Exhibit D - PLZZ-26-0012 Cloud Cap Rezone - Narrative - PZ20261027.pdf

2R PLZZ-26-0012 RECEIVED SEPT 4 2026 WD
PLZZ-26-0012 APPLICATION NARRATIVE
REZONE
Cloud Cap Energy Storage
Taylor Bradshaw Isabelle Zollinger
Manager, Development Associate, Development
+1 (708) 377-9887, TBradshaw@invenergy.com +1 (971) 289-4001, IZollinger@invenergy.com

Table of Contents
1. DESCRIPTION OF THE REQUEST ............................................................................... 2
2. PROJECT INFORMATION ............................................................................................ 2
Nature of the Project ........................................................................................................... 2
Battery Energy Storage System .......................................................................................... 2
Building Types & Design ..................................................................................................... 3
3. LAND INFORMATION ................................................................................................... 3
Current and Proposed Site Conditions ................................................................................ 3
Vicinity Information and Relationship to Surrounding Properties ......................................... 5
Current General Plan Designation, Zoning, and Conformance to Land Use Plans............... 8
Design and Type of Landscaping .......................................................................................11
Drainage ............................................................................................................................11
Proposed Percentage of Parks and Open Space ...............................................................11
Proposed Trails ..................................................................................................................11
4. IMPACT TO CITY SERVICES .......................................................................................12
Roadway Circulation ..........................................................................................................12
Fire Protection and Fire Safety System ..............................................................................12
Source of Water .................................................................................................................13
Wastewater Management ....................................................................................................13
Employment .......................................................................................................................13
Police Protection ................................................................................................................13
Impact to Local Schools .....................................................................................................14
5. PROPOSED DEVELOPMENT STANDARDS ...............................................................14
6. PHASING ......................................................................................................................14
Photo from Invenergy’s Desert Star facility, located at 28100 W. Judd Rd, Buckeye 85326

1. DESCRIPTION OF THE REQUEST
This application narrative supports a request for a rezone of APN 503-84-040D, an approximately 57-
acre private property directly adjacent to the Sun Valley substation and north of Sun Valley Parkway
within the City of Buckeye for the Cloud Cap Energy Storage project, a proposed battery energy
storage system (“BESS”) facility (the “Project”). This request has been submitted along with a Minor
Subdivision application and Conditional Use Permit application, and precedes Site Plan application.
Enclosed here is the required application, including a rezoning exhibit, legal exhibit, pre-application
conference (“PAC”) summary, and citizen participation report to provide a complete application. To
further inform the request, a preliminary site plan is included.
The Project and this request are compatible with the General Plan’s land use designation of Rural.
Per the Buckeye Planning and Zoning map, the Project area is currently zoned as Planned Community
(PC), an Obsolete Zoning District. According to the Buckeye City Development Code § 2.9, obsolete
PC parcels with no Community Master Plan (CMP) are strongly encouraged to be rezoned as R1-43.
As noted in the Project’s PAC comment packet, the planning department supports rezoning to R1-43.
Consistent with this guidance and approval of the amended Development Code on October 21, 2025,
the Project seeks a rezone of the Project area to R1-43.
2. PROJECT INFORMATION
Nature of the Project
The proposed use of the subject land would include up to 1 gigawatt of battery storage. The primary
components of the Project would include:
a. Up to two onsite substations
b. Battery Energy Storage System (BESS)
c. An operation and maintenance (O&M) building, and
d. Associated civil infrastructure, including fencing, access driveways and gates, on-site
parking, drainage channels or retention basins, and signage.
The Project would be built in up to three phases. The current proposed scope of each phase is shown
on the second sheet of the preliminary site plan. The size of each phase may change depending on
what best supports Arizona utilities’ needs. Up to 200 construction workers would be employed
across all phases of construction. At full capacity, we anticipate approximately 4 to 8 full-time and
competitively compensated positions. The Project would be expected to operate for approximately
20 years.
Battery Energy Storage System
The energy storage system would charge and store energy, supporting Arizona’s growing power grid.
The Project would help stabilize Arizona Public Service’s (APS) system by absorbing excess energy
from the neighboring Sun Valley substation and discharging during high-use hours to cover demand
peaks.
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The BESS would be in non-occupiable storage containers composed of batteries, with battery
modules in trays that fit into racks. The batteries would be controlled by a Battery Management
System, which monitors their condition and performance as well as runs them. They would be
monitored by Invenergy’s Control Center 24 hours a day, 7 days a week, and maintained by 4 to 8
on-site operations personnel during business hours.
The storage system would include an electronic security system. Climate control systems would keep
the batteries running at optimal and safe temperatures to maximize performance and longevity.
Should the air conditioning units fail, the batteries and their control systems have redundant
mechanisms to shut the batteries down. The BESS would be designed to meet all applicable life
safety codes.
Building Types & Design
The Project would include an operations and maintenance (O&M) building and two control houses
adjacent to the Project substations. The O&M building would house maintenance staff’s workspace,
equipment, and documents, and the control houses would store protective relay and communications
equipment. During operations, the O&M building would have potable water and a septic system. The
septic system would likely be a conventional gravity system, and an appropriate wastewater system
will be designed and presented to the City as part of construction permitting. The design and
construction of the buildings would be consistent with City building standards.
3. LAND INFORMATION
Current and Proposed Site Conditions
Currently, the property is vacant with no occupiable structures. Exhibit IV in the Rezoning Exhibit,
included on the next page, shows the current land use of the Project site and surrounding area. A
project data table, providing the parcel acreage and location, is included further down in the
narrative, and included as Exhibit VI in the Rezoning Exhibit.
Future site conditions would include up to two substations and a BESS system that would utilize
battery modules, inverters, and transformers. The Project would have an on-site O&M building for
Project personnel. A road would run from the Project parcel to the Sun Valley substation parcel,
connecting to the existing Sun Valley substation access road. Civil infrastructure would be designed
in conformance with the City of Buckeye’s codes and standards and Buckeye Fire Department’s
requirements to enable effective site circulation and access. A preliminary site plan showing
additional details is included in the application packet.
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Map of Surrounding Properties’ Current Land Uses
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Vicinity Information and Relationship to Surrounding Properties
Nearly all of the surrounding parcels are undeveloped, rural land, as shown in Exhibit IV in the
Rezoning Exhibit. The exception is the Sun Valley substation, which adjoins the Project to the north. A
vicinity map showing the substation, project, and surrounding area is included on the next page, and as
Exhibit I of the Rezoning Exhibit. The substation is zoned as PC and has the General Plan land use
designation of Rural. The property to the west is zoned PC, with no Community Master Plan (CMP), and
a General Plan land use of Rural. The properties to the east and south are zoned as PC and within the
Sun Valley Villages CMP, with a General Plan land use of Master Planned Community. The Sun Valley
Villages Land Use Exhibit in the approved CMP shows the parcel to the east slated for a Commerce Park
and the parcel to the south as High Density Residential. Maps of the current General Plan land use and
Zoning are included below, and as Exhibit III and Exhibit II of the Rezoning Exhibit.
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Map of Project Vicinity
6

Map of Current General Plan Designation
No changes are proposed from the current general plan.
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Current General Plan Designation, Zoning, and Conformance to Land Use Plans
The Project is compatible with the Buckeye General Plan’s land use designation of Rural. Per the
Buckeye Planning and Zoning map, the Project area is zoned PC, which is an Obsolete Zoning District.
According to the Buckeye City Development Code § 2.9, obsolete PC parcels with no CMP are
strongly encouraged to be rezoned to R1-43. Consistent with this guidance and approval of the
amended development code on October 21, 2025, the Project seeks a rezone of the Project area to
R1-43, and will pursue a Conditional Use Permit to develop the Project as a BESS facility pursuant to
Table 3: 1-1 in the Buckeye City Development Code. A BESS facility is consistent with surrounding
land uses, including the neighboring Sun Valley substation.
Additionally, the Project is consistent with approved future land uses. The Sun Valley Villages Land
Use Exhibit in the approved CMP shows the parcel to the south as High Density Residential and the
east slated for a Commerce Park. A map of future land uses is shown on the following pages, and as
Exhibit V in the Rezoning Exhibit. A BESS facility is an unobtrusive neighbor, primarily frequented by
a few operations employees. With limited vehicle trips and screening to match the character of the
neighborhood, the Project is a low intensity land use and consistent with the approved High Density
Residential and Commerce Park land uses. Invenergy is well versed in developing, constructing, and
operating sites that coexist with residential developments, and currently operates a BESS facility
located between the Agua Fria Ranch and Rancho Estates homeowners’ associations in Youngtown.
Additionally, the Project is designed with the Use-Specific Standards set out in the Development
Code, including a 150-foot setback of the BESS enclosures from the High Density Residential zoning.
Beyond being an inconspicuous neighbor, the Project would enhance the electrical reliability of the
grid, a valuable asset to commerce parks, which typically require robust and reliable electrical
power.
Furthermore, the Project is aware of real estate agreements made by the property owner of the eastern
and southern parcels to allow the land to be developed as a solar and BESS facility. Should the
appropriate entitlements be approved for those projects, a solar and/or BESS use of those parcels would
be highly consistent with the proposed Project.
To the Project’s knowledge, no new entitlements have been submitted for the parcel to the north or
west. Given the Sun Valley Substation’s key role in supporting the electrical grid, we would expect the
northern parcel to be used for electrical infrastructure for the foreseeable future. The Project cannot
confirm the future development plans of the parcel to the west, and is not aware of any approved
entitlements. A BESS facility is compatible with these future uses, based on the information available.
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Map of Current Zoning Designation
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Map of Surrounding Properties’ Future Land Uses
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Design and Type of Landscaping
The landscape plan will be designed to stabilize soil and control erosion around the perimeter of the
Project. A seed mix of native and naturalized species will be selected that will provide visual benefits
and fit in with the surrounding landscape.
The Project is remote and does not significantly impact the public view. The closest residences are a
minimum of 2 miles away, and the Project is setback more than 1,500 feet from Sun Valley Parkway.
The only building in the vicinity is the APS substation, which services utility personnel. The Project’s
preliminary landscaping plan provides for non-scalable concrete masonry unit (CMU) fence on all
sides with vegetative screening along all sides except where bordering the SunValley substation, and
this may be subject to change based on the future approved entitlements of neighboring parcels.
The Project will finalize the fencing design with the City during Site Plan permitting based on the
approved entitlements of surrounding parcels at the time of Site Plan permitting. Conceptual
illustrations showing current anticipated visual screening are attached to the Project’s Conditional
Use Permit application.
The Project will comply with all requirements of Section 3.2.2.A in the Development Code, including
but not limited to the applicable landscaping requirements for BESS in Section 5.4 of the
Development Code. Wall and landscape screening as well as the final landscaping plan shall be
provided to the City as part of Site Plan Review.
Drainage
The Project has added preliminary locations for retention basins and included an approximate
anticipated retention volume for the site on the Preliminary Site Plan. Should entitlement permits be
granted by the City of Buckeye, the Project will develop a Conceptual Grading and Drainage plan,
Drainage Memo, and conduct associated studies as part of Site Plan permitting, such that drainage and
stormwater management methods for the site meet the requirements of the City of Buckeye’s code.
Proposed Percentage of Parks and Open Space
The Project is not a recreational facility and therefore does not have open space or parks within the
fenceline.
Proposed Trails
There are no identified future trails or paths in Parks and Recreation Master Plan in the vicinity of the
site, and therefore no trails are planned within the Project.
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Project Data Table1
4. IMPACT TO CITY SERVICES
Roadway Circulation
The Project would utilize the same access route as the Sun Valley substation. Primary access to the
property would be provided via Sun Valley Parkway and the private access road to the Sun Valley
substation. All necessary easement agreements have been executed.
The Project would not affect mobility and connectivity in the City. The operation of the proposed
Project will not permanently or significantly impact the transportation corridors within the City of
Buckeye or the State of Arizona. There would be some increased traffic during the construction
period for the delivery of equipment/supplies and from the construction workforce. Still, there
would be no significant increase in traffic during the operational life of the Project. Parking and
internal access roads would be designed to City code, and plans would be submitted for approval in
the Site Plan Review permit.
Fire Protection and Fire Safety System
Invenergy has extensive experience safely constructing and operating battery projects in numerous
locations across Arizona, and operates or consults on 11 projects across the state. Installing and
safely operating battery facilities in desert conditions helped inform the current generation of
technologies, which continue to reach new highs in terms of safety and reliability. Invenergy’s
equipment suppliers follow stringent quality standards, and its battery equipment is tested and
certified by third-party professionals. Additionally, codes and standards are updated regularly to
incorporate industry lessons learned, and the Project will follow the latest versions of each code and
standard under the oversight of the Buckeye Fire Department.
The maturation of the energy storage industry has continued to improve the products, project
designs, and response tactics used, ensuring that safety remains the number one priority. Invenergy
takes several steps to make safety foundational to its design, construction, and operation, including
choosing lithium-iron phosphate batteries, testing to UL 9540 and NFPA 855 standards, conducting a
site-specific hazard mitigation analysis, and creating a site-specific emergency response plan in
1 The site enhancement landscaping percentage will be provided at Site Plan permitting and will be
limited to perimeter landscaping.
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coordination with the local response team. With the Buckeye Fire Department Station 704
approximately 3 miles from the Project site, the Project is within reach of emergency services.
Examples of this design for the battery storage system include:
 Two emergency ingress/egress points for the battery area
 Access road surrounding the battery storage system
 Heat & gas detectors or external flame or heat detectors
 Central fire alarm control panel at the muster point
 First responder station containing a central fire alarm control panel that actively monitors
each enclosure on site for hazards
 Remote monitoring
 Site cameras
 Enclosure deflagration control in compliance with NFPA 855
 HVAC units and/or chillers to cool and provide humidity control to the battery cabinets
 Water tank for Buckeye Fire Department use
Additional information about the Project’s fire safety can be found in the Conditional Use Permit
application.
Source of Water
The Project will use relatively small amounts of water during construction and operation. During
construction, non-potable water will be used to facilitate soil compaction and, as needed, to control
fugitive dust on exposed soils. This water would be brought on-site by construction personnel.
During operation, the Project will use a small amount of water for the O&M building and water tank.
Water for the minimal operations needs could be provided by digging a well meeting local permitting
requirements. Alternatively, water could be delivered to the site and stored in water tanks.
Wastewater Management
Portable toilets, a temporary septic system, and/or holding tanks will be used to provide needed
wastewater facilities during construction. During operations, a septic system would be installed.
Employment
The Project would generate employment opportunities during construction and operation. During
construction, the number of workers on the site would be expected to vary over the construction
period and by phase, but would in total employ approximately 100 to 200 people.
At full operating capacity, approximately 4 to 8 full-time workers would be employed during the
operation of the Project. These personnel would perform maintenance and security functions.
Police Protection
There are no anticipated impacts to police services. Cloud Cap will design measures to secure the site,
and O&M personnel will be present for day-to-day operations activities.
Prior to construction, Invenergy will coordinate with the Buckeye Police Department to establish open
lines of communication ahead of project site activity. Proposed security measures will be included in the
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plans submitted at Site Plan permitting.
Impact to Local Schools
As a private industrial facility, there are no anticipated impacts to local schools.
5. PROPOSED DEVELOPMENT STANDARDS
The project proposes to follow the development standards in Section 3.2.2.A., Article 4 and Article 5 of
the Development Code to the extent applicable except as noted below.
The table below lists the City of Buckeye zoning standards for the R1-43 zone, as set out in Table 4.1-1:
Dimensional Standards.
City of Buckeye R1-43 Zoning Standards
Lot Dimensions, Setbacks, minimum Lot Coverage, Building
minimum maximum (%) Height,
Lot Size Lot Front Side Rear maximum (ft)
(sq. ft.) Width (ft.) (ft.) (ft.)]
(ft.)
Current 43,000 140 40 20 30 30 352
Standards
6. PHASING
The Project would be built in up to three phases. The current proposed scope of each phase is shown on
the second sheet of the preliminary site plan. The size of each phase may change depending on what
best supports Arizona utilities’ needs.
2 Accessory structures, including transmission structures are exempted from the height limit, subject to
approval in the Site Plan application. Development Code § 3.2.2.A.2.
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