Z2020075 BOS REPORT_PART2.PDF

Maricopa County — Formal (2021-04-21)

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Legend
Ave
W
Salome 339th Road
Hwy W Southern Ave W Southern Ave
Railroad
Project Components
Sun Streams Expansion
Boundary
Ave
Fence Line
351st
Panels
100ft Setbacks*
* All other boundary setbacks would be 25'
Baseline Rd
°
Ave
0 1,000 2,000 3,000 4,000
331st Rd
Ward
Feet
Dobbins Rd State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit: Foot US
Maricopa County
Map
Extent Phoenix
ARIZONA
SUN STREAMS EXPANSION
U.P.R.R.
Figure 2 – Project Site Plan
Showing Setbacks and
Open Space Corridors
Map Extent: Maricopa County, Arizona
Date: 01-29-21 Author: rnc
G:\Sunstreams/MXD's/Sun Streams Expansion

W W BASELINE ROAD
SALOME
HIGHWAY
LEGEND
FENCED AREA
TOTAL PROJECT AREA
AREA ADDED TO WILDLIFE CORRIDOR
RAILROAD
PACIFIC Figure 3
SOUTHERN Optimization of
Undeveloped Habitat
At Salome / Baseline
NORTH
Birding Area

Maricopa County
Planning & Development Department
Date: March 04, 2021 (Revised 3/8/2021)
Robert Fedorka, P.E.
Planning & Development
501 North 44th Street, Suite 200 Memo To: Darren Gerard, AICP, Deputy Director, Department of Planning &
Phoenix, Arizona 85008
Phone: (602) 506-7151 Development
www.maricopa.gov/planning
Email address:
Bob.Fedorka@Maricopa.gov Attn: Adam Cannon, Planner, Planning & Development Services
From: Robert Fedorka, P.E., Engineering Supervisor, Planning & Development
Services
cc: Michael Norris, P.E., Engineering Manager, Planning & Development
Subject: Z2020075 – Re-Zone & IUPD for Sun Streams Solar Expansion
(E3 Memo-Rev)
Job Site Address: 33102 W. Baseline Road, Tonopah
APN(s): Various // State Land
I have reviewed the 3rd submittal Plans and Drainage Report, routed for review on March 4,
2021, for the subject application. PND Engineering review has no objections subject to the
following stipulations:
STIPULATIONS
The following stipulations will apply:
1. Final design of drainage infrastructure shall be based on Rational Method
calculations, except in situations where drainage areas significantly exceed 160 acres.
2. Drainage Waiver case DRB2021002 must be approved prior to issuance of building
permits.
3. Detailed Grading and Drainage Plans showing the new site improvements must be
submitted for the acquisition of building permits. On-site (solar field) areas must be
designed in such a manner so that flows area directed to retention basin(s). Basin
bleed-offs and overflows must be directed to well defined drainage corridors, to the
maximum extent possible.
4. Drainage review of planning and/or zoning cases is for conceptual design only and
does not represent final design approval nor shall it entitle applicants to future
designs that are not in conformance with Section 1205 of the Maricopa County Zoning
Ordinance and the Maricopa County Drainage Policies and Standards. All
development and engineering design shall be in conformance with Section 1205 of
the Maricopa County Zoning Ordinance and current engineering policies, standards
and best practices at the time of application for construction.

5. Owner or owner’s agent shall be responsible for identifying and procuring any
permit(s) for disturbance of, or work within delineated jurisdictional (404) washes.
6. Any work within a regulated SFHA (floodplain) will require as Floodplain Use Permit
(issued concurrent with the required building permit(s) for the site improvements).
7. Pads for inverters and other electrical equipment; and any buildings within the Zone
A or AE Floodplain must be elevated to the regulatory flood elevation or otherwise
designed to meet the requirements of the Floodplain Use Regulations. All
development and engineering design shall be in conformance with the most current
version of the Floodplain Use Regulations for Maricopa County.
8. The following right-of-way preservations shall be required and shown on the plans
submitted for building permits:
Required Preservations:
a. 65’ half width, 130’ full width right-of-way for Salome Highway
b. 65’ half width, 130’ full width right-of-way for 331st Avenue
c. 55’ half width, 110’ full width right-of-way for Dobbins Road
d. 65’ half width, 130’ full width right-of-way for Baseline Road (east of Salome
Highway)
e. 65’ half width, 130’ full width right-of-way for 339th Avenue (north of Salome
Highway)
f. 100’ half width right-of-way for Southern Avenue
g. 55’ half width right-of-way for 339th Avenue (between Baseline and Dobbins
Road)
h. 40’ half width right-of-way for 335th Avenue (between Dobbins and South
Mountain, and Vineyard and Southern)
i. 40’ half width right-of-way for South Mountain Avenue
j. 40’ half width right-of-way for Vineyard Road
k. 55’ half width right-of-way for Elliot Road
l. 55’ half width, 130’ full width right-of-way for Baseline Road (west of Salome
Highway)
m. 55’ half width right-of-way for 347th Avenue (section line alignment)
Please contact me if you have any questions or require clarification of these comments.

Maricopa County
Environmental Services Department
Water & Waste Management Division
Subdivision Planning Program Infrastructure & DATE: October 8, 2020
1001 N. Central Avenue #150
Phoenix, Phone: (602) Arizona 372-2907 85004 TO : Adam Cannon, Planning & Development Dept.
Fax: (602) 506-5813 Planner
TDD 602 506 6704
FROM: Souren Naradikian, P.E.
Senior Civil Engineer
SUBJECT: Sun Streams Expansion Solar Project. Z2020075
The Maricopa County Environmental Services Department (MCESD) has received
documentation for Sun Streams Expansion Solar Project at APS # State Land.
According to the submitted documentation Maricopa County Comprehensive Plan
Amendment (CPA) and Rezoning (the “Entitlements”) on State Trust land described
above, to change the use from Rural Zoning (RU-43) to Industrial with an Industrial
Unit Plan of Development (IND-2 IUPD for a Photovoltaic Solar Project). The need for
water on the site during operations is minimal, necessary only for needs of employees
And possible cleaning of the panels. Operations could include up to eight full-time
employees on the site. Potable water needs of these employees will be provided via
bottled water or from an ADWR-exempt well. Cleaning of the panels is infrequent so
this IUPD indicates one exempt, potable well on site to serve these water needs. This
volume of water use does not require a Public Water System. Alternatively, water
could be trucked in as needed. The wastewater generated at the facility during
operations will be treated with up to two on-site conventional septic tank systems or
similar alternative systems as regulated by Arizona Department of Environmental
Quality and administered by Maricopa County Environmental Services Department
(NOID). Additionally, portable toilets could be used during operations.
Based on the above, MCESD raise no concern for this project to the Planning &
Development Department in Accela Automation on October 8, 2020.
It should be noted that this document does not approve the referenced project.
Comments are provided only as advisory to Maricopa County Planning and
Development Department to assist staff to prepare a staff report. Other Maricopa
County agencies may have additional requirements. Final review and approval will be
made through Planning and Development Department procedures. Applicant may
need to submit separate applications to the Maricopa County Environmental Services
Department for approval of proposed facilities regulated by the Department. Review
of any such application will be based on regulations in force at the time of application.

From: Robert Busick
To: Adam Cannon (PND)
Subject: Z2020075 - 2nd Submittal - Sun Streams Expansion Solar Project
Date: Tuesday, February 9, 2021 9:25:19 AM
Attachments: image001.png
Good morning, Adam,
Regarding case Z2020075: after reviewing the associated 2nd submittal documents, the City of
Buckeye has no comment.
Take care,
ROBErT BUSICK | PLANNEr I | DEVELOpMENT SErVICES
CITY OF BUCKEYE | 530 EAST MONrOE AVENUE, BUCKEYE, AZ 85326
O: 623.349.6242 | C: 623.414.2066 | rBUSICK@BUCKEYEAZ.GOV
CITY HALL HOURS: MON-THURS 7AM-6PM
CLOSED ON FRIDAYS
www.buckeyeaz.gov
This message contains confidential information and is intended only for the individual(s)
addressed in the message. If you are not the named addressee, you should not disseminate,
distribute, or copy this e-mail. If you are not the intended recipient, you are notified that
disclosing, distributing, or copying this e-mail is strictly prohibited.

From: Robert Busick
To: Adam Cannon (PND)
Subject: Z2020075 - 1st Submittal - Sun Streams Expansion Solar Project
Date: Tuesday, October 13, 2020 7:40:52 AM
Attachments: image001.png
Good morning, Adam:
Regarding case Z2020075: after reviewing the associated documents, the City of Buckeye has no
comment.
Thank you,
Robert Busick | Planner I
City of Buckeye | Development Services
530 E Monroe Ave| Buckeye, Arizona 85326
P 623-349-6242 | rbusick@buckeyeaz.gov
Monday-Thursday 7am-6pm CLOSED FRIDAYS
2020 Census – Everyone Counts in Buckeye! – ¡Todos Cuentan en Buckeye! – www.icount2020.info
This message contains confidential information and is intended only for the individual(s)
addressed in the message. If you are not the named addressee, you should not disseminate,
distribute, or copy this e-mail. If you are not the intended recipient, you are notified that
disclosing, distributing, or copying this e-mail is strictly prohibited.

From: Peggy Fehlman
To: Adam Cannon (PND)
Subject: Fwd: Z2020075 - 1st Submittal - Sun Streams Expansion Solar Project
Date: Thursday, October 8, 2020 11:37:24 AM
Attachments: image002.png
image003.png
image001.png
Thank you for the notification of the above-referenced proposed development.
ADOT is neutral on this matter. As such, ADOT has no comment.
ADOT traffic engineering may offer additional comments, it is recommended that the developer ascertain if a traffic study or permit will be
necessary. We appreciate receiving the notice, and the opportunity to review and comment. I am happy to assist with any other questions or
concerns.
Kind Regards,
Peggy Fehlman
Right of Way Coordinator
ADOT Central District
2140 W. Hilton Avenue
Phoenix, AZ 85009
(602)712-6622 Office
(480)586-0089 Cell
www.azdot.gov
---------- Forwarded message ---------
From: Adam Cannon (PND) <Thank you for the notification of the above-referenced proposed development.
>
Date: Wed, Oct 7, 2020 at 10:52 AM
Subject: Z2020075 - 1st Submittal - Sun Streams Expansion Solar Project
To: tvcc.events@gmail.com <tvcc.events@gmail.com>, dhenning@westvalleyview.com <dhenning@westvalleyview.com>, Robert Rowley
(EMG) <ROBERT.ROWLEY@maricopa.gov>, todd.williams@aps.com <todd.williams@aps.com>, dmheisler1@aol.com
<dmheisler1@aol.com>, ronsatt@ev1.net <ronsatt@ev1.net>, swilken@azmag.gov <swilken@azmag.gov>, vwolfley@azmag.gov
<vwolfley@azmag.gov>, redletter@azdot.gov <redletter@azdot.gov>, Bruce Monson (EMG) <Bruce.Monson@maricopa.gov>,
admin@bvfd.az.gov <admin@bvfd.az.gov>, charlotte.shields@aps.com <charlotte.shields@aps.com>, travis.icard@aps.com
<travis.icard@aps.com>, Richard Peel (EMG) <Richard.Peel@maricopa.gov>, Madison Wisler (EMG) <Madison.Wisler@maricopa.gov>,
mark.burdick@bvfd.az.gov <mark.burdick@bvfd.az.gov>, bhurley@buhsd.org <bhurley@buhsd.org>, chadt@arlingtonk8.org
<chadt@arlingtonk8.org>, kirk.waddle@smusd90.org <kirk.waddle@smusd90.org>, thogan@buckeyeaz.gov <thogan@buckeyeaz.gov>,
graham.symmonds@gwresources.com <graham.symmonds@gwresources.com>, rongrossltd@cox.net <rongrossltd@cox.net>,
tonopahvalleycc@yahoo.com <tonopahvalleycc@yahoo.com>, gritter@azgfd.gov <gritter@azgfd.gov>, mwalsh@azstateparks.gov
<mwalsh@azstateparks.gov>, steve_spangle@fws.gov <steve_spangle@fws.gov>, mkillian@azda.gov <mkillian@azda.gov>,
rick.moreau@aztvcc.org <rick.moreau@aztvcc.org>, contact@fosmaz.org <contact@fosmaz.org>, scleveland@buckeyeaz.gov
<scleveland@buckeyeaz.gov>, I_thompson@MCSO.maricopa.gov <I_thompson@mcso.maricopa.gov>, Andrew Cavalcant
<acavalcant@azgfd.gov>, Adam Carreon <ACarreon@azdot.gov>
Cc: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Good morning all:
This e-mail serves as notification of an application we have received from Sun Streams Expansion, LLC for a Zone Change with Overlay from
Rural-43 to IND-2 IUPD for the Sun Streams Expansion Solar Project. Applicable documents for review are available on the Online Permit
Manager at: https://accela.maricopa.gov/CitizenAccessMCOSS/Default.aspx. You can search for the case by using the Zone Change case number
Z2020075.
A TAC meeting has been scheduled for November 17, 2020 at 9:00 a.m. Please let me know if you would like to attend and I will send you the
Go To Meeting access instructions.
Best regards,
Adam Cannon

Planner
Maricopa County Planning & Development Department
501 N. 44th Street, Suite 200, Phoenix, AZ 85008
Desk: 602-372-0292
adam.cannon@maricopa.gov

From: David Jacobs
To: Adam Cannon (PND)
Subject: Sun Streams Expansion Solar Project Z2020075
Date: Thursday, October 8, 2020 4:31:45 PM
Adam-
Thank you for sending materials related to the zone changes associated with the Sun Streams
Expansion Solar Project. The expansion of the Sun Streams Solar Project involves
several thousands of acres of State Trust Land, and was recently surveyed for cultural
resources. Our office received and reviewed that survey required by ASLD in August, 2020,
and concurred with its adequacy and findings of "no historic properties affected" for the
project. Those findings are appropriate for the zone change. If you have any questions or
concerns, please contact me at 602-542-7140 or via e-mail.
David Jacobs, Arizona State Historic Preservation Office




10/27/2020
Maricopa County Board of Supervisors
301 West Jefferson Street
Phoenix, Arizona 85003
Maricopa County Planning and Zoning Commission
501 N 44th Street
Suite 200
Phoenix, AZ 85008
Re: Case Z2020075 and CPA2020001
Dear Maricopa County Supervisors and Commissioners,
I am writing to convey my strong support of the Sun Streams Expansion Solar Photovoltaic (PV) Project and to
encourage its approval for Rezoning and a Comprehensive Plan Amendment.
The economic and social benefits of this project far outweigh its perceived impacts. The 385-megawatt Sun
Streams Expansion project would use the clean, unlimited fuel source of the sun to generate enough energy to
power approximately 92,000 homes.
The project will play an important role in overcoming the energy crisis. Not only will the project help to
generate clean renewable energy here in Arizona, but it will also employ hundreds of people and inject millions
of dollars into the state and local economy. The project will provide needed construction and service industry
jobs. Construction and operation will create new demand for equipment and services from the local
community.
We are seeing the benefits of solar energy all around us. Solar facilities like Sun Streams Expansion help clean
up our air, protect our health, reduce the adverse effects of climate change, and inject economic stimulus to
areas around Arlington and Maricopa County.
Thank you for your consideration – I am very excited about these projects and the benefits they will bring to
our community.
Sincerely,
David Dean
VP of Construction
602-885-4655
david@blountco.com
Address: 1353 S Vista Rd Apache Junction, AZ 85119 Web: blountco.com Phone: (480) 985-2112

10/27/2020
Maricopa County Board of Supervisors
301 West Jefferson Street
Phoenix, Arizona 85003
Maricopa County Planning and Zoning Commission
501 N 44th Street
Suite 200
Phoenix, AZ 85008
Re: Case Z2020075 and CPA2020001
Dear Maricopa County Supervisors and Commissioners,
I am writing to convey my strong support of the Sun Streams Expansion Solar Photovoltaic (PV) Project
and to encourage its approval for Rezoning and a Comprehensive Plan Amendment.
The economic and social benefits of this project far outweigh its perceived impacts. The 385-megawatt
Sun Streams Expansion project would use the clean, unlimited fuel source of the sun to generate enough
energy to power approximately 92,000 homes.
The project will play an important role in overcoming the energy crisis. Not only will the project help to
generate clean renewable energy here in Arizona, but it will also employ hundreds of people and inject
millions of dollars into the state and local economy. The project will provide needed construction and
service industry jobs. Construction and operation will create new demand for equipment and services
from the local community.
We are seeing the benefits of solar energy all around us. Solar facilities like Sun Streams Expansion help
clean up our air, protect our health, reduce the adverse effects of climate change, and inject economic
stimulus to areas around Arlington and Maricopa County.
Thank you for your consideration – I am very excited about these projects and the benefits they will bring
to our community.
Sincerely,
Steve Gotschall
Sr. Project Manager
McCarthy Building Companies
602-770-0463


From: Mark Horlings
To: Adam Cannon (PND)
Subject: Sunstreams Expansion Solar Project, Z20200075
Date: Thursday, March 4, 2021 11:17:23 AM
Attachments: MAS Thrashers Summary.docx
MAS 1st Solar Cover Ltr to Zoning.docx
Hi Adam,
I am attaching the Report from the surveyors who studied life in the area, a one page
summary of that report, and a cover letter for that summary and the report. I hope
these can be included in the materials available to the Commissioners.
Thanks for your help with this.
Mark Horlings
Maricopa Audubon
PS: I will send the text of the report separately. The file seems to be too large for this
email.

334 W. Palm Lane
Phoenix, AZ 85003
March 4, 2021
Commissioners
Planning and Zoning Commission for Maricopa County
501 N. 44th Street, Suite 200
Phoenix, AZ 85008
(Via email)
Dear Commissioners,
Solar Streams Expansion, Case #Z20200075
There’s a reason why this land is known as the “Thrasher Spot.” A survey Maricopa
Audubon Society (MAS) commissioned shows that four species of desert birds (LeConte’s,
Bendire’s, Crissal and Sage Thrashers) share the territory. Audubon members and
birdwatchers from around the country have visited the intersection of the Salome Highway and
Baseline for years, hoping to see these birds.
These birds survive in a harsh environment to which they are singularly adapted. As the
MAS study notes, the feeding and breeding territories they require can be larger than other
birds need. However, the MAS study suggests their populations in this area can be protected.
Plans for a solar farm on the State Trust Land need to be slightly modified. Also,
reasonable restrictions should be added to avoid construction during breeding season and to
exclude storage, parking and construction staging from washes and floodplains which First Solar
has already said they will not develop.
MAS and other Audubon groups support renewable energy. We understand that the
species found at the Thrasher Spot have been named as Species of Conservation Concern but
not as in danger of extinction. The MAS study demonstrates that these unusual birds persist
and can be found throughout the project area. MAS and its members hope the Commission
will attach conditions to the zoning changes proposed that will give these birds a fighting
chance to survive.
Very truly yours,
Mark Horlings
Chair of the Conservation Committee
Maricopa Audubon Society

Maricopa Audubon Society
Summary of:
Thrasher Surveys on Arizona State Trust Lands Proposed for the
Sun Streams Expansion Solar Project
• High Local Diversity: Four Species of Thrasher : “More people have probably seen their
“lifer” LeConte’s Thrasher here than any other place in the United States” from Birds of
Phoenix and Maricopa County. First formal survey conducted at the Thrasher Spot.
• Surveyed 2567 acres of State Land to be included in the First Solar Project. Did not
survey on private land.
• Four species of Thrasher found: (pps 5-16)
o LeConte’s: desert dweller, breeds in the area, does not require drinking water,
requires breeding territory of 15 acres and feeding territory of up to 40 acres per
breeding pair, rated as a species of Greater Conservation Concern in Arizona’s
comprehensive wildlife strategy.
o Bendire’s: most common species in the survey area, breeds here and in upland
Arizona, breeding territory about 4 acres, total global population fewer than
120,000, species listed as “vulnerable” by IUCN.
o Sage: winter in in the area but do not breed in the survey area, second most
common species found.
o Crissal: winter resident, the rarest in the area, breeds in N. Arizona.
o Survey team also found burrowing owls and a kit fox den.
• Recommendations: (pps 20-27)
o Developer should avoid habitat fragmentation.
o First Solar’s plans leave 1000 acres undeveloped but often in wildlife corridors
instead of contiguous areas suitable for breeding and feeding habitat.
o Solar arrays should be removed from four areas where significant bird
populations were found. (Maps of these areas are at pps 24-27)
o Construction during breeding season (January through June) for LeConte’s and
Bendire’s Thrashers should be restricted.
o No structures, parking or construction staging in the 1000 acres not planned for
solar panels.
o First Solar should conduct studies in future years to gauge the effect of the solar
farm on Thrashers. This study provides a baseline for evaluation.

Thrasher Surveys
On Arizona state lands proposed for the Sun Streams Expansion
Solar Project
LeConte’s (upper left), Crissal (upper right), Sage (center right), Curve-billed (bottom
left) and Bendire’s (bottom right) thrashers. Painting by Micah Riegner.
Prepared for the Maricopa Chapter of the
Audubon Society
March 01, 2021
Prepared by:
James Holderer & Micah Riegner

Thrasher Surveys at the Thrasher Spot
Table of Contents
STUDY BACKGROUND P. 3
Section 1: Introduction
Thrasher ecology as it pertains to the study site P. 6
Overview map showing locations and boundaries of the project P. 8
Section 2: Methods
Materials, methods, maps of the surveys P. 9
Section 3: Results
Maps of data by species, vegetation graphs P.13
Section 4: Discussion & Recommendations
Narrative, maps of recommendations P.20
Section 5: Supplemental Information
Other species of interest, burrowing owls P.27
Section 6: Literature Cited P.33
Section 7: Acknowledgments P.34
Section 8: Appendices P.35
2 Holderer & Riegner 2021

Thrasher Surveys at the Thrasher Spot
STUDY BACKGROUND
First Solar, Inc. (via Sun Stream Expansion, LLC) aims to continue their widespread
development of solar energy in Maricopa County, in the vicinity of Arlington, AZ, with the
Sun Streams Expansion Solar Project. The project area is slated for 2,567 acres of
contiguous Arizona State Land Department land and an additional 624 acres of
undeveloped private lands1. A popular birding destination, known to birders as the
“Thrasher Spot,” is located in the heart of the proposed solar project at the intersection of
W Baseline Road and N Salome Highway. Aptly named, the Thrasher Spot is famous for its
high local diversity of thrasher species, including the sensitive species LeConte’s and
Bendire’s thrashers, among Crissal, Curve-billed, and Sage thrashers, as well. Janet
Witzeman and Troy Corman in Birds of Phoenix and Maricopa County, published by the
Maricopa Audubon Society, write: “More people have probably seen their ‘lifer’ LeConte’s
Thrasher here than any other place in the United States.” However, much of what makes
this place enjoyable to birders and hospitable to thrashers stands to be lost in the wake of
this solar development. Scientifically informed negotiations with First Solar and Maricopa
County Planning will hopefully heed local protections for these species habitat.
Fig. 1: Looking SE at the immediate vicinity of the Thrasher Spot, at the corner of Baseline
Road and Salome Highway. Photo taken by Micah Riegner.
The looming development of solar energy at this location poses a threat to local
thrashers. Currently, there have been no avian surveys conducted on the lands First Solar
plans to develop. eBird (Cornell Lab of Ornithology) data show numerous observations of
LeConte’s and Bendire’s Thrashers at the “The Thrasher Spot” near the planned
1 Report to the Planning and Zoning Commission, Case: 2020001. p. 2.
3 Holderer & Riegner 2021

Thrasher Surveys at the Thrasher Spot
development; however, these sightings are rare beyond a 600m-radius from the parking
pull-off, because many birders tend not to travel great distances. The area in which eBird
sightings are concentrated comprises a negligible percentage of the overall SSE project
acreage; this dataset simply does not depict what we stand to lose. Maricopa Audubon and
the Consultants hypothesized that thrasher habitation extends well beyond these small
concentrations of eBird data; our hypothesis were tested to be true.
First Solar has expressed that they are the “leader in sustainable solar development”
and are “…committed to… minimizing the environmental impacts of our products…”2.
Specific to the project, this inclination is demonstrated in the Application for a Major
Comprehensive Amendment submitted by Sun Stream Expansion, LLC (hereafter SSE);
repeatedly, the narrative report asserts that the largest washes would be kept free of
development and retain a natural state3. Additionally, the application states a goal of
promoting development that mitigates adverse environmental impacts on the natural and
cultural environment4. First Solar appears willing to consider, and perhaps alter, project
plans in regard to thrasher habitation on-site.
We, the consultants, objectively sampled the 2,567 acres of Arizona State Land Department
land slated for zone change and development, for these desert thrashers. Private lands
were not surveyed. This ornithological study addressed the deficit of thrasher data in the
vicinity of the Thrasher Spot. Our data analyses indicate clusters of thrasher activity and
advise our recommendations; a review of scientific literature further refines our data
analyses and decisions regarding protection priorities. The following report is complete
with our methodology, findings, maps, site images, data appendices, and a discussion. GIS
data is available upon request.
2 http://www.firstsolar.com/About-Us/Corporate-Responsibility
3 Application for a Major Comprehensive Amendment; p. 10 (p. 27 of CPA2020001).
4 Application for a Major Comprehensive Amendment; p. 9 (p. 26 of CPA2020001).
4 Holderer & Riegner 2021

Thrasher Surveys at the Thrasher Spot
Section 1: Introduction
The deserts of the Southwest are under increasing pressure, from urban development,
agriculture, and climate change, making desert birds some of the fastest declining species
in North America. Thrashers fall into this group, which have experienced precipitous
declines in recent years5.
Thrashers are in the family Mimidae, whose
center of diversity is the arid southwestern U.S.,
where up to 5 species, can occur in the same
habitat. They all have relatively dull brown
plumage but make up for it with their bright
songs, which float exuberantly across the desert.
Of all the North American thrashers, LeConte’s is
the most specialized per se, residing in the
Lower Colorado Subdivision of the Sonoran
Desert, one of the harshest corners of North Figure 2: LeConte’s Thrasher in saltbush at the
Thrasher Spot. Photo by Micah Riegner.
America, where it favors braided washes on
gently sloping creosote flats (Corman and Wise-
Gervais 2005). Other plant species it associates with include Little-leaf Saltbush (Atriplex
polycarpa), Bursages (Ambrosia spp.), Graythorn (Ziziphus obtusifolia), and Wolfberries
(Lycium spp.). This bird is truly adapted to life in the desert, able to live without drinking,
as it metabolizes water from its food. One of the striking aspects of LeConte’s Thrasher is
its propensity to run on the ground rather than fly, often darting from shrub to shrub with
its tail cocked up in the air like a roadrunner6.
LeConte’s Thrashers remain in pairs throughout the year— a somewhat unusual trait for a
passerine. Peak singing for LeConte’s Thrasher is between December and February5;
however, the breeding season extends through May6. A study in Maricopa, California found
that LeConte’s Thrashers occupy ovate
territories 400-450 m long and 200-300 m
wide along washes or arroyos7. Nesting
territories are an average of 7.34 ha but,
over the course of a year, a pair can occupy
an area of 10-18 ha8. While the birds are
nest building, they will remain within a
150-275 m radius of the nest and, while
they are incubating, that radius contracts to
25-80 m. Pairs mate for life and maintain
Figure 3: LeConte’s Thrasher foraging at the Thrasher the same territory year after year, and, in
Spot. Photo by Micah Riegner. the summer when the birds are least
5 Desmond and Sutton 2020
6 Corman and Wise-Gervais 2005
7 Sheppard 2018
8 Sheppard 2018
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Thrasher Surveys at the Thrasher Spot
territorial, home ranges of different pairs will overlap9.
Given their habitat specificity and general sparseness, LeConte’s Thrashers are a species of
concern on the Red Watch List Partners in Flight10. In Arizona they are listed as a species of
Greater Conservation Concern in the 1B tier within the State’s comprehensive wildlife
conservation strategy11. Their populations have declined over the years due to urban
development and agricultural encroachment and the spread of invasive plants such as
Sahara mustard (Brassica tournefortii), black mustard (Brassica nigra), Mediterranean
grass (Schismus barbatus), and Arabian schismus (Schismus arabicus), which choke out
native vegetation and bring unprecedented fire to the Sonoran Desert7. They are also
sensitive to habitat degradation from ATVs, livestock grazing, and pollutants from
agricultural runoff12.
Bendire’s Thrasher is another species in
serious decline13. It is very similar in
appearance to the more common Curve-
billed Thrasher but has a shorter bill with a
pale base to the lower mandible. It has a
relatively small breeding distribution
centered in Arizona—its movements are still
being worked out. In some parts of its range
it is resident, while in other parts it seems to
be migratory14. This species breeds in a
variety of open habitats throughout the state
Figure 4: Bendire’s Thrasher perched in mesquite at from low desertscrub at 500 ft to grasslands
the Thrasher Spot. Photo by Micah Riegner. and Pinyon/Juniper woodland at 6100 ft on
the Colorado Plateau. It can be found in rural
areas as long as there are scattered islands of vegetation. They seem to be most abundant
in desertscrub with scattered Paloverdes (Parkinsonia spp.). Males begin to sing and
establish territories in January, and peak vocal activity is February-March15. A study in NM
suggested territory size of 1.67 ha, comparable to that of Curve-billed Thrashers, which
hold territories of 2 ha, and Crissal Thrashers, which hold territories of 2.6 ha16.
Like other desert birds, Bendire’s Thrasher numbers fluctuate in response to moisture:
their numbers go up after wet years and decline in times of drought17. A 2016 estimate
suggested the global population was between 70,000 and 120,000 and expected to decline
by 30% in the next 15 years due to a number of factors18. These include overgrazing,
9 Sheppard 2020
10 Kondrat-Smith and Lowery 2018
11 Sheppard 2020
12 Sheppard 2020
13 (Desmond and Sutton 2020)
14 Corman and Wise-Gervais 2005
15 Corman and Wise-Gervais 2005
16 Desmond and Sutton 2020
17 Corman and Wise-Gervais 2005
18 Desmond and Sutton 2020
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Thrasher Surveys at the Thrasher Spot
development, invasive plants, and displacement by Curve-billed Thrashers19. This species
is classified as vulnerable under IUCN.
Sage Thrashers are another common
winter resident at the “Thrasher Spot.”
These birds breed from northern Arizona20
up into Idaho and spend the winter in the
Sonoran Desert. As for all migratory birds,
wintering sites are just as important as
breeding sites and must not be
underestimated for their conservation
value. Crissal Thrasher also occurs at the
Thrasher Spot. These birds occur widely
throughout Arizona and in numerous
habitats that offer dense vegetation21. Figure 5: Sage Thrasher perched at the Thrasher Spot.
Photo by Micah Riegner.
Figure 6: Every morning at sunrise during the second survey we were delighted by this LeConte Thrasher’s
cheerful song ringing through our camp. Photo by Micah Riegner.
19 Desert Thrasher Working Group. 2018.
20 Corman and Wise-Gervais 2005
21 Corman and Wise-Gervais 2005
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Thrasher Surveys at the Thrasher Spot
Figure 7: This map depicts the entire Sun Streams Expansion Solar Project, which consists of ASLD and private lands.
The study area consists only of ASLD lands.
8 Holderer & Riegner 2021

Thrasher Surveys at the Thrasher Spot
Section 2: Materials & Methods
Materials
Binoculars GPS Cameras Audio Drone
Recording
Vortex Crossfire Gaia GPS for Nikon COOLPIX Tascam DJI Mavic Mini
8x42 iPhone P100 recorder
Swarovski SLC Input for Sony RX10 IV Sennheiser
10x42 iPhone me66 mic
Methods
Area search surveys22 were completed for thrashers during January 3-5 and February 4-6,
2021, in order to coincide with peak vocal activity for thrashers23. Due to the implicit site
fidelity of these thrasher species, with repeated visits, one can begin to ascertain where the
thrashers have their territories. We conducted two visits, Surveys started at 0715 just
before sunrise and lasted throughout the day (10 hours) if the wind didn’t pick up.
Volunteers from Maricopa Audubon assisted in the survey, mostly to help spot birds. Our
survey protocols were advised by those found in Desert Thrasher Working Group (2018)
and Jongsomjit et al. (2012).
The habitat at the “Thrasher Spot” is Sonoran Desertscrub within the Lower Colorado
Subdivision of the Sonoran Desert24. The main north-south drainage, hereafter “Thrasher
Wash”, running through the central part of the proposed development is dominated by
Littleleaf Saltbush (Atriplex polycarpa) with ribbons of Mesquite (Prosopis sp.) and Foothill
Paloverde (Parkinsonia microphylla) defining the ephemeral waterways. As one moves out
of the drainage of soft clay deposits into the more gravel-covered uplands, the Saltbush
gradually fades into Creosote (Larrea tridentata). These “Creosote Uplands,” as we refer to
them, are dotted with islands of Mesquite and Paloverde with occasional Saguaros and
Barrel Cacti.
The entire survey area was partitioned into a grid of 300m x 300m frames25, which
resulted in about 168 frames. These grids were uploaded into GPS applications, and were
taken into the field with each surveyor. Surveyors systematically walked each frame,
meandering back and forth as to flush any hidden thrashers on the ground. When a species
of interest was located, its location and other variables were noted. Approximately 20-30
minutes were spent in each frame; when vegetation was denser, survey times increased.
Our species of interest were: Bendire’s Thrasher, LeConte’s Thrasher, Crissal Thrasher,
Sage Thrasher, Sagebrush Sparrow, and Loggerhead Shrikes.
22 Ralph et al. 1993
23 Corman and Wise-Gervais 2005
24 Brown 1982
25 The Desert Thrasher Working Group 2018
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Thrasher Surveys at the Thrasher Spot
Data collection was facilitated by the “Input” iPhone application, developed by Lutra
Consulting. Forms were prepared in QGIS and uploaded into the Input app. When a species
of interest was located, its georeferenced location and the following variables were
recorded into the application: species, number of individuals at that point, dominant
vegetation type (Creosote uplands, Saltbush, Saltbush/Creosote, Mesquite/palo verde
terraces, Mesquite/saltbush terraces, Mesquite/creosote patches), and any other pertinent
information. If we managed to observe a bird as it moved unperturbed through its habitat,
we created a polygon of its movements using a polygon collection feature on the app. Data
were then synced at the end of each day using a cloud data management service called
Mergin, which seamlessly transfers data into our desktop GIS application, QGIS.
It took us a total of 3 days per visit surveying all day to thoroughly cover the entire
proposed development. In addition to the survey data, we made eBird lists for each day and
opportunistically took photos and made recordings of the birds we encountered. A drone
was used to obtain high-quality aerial photos of the study area.
On occasion, other features of conservation interest would be located during surveys.
While surveying, one active Desert Kit Fox and one active Burrowing Owl colony were
identified. Opportunistically, we set up a couple of Bushnell Camera traps at an active Kit
Fox den (33.382023 o N, 112.783369oW) and a Burrowing Owl den (33.389024oN,
112.777468oW) to document their presence at the site. These cameras were set to film for
1 minute every 30 seconds and placed roughly 1 m off the ground.
Data were analyzed and prepared using the free and open source GIS platform, QGIS.
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Thrasher Surveys at the Thrasher Spot
The following three maps depict the locations of 168 study frames, formatted in a grid.
Each frame is 300 m2, with several exceptions made to retrofit the geometry of the study
area. The intent of this grid design is to facilitate a systematic, complete study of the entire
project area, rather then a sampling method aimed at performing a comparative analysis
between plots.
11 Holderer & Riegner 2021