04.Z250045 PZ Staff Report
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Z250045
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Report to the Planning and Zoning Commission
Prepared by the Maricopa County Planning and Development Department
Case:
Z250045 – RE Papago Photovoltaic Solar Energy Generation and Storage
Project
Hearing Date:
April 9, 2026
Supervisor District:
4
Applicant:
Liam Duncan, Recurrent Energy
Owners:
RE Papago PV, LLC and RE Papago Landco, LLC
Request:
Modification of conditions to the IND-2 IUPD zoning district – to increase
maximum transmission line height from 140’ to 170’
Site Location:
Generally located south of I-10, north of the Thomas Road alignment, and
east of the 467th Avenue alignment in the Tonopah area
Site Size:
Approx. 1,281 acres
Density:
N/A
County Island:
No
County Plan:
Tonopah / Arlington Area Plan & Vision 2030 Maricopa County
Comprehensive Plan – Utilities
Municipal Plan:
N/A
Municipal Comments:
None received to date
Support/Opposition:
None known
Recommendation:
Approve with conditions
Z250045
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Project Summary:
1.
The applicant, Liam Duncan of Recurrent Energy, is requesting a Modification of Conditions for
the RE Papago Photovoltaic Solar Energy Generation and Storage project. The project was entitled
when the Board of Supervisors approved IND-2 IUPD zoning, per case Z2019121, on September
1, 2021. Prior to this, the Board had approved two major comprehensive plan amendments
(CPAs), per cases CPA2019004 and CPA2019012, to change the land use designations in the
Tonopah / Arlington Area Plan and the Vision 2030 Maricopa County Comprehensive Plan to
“utilities” in anticipation of the solar energy project.
2.
Staff notes that the original zone change was approved for an area covering approximately 2,806
acres. However, following the Board’s approval of the original zone change, staff administratively
approved two minor amendments to the project plan of development in 2024: Z2023086 and
PD240006. While both of these amendments were primarily intended to facilitate minor design
modifications that became necessary as the project advanced, staff notes that, with PD240006,
the developer reduced the project area by more than 54% from approximately 2,806 acres to
approximately 1,281 acres. The projected power generation was also scaled down from
approximately 300 megawatt hours (MWhs) to approximately 150 MWhs. The area since
removed from the project limits – located entirely to the west of the remaining project area –
remains zoned IND-2 IUPD, with the IUPD overlay limiting the allowed use of the land exclusively
to a solar electric generating facility, including ancillary offices and uses, per BOS-approved
condition ‘f’ of Z2019121. However, this land is no longer intended for the entitled development
and has therefore been excluded from this request.
3.
The purpose of this request is to amend one of the IUPD standards established per BOS-approved
condition ‘d’ of case Z2019121 – specifically, condition ‘d.1,’ which establishes a maximum
allowed electric transmission line height of 140’. This standard is already an increase from the
standard established in MCZO Article 811.7, which allows a maximum electric transmission line
height of 120’. The purpose of the original variation to 140’ was to accommodate the then-
anticipated design considerations for the transmission line that would connect the project to the
adjacent APS Delaney Substation. The support structures were anticipated to be approximately
126’ in height but no more than 140’ in height. With the design having progressed in the years
since the original zoning approval and the project now under development, the developer has
realized that additional height clearance is necessary to support a planned third phase of the
project. This third phase will establish additional battery energy storage system (BESS)
infrastructure to what was already developed during the first phase of the project (completed in
2025). To accommodate the third phase, the developer intends to submit another minor
amendment to the plan of development in the future. The requested height increase is specifically
to allow the safe crossing of the proposed Phase 3 transmission lines over the existing
transmission lines supporting Phase 2 of the project (which concerns the development of the
photovoltaic solar arrays across the project site and is nearing completion).
4.
The applicant and developer are not proposing any additional modifications to the conditions of
approval from Z2019121 other than the increase to the maximum allowed transmission line
height. The existing IUPD development standards, as well as the proposed modification, are
summarized in the table on the following page (staff notes that the base zoning district
regulations listed reflect those in the previous revision of the MCZO effective prior to the update
on January 9, 2026, as this was the revision of the MCZO in effect when this application was
submitted):
Z250045
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Regulation
Base Zoning District
Regulations (IND-2)
Approved Zoning
District Regulations per
Z2019121
(IND-2 IUPD)
Requested Zoning
District Regulations per
Z250045
(IND-2 IUPD)
Max. Electric
Transmission Line
Height
120’
140’
170’
Min. Side Yard
3’ – 10’
0’
0’
Min. Rear Yard
25’
0’
0’
Parking Spaces
Required
1 per 250 sq. ft. of floor
area
None required with a
Maricopa County Air
Quality Department
approved dust control
plan. High curb and/or
bumper guards not
required.
None required with a
Maricopa County Air
Quality Department
approved dust control
plan. High curb and/or
bumper guards not
required.
Landscaping
All properties abutting
a public street shall
have an open setback
area which shall be
landscaped extending
for the full width of the
property.
No landscaping areas
required.
No landscaping areas
required.
Sight Visibility Triangles
Required
No sight visibility
triangles are required
at project site
entry/access points
and road intersection,
section line, mid-
section line or
alignment corners.
No sight visibility
triangles are required
at project site
entry/access points
and road intersection,
section line, mid-
section line or
alignment corners.
Outdoor Uses
All uses except for
parking, loading,
unloading, or storage
shall be conducted
within a completely
enclosed building
All utility uses shall be
permitted to be
conducted outdoors.
All utility uses shall be
permitted to be
conducted outdoors.
Screening
A solid masonry wall
not less than six feet in
height shall be required
along and adjacent to
any side or rear
property line abutting
any rural or residential
zone boundary, or any
alley abutting such
zone boundary. Further,
any access gates shall
be constructed of view-
obscuring material to
provide effective site
screening.
6’ chain-link fencing
with 1’ of barbed wire
permitted.
6’ chain-link fencing
with 1’ of barbed wire
permitted.
Z250045
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2026 Parcel Aerial
2026 Regional Aerial – RE Papago parcels are to the far left (west) of the image.
Z250045
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Zoning Map (subject parcels in maroon, other IND-2 parcels in grey, Rural-43 parcels in yellow)
Existing On-Site and Adjacent Zoning / Land Use:
5.
On-site:
IND-2 IUPD / PV solar energy generation and storage facility
North:
I-10, then Rural-43 / native desert
South:
Rural-43 / APS Delaney Substation and native desert
East:
Rural-43 / native desert (Saddle Mountain)
West:
IND-2 IUPD and Rural-43 / native desert
Utilities and Services:
6.
Water:
N/A
Wastewater:
N/A
School Districts:
Arlington Elementary School District & Buckeye Union High School District
Fire:
Arizona Fire & Medical Authority (AFMA) & Harquahala Fire District
Police:
Maricopa County Sheriff’s Office (MCSO)
Right-of-Way:
7.
The following table includes the existing and proposed half-widths for the rights-of-way through
and adjacent to the project area, as well as the future classifications for the corresponding
roadways, based upon the Maricopa County Department of Transportation (MCDOT)
Transportation System Plan 2040 and Road Information Tool.
Street Name
Half-width Existing R/W
Half-width Proposed R/W
Future Classification
Indian School Road
65’
65’
Principal Arterial
Salome Highway
65’
65’
Principal Arterial
Z250045
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Adopted Plan:
8.
Tonopah / Arlington Area Plan and Vision 2030 Maricopa County Comprehensive Plan (adopted
September 2000 and January 2016, respectively): The project area, which includes land both
within and outside the Tonopah / Arlington Area Plan, was subject to two major CPAs, per cases
CPA2019004 and CPA2019012, to change the land use designation in both plans to “utilities” in
anticipation of the solar energy generation and storage facility now under construction. The Board
of Supervisors approved CPA2019004 on December 11, 2019, and approved CPA2019012 on
January 15, 2020.
Public Participation Summary:
9.
The applicant complied with the requirements of the citizen review process by posting the site
and sending notification by first class mail to interested parties and adjacent property owners
within 300’ of the site. Ten signs were posted along Indian School Road and Salome Highway –
one for each quarter mile of frontage along MCDOT-maintained rights-of-way through the project
area boundaries – in accordance with applicable regulations. Luke Air Force Base (LAFB)
confirmed that the project will not impact its operations. LAFB did confirm, however, that any
structures for this development are subject to the results of an FAA Obstruction Evaluation /
Airport Airspace Analysis and Spectrum Analysis (OE/AAA), and that LAFB reserves the right to
comment as the development matures and amended plans become available. Furthermore, LAFB
requested that the project be submitted for an informal review through the DoD Siting
Clearinghouse for Energy, Installations, and the Environment, and that LAFB’s response is
conditional upon their approval/input.
Outstanding Concerns from Reviewing Agencies:
10.
N/A
Staff Analysis:
11.
Staff supports the applicant’s request for a modification of conditions to the IND-2 IUPD zoning
district. Allowing an increase to the maximum allowed height of the electric transmission lines
within the project area will not have a measurable impact on nearby land uses, all of which are
either undisturbed desert or also developed for utilities (including the APS Delaney Substation).
Furthermore, the area in which the RE Papago project is located (generally west of Saddle
Mountain and east of the Maricopa – La Paz County line) is increasingly being entitled and
developed for similar solar energy generation and storage facilities, as well as the transmission
line infrastructure necessary to support said projects. The modification requested to support the
RE Papago project as its final design progresses will not diminish the project’s suitability for its
location. As documented in the original report to the Planning & Zoning Commission for
Z2019121, the subject solar facility is well suited to the surrounding rural area, which features
large expanses of flat, open land, as well as existing infrastructure such as transmission lines,
stations, and substations that are necessary to support a large utility-scale solar facility.
12.
In addition to the modified transmission line height proposed per condition ‘d.1,’ staff proposes
modifications to conditions ‘a’ and ‘b’ to reflect the changes to the project narrative and site plan
since the original zone change was approved. Both conditions required that the applicant submit
revised documents within 30 days of the Board’s approval of the original zone change to reflect
substantial conformance with condition ‘d.4.’ These revised documents were received and
Z250045
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stamped approved, so staff proposes modifying both conditions to reference the updated
documents. Although no site plan was submitted or necessary for this request, staff proposes
further amending condition ‘a’ to reference the most recent site plan approved for the project,
which is the amended plan of development that staff approved administratively on October 3,
2024, per case PD240006. Likewise, staff proposes further amending condition ‘b’ to reference
the most recent narrative report for the project, which the applicant submitted with this
application.
13.
The full list of proposed modifications is provided as follows:
a.
The initial Plan of Development site shall be developed in substantial conformance with
the Site Plan entitled “RE Papago Solar Photovoltaic Power and Energy Storage Project”
consisting of 32 full-size sheets, dated June 15 October 11, 2021, and stamped received
July 7 approved in substantial conformance October 25, 2021, except that a revised site
plan shall be submitted within 30 days of Board approval that reflects compliance with
condition ‘d.4.” as it pertains to maximum lot coverage.; and with the amended Site Plan
entitled “RE Papago Photovoltaic Solar Energy Generation and Storage Project,”
consisting of 22 full-size sheets, dated September 25, 2024, and stamped approved
October 3, 2024; except as further modified by the following conditions.
b.
Development of the site shall be in substantial conformance with the Narrative Report
entitled “Zone Change Narrative”, consisting of 22 pages, dated July 6 September 2, 2021,
and stamped received July 6 approved in substantial conformance October 4, 2021
except as modified by the following conditions except that a revised narrative shall be
submitted within 30 days of Board approval that reflects compliance with condition ‘d.4.”
as it pertains to maximum lot coverage.; and with the modified Narrative Report entitled
“Request for Modification of Conditions to Zone Change Z2019121,” consisting of 25
pages, dated December 18, 2025, and stamped received March 30, 2026; except as
further modified by the following conditions.
d.
The following IND-2 IUPD Zoning District standards shall apply:
1.
Maximum Electric Transmission Line Height – 140’ 170’
2.
Minimum Side Yard – 0’
3.
Minimum Rear Yard – 0’
4.
Maximum Lot Coverage – 60%
5.
Parking Spaces Required – None required with a Maricopa County Air Quality
Department approved dust control plan. High curb and/or bumper guards not
required.
6.
Landscaping – No landscaping areas required
7.
Sight Visibility Triangles – No sight visibility triangles are required at project site
entry/access points and road intersection, section line, mid-section line or
alignment corners
8.
Article 902.91 – All utility uses shall be permitted to be conducted outdoors
Z250045
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9.
Site Enclosure and Screening – 6’ chain-link fencing with 1’ of barbed wire
permitted
Recommendation:
14.
Staff recommends the Commission adopt a motion recommending that the Board of Supervisors
approve Z250045 subject to the following conditions ‘a’ – ‘i’:
a.
The site shall be developed in substantial conformance with the Site Plan entitled “RE
Papago Solar Photovoltaic Power and Energy Storage Project” consisting of 32 full-size
sheets, dated October 11, 2021, and stamped approved in substantial conformance
October 25, 2021; and with the amended Site Plan entitled “RE Papago Photovoltaic Solar
Energy Generation and Storage Project,” consisting of 22 full-size sheets, dated
September 25, 2024, and stamped approved October 3, 2024; except as further modified
by the following conditions.
b.
Development of the site shall be in substantial conformance with the Narrative Report
entitled “Zone Change Narrative”, consisting of 22 pages, dated September 2, 2021, and
stamped approved in substantial conformance October 4, 2021; and with the modified
Narrative Report entitled “Request for Modification of Conditions to Zone Change
Z2019121,” consisting of 25 pages, dated December 18, 2025, and stamped received
March 30, 2026; except as further modified by the following conditions.
c.
The following Planning Engineering conditions shall apply:
1.
Drainage Waiver case DRB2021005 must be approved prior to issuance of building
permits.
2.
Detailed Grading and Drainage Plans showing the new site improvements must be
submitted for the acquisition of building permits. On-site (solar field & substation)
areas Page 2 of 4 must be designed in such a manner so that flows are directed
to retention basin(s). Basin overflows must be directed to well-defined drainage
corridors, to the maximum extent possible.
3.
Owner or owner’s agent shall be responsible for identifying and procuring any
permit(s) for disturbance of, or work within delineated jurisdictional (Section 404)
washes.
4.
Sizing of the basin spillways must be determined based on the peak unattenuated
flow rate, based on the proposed site condition, using either the Rational Method
or DDMSW. Where the retention areas will be comingled with offsite flows, the
offsite flows must be included in the discharge rate.
5.
As part of the final design, channelized flow may be required to be dissipated
(spread) at their outflow locations to match existing downstream conditions.
6.
Drainage review of planning and/or zoning cases is for conceptual design only and
does not represent final design approval nor shall it entitle applicants to future
designs that are not in conformance with Section 1205 of the Maricopa County
Zoning Ordinance and the Maricopa County Drainage Policies and Standards. All
Z250045
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development and engineering design shall be in conformance with Section 1205
of the Maricopa County Zoning Ordinance and current engineering policies,
standards and best practices at the time of application for construction.
7.
Any disturbance to Special Flood Hazard Areas (floodplains) will require that a
Floodplain Use Permit be issued concurrent with the associated building permit.
8.
Pads for inverters, other electrical equipment, and any buildings within a
Floodplain must be elevated to the regulatory flood elevation or otherwise
designed to meet the requirements of the Floodplain Use Regulations. All
development and engineering design shall be in conformance with the most
current version of the Floodplain Use Regulations for Maricopa County.
9.
Project improvements (i.e. electric lines) within and immediately adjacent to
District owned properties require a Right-of-Way Permit from the Flood Control
District.
10.
Future right-of-way needs, dedication, preservation, and offsite improvements,
shall be addressed during site plan and/or building permit review, with the
submittal of a traffic impact study, prior to any approvals.
11.
Driveway accesses to paved MCDOT right-of-ways must be paved for the full width
of the right-of-way.
d.
The following IND-2 IUPD Zoning District standards shall apply:
1.
Maximum Electric Transmission Line Height – 170’
2.
Minimum Side Yard – 0’
3.
Minimum Rear Yard – 0’
4.
Maximum Lot Coverage – 60%
5.
Parking Spaces Required – None required with a Maricopa County Air Quality
Department approved dust control plan. High curb and/or bumper guards not
required.
6.
Landscaping – No landscaping areas required
7.
Sight Visibility Triangles – No sight visibility triangles are required at project site
entry/access points and road intersection, section line, mid-section line or
alignment corners
8.
Article 902.91 – All utility uses shall be permitted to be conducted outdoors
9.
Site Enclosure and Screening – 6’ chain-link fencing with 1’ of barbed wire
permitted
e.
The Owner or Developer shall address and respond to all recommendations of the Arizona
Game and Fish Department (AZGFD) included in the letter dated May 26, 2021 at the time
Z250045
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of construction permitting. The response shall be sent to AZGFD for review and
consideration. The Zoning Inspector and/or their designee shall review the applicant’s
response, and any subsequent comments received from AZGFD, to determine whether the
response issued by the Owner or Developer addresses AZGFD comments in good faith.
Should the Zoning Inspector and/or their designee decide that the Owner or Developer has
not substantially addressed AZGFD comments in good faith, the Owner or Developer shall
be required to propose and implement alternatives to the recommendations made by
AZGFD.
f.
The IND-2 IUPD shall limit the use of the site exclusively to a solar electric generating
facility including ancillary offices and ancillary uses. All other site uses shall require a Zone
Change Major Amendment.
g.
Noncompliance with any Maricopa County Regulation shall be grounds for initiating a
revocation of this Zone Change as set forth in the Maricopa County Zoning Ordinance.
h.
The property owner/s and their successors waive claim for diminution in value if the
County takes action to rescind approval due to noncompliance with conditions.
i.
The granting of this change in use of the property has been at the request of the applicant,
with the consent of the landowner. The granting of this approval allows the property to
enjoy uses in excess of those permitted by the zoning existing on the date of application,
subject to conditions. In the event of the failure to comply with any condition, and at the
time of expiration of the Zone Change, the property shall revert to the zoning that existed
on the date of application. It is, therefore, stipulated and agreed that either revocation due
to the failure to comply with any conditions, or the expiration of the Zone Change, does
not reduce any rights that existed on the date of application to use, divide, sell or possess
the property and that there would be no diminution in value of the property from the value
it held on the date of application due to such revocation or expiration of the Special Use
Permit. The Zone Change enhances the value of the property above its value as of the date
the Zone Change is granted and reverting to the prior zoning results in the same value of
the property as if the Zone Change had never been granted.
Presented by:
Nick Schlimm, Planner
Reviewed by:
Rachel Applegate, Planning Supervisor
Attachments:
Case Map (1 page)
Site Plan Approved per Case PD240006 (22 pages)
Narrative Report (25 pages)
DPR comments (2 pages)
MCDOT-approved TIS (4 pages)
Luke AFB comments (2 pages)
/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 1,276 approx.
Generated March 12, 2026 8:55 AM
Z250045
Application Name:
Legal Description
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Applicant
Case Address
2N 8W 26, 2N 8W 24, 2N 8W 25, 2N 8W 14, 2N 8W 13
Latigo BESS
45558 W SALOME HWY
Applicant Phone/Email
Parcel Primary:506-31-006E
(512) 240-9107
TONOPAH, AZ 85354
Map scale 1:32,694
Supervisor District No.
In this request for a Modification of Conditions to the Zone Change, the applicant is requesting an
increase in the Maximum Allowed Electrical Transmission Line Structure Height to 170ft from the
130.00
22
15
14
13
12
23
24
19
27
26
30
25
SALOME HWY
(GRAVEL)
INDIAN SCHOOL RD
(GRAVEL)
RANGE 8 WEST
RANGE 7 WEST
FEMA FLOOD ZONE A
X
VICINITY MAP
RE PAPAGO PHOTOVOLTAIC SOLAR ENERGY
GENERATION AND STORAGE PROJECT
(MINOR AMENDMENT CASE #PD2024006)
Located in a portion of Township 2 North, Range 8 West of the Gila and Salt River Base and Meridian, Maricopa County, Arizona
A subsidiary of Canadian Solar
September 26, 2024
10/03/2024 - PD240006
Approved Subject to
Condition "a" - Staff
A subsidiary of Canadian Solar
A subsidiary of Canadian Solar
A subsidiary of Canadian Solar
65.00
65.00
65.00
40.00
40.00
130.00
A subsidiary of Canadian Solar
65.00
65.00
65.00
40.00
40.00
130.00
A subsidiary of Canadian Solar
65.00
65.00
65.00
40.00
40.00
130.00
22
FEMA FLOOD ZONE A
INDIAN SCHOOL RD (GRAVEL)
15
14
13
12
23
24
19
27
26
30
31
34
NAP
NAP
NAP
25
CAMPBELL AVE
467TH AVE
459TH AVE
PAPAGO FWY (INTERSTATE 10)
A subsidiary of Canadian Solar
22
FEMA FLOOD ZONE A
INDIAN SCHOOL RD (GRAVEL)
15
14
13
23
24
27
26
NAP
NAP
NAP
NAP
25
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467TH AVE
459TH AVE
WY (INTERSTATE 10)
X
FZ
>
>
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A subsidiary of Canadian Solar
A subsidiary of Canadian Solar
A subsidiary of Canadian Solar
NAP
NAP
NAP
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MV 15B
MV 15B
MV 24B
MV 24B
MV 24B
MV 24B
MV 23B
MV 23B
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REQUEST FOR MODIFICATION OF CONDITIONS TO ZONE CHANGE
Z2019121
RE
Papago
Photovoltaic Solar Energy Generation and Storage
Project
Maricopa County Planning and Development Department
Zone Change with Industrial Overlay Plan of Development
Original Zone Change (Z2019121) Approved September 1, 2021
Minor Amendment No. 1 to the Plan of Development (Z2023086) Approved February 20, 2024
Minor Amendment No. 2 to the Plan of Development (PD240006): Approved October 03, 2024
Modification of Conditions to an Approved Zone Change (Z250045): Application Submitted December 18,
2025
Z250045
March 30, 2026
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page i
TABLE OF CONTENTS
1.0
Title Page ................................................................................................................................... 1
1.1
General Location ....................................................................................................................... 1
2.0
Purpose of Request .................................................................................................................... 3
3.0
Description of Proposal ............................................................................................................ 3
3.1
Overview ................................................................................................................................... 3
3.2
Proposed Uses ........................................................................................................................... 4
3.3
Hours of Operations .................................................................................................................. 4
3.4
Project Components .................................................................................................................. 4
3.4.1
Preconstruction Activities and Site Preparation ................................................................. 4
3.4.2
Permanent Project Site Entrances and Internal Roads ...................................................... 5
3.4.3
PV Modules and Support System ...................................................................................... 5
3.4.4
Electric (34.5-kV) Collection Lines .................................................................................. 6
3.4.5
Inverters and Transformers ................................................................................................ 7
3.4.6
Project Substation and Gen-tie .......................................................................................... 7
3.4.7
Energy Storage System...................................................................................................... 8
3.4.8
Construction Schedule and Workforce .............................................................................. 9
3.4.9
Construction Access, Equipment, and Traffic ................................................................ 10
3.4.10
Personnel Training ........................................................................................................... 10
3.4.11
Perimeter Fencing and Gates ........................................................................................... 11
3.4.12
Site Security and Outdoor Lighting ................................................................................. 11
3.4.13
Permanent Buildings ....................................................................................................... 11
3.4.14
On-site Drainage Areas .................................................................................................... 12
3.4.15
Operation and Maintenance ............................................................................................. 13
3.4.16
Water Requirements ........................................................................................................ 14
3.5
Decommissioning and Site Reclamation ................................................................................ 15
3.5.1
Decommissioning of Facilities ......................................................................................... 15
3.5.2
Site Reclamation ............................................................................................................. 15
4.0
Relationship to Surrounding Parcels ........................................................................................ 16
4.1
Project Site Parcels .................................................................................................................. 16
4.2
Surrounding Parcels ................................................................................................................ 17
4.3
Benefits to the Community and Surrounding Area .................................................................. 17
4.3.1
Economic Benefits........................................................................................................... 17
4.3.2
Environmental Benefits ................................................................................................... 17
4.4
Recent Changes in the Area that Support the Application Request ......................................... 18
5.0
Location and Accessibility ...................................................................................................... 18
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page ii
5.1
Project Location ...................................................................................................................... 18
5.2
Accessibility ............................................................................................................................ 18
6.0
Circulation System .................................................................................................................. 19
6.1
On-Site .................................................................................................................................... 19
6.2
Off-Site .................................................................................................................................... 19
7.0
Development Schedule ........................................................................................................... 20
8.0
Community Facilities and Services ......................................................................................... 20
9.0
Public Utilities and Services ................................................................................................... 20
10.0
Comparison Chart ................................................................................................................... 21
LIST OF TABLES
Table 1 Project Site Parcels ........................................................................................................................ 16
Table 2 RE Papago Solar Project: Utility Commitments ............................................................................ 20
Table 3 RE Papago Solar Project Unit Plan of Development: Proposed Zoning Regulations ................... 21
LIST OF FIGURES
Figure 1. Project Vicinity ............................................................................................................................ 2
Figure 2. Artistic rendering of the AC-coupled/centralized energy storage system. ................................... 8
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 1
1.0
TITLE PAGE
Project Name: RE Papago Photovoltaic Solar Energy Generation and Storage Project
Related Case #s: Z2019121, Z2023086, PD240006
1.1
General Location
The project site is located in the western region of unincorporated Maricopa County, south of Interstate 10
(I-10) and approximately 5.5 miles west of the community of Tonopah, Arizona. The project site is about
55 miles west of Phoenix, Arizona.
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 2
Figure 1. Project Vicinity
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 3
2.0 PURPOSE OF REQUEST
On September 1, 2021, the Maricopa Board of Supervisors approved RE Papago LLC’s Zone Change with
Overlay application (Z2019121) to construct, operate, maintain, and eventually decommission a solar
photovoltaic (PV) electricity-generating and energy storage facility and associated infrastructure
collectively referred to as the RE Papago Photovoltaic Solar Energy Generation and Storage Project
(project). The project’s as approved Plan of Development allows for construction of an energy facility that
would generate 300 megawatts (MW) of alternating current (AC) electricity and provide up to 1,200
megawatt-hours (MWh) of energy storage on approximately 2,805.23 acres of privately owned land in
unincorporated Maricopa County. The approved zoning designation is IND-2 with an Industrial Unit Plan
of Development (IUPD).
On February 20, 2024, Maricopa County approved a Minor Amendment to the Plan of Development
(Z2023086) to allow for modifications necessary to construct Phase 1 of the project. Phase 1 consists of
construction and operation of the battery energy storage system (BESS) portion of the previously approved
project (Phase 1/BESS) on a land parcel (APN: 506-31-006E) that is approximately 120 acres within the
project site and which borders the existing Delaney Substation (APN: 506-31-006D).
On October 3, 2025, Maricopa County approved a Minor Amendment to the Plan of Development
(PD240006) to allow for modifications necessary to construct Phase 2 of the project. Phase 2 consists of
construction and operation of the solar photovoltaic system (PV) portion of the previously approved project
on the following parcels:
506-31-001
506-31-002
506-31-005A
506-31-006F
506-31-007G
506-31-010G
506-31-010H
506-31-010J
506-31-010K
506-31-010L
506-31-059A
This minor amendment reduced the generation of Phase 2/PV from the previously approved 300 megawatts
to 150 megawatts and reduced the project footprint by approximately 1525 acres.
In this request for a Modification of Conditions to the Zone Change, the applicant is requesting an increase
in the Maximum Allowed Electrical Transmission Line Structure Height to 170 feet from the previously
approved 140 feet height limit. This is to support a future Phase 3/BESS for which the applicant will submit
another Minor Amendment to the Plan of Development in the future. The increase is required to safely
cross the existing transmission line supporting Phase 2/PV with a new transmission line to support Phase
3/BESS.
3.0
DESCRIPTION OF PROPOSAL
3.1
Overview
The proposed overall project would consist of the following development activities:
•
Two phases of project construction; Phase 1/BESS and Phase 2/PV
•
Site preparation, including mowing/removal of vegetation and grading (as necessary)
•
Installation of PV solar arrays, including approximately 300,000PV modules, and steel support
structures, transformers, and up to 50 electrical inverters
•
Installation of approximately 19,000 feet of underground 34.5-kilovolt (kV) electric collection lines
to connect parts of the site to the project substations
•
Construction of two electrical substations, one for each project phase and appurtenant equipment
in the southeast portion of the site as shown on Sheet C2.3 of the Site Plan
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 4
•
Construction of two 500-kV generation intertie electric transmission lines (gen-tie lines) for a total
combined length of less than 0.5 mile consisting of metal transmission towers, conductors,
insulators, optical fiber cables, and safety equipment. The gen-tie line from the Phase 1/BESS
Substation to Arizona Public Service's Delaney Substation would be 500ft and completed as part
of Phase 1 of construction. The gen-tie line from the Phase 2/PV Substation to the Phase 1/BESS
substation would be 0.3 miles and completed as part of Phase 2/PV.
•
For Phase 1/BESS, Installation of an energy storage system at size up to 1,200 MWh, consisting of
batteries or enclosures and electrical cabling and appurtenant equipment. Up to 360 battery
containers would be installed
•
Construction of temporary and permanent project site perimeter fencing and access gates
•
Construction of temporary and permanent on-site access roads for construction and maintenance
activities
•
Construction of other necessary infrastructure, including two permanent operation and maintenance
buildings/first responder stations (O&M building/FRS), two supervisory control and data
acquisition (SCADA) systems, and two meteorological data systems (one for each phase)
3.2
Proposed Uses
The project would be constructed to provide clean and efficient renewable energy to the regional electric
grid. The project would generate up to 150 MW of AC electricity and provide up to 1,200 MWh of energy
storage. The project is compatible with nearby land uses as it is located adjacent to the Delaney Substation,
multiple existing high-voltage electric utility lines, and the corridor for the newly constructed and in-service
Ten West Link high-voltage electric transmission line. Ten West Link has secured easement for a 500-kV
Transmission Line to interconnect into Delaney Substation. Third-party access to Delaney for the purpose
of interconnection at 500 kV has been granted. Electricity produced from this project would provide clean
energy for up to approximately 28,500 homes.
3.3
Hours of Operations
Once operational, project solar generation would occur during daylight hours. During the longest days of
the year, this would be from 5:30 am to 8:00 pm. With an energy storage system, stored electricity would
also be transmitted to the grid at other times when needed. O&M activities would occur during the lifetime
of the project and would include occasional cleaning of PV modules and replacement/repair of project
equipment and components as needed. These activities would typically occur during normal daytime
business hours between 7:00 am and 5:00 pm.
3.4
Project Components
Below is a description of the individual project components.
3.4.1
Preconstruction Activities and Site Preparation
Preconstruction activities include surveying and staking for various project features such as driveways,
array blocks, utility trenches, equipment pads, and support structures. Temporary work areas would also be
laid out.
Site preparation activities that occur prior to general construction include site clearing and grading,
preparation of construction staging areas, and construction of the main internal driveways.
3.4.1.1
Clearing and Grading
Prior to construction, the site would be cleared of vegetation and graded and compacted to the minimum
extent needed. Site clearing and soil preparation would occur incrementally and would not commence until
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the area is needed for construction or equipment access. Vegetative cover would be retained for as long as
possible, with overall ground disturbance minimized to extent practicable.
Large areas of the site would undergo grading for the installation of drainage basins and related structures.
Final grades would be designed to provide for positive drainage, as described in On-site Drainage Areas
below (3.4.14).
3.4.1.2
Construction Staging Areas
One or two main staging areas would be located within the site footprint and would likely be located in the
northwest or southwest portions of the site. For the Phase 1/BESS and Phase 2/PV construction, staging
areas would be north of the construction area, within the Phase 1/BESS parcel (Sheet C2.4). The staging
area or areas would be used for construction offices, worker parking, a first-aid station, material and
equipment storage and assembly, and a parking area for vehicles and equipment. Additional staging areas
may be located throughout the site for temporary material storage and assembly during construction. The
staging areas would encompass up to 10 acres and would be secured with an 8-foot-high fence. As needed,
temporary power would be provided via mobile generators or local distribution lines.
3.4.1.3
Temporary Roads and Driveways
Temporary roads and driveways would be built for use during construction; some of these roads and
driveways would be established as permanent features prior to the start of project operation. Temporary
driveway aprons to points of ingress/egress during construction may be up to 80 feet wide to accommodate
construction traffic.
3.4.2
Permanent Project Site Entrances and Internal Roads
The project’s on-site circulation would include project entrances and internal roads. Roads would be
compacted, may include gravel or equivalent, and would be designed according to Maricopa County
standards, rules, and guidance. Road construction would typically proceed as follows: the ground would
be grubbed (cleared of vegetation), scarified (loosened), moisture conditioned, compacted, and graded with
a crown in the center.
All roads would be constructed to be consistent with facility maintenance requirements and Arizona Fire
and Medical Authority standards, the standards of the Harquahala Fire District (HFD), and/or any other
applicable standards.
Any required road improvements would be developed in coordination with the Maricopa County
Department of Transportation (MCDOT) and would be subject to MCDOT requirements, as well as all
applicable requirements of the Maricopa County Air Quality Department, the Maricopa County Flood
Control District (FCD), and the Maricopa County Planning and Development Department.
3.4.3
PV Modules and Support System
Most of the Phase 2/PV project site area would be occupied by solar PV modules and support structures. The
ultimate decision for the module types and racking systems would depend on market conditions and
environmental factors. Solar thermal technology is not being considered.
Types of modules that may be installed include crystalline silicon (abbreviated as c-Si), amorphous silicon
(abbreviated as a-Si), thin-film (including cadmium telluride [abbreviated as CdTe or cad tel] and copper
indium gallium diselenide technologies [abbreviated as CIGS]), or any other commercially available PV
technology. Module mounting systems that may be installed are likely to include tracking technology but
could be fixed tilt depending on the PV modules ultimately selected. Multiple types of modules and racking
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systems may be installed across the site.
The PV modules would be manufactured at an off-site location and transported to the project site. Module
faces would be minimally reflective, dark in color, and highly absorptive.
Modules would be arranged on-site in long strings called rows. For single-axis tracking systems, the length
of each row of modules would be approximately 300 feet along the north/south axis. For fixed-tilt systems, a
row consists of multiple tables (4 modules high by 10 modules wide, depending on design), each table
approximately 65 feet along the east/west axis, with 1-foot spacing between each table. Spacing between
each row would be a minimum of 14 feet. The solar module arrays would generate electricity directly from
sunlight, and electricity would be collected to a single point at the project substation.
Structures supporting the PV modules would consist of steel piles (e.g., cylindrical pipes, H-beams, or
similar). Tracking arrays would be oriented along a north-south axis, with modules tracking east to west to
follow the movement of the sun. Fixed-tilt arrays would be oriented along an east-west axis, with modules
facing generally south. The total height of the module system measured from ground surface would be up
to 12 feet. For fixed-tilt systems, the modules would be fixed at an approximate 20- to 60-degree angle or
as otherwise determined necessary during final project design. Details in Sheet C3.0 of the Site Plan show
typical elevation drawings of solar panels and tracking systems.
Where excavations are required, the majority of proposed construction activities would be limited to less
than 6 feet in depth; however, some excavations, such as those undertaken for the installation of electricity
collection poles and dead-end structures, may reach depths of 20 feet or more.
3.4.3.1
Solar PV System Installation
Prior to the installation of solar arrays, the perimeter of each project area would be securely fenced and
gated to prevent unauthorized access. Perimeter fencing would consist of 6-foot-high chain-link galvanized
metal fence topped by 3 strands of barbed wire approximately 1 foot high. Fence posts would be spaced
approximately 10 feet apart, drilled and grouted or driven pneumatically into the soil profile up to an
estimated 5 feet deep.
Construction of the solar arrays would begin with installation of the steel piles (e.g., cylindrical pipes, H-
beams, or similar), which would be driven into the soil using pneumatic techniques, similar to a hydraulic
rock hammer attachment on the boom of a rubber-tired backhoe excavator. The piles would typically be
spaced 10 feet apart. For a single-axis tracking system, piles typically would be installed to a reveal height
of approximately 4 feet above grade, while for a fixed-tilt system the reveal height would vary based on the
racking configuration specified in the final design. For some single-axis tracking systems and for all fixed- tilt
systems, a galvanized metal racking system, which secures the PV modules to the installed foundations,
would then be field-assembled and attached according to the manufacturer’s guidelines.
Modules would be electrically connected into module strings using wiring secured to the module racking
system. Underground cables, either rated for direct bury or installed inside a polyvinyl chloride (PVC)
conduit, would convey the direct current (DC) electricity from the modules via combiner boxes located
throughout the PV arrays to inverters to convert the DC power to AC. The output voltage of the inverters
would be stepped up to 34.5 kV, the collection system voltage, via transformers located in close proximity
to the inverters.
3.4.4
Electric (34.5-kV) Collection Lines
The 34.5-kV collection cables would be buried underground. Underground collection line cables to connect
arrays would be installed using ordinary trenching techniques, which typically include a rubber-tired
backhoe excavator or trencher. Wire depths would be in accordance with local, state, and federal
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requirements and would likely be buried at a minimum of 18 inches below grade by excavating a trench
approximately 3 to 6 feet wide to accommodate the conduits or direct buried cables. After excavation, cable
rated for direct burial or cables installed inside a PVC conduit would be installed in the trench, and the
excavated soil would likely be used to fill the trench and lightly compressed. All cabling excavations would
be to a maximum depth of 10 feet.
3.4.5
Inverters and Transformers
The project would be designed and laid out in approximately 2-MW increments, which would include an
inverter equipment area measuring approximately 40 feet by 25 feet. Up to 50 inverters would be installed.
Each 2-MW increment would include an inverter-transformer station constructed on a concrete pad or steel
skid and centrally located within the PV arrays. Each inverter-transformer station would contain a DC
combiner (which would collect DC electrical power from the PV modules), up to 4 inverters, a transformer,
an auxiliary power transformer, and a switchboard approximately 8 to 11 feet high. Refer to Sheet C3.5 of
the Site Plan for a typical inverter-transformer station.
All electrical inverters and transformers would be placed on concrete foundation structures or steel skids.
In lieu of steel skids or pre-cast concrete foundations, foundations for the transformer and inverter locations
would be formed with plywood and reinforced with structural rebar and would use poured-in-place
concrete.
3.4.6
Project Substation and Gen-tie
The project would also include two electrical substations, which would receive electricity from consolidated
medium-voltage cables from the collection system and step the voltage up to 500 kV via 1 or 2 high-voltage
transformer banks consisting of up to 4 individual transformers as well as switchgear and related substation
facilities. Each substation area would include an electrical control building. A conceptual elevation of the
control building enclosure is shown in Sheet C3.6 of the Site Plan. The substations would be located in the
southeastern portion of the site near the Delaney substation, as shown on Sheets C2.3 and C2.4.
The project’s generator intertie electric transmission line or “gen-tie line” would then transmit the power at
a voltage of 500 kV from the project substation to the project point of interconnection at Delaney Substation.
The gen-tie lines would be supported by up to four high-voltage support structures consisting of a
combination of A-frame dead-end structures and either H-frames, monopoles, or three-poles. The number
of support structures would be kept to the minimum needed based on potential engineering constraints. The
Phase 1/BESS gen-tie line route would run straight east-west. The Phase 2/PV gen-tie line route would run
north-south, turning east-west to meet the Phase 1/BESS substation. The support structures were previously
anticipated to be approximately 126 feet in height but not more than 140 feet in height. As part of the
original zone change approved on September 1, 2019 (Z2019121), applicant sought and received approval
for a variance to the county requirement stating that structures to support electric transmission lines observe
a maximum height of 120 feet (Article 1111.7 of the Maricopa County Zoning Ordinance). Applicant is
now seeking a second variance to increase the height to 170 feet alongside its requested Modification of
Conditions to the Zone Change. This variance is also described in Table 3 (RE Papago Solar Project Unit
Plan of Development: Proposed Zoning Regulations) at the end of this Narrative.
Telecommunications infrastructure at the project substation would include the installation of an antenna and
may include the installation of a telecommunications tower up to 100 feet high.
3.4.6.1
Installation of Substations and Gen-Tie Lines
The substation areas would be graded and compacted to an approximately level grade. Concrete pads would
be constructed on-site as foundations for substation equipment, and the remaining area would be graveled
to a maximum depth of approximately 6 inches. The substation would be surrounded by an up-to-8-foot-
high chain-link fence topped with one foot of barbed wire.
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For the gen-tie line connections, overhead structure foundations would be installed by excavating
foundation holes to a depth of approximately 35 feet using a truck-mounted drill rig. The size of the footprint
for construction of the pole foundation would be approximately 100 square feet. Poles/support structures
would be delivered on a flat-bed trailer and hoisted into place by a crane. The annular space between poles
and holes would be backfilled with concrete or soil. Conductors would be strung between poles with heavy-
duty trucks.
3.4.7
Energy Storage System
Phase 1 of the project would include a battery storage system capable of storing up to 1,200 MWh of
electricity and conducting energy to the regional electricity grid. The storage system would consist of
batteries housed in electrical enclosures and buried electrical conduit. The project would use commercially
available energy storage technology. Options could include but would not be limited to lithium-ion (Li-ion)
batteries, lithium-iron phosphate batteries, flow batteries, or sodium sulfur batteries. Battery systems are
operationally silent (except for noise that could be generated by heating, ventilation, and air conditioning
[HVAC] systems that may be required). Standard HVAC systems have a noise rating ranging from 60 to
68 dBA.
The energy storage system would be concentrated in one location on the site and may ultimately be
connected to the PV array.
For the AC-coupled system, energy storage containers will include an HVAC system and monitoring,
controls, and operational management systems that will maintain normal battery operation and provide
alerts in the case of malfunction. Energy storage containers with related equipment would be grouped
together in one area of the site. The energy storage system would not be housed in a building.. Figure 2
shows the conceptual renderings of the potential appearance of a centralized storage system.
Figure 2. Artistic rendering of the AC-coupled/centralized energy storage system.
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The energy storage system monitoring, controls, and operational management systems may connect to the
overall solar facility management system and use sensors to monitor the performance of the energy storage
system, detect malfunctions or conditions requiring maintenance, and provide plant operators with
notification of these conditions in real time. Li-ion or lithium-iron phosphate battery system containers will
include internal fire suppression systems, and/or a fire suppression system will be installed on the site, as
required. Flow battery containers would include secondary containment, as necessary, for circulating fluid
systems.
Energy from the storage system would be conducted directly to the grid. With the use of bi-directional
inverters with electricity backflow preventers, the energy storage systems could also be charged by the
electrical grid (as well as being charged by the PV modules) and therefore provide grid support.
3.4.7.1
Energy Storage System Installation
Construction of the energy storage systems would include 1) site preparation; 2) installation of the
foundations, structures, and systems; and 3) installation of the inverters, substation, and connection.
The energy storage equipment, including battery storage containers on concrete foundations, power
conversion equipment, and electrical collection, would be concentrated in a single location near the project
substation, as shown on Sheet C2.4 of the Site Plan. The total area of an AC-coupled system would be
approximately 19 acres. The site would be cleared and graded prior to installation. The energy storage
system would be largely assembled off-site and delivered to the project site for final installation. Heavy
trucks and other equipment would be used to deliver and install the infrastructure and battery enclosures.
After a system is installed, it would be tested and commissioned.
The applicant plans to install the energy storage system as part of Phase 1/BESS of construction. Installation of
the PV arrays would take place during Phase 2/PV construction.
3.4.8
Construction Schedule and Workforce
Construction of the Phase 1/BESS was completed in Q2 2025. Phase 2/PV is currently under construction
with an anticipated completion date as early as Quarter 1 (Q1) of 2026. The applicant’s request is to support
a planned Phase 3/BESS, for which a Minor Amendment to a Plan of Development will be submitted. Phase
3/BESS’ schedule and workforce will be updated as part of that process. The completed and anticipated
construction processes, schedule, and workforce are further described in this section.
The majority of the labor force is expected to come from the surrounding communities with an average
round- trip commute of 130 miles, and a maximum round-trip commute of up to 170 miles. All workers are
expected to come from within Phoenix’s metropolitan area. There would be an estimated workforce of 240
to 500 full-time employees during construction of the entire project.
Construction equipment would generally operate between the hours of 7:00 a.m. and 7:00 p.m., Monday
through Friday, for up to a maximum of 8 hours per piece of equipment, daily. Weekend construction work
is not expected to be required, but may occur on occasion, depending on schedule considerations.
However, to meet schedule demands, it may be necessary to work early morning, evening, or nights and on
weekends during certain construction stages. Varying work hours can also improve the work environment
by allowing work to be completed during more favorable temperatures. For safety reasons, certain
construction tasks, including final electrical terminations, may be performed after dark when no electricity
is being produced by the PV modules. All construction work, including any weekend work, would
comply with the policies and requirements established by Maricopa County, including the Maricopa
County Noise Ordinance.
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3.4.9
Construction Access, Equipment, and Traffic
Access to the project site would be provided via I-10 (Exit 94), West Salome Highway, and West Indian
School Road.
All materials for the project’s construction would be delivered by truck. The majority of truck traffic would
occur on designated truck routes and major streets. Flatbed trailers and trucks would be used to transport
construction equipment and materials to the site. Project components would be assembled on-site. Traffic
resulting from construction activities would be temporary and could occur as workers and materials are
transported to and from the project site. Materials deliveries during construction would travel up to 85 miles
one way from the source to the project site.
Anticipated daily peak-hour vehicle trip volumes and equipment to be used for each construction phase are
presented in the project’s approved Traffic Impact Study. Typical equipment will include pickup trucks,
bulldozers, water trucks, and gravel trucks. Any required road improvements for construction activities
would be developed in coordination with MCDOT and would be subject to MCDOT requirements, as well
as all applicable requirements of the Maricopa County Air Quality Department, the Maricopa County FCD,
and the Maricopa County Planning and Development Department.
3.4.10 Personnel Training
3.4.10.1 Biological Resources
Prior to construction, a qualified biologist would be retained by the project applicant or construction
contractor to conduct environmental awareness training for project construction personnel. Such training
would communicate information related to the protection of sensitive biological resources that might be
present at the project site and would include:
•
A description of species of concern and associated habitats
•
The general provisions of applicable environmental regulations and the need to adhere to the
provisions of the regulations
•
General measures being implemented to conserve the species of concern as they relate to the project
•
A discussion of the defined access routes to the project site and project site boundaries within which
project activities must be accomplished
Construction employees would strictly limit their activities, vehicles, equipment, and construction materials
to the project footprint, designated staging areas, and routes of travel. The construction areas would be the
minimal area necessary to complete the project and would be specified in the construction plans.
Construction areas would be demarcated on-site, and employees would be instructed to limit activities to
these areas.
3.4.10.2 Cultural Resources
Prior to construction, a qualified archeologist would conduct a training program for construction personnel.
The training program would inform the construction personnel about the possibility of encountering buried
cultural resources and the proper procedures should cultural resources be encountered.
3.4.10.3 Fire Prevention, Suppression, and Safety Program
The project applicant would coordinate with the Arizona Fire and Medical Authority and/or Harquahala
HFD to provide training for personnel to safely interrupt electrical power in the event of emergency
incidents requiring fire suppression or rescue activities.
To minimize fire risk, combustible vegetation or agricultural products on and around the project site
boundary would be actively managed by the project owner or its affiliates. Combustible vegetation would
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either be limited in height or removed, consistent with fire-safe requirements and dust control standards of
the Maricopa County Air Quality Control District for solar electrical generation facilities.
The project applicant would also implement the following measures during project construction and
operation:
•
All applicable Maricopa County standards and requirements would be followed to ensure
accessibility and ground clearance of emergency vehicles (e.g., fire engines)
•
Smoking would be prohibited at the project site, except within designated areas
•
Work crews would be required to park vehicles away from flammable vegetation such as dry grass
and brush. At the end of each workday, heavy equipment would be required to be parked over
mineral soil, asphalt, or concrete, where available, to reduce the risk of fire
•
All heavy equipment would be required to include mechanisms for fire suppression, including spark
arresters or turbo-charging (which eliminates sparks in exhaust) and fire extinguishers
3.4.11 Perimeter Fencing and Gates
Perimeter fencing would be installed around the project site with gates located at key access points for both
the construction and O&M phases of the project. All fencing and gates would be installed according to the
specifications and requirements established by Maricopa County within the Maricopa County Zoning
Ordinance. Proposed locations of all fencing and gates are illustrated on figures within the Site Plan
provided as part of this application. Fencing and gates for the BESS have been adjusted to move gates away
from West Salome Highway and closer to the BESS yard and substation. Additionally, up to four gates
have been proposed on the North and East side of the BESS yard perimeter fencing for maintenance access
to drainage swales.
3.4.12 Site Security and Outdoor Lighting
Security cameras would be installed along the perimeter of the project site within the project footprint
and/or at the inverters. Cameras will be mounted on poles approximately 20 feet in height and will face
inward to monitor on-site activity.
Outdoor lighting shall comply with Section 1112 of the Zoning Ordinance and all other County standards,
regulations, and requirements. Lighting would be installed at the substation per utility requirements, along
perimeter fencing, at the facility entrances and interior gates, at the O&M Building/FRS facilities, at the
inverter and transformer equipment areas, and at the substations/switching stations. Exterior lighting would
be shielded and directed downward to minimize the potential for glare or spillover onto adjacent properties.
Lighting may be either motion activated or light sensitive to automatically come on in the evening and shut
off in the morning.
3.4.13 Permanent Buildings
Ancillary facilities such as the O&M Buildings/FRSs for the Phase 1/BESS and Phase 2/PV, septic system
and leach exterior lighting, signage, SCADA, telecommunications, and meteorological data collection
system may also be installed with the solar arrays.
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3.4.13.1 O&M Buildings and First Responder Stations
The battery energy storage system (Phase 1) would include an O&M Building/FRS to accommodate up
to 5 permanent O&M and first responder staff. First responder staff would be trained in emergency
response procedures. The building would be approximately 720 square feet in size (approximately 12
feet by 60 feet by 15 feet high at its tallest point) and located near the Phase 1/BESS substation for the
battery energy storage system, as shown on Sheet C2.4 of the Site Plan. The building would be
constructed on a concrete foundation and would include permanent plumbing and restroom facilities for
use by the staff.
The PV portion of the project (Phase 2) would also include an O&M Building/FRS to accommodate up to 5
permanent O&M and first responder staff. The building would be approximately 720 square feet in size
(approximately 12 feet by 60 feet by 15 feet high at its tallest point) and located near the Phase 2/PV project
substation. The O&M building/FRS would include permanent plumbing and restroom facilities for use by
the staff. Additional personnel occasionally on-site to perform periodic module washing (up to four times
per year) would be provided with portable restrooms on the project site as well as bottled water for drinking
and hand washing. The O&M building/FRS would be constructed on a concrete foundation.
3.4.13.2 Control Enclosures for Relay and SCADA Equipment
The project would include a comprehensive SCADA system to allow remote monitoring of facility
operation and/or remote control of critical components. The fiber optic or other cabling required for the
monitoring system typically would be installed in buried conduit leading to a SCADA system cabinet
centrally located within the project site or a series of appropriately located SCADA system cabinets
constructed within the O&M buildings. The dimensions of each cabinet would be approximately 20 feet
long by 8 feet wide by 9 feet high. External telecommunications connections to the SCADA system cabinets
could be provided through wireless or hard-wired connections to locally available commercial service
providers. The SCADA system would interconnect to a fiber optic network. Some trenching work may be
required to bury fiber optic cables, or such cables may be installed on overhead poles.
Through the SCADA system, operations staff would be on-call to respond to alerts generated by the
monitoring equipment at the project site and would analyze collected data on an ongoing basis to schedule
maintenance. Facility outputs and performance would be measured against forecast production to identify
equipment failure or abnormalities. Attributes that would be monitored include amount of energy generated,
equipment (for example, inverters and combiners) failure, and weather.
3.4.13.3 Septic System
Septic systems may be installed adjacent to the O&M Buildings/FRSs to support the restroom facilities and
sewage needs of permanent staff during operation. If a septic system is proposed, approval of septic system
plans will be sought from Maricopa County prior to building permit approval. 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. Anticipated peak flow is less than 300 gallons into the leach field per day during
project operation. No surface discharges are proposed, other than natural stormwater runoff.
3.4.14 On-site Drainage Areas
On-site drainage areas have been delineated, and retention basins are proposed in each to provide the
required storage to accommodate the runoff volume from the specified storm event (see Drainage Report).
Although none are currently proposed, if the final design contains retention basins with ponding depths
greater than 3 feet, these basins will be equipped with a perimeter fence. Final grading plans will specify the
location, elevation, and volume of each on-site retention basin. A combination of percolation and/or dry
wells may be used to drain the basins within 36 hours.
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Basins have been designed as berms, which will provide storage up gradient of the basins. Solar panels will
be located within the basin areas, elevated sufficiently to avoid the ponded water.
3.4.15 Operation and Maintenance
Upon commissioning, the project would enter the operation stage. The solar modules at the site would
operate during daylight hours 7 days per week, 365 days per year. The energy storage system would store
and dispatch power during both daylight and non-daylight hours as required by grid operators year-round.
Operational activities at the project site would include:
•
Solar module washing
•
Vegetation, weed, and pest management
•
Security
•
Responding to automated electronic alerts based on monitored data, including actual versus
expected tolerances for system output and other key performance metrics
•
Occasional equipment repair and replacement
•
Communicating with customers, transmission system operators, and other entities involved in
facility operations.
3.4.15.1 O&M Workforce
Up to 10 permanent staff could be on the site at any given time for ongoing facility maintenance and repairs.
The duration of scheduled maintenance activities would vary in accordance with the required task but could
involve up to 25 workers full time for up to 2 weeks up to 4 times a year for module washing and a similar
number and duration for workers regularly visiting the site for routine maintenance activities, including
maintenance of the energy storage system. On intermittent occasions, up to 40 workers could be remotely
dispatched to the site if repairs or replacement of equipment were needed in addition to module washing.
A record of inspections would be kept on-site. The maximum number of staff on-site at any time would be
75 (10 permanent staff and 65 temporary staff). The personnel and time required for emergency maintenance
would vary in accordance with the necessary response.
The operational labor force is expected to be from the Phoenix metropolitan area with a maximum
anticipated commute of 85 miles one way.
3.4.15.2 Site Maintenance
Project site maintenance would be largely conducted during daytime hours. Equipment repairs and
preventative maintenance could take place in the early morning or evening when the plant would be
producing the least amount of energy. Key program elements would include maintenance activities
undertaken by staff at the on-site O&M buildings and on-site maintenance as required to clear weeds for
ground-mount systems.
Maintenance typically would include module repairs; module washing; maintenance of transformers,
inverters, high-voltage systems, and other electrical equipment as needed; maintenance of the substation,
including the oil/water separator system; and road and fence repairs. Visual inspections of the transformers
and the oil/water separator system would be conducted monthly. On-site vegetation would be managed to
ensure access to all areas of the site.
Solar modules would be washed as needed (up to four times each year) using light utility vehicles with tow-
behind water trailers, as needed, to maintain optimal electricity production. No chemical cleaners would be
used for module washing.
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As part of ongoing O&M, the energy storage system would be inspected once a year at minimum.
Regular preventative maintenance would include checking security of AC connections; replacement of fans,
filters, and pumps as required or recommended; fire suppression system inspection as required; and
validating measurements of key electrical and environmental sensors.
Typical equipment used during O&M would include pickup trucks, tractors, and portable water trailers.
3.4.15.3 Fire Prevention, Suppression, and Safety Program
During the O&M phase of the project, the Fire Prevention, Suppression, and Safety Program, including all
training and practices, would be consistent with those described above under construction activities.
3.4.15.4 Site Safety and Security Plan
The project is proposed in an unincorporated area of Maricopa County, where law enforcement
responsibility and services are provided by the Maricopa County Sheriff’s Office. The project is designed
to avoid placing additional burden on the resources of the Maricopa County Sheriff’s Office through the
implementation of the following Security Plan.
Controlled Access
The solar facility would be accessed by gated entrances equipped with Knox Box or similar emergency
access systems. The entrances would feature locked gates approximately 7 feet high.
Lighting
Motion sensitive, directional security lights would be installed to provide adequate illumination around the
substation areas, each inverter cluster, at gates, and along perimeter fencing. All lighting would be shielded
and directed downward to minimize the potential for glare or spillover onto adjacent properties. All lighting
also would conform to applicable Maricopa County rules and regulations for outdoor lighting.
Other Security Measures
Off-site security personnel could be dispatched during nighttime hours or could be on-site, depending on
security risks and operating needs. Infrared security cameras, motion detectors, and/or other similar
technology would be installed to allow for monitoring of the site through review of live footage 24 hours
per day, 7 days per week. Such cameras or other equipment would be placed along the perimeter of the
facility and/or at the inverters. Security cameras located at the inverters would be posted on poles
approximately 20 feet high.
Signage
During all phases of the project, signage for safety and identification would be posted around the perimeter
of the project site. No large billboards or other forms of advertising signage are proposed. All signage would
conform to Maricopa County requirements.
3.4.16 Water Requirements
During the construction of both project phases, it is anticipated that up to 350 acre-feet of water would be
used for dust suppression and other purposes. Water used during construction could come from an on-site
well, a nearby well, or could be trucked to the site from a source within 60 miles of the site.
During the O&M phase (which could last up to 40 years), up to approximately 10 acre-feet of water would
be required per year for module washing and maintenance and for the O&M building restroom facilities.
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 15
3.5
Decommissioning and Site Reclamation
3.5.1
Decommissioning of Facilities
The project is anticipated to have an operating life of up to 40 years. After this period, the project would be
either repowered or decommissioned. Project decommissioning would involve the removal of above-grade
facilities, buried electrical conduit, and all concrete foundations. Equipment would be repurposed off-site,
recycled, or disposed of in a landfill as appropriate. Some or most of the PV modules would be recycled or
repurposed.
After the operating life of the project is complete, the energy storage system would be decommissioned
along with the rest of the solar facility. Some or most battery components would be recycled, and other
components may be disposed of as hazardous waste, depending on available technology. Li-ion and lithium-
iron phosphate batteries and their constituent parts will likely be recycled. Some batteries may have the
capacity to be reused at the end of the operating life of the project.
Decommissioning would take up to 13 months to complete and would occur in 3 phases: Phase 1 would
involve shutting down the systems and removing hazardous materials and wiring; Phase 2 would include
removing the battery storage containers and PV modules, inverters, and substations; and Phase 3 would
include removing site fencing and driveways and the final soils reclamation process.
Decommissioning would involve the use of heavy equipment similar to that used for construction.
Appropriate hazardous materials control and erosion control measures would be used throughout the
decommissioning process. It is anticipated that such controls would be substantially similar to those
implemented during construction, although the intensity of activities would be lower.
3.5.2
Site Reclamation
All roads, driveways, and other areas compacted during original construction or by equipment used for
decommissioning would be tilled in a manner adequate to restore the sub-grade material to the proper
density and depth consistent with adjacent properties. Low areas would be filled with clean, compatible
sub-grade material. After proper sub-grade depth is established, locally sourced topsoil would be placed to
a depth and density consistent with adjacent properties. Locally sourced compost would be applied to the
topsoil, and revegetation with native seeds or plantings would be accomplished.
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 16
4.0
RELATIONSHIP TO SURROUNDING PARCELS
4.1
Project Site Parcels
The size of the approved Zoning with Overlay change is 2,805.23 acres. The project’s subsequentially approved
Minor Amendment to the Plan of Development removed parcels from the project assemblage for an amended acreage of
approximately 1281 acres. All parcels in the project footprint are currently zoned IND-2 with an IUPD. Table 1
below lists individual parcels comprising the amended project footprint.
TABLE 1
PROJECT SITE PARCELS
Assessor’s Parcel Number
Acres
506-31-001
139.98
506-31-002
159.32
506-31-005A
(Formerly 506-31-005)
320.66
506-31-006F
(Formerly 506-31-006A)
160.39
506-31-006E
(Formerly 506-31-006C)
120.13
506-31-007G
51.41
506-31-010G
39.97
506-31-010H
80.02
506-31-010J
55.05
506-31-010K
53.40
506-31-010L
60.35
506-31-059A
(Formerly 506-31-059)
40.01
TOTAL
Approximately 1281
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 17
4.2
Surrounding Parcels
The subject property is located adjacent to the Delaney Substation, minimizing the amount of additional
power lines required to facilitate connection to the regional electrical system. The project site is also located
near an existing energy generation facility, the Harquahala Generating Station, 1 mile west of the proposed
project site at the intersection of Thomas Road and 491st Avenue. Thus, the project site is bookended to the
west by the Harquahala Generating Station and to the east by the Delaney Substation, and with the
construction of the project, the use of lands between these two significant pieces of energy infrastructure
would be consistent with the surrounding context of energy generation.
Other adjacent land uses include industrial and rural. Adjacent to the north of the project, the majority of the
land is administered by the Arizona State Lands Department (ASLD). All land use to the north of the project
is classified as Rural Density (0-1) and is zoned as RU-43 (Rural). Adjacent the east of the project, all land
is administered by the ASLD, with the exception of the Arizona Public Service-owned Delaney
Substation located adjacent the southeast corner of the project. All land use here is designated as Rural
Density (0-1) and is zoned as RU-43. Adjacent to the south of the project, the majority of land is
administered by the ASLD, the FCD of Maricopa County, and the BLM. Land use to the south of the project
is classified as a mix of Rural Density (0-1) and Industrial, and is zoned as RU-43, C-2 (Intermediate
Commercial), and C-3 (General Commercial). Adjacent to the west of the project, land use is classified as
a mix of Rural Density (0-1), Rural Development Area and Industrial (adjacent to the southwest corner of
the project). All zoning adjacent to the west of the project is zoned as RU-43. The project, as proposed, will
be compatible with both industrial and surrounding residential uses. The project would not produce, use,
store, transport, or dispose of hazardous materials as defined in Title 40, Part 335 of the Code of Federal
Regulations. Materials such as fuels, inverter coolant, transformer oil, and batteries installed as part of the
energy storage system would be used during construction, operation, and decommissioning of the proposed
project. These materials are subject to local, state, and federal regulations to minimize risk and exposure to
the public and to the environment.
4.3
Benefits to the Community and Surrounding Area
4.3.1
Economic Benefits
During public involvement activities for the Major Comprehensive Plan Amendment and the Zone Change
applications, one important public interest voiced by those who participated was the availability of jobs
created as a result of the project for interested local citizens. The project as proposed will create the need
for a variety of new skilled jobs. Project construction is anticipated to take up to 24 months but could last up
to 36 months and will need an estimated workforce of 240 to 500 full-time employees. During operations,
there will be up to 10 permanent full-time employees for ongoing facility management, up to 25 part-time
employees for regularly scheduled module washing and routine maintenance activities, and up to 40
employees on an intermittent basis for equipment replacement or repair.
4.3.2
Environmental Benefits
Phase 2/PV of the project is a 150-MW solar electric generating and storage facility, which will increase
the amount of renewable energy available to a growing Maricopa County. Tangible environmental benefits
from the project include a reduction in greenhouse gas emissions over the life of the project as well as a
corresponding reduction in emissions that adversely impact air quality. The applicant and its consultant,
Eocene Environmental Group, have also completed several screenings in the area of the project for biological
resources and cultural resources and have determined that the subject property does not contain unique
habitats, threatened or endangered species, or important cultural resources. There will not be significant
adverse impacts to the natural environment. Visually, the infrastructure associated with the solar energy
generation and storage will be low-lying; thus, the impacts to scenic quality will be limited and highly
localized. Additionally, the project will benefit air quality in Maricopa County and beyond.
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 18
4.4
Recent Changes in the Area that Support the Application Request
In addition to the approved zoning change, RE Papago LLC received approval for a Major Comprehensive
Plan Amendment and a related General Comprehensive Plan Amendment for the subject project. This is in
line with a number of other recently approved Comprehensive Plan Amendments for solar energy
generation surrounding, abutting, and immediately adjacent to the proposed project site, including the Sun
Valley North, Sun Valley South, Harquahala Solar, and Almeria Solar projects. RE Papago LLC has also
set aside easement areas for proposed solar projects to interconnect into Delaney Substation on parcels 506-
31-010L and 506-31-006E (formerly 506-31-006-C). Additionally, the Ten West Link transmission project has
been granted an easement (third party access) on the east side of parcels 506-31-006E (formerly 506-31-006-C),
506-31-006F, 506-31-005A, and 506-31-001.
5.0
LOCATION AND ACCESSIBILITY
5.1
Project Location
The project site is located in the western region of unincorporated Maricopa County, south of I-10 and
approximately 5.5 miles west of the community of Tonopah, Arizona. The project site’s location is
generally north of West Courthouse Road, northwest of the Delaney Substation and the junction of West
Courthouse Road and West Salome Highway, east of 491st Avenue, and south of I-10. Indian School Road
and Salome Highway extend through parts of the project site. The project site is located about 55 miles west
of Phoenix, Arizona.
5.2
Accessibility
As the project is located immediately south of I-10, it is anticipated that I-10 would serve as the primary
corridor for both construction traffic and operational traffic serving the proposed project. From I-10, the
primary arterial roads that will be used to access the project site are existing roads, including West Salome
Road, Indian School Road, and West Courthouse Road. From these arterial roads, 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.
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 19
6.0
CIRCULATION SYSTEM
6.1
On-Site
On-site access roads would consist of only those required for vehicle access and maintenance activities.
Roads would typically be constructed to be 20 feet wide or less and would be paved or graveled as needed
for access and dust control during construction and O&M phases. There are no existing access roads within
the project on-site boundaries, and, thus, no improvements are necessary.
The applicant has submitted ROW waiver requests to MCDOT and received approval for section and
midsection lines internal to the project site in the following locations (See Sheet T1.5 of the Site Plan):
•
APN 506-31-002: The ROW setbacks along the northern, eastern and western boundaries have been
reduced to 0’, the ROW setback along the southern boundary has been reduced to 40’.
•
APN 506-31-005A: The ROW setbacks along the northern and eastern boundaries have been reduced
to 0’, the ROW setback along the western boundary has been reduced to 40’.
•
APN 506-31-007G: The ROW setbacks along the northern and eastern boundaries have been reduced
to 0’.
6.2
Off-Site
The MCDOT has requested ROW dedications/reservations along road alignments internal to the project
boundary. The applicant completed dedication/reservation of the following alignments on December 18,
2024:
•
Salome Highway: APNs 506-31-006E, 506-31-010J, 506-31-010K, 506-31-010L, and 506-31-
059A dedicate to 130 feet (65 feet either side of road centerline)
•
Indian School Road along parcel APNs 506-31-059A, 506-31-005A, 506-31-010G, 506-31-010H,
506-31-006F: dedicate to 65 feet
The approved POD amendment reduced the project size and eliminated certain parcels from the project
boundary. Where certain roads are no longer contained within the project boundary, the applicant will no
longer dedicate or preserve alignments. The following alignments will no longer be dedicated/preserved by
the applicant:
•
Salome Highway through APN 506-31-061
•
Indian School Road (west of Salome Highway): preserve 25 feet (half width) and/or 50 feet (full
width)
•
467th Avenue: preserve 65 feet half-width
•
Campbell Avenue east from Salome Highway to 267th Avenue: preserve 25 feet
There would be no significant increase in traffic during the operational life of the project that would
require road improvements. There would be an increase in the level of traffic during the up to 36 months
required for project construction. This increased traffic would result primarily from the delivery of
equipment and supplies and the commuting of the construction workforce. A detailed traffic impact
analysis was completed as part of the zoning change process. RE Papago LLC, RE Papago PV LLC, and
RE Latigo LLC has agreed to be held financial responsibility for repair of roads used during construction,
including bonding for such work, so that there is no public expenditure required for transportation
infrastructure associated with the project.
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 20
7.0 DEVELOPMENT SCHEDULE
Below is an indicative schedule for development:
•
Q3 2021 COMPLETE—Attain all required major approvals and permits, which may include but
not be limited to the following: Zone Change with Industrial Overlay, Major Comprehensive Plan
Amendment, General Comprehensive Plan Amendment, CEC.
•
Q1 2024 COMPLETE—Phase 1/BESS air quality permit/approval and other necessary pre-
construction
•
permits complete. Construction of battery energy storage system starts (earliest anticipated).
•
Q3 2024 COMPLETE – Phase 2 PV air quality permit/approval and other necessary pre-
construction permits complete. Construction of the Phase 2/PV begins (earliest anticipated).
•
Q2 2025 COMPLETE—Construction of Phase 1/BESS complete. Operation of battery energy
storage system begins (earliest anticipated)
•
Q1 2026—Construction of Phase 2/PV complete. Operation of Phase 2/PV begins (earliest
anticipated)
•
2026 to 2066—O&M Phase (up to 40 years)
8.0 COMMUNITY FACILITIES AND SERVICES
The proposed project area is located within the Arlington #47 school district in the Buckeye Union High
School District #201.
The project site is located in a rural and relatively undeveloped area of Maricopa County. No additional
amenities or public parks exist within or near to the project area.
9.0 PUBLIC UTILITIES AND SERVICES
TABLE 2
RE PAPAGO SOLAR PROJECT: UTILITY COMMITMENTS
Utilities
Agency
Water
N/A (water used during construction could come from an on-site or
nearby well or could be trucked to the site from a source within 60 miles of
the site)
Wastewater Disposal
N/A (wastewater generated at the project site would be treated with an on-
site wastewater treatment facility, such as a septic tank system)
Fire Protection
Harquahala Fire District, Arizona Fire and Medical Authority
Police Protection
Maricopa County Sheriff's Office
Electric Service
Arizona Public Service
Natural Gas Service
N/A
Telephone Service
Lumen
Refuse/Solid Waste Disposal
Republic Services
N/A = Not applicable
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 21
10.0 COMPARISON CHART
TABLE 3
RE PAPAGO SOLAR PROJECT IND-2 IUPD: APPROVED ZONING REGULATIONS
Regulation
Base Zoning District
Regulations (IND-2)
Approved Zoning
District Regulations
(IND-2 IUPD)
Requested Zoning
District Regulations
(IND-2 IUPD)
Justification
Min. Side Yard
3–10’
0’
0’
No homes are adjacent to any side yards of the project
parcels. A 0-foot setback for side yards that are not adjacent to
streets or road dedications/preservations would make more
site area available for energy production.
Min. Rear Yard
25’
0’
0’
No homes are adjacent to any side yards of the project
parcels. Setbacks of 0 feet make more site area available for
energy production.
Min. Lot Area
6000 sq. ft.
6000 sq. ft.
6000 sq. ft.
N/A
Min. Lot Width
60’
60’
60’
N/A
Max. Lot Coverage 60%
60%
60%
N/A
Screening
A solid masonry wall not
less than 6 feet in height
shall be required along and
adjacent to any side or rear
property line abutting any
rural or residential zone
boundary, or any alley
abutting such zone
boundary. Further, any
access gates shall be
constructed of view-
obscuring material to
provide effective site
screening.
6’ minimum chain-link
fencing (with 1’ of
barbwire permitted)
6’ minimum chain-link
fencing (with 1’ of
barbwire permitted)
Because of the low profile of the solar PV panels and because
the site is not located near any population centers or heavily
travelled roads, landscaping, solid walls or other screening
methods would not be required to mitigate a visual impact.
The proposed solar PV panel arrays would be visible from
viewpoints along public roads, including West Salome
Highway and Indian School Road, but would be located on
relatively flat lands, and would not block or obscure landscape
views through the site. Chain-link fencing would be consistent
with other solar energy developments in the area.
Landscaping
5’–20’ landscaping strip
required along road
frontages
No landscaping strip
required
No landscaping strip
required
Installing a landscaping strip on the site along all road
frontages would be cost prohibitive. The project is designed to
minimize the disruption of natural vegetation as much as
possible. Existing natural vegetation will remain undisturbed
along front setback areas.
RE Papago Photovoltaic Solar Energy Generation and Storage Project
Modification of Conditions to an Approved Zone Change (Z250045)
page 22
TABLE 3
RE PAPAGO SOLAR PROJECT IND-2 IUPD: APPROVED ZONING REGULATIONS
Regulation
Base Zoning District
Regulations (IND-2)
Approved Zoning
District Regulations
(IND-2 IUPD)
Requested Zoning
District Regulations
(IND-2 IUPD)
Justification
Sight Visibility
Triangles (SVTs)
25’ x 25’ SVT required at all
access points and
intersection corners
Waive all SVTs at project
site entry/exit points and
road intersection, section-
line, mid-section line or
alignment corners
Waive all SVTs at project
site entry/exit points and
road intersection, section-
line, mid-section line or
alignment corners
Fencing at intersections will be open chain-linked, and,
therefore, visibility will be maintained. Most alignments and
section lines are internal to the Project site footprint.
No access to the Project site parcels would occur at
intersections.
Parking
Paved parking required.
High curb or bumper guard
required for parking areas.
Paved parking not
required with approved
dust control plan from
Maricopa County Air
Quality Control. High curb
and/or bumper guard not
required.
Paved parking not
required with approved
dust control plan from
Maricopa County Air
Quality Control. High
curb and/or bumper
guard not required.
Onsite parking would be limited to the O&M building. No
paved surfaces are planned within areas near to where the
O&M building would be constructed. Onsite parking will not
be located near property lines.
Max. Electric
Transmission
Line Structure
Height
120’
140’
170’
Utility pole heights up to 170 feet are requested because
utility structures 140 feet or less in height will not be
sufficient for the planned crossing of 500 kilovolt (kV)
transmission lines. The applicant requests additional
flexibility to make the necessary adjustments, as needed,
for future final designs.
Additional
Regulations
All uses except for
parking, loading,
unloading or storage shall
be conducted within a
completely enclosed
building.
Utility uses are
permitted to be
conducted outside of an
enclosed building.
Utility uses are
permitted to be
conducted outside of an
enclosed building.
The 2,000-square foot O&M building would be the sole
staffed structure on the site. The operating uses of the site
include energy generation and storage, which would take
place within the solar PV arrays and BESS, respectively,
and would not take place within enclosed structures (with
the exception of the unstaffed project substation and
SCADA/control system enclosure).
Page 1 of 2
Anh Harambasic, PE
Planning & Development
301 W. Jefferson St., Suite 170
Phoenix, Arizona 85003
Phone: (602) 506-3611
www.maricopa.gov/planning
Email address:
anh.harambasic@maricopa.go
v
Planning & Development
Engineering Plan Review
Date:
January 23, 2026
Memo To: Darren Gerard, AICP, Planning Manager, Department of Planning &
Development
Attn:
Nicholas Schlimm, Planner, Planning & Development Services
From:
Anh Harambasic, P.E. Engineering Plans Reviewer, Planning and
Development Services.
cc:
Doug Jones, P.E., Engineering Supervisor, Planning & Development
Services
Subject:
Zone Change request without a plan of development for Hassayampa
Ranch PA250116
Job Site Address: 45558 W. Salome Hwy Tonopah, AZ
APN(s):
506-31-006E, 506-31-059A, 506-31-010K + additional parcels.
This application is requesting in their narrative a modification of a condition to the zone
change. The modification requested is an increase in the maximum allowed
electronical transmission line structure height to 170 feet from previously approved
140 feet height limit. This is to support a future phase 3 BESS for which the applicant
will submit a minor amendment to the plan of development.
PND Engineering Plan Review (DPR, FCD and PND Transportation) has reviewed the
1st submittal of the modification of condition, maximum allowable height, application
routed for review on 1.2.2026 and has no objections to the zone change subject to the
following conditions:
1. All original conditions of approval engineering/drainage stipulations for
Z2019121, Z2023086, PD240006 and any other entitlement case associated
to this development remains unchanged. The only condition modification for
this approval pertains to the maximum allowable height change from 140 feet
to 170 feet. No objections.
General drainage conditions:
2. Engineering and drainage review was based on a zone change without a plan
of development. Therefore, without the submittal of a precise plan of
development, no development approval is inferred by this review, including,
but not limited to number of proposed building lots/units, drainage design,
access and roadway alignments. These items will be addressed as
development plans progress and are submitted to the County for further review
and/or entitlement.
Page 2 of 2
3. Engineering review of re-zone cases is conceptual in nature. All development
and engineering design shall be in conformance with Section 905 of the
Maricopa County Zoning Ordinance; Drainage Policies and Standards;
Floodplain Regulations for Maricopa County; MCDOT Roadway Design
Manual; and current engineering policies, standards and best practices at the
time of application for construction.
4. The County does not provide fire service, therefore, it is incumbent that the
applicant seek service and approval of plans from the jurisdictional fire service
provider.
Please contact me if you have any questions or require any additional information.
Papago Solar Project | TIS Addendum Due to Modifications
Discipline
Traffic Impact Study
Salome Road
Consultant
Recurrent Energy
Z250045 (Originally approved under Z2019121 & Z20250045)
Plans Sealed By
Not Applicable
Laxmikanth Narwa, PE
Laxmikanth.Narwa@maricopa.gov / 602-506-8677
Int.
Review No.
Date
Item No.
Approval Comment / Condition
LN
1
2/23/2026
1
As the applicant is not seeking any changes in this Modification of Conditions to an approved Zone Change request that
would impact the traffic projections from the originally approved TIS unde Z2019121 (see attached), MCDOT has no traffic
related concerns for the proposed modifications to the project site.
This Traffic Impact Study is Approved
Traffic Engineering TIA Approval Memo
Project Name
Location
MCDOT Reviewer: Attach the Project TIA Cover Sheet with Maricopa County Approval Stamp.
General Project Summary:
Applicant has submitted TIS Addendum to support their application for approval of modification of conditions to previously approved Zone Change application under Z20250045. The
original Traffic Impact Statement (TIS), dated and stamped August 8, 2020, was previously approved Under MCDOT File Number Z2019121. As per the information provided by the
applicant, in the current modification of conditions request, the applicant is requesting an increase in the Maximum Allowed Transmission Line Structure Height to 170ft from the
previously approved 140ft height limit. This is the only condition of approval that is requested for modification.
Notes / Reference
See attached Comment/Review history for reference.
MCDOT File No.
TIA Approved By
Contact
The below TIA Approval Memo comments are reviewed and approved by a Professional Engineer working for MCDOT. The comments include all previous review comments issued by MCDOT TSMO Branch reviewers, addressed &
acknowledged by the consultant. This Memo is issued for all Stakeholders to utilize the final review comments and conditions from this Memo along with the approved TIA submittal to proceed futher in the permit process.
Page 1 of 1
I:\TSM-Design Branch\Maie Elkeshky\Papago Solar Project_Z2019121_11_12_2019\Papago Solar Project_Z2019121.pdf.doc
MCDOT -- TRAFFIC ENGINEERING
REVIEW COMMENT SHEET
1 OF 2
Project Name: Papago Solar Project
Location: Salome Road
P&D/MCDOT File No.: Z2019121
Date: 09-23-2020
Reviewer: Raj Thoutam
Phone No.: 602-506-8940
Consultant: Westwood
Project No.: 0022642
Report Sealed By: Randall J. Gardner, PE Phone No: Fax:
CONSULTANT CODE:
A = Will Comply B = Deleted
C = Consultant to Evaluate
Item
Number
Page
Number
Comments
Consultant
Reply
= = =
1
= = =
2nd REVIEW (TIS)
Consultant: Please use the code and respond to each comment in the Consultant
Reply Column. This sheet is for our record, please answer every question and sign
and date your acknowledgement or the plans will be sent back to complete the
process. Send back the marked-up plans and a new set of plans along with this
comment sheet. Thank you for your cooperation.
= = = = = = = = = = = = = = = = = = = = = = = = = = = = = = =
General Summary:
The proposed solar project location is located at Salome Hwy between 411th avenue
and I-10 & Salome Hwy intersection north of W Courthouse Road. The project will
employ about 10 full time staff for operation, hence the ITE land use code 170 trip
generation in not used. Construction is estimated to take about 300 workdays,
producing Peak Vehicle count of 412 trips per day on the highest road segment
(Salome Hwy and 411th avenue and Courthouse road). The peak hour volume is
about 165 vehicle per hour.
Review Comments:
Concur with the study findings; therefore, there are no further comments.
The traffic statement is approved.
Signature: _____________________________________ Date: ___________
I:\TSM-Design Branch\Maie Elkeshky\Papago Solar Project_Z2019121_11_12_2019\Papago Solar Project_Z2019121.pdf.doc
MCDOT -- TRAFFIC ENGINEERING
REVIEW COMMENT SHEET
2 OF 2
Project Name: Papago Solar Project
Location: Salome Road
P&D/MCDOT File No.: Z2019121
Date: 11-14-2019
Reviewer: Raj Thoutam
Phone No.: 602-506-8940
Reviewer: Maie Elkeshky
Phone No.: 602-506-1788
Consultant: Westwood
Project No.: 0022642
Report Sealed By: XXXXXX Phone No: XXX-XXX-XXXX Fax:
CONSULTANT CODE:
A = Will Comply B = Deleted
C = Consultant to Evaluate
Item
Number
Page
Number
Comments
Consultant
Reply
= = =
1
2
4
5
= = =
1ST REVIEW (TIS)
Consultant: Please use the code and respond to each comment in the Consultant
Reply Column. This sheet is for our record, please answer every question and sign
and date your acknowledgement or the plans will be sent back to complete the
process. Send back the marked-up plans and a new set of plans along with this
comment sheet. Thank you for your cooperation.
= = = = = = = = = = = = = = = = = = = = = = = = = = = = = = =
General Summary:
The proposed solar project location is located at Salome Hwy between 411th avenue
and I-10 & Salome Hwy intersection north of W Courthouse Road. The project will
employ about 10 full time staff for operation, hence the ITE land use code 170 trip
generation in not used. Construction is estimated to take about 300 workdays,
producing Peak Vehicle count of 412 trips per day on the highest road segment
(Salome Hwy and 411th avenue and Courthouse road. The peak hour volume is about
165 vehicle per hour
Review Comments:
Please provide the project location or parcels numbers under the introduction section.
Please provide site plan showing all access points during operations.
The approximated trips generated of 49,000 is very high, please clarify it is for the
whole construction period of the project.
The report needs to be signed and sealed.
Signature: _____________________________________ Date: ___________
1
Nicholas Schlimm (PND)
From:
RAHN, JENNIFER L CIV USAF AETC 56 CES/CENP <jennifer.rahn@us.af.mil>
Sent:
Friday, February 20, 2026 12:03 PM
To:
Nicholas Schlimm (PND)
Cc:
GERARDI, CHRISTINE L CIV USAF AETC 56 FW/CVE; BINKLEY, ERIC S CIV USAF AETC 56
FW/CVE
Subject:
RE: Z250045: Modification of Conditions to a Zone Change
This Message Is From an External Sender
This message came from outside your organization. Please use caution when corresponding outside the county.
Good morning Mr. Schlimm,
Thank you for the opportunity to comment on the zone change modification of conditions for the proposed Papago
Photovoltaic Solar Energy Generation and Storage Project. The site comprises approximately 2,805.23 acres of
privately held land located at 45558 W Salome Highway in Maricopa County, AZ. The request is to increase the
height of associated transmission lines from 140ft to 170ft. The site is located outside the Luke AFB 1988 JLUS 65
Ldn, “high noise or accident potential zone,” as identified by A.R.S. § 28-8461, and is outside the “territory in the
vicinity of a military airport,” also defined by A.R.S. § 28-8461.
Luke AFB continually appreciates the opportunity to provide comments, acknowledging that we are not the
approval authority. Luke AFB follows A.R.S. § 28-8481 when evaluating compatible land use within the “territory in
the vicinity of a military airport”. As described, this project will not impact the operations of Luke AFB.
Any structures for this development are subject to the results of an FAA Obstruction Evaluation/Airport
Airspace Analysis and Spectrum Analysis (OE/AAA). Luke AFB reserves the right to comment as the
development matures and amended plans become available.
Please ensure the project is submitted for an informal review through the DoD Siting Clearinghouse for
Energy, Installations, and Environment. The project narrative may be sent to: osd.dod-siting-
clearinghouse@mail.mil. This response is also conditional upon their approval/input.
Additionally, it should be noted that certain investments and real estate transactions within the military
installation footprint of Luke AFB may be subject to review by the Committee on Foreign Investment in the United
States (CFIUS) to determine the effect of such transactions on the national security of the United States. The
CFIUS regulations, Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) provisions, and related
resources can be found on the Department of the Treasury’s website: http://www.treasury.gov/cfius. Please
contact Luke AFB for an informal review process.
Luke AFB recognizes there are capacity concerns for energy intensive developments in the state. Through strategic
grid resilience and reliability planning on the part of municipalities and utility providers, this project will not impact
the energy resilience of Luke AFB.
Although the development will be located outside the “territory in the vicinity of a military airport,” it may be
subjected to approximately 170 over flights a day. We recommend you review the sound attenuation requirements
found in A.R.S. § 28-8482. A strong notification program on the part of the applicant is essential to inform potential
occupant(s) about Luke AFB operations.
2
V/r,
Jenn Rahn
Portfolio Optimization Chief
56th Civil Engineer Squadron
Luke Air Force Base
(623) 856-4746
DSN: 896-4746
From: Nicholas Schlimm (PND) <Nicholas.Schlimm@maricopa.gov>
Sent: Friday, February 6, 2026 2:52 PM
To: proetto1950@gmail.com; jmcmenemy@hfdaz.org; dmheisler1@aol.com; HStumpRR@gmail.com; Teigan Williams
<tstruck@azgfd.gov>; Calle Hinkle <chinkle@azgfd.gov>; redletter@azdot.gov; Rolmstead@AFMA.Az.gov; Philip Hilliker
(MCSO) <P_Hilliker@MCSO.maricopa.gov>; 56 FW/CIT Community Initiative
<56FW.CIT.CommunityInitiative@us.af.mil>; kcotner@azmag.gov; pburnett@azmag.gov; pe@azland.gov; Paul Chagolla
(MCSO) <P_Chagolla@MCSO.maricopa.gov>; Project Evaluation Program - Game and Fish <pep@azgfd.gov>; AQD
Business Assistance <AQBusinessAssistance@maricopa.gov>; steven.kadatz@aps.com
Subject: [Non-DoD Source] Z250045: Modification of Conditions to a Zone Change
Good afternoon,
Case Z250045 for a Modification of Conditions to a Zone Change is in for review.
To access and review application materials, please visit the following link to the Maricopa County Permit Center:
https://maricopacountyaz-energovweb.tylerhost.net/apps/selfservice#/home.
On the right-hand side of the menu bar, select the Search icon.
Enter the case number, Z250045, and click the blue Search icon.
Click on the highlighted plan number, Z250045.
A new page will load with case information; select Attachments.
If you have any questions, please feel free to contact me.
Sincerely,
Nick Schlimm
PLANNING & DEVELOPMENT
301 W. Jefferson St. #170 Phoenix, AZ 85003
Planner
O: 602-506-0031
MARICOPA.GOV
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