height that could conflict with Facility infrastructure (usually between 12-24 inches tall). It is Verdantas’ recommendation to delay mowing until fall to allow time for seed to set and for activities to occur outside the peak breeding season for local birds (May 10 – August 31 per USFWS information). If mowing must occur during this window, Verdantas recommends referencing the Nationwide Avoidance and Minimization Measures for Birds (USFWS, 2024). Expect to mow the site two or three times throughout the growing season to help control establishment of undesirable vegetation that may shade out the permanent seed mix as it grows.
Invasive species and noxious weeds should be continually eliminated throughout the season to prevent potential on-site seed sources that may become problematic. Invasive species and weed treatments should use methods deemed appropriate for maintenance of the solar array and soil integrity (e.g., herbicide spot sprays, manual removal). Due to the persistence of invasive and weedy species, a second application of herbicide may be needed based on on-site observations. Herbicide application should only occur when necessary.
4.2.2 Subsequent Maintenance of Vegetation
4.2.2.1
Sheep Grazing
The primary objectives of long-term vegetation maintenance on-site are to maintain at least 70% growth density of permanent vegetation, based on visual inspection, and to control invasive and weedy species. Once the pasture has been allowed adequate time to rest, sheep may be added to the Facility as the primary mode of vegetation maintenance. The Project’s agricultural integration plan contains a grazing plan, which is the primary guiding document regarding the use of sheep at the Facility. The grazing plan allows the shepherd to organize the site, allocate resources, determine stocking rate/sustainability, and plan for level of effort needed to reach the Site’s long-term goals. This section describes vegetation-related considerations related to the grazing plan and use of sheep on-site.
Prior to the addition of sheep, Crossroads and the shepherd should walk the site together. Agreements should be made on who will fence off items that would be in danger of being damaged by sheep and areas that sheep should be excluded from (such as wetlands); how deficiencies in the perimeter fencing will be addressed (if present); vehicle/trailer ingress and egress plans to
avoid compaction of soil and damage of vegetation; and other site-specific concerns. Provisions should be made for the shepherd to access the site 24/7. If other contractors are on-site regularly, Crossroads should facilitate meetings between the shepherd and those individuals.
If sheep are added to the site during the spring, the shepherd should monitor soil saturation and wait to introduce flocks until the ground is dry enough to avoid trampling damage. A rotational grazing management system is planned to be used to control vegetation height, manage invasive and woody vegetation, and maintain desirable forage material. The size, orientation, and stocking rate of paddocks should be determined based on industry BMPs.
To prevent overgrazing, the residency period of a flock within a given paddock should generally be determined based on “start grazing” and “stop grazing” vegetation heights. The maintenance of residual vegetative cover heights is described in the preliminary grazing plan prepared for this project. Care should be taken to ensure no permanent damage is caused by hooves to soils during periods of saturation.
Vegetation should be 6 inches or less in the early spring. If not, Verdantas recommends grazing or mowing prior to the peak breeding season for local bird species (usually no later than May 10). Verdantas recommends following the Nationwide Avoidance and Minimization Measures for Birds if activities must occur during this window (USFWS, 2024).
4.2.2.2 Weed Whipping and Mowing for Managing Vegetation
Although sheep are highly effective at managing vegetation, the results of grazing will not yield a uniform-height lawn as traditional mowing practices do. Weed whipping along fence lines, pilings, and other areas of infrastructure likely will be needed to reduce conflicts with vegetation. Weed whipping usually coincides with mowing events but can occur at any time of the year.
Mowing may still be needed in certain areas of the Site where sheep are not permitted. If vegetation is taller than 6 inches in the early spring, Verdantas recommends mowing prior to the peak breeding season for local bird species (usually no later than May 10). Mowing should occur to a height no lower than six inches to prevent scalping of the vegetation. Subsequent mowings should occur as needed based on how quickly the stand reaches a height that could conflict with Facility infrastructure (usually between 12-24 inches tall). If feasible, Verdantas recommends delaying mowing until fall to allow time for seed to set and for activities to occur outside the peak breeding season for local birds (May 10 – August 31 per the USFWS IPaC). If mowing must occur during this window, Verdantas recommends following the Nationwide Avoidance and Minimization Measures for Birds (USFWS, 2024). Expect to mow the site once or twice during the growing season.
4.2.2.3
Invasive and Weedy Species Control
Invasive species and noxious weeds should be controlled using methods deemed appropriate for maintenance of the solar array and soil integrity (e.g., herbicide, manual removal). All herbicides that will be used on-site should be screened for grazing withhold times. Herbicide application should only occur when necessary and should be discontinued at least one year prior to decommissioning to ensure breakdown of residual herbicides prior to return to agricultural production (Cleveland & Sarkisian, 2019).
4.2.2.4
Inspection and Maintenance of Vegetation and Topsoil
Over the life of the Project, the site should be inspected regularly; usually once per season is sufficient. Areas with less than 70% growth density, based on visual inspection, should be
repaired or reseeded. Overseeding to repair bare spots should be completed annually between March 15 and May 15 or between September 1 and October 15 per ODOT’s Item 659 Seeding and Mulching. Areas that continue to exhibit poor germination should be assessed to determine if additional remediation practices, such as further soil amendments or greater decompaction, are necessary.
5. References
A variety of technical documents and publications were referred to during the course of this project. Some of the references consulted are presented below. References documents and publications may or may not have been reviewed in their entirety. The guidelines and procedures presented in the documents and publications referenced have not been strictly adhered to unless stated otherwise.
Cleveland, T., & Sarkisian, D. 2019. Balancing Agricultural Productivity with Ground-Based Solar Photovoltaic (PV) Development. Raleigh, NC: NC State University.
Crossroads Solar Grazing Center. Application to the Ohio Power Siting Board for a Certificate of Environmental Compatibility and Public Need. August 2025. Available at: https://dis.puc.state.oh.us/CaseRecord.aspx?CaseNo=25-0142-EL-BGN
Crossroads Solar Grazing Center. Ecology Impact Assessment. August 2025. Available at: https://dis.puc.state.oh.us/CaseRecord.aspx?CaseNo=25-0142-EL-BGN
Ernst Conservation Seeds. 2024. Fuzz & Buzz Mix – Premium – ERNMX-147. Retrieved from: https://www.ernstseed.com/.
Gelley, C., J. Morris, and E. Romich. 2021. Forage as Vegetative Cover for Utility-Scale Solar in Ohio. Ohioline, Ohio State University Extension. Retrieved from: https://ohioline.osu.edu/factsheet/cdfs-4106
Ohio Department of Natural Resources. 2006. Ohio Rainwater and Land Development Manual. Columbus: Division of Soil and Water Conservation.
Ohio Department of Transportation. 2020. Item 659 Seeding and Mulching. Retrieved from Construction Management: http://www.dot.state.oh.us/Divisions/ConstructionMgt/OnlineDocs/Specifications/2008C MS/600/659.htm#a_659_02
Ohio EPA. 2022. Guidance on Post-Construction Stormwater Management for Solar Panel Fields. Ohio State University College of Food, Agricultural, and Environmental Sciences. 2025. Weed Control Guide for Ohio, Indiana, Illinois, and Missouri. Document Number ANR-789/WS16/IL15/M171.
U.S. Department of Agriculture (USDA). 2024. Web Soil Survey. Retrieved from: http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx
U.S. Fish and Wildlife Service (USFWS). 2024. Nationwide Avoidance and Minimization Measures for Birds
U.S. Geological Survey (USGS). 2024. The USGS 3D Hydrography Program (3DHP). Retrieved from: https://hydro.nationalmap.gov/arcgis/rest/services/3DHP_all/MapServer
USGS. 1963. Topographical quadrangle maps (7.5-minute series). Ashley, Ohio quadrangle. U.S. Department of the Interior. Washington, D.C.
Figures
Figure 1 Project Location Map
Figure 2 Land Cover Map
Figure 3 Project Vicinity Map
Figure 4 Natural Resources Conservation Service Soils Map
Appendix A
Ohio Administrative Code 901:5-30 Invasive Plant Species and 901:5-37 Prohibited Noxious Weeds
Ohio Administrative Code
Rule 901:5-30-01 Invasive plant species.
Effective: February 13, 2023
(A) In order to protect native plant species and thwart the growth of invasive plant species, the director of the Ohio department of agriculture pursuant to section 901.50 of the Revised Code hereby declares the plants listed in paragraphs (A)(1) to (A)(63) of this rule as invasive plants. The invasive plants are first designated by the plant's botanical name and then by the plants common name. The botanical name is the official designation for the plant.
(1) Ailanthus altissima, tree of heaven;
(2) Alliaria petiolata, garlic mustard;
(3) Ampelopsis brevipedunculata, porcelainberry;
(4) Azolla pinnata, Pinnate mosquitofern;
(5) Berberis vulgaris, common barberry;
(6) Butomus umbellatus, flowering rush;
(7) Celastrus orbiculatus, Asian bittersweet;
(8) Centaurea stoebe ssp. micranthos, spotted knapweed;
(9) Dipsacus fullonum, common teasel;
(10) Dipsacus laciniatus, cutleaf teasel;
(11) Egeria densa, Brazilian waterweed;
(12) Eichhornia azurea, anchored water hyacinth;
(13) Elaeagnus angustifolia, Russian olive;
(14) Elaeagnus umbellata, autumn olive;
(15) Epilobium hirsutum; hairy willowherb;
(16) Fallopia japonica, Japanese knotweed;
(17) Ficaria verna, lesser celandine;
(18) Heracleum mantegazzianum, giant hogweed;
(19) Hesperis matronlis, dames rocket;
(20) Hydrilla verticillata, hydrilla;
(21) Hydrocharis morsus-ranae, European frogbit;
(22) Hygrophila polysperma, Indian swampweed;
(23) Iris pseudacorus, yellow flag iris;
(24) Lagarosiphon major, African oxygen weed;
(25) Ligustrum vulgare, common privet;
(26) Limnophila sessiliflora, Asian marshweed;
(27) Lonicera japonica, Japanese honeysuckle;
(28) Lonicera maackii, Amur honeysuckle;
(29) Lonicera morrowii, Morrow's honeysuckle;
(30) Lonicera tatarica, Tatarian honeysuckle;
(31) Lythrum salicaria, purple loosestrife;
(32) Lythrum virgatum, European wand loosestrife;
(33) Marsilea guadrifolia, European water-clover;
(34) Microstegium vimineum, Japanese stiltgrass;
(35) Monochoria hastata, arrowleaf false pickerelweed;
(36) Monochoria vaginalis, heartshape false pickerelweed;
(37) Morus alba, white mulberry;
(38) Myriophyllum aquaticum, parrot feather watermilfoil;
(39) Myriophyllum spicatum, Eurasian watermilfoil;
(40) Najas minor, brittle waternymph;
(41) Nymphoides peltata, yellow floating heart;
(42) Ottelia alismoides, duck lettuce;
(43) Paulownia tomentosa, princess tree;
(44) Persicaria perfoliata, mile-a-minute;
(45) Phalaris arundinacea, reed canary grass;
(46) Phragmites australis ssp. australis, common reed;
(47) Pistia stratiotes, water lettuce;
(48) Potamogeton crispus, curly pondweed;
(49) Pueraria montana var. lobata, kudzu;
(50) Pyrus calleryana, Callery pear;
(51) Rhamnus cathartica, European buckthorn;
(52) Rosa multiflora, multiflora rose;
(53) Sagittaria sagittifolia, arrowhead;
(54) Salix fragilis, crack willow;
(55) Salvinia minima, common salvinia;
(56) Salvinia molesta, giant salvinia;
(57) Sparganium erectum, simple bur-reed;
(58) Stratiotes aloides, water soldier;
(59) Trapa natans, water chestnut;
(60) Typha angustifolia, narrowleaf cattail;
(61) Typha x glauca, hybrid cattail;
(62) Ulmus pumila, Siberian elm; and
(63) Vincetoxicum nigrum, black swallowwort.
(B) Except as provided in paragraphs (C) and (D) of this rule, no person shall sell, offer for sale, propagate, distribute, import or intentionally cause the dissemination of any invasive plant as defined in paragraph (A) of this rule in the state of Ohio.
(C) The prohibitions listed in paragraph (B) of this rule do not apply to the following:
(1) Pyrus calleryana, callery pear until January 7, 2023.
(2) Ligustrum vulgare, common privet until January 1, 2026.
(3) Reed canary grass that is sold for use as animal feed.
(D) A person may conduct the following activities with the species listed in paragraphs (A)(1) to (A)(63) of this rule in a manner that does not result in the further spread of those species:
(1) Dispose of the plant;
(2) Controlling the plant; and
(3) Using the plant for research or educational purposes pursuant to a compliance agreement issued by the department.
(E) The director of the Ohio department of agriculture or the director's authorized representative may seize, order removed from sale or distribution any plant described in paragraph (A) of this rule which has been found in violation of paragraph (B) of this rule.
(F) The director may exempt a cultivar of any invasive plant species defined in paragraph (A) of this rule if scientific evidence is presented that the cultivar is not invasive.
Ohio Administrative Code
Rule 901:5-37-01 Prohibited noxious weeds.
Effective: September 14, 2018
The following plants are hereby designated"prohibited noxious weeds":
(A) Shatter cane (Sorghum bicolor).
(B) Russian thistle (Salsola Kali var. tenuifolia).
(C) Johnsongrass (Sorghum halepense).
(D) Wild parsnip (Pastinaca sativa).
(E) Grapevines (Vitis spp.), when growing in groups of one hundred or more and not pruned, sprayed, cultivated, or otherwise maintained for two consecutive years.
(F) Canada thistle (Cirsium arvense).
(G) Poison hemlock (Conium maculatum).
(H) Cressleaf groundsel (Senecio glabellus).
(I) Musk thistle (Carduus nutans).
(J) Purple loosestrife (Lythrum salicaria).
(K) Mile-A-Minute Weed (Polygonum perfoliatum).
(L) Giant Hogweed (Heracleum mantegazzianum).
(M) Apple of Peru (Nicandra physalodes).
(N) Marestail (Conyza canadensis)
(O) Kochia (Bassia scoparia).
(P) Palmer amaranth (Amaranthus palmeri).
(Q) Kudzu (Pueraria montana var. lobata).
(R) Japanese knotweed (Polygonum cuspidatum).
(S) Yellow Groove Bamboo (Phyllostachys aureasculata), when the plant has spread from its original premise of planting and is not being maintained.
(T) Field bindweed (Convolvulus arvensis).
(U) Heart-podded hoary cress (Lepidium draba sub. draba).
(V) Hairy whitetop or ballcress Lepidium appelianum).
(W) Perennial sowthistle (Sonchus arvensis).
(X) Russian knapweed (Acroptilon repens).
(Y) Leafy spurge (Euphorbia esula).
(Z) Hedge bindweed (Calystegia sepium).
(AA) Serrated tussock (Nassella trichotoma).
(BB) Columbus grass (Sorghum x almum).
(CC) Musk thistle (Carduus nutans).
(DD) Forage Kochia (Bassia prostrata).
(EE) Water Hemp (Amaranthus tuberculatus).