CPA2022010 BOS REPORT.PDF

Maricopa County — Formal (2022-12-07)

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December 7, 2022 
CPA2022010 
Page 1 of 2 
Report to the Board of Supervisors 
Prepared by the Maricopa County Planning and Development Department 
 
 
 
Board Hearing Date: 
December 7, 2022 
 
Case #/Title:   
 
 
CPA2022010 – Harquahala Sun III 
 
Supervisor District: 
5 
 
Applicant:  
Kimley-Horn 
 
Owners: 
Multiple – See Parcel Exhibit in Planning & Zoning Packet 
 
Request: 
Major Comprehensive Plan Amendment (CPA) to change 
the land use designation in the Vision 2030 Maricopa County 
Comprehensive Plan from Rural Development Area to Utilities. 
CPA approval is by Resolution. 
 
Site Location: 
Generally located between Lower Buckeye Rd. to the north, 
Elliot Rd. to the south, 539th Ave. to the west and the 487th 
Ave. alignment to the east 
 
Site Size: 
Approx. 9,033 acres 
 
County Island Status: 
No 
Additional 
Comments: 
The 
applicant 
seeks 
a 
Major 
Comprehensive 
Plan 
Amendment to change the land use designation in the 
Comprehensive Plan to utilities in order to develop a solar 
installation. The subject site is identified as having Rural 
Development Area land use designation in the Vision 2030 
Maricopa County Comprehensive Plan. All approx. 9,033 
acres are designated as Rural Development Area (0-1 
d.u./acre).  This designation encourages low-density rural 
residential and agricultural uses.  Staff received three (3) 
letters from adjacent/internal jurisdictions (Town of Carefree, 
Yavapai County, Pima County) expressing no concerns.  AZ 
Dept. of Game & Fish commented on the site regarding 
wildlife and hydrology.  AZSHPO and AZAG had no concerns.  
Luke Air Force Base requested that the applicant complete 
the DOD Siting Clearinghouse review.  The applicant agreed 
to complete the DOD Siting Clearinghouse review at the time 
of a future zone change. Staff received no opposition to this 
case.

December 7, 2022 
CPA2022010 
Page 2 of 2 
Commission  
 
Recommendation: 
On 11/3/22, the Commission voted 9-0 to recommend 
approval of CPA2022010 subject to conditions ‘a’ – ‘d’: 
  
a. 
Development and use of the site shall be substantial conformance with the 
narrative report entitled “Harquahala Sun III” dated revised October 7, 2022 and 
stamped received October 17, 2022, except as modified by the following 
conditions.  
 
b. 
Development and use of the site shall be in substantial conformance with the land 
use exhibit entitled “Harquahala Sun III” dated revised October 7, 2022 and 
stamped received October 13, 2022, except as modified by the following 
conditions. 
 
c. 
The land use designation of utilities approved as part of case CPA2022010 shall be 
subject to any applicable time limits set forth in the subsequent zone change. 
  
d. 
The applicant is proposing to develop a photovoltaic solar electric generating 
facility which, pursuant to the Maricopa County Comprehensive Plan, 
necessitates a change in the land use designation from Rural Development Area 
to Utilities. The proposal by the applicant represents a comprehensive approach 
to the subject property and will allow the applicant to pursue the proper 
entitlements pursuant to state law so that they can lawfully operate in 
unincorporated Maricopa County. This particular proposal is an appropriate plan 
for the property and is consistent with the overall intention of the comprehensive 
plan. However, in the event that the zone change or a zone change phase for this 
particular proposal is not approved by Maricopa County Board of Supervisors 
(BOS) within five (5) years from the date of Board approval of this comprehensive 
plan amendment, this amendment shall no longer be effective as the planning 
justification for this comprehensive plan amendment will no longer be present. In 
such instance, a change of the land use designation from Utilities to Rural 
Development Area will occur, and all comprehensive plan land use maps shall be 
altered to reflect as such, because this represents superior long-range planning by 
Maricopa County.  
 
Presented by: 
 
Adam Cannon, AICP, Senior Planner 
Reviewed by: 
 
Darren Gerard, AICP, Planning Manager   
 
Attachments: 
 
11/3/22 P&Z Packet (71 pages) 
 
 
CPA2022010 Resolution (2 pages) 
 
 
Note: 
11/3/22 Draft P&Z Minutes are not available as of the writing of this report, but can 
be provided upon request later when available.

CPA2022010 
Page 1 of 10 
Report to the Planning and Zoning Commission 
Prepared by the Maricopa County Planning and Development Department 
 
 
 
Case: 
CPA2022010 – Harquahala Sun III  
 
 
Hearing Date: 
November 3, 2022 
 
Supervisor District: 
5 
 
  
 
Applicant: 
Kimley-Horn  
 
Owners: 
Multiple – See Parcel Exhibit in Attachments 
   
Request: 
Major Comprehensive Plan Amendment (CPA) to change the land 
use designation in the Vision 2030 Maricopa County Comprehensive 
Plan from Rural Development Area to Utilities 
 
  
 
Site Location: 
Generally located between Lower Buckeye Rd. to the north, Elliot 
Rd. to the south, 539th Ave. to the west and the 487th Ave. alignment 
to the east 
 
  
Site Size: 
Approx. 9,033 acres 
 
Density: 
N/A 
 
County Island:  
No 
 
 
County Plan: 
Vision 2030 Maricopa County Comprehensive Plan – Rural 
Development Area (0-1 d.u./ac.) 
 
Municipal Plan: 
N/A 
 
Agency Comments: 
Yavapai County, Pima County, Town of Carefree, Luke Air Force 
Base (LAFB), Arizona Game & Fish Department (AZGFD), ADOT ROW 
Project Management, ADOT Southwest District, Arizona Attorney 
General’s Office, Arizona State Historic Preservation Office (AZSHPO) 
 
Support/Opposition: 
None received 
 
Recommendation: 
Approve with conditions

CPA2022010 
Page 2 of 10 
Project Summary: 
 
1. 
Kimley-Horn is requesting a Major Comprehensive Plan Amendment (CPA) to change the 
land use designation in the Vision 2030 Maricopa County Comprehensive Plan from Rural 
Development Area to Utilities to allow development of a phased utility-scale solar electric 
generating project generating approximately 1-gigawatt (GW) of electricity along with 
a battery energy storage system.  Due to the size of the project at 9,033.17 acres, a Major 
CPA is required. The applicant will subsequently be required to obtain a Zone Change 
with Overlay (including a precise Plan of Development) to IND-2 IUPD as part of the 
entitlement process within five (5) years (on initial phase or for the entirety of the 
development).  
 
2. 
The site is comprised of sixty-three (63) privately-owned, contiguous parcels located in 
the Harquahala Valley.  The valley is situated in between the Eagletail Mountain 
Wilderness area to the west and Saddle Mountain to the east.  Parcels adjacent to the 
site include a mix of private, state and federal ownership including land owned by the 
Arizona State Land Department (ASLD) and Bureau of Land Management (BLM). Several 
rural residential subdivisions such as Eagletail Ranches are located on the perimeter of or 
near the site.  A single parcel internal to the subject site that is not a part of the CPA 
request serves as an APS substation.  The applicant’s narrative does not specify whether 
site control options are secured for all of the parcels.   
 
3. 
Nearly all land used for solar energy projects are developed with the large fields of solar 
collectors that capture the energy through photovoltaic technology. The topography is 
flat which allows for development of solar energy with little or no additional grading. The 
site includes vacant, native desert land and some large agricultural parcels utilized for 
row crops.  Some washes are also present throughout the site.  In addition, the general 
area contains significant local electrical infrastructure including the aforementioned APS 
substation.  
 
4. 
Adjacent to the site are vacant, agricultural, industrial and rural residential uses.  Board 
approved CPAs and zone changes for solar projects adjacent to the site include Saddle 
Mountain Solar and Eagletail Solar Farm.  Additionally, the Board approved the Maricopa 
Solar and Storage Project in 2020 under CPA2020002.  The Maricopa Solar and Storage 
Project is an approx. 11,260 acre site to the northeast of the subject request.  Harquahala 
Sun III is expected to interconnect to the APS Delaney Substation.   
 
5. 
The narrative asserts that the proposed development meets the Comprehensive Plan 
Amendment criteria in the following manner:  
 
Whether the amendment constitutes an overall improvement to the Comprehensive Plan 
and is not solely for the good or benefit of a particular landowner or owners at a particular 
point in time.  
 
The narrative states that Harquahala Sun III is an improvement to the Comprehensive Plan 
due to the benefits to the state, county, local and regional economy.  According to the 
narrative, a future solar and battery storage development will provide employment for 
approximately 400-600 construction employees per 30 month construction phase for up 
to 4 construction phases.  The site is also expected to have 15 part-time seasonal 
employees and 20 part-time employees for equipment repair and replacement.  The

CPA2022010 
Page 3 of 10 
applicant will make efforts to hire individuals from the local area and region.  The 
applicant’s narrative references APS’s request for proposals to supply renewable energy 
to APS customers within the regional grid to meet Arizona’s Renewable Portfolio Standard 
which includes standards for investor-owned utilities at 45% by 2030 and 100% by 2050.  
Additionally, there will be little transportation infrastructure or water resources required to 
serve the site. Therefore, the amendment constitutes an overall improvement to the 
Vision 2030 Maricopa County Comprehensive Plan and is not solely for the good or 
benefit of a particular landowner/owners at a particular point in time. 
 
Whether the amendment will adversely impact all or a portion of the planning area.  
 
A. 
Altering acceptable land use patterns to the detriment of the plan – According to 
the narrative, the amendment will not alter any surrounding land uses or land use 
patterns.  The land is currently vacant or agricultural.  While this land will be 
unavailable during the life of the project, the land can return to its agricultural 
function when the project ceases.  Moreover, this site is situated in the vicinity of 
other utility uses in Maricopa County and comprises a key use-sector of 
unincorporated Maricopa County including utilities (solar and electric generating 
stations), agriculture and rural-residential. 
 
B. 
Requiring public expenditures for larger or more expensive infrastructure - The 
narrative states that the project would not require public expenditures for larger 
or more expensive infrastructure.  The costs of the project’s infrastructure needs 
shall be borne by the developer. 
 
C. 
Requiring public improvements to roads, sewer, or water systems that are needed 
to support the planned land uses – The narrative states that the project would 
require improvements to roads (underground cabling and access) and on-site 
water and wastewater service using hauled or well water and septic.  Existing 
roads are expected to serve the project and any additional project infrastructure 
needs shall be borne by the developer. 
 
D. 
Adversely impacting planned uses because of increased traffic – The narrative 
indicates there would be increased traffic during the four construction phases 
(approximately 30 months per phase) for the delivery of equipment / supplies and 
the commuting of the construction work force, but there would be no significant 
increase in traffic during the operational life of the project following the 
construction phase.  Access to existing uses within and around the site area would 
remain open to owners.  A traffic statement will be provided in a future zone 
change proposal if the CPA is approved.   
 
E. 
Affecting the livability of the area or health or safety of present and future residents 
– During the construction period, dust control measures shall be utilized to minimize 
fugitive dust generation including proper grading and erosion control.  
Additionally, the project will follow federal, state and local regulations regarding 
the production, use, storage, transport or disposal of hazardous materials, but the 
construction or operation is not expected to include hazardous activities, 
materials, processes or outputs.  Wildlife prevention and mitigation measures will 
be incorporated into the Plan of Development.  Fire hazard risks will be controlled

CPA2022010 
Page 4 of 10 
through weed control.  Therefore, the project will not affect the livability of the 
area or health or safety of present and future residents. 
 
F. 
Adversely impacting the natural environment or scenic quality of the area in 
contradiction to the plan – The applicant states that the project will not significantly 
impact the natural environment or overall scenic quality of the area.  There are 
key measures of responsibility that demonstrate an applicant’s commitment to 
avoiding adverse impacts to the natural environment and scenic quality of a site.  
These measures are subjective in a sense, but may include animals, plants, 
historical resources, scenic views and hydrology/ground disturbance.  
 
Animals 
The applicant performed a preliminary site investigation to identify habitats for 
creatures.  The Arizona Game and Fish Department (AZGFD) has commented on 
the proposed project regarding measures to protect wildlife encountered on the 
site such as the Mule Deer, Sonoran Desert Tortoise, Sonoran Pronghorn, Kit Fox, 
Gila Monster, Arizona Toad, Western Burrowing Owl, LeConte’s Thrasher and Bald 
Eagle.  Satisfaction of those comments are only required at the Zone Change with 
Overlay stage (where a precise Plan of Development is required); however, Staff 
expects coordination to occur during the CPA process. The applicant 
demonstrated some coordination with AZGFD. 
 
Plants 
The applicant will salvage or dispose of protected native plants in accordance 
with AAC Title 3, Chapter 3, Article 11. 
 
 
Historical Resources 
The applicant indicated that they performed a preliminary site inspection to 
identify cultural resources, but did not perform a survey.  AZSHPO did not comment 
on the proposal. Satisfaction of SHPO comments is only required at the time of 
construction permitting.  Development will avoid any known archeological sites 
and any discovery of human remains or funerary objects will be reported to the 
Director of the Arizona State Museum upon discovery per state law. 
 
Scenic Views 
The narrative indicates that the height of panels and any screening from 
residential will not obscure scenic views. The applicant noted that screening from 
residential will be required to minimize the visual impact of the solar panels on 
residence owners.   
 
 
Hydrology/Ground Disturbance 
The applicant does not address hydrology in detail in the narrative; however, notes 
that any environmental impacts will be evaluated as part of the zone change and 
plan of development stage if approved.  For ground disturbance, it is not 
expected that major road or transportation network improvements will be 
required.  Additionally, the applicant will implement dust mitigation, erosion 
control BMPs and select soil stabilization/enhancement where existing erosion is 
encountered.

CPA2022010 
Page 5 of 10 
 
 
Whether the amendment is consistent with the overall intent of the Comprehensive Plan. 
 
The applicant’s narrative states that the request is consistent with the overall intent of the 
Comprehensive Plan by addressing the Strategic Priorities for Maricopa County such as 
protecting public health and safety, promoting stable economic growth, maintaining a 
healthy environment, providing adequate community services and ensuring tax money 
is spent efficiently. The applicant argues that the consistency to the intent is found within 
the request’s consistency to the specific goals and policies each addressing the county’s 
quality of life. Staff does not share the argument that consistency to the specific goals 
and policies indicates outright consistency to the intent of the Plan; however, it would be 
likely that a proposal does if it is overwhelmingly consistent.  The applicant states the 
proposal provides fiscally responsible alternative energy services and effective and 
efficient infrastructure to implement delivery of services that help promote and 
contribute to a healthy community that residents can enjoy. Staff feels that this statement 
supports a component of the mission of the Plan which is providing responsible, necessary 
public services so that residents can enjoy living in a healthy and safe community. 
 
The extent to which the amendment is consistent with the specific goals and policies 
contained within the plan. 
 
The applicant’s narrative contains a substantial list of Goals and Policies from the Vision 
2030 Maricopa County Comprehensive Plan. This staff report identifies which Goals and 
Policies the applicant’s narrative addressed. 
 
Vision 2030 Maricopa County Comprehensive Plan 
 
Land Use Element – Goal 3, Policy 7, Policy 20, Policy 22, Policy 27, Policy 31, Policy 33 
 
Transportation Element – Goal 1, Goal 2, Goal 3, Policy 11, Policy 12, Policy 14 
 
Environment Element – Goal 1, Policy 2, Policy 3, Policy 4, Policy 5 
 
Economic Growth Element – Goal 1, Policy 5, Policy 10 
 
Growth Area Element – Goal 1, Policy 1 
 
Open Space Element – Goal 1 
 
Water Resources Element –Goal 4, Policy 2, Policy 4, Policy 5, Policy 7 
 
Energy Element – Goal 1, Goal 2, Policy 6 
 
Cost of Development Element – Goal 2, Policy 2 
 
Other pertinent information as requested by the Maricopa County Planning Department 
Staff. 
 
The applicant was responsive and provided quality information as requested by 
Maricopa County Planning Department Staff.

CPA2022010 
Page 6 of 10 
2018 Aerial Map 
 
 
Zoning Map – Rural-190, Rural-43 Zoning Districts & Surrounding Districts

CPA2022010 
Page 7 of 10 
Land Use Exhibit Excerpt – Current & Proposed Land Use – Rural Development Area to Utilities 
 
Existing On-Site and Adjacent Zoning / Land Use: 
 
6. 
On-site: 
 
Rural-43 & Rural-190 / Vacant/Agricultural  
North: 
Rural-43 / Vacant/Agricultural & Rural Residential 
South: 
Rural-43 & Rural-190 / Vacant/Agricultural, Rural Residential & Utilities 
East: 
Rural-43 & Rural-190 / Vacant/Agricultural, Rural Residential & Utilities 
West: 
Rural-43 / Vacant/Agricultural & Rural Residential 
 
 
Utilities and Services: 
 
7. 
Water: 
Private Well or Hauled Water 
Wastewater: 
Septic 
School Districts: 
Buckeye Union High School District #1 
 
Arlington Elementary School District #47 
Fire: 
Harquahala Valley Fire District 
Police:  
MCSO  
 
Right-of-Way: 
 
8. 
The following table includes existing and future right-of-way* and the future classification* 
based upon the Maricopa County Department of Transportation (MCDOT) Major Streets 
and Routes Plan.

CPA2022010 
Page 8 of 10 
Street Name 
Existing ½ Width R/W 
Future R/W* (Full) 
Future Classification* 
Baseline Rd. 
65’ (Varies) 
130’ 
Minor Arterial 
Harquahala Valley Rd. 
55’ (Varies) 
200’ 
Parkway 
Elliott Rd. 
Unknown (Varies) 
130’ 
Minor Arterial 
539th Ave. 
40’ (Varies) 
130’ 
Minor Arterial 
*Required dedication and future classification of ROW is tentative and subject to change 
and will be established by MCDOT during a future Plan of Development review. 
 
Adopted Plan: 
 
9. 
Vision 2030 Maricopa County Comprehensive Plan: The entire site (approx. 9,033.17 
acres) is designated as Rural Development Area (0-1 d.u./ac.).  The Rural Development 
Area land use designation encourages low-density rural residential and agricultural uses. 
 
Public Participation Summary: 
 
10. 
The applicant posted the subject site and staff notified all property owners within 300’ of 
the site.  Pursuant to state law, Staff issued enhanced notification letters to all adjacent 
and internal jurisdictions to Maricopa County, select state and regional agencies and 
Luke Air Force Base (LAFB). Staff received three (3) letters from adjacent/internal 
jurisdictions (Town of Carefree, Yavapai County, Pima County) expressing no concerns.  
LAFB sent two comment letters to Staff asking the applicant to undergo informal review 
through the DOD Siting Clearinghouse for Energy.  LAFB did not issue a determination 
stating whether the proposal would impact flying operations though noted in a phone 
conversation that they were pleased with what the applicant included in their narrative.  
The Arizona Attorney General’s Office stated that there are no objections to the request 
as the site does not have an adverse impact on LAFB and does not appear that the site 
will have a significant impact on automobile traffic.  ADOT Right-of Way Project 
Management and ADOT Southwest District had no comments.  Comments received from 
Arizona Game & Fish Department (AZGFD) and associated responses by the applicant 
are included in the attachments section and are not actionable from the County’s 
perspective until the Zone Change and Plan of Development stage.  The Arizona State 
Historic Preservation Office (AZSHPO) commented that they had no comments at this 
time.  
 
11. 
According to the Public Participation Results Report submitted by the applicant, the 
applicant did not conduct a public meeting and felt it was unnecessary to do so 
because the applicant received approval on a previous case, remoteness of the site and 
lack of surrounding facilities.  Staff does not share this position; however, the applicant is 
free to conduct public participation as the applicant desires outside of what is required 
by County or State law.   
 
12. 
The Public Participation Results Report included a record of all phone calls and their 
communications.  All of the communications are information requests.  One individual 
asking for information also asked if their property could be included in the request.   
 
13. 
County Staff received no opposition or support letters for the request.

CPA2022010 
Page 9 of 10 
Outstanding Concerns from Reviewing Agencies: 
 
14. 
N/A 
 
Staff Analysis: 
 
15. 
The state and Maricopa County recognize the potential environmental and economic 
benefits that solar technology can provide.  Harquahala Sun III will use photovoltaic 
technology that generates energy from sun absorption.  Photovoltaic technology differs 
from other techniques that required vast amounts of water to cool the units.  In contrast, 
very little water is utilized for photovoltaic technology.  As a result, this development 
would not pose a threat to groundwater depletion.  The battery storage component 
associated with this proposal assists with additional production and any concerns 
associated with fire will be resolved prior to any construction permit issuance. 
  
16. 
Staff believes the proposed solar facility is well suited to this rural area.  Solar facilities 
require large amounts of relatively flat land, and the vast majority of the subject site is 
flat.   Staff agrees with the applicant that the subject site is suitable due to relative 
proximity to electrical transmission lines, nearby stations and substations, and because 
the surrounding area is undeveloped.  Staff agrees with the applicant that the project 
will not detrimentally affect the visual quality of the area.  Since the area is primarily 
undeveloped vacant land in near proximity to other existing utility-scale solar projects, 
staff believes there will be minimal impacts to the surrounding area.   
 
17. 
Promoting the development of solar energy over the past several years in Maricopa 
County reinforces the County’s interest in promoting the County as an economic leader 
for solar development. Staff believes Harquahala Sun III would add to this effort in a 
positive way by providing the potential for 400-600 temporary construction jobs for up to 
4 construction phases lasting approximately 30 months each.  There will also be small 
number of seasonal employment opportunities for County residents.  
 
18. 
Staff believes Harquahala Sun III is consistent with and meets the goals and policies of the 
Comprehensive Plan. Staff’s position is that this project, as proposed and as governed by 
the recommended conditions, represent proper long-term land use planning in the 
region and for Maricopa County as a whole.   
 
Recommendation: 
 
19. 
For the reasons outlined in this report, staff recommends the Commission motion for 
Approval, subject to conditions ‘a’ – ‘d’. 
 
a. 
Development and use of the site shall be substantial conformance with the 
narrative report entitled “Harquahala Sun III” dated revised October 7, 2022 and 
stamped received October 17, 2022, except as modified by the following 
conditions.  
 
b. 
Development and use of the site shall be in substantial conformance with the land 
use exhibit entitled “Harquahala Sun III” dated revised October 7, 2022 and 
stamped received October 13, 2022, except as modified by the following 
conditions.

CPA2022010 
Page 10 of 10 
 
c. 
The land use designation of utilities approved as part of case CPA2022010 shall be 
subject to any applicable time limits set forth in the subsequent zone change. 
  
d. 
The applicant is proposing to develop a photovoltaic solar electric generating 
facility which, pursuant to the Maricopa County Comprehensive Plan, 
necessitates a change in the land use designation from Rural Development Area 
to Utilities. The proposal by the applicant represents a comprehensive approach 
to the subject property and will allow the applicant to pursue the proper 
entitlements pursuant to state law so that they can lawfully operate in 
unincorporated Maricopa County. This particular proposal is an appropriate plan 
for the property and is consistent with the overall intention of the comprehensive 
plan. However, in the event that the zone change or a zone change phase for this 
particular proposal is not approved by Maricopa County Board of Supervisors 
(BOS) within five (5) years from the date of Board approval of this comprehensive 
plan amendment, this amendment shall no longer be effective as the planning 
justification for this comprehensive plan amendment will no longer be present. In 
such instance, a change of the land use designation from Utilities to Rural 
Development Area will occur, and all comprehensive plan land use maps shall be 
altered to reflect as such, because this represents superior long-range planning by 
Maricopa County.  
 
Presented by: 
Adam Cannon, AICP, Senior Planner 
Reviewed by: 
Matthew Holm, AICP, Planning Supervisor 
 
Attachments: 
Case Map (1 page) 
 
Land Use Exhibit (reduced 8.5”x11”, 1 page) 
 
Narrative Report (25 pages) 
 
Parcel Exhibit (1 page) 
 
MCESD Comments (1 page) 
 
AZGFD Comments & Applicant Responses (17 pages) 
 
AZSHPO Comments (1 page) 
 
LAFB Comments (3 pages) 
 
AZAG Comments (2 pages) 
 
ADOT ROW Project Management Comments (2 pages) 
 
ADOT Southwest District Comments (3 pages) 
 
Yavapai County Comments (1 page) 
 
Pima County Comments (1 page) 
 
Town of Carefree Comments (1 page)

MARICOPA COUNTY
/
Maricopa County Planning & Development - Phoenix, AZ
5
Gross Acres: 9033.17 approx.
Generated October 24, 2022 15:28 PM
CPA2022010
Application Name:
Legal Description
Harquahala Sun III
Applicant
Case Address
T01S R09W 4, T1N R09W 20, T1N R09W 21, T1N R09W 22, T1N R09W 25, T1N R09W 26, T1N R09W 27, T1N R09W 28, T1N R
KEITH NICHTER for KIMLEY-HORN
Applicant Phone/Email
Parcel Primary:401-57-006
602.313.7206
KEITH.NICHTER@KIMLEY-HORN.COM
Map scale 1:85,412
Supervisor District No.
401-55-007G,  401-55-024,  401-55-026+
MAJOR CPA TO CHANGE THE LAND USE DESIGNATION IN THE VISION 2030 MARICOPA COUNTY
COMPREHENSIVE PLAN FROM RURAL DEVELOPMENT AREA TO UTILITIES
5.3585 in

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N
0'
2,000'
4,000'
HARQUAHALA SUN III
MARICOPA COUNTY, AZ
EXISTING & PROPOSED LAND USE EXHIBIT
COMPREHENSIVE PLAN AMENDMENT
DRAWN BY: JK
SCALE: APPROX.
LEGEND
PROPOSED CPA
BOUNDARY
ARIZONA STATE LAND
DEPARTMENT (ASLD)
BUREAU OF LAND
MANAGEMENT (BLM)
RURAL DEVELOPMENT
AREA
UTILITIES
PRIVATE LAND
TOWNSHIP/RANGE LINE
T01N R08W
T01S R08W
T01N R09W
T01S R09W
T01N R09W
T01N R08W
T01S R09W
T01S R08W
W LOWER BUCKEYE RD
S 487TH AVE
S 539TH AVE
W ELLIOT RD
W BASELINE RD
W SOUTHERN AVE
W LOWER BUCKEYE RD
S 487TH AVE
S 539TH AVE
W ELLIOT RD
W BASELINE RD
W SOUTHERN AVE
S 507TH AVE
S 507TH AVE
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
T01N R08W
T01S R08W
T01N R09W
T01S R09W
T01N R09W
T01N R08W
T01S R09W
T01S R08W
W LOWER BUCKEYE RD
S 487TH AVE
S 539TH AVE
W ELLIOT RD
W BASELINE RD
W SOUTHERN AVE
W LOWER BUCKEYE RD
S 487TH AVE
S 539TH AVE
W ELLIOT RD
W BASELINE RD
W SOUTHERN AVE
S 507TH AVE
S 507TH AVE
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
CPA2022010
REVISED:
FRIDAY,OCTOBER 7,2022
EXISTING LAND USE - RURAL DEVELOPMENT AREA
PROPOSED LAND USE - UTILITIES

kimley-horn.com 
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
 
 
 
Kimley-Horn and Associates 
HARQUAHALA SUN III
COMPREHENSIVE PLAN AMENDMENT 
PROJECT NARRATIVE  
CPA2022010 
05-31-2022, 
Revised Friday, 09-16-2022

Page 1 
kimley-horn.com 
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
Contents 
A. EXECUTIVE SUMMARY ....................................................................................................... 2 
I. ON-SITE AND REGIONAL LOCATION ............................................................................................ 3 
II. CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY ACREAGES....................................... 4 
III. ROADS/TRANSPORTATION SYSTEMS SERVING THE PROPOSED PROJECT ........................ 4 
IV. SUITABILITY WITH SURROUNDING LAND USES......................................................................... 5 
EXISTING SURROUNDING SOLAR (UTILITY) LAND USE APPROVALS .......................................... 6 
B. WHETHER THE AMENDMENT CONSTITUTES AN OVERALL IMPROVEMENT TO THE 
COMPREHENSIVE PLAN AND IS NOT SOLELY FOR THE GOOD OR BENEFIT OF A 
PARTICULAR LANDOWNER OR OWNERS AT A PARTICULAR POINT IN TIME............... 7 
C. THE AMENDMENT WILL NOT ADVERSELY IMPACT ALL OR A PORTION OF THE 
PLANNING AREA BY: .......................................................................................................... 8 
I. 
ALTERING ACCEPTABLE LAND USE PATTERNS TO THE DETRIMENT OF THE PLAN. ...... 8 
II. 
REQUIRING 
PUBLIC 
EXPENDITURES 
FOR 
LARGER 
AND 
MORE 
EXPENSIVE 
INFRASTRUCTURE. .............................................................................................................................. 8 
III. 
REQUIRING PUBLIC IMPROVEMENTS TO ROADS, SEWER, OR WATER SYSTEMS THAT 
ARE NEEDED TO SUPPORT THE PLANNED LAND USES. ............................................................... 9 
IV. 
ADVERSELY IMPACTING PLANNED USES BECAUSE OF INCREASED TRAFFIC. ............... 9 
V. 
AFFECTING THE LIVABILITY OF THE AREA OR HEALTH OR SAFETY OF PRESENT AND 
FUTURE RESIDENTS. ........................................................................................................................ 10 
VI. 
ADVERSELY IMPACTING THE NATURAL ENVIRONMENT OR SCENIC QUALITY OF THE 
AREA IN CONTRADICTION TO THE PLAN. ...................................................................................... 10 
D. WHETHER THE AMENDMENT IS CONSISTENT WITH OVERALL INTENT OF THE 
COMPREHENSIVE PLAN:.................................................................................................. 12 
E. THE EXTENT TO WHICH THE AMENDMENT IS CONSISTENT WITH THE SPECIFIC 
GOALS AND POLICIES CONTAINED WITHIN THE PLAN. ............................................... 12 
F. COMPREHENSIVE PLAN AMENDMENT MAP EXHIBIT.................................................... 21 
G. COMPREHENSIVE PLAN AMENDMENT LEGAL DESCRIPTIONS EXHIBITS .................. 22

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A. EXECUTIVE SUMMARY  
HV Sunrise, (hereafter, “Applicant”) on behalf of the subject property owners (CV Harquahala LLC, WPI II-
Harq III Farm AZ LLC, Rancho Amable SPE LLC, CV Farming LLC, Shelli Lamoreaux Living Trust/ETAL, 
PSC-94 Site LLC, Waydon Farms LLC, Davenport Stephanie/TMV Income Trust) is requesting a major 
Comprehensive Plan Amendment (CPA) of the Vision 2030 Comprehensive Plan to change the land use 
designation of ±9,033.17 acres from Rural Development Area to Utilities. The CPA request will be 
accompanied by a subsequent zone change request to rezone the underlying parcels from RU-190 and 
RU-43 to the IND-2 IUPD Zone. The CPA will affect the land use designation of the following sixty-three 
(63) underlying parcels:  
 
Assessor Parcel Numbers (APN’s): 401-55-023, 401-55-024, 401-55-026, 401-55-027, 401-55-028, 401-
55-029, 401-55-030, 401-56-001, 401-56-002, 401-56-018, 506-27-014, 506-27-015, 506-27-016, 506-27-
017, 506-27-018, 506-27-019, 506-27-020, 506-28-001, 506-28-002, 506-28-004, 506-28-010, 506-28-011, 
506-28-012, 506-28-013, 506-28-014, 506-28-015, 506-28-016, 506-28-020, 401-55-007G, 401-55-032A, 
401-55-032B, 401-56-025B, 506-27-034A, 506-28-007B, 506-28-008A, 506-28-009B, 506-28-025A, 506-
28-026A, 506-28-027A, 506-27-033, 401-56-007, 401-56-008, 401-56-009, 401-56-010, 401-56-011, 401-
56-013, 401-56-021, 401-56-012B, 401-56-003C, 401-56-003D, 401-56-003E,401-56-003F, 401-56-025A, 
506-27-011, 506-27-010, 401-57-006, 506-28-018, 506-28-019, 401-57-007B, 401-56-006, 401-56-024, 
506-28-009C, 506-28-009D. 
 
The Applicant proposes to construct, operate, and maintain up to approximately 1-gigawatt hybrid solar 
photovoltaic (PV) and battery power plant and associated infrastructure for the Harquahala Sun III Project 
(Project).  
The Project will be constructed in approximately four (4) phases with each phase including an approximately 
250-MWac or more hybrid solar PV and battery power plant constructed on approximately 1,500 to 2,500 
acres. Each phase of the project will include approximately 600,000 solar modules (~4,000,000 modules 
total) mounted on single axis trackers, inverters to convert direct current into grid-compatible alternating 
current, transformers to increase the voltage of the electricity generated, and battery energy storage 
system. The Project will also include two 500 kV utility substations and one or more small buildings to house 
telecommunication equipment. The Project is expected to interconnect to the transmission grid at the 
Delaney Substation operated by Arizona Public Service (APS).  
Off-site supporting improvements, infrastructure, and/or uses are expected to include up to a 200-foot-wide 
gen-tie route corridor that extends approximately 10 miles through private land and to the Project 
substation. 
The proposed CPA in support of the ±9,033.17-acre Project will not adversely impact the planning area in 
part nor portion. Approval of the proposed CPA, subsequent rezone and associated development plans for 
the proposed Project will not generate undue nor unmitigated impacts to the following areas of consideration 
identified in the Comprehensive Plan, which include, but are not specifically limited to: land use; public 
transportation system improvements; drainage and/or stormwater management; environmental 
considerations (air & water quality, potable water & wastewater treatment), areas of geologic concern, 
hazard, and/or significance; plant and wildlife habitat/migration environs and/or patterns; aviation and 
military installation operations and flight paths/patterns; economic growth; growth areas; open space, water 
resources; energy; and/or the cost of development.

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Issues relating to these are addressed by the required reports, plans, and analysis submitted in support of 
the CPA and subsequent rezone application. 
I. ON-SITE AND REGIONAL LOCATION  
The proposed Project is located southwest of Saddle Mountain, and northeast of the Eagle Tail 
Mountains in Township 1 North, Range 8 and 9 West, Township 1 South, Range 8 and 9 West. The 
site is approximately 20 miles west of the City of Buckeye, Arizona in unincorporated Maricopa 
County, Arizona with parcels lying south of the intersection of W Lower Buckeye Rd and S 
Harquahala Valley Rd which generally bisects the site. The Project area is generally bound on the 
north side, just south of the W Lower Buckeye Rd, on the west side by S 539th Ave, on the east side 
by S 487th and on the south by Elliot Rd. 
 
The CPA is inclusive of sixty-three (63) parcels which are held under eight (8) separate ownerships. 
The cumulative area of the property included in the CPA request is ±9,033.17 acres. The subject 
properties are mostly being used for irrigated agricultural uses or vacant along with a few limited 
residential structures (APN:401-56-021, 56-024, 55-029, 55-032, 28-009C). A detailed list of the 
parcels considered under this CPA are listed in Appendix A. 
HARQUAHALA 
SUN III SITE

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II. CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY ACREAGES  
The CPA request is inclusive of sixty-three (63) parcels totaling ±9,033.17 acres in the Rural 
Development Area which is intended to conserve and protect farms and other open land uses, foster 
orderly growth in rural and agricultural areas, to prevent urban and agricultural land use conflicts, and 
to encourage sustainable development. The current RU-43 and RU-190 zoning districts have 
residential densities of one (1) dwelling unit per acre (du/ac) and 0.22 du/ac. Principal permitted uses 
in the Rural zoning districts include both farming and non-farming related residential uses, farms, and 
recreational and institutional uses. 
III. ROADS/TRANSPORTATION SYSTEMS SERVING THE PROPOSED PROJECT  
The roadway network serving the proposed Project from the I-10 corridor includes the I-10/Salome 
Highway interchange that connects Salome Hwy to Harquahala Valley Rd. The site can be accessed 
from the I-10/ Salome Highway interchange. Salome Highway provides connections to Harquahala 
Valley Road which extends southerly past W. Lower Buckeye Road to the site. Primary access to the 
site is via Harquahala Valley Road which generally bisects the irregular shaped site with W. Lower 
Buckeye Road near the northern side, 539th Ave alignment on the west side, 487th Ave alignment on 
the east side and W Elliot Rd as the southernmost boundary.  There are a number of smaller, existing 
roads, both named and unnamed, that traverse the Project site, which are anticipated to be used and 
improved for construction and ongoing operations of the Project. Site access will be identified with

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the zone change and plan of development applications. Final access locations will be determined in 
accordance with access management policies and permitting requirements of Maricopa County. 
 
Properties within the Project area are located between W. Lower Buckeye Road to the north and E. 
Elliot Road to the south as well as 529th Avenue to the west and 487th Avenue to the east. The 
Maricopa County Department of Transportation may request ROW dedications/preservations along 
the following alignments: 
 
 Baseline Road: 65’ half, 130’ full ROW 
 Harquahala Valley Road: 65’ half, 130’ full ROW 
 Dobbins/Eagletail Road: 65’ half, 130’ full ROW 
 North/south – east/west mid-section alignments: 40’ half, 80’ full ROW 
 
There would be no significant increase in traffic during the operational life of the Project that would 
require road improvements. There would be a relatively minor increase in the level of traffic during 
the approximately 30 months required for each phase of Project construction. This increased traffic 
is expected to be fewer than 100 trips during single peak morning and evening hours, primarily for 
the delivery of equipment and supplies and the commuting of the construction workforce. A traffic 
impact study will be completed as part of the zone change process associated with the Project. The 
Applicant has agreed to financial responsibility for repair of existing roads used during construction, 
including bonding for such work, so that there is not public expenditure for transportation 
infrastructure associated with the Project. 
IV. SUITABILITY WITH SURROUNDING LAND USES 
The surrounding area is characterized by active and passive agricultural land uses, natural gas-
powered electric generation facilities, solar powered electric generation facilities, and native desert 
lands. The dominant private land use within the area surrounding the current CPA is solar generation 
facilities, which occurs on parcels or combinations of parcels totaling several hundred to thousands 
of acres in irregular configurations. Other surrounding land uses include publicly owned and managed 
Local, State, and Federal Lands. These include lands controlled by the Maricopa Flood Control 
District, Arizona State Land Trust, and Bureau of Land Management. Other surrounding land uses 
include vacant and active agricultural uses with limited and sparse distribution of privately owned 
parcels used for residential purposes within the surrounding area. Additionally, Luke Air Force Base 
(LAFB) is known to have military training routes out in this area. Under the Department of Defense 
(DOD) Clearinghouse process, energy projects greater than 199’ above ground level are required to 
go through a Formal Review. The routes in this area already fly over several existing 500kV lines and 
fly nearby several other solar projects. The proposed gen-tie pole heights will vary slightly, but no 
pole height is expected to exceed 150’. Although, the Project team will be proactive in addressing 
any potential concerns and will submit under the Informal Review DOD Clearinghouse process during 
the zoning process. 
 
Property owners and residents will be notified of the project and efforts will be made to identify 
concerns over visual impacts and incorporate effective mitigation and screening of the site against 
any residential boundaries.

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Considerations for buffering and screening of the Project and mitigation of visual impacts during 
construction and operational activities. Screening and mitigation of visual impacts will be addressed 
in greater detail at the rezone and plan of development submittals.  
 
Site parcels will be enclosed by perimeter security fencing located along each phase project 
boundaries and adjacent rights of way. No fencing will impede or otherwise enclose existing roads 
within the project boundaries.  
 
Harquahala Sun III looks to expand upon the upcoming improvements to be constructed as a part of 
the recently approved Harquahala Sun CPA (CPA2021007) and Zone Change with a Plan of 
Development (Z2021111). Additionally, the proposed Utility land use contemplated by the 
Harquahala Sun III CPA is compatible with other similar approved and implemented solar Projects 
within the general area. Associated facilities within this area include approved CPA’s for Utility (solar) 
land uses, PV solar generation facilities, utility corridors, transmission lines and a utility substation. 
Many of the surrounding parcels around the Harquahala Sun III CPA boundary have been subject to 
previous CPA approvals, by the BOS, including the adjacent solar and storage generation projects 
of Maricopa Solar & Storage Project (CPA2020002), Saddle Mountain Solar (CPA2011015 & 16) and 
Eagletail Solar Farm (CPA2010023 & 24). Other nearby projects are as follows: 
      EXISTING SURROUNDING SOLAR (UTILITY) LAND USE APPROVALS 
Project 
Location (Township/Range) 
Maricopa Solar and Storage Project  
T1N R8W; T1N R9W; T2N R8W; T2N R9W
Harquahala Sun 
T1N R9W 
Saddle Mountain Solar 
T1N R9W 
Eagletail Solar Farm 
T1S R9W 
Almeria Solar 
T2N R8W 
Sun Valley North 
T2N R8W 
Sun Valley South 
T2N R8W 
Areva Solar AZ II 
T2N R7W 
Papago Solar 
T2N R8W 
Tonopah Photovoltaic 
T2N R8W 
 
Most notable of these approvals is the recently approved the Maricopa Solar and Storage Project 
(CPA2020002), as seen below. BOS approved the change in land use of 11,260 acres from Rural 
Development Area to Utilities. This CPA is adjacent to the subject Project boundary, establishing the 
precedent for a primary alternative energy corridor that Harquahala Sun III looks to build upon. 
 
 
 
 
(The remainder of this page is left intentionally blank)

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B. WHETHER THE AMENDMENT CONSTITUTES AN OVERALL IMPROVEMENT TO 
THE COMPREHENSIVE PLAN AND IS NOT SOLELY FOR THE GOOD OR BENEFIT 
OF A PARTICULAR LANDOWNER OR OWNERS AT A PARTICULAR POINT IN TIME. 
Per the Vision 2030 Maricopa County Comprehensive Plan (2016), Major Plan Amendments should 
improve the County’s overall condition and not undermine the plan’s core principles. The Plan recognizes 
the need to redesignate land uses in response to changing market conditions and to address the increasing 
demands of growth to the public infrastructure needs, specifically energy generation and consumption 
demands within the local economy.  
As stated, and reinforced in the Plan, the supply of energy is essential to the region’s transportation and 
manufacturing sectors. Energy resources significantly impact economic development by contributing to the 
region’s overall attractivity on basic and corresponding non-basic employment, primary and secondary 
employment sectors and markets, and research and development within existing and emerging markets 
and industries. Additionally, energy availability and even surplus opportunities function as an incubator for 
innovations within all segments of the local, regional, and state economy. 
The Project is anticipated to generate approximately 400-600 jobs in the construction, contracting, 
administrative, and project management fields during the construction and implementation of each Project 
phase over an estimated 30 months. Operation of the site will employ zero full-time employees daily. 
Routine maintenance activities will require up to 15 part-time or seasonal employees and up to 20 
employees for equipment repair and replacement as needed per phase. The Project could enter 
construction as early as 2023 and is expected to be operational in 2025. 
The Project supports the County and greater region within the state by providing additional renewable 
energy resources, battery storage for local energy reliability and resiliency. The location and surrounding 
utility land uses minimize impacts to neighbors and lessen the impact to the environment based on proximity 
to the APS Delaney Substation by minimizing very long electrical interconnects. The electricity generated 
through these facilities would be distributed to the regional electrical grid, supplying the County, State and 
wider west/southwest regions while directly benefitting Arizona corporations seeking competitively priced 
renewable energy. Additionally, local projects like Harquahala Sun III will help contribute to the regional 
economy by providing tax revenue and construction jobs, long term technical careers, and use local 
engineering and development contractors in Maricopa County.   
The Plan is intended to promote and incentivize the production and delivery of renewable energy resources 
that meet and otherwise support consumption needs of existing and emerging markets which benefit the 
regional and state economies and tax bases. The availability of sustainable, renewable, and economically 
efficient energy and the resulting cost savings, both immediate and over time, creates opportunity for 
reinvestment of public and private capital back into the local and regional economy. 
The proposed Harquahala Sun III Project is in direct support of this stated goal, the implementation of which 
is evidenced by the current approved CPA and rezoning of property within the current Project vicinity for 
solar Projects. The need for this Project is established by growing demand for renewable energy as 
evidenced by APS’s request for proposals to supply renewable energy and by Arizona’s Renewable 
Portfolio Standard (RPS). RPS are policies designed to increase the use of renewable energy sources for 
electricity generation. These policies require or encourage electricity suppliers to provide their customers 
with a stated minimum share of electricity from eligible renewable resources. Most states, including Arizona,

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have enacted their own RPS programs to diversify their energy resources, promote domestic energy 
production and encourage economic development. Arizona has set their standards for investor-owned 
utilities at 45% by 2030 and 100% by 2050. 
Approval of the Project strengthens the overall energy production output within Maricopa County. The 
increased local production over time will create energy surplus within the market resulting in a reduction of 
cost and consumption by additional sectors of the local and regional economy. Project approval facilitates 
a larger Regional share of renewable energy generation activities within the national production mix thereby 
promoting energy independence throughout related national industries and markets. 
C. THE AMENDMENT WILL NOT ADVERSELY IMPACT ALL OR A PORTION OF THE 
PLANNING AREA BY: 
*EACH CRITERION IS ADDRESSED SEPARATELY WITH THE CRITERIA LISTED AND GENERAL 
RESPONSES TO THE CRITERIA CITED AS SUBHEADINGS IN THE PROCEEDING 
SUBSECTIONS BELOW: 
I. 
ALTERING ACCEPTABLE LAND USE PATTERNS TO THE DETRIMENT OF THE PLAN.  
The proposed CPA will not alter the acceptable land use patterns in the planning area in an adverse 
manner to the detriment of the plan. The proposed change in land use is consistent with existing 
approved utility land use patterns and subsequent zone change requests. Previous land use approvals 
should not be construed to imply future precedents, nor obligate future Board of Supervisor decisions. 
However, the infrastructure investment and development within this portion of the planning area make 
the Project site a more suitable and logical location for future development of solar powered generation. 
The single Renewable Energy Strategy in the Plan promotes/encourages the “[attraction] of solar and 
other alternative energy research and development to Maricopa County.” Approval of the CPA is 
consistent with this strategy and the utility pattern that has been established in the Project area by 
recent BOS approvals in favor of large-scale solar powered generation facilities within this remote area.  
 
Increasing the County’s investment (in terms of land use planning) in local solar powered generation 
facilities and infrastructure has a long-term tangible impact of lowering costs of energy production, 
delivery, and consumption. This goal is achieved in part by increasing local/regional energy 
production/generation. The increased supply has a proportionate impact on the accessibility of the 
resource and encourages integration of applied uses and transitions away from reliance on outdated 
and inefficient modes of energy generation and transmission creating efficiencies in these areas. 
Increased supply and efficiencies will promote increased integration into the market for various sectors 
of the economy (housing, manufacturing, transportation, etc.).  
 
The CPA to change the land use from Rural Development Area to Utilities to accommodate the 
proposed solar facility is in substantial conformance with renewable energy policies identified in the 
Plan, addressed in the Energy Goal and Policy Considerations in Section D of this report.  
II. REQUIRING 
PUBLIC 
EXPENDITURES 
FOR 
LARGER 
AND 
MORE 
EXPENSIVE 
INFRASTRUCTURE.  
Any and all expenditures for larger and more expensive infrastructure that are required as a result of 
the development shall be borne by the developer. Improvements for adjacent access roads will be

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borne solely at the expense of the developer proportionate to the impacts placed on the transportation 
network. Any public or private electric transmission infrastructure improvement costs needed in support 
of the Project will be borne solely by the developer. 
III. REQUIRING PUBLIC IMPROVEMENTS TO ROADS, SEWER, OR WATER SYSTEMS THAT 
ARE NEEDED TO SUPPORT THE PLANNED LAND USES.  
The amendment will not adversely impact the planning area by requiring public improvements to roads, 
sewer, or water system needed to support the planned land uses. The provision of these services will 
be the responsibility of the developer in a manner that does not detract or negatively impact the 
availability, delivery, and/or use of existing services within the planning area. All costs for public 
improvements or services necessary to support the planned development will be borne solely by the 
developer. 
It is anticipated the Project would not connect to any existing sewer system.  Personnel who are on-
site to perform module washing (up to four times per year) would be provided with portable restrooms 
serviced by a licensed provider. Construction staff would also utilize portable restrooms serviced by a 
licensed provider. 
Options for construction and operational water needs is currently under examination by the applicant, 
and none of these options would require improvements to public water systems.  
Each phase of the Project is anticipated to require approximately 210 acre-feet of water over the 
construction period. This water will be sourced from an on-site well, a nearby well, or delivered from 
the Harquahala Valley Irrigation District. Neither water storage tanks nor holding ponds are expected 
to be needed or placed within the adjacent road ROW. During the O&M phase, up to approximately 10 
acre-feet of water would be required per year for module washing and maintenance. The Project will 
be consistent with Maricopa County’s water and wastewater treatment programs during all phases of 
the development. 
Underground wet/dry utility service or transmission lines within adjacent right-of-way will be solely at 
the developer’s expense. Required on-site water and wastewater service and/or treatment for 
construction, operations, and maintenance, activities will be the sole financial burden of the developer. 
Required services and the developer’s plan of provision will meet County and State requirements for 
water and on-site wastewater disposal criteria, permitting, and monitoring standards. 
IV. ADVERSELY IMPACTING PLANNED USES BECAUSE OF INCREASED TRAFFIC.  
Existing and planned uses surrounding the site which are dependent on the surrounding transportation 
system are not anticipated to be impacted due to increased traffic. Planned uses on-site will not be 
adversely impacted due to increased traffic. Increased traffic will be limited to construction and 
implementation activities associated with this Project and not from others. It is not anticipated that 
surrounding approved, but not yet implemented solar utility Projects will begin construction activities at 
the same time as the Harquahala Sun III Project. During the construction period less than 100 additional 
ADT are expected for each phase of Project construction; therefore, per the MCDOT Traffic Impact 
Study Manual, a traffic statement will be required for each phase of the proposed site. A traffic impact 
study will be provided in support of the necessary zone change and plan of development application 
and review process. A traffic statement is a scaled down and simplified version of the traffic impact

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study and is intended for smaller Projects that will have lesser impacts on existing traffic as compared 
to the larger type master plan developments. At that time, a clearer Projection of traffic impacts will be 
available which will consider construction and operational ADT, construction haul routes, necessary 
ROW dedications, and road improvements. 
V. AFFECTING THE LIVABILITY OF THE AREA OR HEALTH OR SAFETY OF PRESENT AND 
FUTURE RESIDENTS.  
The CPA will not adversely affect the livability of the area or health or safety of present and future 
residents of the area. As previously discussed, there are relatively few residences in the area. Site 
preparation, construction, or operation will not include any hazardous activities, materials, processes, 
or outputs. Noise impacts would be limited construction activities during specified construction hours. 
Fugitive dust control will be achieved during construction and operational periods by implementation of 
proper grading and erosion control measures, BMP’s to include appropriate dust control and mitigation 
of dust on unpaved roads. Standard operational activities conform to applicable noise ordinances. Fire 
hazard and wildfire mitigation will be addressed with the plan of development. Harquahala Sun III will 
comply with all applicable local and County fire laws and regulations. All reasonable measures will be 
taken to prevent fires on the site including the control or suppression of weeds. If necessary, all weed 
control would be in compliance with County regulations.  The CPA will not result in undue or unmitigated 
social, visual, traffic, air quality, water quality, or other impacts which may have a disproportionate 
affecting the livability of the area.  
VI. ADVERSELY IMPACTING THE NATURAL ENVIRONMENT OR SCENIC QUALITY OF THE 
AREA IN CONTRADICTION TO THE PLAN. 
The Project site has mostly been disturbed to accommodate agricultural uses and is not anticipated to 
generate adverse impacts to the natural environment or the scenic quality of the area. Preliminary site 
investigations have not identified any significant, unique, or critical wildlife habitats, endangered and/or 
protected flora/fauna species, or significant cultural resources within the Project area.  
The Project team will conduct onsite investigations and implement appropriate protective measures as 
needed for biological and historical/archaeological resources to either avoid or mitigate impacts to the 
natural environment, in coordination with the Arizona State Historic Preservation Office (SHPO) and 
Arizona Game and Fish Department (AZGFD). High level conversations have been had with AZGFD 
and the project team recognizes that appropriate coordination, proper planning, and implementation of 
best management practices allow projects to be developed that avoid, minimize, or mitigate potential 
impacts to wildlife and recreational access during development and operation of the facilities. This 
coordination will continue in a more detailed fashion with the subsequent zone change and plan of 
development to minimize any potential impacts to the surrounding wildlife including proper treatment 
or preservation of drainage ways and wildlife corridors. Specific to wildlife, AZGFD has recommended 
surveys and monitoring to identify the species in the area. Based on previous approvals, it is known 
that this site is located south and west of the known big horn sheep movement patterns in the area 
which occur to the north and east through the Saddle Mountain range. Best management practices will 
be introduced to address Avian safety. Future 500 kv lines do not pose significant threat to avian 
species because of their spacing due to voltage. However, in general the Project team will follow best 
practices in the industry to protect avian species such as adhering to APLIC standards. Our biologist

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team has reviewed these designs and indicated that these power lines pose an almost negligible risk 
to avian species. Additionally, a burrowing owl survey will be required prior to final plan approval.  
As discussed in the transportation sections, no major offsite road or transportation network 
improvements are required to support the Project. Dust control measures will be provided to protect air 
quality during construction activities. Ground disturbing activities may also require dust mitigation, 
erosion control BMPs, and select soils stabilization or enhancement where existing erosion is 
encountered to maintain compliance with local, state, and federal air and water quality standards. 
The site is predominately flat and will require little to no grading for access, PV pedestals, or supporting 
accessory equipment or storage structures. Construction activities will implement accepted BMP’s for 
solar PV facility development, which include minimum ground disturbance and non-disturbance of 
existing low-lying vegetation and vegetation for erosion control purposes. Vegetation may require 
mowing to heights approved by the fire district or other environmental agencies to maintain appropriate 
levels of fire mitigation and erosion control.  
 
The site will have minor visual impacts to surrounding areas and properties. The site will be screened 
with a minimum 6-foot fence to provide separation and security. Details of proposed fencing will be 
provided with subsequent zone change and plan of development applications and finalized through 
coordination and input from residents and impacted property owners.  
 
The solar arrays will extend to an approximate 10-foot vertical height (typical) when panels are nearly 
vertical during sunrise and sunset. The site is adjacent to a future utility use (solar farm) to the north 
and northwest, vacant agricultural land adjacent to the north, east, and west; current utility use (SunE 
AZ2 LLC solar farm) in the northwest corner of W. Baseline Road and 523rd Avenue; the vacant 
Harquahala Ranches 3 residential platted subdivision to the west separated by S. 535rd Ave; and a 
commercial nursery on agricultural exempt land to the south. One residence is located within 60 feet of 
the site opposite the 483rd Avenue frontage. Most residences within this subdivision are more than 300 
feet away from the Project area’s eastern most boundary. 
No adverse or otherwise unmitigated impacts to the natural environment or scenic quality of the area 
are anticipated.  
The site will be surveyed prior to construction activities to identify plant/vegetation species which are 
protected by the Arizona Department of Agriculture under the Arizona Native Plant Law. Protected plant 
life and/or vegetation will be relocated or otherwise salvaged. All activities associated with the removal, 
relocation, or sale of protected plants/vegetation will comply with the notice requirements of Title 3, 
Chapter 3, Title II, of the Arizona Administrative Code. 
Additional detailed analysis of environmental impacts will occur with pending zone change and plan of 
development submittals. Any identified impacts will be evaluated together with Planning and other staff 
within affected local, state, federal regulatory agencies and corresponding County departments and 
agencies, and participating stakeholders to identify appropriate mitigation strategies and/or other 
acceptable offsetting measures. The Project will maintain compliance with applicable Maricopa County 
Air Quality Department permitting and operational standards, including conformance with U.S. 
Environmental Protection Agency (EPA), and Arizona Department of Environmental Quality.

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D. WHETHER THE AMENDMENT IS CONSISTENT WITH OVERALL INTENT OF THE 
COMPREHENSIVE PLAN: 
Maricopa County’s original Comprehensive Plan was adopted in 1997 as a sensible approach to addressing 
the regions fast paced growth and associated development issues. A lot has changed since 1997, including 
a relevant update to introduce energy efficiency and renewable energy into the plan 2002, and the County 
looks to build on the past and lessons learned to achieve a healthy, vibrant and prosperous future. This can 
be seen in the County’s current Vision 2030 Comprehensive Plan, which is a planning mechanism that 
looks to balance the County’s future growth with a high quality of life. The Comprehensive Plan looks to 
accomplish this challenge by providing policies and recommendations on how to protect public health and 
safety, promote stable economic growth, maintain a healthy environment, provide adequate community 
services, and ensure that tax money is spent efficiently. These policies and recommendations also guide 
Maricopa County’s decisions regarding future development, and for when changes to this plan are justified.  
Applicant initiated changes to the comprehensive plan, like this change in land use designation, may occur 
with Board approval to account for changing conditions provided that such revisions benefit the County as 
a whole. This benefit can be weighed through the goals and policies of a series of plan elements, which 
each address a subject that affects the County’s quality of life. While each element is distinct, combined 
they reinforce the County’s strategic priorities and the core principals of Vision 2030, and promote 
consistent interpretation and implementation of its policies and recommendations. Harquahala Sun III 
meets the overall intent of the Comprehensive Plan by providing a future need in renewable energy, which 
has been identified as a strategic priority, that benefits the region and County as a whole. Additionally, this 
Project will improve the quality of life as identified in the goals and policies of the Comprehensive Plan as 
discussed in the following section. 
E. THE EXTENT TO WHICH THE AMENDMENT IS CONSISTENT WITH THE SPECIFIC 
GOALS AND POLICIES CONTAINED WITHIN THE PLAN. 
The County’s Vision 2030 Comprehensive Plan considers growth-related topics that will affect the County’s 
future. The following nine (9) plan elements examine key issues that shape the goals and policies that 
Maricopa County uses to implement its mission, vision, strategic priorities and make informed and effective 
decisions. 
 
Land Use 
 
Transportation 
 
Environment 
 
Economic Growth 
 
Growth Areas 
 
Open Space 
 
Water Resources 
 
Energy 
 
Cost of Development 
Harquahala Sun III and the Utilities land use designation are affirmed by many of the goals, objectives, and 
policies identified within these identified plan elements. The relevant goals, objectives, and policies 
contained in the Comprehensive Plan are listed below with specific examples and guarantees of how each 
is relevant to the proposed use and why it is consistent.

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LAND USE GOALS AND POLICIES 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Land Use Goal #3: Protect public 
health, safety and well-being  
Harquahala Sun III is a low impact land use, consistently found in 
the area, that provides renewable energy generation to the 
region. The Project requires minimal water usage, minimal traffic, 
minimal operational employment or activity and no wastewater. 
Additionally, it improves air quality and will provide necessary 
ROW dedications, circulation, screening, and appropriate buffers. 
Altogether, this passive land use will help contribute to the public 
health, safety and well-being of the area.  
Land Use Policy #7:  Maricopa 
County supports coordinating land 
use and infrastructure planning with 
state 
agencies, 
counties, 
and 
municipalities.  
 
The process requires ongoing coordination with local, state, and 
federal agencies to ensure protections of public services, utilities, 
infrastructure, and natural resources. Coordination has occurred 
directly 
with 
Maricopa 
County 
Planning 
and 
Zoning, 
Environmental Services, the Maricopa County Department of 
Transportation, and Arizona Game and Fish Department 
(AZGFD). Feedback from state agencies, other counties and 
municipalities located in close proximity to the Project has been 
received as well through Maricopa County’s enhanced notification 
process. Additional coordination will occur with these groups in 
addition to the State Historic Preservation Office (SHPO) and 
Arizona Department of Agriculture (AZDA). The coordination 
includes preparation of necessary reports and considerations for 
the provision as well as protection of natural resources and public 
services including, but not limited to, water resources 
(ground/surface water supplies), flora and fauna impacts, air and 
water quality, and stormwater impacts, open spaces, buffering 
and screening, and transportation facilities and rights-of-way. 
Land Use Policy #20: Maricopa 
County 
supports 
reducing 
the 
impacts of new urban development 
on existing rural land uses and 
agriculture. 
The Project is a land use already found in the surrounding area, 
reducing the impact on nearby agricultural and rural land uses. 
Additionally, at the end of the life of the project, agricultural uses 
could continue on the site due to the flat terrain and minimal 
impact to underlying soils. 
Land Use Policy #22: Maricopa 
County 
supports 
reducing 
the 
impacts of new development on 
environmentally 
sensitive 
areas, 
including native flora and fauna 
habitat and corridors.  
 
The Project does not include environmentally sensitive areas 
requiring avoidance or mitigation that we are aware of at this time. 
Initial analysis hasn’t identified any flora or fauna species 
requiring special mitigation or preservation. All development 
activities will remain compliant with applicable environmental 
regulations requiring flora/fauna habitat and/or environmental 
protection or relocation. Ongoing coordination with the 
appropriate agencies, including AZGFD, SHPO and AZDA, 
throughout the Project life cycle will ensure appropriate site 
treatments 
and 
regulatory 
compliance 
with 
applicable 
environmental policies, protocols, and regulations.

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TRANSPORTATION GOALS AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Transportation Goal #1: Promote 
and protect public health through a 
safe transportation system.  
 
One of Maricopa County’s strategic priorities is creating a safe, 
efficient and effective transportation system. Harquahala Sun III 
will further this priority by addressing some of their related 
concerns specific to the preservation of road alignments and air 
pollution. The Project will be responsible for ROW dedication of 
the necessary roadway alignments, as indicated by MCDOT from 
its respective boundaries to comply with the Maricopa County 
Transportation Plan and road/ROW dedication standards of the 
County. Exceptions will be negotiated with MCDOT and 
authorized by the MC BOS and may require specific development 
agreements to memorialize terms of negotiated dedications, 
preservation, and/or and deferments or exemptions. Because no 
full-time employees are proposed on-site, outside of the limited 
construction traffic, Harquahala Sun III provides a use that will 
limit automobile usage and reduce air pollution. 
 
Transportation Goal #2: Contribute 
to a safe, seamless and effective 
transportation system.  
 
The Project will support a safe, seamless, and effective 
transportation system by dedicating and/or preserving required 
ROW in support of future road alignments as coordinated with 
MCDOT in a manner consistent with Departmental planning 
objectives and the Maricopa County Transportation Plan. 
 
Transportation 
Goal 
#3: 
Coordinate land use decisions with 
transportation investments to help 
the County exercise sound financial 
management and build the County’s 
fiscal strength.   
 
All transportation improvements required to support the planned 
use or any expansion thereof will be borne solely by the 
developer, subject to all required agreements, financial 
assurances and/or performance bonds. 
Transportation 
Policy 
#11: 
Maricopa County supports National 
Ambient 
Air 
Quality 
Standards 
(NAAQS) compliance.  
 
The Project will maintain compliance with National Ambient Air 
Quality Standards throughout development phases. Operation of 
the Project will result in lower overall emissions. 
Transportation 
Policy 
#12: 
Maricopa 
County 
supports 
improving low volume dirt roads as 
directed 
by 
its 
PM-10 
Dust 
Abatement Program.  
 
The Project will maintain compliance with the permitting and 
operational standards of the Maricopa County Air Quality 
Department dust control requirements as governed by activities 
regulated by a dust control permit or Rule 310.01.

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ENVIRONMENTAL GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Environment 
Goal 
#1: 
Provide 
regional leadership to promote all 
aspects of regional environmental 
quality.  
 
One of the reasons Maricopa County supports state and local 
efforts to attract solar research and development to this region is 
due to the environmental benefits. Harquahala Sun III would 
further Maricopa County’s potential to be a leader in renewable 
energy research and development, with respect to solar energy, 
and would benefit their Green Government Program to help 
protect the environment with a use that promotes low water 
usage and better air quality. Additionally, throughout the 
Harquahala Sun III approvals, reports, plans, and permits will be 
prepared, for all on-site and off-site Project activities and phases, 
to identify areas of environmental concern, demonstrate 
proposed methods of mitigation and compliance, and identify 
compliance with environmental performance criteria. 
Environmental Policy #2: To help 
improve air quality Maricopa County 
supports balanced and efficient land 
use patterns where employment, 
retail and residential land uses are 
proximate rather 
than separate. 
Harquahala Sun III supports improved air quality by proposing 
an alternative energy use that decreases emissions that result 
from electricity produced by fossil fuels. Compared to other 
power producers, solar powered plants significantly decrease 
carbon dioxide emissions and eliminate sulfur, nitrous oxides, 
and mercury emissions generated by conventional electric 
generation facilities. Additionally, compared to the current 
agricultural uses on-site, this Project which will treated to reduce 
potential fugitive dust will improve local air quality impacts from 
fugitive dust emissions. 
Environment Policy #3: 
To 
help 
protect 
water 
quality 
Maricopa 
County 
supports 
compliance with its Drinking Water 
program 
and 
its 
Water 
and 
Wastewater Treatment program.  
 
The Project as proposed is consistent with and will maintain 
compliance with Maricopa County Drinking and Wastewater 
Treatment program including water supply of the Maricopa 
County Environmental Health Code. As proposed, drinking water 
will be delivered by truck. If a local well is required for water use, 
such well will comply with local and state permitting, operations, 
monitoring, and recharge requirements. The Project, as 
proposed, will not have wastewater demands or discharge. A 
septic system will be used if an O&M building is required. 
Environment Policy #4: Maricopa 
County supports innovative Project 
design and development techniques 
that protect and mitigate damage to 
important plant and animal habitat 
and migration corridors.   
 
The Project will be designed to minimize, avoid, and/or mitigate 
negative impacts to flora and fauna habitat and wildlife migration 
corridors during implementation and operational activities. 
Comments from the Arizona Game and Fish Department 
(AZGFD) will be addressed in a manner consistent with the intent 
of this policy, which may include preservation and/or relocation 
of impacted flora and/or fauna species. Best management 
practices will be employed to address flora/fauna impacts.

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Environment Policy #5: As directed 
by SHPO and Arizona Game and 
Fish Department, Maricopa County 
supports 
cultural 
resource 
and 
biological surveys being completed – 
and needed mitigation measures 
established 
– 
prior 
to 
new 
development.   
 
Cultural and biological reporting and surveys as required by the 
State Historic Preservation Office (SHPO) and AZGFD will be 
submitted with the zone change and plan of development 
application to identify sensitive areas requiring protection, 
preservation, and/or mitigation of impacts to respective natural, 
biologic, and/or cultural resources. Mitigation identified by these 
or by the respective agency’s staff or other guidance documents 
will be adhered to during implementation, and operation of the 
use. 
 
 
ECONOMIC GROWTH GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Economic 
Growth 
Goal 
#1: 
Contribute to an effective Regional 
economy. 
The physical development of the site will employ hundreds of 
specialized construction and skilled trade workers and laborers 
from unincorporated areas and incorporated municipalities 
within Maricopa County. Construction activities will generate 
employment opportunities for qualified workers over a 
construction period which is anticipated to occur from 
approximately 2023 through 2025. Local businesses including, 
but not limited to retail, food service, gas station/convenience, 
and hospitality businesses will be supported by workers 
commuting to the site or lodging near the site for short/long terms 
during their respective periods of construction activities. No 
construction camps or on-site housing are proposed during the 
implementation (construction) phase of the Project. No on-site 
security or maintenance housing is proposed during the 
operational phase of this development. 
Economic 
Growth 
Policy 
#5:  
Maricopa County supports programs 
that attract a variety of Basic Sector 
industry clusters that have long-term, 
stable growth prospects. 
Economic 
Growth 
Policy 
#10: 
Maricopa County supports leveraging 
its solar resource potential to attract 
solar-related 
industries 
and 
alternative 
energy 
research 
and 
development. 
More accessible energy sources will attract energy dependent 
employment sectors to the region and allow existing basic sector 
industries to reinvest energy savings into expansions, research 
and development, and retrofitting activities to increase 
productivity in response to growing demands and competition in 
the regional and national share of their respective industries. 
Increasing the supply of locally generated renewable energy 
increases the attractiveness of the region on the demand for 
technological innovations to meet the demand for additional 
skilled and specialized workers. There will also be an increase 
in the demand for specialized workers to respond to changes 
and innovations in the solar powered generation industry and in 
the development of spin off applications in the manufacturing, 
transportation, and research/development industries.

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GROWTH AREA’S GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Growth Areas Goal #1: Achieve 
orderly urban growth that is fiscally 
and 
environmentally 
responsible, 
protects public health and safety and 
promotes 
sensible 
annexation 
patterns. 
The Project is located near existing and approved generation 
facilities and has convenient access to existing electrical 
infrastructure, major transmission corridors, and a major 
electrical substation. Proximity to existing transmission lines, 
corridors, and easements reduces the applicant’s expenditures 
to utilize existing infrastructure and to obtain necessary 
easements to interconnect to the electrical grid. Construction 
and operational activities will maintain compliance with 
applicable environmental criteria, regulations, and permitting to 
ensure protection of biologic and natural resources.  
Growth Areas Policy #1: Maricopa 
County 
supports 
consistent 
implementation of its urban growth 
area except in the noted instances.   
The proposed Project is considered an industrial land use 
requiring large amounts of land to operate that do not require a 
corresponding level of urban services and infrastructure and can 
be located in rural remote areas. As the plan recommends, this 
land use is acceptable outside the urban growth area. These 
uses could include electric generating facilities, proving grounds 
and test facilities, agriculturally oriented businesses, and other 
rural-type industrial uses on a case-by-case basis. 
 
 
 
 
 
 
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WATER RESOURCES GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Water Resources Goal #4:  Increase 
water conservation. 
The switch in land use from agriculture to solar will significantly 
increase water conservation in the county. The Project will utilize 
photovoltaic (PV) modules to generate electricity. PV technology 
is the most water-efficient solar generation technology available. 
The Applicant recognizes that the proposed site receives a high 
degree of solar radiation and that water supplies in the vicinity 
are limited. The Project will implement water conservation 
measures while utilizing water-efficient technology. Solar uses 
roughly 835 gallons of water per acre per year where agriculture 
uses roughly 3,340 gallons of water per acre per year. Solar 
plants use approximately 25 percent of water required for a 
similar parcel of land growing alfalfa or other agricultural uses. 
Construction Peak Water Usage would be roughly 5,690 AF/YR 
and Operations & Maintenance Water Usage would be roughly 
54 AF/YR for the Harquahala Sun III 1,000 MW Facility. 
Water 
Resources 
Policy 
#2: 
Maricopa County supports water 
conservation 
techniques 
in 
the 
planning 
and 
design 
of 
new 
development. 
The Project will include a comprehensive Water Conservation 
Plan with established BMPs for water conservation. The 
Project’s water-conscious design and implementation is 
consistent with the applicable water goals and policies of the 
Comprehensive Plan. 
Water 
Resources 
Policy 
#4: 
Maricopa 
County 
supports 
compliance with its Drinking Water 
and 
Water 
and 
Wastewater 
Treatment Programs. 
Drinking water will be delivered by truck. If a local well is required 
for water use, such well will comply with local and state 
permitting, operations, monitoring, and recharge requirements. 
The Project will maintain compliance with Maricopa County’s 
wastewater treatment programs during the construction activity 
period. The Project as proposed will not have wastewater 
demands or discharge. A septic system will be used if an O&M 
building is required. Alternatively, portable restroom facilities will 
be provided for employee use during the implementation and 
operational phases. 
Water 
Resources 
Policy 
#5: 
Maricopa County supports low water 
use 
solar 
electric 
generating 
technologies.   
Harquahala Sun III will require very little water except for 
maintenance for cleaning the solar panels and equipment. This 
water will either be hauled to the site during construction and 
operation or obtained from existing wells on-site or new wells 
permitted through the Arizona Department of Water Resources 
(ADWR), as needed. Water hauled to the site would be from 
permitted sources. 
Water 
Resources 
Policy 
#7: 
Maricopa County supports low water 
use and drought tolerant landscaping.  
If landscape treatments are required to provide visual buffering, 
they will be selected from drought tolerant xeric species which 
will require low water use to establish and maintain.

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ENERGY GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Energy Goal #1: 
Provide 
leadership 
to 
promote 
regional environmental quality.  
 
Harquahala Sun III will have a long-term environmental impact 
of improving air quality by reducing emissions associated with 
conventional electric energy generation. The County has 
adopted environmental performance standards intended to 
preserve and sustain biologic, cultural, and environmental 
resources of the region which are evidence of the County’s 
regional leadership role in the promotion of environmental 
quality.  
Energy Goal #2: 
Make Maricopa County a leader in 
alternative 
energy 
research 
and 
development. 
 
Harquahala Sun III provides the opportunity to implement, test, 
and evaluate the efficiencies of the most current PV solar 
generation equipment and battery energy storage systems. 
Evaluation of their operational performance is key to the 
research and development of more efficient equipment and 
related processes. An operational facility provides opportunities 
to implement advances in the associated technologies over the 
life of the Project. Approval of the facility provides opportunities 
to test storage systems in response to increasing demands for 
the use of stored energy.  
Energy Policy #6: 
Maricopa County supports being a 
responsible leader in alternative 
energy research and development. 
Harquahala Sun III will be reflective of the Maricopa County 
Board of Supervisor’s regional and statewide leadership in the 
attraction, promotion, and delivery of renewable energy 
resources and infrastructure.  
 
COST OF DEVELOPMENT GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Cost of Development Goal #2: New 
development pays its proper and 
reasonable share of the costs of new 
infrastructure, services and other 
public improvements. 
 
All Project costs, including, but not limited to, on-site 
improvements, gen-tie line infrastructure and connections, 
collection lines, off-site road improvements, and water and 
wastewater treatment service, shall be borne solely by the 
Developer. 
Cost of Development Policy #2: 
Maricopa County supports recouping 
the costs of its products and services 
without unfairly burdening those most 
in need of its products and services. 
All development costs will be borne solely by the developer, 
including, but not limited to, applicable fees for service, impact 
fees, performance bonds and sureties, and property taxes.

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OPEN SPACE GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Open Space Goal #1:  Provide 
regional 
leadership 
to 
promote 
environmental quality, including the 
preservation of open, natural park 
and recreation lands. 
Despite the Project being mostly disturbed for agricultural 
purposes, Harquahala Sun III encourages the preservation of 
natural open space in the form of drainage corridors and wildlife 
linkages. The Project, which is adjacent to the Centennial Wash, 
will conduct onsite investigations and implement appropriate 
protective 
measures 
as 
needed 
for 
biological 
and 
historical/archaeological resources to either avoid or mitigate 
impacts to the natural environment, in coordination with the 
Arizona State Historic Preservation Office (SHPO) and Arizona 
Game and Fish Department (AZGFD). This project will be 
developed to avoid, minimize, or mitigate potential impacts to 
wildlife and recreational access during development and 
operation of the facilities. This coordination will continue in a 
more detailed fashion with the subsequent zone change and 
plan of development to minimize any potential impacts to the 
surrounding wildlife including proper treatment or preservation of 
drainage ways and wildlife corridors. 
 
 
 
 
 
 
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F. COMPREHENSIVE PLAN AMENDMENT MAP EXHIBIT

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G. COMPREHENSIVE PLAN AMENDMENT LEGAL DESCRIPTIONS EXHIBITS 
 
(Legal descriptions for the 63 parcels are available in a separate deed attachment.)

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APPENDIX - A ‘Site Parcels’  
Sixty-three (63) parcels that constitute the +/-9,033.17-acre site. 
# of 
Parcels 
APN 
Owner 
Assessor 
Parcel S.F.
Assessor 
Parcel 
Acres
 * CPA 
Parcel 
Acres
1 
401-55-023 
CV HARQUAHALA LLC 
9,854,579
226.23
226.23
2 
401-55-024 
CV HARQUAHALA LLC 
3,427,301
78.68
78.68
3 
401-55-026 
CV HARQUAHALA LLC 
1,820,808
41.80
41.80
4 
401-55-027 
CV HARQUAHALA LLC 
3,563,208
81.80
81.80
5 
401-55-028 
CV HARQUAHALA LLC 
6,969,600
160.00
160.00
6 
401-55-029 
CV HARQUAHALA LLC 
6,969,600
160.00
130.00
7 
401-55-030 
CV HARQUAHALA LLC 
1,742,400
40.00
40.00
8 
401-56-001 
CV HARQUAHALA LLC 
6,969,600
160.00
160.00
9 
401-56-002 
CV HARQUAHALA LLC 
7,125,980
163.59
163.59
10 
401-56-018 
CV HARQUAHALA LLC 
14,094,709
323.57
323.57
11 
506-27-014 
CV HARQUAHALA LLC 
13,939,200
320.00
320.00
12 
506-27-015 
CV HARQUAHALA LLC 
6,969,600
160.00
160.00
13 
506-27-016 
CV HARQUAHALA LLC 
3,484,800
80.00
80.00
14 
506-27-017 
CV HARQUAHALA LLC 
3,484,800
80.00
80.00
15 
506-27-018 
CV HARQUAHALA LLC 
6,969,600
160.00
160.00
16 
506-27-019 
CV HARQUAHALA LLC 
3,484,800
80.00
80.00
17 
506-27-020 
CV HARQUAHALA LLC 
3,484,800
80.00
80.00
18 
506-28-001 
CV HARQUAHALA LLC 
6,969,600
160.00
160.00
19 
506-28-002 
CV HARQUAHALA LLC 
6,864,011
157.58
52.53
20 
506-28-004 
CV HARQUAHALA LLC 
6,824,415
156.67
156.67
21 
506-28-010 
CV HARQUAHALA LLC 
3,484,800
80.00
80.00
22 
506-28-011 
CV HARQUAHALA LLC 
10,454,400
240.00
197.00
23 
506-28-012 
CV HARQUAHALA LLC 
6,824,415
156.67
156.67
24 
506-28-013 
CV HARQUAHALA LLC 
819,843
18.82
18.82
25 
506-28-014 
CV HARQUAHALA LLC 
6,969,600
160.00
160.00
26 
506-28-015 
CV HARQUAHALA LLC 
6,004,572
137.85
137.85
27 
506-28-016 
CV HARQUAHALA LLC 
6,969,600
160.00
160.00
28 
506-28-020 
CV HARQUAHALA LLC 
13,939,200
320.00
320.00
29 
401-55-007G
CV HARQUAHALA LLC 
1,132,560
26.00
26.00
30 
401-55-032A 
CV HARQUAHALA LLC 
6,708,240
154.00
154.00
31 
401-55-032B 
CV HARQUAHALA LLC 
261,360
6.00
6.00
32 
401-56-025B 
CV HARQUAHALA LLC 
14,069,880
323.00
323.00
33 
506-27-034A 
CV HARQUAHALA LLC 
6,801,505
156.14
156.14

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34 
506-28-007B 
CV HARQUAHALA LLC 
5,227,200
120.00
120.00
35 
506-28-008A 
CV HARQUAHALA LLC 
3,412,185
78.33
78.33
36 
506-28-009B 
CV HARQUAHALA LLC 
3,049,200
70.00
70.00
37 
506-28-025A 
CV HARQUAHALA LLC 
3,412,200
78.33
78.33
38 
506-28-026A 
CV HARQUAHALA LLC 
3,412,200
78.33
78.33
39 
506-28-027A 
CV HARQUAHALA LLC 
3,484,800
80.00
80.00
40 
506-27-033 
DAVENPORT STEPHANIE/TMV 
INCOME TRUST 
13,939,200
320.00
320.00
41 
401-56-007 
RANCHO AMABLE SPE LLC 
1,742,400
40.00
40.00
42 
401-56-008 
RANCHO AMABLE SPE LLC 
1,742,400
40.00
40.00
43 
401-56-009 
RANCHO AMABLE SPE LLC 
2,613,600
60.00
60.00
44 
401-56-010 
RANCHO AMABLE SPE LLC 
1,742,400
40.00
40.00
45 
401-56-011 
RANCHO AMABLE SPE LLC 
4,356,000
100.00
100.00
46 
401-56-013 
RANCHO AMABLE SPE LLC 
1,742,400
40.00
40.00
47 
401-56-021 
RANCHO AMABLE SPE LLC 
13,939,200
320.00
320.00
48 
401-56-012B 
RANCHO AMABLE SPE LLC 
6,969,600
160.00
80.00
49 
401-56-003C 
SHELLI LAMOREAUX LIVING 
TRUST/ETAL 
9,583,200
220.00
220.00
50 
401-56-003D 
SHELLI LAMOREAUX LIVING 
TRUST/ETAL 
1,755,032
40.29
40.29
51 
401-56-003E 
SHELLI LAMOREAUX LIVING 
TRUST/ETAL 
1,801,642
41.36
41.36
52 
401-56-003F 
SHELLI LAMOREAUX LIVING 
TRUST/ETAL 
871,200
20.00
20.00
53 
401-56-025A 
SHELLI LAMOREAUX LIVING 
TRUST/ETAL 
14,069,880
323.00
323.00
54 
506-27-011 
WAYDON FARMS LLC 
6,969,600
160.00
160.00
55 
506-27-010 
WAYDON FARMS LLC 
6,969,600
160.00
160.00
56 
401-57-006 
CV FARMING LLC 
14,052,892
322.61
322.61
57 
506-28-018 
CV FARMING LLC 
13,545,243
310.96
310.96
58 
506-28-019 
CV FARMING LLC 
13,623,826
312.76
312.76
59 
401-57-007B 
CV FARMING LLC 
12,950,824
297.31
297.31
60 
401-56-006 
WPI II-HARQ III FARM AZ LLC 
13,939,200
320.00
320.00
61 
401-56-024 
WPI II-HARQ III FARM AZ LLC 
13,939,200
320.00
320.00
62 
506-28-009C 
PSC-94 SITE LLC 
362,985
8.33
8.33
63 
506-28-009D 
PSC-94 SITE LLC 
52,795
1.21
1.21
 
 
TOTALS
404,725,490
9,291.22
9,033.17
 
* Note: The CPA cover the entirety of each parcel which exception of APN’s 401-55-029, 506-28-002, 506-
28-011 and 401-56-012B.

T01S R09W
T01S R08W
T01N R08W
T01S R08W
T01N R09W
T01S R09W
T01N R09W
T01N R08W
29
28
27
26
25
32
33
34
35
36
20
21
22
23
24
17
16
15
14
13
30
29
28
27
26
31
32
33
34
35
19
20
21
22
23
18
17
16
15
14
05
04
03
02
01
06
05
04
03
02
08
09
10
11
12
07
08
09
10
11
W LOWER BUCKEYE RD
487TH AVE
S 539TH AVE
W ELLIOT RD
W BASELINE RD
W SOUTHERN AVE
W LOWER BUCKEYE RD
487TH AVE
S 539TH AVE
W ELLIOT RD
W BASELINE RD
W SOUTHERN AVE
S 507TH AVE
S 507TH AVE
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
WAYDON FARMS LLC
APN: 506-27-011
WAYDON FARMS LLC
APN: 506-27-010
CV HARQUAHALA LLC
APN: 506-27-014
CV HARQUAHALA LLC
APN: 506-20-001
CV HARQUAHALA LLC
APN: 506-28-004
CV HARQUAHALA LLC
APN: 506-28-002
CV HARQUAHALA LLC
APN: 506-27-015
CV HARQUAHALA LLC
APN: 506-27-019
CV HARQUAHALA LLC
APN: 506-27-016
CV HARQUAHALA LLC
APN: 506-28-014
CV HARQUAHALA LLC
APN: 506-28-015
CV HARQ-
UAHALA
LLC
APN:506
-28-013
CV HARQUAHALA LLC
APN: 506-28-025A
CV HARQUAHALA LLC
APN: 506-28-026A
CV HARQUAHALA LLC
APN: 506-28-011
CV HARQUAHALA LLC
APN: 506-28-008A
CV HARQUAHALA LLC
APN: 506-28-007B
CV HARQUAHALA LLC
APN: 506-28-027A
CV HARQUAHALA LLC
APN: 506-28-010
CV HARQUAHALA LLC
APN: 506-28-009B
PSC-94 LLC
APN: 506-28-009C
CV HARQUAHALA LLC
APN: 506-28-012
CV HARQUAHALA LLC
APN: 506-28-016
CV HARQUAHALA LLC
APN: 506-27-018
CV HARQUAHALA LLC
APN: 506-27-017
CV HARQUAHALA LLC
APN: 506-27-020
DAVENPORT TRUST
APN: 506-27-033
CV HARQUAHALA LLC
APN: 506-27-034A
CV FARMING LLC
APN: 401-57-007B
CV FARMING LLC
APN: 401-57-006
CV FARMING LLC
APN: 506-28-018
CV FARMING LLC
APN: 506-28-019
CV HARQUAHALA LLC
APN: 506-28-020
LAMOREAUX
TRUST
APN: 401-56-003E
LAMOREAUX TRUST
APN: 401-56-003C
LAMOREAUX TRUST
APN: 401-56-025A
CV HARQUAHALA LLC
APN: 401-56-025B
CV HARQUAHALA LLC
APN: 401-56-018
CV HARQUAHALA LLC
APN: 401-56-002
CV HARQUAHALA LLC
APN: 401-56-001
CV HARQUAHALA LLC
APN: 401-55-024
CV HARQUAHALA LLC
APN: 401-55-023
CV HARQUAHALA LLC
APN: 401-55-028
CV HARQUAHALA LLC
APN: 401-55-029
CV HARQUAHALA LLC
APN: 401-55-027
CV HARQUAHALA LLC
APN: 401-55-026
CV HARQUAHALA LLC
APN: 401-55-030
CV HARQUAHALA LLC
APN: 401-55-032A
WPI II-HARQ FARM AZ LLC
APN: 401-56-024
WPI II-HARQ FARM AZ LLC
APN: 401-56-006
RANCHO AMABLE SPE LLC
APN: 401-56-021
RANCHO AMABLE SPE LLC
APN: 401-56-012B
RANCHO AMABLE
SPE LLC
APN: 401-56-010 APN: 401-56-007
APN: 401-56-013 APN: 401-56-008
RANCHO AMABLE
SPE LLC
APN: 401-56-009
APN: 401-56-011
LAMOREAUX TRUST
APN: 401-56-003F
APN: 401-55-032B
APN: 401-55-029
APN: 506-28-009D
APN: 401-56-012B
APN: 506-28-002
LAMOREAUX
TRUST
APN: 401-56-003D
APN:
506-28-011
APN: 401-55-007G
N
0'
HARQUAHALA SUN III
MARICOPA COUNTY, AZ
PARCEL OWNERSHIP MAP
COMPREHENSIVE PLAN AMENDMENT
DRAWN BY: JK
SCALE: APPROX.
LEGEND
PROPOSED CPA
BOUNDARY
ARIZONA STATE LAND
DEPARTMENT (ASLD)
BUREAU OF LAND
MANAGEMENT (BLM)
PRIVATE LAND
TOWNSHIP/RANGE LINE
2,000'
4,000'
CPA2022010
REVISED:
THURSDAY,OCTOBER 6,2022

Subdivision Infrastructure & 
Planning Program 
1001 N. Central Avenue #150 
Phoenix, Arizona 85004 
Phone: (602) 506-1058 
Fax: (602) 506-5813  
TDD 602 506 6704 
 
 
Maricopa County 
Environmental Services Department  
Water and Waste Management Division 
DATE: 
June 24, 2022  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TO : 
Adam Cannon, Planning & Development Dept. 
 
 
Planner 
 
 
 
 
 
 
 
FROM: 
Souren Naradikian, P.E. 
 
 
Senior Civil Engineer 
 
SUBJECT:  
Harquahala CPA Comprehensive Plan Amendment. 2078 
 
The Maricopa County Environmental Services Department (MCESD) has reviewed 
revised documents received from the Maricopa County Planning and Development 
Department for the above referenced project. This project is s requesting a major  
Comprehensive Plan Amendment (CPA) of the Vision 2030 Comprehensive Plan to 
change the land use designation of ±9,291 acres from Rural Development Area to 
Utilities. The CPA request will be accompanied by a subsequent zone change request 
to rezone the underlying parcels from RU-43 to the IND-2 IUPD Zone. at APN# 401-
57-006. Water and Sewer services will not be impacted by the proposed CPA. 
MCESD has no concerns. 
 
Based on the above, MCESD raised no objections to the Planning & Development 
Department in Accela: on June 24, 2022 and will allow the project to proceed at this 
time subject to the following stipulations 
 
Stipulations:  
None. 
 
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.

July 27, 2022 
 Mr. Adam Cannon 
 Maricopa County Planning and Development Department 
 301 West Jefferson Street, Suite 170 
 Phoenix, Arizona 85003 
 Electronically submitted to  Adam.Cannon@maricopa.gov 
 RE: 
 Harquahala  Sun  III  Solar  Project  Major  Comprehensive  Plan  Amendment 
 (CPA2022010) 
 Dear Mr. Cannon: 
 The  Arizona  Game  and  Fish  Department  (Department)  appreciates  the  opportunity  to  review  the 
 Harquahala  Sun  III  Solar  Project  Major  Comprehensive  Plan  Amendment  (CPA2022010).  The 
 Department  understands  that  HV  Sunrise  is  proposing  construction  and  operation  of  an 
 approximately  1  GW  photovoltaic  (PV)  solar  facility  with  battery  storage  on  9,291  acres  of  land 
 in  unincorporated  Maricopa  County  (County)  southwest  of  Tonopah,  Arizona,  between  the  Eagle 
 Tail  Mountains  and  Saddle  Mountain.  The  majority  of  the  project  area  is  currently  agricultural 
 fields  with  small  portions  of  natural  desert  scrub  and  riparian  habitat.  The  project  would  be 
 constructed  in  four  phases,  with  each  phase  including  approximately  250  MW  of  energy  on 
 1500–2000  acres  of  land.  The  project  will  also  include  a  utility  substation  and  an  approximately 
 10-mile-long generation interconnection (gen-tie) line. 
 Under  Title  17  of  the  Arizona  Revised  Statutes,  the  Department,  by  and  through  the  Arizona 
 Game  and  Fish  Commission  (Commission),  has  jurisdictional  authority  and  public  trust 
 responsibilities  to  conserve  and  protect  the  state  fish  and  wildlife  resources.  In  addition,  the 
 Department  manages  threatened  and  endangered  species  through  authorities  of  Section  6  of  the 
 Endangered  Species  Act  and  the  Department’s  10(a)(1)(A)  permit.  It  is  the  mission  of  the 
 Department  to  conserve  and  protect  Arizona's  diverse  fish  and  wildlife  resources  and  manage  for 
 safe, compatible outdoor recreation opportunities for current and future generations. 
 The  Department  recognizes  the  importance  of  planning  efforts  to  develop  renewable  energy 
 locations  that  contribute  to  regional  and  state  economic  growth  needs  and  would  like  to  work 
 closely  with  HV  Sunrise,  Kimley-Horn  and  Associates  (Kimley-Horn),  and  the  County  during 
 the  planning  and  development  of  this  economically-important  facility.  The  Department 
 recognizes  that  appropriate  coordination,  proper  planning,  and  voluntary  implementation  of  best 
 management  practices  allow  projects  to  be  developed  that  avoid,  minimize,  or  mitigate  potential 
 impacts  to  wildlife  and  recreational  access  during  development  and  operation  of  the  facilities. 
 For  your  consideration,  the  Department  provides  the  following  comments  based  on  the  agency's

AZGFD - Harquahala Sun III Solar Project Major Comprehensive Plan Amendment (CPA2022010) 
 July 27, 2022 
 Page  2 
 statutory  authorities,  public  trust  responsibilities,  and  special  expertise  related  to  wildlife 
 resources and recreation. 
 Arizona  has  recently  seen  an  increase  in  the  number  of  proposed  and  in-development  solar 
 energy  generation  projects,  including  several  in  the  vicinity  of  the  proposed  Harquahala  Sun  III 
 facility.  Within  a  30-mile  radius  of  the  Harquahala  Sun  III  project,  solar  projects  have  been 
 proposed  on  nearly  100,000  acres  of  land.  Although  each  individual  project  may  have  a  minimal 
 impact  on  the  broader  landscape,  these  projects  cumulatively  would  result  in  substantial  loss  of 
 habitat,  impact  wildlife  movements,  and  affect  wildlife  related  recreation.  It  is  important  for  this 
 project  to  be  evaluated  in  association  with  other  similar  projects  in  the  region.  Long-term  effects 
 to  wildlife  can  extend  several  kilometers  beyond  the  footprint  of  a  project  area  ( Sawyer  et  al. 
 2022  ),  and  the  Department  recommends  that  the  County  consider  these  effects  in  its  evaluation 
1
 of  this  application.  Department  staff  are  available  to  assist  in  identifying  potential  cumulative 
 impacts  to  wildlife  and  associated  voluntary  conservation  measures  that  can  be  implemented  for 
 the project. 
 To  help  determine  wildlife  species  presence  and  potential  conflicts,  the  Department  recommends 
 surveys  and  monitoring  be  conducted  during  the  planning  phase.  As  referenced  in  Guidelines  for 
 Solar  Development  in  Arizona  ,  these  surveys  should  be  of  sufficient  duration  and  intensity  to 
2
 adequately  assess  all  habitat  types  and  potential  species  occurrence  in  and  adjacent  to  the  project 
 area.  If  this  project  is  approved,  Department  staff  are  available  to  assist  HV  Sunrise  in 
 determining  appropriate  design  features  and  best  management  practices  that  can  help  minimize 
 potential  impacts.  The  Department  offers  the  following  recommendations  to  reduce  impacts  to 
 wildlife and habitat: 
 ●  The  endangered  Sonoran  pronghorn  could  occur  in  the  project  area  and  adjacent  lands. 
 Sonoran  pronghorn  have  specific  habitat  requirements  based  on  their  life  history  and 
 survival  strategy.  The  Department  would  like  to  work  with  HV  Sunrise  to  minimize  any 
 potential  impacts  to  this  species  and  requests  coordination  prior  to  construction  activities 
 in  order  to  exchange  information  on  current  Sonoran  pronghorn  use  in  the  project  area.  If 
 pronghorn  are  detected  during  project  activities,  please  notify  the  U.S.  Fish  and  Wildlife 
 Service  (USFWS)  Arizona  Ecological  Services  Office  (AESO)  and  the  Department’s 
3
 Sonoran Pronghorn Program Lead ( jbright@azgfd.gov )  as soon as possible. 
 ●  Kit  fox  are  likely  to  occur  within  the  project  area  and  could  be  influenced  by  loss  of 
 habitat  and  connectivity.  Surveys  for  this  species  are  recommended  to  determine  potential 
 impacts  and  to  inform  pre-construction  activities.  Department  staff  are  available  to  assist 
 in identifying suitable conservation measures if foxes or their burrows are detected. 
 ●  The  Sonoran  desert  tortoise,  which  is  covered  under  a  Candidate  Conservation 
 Agreement  (CCA),  could  occur  in  the  project  area.  The  Department  recommends 
 conducting  surveys,  in  accordance  with  the  Desert  Tortoise  Survey  Guidelines  for 
 Environmental  Consultants  ,  to  determine  the  presence  of  this  species  or  its  habitat.  If 
4
 4  https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/2010SurveyguidelinesForConsultants.pdf 
 3  hƩps://www.fws.gov/office/arizona-ecological-services/contact-us 
 2  https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/ 
 FinalSolarGuidelines03122010.pdf 
 1  https://esajournals.onlinelibrary.wiley.com/doi/10.1002/fee.2498

AZGFD - Harquahala Sun III Solar Project Major Comprehensive Plan Amendment (CPA2022010) 
 July 27, 2022 
 Page  3 
 tortoises  are  identified,  please  refer  to  and  implement  the  Recommended  Standard 
 Mitigation  Measures  for  Projects  in  Sonoran  Desert  Tortoise  Habitat  and  Guidelines  for 
5
 Handling Sonoran Desert Tortoises Encountered on Development Projects  . 
6
 ●  A  number  of  other  reptile  and  amphibian  species  have  potential  to  occur  in  the  project 
 vicinity,  including  Gila  monster  and  Arizona  toad,  which  are  Arizona  Species  of  Greatest 
 Conservation  Need  (SGCN).  To  the  extent  feasible,  the  Department  recommends 
 avoiding  areas  where  these  species  occur.  If  any  are  observed  during  construction 
 activities,  the  Department  recommends  moving  them  no  more  than  0.25  mile  outside  the 
 project  boundary.  To  aid  with  possible  relocations,  the  Department  recommends  that  all 
 personnel  take  venomous  reptile  safety  training  from  a  reputable  source  so  any  Gila 
 monsters  or  rattlesnakes  that  may  enter  the  site  can  be  safely  relocated  out  of  harm’s  way 
 without injury or mortality to the animal. 
 ●  Large-scale  solar  PV  facilities  can  result  in  bird  mortality  due  to  habitat  loss,  collision 
 with  panels,  attraction  due  to  an  optical  illusion  of  water,  and  unknown  causes  ( Kosciuch 
 et  al.  2020  ).  The  Department  recommends  a  qualified  biologist  survey  for  bird  species 
7
 within  the  project  area  to  better  understand  potential  impacts  from  these  projects. 
 Additional  surveys  for  LeConte’s  thrashers,  a  bird  species  of  conservation  concern  known 
 to  occur  in  the  area,  are  recommended.  Adjustments  to  panel  spacing  could  help  break  up 
 the  illusion  of  water  and  reduce  bird  mortality;  research  is  currently  being  conducted  to 
 assess  this  mitigation  option  (Wilkening  and  Rautenstrauch  2019  ).  Additionally,  the 
8
 Department  recommends  surveys  for  nesting  birds  be  conducted  prior  to  construction 
 activities  that  occur  during  the  breeding  season.  The  vegetation  within  the  project  area 
 may  provide  nesting  opportunities  for  avian  species  that  are  regulated  under  the 
 Migratory  Bird  Treaty  Act  (MBTA)  and  protected  under  state  law.  Breeding  season  for 
 birds  in  this  area  is  generally  mid-January  through  late  June.  If  it  is  anticipated  the  project 
 will  not  be  in  compliance  with  MBTA,  the  Department  recommends  contacting  the  U.S. 
 Fish  and  Wildlife  Service  (USFWS)  for  technical  assistance.  The  USFWS  will  provide 
 options to comply with the MBTA. 
 ●  The  western  burrowing  owl,  a  special  status  species  that  is  regulated  under  the  MBTA, 
 could  occur  within  the  project  area.  The  Department  recommends  conducting  occupancy 
 surveys  for  western  burrowing  owls  throughout  the  project  area  to  determine  if  this 
 species  occurs  within  the  project  footprints.  Guidelines  for  conducting  this  survey  are 
 found  in  Burrowing  Owl  Project  Clearance  Guidance  for  Landowners  .  Please  note  that 
9
 the  surveys  should  be  conducted  by  a  surveyor  that  is  certified  by  the  Department.  If  an 
 active  burrowing  owl  burrow  is  detected,  please  contact  the  Department  and  the  USFWS 
 for direction, in accordance with the guidelines. 
 ●  Bald  and  golden  eagles,  which  are  regulated  under  the  Bald  and  Golden  Eagle  Protection 
 Act  (BGEPA),  could  occur  within  the  project  area.  If  uncertain  about  the  effects  of  the 
 project  to  eagles,  or  if  it  is  anticipated  the  project  will  not  be  in  compliance  with  the 
 BGEPA,  the  Department  recommends  contacting  the  USFWS  for  their  Technical 
 9  https://www.azgfd.com/wildlife/speciesofgreatestconservneed/raptor-management/burrowing-owl-mangement/ 
 8  Wilkening, J., and K. Rautenstrauch. 2019. Can solar farms be wildlife friendly? The Wildlife Professional 13(1):46–50. 
 7  https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0232034 
 6  https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/2014%20Tortoise%20handling%20guidelines.pdf 
 5  https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/MitigationMeasures.pdf

AZGFD - Harquahala Sun III Solar Project Major Comprehensive Plan Amendment (CPA2022010) 
 July 27, 2022 
 Page  4 
 Assistance, 
 as 
 well  as  Tuk  Jacobson,  the  Department’s  raptor  expert,  at 
 raptors@azgfd.gov  or  623-236-7575.  The  USFWS  and  the  Department  will  provide 
 options  to  comply  with  the  BGEPA,  such  as  conservation  measures  to  avoid  or  minimize 
 adverse effects to the eagles. 
 ●  The  northern  portion  of  the  project  area  contains  riparian  habitat.  The  Arizona  Game  and 
 Fish  Commission  and  the  Department  recognize  riparian  habitats  as  areas  of 
 environmental  importance  to  wildlife.  The  Department  encourages  management  practices 
 that  will  maintain  current  riparian  areas  so  that  there  is  no  net  loss  of  habitat,  including 
 maintaining  a  150-foot  buffer  around  these  areas  and  appropriate  connections  for  wildlife 
 movement.  Additional  recommendations  to  maintain  the  integrity  of  riparian  areas  can  be 
 found in these  Riparian Area Guidelines  . 
10
 Maintaining  habitat  connectivity  is  a  high  priority  for  the  Department,  and  wildlife  movement 
 corridors  are  important  for  wildlife  to  respond  to  changing  environmental  conditions.  Attached 
 for  your  review  and  reference  is  the  Heritage  Data  Management  System  (HDMS)  Online 
 Environmental  Review  Tool  (ERT)  report  (HGIS-16831).  As  identified  in  the  report,  this  project 
 falls  within  two  identified  wildlife  movement  areas.  Telemetry  data  show  that  mule  deer,  a 
 Species  of  Economic  and  Recreational  Importance  to  the  State,  use  these  corridors  as  well  as  the 
 project  area.  If  this  project  is  approved,  the  Department  is  available  to  share  its  expertise  on 
 measures to reduce impacts to connectivity, including the following: 
 ●  The  Department  recommends  conducting  wildlife  movement  studies  in  the  project  area 
 and  surrounding  landscape  to  inform  project  design.  Continued  movement  studies  during 
 construction  and  post-construction  can  help  assess  the  broader  footprint  of  this  project 
 and  inform  future  conservation  measures.  Department  staff  are  available  to  assist  HV 
 Sunrise in determining the scope and timeline of these studies. 
 ●  The  Department  recommends  establishing  a  set-back  from  the  identified  wildlife 
 movement  areas  and  maintaining  additional  open  corridors  across  the  project  area  to 
 facilitate  wildlife  movement.  The  Department  is  available  to  assist  in  development  of  the 
 site  design  to  provide  input  on  the  set-back,  possible  corridors,  and  ways  to  maintain  the 
 ephemeral  washes  that  occur  in  the  project  area  in  their  natural  state.  These  washes  serve 
 multiple  functions  in  the  ecosystem.  Not  only  do  they  provide  for  hydrologic  flow,  which 
 is  especially  important  in  areas  that  receive  infrequent  and  isolated  precipitation  events, 
 but  these  washes  also  contain  crucial  riparian  habitat  and  serve  as  important 
 landscape-level conveyance corridors for wildlife movement. 
 ●  The  Department’s  Wildlife  Compatible  Fencing  Guidelines  provide  information  on  how 
11
 fencing  impacts  wildlife,  ways  to  design  fencing  to  prevent  wildlife  entanglement  and 
 impalement,  and  to  ensure  wildlife  movement  is  not  restricted.  Department  personnel  are 
 available  as  resources  to  help  determine  appropriate  fencing  design  and  layout  that  will 
 achieve  its  objective  while  reducing  impact  to  wildlife,  such  as  leaving  a  6–8-inch  gap 
 between  the  ground  surface  and  bottom  of  the  fence  to  allow  for  smaller  wildlife  species 
 to move freely through the area and make use of any habitat within the project boundary. 
 11  https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/ 
 110125_AGFD_fencing_guidelines.pdf 
 10  https://www.azgfd.com/wildlife/planning/wildlifeguidelines

AZGFD - Harquahala Sun III Solar Project Major Comprehensive Plan Amendment (CPA2022010) 
 July 27, 2022 
 Page  5 
 ●  To  the  extent  possible,  the  Department  recommends  retaining  habitat  features  underneath 
 the  panels,  including  vegetation  and  soils,  instead  of  grading  the  entire  site.  Keeping  the 
 existing  soil  and  root  structures  intact  would  serve  to  minimize  erosional  run-off  and  help 
 reduce biodiversity loss within the site ( Grodsky and Hernandez 2020  ). 
12
 Thank  you  for  the  opportunity  to  provide  input  on  the  Harquahala  Sun  III  Solar  Project  Major 
 Comprehensive  Plan  Amendment.  For  further  coordination,  please  contact  Tiffany  Sprague  at 
 tsprague@azgfd.gov  or 623-236-7222. 
 Sincerely, 
 for 
 Luke Thompson 
 Habitat, Evaluation, and Lands Branch Chief 
 cc: 
 Michael Sumner - Regional Supervisor - Region IV 
 Tyler Williford, Region IV Habitat, Evaluation, and Lands Program Supervisor 
 Ginger Ritter - Project Evaluation Program Supervisor 
 Tiffany Sprague - Project Evaluation Program Specialist 
 Attachment: 
 Harquahala Sun III_HGIS-16831_20220718.pdf 
 AZGFD #M22-06241452 
 12  https://www.nature.com/articles/s41893-020-0574-x

Arizona Environmental Online Review Tool Report
Arizona Game and Fish Department Mission
To conserve Arizona's diverse wildlife resources and manage for safe, compatible outdoor recreation
opportunities for current and future generations.
Project Name:
Harquahala Sun III Solar Project
Project Description:
The Applicant proposes to construct, operate, and maintain up to approximately 1-gigawatt hybrid solar
photovoltaic (PV) and battery power plant and associated infrastructure for the Harquahala Sun III Project
(Project) on ±9,291 acres of county land. The Project will be constructed in approximately four (4) phases with
each phase including an estimated 250-MWac or more hybrid solar PV and battery power plant constructed on
approximately 1,500 to 2,500 acres. Each phase of the project will include approximately 600,000 solar modules
(~4,000,000 modules total) mounted on single axis trackers, inverters to convert direct current into grid-
compatible alternating current, transformers to increase the voltage of the electricity generated, and battery
energy storage system. The Project will also include a 500 kV utility substation and one or more small buildings
to house telecommunication equipment. The Project is expected to interconnect to the transmission grid at the
Delaney Substation operated by Arizona Public Service (APS) or a similar facility. Off-site supporting
improvements, infrastructure, and/or uses are expected to include up to a 200-foot-wide gen-tie route corridor
that extends approximately 10 miles through private land and to the Project substation.
Project Type:
Energy Storage/Production/Transfer, Energy Production (generation), photovoltaic solar facility
(modification/expansion)
Contact Person:
Tiffany Sprague
Organization:
AZ Game and Fish Dept
Page 1 of 12

On Behalf Of:
MARICOPA
Project ID:
HGIS-16831
Please review the entire report for project type and/or species recommendations for the location information
entered. Please retain a copy for future reference.
Page 2 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Disclaimer: 
1. This Environmental Review is based on the project study area that was entered. The report must be updated if
the project study area, location, or the type of project changes.
2. This is a preliminary environmental screening tool. It is not a substitute for the potential knowledge gained by
having a biologist conduct a field survey of the project area. This review is also not intended to replace
environmental consultation (including federal consultation under the Endangered Species Act), land use
permitting, or the Departments review of site-specific projects.
3. The Departments Heritage Data Management System (HDMS) data is not intended to include potential
distribution of special status species. Arizona is large and diverse with plants, animals, and environmental
conditions that are ever changing. Consequently, many areas may contain species that biologists do not know
about or species previously noted in a particular area may no longer occur there. HDMS data contains
information about species occurrences that have actually been reported to the Department. Not all of Arizona has
been surveyed for special status species, and surveys that have been conducted have varied greatly in scope
and intensity. Such surveys may reveal previously undocumented population of species of special concern.
4. HabiMap Arizona data, specifically Species of Greatest Conservation Need (SGCN) under our State Wildlife
Action Plan (SWAP) and Species of Economic and Recreational Importance (SERI), represent potential species
distribution models for the State of Arizona which are subject to ongoing change, modification and refinement.
The status of a wildlife resource can change quickly, and the availability of new data will necessitate a refined
assessment.
Locations Accuracy Disclaimer:
Project locations are assumed to be both precise and accurate for the purposes of environmental review. The
creator/owner of the Project Review Report is solely responsible for the project location and thus the correctness of the
Project Review Report content.
Page 3 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Recommendations Disclaimer:
1. The Department is interested in the conservation of all fish and wildlife resources, including those species listed
in this report and those that may have not been documented within the project vicinity as well as other game and
nongame wildlife.
2. Recommendations have been made by the Department, under authority of Arizona Revised Statutes Title 5
(Amusements and Sports), 17 (Game and Fish), and 28 (Transportation).
3. Potential impacts to fish and wildlife resources may be minimized or avoided by the recommendations generated
from information submitted for your proposed project. These recommendations are preliminary in scope,
designed to provide early considerations on all species of wildlife.
4. Making this information directly available does not substitute for the Department's review of project proposals,
and should not decrease our opportunity to review and evaluate additional project information and/or new project
proposals.
5. Further coordination with the Department requires the submittal of this Environmental Review Report with a cover
letter and project plans or documentation that includes project narrative, acreage to be impacted, how
construction or project activity(s) are to be accomplished, and project locality information (including site map).
Once AGFD had received the information, please allow 30 days for completion of project reviews. Send requests
to:
Project Evaluation Program, Habitat Branch
Arizona Game and Fish Department
5000 West Carefree Highway
Phoenix, Arizona 85086-5000
Phone Number: (623) 236-7600
Fax Number: (623) 236-7366
Or
PEP@azgfd.gov
6. Coordination may also be necessary under the National Environmental Policy Act (NEPA) and/or Endangered
Species Act (ESA). Site specific recommendations may be proposed during further NEPA/ESA analysis or
through coordination with affected agencies
Page 4 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Page 5 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Page 6 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Page 7 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Page 8 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Special Status Species Documented within 5 Miles of Project Vicinity
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Antilocapra americana sonoriensis
Sonoran Pronghorn
LE,XN
S
1A
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1A
Toxostoma lecontei
LeConte's Thrasher
S
1B
Note: Status code definitions can be found at https://www.azgfd.com/wildlife/planning/wildlifeguidelines/statusdefinitions/
. 
Special Areas Documented that Intersect with Project Footprint as Drawn
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Belmont Mtns - Saddle Mtn - Gila
Bend Mtns
Maricopa County Wildlife Movement
Area - Landscape
Centennial Wash
Maricopa County Wildlife Movement
Area - Riparian/Wash
Note: Status code definitions can be found at https://www.azgfd.com/wildlife/planning/wildlifeguidelines/statusdefinitions/
. 
Species of Greatest Conservation Need Predicted that Intersect with Project Footprint as Drawn, based on
Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Aix sponsa
Wood Duck
1B
Ammospermophilus harrisii
Harris' Antelope Squirrel
1B
Anaxyrus microscaphus
Arizona Toad
SC
S
1B
Anthus spragueii
Sprague's Pipit
SC
1A
Aquila chrysaetos
Golden Eagle
BGA
S
1B
Botaurus lentiginosus
American Bittern
1B
Buteo regalis
Ferruginous Hawk
SC
S
1B
Calypte costae
Costa's Hummingbird
1C
Chilomeniscus stramineus
Variable Sandsnake
1B
Colaptes chrysoides
Gilded Flicker
S
1B
Corynorhinus townsendii pallescens Pale Townsend's Big-eared Bat
SC
S
S
1B
Euderma maculatum
Spotted Bat
SC
S
S
1B
Eumops perotis californicus
Greater Western Bonneted Bat
SC
S
1B
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1A
Haliaeetus leucocephalus
Bald Eagle
SC,
BGA
S
S
1A
Heloderma suspectum
Gila Monster
1A
Incilius alvarius
Sonoran Desert Toad
1B
Lasiurus blossevillii
Western Red Bat
S
1B
Lasiurus xanthinus
Western Yellow Bat
S
1B
Macrotus californicus
California Leaf-nosed Bat
SC
S
1B
Melanerpes uropygialis
Gila Woodpecker
1B
Page 9 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Species of Greatest Conservation Need Predicted that Intersect with Project Footprint as Drawn, based on
Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Melospiza lincolnii
Lincoln's Sparrow
1B
Melozone aberti
Abert's Towhee
S
1B
Micrathene whitneyi
Elf Owl
1C
Myotis velifer
Cave Myotis
SC
S
1B
Myotis yumanensis
Yuma Myotis
SC
1B
Nyctinomops femorosaccus
Pocketed Free-tailed Bat
1B
Oreoscoptes montanus
Sage Thrasher
1C
Oreothlypis luciae
Lucy's Warbler
1C
Passerculus sandwichensis
Savannah Sparrow
1B
Perognathus longimembris
Little Pocket Mouse
No
Status
1B
Spizella breweri
Brewer's Sparrow
1C
Tadarida brasiliensis
Brazilian Free-tailed Bat
1B
Thomomys bottae subsimilis
Harquahala Southern Pocket Gopher
SC
1B
Toxostoma lecontei
LeConte's Thrasher
S
1B
Troglodytes pacificus
Pacific Wren
1B
Vireo bellii arizonae
Arizona Bell's Vireo
1B
Vulpes macrotis
Kit Fox
No
Status
1B
Species of Economic and Recreation Importance Predicted that Intersect with Project Footprint as Drawn
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Callipepla gambelii
Gambel's Quail
Odocoileus hemionus
Mule Deer
Pecari tajacu
Javelina
Puma concolor
Mountain Lion
Zenaida asiatica
White-winged Dove
Zenaida macroura
Mourning Dove
Page 10 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
Project Type: Energy Storage/Production/Transfer, Energy Production (generation), photovoltaic solar facility
(modification/expansion)
Project Type Recommendations:
During the planning stages of your project, please consider the local or regional needs of wildlife in regards to movement,
connectivity, and access to habitat needs. Loss of this permeability prevents wildlife from accessing resources, finding
mates, reduces gene flow, prevents wildlife from re-colonizing areas where local extirpations may have occurred, and
ultimately prevents wildlife from contributing to ecosystem functions, such as pollination, seed dispersal, control of prey
numbers, and resistance to invasive species. In many cases, streams and washes provide natural movement corridors
for wildlife and should be maintained in their natural state. Uplands also support a large diversity of species, and should
be contained within important wildlife movement corridors. In addition, maintaining biodiversity and ecosystem functions
can be facilitated through improving designs of structures, fences, roadways, and culverts to promote passage for a
variety of wildlife. Guidelines for many of these can be found
at: https://www.azgfd.com/wildlife/planning/wildlifeguidelines/.
Consider impacts of outdoor lighting on wildlife and develop measures or alternatives that can be taken to increase
human safety while minimizing potential impacts to wildlife. Conduct wildlife surveys to determine species within project
area, and evaluate proposed activities based on species biology and natural history to determine if artificial lighting may
disrupt behavior patterns or habitat use. Use only the minimum amount of light needed for safety. Narrow spectrum bulbs
should be used as often as possible to lower the range of species affected by lighting. All lighting should be shielded,
canted, or cut to ensure that light reaches only areas needing illumination.
Minimize the potential introduction or spread of exotic invasive species, including aquatic and terrestrial plants, animals,
insects and pathogens. Precautions should be taken to wash and/or decontaminate all equipment utilized in the project
activities before entering and leaving the site. See the Arizona Department of Agriculture website for a list of prohibited
and restricted noxious weeds at https://www.invasivespeciesinfo.gov/unitedstates/az.shtml and the Arizona Native Plant
Society https://aznps.com/invas for recommendations on how to control. To view a list of documented invasive species or
to report invasive species in or near your project area visit iMapInvasives - a national cloud-based application for tracking
and managing invasive species at https://imap.natureserve.org/imap/services/page/map.html. 
To build a list: zoom to your area of interest, use the identify/measure tool to draw a polygon around your area of
interest, and select “See What’s Here” for a list of reported species. To export the list, you must have an
account and be logged in. You can then use the export tool to draw a boundary and export the records in a csv
file. 
 
Minimization and mitigation of impacts to wildlife and fish species due to changes in water quality, quantity, chemistry,
temperature, and alteration to flow regimes (timing, magnitude, duration, and frequency of floods) should be evaluated.
Minimize impacts to springs, in-stream flow, and consider irrigation improvements to decrease water use. If dredging is a
project component, consider timing of the project in order to minimize impacts to spawning fish and other aquatic species
(include spawning seasons), and to reduce spread of exotic invasive species. We recommend early direct coordination
with Project Evaluation Program for projects that could impact water resources, wetlands, streams, springs, and/or
riparian habitats.
The Department recommends that wildlife surveys are conducted to determine if noise-sensitive species occur within the
project area. Avoidance or minimization measures could include conducting project activities outside of breeding
seasons.
Page 11 of 12

Arizona Game and Fish Department
project_report_harquahala_sun_iii_solar_pr_52256_53918.pdf
Project ID: HGIS-16831
Review Date: 7/18/2022 05:10:41 PM
For any powerlines built, proper design and construction of the transmission line is necessary to prevent or minimize risk
of electrocution of raptors, owls, vultures, and golden or bald eagles, which are protected under state and federal laws.
Limit project activities during the breeding season for birds, generally March through late August, depending on species
in the local area (raptors breed in early February through May). Conduct avian surveys to determine bird species that
may be utilizing the area and develop a plan to avoid disturbance during the nesting season. For underground
powerlines, trenches should be covered or back-filled as soon as possible. Incorporate escape ramps in ditches or
fencing along the perimeter to deter small mammals and herptefauna (snakes, lizards, tortoise) from entering ditches. In
addition, indirect affects to wildlife due to construction (timing of activity, clearing of rights-of-way, associated bridges and
culverts, affects to wetlands, fences) should also be considered and mitigated.
Based on the project type entered, coordination with State Historic Preservation Office may be required
(http://azstateparks.com/SHPO/index.html).
Based on the project type entered, coordination with U.S. Fish and Wildlife Service (Migratory Bird Treaty Act) may be
required (https://www.fws.gov/office/arizona-ecological-services).
Vegetation restoration projects (including treatments of invasive or exotic species) should have a completed site-
evaluation plan (identifying environmental conditions necessary to re-establish native vegetation), a revegetation plan
(species, density, method of establishment), a short and long-term monitoring plan, including adaptive management
guidelines to address needs for replacement vegetation.
The Department requests further coordination to provide project/species specific recommendations, please
contact Project Evaluation Program directly at PEP@azgfd.gov. 
Project Location and/or Species Recommendations:
Analysis indicates that your project is located in the vicinity of an identified wildlife habitat connectivity feature. The 
County-level Stakeholder Assessments contain five categories of data (Barrier/Development, Wildlife Crossing Area,
Wildlife Movement Area- Diffuse, Wildlife movement Area- Landscape, Wildlife Movement Area- Riparian/Washes) that
provide a context of select anthropogenic barriers, and potential connectivity. The reports provide recommendations for
opportunities to preserve or enhance permeability. Project planning and implementation efforts should focus on
maintaining and improving opportunities for wildlife permeability. For information pertaining to the linkage assessment
and wildlife species that may be affected, please refer
to: https://www.azgfd.com/wildlife/planning/habitatconnectivity/identifying-corridors/.
Please contact the Project Evaluation Program (pep@azgfd.gov) for specific project recommendations.
HDMS records indicate that one or more Listed, Proposed, or Candidate species or Critical Habitat (Designated or
Proposed) have been documented in the vicinity of your project. The Endangered Species Act (ESA) gives the US Fish
and Wildlife Service (USFWS) regulatory authority over all federally listed species. Please contact USFWS Ecological
Services Offices at https://www.fws.gov/office/arizona-ecological-services or:
 
Phoenix Main Office
Tucson Sub-Office
Flagstaff Sub-Office
9828 North 31st Avenue #C3
201 N. Bonita Suite 141
SW Forest Science Complex
Phoenix, AZ 85051-2517
Tucson, AZ 85745
2500 S. Pine Knoll Dr.
Phone: 602-242-0210
Phone: 520-670-6144
Flagstaff, AZ 86001
Fax: 602-242-2513
Fax: 520-670-6155
Phone: 928-556-2157
 
 
Fax: 928-556-2121
 
 
 
HDMS records indicate that Sonoran Desert Tortoise have been documented within the vicinity of your project area.
Please review the Tortoise Handling Guidelines found at: https://www.azgfd.com/wildlife/nongamemanagement/tortoise/
Powered by TCPDF (www.tcpdf.org)
Page 12 of 12

From:
Caroline Klebacha
To:
Adam Cannon (PND)
Subject:
Re: 2nd Submittal - CPA2022010 - Major Comprehensive Plan Amendment for Harquahala Sun III
Date:
Tuesday, October 18, 2022 1:01:43 PM
Good afternoon,
Thank you for the updated submittal from Kimley-Horn. We note that the applicant has
included cultural resources into their plans. We have no further comments at this time and
look forward to reviewing the reports.
Thank you,
Caroline
Caroline Klebacha, M.A.
Archaeological Compliance Specialist
State Historic Preservation Office
A Division of Arizona State Parks & Trails
Please use azshpo@azstateparks.gov for all consultation!
1110 West Washington Street, Suite 100
Phoenix, AZ 85007-2957
Phone: 602-542-7140
Email: cklebacha@azstateparks.gov
Web: http://AZStateParks.com/SHPO
On Fri, Sep 23, 2022 at 9:26 AM AZSHPO - AZPARKS <azshpo@azstateparks.gov> wrote:
SHPO-2022-0759 (165920)
---------- Forwarded message ---------
From: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Date: Thu, Sep 22, 2022 at 8:13 AM
Subject: 2nd Submittal - CPA2022010 - Major Comprehensive Plan Amendment for
Harquahala Sun III
To: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Cc: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Good morning all,
This e-mail serves as notification of a 2nd Submittal we have received from Kimley-Horn
for a Major Comprehensive Plan Amendment for Harquahala Sun III. 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 CPA case number CPA2022010.
Please let me know if you have any questions or concerns.
Adam Cannon, AICP
Planner
Maricopa County Planning & Development Department
301 W. Jefferson St., Suite 170, Phoenix, AZ 85003
Desk: 602-372-0292
adam.cannon@maricopa.gov
P&D is now 100% digital for construction permit applications.
Find information on our new permit process here.

DEPARTMENT OF THE AIR FORCE 
AIR EDUCATION AND TRAINING COMMAND 
11 August 2022 
Mr. Christopher P. Toale 
Director, Community Initiatives Team 
56th Fighter Wing 
14185 W. Falcon Street 
Luke AFB AZ 85309-1629 
Mr. Adam Cannon 
Maricopa County Planning & Development Department 
501 North 44th Street, Suite 200 
Phoenix, AZ 85008 
RE:  CPA2022010; Harquahala Sun III (APNs:  401-55-023 thru 506-27-033) 
Dear Mr. Cannon 
Thank you for the opportunity to comment on the Comprehensive Plan Amendment Application 
to change the land use designation from Rural to Utilities in order to develop and operate a solar 
generating facility.  The site sits on approximately 9,291 acres and is located approximately 20 miles west 
of the city of Buckeye, just south of the W Lower Buckeye Rd, west of 539th Ave and east of 487th Ave 
in unincorporated Maricopa County, AZ.  The applicant proposes to construct, operate, and maintain a 1-
gigawatt hybrid solar photovoltaic (PV) and battery power plant and associated infrastructure.   
The site is located under a Military Training Route (MTR) and therefore requires further review 
as it could possibly impact the flying operations of Luke AFB.  Please ensure the project is submitted for 
an informal review through the DoD Siting Clearinghouse for Energy, Installations, and Environment.  
Please send the project narrative for review to:   osd.dod-siting-clearinghouse@mail.mil.  This response is 
conditional upon their approval/input.   
If you have any questions, please contact my Community Planner, Mr. Mark James at 
(623) 856-9981.
     Sincerely 
  CHRISTOPHER P. TOALE 
cc: 
Colonel Keagan L. McLeese, Vice Commander, 56th Fighter Wing 
Mr. Charles E. Buchanan, Director, 56th Fighter Wing Range Management Office
Mr. Timothy A. Forero, GS-13, General Law Attorney, 56th Fighter Wing

From:
JAMES, MARK C GS-12 USAF AETC 56 FW/CVE
To:
Adam Cannon (PND)
Subject:
[WARNING: ATTACHMENT UNSCANNED]DoD Siting Clearinghouse Review Process
Date:
Thursday, July 28, 2022 8:05:29 AM
Adam,
Per our convo yesterday, please see below process to ensure solar applicants
have the right information for their project.  Thanks
Informal Review info:
https://www.acq.osd.mil/dodsc/about/faq.html
Informal reviews are recommended early in the siting process. The Military
Aviation and Installation Assurance Siting Clearinghouse recognizes there
may be no definitive plans at this point, but early engagement is key in
preventing issues during the formal review process. The goal of an informal
review is to identify areas of potential impact and, once identified, refer
the proponent to the proper DoD stakeholder for further discussion.
To request an informal review, please send the following information to the
Military Aviation and Installation Assurance Siting Clearinghouse at
osd.dod-siting-clearinghouse@mail.mil. At a minimum, anyone requesting an
informal review must provide:
1. Contact information, including the name of the company, vendor or
developer, as well as address, city, state and zip code; project point of
contact, including first and last name; contact phone, fax, and email; and
project name, nearest city or county, and state.
2. The geographic location of the project, including its latitude and
longitude.
3. The nature of the project (e.g., wind, solar).
In order to provide the most expeditious review, the following information
is recommended:
1. Contact information, including the name of the company, vendor or
developer, as well as address, city, state and zip code; project point of
contact, including first and last name; contact phone, fax, and email; and
project name, nearest city or county, and state.
2. The geographic location of the project, including latitude and longitude:
Please include Lat/Longs in DMS (Degrees, Minutes, Seconds) for each turbine
tower in Excel format and a map of the project in PowerPoint or Adobe pdf
format, if possible.
3. The nature of the project (e.g., wind, solar) and the following
information:
a. Number of Structures
b. Wind Turbine: Include turbine height, hub height, blade tip height, and

turbine farm layout
c. Solar: Include solar tower or panel height, solar layout, and solar array
acreage, with map
d. Geothermal: Include geothermal layout/acreage, with map
e. Transmission, Utility, and Power Lines: Height and type of structure(s),
substation(s) tie-in, if known, KV of line(s), and map of route
f. BLM ID, NEPA number, or any Federal/State/Local identifiers, if
applicable
g. Associated transmission/lines for project and obstructions to structure
(guideline supports, lighting)
h. Intended grid connection with location (DMS)
i. Shapefile for project (Lat/Longs in DMS and decimals)
Respectfully,
Mark James
56th Fighter Wing, Community Initiatives Team
Luke AFB AZ 85309
Office:  623-856-9981
DSN:  896-9981

From:
Katz, Paul
To:
Adam Cannon (PND)
Subject:
RE: CPA2022010 - Major Comprehensive Plan Amendment for Harquahala Sun III
Date:
Thursday, June 30, 2022 1:46:00 PM
Mr. Cannon,
 
I have reviewed the Notice of Major Comprehensive Plan Amendment No. CPA2022010 in reference
to the Harquahala Sun III project on behalf of the Arizona Attorney General.  This proposed
Amendment does not have any adverse impact upon Luke AFB nor does it appear to have any
significant impact upon local automobile traffic.  Our office has no objection to this proposed
Amendment.
 
 
Paul A. Katz
Assistant Attorney General
Arizona Attorney General's Office
2005 N. Central Avenue
Phoenix, AZ 85004
Direct: (602) 542-7785
Fax: (602) 542-4084
Email: paul.katz@azag.gov
 
 
 
From: Adam Cannon (PND) [mailto:Adam.Cannon@maricopa.gov] 
Sent: Friday, June 24, 2022 8:52 AM
To: bhurley@buhsd.org; chadt@arlingtonk8.org; tvcc.events@gmail.com; dmheisler1@aol.com;
swilken@azmag.gov; Vwolfley@azmag.gov; kcotner@azmag.gov; Rerickson@azdot.gov;
contact.dds@co.yuma.az.us; gramirez@azdot.gov; redletter@azdot.gov; twilliford@azgfd.gov;
pep@azgfd.gov; pe@azland.gov; bfenske@azdot.gov; jgarcia@azdot.gov; Dkrantz@citytocitycre.com;
Frank McWilliams (MCSO); azshpo@azstateparks.gov; proetto1950@gmail.com; ssandell@hfdaz.org;
56fw.cit.communityinitiative@us.af.mil; Eileen Baden (PRK); pdoweb_az@blm.gov;
tbuschatzke@azwater.gov; steve_spangle@fws.gov; mkillian@azda.gov; lc1@azdeq.gov; Katz, Paul;
david.mckay@az.usda.gov; johnson.kathleen@epa.gov
Cc: Adam Cannon (PND)
Subject: CPA2022010 - Major Comprehensive Plan Amendment for Harquahala Sun III
 
Good morning all,
 
This e-mail serves as notification of an application we have received from Kimley-Horn for a Major
Comprehensive Plan Amendment for Harquahala Sun III.  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 CPA case number CPA2022010.  A Technical Advisory Committee meeting is scheduled for
August 2, 2022 at 9:00 a.m.  If you would like to attend please let me know and I will send you an
invite.
 
Please let me know if you have any questions or concerns.

Adam Cannon, AICP
Planner
Maricopa County Planning & Development Department
301 W. Jefferson St., Suite 170, Phoenix, AZ 85003
Desk: 602-372-0292
adam.cannon@maricopa.gov
 
P&D is now 100% digital for construction permit applications.
Find information on our new permit process here.

From:
Bernadette Martinez
To:
Adam Cannon (PND)
Subject:
Re: CPA2022010 - Major Comprehensive Plan Amendment for Harquahala Sun III
Date:
Monday, August 1, 2022 2:19:19 PM
Thank you for your notice of the above referenced item.
After review, the above referenced location is more than 1/2 mile from any ADOT proposed or 
existing highway facility and is not anticipated to cause impacts to ADOT facilities.  Exceptions to this 
would be traffic control necessary at ADOT facilities. If you are in need of performing traffic control 
on ADOT facilities said traffic control would require a permit. Otherwise, ADOT has no comment 
regarding the request associated with this case.
See Permit Encroachment Links:
Permit Encroachment Process Link - https://azdot.gov/business/permits/encroachment-permits. 
Permit Encroachment General Mailbox is: CentralPermit@azdot.gov. 
ADOT reserves the right to review any future plans, additions and/or changes to this development as 
to any impact they may have on the State Highway System.
Please feel free to contact me should you have any further questions. We appreciate the 
opportunity to review and comment. Thank you.
Bernadette Martinez
Right of Way Coordinator Assistant
Central District
2140 W. Hilton Ave, MD 700
Phoenix, AZ  85009
602.712.2086
On Fri, Jun 24, 2022 at 8:51 AM Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
wrote:
Good morning all,
 
This e-mail serves as notification of an application we have received from Kimley-Horn for
a Major Comprehensive Plan Amendment for Harquahala Sun III.  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 CPA case number CPA2022010.  A Technical Advisory Committee
meeting is scheduled for August 2, 2022 at 9:00 a.m.  If you would like to attend please let
me know and I will send you an invite.
 
Please let me know if you have any questions or concerns.

Adam Cannon, AICP
Planner
Maricopa County Planning & Development Department
301 W. Jefferson St., Suite 170, Phoenix, AZ 85003
Desk: 602-372-0292
adam.cannon@maricopa.gov
 
P&D is now 100% digital for construction permit applications.
Find information on our new permit process here.

From:
Bruce Fenske
To:
Adam Cannon (PND)
Subject:
Re: CPA2022010 - Major Comprehensive Plan Amendment for Harquahala Sun III
Date:
Thursday, July 21, 2022 1:29:21 PM
Thanks.  Southwest District of ADOT has no comments on this project.
Bruce A. Fenske, P.E.
District Administrator
Southwest District
Tel.       928.317.2138
Mobile  928.210.8882
On Thu, 21 Jul 2022 at 13:21, Adam Cannon (PND) <Adam.Cannon@maricopa.gov> wrote:
Bruce,
 
Yes it’s a solar farm with battery storage and a substation.
 
 
Adam Cannon, AICP
Senior Planner
Maricopa County Planning & Development Department
301 W. Jefferson St., Suite 170, Phoenix, AZ 85003
Desk: 602-372-0292
adam.cannon@maricopa.gov
 
P&D is now 100% digital for construction permit applications.
Find information on our new permit process here.
 
 
From: Bruce Fenske <bfenske@azdot.gov> 
Sent: Thursday, July 21, 2022 1:19 PM

To: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Subject: Re: CPA2022010 - Major Comprehensive Plan Amendment for Harquahala Sun
III
 
Adam:
 
I cannot tell from searching the Online Permit Manager using CPA2022010 as the search,
but is this a solar plant?
 
Thanks for your help.
 
Bruce A. Fenske, P.E.
District Administrator
Southwest District
Tel.       928.317.2138
Mobile  928.210.8882
 
 
 
On Fri, 24 Jun 2022 at 08:51, Adam Cannon (PND) <Adam.Cannon@maricopa.gov> wrote:
Good morning all,
 
This e-mail serves as notification of an application we have received from Kimley-Horn
for a Major Comprehensive Plan Amendment for Harquahala Sun III.  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 CPA case number CPA2022010.  A Technical Advisory Committee
meeting is scheduled for August 2, 2022 at 9:00 a.m.  If you would like to attend please
let me know and I will send you an invite.

Please let me know if you have any questions or concerns.
 
Adam Cannon, AICP
Planner
Maricopa County Planning & Development Department
301 W. Jefferson St., Suite 170, Phoenix, AZ 85003
Desk: 602-372-0292
adam.cannon@maricopa.gov
 
P&D is now 100% digital for construction permit applications.
Find information on our new permit process here.

July 5, 2022 
 
 
 
 
 
 
 
 
SENT VIA EMAIL 
 
 
Adam Cannon, AICP, Planner 
Maricopa County Planning and Development Department  
301 W. Jefferson Street, Suite 170 
Phoenix, AZ  85003 
 
Subject: 
 
CPA2022009: Major Comprehensive Plan Amendment - Hyder Solar & Storage Project 
CPA2022010: Major Comprehensive Plan Amendment - Harquahala Sun III 
 
Dear Adam: 
 
Thank you for the opportunity to review and comment on Maricopa County Major Comprehensive 
Plan Amendments CPA2022009 and CPA2022010 for a solar energy projects in the county, to 
change land use designations from Rural Residential to Utilities on ± 2,000 acres and ± 9,300 
acres, respectively, for large-scale solar farm and battery storage systems. 
 
The Hyder Solar and Storage Project is located about 12 miles north of Interstate 8 near the 
farming community of Hyder, AZ. The Harquahala Sun III project is located about 8 miles south 
of Interstate 10 and 18 miles west of the Palo Verde Generating Station. Both projects are located 
in extremely remote areas of the state, with surrounding land uses including scattered agricultural 
lands, solar farms, undeveloped lands, and extremely low density rural residential development. 
 
The proposed solar energy generation and storage projects are located in regions of high solar 
exposure, proximity to other existing solar energy farms and adequate energy transmission 
infrastructure. Projects should have minimal impact on surrounding properties and generation of 
renewable energy would be a benefit to the region. Pima County Development Services 
Department, Planning Division has no opposition to the proposed major comprehensive plan 
amendments. 
 
 
Sincerely, 
 
Mark Holden, AICP 
Principal Planner 
Pima County Development Services Department, Planning Division

From:
Stacey Bridge-Denzak
To:
Adam Cannon (PND)
Subject:
CPA2022009 Hyder Solar & Storage and CPA2022010 Harquahala Sun III
Date:
Wednesday, June 29, 2022 5:35:54 PM
Dear Adam,
 
Thank you for the opportunity to provide feedback on the two Major Comprehensive Plan
Amendments as referenced above.  The Town of Carefree has no comments.
 
Regards,
Stacey
 
 
Stacey Bridge-Denzak
Planning Director and Zoning Administrator
Town of Carefree
 
Email: stacey@carefree.org
Phone: 480-488-3686  Fax: 480-488-3845
PO Box 740, 8 Sundial Circle, Carefree, AZ 85377
 
www.carefree.org