Z2024012 BOS REPORT.PDF

October 23, 2024 
Z2024012 
Page 1 of 3 
 
 
 
 
Report to the Board of Supervisors 
Prepared by the Maricopa County Planning and Development Department 
 
Board Hearing Date: 
October 23, 2024 
 
Case #/Title:   
 
 
Z2024012 – Saguaro BESS      
 
Supervisor District: 
4 
 
Applicant/Owners:  
Jennifer Hall and Ty Utton, Rose Law Group / Desert Forrest 
Nursery LLC and FHF LLC 
 
Request: 
Zone Change with Overlay from C-2 CUPD to IND-2 IUPD 
 
Site Location: 
Generally located 1,500’ southeast from the intersection of Olive 
Ave. and Cotton Ln. in west Glendale area 
 
Site Size: 
Approximately 10.5 acres 
 
County Island Status: 
Yes, City of Glendale 
Additional 
Comments: 
Approval of this item would rezone an 11-acre portion of a 38-acre 
property from C-2 CUPD to IND-2 IUPD to allow for the development 
of a battery energy storage system (BESS) facility. Based largely 
upon the support of Rural Metro Fire Department (RMFD), the fire 
authority over this region, staff’s report to the Commission 
recommended approval.  However, the staff recommendation 
included IUPD standards that would limit potential BESS 
development – specifically a minimum 100’ setback for battery 
units from all lot lines and a minimum  500’ separation for battery 
units from dwelling units.  This was much stricter than the 
applicant’s request.  
 
After lengthy discussion the Commission’s vote was 5-3 (with 
commissions Lawrence and Lindblom of Dist. 1 and Curley of Dist. 
3 dissenting) to recommend denial of the requested IND-2 IUPD 
zoning.  They indicated the general industrial zoning would be less 
appropriate than the existing community commercial zoning as it 
presented potential for BESS development in close proximity to 
moderate density housing. Their recommendation was based upon 
concern that the proposed BESS was too close to an existing 
residential neighborhood. No new information had been provided 
by applicant since Commission hearing

October 23, 2024 
Z2024012 
Page 2 of 3 
There are no concerns from county review agencies. As mentioned 
RMFD is supportive of the request and maintains a fire station 
within two blocks of the site. 
 
 
Should the Board consider approving the IND-2 IUPD zoning, staff 
offers the following conditions which includes modified IND-2 IUPD 
development standards in condition ‘d.2’ from those listed in staff’s 
report to the Commission. The following are the changes requested 
to condition ‘D.2’ as proposed by the applicant at the PZ hearing: 
 
a. Development of the site shall be in substantial conformance with the Zoning Exhibit entitled 
“Saguaro BESS Project“, consisting of 1 full-size sheet, dated April 11, 2024 and except as 
modified by the following conditions. Staff may determine slight refinements to remain in 
substantial conformance with the approved site plan.  Minor and major amendments to the 
site plan will be determined in accordance with Chapter 3 of the Maricopa County Zoning 
Ordinance. 
 
b. Development of the site shall be in substantial conformance with the Narrative Report 
entitled “Saguaro BESS Project”, consisting of 6 pages, dated July 8, 2024, except as 
modified by the following conditions. 
 
c. Prior to issuance of initial building permits, all parcels shall be combined to create a single 
parcel matching the zoning exhibit of Z2024012. 
 
d. The following IND-2 IUPD zoning regulations will apply: 
 
1. Allowed uses: MCZO Sec. 902.2.17 including battery energy storage systems (BESS), 
and off-site advertising signs / billboards 
2. Setbacks (minimums) 
i. Min. Front yard (west): 90’ 
ii. Min. Side yard (north): 70’ 
iii. Min. Side Yard (south): 170’ 
iv. Min. Rear Yard (east): 100’ 
v. Min. separation from existing, permitted residential (dwelling units): 170’ 
3. Min. Parking: 2 spaces per 10.5 acres of BESS development (one ADA accessible) 
4. Standards for Billboards: 
i. Max. Off-Site Sign Height: Max. 70’ on side directly abutting and oriented to 
or within 150’ of Loop 303. Max. 45’ on side directly abutting and oriented to 
Cotton Lane 
ii. Off-Site Sign Separation Distance: Maximum 2 off-site signs oriented to or 
within 150’ of Loop 303 at minimum 700’ separation distance. 
iii. Off-Site Signs: Maximum of 2 off-site signs permitted on side directly abutting 
and oriented to Loop 303. A maximum of 1 off-site sign permitted on side 
directly abutting and oriented to Cotton Lane and setback a minimum of 500’ 
from the centerline of Olive Avenue. No other off-site signs permitted. 
iv. Off-Site Sign Max Size: 672 square feet 
v. Min. Rear (East) Yard Setback (billboard only): 0’ 
vi. Min. Setback to Rural or Residential zoning: 0’ East and North, 50’ South 
vii. Min. Setback to Rural or Residential zoning for illuminated off-site sign: 0’ 
East and North, 50’ South 
viii. Min. 6’ height screening adjacent to Rural or Residential zoning boundary: 
Zero screening unless POD submitted for use other than billboard or nursery

October 23, 2024 
Z2024012 
Page 3 of 3 
 
e. The following Planning Engineering conditions shall apply:  
 
1. 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. 
 
2. A traffic impact study must be submitted with future entitlement (POD or Preliminary 
Plat) application(s). 
 
3. Engineering review of re-zone case is conceptual in nature. All development and 
engineering design shall be in conformance with Section 1205 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. 
 
f. 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. 
 
g. The property owner/s and their successors waive claim for diminution in value if Maricopa 
County takes action to rescind approval due to noncompliance with conditions.  
 
h. 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, 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, 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 of the zone change.  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. 
 
 
Commission  
 
Recommendation: 
On 9/12/24, the Commission voted 5-3 to adopt a motion 
recommending the Board of Supervisors deny Z2024012.  
 
Presented by: 
 
Joel Landis, Planner 
Reviewed by: 
 
Darren Gérard, AICP, Planning Manager   
 
Attachments: 
 
9/12/24 P&Z staff report packet (57 Pages)  
 
 
9/12/24 PZ handout memo (2 pages)  
 
Note: 
9/12/24 Draft P&Z Minutes are not available as of the writing of this report, but can be 
provided upon request later when available.

Z2024012 
Page 1 of 8 
 
 
Report to the Planning and Zoning Commission 
Prepared by the Maricopa County Planning and Development Department 
 
 
Case: 
Z2024012 – Saguaro BESS 
 
 
 
 
 
Hearing Date: 
September 12, 2024 
 
Supervisor District: 
4 
 
 
 
  
 
Applicants: 
Jennifer Hall and Ty Utton, Rose Law Group 
 
Owners: 
Desert Forrest Nursery LLC and FHF LLC 
   
Request: 
Zone Change with Overlay from C-2 CUPD to IND-2 IUPD 
 
  
 
Site Location: 
Generally located 1,500’ southeast from the intersection of Olive Ave. and 
Cotton Ln. in west Glendale area  
 
  
Site Size: 
Approximately 10.5 acres 
 
Density: 
N/A 
 
County Island:  
Yes, City of Glendale 
 
 
County Plan: 
White Tank/Grand Avenue Area Plan – Single-Family Rural 
 
Municipal Plan: 
City of Glendale – Regional Mixed Use 
 
Municipal Comments: 
None received to date  
 
Support/Opposition: 
One petition with eight signatures in support 
 
Recommendation: 
Approve with conditions

Z2024012 
Page 2 of 8 
Project Summary: 
 
1. 
The applicant is proposing to rezone the site from C-2 CUPD to IND-2 IUPD to develop a 250 MW 
utility-scale battery energy storage system (BESS) facility and substation on a 10.5-acre portion 
of a 38.5 acre site located just northwest of the intersection of Loop 303 and Northern Parkway. 
The project’s intention is to store and release generated power within battery systems to be used 
in times of excess service demand. This facility would be capable of storing enough electricity to 
power approximately 80,000 end-users for up to four hours, increasing the overall resiliency of 
the valley’s power systems. The facility will be connected via a transmission line easement to the 
under-development APS Parkway Station located north of Olive Ave. within City of Glendale 
jurisdiction. 
 
2. 
Historical aerials indicate this site having been used for agriculture for several decades before 
the development of Loop 303 which lies just east of the site. This use has continued to the present 
despite recent attempts to redevelop. Most recently, the subject site was part of a larger rezone 
of 38.5 acres southeast of Cotton Ln. and Olive Ave. from Rural-43 to C-2 CUPD under case 
Z2019129, ostensibly to allow retail component for a plant nursery on-site which was operating 
under a prior approved agricultural exemption. Said rezone only limited a few select incompatible 
uses 
while 
allowing 
most 
other  
C-2 uses. The only new developments on the site were two billboards along Loop 303 on what is 
currently APN 501-05-006M. As the subject 10.5 acres are split between several parcels, the 
applicant is currently undergoing the process of redelineating parcels.  It is conceivable the rest 
of the parcel outside of the 10.5-acres could redevelop soon to any number of commercial or 
residential uses.  
 
3. 
In contrast, this rezone would only allow a singular use within the IUPD overlay, that being the 
BESS facility. The following table includes the differed site standards under the proposed IND-2 
IUPD overlay (changes highlighted in bold):

Z2024012 
Page 3 of 8 
 
 
4. 
Additionally, to prevent further issues regarding permitting of the existing billboards, this rezone 
would also apply the following billboard standards:

Z2024012 
Page 4 of 8 
Aerial photo of the site circa 2024, oriented north. Also shown is the location of the electrical easement leading towards the substation and 
Rural Metro fire station. 
 
 
 
Zoning exhibit showing proposed conceptual site development. No Plan of Development has been included with this proposal.

Z2024012 
Page 5 of 8 
Existing On-Site and Adjacent Zoning / Land Use: 
 
5. 
On-site: 
 
C-2 CUPD / Plant Nursery 
North: 
C-2 CUPD / Plant Nursery  
South: 
R1-6 / Single-family residences 
East: 
Rural-43 / AZ-303 
West: 
C-2 CUPD/Rural-43 / Plant Nursery/Rural residences 
 
 
Utilities and Services: 
 
6. 
Water: 
 
EPCOR 
Electric: 
APS 
Fire: 
Rural Metro 
Police:  
Maricopa County Sheriff  
 
Right-of-Way: 
 
7. 
The following table includes existing and proposed half-width right-of-way and the future 
classification based upon the Maricopa County Department of Transportation (MCDOT) Major 
Streets and Routes Plan.   
 
Street Name 
Half-width Existing R/W 
Half-width Proposed R/W 
Future Classification 
Cotton Ln. 
50’ 
80’ 
Major Collector 
Olive Ave. 
50’ 
80’ 
Major Collector 
 
Adopted Plans: 
 
8. 
City of Glendale General Plan (adopted 2016): The Regional Mixed Use designation is designed 
to encourage new, multi-modal, mixed-use development in regionally significant areas. 
 
9. 
White Tank/Grand Avenue Plan (adopted 2023): Density of 1 dwelling unit or less per gross acre 
with Single-family Rural. 
 
Public Participation Summary: 
 
10. 
The applicant complied with the Maricopa County Public Participation Process with the required 
posting of the property and notification by first class mail to the adjacent property owners within 
300’ of the subject site and interested parties. The applicant has provided a list of 8 signatures of 
property owners from the nearby residential communities indicating support of the project. 
 
11. 
The applicant provided correspondence from Rural Metro indicating their support for the project. 
They have indicated the proximity of the site to a nearby station, setbacks, and proposed site 
design as allowing them to be comfortable in providing their support. 
 
 
Outstanding Concerns from Reviewing Agencies: 
 
12. 
N/A

Z2024012 
Page 6 of 8 
Staff Analysis: 
 
13. 
Staff is supportive of this noting that Rural Metro has no concerns regarding the development. 
BESS facilities are still quite new and while there have been limited instances of such facilities 
causing dangers to surrounding communities, the proximity of this site to such communities 
raises concerns for staff. Staff generally takes the position that 500’ would be an appropriate 
boundary between a BESS site and nearby residential zoning. As designed, this site is 173’ from 
the nearest residential zone. Additionally, there is concern regarding the remaining C-2 zoning to 
the north and west of the subject site. It is the case that residential uses are allowed in 
commercially zoned districts. While these concerns are somewhat alleviated by graduated 
density concept for sites near Luke AFB, staff cannot guarantee that residential will not develop 
on these sites. Furthermore, such developments could be done administratively without further 
review by the public, Planning and Zoning Commission, and Board of Supervisors. 
 
14. 
Staff would therefore propose an alternative that would accomplish the goal of separating the 
BESS use from the existing residential to the south while simplifying the requested zoning 
setbacks. Staff proposes a 100’ setback for BESS systems and associated components from all 
zoning boundaries and 500’ from all currently permitted residential uses (residences). This would 
provide additional buffering to the BESS site. This would also serve to protect future 
developments from the site use to the north and west. 
 
15. 
Staff does recognize the mitigation of these risks by the proximity of the fire station and support 
of Rural Metro as the primary factor in recommending approval, but the positive aspects of BESS 
facilities are important to note as well. BESS facilities provide a unique solution to energy need 
issues within the local power grid. As the west valley continues to grow, such facilities will be key 
in preventing service interruptions that could be catastrophic during the hottest parts of the year. 
 
Recommendation: 
 
16. 
Staff recommends the Commission adopt a motion recommending that the Board of Supervisors 
approve Z2024012 subject to the following conditions ‘a’ – ‘h’: 
 
a. 
Development of the site shall be in substantial conformance with the Zoning Exhibit 
entitled “Saguaro BESS Project“, consisting of 1 full-size sheet, dated April 11, 2024 and 
except as modified by the following conditions. Staff may determine slight refinements to 
remain in substantial conformance with the approved site plan.  Minor and major 
amendments to the site plan will be determined in accordance with Chapter 3 of the 
Maricopa County Zoning Ordinance. 
 
b. 
Development of the site shall be in substantial conformance with the Narrative Report 
entitled “Saguaro BESS Project”, consisting of 6 pages, dated July 8, 2024, except as 
modified by the following conditions. 
 
c. 
Prior to issuance of initial building permits, all parcels shall be combined to create a single 
parcel matching the zoning exhibit of Z2024012. 
 
d. 
The following IND-2 IUPD zoning regulations will apply: 
 
1. Allowed uses: MCZO Sec. 902.2.17 
2. Setbacks (minimums) 
i. Min. Front yard (west): 100’

Z2024012 
Page 7 of 8 
ii. Min. Side yard (north): 100’ 
iii. Min. Side Yard (south): 100’ 
iv. Min. Rear Yard (east): 100’ 
v. Min. from existing, permitted residential uses: 500’ 
3. Min. Parking: 2 spaces with one ADA accessible space 
4. Standards for Billboards: 
i. Max. Off-Site Sign Height: Max. 70’ on side directly abutting and oriented 
to or within 150’ of Loop 303. Max. 45’ on side directly abutting and 
oriented to Cotton Lane 
ii. Off-Site Sign Separation Distance: Maximum 2 off-site signs oriented to or 
within 150’ of Loop 303 at minimum 700’ separation distance. 
iii. Off-Site Signs: Maximum of 2 off-site signs permitted on side directly 
abutting and oriented to Loop 303. A maximum of 1 off-site sign permitted 
on side directly abutting and oriented to Cotton Lane and setback a 
minimum of 500’ from the centerline of Olive Avenue. No other off-site 
signs permitted. 
iv. Off-Site Sign Max Size: 672 square feet 
v. Min. Rear (East) Yard Setback (billboard only): 0’ 
vi. Min. Setback to RU-43: 0’ East and North, 50’ South 
vii. Min. Setback to RU-43 for illuminated off-site sign: 0’ East and North 50’ 
South 
viii. Min. 6’ height screening adjacent to rural or residential zoning boundary: 
Zero screening unless POD submitted for use other than billboard or 
nursery 
 
e. 
The following Planning Engineering conditions shall apply:  
 
1. 
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. 
 
2. 
A traffic impact study must be submitted with future entitlement (POD or 
Preliminary Plat) application(s). 
 
3. 
Engineering review of re-zone case is conceptual in nature. All development and 
engineering design shall be in conformance with Section 1205 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. 
 
f. 
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. 
 
g. 
The property owner/s and their successors waive claim for diminution in value if Maricopa 
County takes action to rescind approval due to noncompliance with conditions.  
 
h. 
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

Z2024012 
Page 8 of 8 
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, 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, 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 of the zone change.  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: 
Joel Landis, Planner 
Reviewed by: 
Rachel Applegate, Acting Planning Supervisor 
 
Attachments: 
Case Map (1 page) 
 
Narrative Report (10 pages) 
 
Site Plan (4 pages) 
 
Rural Metro Support and Analysis (27 pages) 
 
Support petition (1 page) 
 
MC Engineering comments (1 pages)

/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 31 approx.
Generated August 22, 2024 10:57 AM
Z2024012
Application Name:
Legal Description
Applicant
Case Address
Applicant Phone/Email
Parcel Primary:
Map scale 1:5,354
Supervisor District No.

Saguaro BESS Project 
at 
Generally at the SEC of Olive Avenue and Cotton Lane 
ZONE CHANGE with OVERLAY 
REZONING NARRATIVE 
Case No: Z2024012 
Maricopa County, Arizona 
First Submittal: February 8, 2024
Second Submittal: July 8, 2024

DEVELOPMENT TEAM 
 
Developer/Applicant 
 
Saguaro BESS LLC 
Charles McGovern 
cmcgovern@aypa.com 
203-722-9688 
 
 
Legal Representative 
 
Rose Law Group 
Jordan Rose, Attorney  
jrose@roselawgroup.com 
480-505-3939 
 
Ty Utton, Planner 
tutton@roselawgroup.com 
480-944-4189 
 
 
Engineer 
 
TRC Companies Inc. 
6 Executive Circle 
Suite 200 
Irvine, CA 92614 
 
 
Fire Consultant 
 
TERPconsulting  
Joseph E. Chacon, PE 
jchacon@terpconsulting.com

Background 
 
Saguaro BESS LLC (“Saguaro”) is a renewable energy developer, owner, and operator 
who is proposing the development of a new 250-MW Battery Energy Storage System (“BESS” or 
the “Project”) on approximately 10.5 acres located generally at the southeast corner of Cotton 
Lane and Olive Avenue in unincorporated Maricopa County, otherwise identified by Maricopa 
County Assessor (“MCA”) Parcel Number (“APN”) 501-05-005S and portions of APNs 501-05-
005U, 501-05-005R, and 501-05-005M (collectively, the “Site”) (see Exhibit A – Aerial Vicinity 
Map attached hereto). A lot division and combination application will be submitted under a 
separate cover to align the desired property line configuration needed to facilitate the 
proposed Project as illustrated in Exhibit A. 
  
Battery Energy Storage Systems (“BESS”) such as the proposed Project are a necessary 
part of a modern and robust power network.  The proposed facility is capable of storing enough 
electricity to power over 80,000 homes and businesses in the valley for four hours. The Project 
will serve the electrical grid in multiple ways including immediate power for ‘peak’ demand on 
hot days, back-up energy to reduce/avoid blackouts, increased grid resiliency, near-
instantaneous response to changes in renewable energy generation that help integrate and 
balance intermittent renewable sources, and storage of excess solar power to be used after the 
sun goes down. 
Purpose of Request 
 
The Site is currently zoned Intermediate Commercial (“C-2”) and is located within 
Maricopa County’s White Tank/Grand Avenue Area Plan which designates the Site as “Rural 
Densities (0-1)” and within the Olive Avenue Scenic Corridor Plan which designates the Site as 
“Dev. Master Plan”. The Site is also located within the General Plan planning area of the City of 
Glendale, which designates the Site as “Regional Mixed Use”. 
 
The purpose of this request is to pursue approval of a Zone Change with Overlay from 
“C-2” to Light Industrial (“IND-2”) with a corresponding Industrial Unit Plan of Development 
(“IUPD”) to allow for the development of the proposed BESS on the Site.

Description of Proposal  
BESS Use & Equipment 
 
 
The requested Zone Change would specifically provide for the development of a new 
BESS on the Site.  The proposed IUPD will then restrict the permitted uses on the Site to only 
those that provide for the proposed BESS use as indicated in Table 1: Permitted Uses below as 
well as to allow the existing billboard located at the southeast corner of the Site to remain in its 
current conditions. The use types described in Section 902.2.17 of the Maricopa County Zoning 
Ordinance (“MCZO”) have been determined by the County to include a BESS. Restricting the 
Site to these uses will prevent other uses that may be considered incompatible with the 
surrounding area from being constructed on the Site. Any uses not specifically allowed pursuant 
to MCZO Section 902.2.17 shall not be permitted. 
 
Table 1: Permitted Uses 
Base Zoning District 
Use Description 
IND-2 
MCZO Section 902.2.17: 
 
Public utility treatment and generating plants including sewage, 
wastewater, water, power, electrical, nuclear and solar, and including 
ancillary offices. Attendant facilities and appurtenances to the above 
uses as well as uses associated with service to the public of water, 
gas, telephone and cable television. Where an electrical generating 
plant is in operation, evaporation ponds and other appurtenances 
may 
be 
permitted 
provided 
such 
evaporation 
ponds 
or 
appurtenances are associated within the facility being served. 
 
Access to the Site will occur from Lawrence Lane via a 24’ wide secured access gate. The 
Project will consist of battery storage units located within enclosed cabinets mounted on 
outdoor concrete pads situated in rows (see Exhibit B – Example Battery Cabinets attached 
hereto). This “outdoor use” will require a deviation to the IND-2 development standards as 
noted in Table 2: IND-2 Development Standards Comparison below. Internal drives and fire 
lanes will provide maintenance and emergency response access to the entire Site, including the 
battery storage units and the private substation in the northwest portion of the Site (see 
Exhibit C– Site Plan attached hereto).   
 
The on-site private substation will be connected to the APS Parkway substation which 
will be located on the north side of Olive Ave, north of the Site and will be connected via the 
existing Palm Valley Transmission Line that runs along the entire length of the western 
boundary of the Site (North to South). The proximity of the Site to the planned APS substation 
will minimize the gen-tie length and amount of transmission infrastructure needed in the area 
minimizing impacts to the surrounding community and neighbors. This interconnection is a 
critical one for both the proposed Project and the APS electrical grid in multiple ways, 
potentially including immediate power for ‘peak’ demand on hot days, back-up energy to 
reduce/avoid blackouts, increased grid resiliency, near-instantaneous response to changes in

renewable energy generation that help integrate and balance intermittent renewable sources, 
and storage of excess solar power to be used after the sun goes down.  
On-Site Operations Areas 
 
 
The Project will be remotely operated and monitored on a 24/7-hour basis with only 
routine maintenance visits. Saguaro anticipates the long-term operational workforce will 
consist of a maximum of four (4) employees visiting every two (2) to three (3) months 
throughout any given year to perform routine maintenance and inspections. The crew normally 
consists of one operator, one contracted field engineer, and two mechanical or electrical 
technicians who arrive on-site together. These employees will continuously monitor the safety 
and operations of the Project and perform routine Project maintenance, as necessary. There 
will be no public access to the Site and no daily employees. 
Perimeter Screening 
 
 
The Site will be enclosed with an 8’ CMU block wall perimeter fence on its north, west, 
and south property lines to obscure the proposed facility from the adjacent residential and 
commercial uses. The proposed perimeter screening will require a deviation to the IND-2 
development standards as noted in Table 2: IND-2 Development Standards Comparison below. 
The east perimeter will maintain the current chain link fence already in place.  
On-Site Lighting 
 
Lighting will be limited to bollard lights at the Project entrance/exit and pole mounted 
lights around the on-site private substation in order to satisfy security needs. All lighting will 
meet MCZO requirements. 
Fire & Hazard Mitigation 
 
Saguaro has worked closely with Rural Metro to ensure that all fire suppression and 
other public safety measures and concerns are addressed for the Project. Each battery unit will 
be equipped with state-of-the-art remote detection and multiple shut down points to ensure 
that in the event of a safety incident a quick and safe response will take place. Rural Metro has 
reviewed the revised site plan and has issued a letter of support for the Project, which is 
attached as Exhibit D.  
 
The Project design includes a codified 173’ setbacks along the southern property line 
(residential) to all battery storage units. Fire hydrants are spaced throughout the Site to ensure 
every portion of the Site is within International Fire Code standards. A Fire Flow analysis has 
been completed since the last submittal to ensure adequate pressure is available for the 
Project. The complete analysis is attached as Exhibit E. The Site features excessive staging areas 
for first responders and will connect directly into the existing water line for fire suppression as

needed. Additionally, a formal Hazard Mitigation Analysis for the Project has been prepared 
and is attached hereto as Exhibit F.  
 
Proposed Development Standards 
 
 
 
The Site will comply with all general IND-2 base zoning district regulations. The 
proposed development standards for the Project, including two (2) minor deviations to the IND-
2 development standards, are outlined in Table 2: IND-2 Development Standards Comparison 
and described below. Additionally, the standards for the existing billboard are included in Table 
2. 
 
 
The first development standard deviation proposed for the Site is to provide for the 
BESS use and related activities to be conducted “outdoors”, outside of a completely enclosed 
building. MCZO Section 902.9.1 requires that all IND-2 uses except for parking, loading, 
unloading or storage be conducted within a completely enclosed building. While we believe the 
proposed BESS use is already very similar in nature to these exceptions, a specific deviation to 
allow the BESS use to be conducted outdoors is requested. 
 
 
 
The second development standard deviation proposed for the Site is a reduction in the 
amount of required parking. As noted above, the Site will be periodically visited by a team 
every two (2) to three (3) months and will arrive together. At a parking ratio of 1 space per 600 
SF for “industrial” (per MCZO Section 1102), the Site would require a total of 8 parking spaces. 
However, the Site is not open or accessible to the public and Saguaro will have a maximum of 
four (4) on-site employees. Saguaro is therefore proposing to provide a total of two (2) parking 
spaces (including one ADA accessible space), based on a ratio of 1 space per 750 SF for “office” 
and 1 space per 1,200 SF for “industrial”, which is more than sufficient for their on-site 
employees and operational needs. 
Table 2: IND-2 Development Standards Comparison 
Regulation 
Base Zoning District 
Regulations (IND-2) 
Proposed Zoning District 
Regulations (IND-2 IUPD) 
Maximum Height 
40' 
40’ 
Min. Front Yard (West) 
15’ (abutting collector street) 
90’ 
Min. Side Yard (North) 
5’ (adjacent to rural or 
residential zoning district) 
70’ 
Min. Side Yard (South) 
5’ (adjacent to rural or 
residential zoning district) 
173’ 
Min. Rear Yard (East) 
25' (abutting a rural or 
residential zoning district) 
126’ 
Minimum Lot Area 
6,000 sq ft 
6,000 sq ft 
Min. Lot Width 
60' 
60’

Maximum Lot Coverage 
60% 
60% 
Additional Regulations (MCZO 
Section 902.9.1) 
All uses except for parking, 
loading, unloading or storage 
shall be conducted within a 
completely enclosed building 
The activities and operations 
associated with the BESS use 
are not required to be 
conducted within a 
completely enclosed building 
Parking (MCZO Section 1102) 
Office: 1 space per 250 SF 
Industrial: 1 space per 600 SF 
2 spaces 
Handicapped 
Parking 
(MCZO 
Section 1102) 
5% of parking spaces shall be 
handicapped parking spaces. 
1 space (33%) 
Perimeter Screening 
(Side & Rear abutting a rural or 
residential zoning district)  
8’ masonry wall 
8’ masonry wall 
Perimeter Screening 
(not abutting a rural or 
residential zoning district)  
6’ masonry wall or fence with 
view obscuring material 
8’ chain link fence on east 
perimeter  
 
Billboard Standards 
Regulation 
Base Zoning District 
Regulations (IND-2) 
Proposed Zoning District 
Regulations (IND-2 IUPD) 
Max. Off-Site Sign Height 
30’ 
Max. 70’ on side directly 
abutting and oriented to or 
within 150’ of Loop 303. Max. 
45’ on side directly abutting 
and oriented to Cotton Lane 
Off-Site Sign Separation 
Distance 
1000’ 
Maximum 2 off-site signs 
oriented to or within 150’ of 
Loop 303 at minimum 700’ 
separation distance. 
Off-Site Signs 
Permitted 
Maximum of 2 off-site signs 
permitted on side directly 
abutting and oriented to Loop 
303. A maximum of 1 off-site 
sign permitted on side 
directly abutting and oriented 
to Cotton Lane and setback a 
minimum of 500’ from the 
centerline of Olive Avenue. 
No other off-site signs 
permitted. 
Off-Site Sign Max Size 
300 square feet 
672 square feet 
Min. Rear (East) Yard Setback 
(Only for parcel 501-05-006M) 
(billboard only) 
25’ 
0’ 
Min. Setback to RU-43 
(billboard only) 
100’ 
0’ East and North 
50’ South

Min. Setback to RU-43 for 
illuminated off-site sign 
150’ 
0’ East and North 
50’ South 
Min. 6’ height screening adjacent 
to rural or residential zoning 
boundary 
6’ height along residential 
zoning 
Zero screening unless POD 
submitted for use other than 
billboard or nursery 
 
Relationship to Surrounding Property  
 
 
The requested Zone Change is compatible with the surrounding land uses. BESS facilities 
offer multiple advantages that align well with residential communities. Firstly, BESS facilities do 
not generate significant daily traffic as they do not require frequent deliveries or a large 
number of on-site employees. This is particularly beneficial for residential areas where 
maintaining low traffic volumes is a priority. Additionally, BESS facilities operate quietly, 
utilizing advanced technology to ensure no noise is emitted from the use, making them 
unobtrusive neighbors. They also do not emit odors, ensuring the air quality remains unaffected 
for nearby residents, continuing the status quo for the surrounding neighbors.  
 
The operation of BESS facilities does not necessitate permanent on-site staff, minimizing 
activity on the Site and reducing any disruptions to neighboring residential areas. Furthermore, 
BESS units enhance the reliability of the electrical grid by storing energy and providing it during 
peak demand times or outages, contributing to a more stable and reliable power supply for 
residential areas and enhancing the overall quality of life. Modern BESS facilities are equipped 
with stringent safety measures, including fire suppression systems, regular maintenance, and 
monitoring, which mitigate potential risks and ensure the safety of surrounding areas. 
Additionally, the proposed BESS units create a sense of open space in the surrounding 
environment, reducing visual impact through landscaping and architectural features to ensure 
that the facilities do not detract from the aesthetic appeal of the adjacent residential 
neighborhood. 
 
The specific context of the site further supports the compatibility of the BESS project 
with surrounding land uses. The Site is bordered on the east by Loop 303, which acts as a buffer 
and provides separation from residential areas, and on the north by an existing commercial use, 
aligning with the less intrusive nature of BESS. To the west is a 100 ft transmission line corridor, 
which is a common placement for utility infrastructure and complements the function of a 
BESS, while to the south lies a residential community where the quiet, odorless, and low-traffic 
nature of BESS ensures minimal disruption to residents. Table 3: Surrounding Uses, 
Comprehensive Plan and Zoning Designations below provides a summary of existing and 
surrounding land uses.

Table 3: Surrounding Uses, Comprehensive Plan, & Zoning Designations 
 
Existing Land Uses 
Comprehensive Plan 
Zoning 
Jurisdiction 
Site 
Commercial 
White Tank/Grand Avenue Area Plan 
Rural Densities (0-1) 
C-2 
Maricopa 
County 
North 
Commercial  
White Tank/Grand Avenue Area Plan 
Rural Densities (0-1) 
C-2 
Maricopa 
County 
East 
Transportation  
(Loop 303) 
White Tank/Grand Avenue Area Plan 
Rural Densities (0-1) 
N/A 
Maricopa 
County 
South 
Residential   
White Tank/Grand Avenue Area Plan 
Rural Densities (0-1) 
R1-6 / 
RUPD 
Maricopa 
County & 
Avondale 
West 
Residential   
White Tank/Grand Avenue Area Plan 
Large Lot Residential (1-2) 
RU-43 / C-2 Maricopa 
County 
Location & Accessibility 
 
Access to the Site will occur from existing Lawrence Lane that connects directly to 
Cotton Lane.  Any necessary improvements and or widening of Lawrence Lane will be paid for 
and provided by Saguaro. Lawrence Lane will end at the entrance gate to the new BESS facility.  
Again, this Site is not open to the public so the entrance gate will be secured and only allow 
access to Saguaro maintenance crew and Emergency Responders. 
 
 
 The BESS use will generate virtually zero traffic and relatively low traffic volumes exist 
today on Cotton Lane and Olive Avenue. Because the Project has no frontage on Cotton Lane, 
right-of-way dedications and half-street improvements are not necessary and not anticipated 
with this Project as discussed with Maricopa County Department of Transportation (“MCDOT”). 
Circulation System 
 
 
As noted above, access to the Site will occur from Lawrence Lane, an existing private 
road that will connect to a gated entry at the Project boundary. A 26ft internal road will then 
allow employees and maintenance and emergency vehicles to access all areas of the Site, 
including the battery storage cabinets and the on-site electrical substation. The internal drives 
will allow for these vehicles to move safely around the site in a circular pattern, meeting all fire 
access width and turning radii requirements. 
Development Schedule 
 
 
The Project will begin site plan approval and permitting commencing after the County’s 
approval of the Zone Change. Construction will most likely begin in early 2026 and last for a 
period of approximately 12 months.

Community Facilities & Services 
 
 
As noted above, the proposed BESS use will not have any daily employees, only sporadic 
maintenance visits.  Additionally, the use is remotely operated with 24/7 observation; thus, the 
proposed BESS use will have no impact whatsoever on community facilities and services in the 
area such as schools, parks, libraries, etc. 
Public Utilities & Services  
 
 
Sewer:  
 
None Proposed. 
 
Water:  
 
EPCOR 
 
Refuse: 
 
None Proposed.  
 
Electric: 
 
APS 
 
Fire Protection: 
Rural Metro 
 
Police Service:  
Maricopa County Sheriff 
Compatibility with City of Glendale General Plan 
 
 
The Site is located within the City of Glendale’s planning area and is designated 
“Regional Mixed-Use” under the City’s General Plan, as is all the surrounding area on the East 
and West side of Loop 303. While the Site will not be a mixed-use project, is does further the 
City and County’s goals of developing the area as with cohesive, large‐scale, mixed‐use planned 
development fostering urban, multi‐modal opportunities as the proposed use will provide the 
necessary critical infrastructure needed for future development in the area. The proposed BESS 
provides critical energy infrastructure needed to support sustainable development and 
additional green infrastructure projects that are often incorporated into new developments. 
The proposed use will complement the envisioned future for the area as it is a quiet, non-
impactful, and non-traffic generating use services, a necessary function for the County and the 
City of Glendale. In order to ensure compatibility with the surrounding land uses (both existing 
and planned), the IUPD associated with this Zone Change request proposes to limit the 
permitted uses on the Site to those related to the BESS (see Table 1 above). 
Conclusion 
 
 
Approval of this rezoning request will allow the development of a much-needed 
sustainable energy support use in this area which complements the existing community. The 
Site is an ideal location for this use as it will connect directly into the existing Palm Valley 
Transmission line and provide direct support to the Parkway substation located on the north 
side of Olive Avenue.   BESS storage is a quiet neighbor and will not have any negative impacts 
to the surrounding uses. Rather it will support the continued development of the area and will 
complement any roof top solar installed by the surrounding neighborhoods. Saguaro is an 
experienced operator and will be a good partner in the local community as it continues to grow.

Exhibit “A” 
 
Aerial Vicinity Map

Exhibit “B” 
 
Example Battery Cabinets 
 
 
 
 
 
 
Rendering of the proposed Powin Centipede BESS enclosure. Photo courtesy of Powin.  
 
 
 
 
Rendering of the proposed Powin Centipede BESS system block. Photo courtesy of Powin.

Exhibit “C” 
 
Conceptual Site Plan

XX
XX
XX
XX
XX
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
PARCEL NO. 1
APN 501-05-006M
FAMILY FIRST INVESTMENTS LLC
DEED #20200412155
ZONING: C-2
PARCEL NO. 2A
APN 501-05-005R
FHF LLC
DEED #20210530444
ZONING: C-2
PARCEL NO. 3
APN 501-05-0055
DESERT FORREST NURSERY LLC
DEED #20230101265
ZONING: C-2
PARCEL NO. 4
APN 501-05-005U
CROMER LLC
DEED #20120230773
ZONING: C-2
APN 501-05-005L
COMER LLC
ZONING: RU-43
APN 501-05-005M
COMER LLC
ZONING: RU-43
APN 501-05-005N
CROMER LLC
ZONING: RU-43
APN 501-05-005G
FAMILY FIRST
INVESTMENTS LLC
ZONING: RU-43
APN 501-05-005D
DESERT FORREST NURSERY LLC
ZONING: RU-43
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
30' INGRESS/EGRESS
ESMT DOC 2006-729581
& BOOK 895 MAPS, PG 9
20' SEWER ESMT
DOC #2021-454610
100' ELEC ESMT
DOC #2005-1613945
60' x 60' BILLBOARD ESMT
RESTRICTED ACCESS
DOC #2017-1073662
8' ELEC ESMT PER
DOC 2022-701401
60' x 60' BILLBOARD ESMT
11' DRAINAGE ESMT
DOC 32020-445663
S
S
S
EXISTING DRAINAGE
GRATE (TYP.)
EXISTING FENCE
EXISTING BLOCK FENCE
EXISTING DRAINAGE
GRATE (TYP.)
EXISTING
BLOCK FENCE
EXISTING GATE
8' ELEC ESMT
PER DOC
#2022-701401
20' SETBACK
24'
24.00' (TYP)
PROPOSED IND-2 IUPD
SOUTH SIDE YARD SETBACK
(173')
15' VEGATATIVE BUFFER
20' SETBACK
4.0'
R25' (TYP.)
25' SETBACK
PROPOSED ONSITE
SUBSTATION
PROPOSED
CONTROL HOUSE
GRAVEL 24' PRIVATE DRIVEWAY AND FIRE LANE
PROPOSED 8' BLOCK
WALL FOR SCREENING
ALL PROPOSED VEHICULAR ACCESS GATES
SHALL BE PROVIDED WITH A FIRE
DEPARTMENT APPROVED LOCKING DEVICE
PROPOSED PROJECT BOUNDARY
W. ALICE AVE
W. LAWRENCE LN
(EXTENSION)
W. ALICE AVE
N. 168TH DR
W. ALICE AVE
PROPOSED RETENTION BASIN
EXISTING PARCEL BOUNDARY
PROPOSED AUXILIARY PAD
(20'X20') TYP
PROPOSED FIRE
HYDRANT (TYP.)
CONNECT PROJECT FIRE
WATER SUPPLY TO
EXISTING WATERLINE
PROPOSED PAVEMENT
EXTENSION OF LAWRENCE LN
PROPOSED 8' BLOCK
WALL FOR SCREENING
CONNECT TO EXISTING
W. LAWRENCE LN
PROPOSED SWALE
FLOWLINE (TYP.)
R25' (TYP.)
16' UTILITY
ACCESS
ROAD
5.0'
PROPOSED 9'X20'
PARKING
90'
185'
PROPOSED
RETENTION
BASIN
126'
91'
6 Executive Circle
Suite 200
Irvine, CA 92614
Phone: 949.727.9336
DATE:
DRAWN BY:
CHECKED BY:
APPROVED BY:
PROJECT:
PROJ. NO.:
TITLE:
REVISION
DATE
NO.
BY
APP'D.
SAGUARO BESS PROJECT
16835 W. OLIVE AVENUE
WADDELL, AZ 85355
563842
TSS
DG
SH
4/11/2024
SEAL:
DATE:
PROFESSIONAL ENGINEER:
6 Executive Circle
Suite 200
Irvine, CA 92614
Phone: 949.727.9336
DATE:
DRAWN BY:
CHECKED BY:
APPROVED BY:
PROJECT:
PROJ. NO.:
TITLE:
REVISION
DATE
NO.
BY
APP'D.
SAGUARO BESS PROJECT
16835 W. OLIVE AVENUE
WADDELL, AZ 85355
563842
TSS
DG
SH
4/11/2024
SEAL:
DATE:
PROFESSIONAL ENGINEER:
GRAPHIC SCALE
0
60'
1" = 60'
NORTH
SITE PLAN
 C-001
N
LEGEND
EXISTING MINOR CONTOUR
SIGN
MANHOLE
FIRE HYDRANT
STREET LIGHT
OVERHEAD ELECTRIC
OE
EASEMENT LINE
CHAIN LINK FENCE
X
PROPOSED TELCOM
LINE
TEL
PROPOSED SUBSTATION
CHAIN LINK FENCE
XX
XX
EDGE OF PAVEMENT /
CURB LINE AND GUTTER
SEWER MANHOLE
STORM DRAIN MANHOLE
W
PROPOSED ELECTRIC
LINE
PROPOSED WATER LINE
WATER VALVE
UTILITY BOX
UTILITY POLE
SIDEWALK
PROPOSED CHAIN LINK
FENCE
X
F
PROPOSED FIRE
HYDRANT
PROPOSED MAJOR CONTOUR
PROPOSED MINOR CONTOUR
EXISTING MAJOR CONTOUR
(SL)
(EP)
(WV)
(UB)
(UP)
(S/W)
(MH)
(OH)
ELECTRIC  MANHOLE
ELE
SD
UNKNOWN UTILITY
(UTIL)
CENTERLINE
PROPOSED SETBACK
PROPOSED
LANDSCAPE BUFFER
60'
VICINITY MAP
NTS
PROPOSED 8' BLOCK
WALL
PROPERTY
BOUNDARY
E
PROPOSED GRAVEL
DRIVEWAY
EXISTING
PROPOSED FIRE LINES
NOTE:
1.
BOUNDARY SURVEY CONDUCTED BY
LAND SURVEY SERVICES PLC (JULY
2023)
2.
PROPOSED STORAGE CAPACITY: 250
MW
3.
LOT SPLIT/COMBINATION WILL BE
COMPLETED AFTER REZONING
APPROVAL.
PROPOSED PAVED
ROAD EXTENSION

Exhibit “D” 
Rural Metro Support Letter

Rural Metro Fire Prevention 
Fire Marshal Kenneth Diamond 
Kenneth.Diamond@GMR.Net 
28353 E. Main St | San Tan Valley, AZ 85140 | (480) 869‐2340 
To:  
Ty Utton 
From:   Kenneth Diamond 
RE:  
Proposed BESS Project (Rezoning Case#: Z2024012) 
Date:   July 1, 2024 
 
 
To: Ty Utton 
  
Re: Proposed BESS Project (Rezoning Case#: Z2024012) 
   
We are writing to express our support for the proposed Battery Energy Storage System (BESS) rezoning 
project on the site located at the SEC of Olive Avenue and Cotton Lane. Rural Metro Fire Department 
Fire Prevention has thoroughly reviewed the site plan, including the fire flow tests and fire hydrant 
layouts, and we are pleased to confirm that we have no concerns regarding this development. 
The setbacks and road layout provided on the site plan meet our safety standards, and we are 
comfortable with the layout as proposed. Additionally, the proximity of the site to our station enhances 
our ability to respond promptly in case of any emergency, further supporting our confidence in the 
safety and feasibility of this project. 
We believe this development will be a beneficial addition to the area and are happy to provide our full 
support. Should you require any further information or assistance, please do not hesitate to contact us. 
 
Thank you!  
Kenneth Diamond 
Fire Marshal  
Fire Plans Examiner 
Central Arizona Fire Operations 
kenneth.diamond@gmr.net 
(480) 869‐2340

Exhibit “E” 
Fire Flow Analysis

Fire Flow Report  
Technical Memorandum  
 
 
 
 
Page 1 
Date: 
May 7, 2024 
To: 
Charles McGovern, Saguaro BESS, LLC 
From: 
Scott Horowitz, P.E. – Project Engineer 
CC: 
Dagmawi Geremew, P.E. – Project Manager 
Project: 563842.0DMS.0000 (TRC) 
Subject: Fire Flow Report 
Saguaro BESS Project 
Maricopa County, Arizona 
Introduction 
Saguaro BESS, LLC (Saguaro) is pursuing development of a 250MW battery energy 
storage system (BESS) in Maricopa County, Arizona. The Saguaro BESS (Site) is located 
south of W Olive Ave, East of N. Cotton Lane, and West of Loop 303 in Waddell, Arizona. 
The site intersects multiple parcels as shown in the location map in Figure 1. TRC 
Engineers, Inc. (TRC) was retained to perform a fire flow analysis to confirm the adequacy 
of proposed fire hydrants. This memorandum summarizes the findings of existing hydrant 
test results, hydraulic calculations, and analysis of proposed hydrants. 
 
Figure 1 (Location Map) 
 
 
W. DIANA AVE 
PROJET SITE 
W OLIVE AVE 
ARIZONA STATE RTE 303 
W. ALICE AVE 
N COTTON LN

Fire Flow Report  
Technical Memorandum 
 
 
 
 
Page 2 
Fire Flow Analysis 
Existing Fire Hydrant Flow Test 
Foothills Fire Protection, Inc. performed flow test of existing nearby fire hydrants as per 
the request of TRC. The location of tested hydrants are shown in Figure 2, and the result 
are shown in below:  
 
Figure 2 (Fire Hydrant Test Location Map)

Fire Flow Report  
Technical Memorandum 
 
 
 
 
Page 3 
 
 
 
 
Fire Hydrant Test Resluts

Fire Hydrant Flow Test Results
Project :
Date:
5/20/2024
Location:
Project #
24-053
Test Date:
Test Time:
Performed By:
Witnessed By:
Test Info:
Static
78 psi
Pitot
11  psi
Residual
48 psi
GPM
1,270 gpm
Pressure Drop
30 psi
Coefficient
0.80
Drop %
38.5%
Outlet Dia.
4
 in.
GPM @ 20 psi
1,812 gpm
GPM @ 0 psi
2,127 gpm
Hydrant #1
Hydrant #2
Saguaro Bess Project
16835 W. Olive Ave. - Waddell, AZ 85355
5/29/2024
FFPI
8:00a
EPCOR (E Coppinger)
0
10
20
30
40
50
60
70
80
90
0
500
1000
1500
2000
2500
Pressure (psi)
Flow (gpm)
CAUTION:  Results of this flow test identify water system characteristics for the date, time, and locations of this test only.  
Pressure and flows within the water system vary of time, it is expected and should be considered when preparing designs based upon fire flow test data.  
Numerous factors affect the water system, such as water level fluctuations in reservoirs, operating pressure ranges at booster pump stations, elevations at point of use, daily 
demand fluctuations, seasonal demands, emergency demands, water  treatment plant availability, increased demands due to growth, operation/maintenance schedules, etc.
AZ Cmrl. No. 111750
AZ Res. No. 111742
NM Lic. 363210
Foothills Fire Protection, Inc.
 7435 E. Karen Drive
Scottsdale, AZ 85260
(480) 951-3434
(480) 951-2299 (Fax)

Fire Flow Report  
Technical Memorandum 
 
 
 
 
Page 4 
Hydraulics Analysis 
Existing Water line 
The existing water main as shown in site plan Appendix A is as per the ALTA survey 
performed by Land Survey Service PLC. The pipe size of existing water line is unknown 
and the contractor will need to field verify pipe size, location, and flowline elevation during 
construction. 
Proposed Fire Water line 
The proposed water line will be 6 inch PVC pipe and will connect to the existing water 
main at two locations with ductile iron Tee fittings as shown in the site plan Appendix A. 
The proposed fire water line approximately 1,800 feet forms a turnaround loop along the 
proposed access road. The access road will be 26 feet wide with turning radius of 25 feet, 
which is adequate for allowing the ingress/egress of a pumper truck 8 feet in width and 40 
feet in length. An AutoCAD Vehicle tracking model of fire truck turning was prepared as 
shown in Appendix B. The proposed water line will include fire hydrants installed with 
maximum spacing of 500 feet. 
Proposed Fire Hydrant Flow Calculations: 
A proposed fire hydrant flow is estimated by using the nearby tested fire hydrants capacity. 
The proposed fire hydrant being analyzed is 1,540 feet apart from the tested fire hydrant 
(FH1), and 1,395 feet apart from the second tested fire hydrant (FH2). This fire hydrant 
was selected due to the elevation difference between it and the tested fire hydrants 
created presented with the worst case scenario for pressure. The existing water main pipe 
is assumed to be 8 inch with a flow rate of 1,270 gallons per minute (gpm) at 11 psi, the 
same can be anticipated at FH2. This pipe size and flow is also assumed for the proposed 
new fire hydrant. The total head loss of 13.74 psi (31.74ft) is calculated by using the 
Hazen-Williams equations. After considering major and minor head loss, the residual 
pressure of 64.59 psi is estimated at the proposed fire hydrant which is higher than 
the minimum residual pressure required by NFPA 291. The proposed fire hydrant 
fire flow at 20 psi is calculated to be 2,773 gpm.

Fire Flow Report  
Technical Memorandum 
 
 
 
 
Page 5 
Fire Flow Calculations: 
Tested Fire Hydrant (FH1) 
Static Pressure 
Ps1 
78 
psi 
Residual Pressure 
Pr1 
48 
psi 
Flow at 20 psi 
Q 
1,812 
gpm 
4.04 
ft3/sec 
Surface Elevation 
h1 
1,172.76 
ft 
Distance from Prop FH 
L1 
1540 
ft 
Tested Fire Hydrant (FH2) 
Pitot Pressure 
Pt 
11 
psi 
Flow at 11 psi 
QPt 
1,270 
gpm 
Outlet Diameter 
D 
4 
inch 
Coefficient 
Cd 
0.8 
Flow at 0 psi 
Q 
2,127 
gpm 
Ground Surface Elevation 
h2 
1,176.8 
ft 
Distance from Prop FH 
L2 
1,395 
ft 
Assumptions: 
Projected flow at  Proposed FH 
Q 
1270 
gpm 
2.83 
ft3/sec 
Water Main Pipe Diameter (Existing and Proposed) 
D 
8 
inch 
0.67 
ft 
Pipe C-Area 
A 
0.35 
ft2 
Velocity 
v 
8.11 
ft/sec 
Constants: 
Specific Weight of Water 
Ƴ 
62.4 
lbf/ft3 
Acceleration due to gravity 
g 
32.2 
ft/sec2 
Hazen William Coefficient 
C 
150 
  
Friction Head Loss 
Head Loss (Friction loss) per linear feet 
hf 
0.0094 
psi 
Total Friction Loss 
hf 
13.12 
psi 
Minor Loss 
Fitting Type 
C 
Qty 
  
90° Bend 
0.6 
2 
1.2 
Gate Valve 
0.2 
1 
0.2 
Total 
1.4 
Minor Loss (fittings) 
hfitting 
1.43 
ft 
0662 
psi 
Total Head Loss 
  
  
55.21 psi 
127.54 ft 
Proposed Fire Hydrant 
Ground Surface Elevation 
hp 
1172.01 
ft 
Static Pressure 
Ps2 
78.32 
psi 
Residual Pressure 
Pr2 
23.11 
psi 
Hr = Ps-20 
58.3 
psi 
Hf = Ps-Pr 
55.21 psi 
Flow Rate at 20 psi  
Qr 
2773 gpm

Fire Flow Report  
Technical Memorandum 
 
 
 
 
Page 6 
 
 
 
 
References 
 
1. NFPA 291, Recommended Practice for Fire Flow Testing AND Marking of 
Hydrants, 2019 edition.

Fire Flow Report  
Technical Memorandum 
 
 
 
 
Page 7 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Appendix A 
Site Plan

PARCEL NO. 1
APN 501-05-006M
FAMILY FIRST INVESTMENTS LLC
DEED #20200412155
ZONING: C-2
PARCEL NO. 2A
APN 501-05-005R
FHF LLC
DEED #20210530444
ZONING: C-2
PARCEL NO. 3
APN 501-05-0055
DESERT FORREST NURSERY LLC
DEED #20230101265
ZONING: C-2
PARCEL NO. 4
APN 501-05-005U
CROMER LLC
DEED #20120230773
ZONING: C-2
APN 501-05-006L
303 INVESTMENTS
ZONING: C-2
APN 501-050006Q
FHF LLC
ZONING: RU-43
APN 501-05-005L
COMER LLC
ZONING: RU-43
APN 501-05-005M
COMER LLC
ZONING: RU-43
APN 501-05-005N
CROMER LLC
ZONING: RU-43
APN 501-05-005G
FAMILY FIRST
INVESTMENTS LLC
ZONING: RU-43
05D
RSERY LLC
43
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
30' INGRESS/EGRESS
ESMT DOC 2006-729581
& BOOK 895 MAPS, PG 9
20' SEWER ESMT
DOC #2021-454610
100' ELEC ESMT
DOC #2005-1613945
60' x 60' BILLBOARD ESMT
ARIZONA D.O.T.
R/W CONDEMNATION
DOC #2013-1073662
RESTRICTED ACCESS
DOC #2017-1073662
8' ELEC ESMT PER
DOC 2022-701401
60' x 60' BILLBOARD ESMT
100' ELEC ESMT PER
DOC #2007-775338
MARICOPA COUNTY
R/W CONDEMNATION
DOC #2019-0244870
11' DRAINAGE ESMT
DOC 32020-445663
CORNERS FALL ON
CHAIN LINK FENCE
POSTS
8' ELEC ESMT
PER DOC
#2022-701401
XX
XX
XX
XX
XX
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
F
PROPOSED ONSITE
SUBSTATION
PROPOSED
CONTROL HOUSE
GRAVEL 24' PRIVATE DRIVEWAY AND FIRE LANE
PROPOSED PROJECT BOUNDARY
W. LAWRENCE LN
(EXTENSION)
PROPOSED RETENTION BASIN 1
EXISTING PARCEL BOUNDARY
PROPOSED
RETENTION
BASIN 2
EL = 1176.80
W
W
W
W
W
W
W
EL = 1172.76
EL = 1171.91
S
6 Executive Circle
Suite 200
Irvine, CA 92614
Phone: 949.727.9336
DATE:
DRAWN BY:
CHECKED BY:
APPROVED BY:
PROJECT:
PROJ. NO.:
TITLE:
REVISION
DATE
NO.
BY
APP'D.
SAGUARO BESS PROJECT
16835 W. OLIVE AVENUE
WADDELL, AZ 85355
563842
TSS
DG
SH
6/5/2024
SEAL:
DATE:
PROFESSIONAL ENGINEER:
6 Executive Circle
Suite 200
Irvine, CA 92614
Phone: 949.727.9336
DATE:
DRAWN BY:
CHECKED BY:
APPROVED BY:
PROJECT:
PROJ. NO.:
TITLE:
REVISION
DATE
NO.
BY
APP'D.
SAGUARO BESS PROJECT
16835 W. OLIVE AVENUE
WADDELL, AZ 85355
563842
TSS
DG
SH
6/5/2024
SEAL:
DATE:
PROFESSIONAL ENGINEER:
GRAPHIC SCALE
0
60'
1" = 60'
NORTH
FIRE FLOW EXHIBIT
 1
N
LEGEND
EXISTING MINOR CONTOUR
SIGN
MANHOLE
FIRE HYDRANT
STREET LIGHT
OVERHEAD ELECTRIC
PROPOSED FIRE
HYDRANT (TYP.)
CONNECT PROJECT FIRE
WATER SUPPLY TO
EXISTING WATERLINE
EXISTING WATER LINE
EXISTING FIRE HYDRANT (1)
STATIC = 78 PSI
RESIDUAL =  48 PSI
PRESSURE DROP = 30 PSI
DROP = 38.5%
GPM @ 20 PSI = 1,812 GPM
EXISTING FIRE HYDRANT (2)
PITOT = 11 PSI
GPM = 1,270 GPM
COEFFICIENT = 0.80
OUTLET DIA = 4 INCH
GPM @ 0 PSI = 2,127 GPM
OE
EASEMENT LINE
CHAIN LINK FENCE
X
PROPOSED TELCOM
LINE
TEL
PROPOSED SUBSTATION
CHAIN LINK FENCE
XX
XX
EDGE OF PAVEMENT /
CURB LINE AND GUTTER
SEWER MANHOLE
STORM DRAIN MANHOLE
F
PROPOSED ELECTRIC
LINE
PROPOSED WATER LINE
WATER VALVE
UTILITY BOX
UTILITY POLE
SIDEWALK
PROPOSED CHAIN LINK
FENCE
X
F
PROPOSED FIRE
HYDRANT
PROPOSED MAJOR CONTOUR
PROPOSED MINOR CONTOUR
EXISTING MAJOR CONTOUR
(SL)
(EP)
(WV)
(UB)
(UP)
(S/W)
(MH)
(OH)
ELECTRIC  MANHOLE
ELE
SD
UNKNOWN UTILITY
(UTIL)
CENTERLINE
PROPOSED SETBACK
PROPOSED
LANDSCAPE BUFFER
60'
VICINITY MAP
NTS
PROPOSED 8' BLOCK
WALL
PROPERTY
BOUNDARY
E
PROPOSED GRAVEL
DRIVEWAY
EXISTING
PROPOSED FIRE LINES
NOTE:
1. BOUNDARY SURVEY CONDUCTED BY
LAND SURVEY SERVICES PLC (JULY
2023)
2. PROPOSED STORAGE CAPACITY: 
250MW
3. LOT SPLIT/COMBINATION WILL BE
COMPLETED AFTER REZONING 
APPROVAL.
PROPOSED PAVED
ROAD EXTENSION
PL
PROPOSED PROPERTY
LINE
EXISTING SEWER LINE
EXISTING WATER LINE
W
DRAINAGE GRATE
these bends and a tee
should be included in the
head loss calculations
2,768.59 ft
are the bends to route under
these headwalls accounted for?
are the bends to route under
these pipes accounted for?

Fire Flow Report  
Technical Memorandum 
 
 
 
 
Page 8 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Appendix B 
Vehicle Tracking Exhibit

PARCEL NO. 1
APN 501-05-006M
FAMILY FIRST INVESTMENTS LLC
DEED #20200412155
ZONING: C-2
PARCEL NO. 2A
APN 501-05-005R
FHF LLC
DEED #20210530444
ZONING: C-2
PARCEL NO. 3
APN 501-05-0055
DESERT FORREST NURSERY LLC
DEED #20230101265
ZONING: C-2
PARCEL NO. 4
APN 501-05-005U
CROMER LLC
DEED #20120230773
ZONING: C-2
APN 501-05-006L
303 INVESTMENTS
ZONING: C-2
APN 501-050006Q
FHF LLC
ZONING: RU-43
APN 501-05-005L
COMER LLC
ZONING: RU-43
APN 501-05-005M
COMER LLC
ZONING: RU-43
APN 501-05-005N
CROMER LLC
ZONING: RU-43
APN 501-05-005G
FAMILY FIRST
INVESTMENTS LLC
ZONING: RU-43
05D
RSERY LLC
43
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
30' INGRESS/EGRESS
ESMT DOC 2006-729581
& BOOK 895 MAPS, PG 9
20' SEWER ESMT
DOC #2021-454610
100' ELEC ESMT
DOC #2005-1613945
60' x 60' BILLBOARD ESMT
ARIZONA D.O.T.
R/W CONDEMNATION
DOC #2013-1073662
RESTRICTED ACCESS
DOC #2017-1073662
8' ELEC ESMT PER
DOC 2022-701401
60' x 60' BILLBOARD ESMT
100' ELEC ESMT PER
DOC #2007-775338
MARICOPA COUNTY
R/W CONDEMNATION
DOC #2019-0244870
11' DRAINAGE ESMT
DOC 32020-445663
CORNERS FALL ON
CHAIN LINK FENCE
POSTS
8' ELEC ESMT
PER DOC
#2022-701401
XX
XX
XX
XX
XX
PROPOSED ONSITE
SUBSTATION
PROPOSED
CONTROL HOUSE
GRAVEL 24' PRIVATE DRIVEWAY AND FIRE LANE
PROPOSED PROJECT BOUNDARY
W. LAWRENCE LN
(EXTENSION)
PROPOSED RETENTION BASIN 1
EXISTING PARCEL BOUNDARY
PROPOSED
RETENTION
BASIN 2
Pumper Fire Truck
Pumper Fire Truck
Pumper Fire Truck
PUMPER FIRE TRUCK
OVERALL LENGTH = 40.0 FT
OVERALL WIDTH = 8.167 FT
OVERALL BODY HEIGHT = 7.745 FT
MIN BODY GROUND CLEARANCE = 0.656 FT
TRACK WIDTH = 8.167 FT
LOCK-TO-LOCK TIME = 5.00S
MAX WHEEL ANGLE = 45°
VEHICLE TRACKING
MODEL PATH #1
VEHICLE TRACKING
MODEL PATH #2
VEHICLE TRACKING
MODEL PATH #2
6 Executive Circle
Suite 200
Irvine, CA 92614
Phone: 949.727.9336
DATE:
DRAWN BY:
CHECKED BY:
APPROVED BY:
PROJECT:
PROJ. NO.:
TITLE:
REVISION
DATE
NO.
BY
APP'D.
SAGUARO BESS PROJECT
16835 W. OLIVE AVENUE
WADDELL, AZ 85355
563842
TSS
DG
SH
6/5/2024
SEAL:
DATE:
PROFESSIONAL ENGINEER:
6 Executive Circle
Suite 200
Irvine, CA 92614
Phone: 949.727.9336
DATE:
DRAWN BY:
CHECKED BY:
APPROVED BY:
PROJECT:
PROJ. NO.:
TITLE:
REVISION
DATE
NO.
BY
APP'D.
SAGUARO BESS PROJECT
16835 W. OLIVE AVENUE
WADDELL, AZ 85355
563842
TSS
DG
SH
6/5/2024
SEAL:
DATE:
PROFESSIONAL ENGINEER:
GRAPHIC SCALE
0
60'
1" = 60'
NORTH
VEHICLE TRACKING EXHIBIT
 1
N
LEGEND
EXISTING MINOR CONTOUR
SIGN
MANHOLE
FIRE HYDRANT
STREET LIGHT
OVERHEAD ELECTRIC
OE
EASEMENT LINE
CHAIN LINK FENCE
X
PROPOSED TELCOM
LINE
TEL
PROPOSED SUBSTATION
CHAIN LINK FENCE
XX
XX
EDGE OF PAVEMENT /
CURB LINE AND GUTTER
SEWER MANHOLE
STORM DRAIN MANHOLE
F
PROPOSED ELECTRIC
LINE
PROPOSED WATER LINE
WATER VALVE
UTILITY BOX
UTILITY POLE
SIDEWALK
PROPOSED CHAIN LINK
FENCE
X
F
PROPOSED FIRE
HYDRANT
PROPOSED MAJOR CONTOUR
PROPOSED MINOR CONTOUR
EXISTING MAJOR CONTOUR
(SL)
(EP)
(WV)
(UB)
(UP)
(S/W)
(MH)
(OH)
ELECTRIC  MANHOLE
ELE
SD
UNKNOWN UTILITY
(UTIL)
CENTERLINE
PROPOSED SETBACK
PROPOSED
LANDSCAPE BUFFER
60'
VICINITY MAP
NTS
PROPOSED 8' BLOCK
WALL
PROPERTY
BOUNDARY
E
PROPOSED GRAVEL
DRIVEWAY
EXISTING
PROPOSED FIRE LINES
NOTE:
1. BOUNDARY SURVEY CONDUCTED BY
LAND SURVEY SERVICES PLC (JULY
2023)
2. PROPOSED STORAGE CAPACITY: 
250MW
3. LOT SPLIT/COMBINATION WILL BE
COMPLETED AFTER REZONING 
APPROVAL.
PROPOSED PAVED
ROAD EXTENSION
PL
PROPOSED PROPERTY
LINE
EXISTING SEWER LINE
EXISTING WATER LINE
W
DRAINAGE GRATE
S
R25'
R25'
R25'
R25'
R25'
R26'
R25'
R25'
R25'
24'
24'
recommend showing
fire truck template and
vehicle information

Exhibit “F” 
Hazard Mitigation Plan

Page 
1 of 14 
 
 
 
AYPA POWER Proposal  
EMERGENCY RESPONSE PLAN 
 
SECTION 1 – GENERAL INFORMATION 
SecƟon 1.1 – Product Name 
XXXX Manufacturer 
SecƟon 1.2 – Owner and Operator 
AYPA Power 11801 Domain Blvd, Suite 450 AusƟn, TX 78758 
SecƟon 1.3 – Emergency Contact Number 
Emergency Contact 
Contact Number 
To be provided by AYPA once a ROC provided is onboarded. 
SecƟon 1.4 – Scope 
This document is an Emergency Response Plan (ERP) for the BESS facility. The scope of the ERP focuses 
on the hazards and response tacƟcs associated with BESS emergencies, and the failure of supporƟng 
electrical components resulƟng in class b/c fire hazards. The document also discusses post-fire 
operaƟons and provides disposal guidance. The project is under the jurisdicƟon of xxxx County. 
SecƟon 1.5 – Purpose 
The purpose of this emergency response plan is to provide an overview of the facility along with an 
explanaƟon of the equipment contained therein. The plan outlines failure scenarios, detecƟon 
capabiliƟes, system safety features, hazards and response tacƟcs that define the response posture 
associated with BESS emergencies and the failure of supporƟng electrical components. 
Canadian Solar SESS has fully integrated numerous safety soluƟons to manage the risk of first responders 
operaƟng at the scene of an energy storage system emergency. These designs have incorporated lessons 
learned, industry best pracƟces, research, and development efforts to conƟnuously enhance safety. 
SECTION 2 – DEFINITIONS 
SecƟon 2.1 Batery Management System (BMS) 
A system that monitors, controls, and opƟmizes performance of an individual or mulƟple batery 
modules in an energy storage system and has the ability to control the disconnecƟon of the module(s) 
from the system in the event of abnormal condiƟons. Each string of modules has a dedicated BMS at the 
rack level.

Page 
2 of 14 
 
 
 
AYPA POWER Proposal  
 
SecƟon 2.2 Local Controller 
The local controller is used for the communicaƟon integraƟon of different equipment in the energy 
storage system, faults and alarms management, parallel control of two or more energy storage inverters, 
the design offers one universal communicaƟon interface of the system. 
As shown in the following picture, the local controller collects and uploads the real-Ɵme informaƟon of 
PCSs, batery system and other equipment in the energy storage system through an ethernet 
connecƟon. At the same Ɵme, the Energy Management System (EMS) can control the storage system 
through the local controller. Within the control scope of the local controller, it processes the startup and 
shutdown procedure, protecƟons, and alarms. 
SecƟon 2.3 Cell 
The basic funcƟonal electrochemical unit contains an assembly of electrodes, electrolyte, separators, 
container, and terminals. It is a source of electrical energy by direct conversion of chemical energy. 
SecƟon 2.4 Module 
A subassembly which is a component of a BESS that consists of a group of cells or electrochemical 
capacitors connected together either in a series and/or parallel configuraƟon with or without protecƟve 
devices and monitoring circuitry. There are sixty-nine cells in each module. 
SecƟon 2.5 Batery Rack 
A batery rack is comprised of twenty-four modules. Modules are connected in series to produce the 
required usable voltage/potenƟal. 
SecƟon 2.6 BESS Container 
The BESS houses eight batery racks each with six modules. The voltage output of the container is 
1,324.8 VDC. The BMS exists at the string level within racks and provides autonomous oversight to 
disconnect strings or the container for condiƟons outside of the defined operaƟng parameters. This is 
achieved through the BMS contactor and a dedicated disconnect switch has been provided that allows 
the container to be electrically isolated from the facility. The container has been ouƞited with a liquid 
cooled thermal management system, fire detecƟon, gas detecƟon, and NFPA 69 venƟlaƟon system that 
is acƟvated upon 10% LEL for explosion control. E-Stops have been provided on the terminal ends of 
each container to facility an emergency shutdown if necessary. 
SecƟon 2.7 Medium Voltage Skid (MV Skid) 
An MV Skid is provided for each group of up to 6 BESS containers. Batery containers supply the inverter 
at 1,324.8 VDC. The inverter transforms DC from bateries to AC when discharging, and it turns AC from 
the grid to DC while charging. Power then passes through the step-up transformer where voltage is 
raised to 34,500V. Each MV Skid has an E-Stop, dedicated breaker with a disconnect switch and a ground.

Page 
3 of 14 
 
 
 
AYPA POWER Proposal  
SecƟon 2.8 E-Stop 
Emergency Stop’s or E-Stops are located locally on the terminal ends of each BESS container and there is 
one site level E-Stop as required by NFPA 855 that is capable of shuƫng down the enƟre facility. The site 
level E-Stop is located in the control enclosure or can be iniƟated remotely. The operaƟon of an E-Stop 
will stop the charging and discharging of bateries within the system. However, the operaƟon of an E-
Stop will not dissipate the electrical potenƟal remaining within the batery cells referred to as stranded 
energy. The operaƟon of a BESS Container e-stop will open the PCS Inverter breaker which will island the 
BESS Container. The MV Skid has also been provided with an E-Stop buton located 50 inches above 
grade. 
SecƟon 2.9 Cell VenƟng 
In this iniƟal stage of failure, a flammable electrolyte vents from the module in gaseous state. Based 
upon UL9540a tesƟng the criƟcal temperature where sustained venƟng begins is 147 C/297 F. Gas 
venƟng is oŌen a precursor of thermal runaway. 
SecƟon 2.10 Thermal Runaway 
The incident when an electrochemical cell’s temperature increases at an acceleraƟng rate in an 
uncontrollable fashion sufficient to result in damage to the cell. The thermal runaway progresses when 
the cell’s generaƟon of heat is at a higher rate than the heat it can dissipate. Based on UL9540a TesƟng 
Thermal Runaway begins at 150°C/302°F. 
SecƟon 2.11 Stranded Energy 
During an emergency at a BESS facility E-Stops may be operated to stop charging and discharging of 
modules. However, the E-Stop feature does not discharge the electrical potenƟal remaining in the 
cells/modules which is known as Stranded Energy. 
SecƟon 2.12 CriƟcal Temperatures 
Temperature plays a significant role in the health of bateries. Manufacturers provide thermal operaƟng 
guidelines and UL9540a tesƟng serves to inform on CriƟcal Temperature thresholds that result in cell 
venƟng and thermal runaway. 
SecƟon 2.13 Explosion Control  
•  
Explosion ProtecƟon by DeflagraƟon VenƟng (NFPA68): This standard applies to the design, 
locaƟon, installaƟon, maintenance, and use of devices and systems that vent the combusƟon gases and 
pressures resulƟng from a deflagraƟon within an enclosure so that structural and mechanical damage is 
minimized.  
•  
Explosion PrevenƟon Systems (NFPA 69): This standard provides requirements for installing 
systems for the prevenƟon and control of explosions in enclosures that contain flammable 
concentraƟons of flammable gases, vapors, mists, dusts, or hybrid mixtures.

Page 
4 of 14 
 
 
 
AYPA POWER Proposal  
SecƟon 2.14 AlternaƟng Current / Direct Current (AC/DC) 
Energy produced by the Modules can be categorized as DC. During electrical emergencies, the fire 
services tradiƟonally use non-contact voltage testers to idenƟfy energized equipment. It should be noted 
that non-contact voltage detectors cannot detect the presence of Direct Current (DC) and should never 
be used. 
SecƟon 2.15 BESS – Subject Mater Expert 
The code requires the facility owner/operator to designate and train staff to respond 24/7 within a 
Ɵmely manner to invesƟgate all batery energy storage system incidents. They will serve as the site 
subject mater expert (SME) and work closely with the fire services to invesƟgate and miƟgate condiƟons 
while ensuring the safety of fire service members operaƟng at the scene. 
SecƟon 2.16 Site Operator 
At the direcƟon of the BESS/SME the Site Operator will conduct or coordinate field switching to isolate 
equipment not automaƟcally isolated by the BMS. Switching may involve the operaƟon of breakers, 
disconnects and the applicaƟon of grounds to facilitate suppression, and inspecƟon. 
SECTION 3 – ENERGY STORAGE SYSTEM OVERVIEW 
SecƟon 3.1 Energy Storage System Concept 
Energy Storage Systems (green containers below) are charged from renewable energy such as wind, solar 
or to grid Ɵes. These systems can be charged at night when the cost to produce power is lower and 
discharged at peak loading Ɵmes during the day for grid sustainability. 
SECTION 4 – BATTERY MANAGEMENT SYSTEM 
The BMS has wide reaching oversight to control charging, discharging fault detecƟon and equipment 
isolaƟon. The BMS has design parameters that evaluate the state of charge & state of health for bateries 
along with criƟcal temperature thresholds that generate alarms accordingly. The system plays a key role 
in the Ɵmely response to system emergencies such as cell venƟng and thermal runaway. The BMS has 
the ability to isolate trouble modules or strings as necessary to miƟgate emergencies. The BMS exists at 
a rack level and system level for layered control. 
In order to make informed decisions during system emergencies the BMS should be reviewed with an 
emphasis on the state of charge for cells/modules on the trouble string. A full state of charge will 
increase the duraƟon of the emergency. In addiƟon, the temperature of cells will be an indicaƟon of fire 
propagaƟon within the trouble module or adjacent modules. 
SECTION 5 – FIRE PROTECTION SYSTEM 
SecƟon 5.1 Fire Alarm Panel (FACP) 
The site is provided with a tradiƟonal FACP that monitors the local fire alarm panels within the BESS 
enclosures. In this design these alarms can be seen from the FACP in the control enclosure or the graphic

Page 
5 of 14 
 
 
 
AYPA POWER Proposal  
annunciator at the main entrance. This system is monitored by a central staƟon and reports to the site 
SCADA system. 
SecƟon 5.2 Fire Alarm Annunciator 
A fire alarm graphic annunciator is provided at the gate entrance where the fire department will enter 
the facility. The annunciator will provide the fire alarm system status and indicate any zones that are in 
alarm or trouble. 
SecƟon 5.3 DetecƟon System 
•  
Smoke and Heat DetecƟon: BESS containers have been ouƞited with smoke and heat detecƟon. 
The generaƟon of smoke or heat within a container will generate a fire alarm. This will iniƟate the 
containers E-Stop interrupƟng the charging and discharging of cells/modules in the container, alert the 
fire department, and acƟvate noƟficaƟon appliances. 
H2 Gas DetecƟon: When Hydrogen Gas (H2) is detected and an alarm is generated, purge venƟng is 
acƟvated to maintain the concentraƟon of H2 gas under the LEL of 4% or 40,000PPM. Once purge 
venƟng begins all equipment within the container is remotely isolated through the BMS. 
o CombusƟble Gas Level 1: DetecƟon of combusƟble gas concentraƟons above 10% LEL will trigger a 
Level 1 alarm, sounding the audible alarm bell on the BESS container and stopping batery charging or 
discharging. The venƟlaƟon system controller will receive the signal and acƟvate the exhaust venƟlaƟon 
system, reducing concentraƟons of flammable gas within the BESS enclosure. An alarm indicaƟon is sent 
through the BMS system noƟfying the control room and UI of the operator. 
o CombusƟble Gas Level 2: DetecƟon of combusƟble gas concentraƟons above 20% LEL will trigger a 
Level 2 alarm, sounding the audible and visual noƟficaƟon device (horn strove) on the BESS system. A 
control signal is sent to isolate the affected BESS by opening all BMS contactors and turning off the 
auxiliary power. The venƟlaƟon system controller will receive the signal and acƟvate the exhaust 
venƟlaƟon system, reducing concentraƟons of flammable gas within the BESS enclosure. An alarm 
indicaƟon is sent through the BMS system noƟfying the control room and UI of the operator. 
o UPS Supply for NFPA 69 system: As required by code, upon the interrupƟon of auxiliary power 
supplying the NFPA 69 system a UPS back shall be provided with adequate capacity to operate the 
system for two hours. 
SECTION 6 HAZARDS  
SecƟon 6.1 Chemical  
This secƟon will outline the predominate chemicals hazards along with the recommended personal 
protecƟve equipment.  
SecƟon 6.1.1 Lithium-Ion Phosphate

Page 
6 of 14 
 
 
 
AYPA POWER Proposal  
Toxicity  
Gasses are evaluated during UL9540a Large Scale Fire TesƟng to idenƟfy the producƟon of IDLH 
condiƟons. Carbon Monoxide was the only target IDLH gas idenƟfied. The risk from Carbon Monoxide 
under this situaƟon does not pose a health hazard since the ESS Container cannot be occupied. In 
addiƟon, Carbon Monoxide is simply managed through AdministraƟve Controls such as staging upwind 
and engineering controls in the form of an SCBA to manage the respiratory hazard.  
Note: there is no dermal hazard posed by Carbon Monoxide.  
UL9540a Data  
Cells are ouƞited with a vent that ejects flammable electrolyte during elevated thermal condiƟons. This 
safety feature serves to manage the risk of internal pressurizaƟon resulƟng in a catastrophic failure. 
Lithium-Ion Phosphate (LFP) bateries are more stable than other batery chemistries and are less likely 
to undergo thermal runaway and are not suscepƟble to violent failures of the outer shell. Test data 
indicates that cell failure will not propagate beyond the module level. There was no indicaƟon of flying 
debris, explosive discharge of gas or sparks and electrical arcing. 
Hazards of Vented Electrolyte:  
Cell vent gas composiƟon will depend upon a number of factors, including cell composiƟon, cell state of 
charge, and the cause of cell venƟng. Vent gases may include volaƟle organic compounds (VOCs) such as 
alkyl-carbonates, methane, ethylene, and ethane; hydrogen gas; carbon dioxide; carbon monoxide; soot; 
and parƟculates containing oxides of nickel, aluminum, lithium, copper, and cobalt. AddiƟonally, 
phosphorus pentafluoride, POF3, and HF vapors may form. Vented gases may irritate the eyes, skin, and 
throat. Cell vent gases are typically hot; upon exit from a cell, vent gas temperatures can exceed 
600°C/1,110°F. Contact with hot gases can cause thermal burns. Vented electrolyte is flammable and 
may ignite on contact with a competent igniƟon source such as an open flame, flame, spark, or a 
sufficiently heated surface. Vented electrolyte may also ignite on contact with cells undergoing a thermal 
runaway reacƟon.  
Hazards of Leaked Electrolyte:  
Leaked electrolyte soluƟon is flammable and corrosive / irritaƟng to the eyes and skin. If a liquid is 
observed that is suspected electrolyte, venƟlate the area and avoid contact with the liquid unƟl a 
posiƟve idenƟficaƟon can be made and sufficient protecƟve equipment can be obtained (eye, skin, and 
respiratory protecƟon). Chemical classifier strips can be used to idenƟfy the spilled liquid (electrolyte will 
contain petroleum/organic solvent and fluoride compounds).  
SecƟon 6.1.2 Hydrogen  
When the temperature of a cell reaches the venƟng stage, the primary hazard is the producƟon of 
Hydrogen Gas (H2). The gas is odorless & colorless which requires internal sensors or external meters for 
detecƟon. It is an extremely flammable gas which is lighter than air. Any H2 Gas accumulaƟon within the 
Container will be found in the upper one-third of the unit. 
SecƟon 6.1.3 Carbon Monoxide

Page 
7 of 14 
 
 
 
AYPA POWER Proposal  
Carbon monoxide (CO) is an odorless, colorless flammable gas formed by the incomplete combusƟon of 
fuels. The failure and subsequent arcing /burning of electrical components and cables can readily 
produce Carbon Monoxide. Sampling for CO should begin at the upper one-third in a sealed enclosure as 
the gas tends to straƟfy based on its vapor density. 
SecƟon 6.1.4 Recommended PPE  
All chemicals associated with the failure of BESS equipment and ancillary electrical components present 
dermal and respiratory hazards. The failure of the BESS or electrical components can produce smoke and 
liquid runoff. The recommended PPE for the aforemenƟoned hazards is NFPA 1971 structural firefighƟng 
gear and the use of an SCBA. Note: The PPE recommendaƟon are for emergency response operaƟons/ 
life safety. PPE recommendaƟons for the post-fire removal of damaged modules will be defined by 
condiƟons found at the Ɵme of decommissioning. 
SecƟon 6.2 Electrical  
• 
Shock & ElectrocuƟon: These terms are oŌen misunderstood. Shock is an injury that can either 
be minor or major which results from inadvertent contact with an electrically energized object. Whereas 
electrocuƟon results in death from contact with an energized conductor. The difference between shock 
and electrocuƟon is defined by several factors such as how well the vicƟm was grounded which 
facilitates current flow through the body, the path the current flows such as across the heart or head, 
and duraƟon of contact with the energized object.  
• 
Non-Contact Voltage Tester: These devices are commonly used in the fire services to idenƟfy 
energized equipment/objects. However, the devices are only capable of idenƟfying equipment/objects 
energized by AlternaƟng Current (AC). To assess a surface for the presence of Direct Current (DC) a 
tradiƟonal meter will be required along with a ground reference. Note: Do not use a non-contact voltage 
detector at a BESS facility without guidance from a BESS subject mater expert.  
• 
Energized Equipment: Electrical equipment within the BESS Cabinet such as modules and cables 
can be energized. However, these components are shielded or insulated in a manner that there is no 
chance of shock or electrocuƟon from casual contact.  
• 
Equipment NOT Normally Energized: In a post fire scenario, protecƟve shielding or insulaƟon 
may be damaged resulƟng in equipment/objects that are not normally energized to become energized. 
Examples may be the metal container, batery racks and modules.  
• 
Stranded Energy: Electrical components such as transformers, breakers and cables can be made 
safe once the connecƟon to an energized electrical source has been interrupted. However, in the case of 
energy storage, the operaƟon of process safety stops will interrupt the charging and discharging of 
bateries but will NOT discharge the electrical potenƟal leŌ in the cells referred to as stranded energy.  
SecƟon 6.3 Explosion  
Flammable Gas: During cell venƟng, the prevalent flammable gas is Hydrogen. Hydrogen Gas (H2) is 
detected at 10% of the LEL or 0.4% / 4,000 PPM, at which Ɵme an alarm is generated. Purge venƟng is 
acƟvated at 10% of the LEL to maintain the concentraƟon of H2 gas under the LEL of 4% or 40,000PPM.

Page 
8 of 14 
 
 
 
AYPA POWER Proposal  
SECTION 7 NOTIFICATIONS  
SecƟon 7.1 NoƟficaƟon Flow 
 
SECTION 8 UNIFIED COMMAND  
SecƟon 8.1 Subject Mater Expert (SME)  
The BESS SME will play a criƟcal role guiding members of the fire services through the response posture 
associated with a BESS emergency. The SME will fall under the Unified Command structure where they 
will collaborate with members of the fire services to bring the incident under control. The SME will be 
responsible for coordinaƟng the following:  
• 
Review FACP  
• 
Review and interpret BMS data, such as gas alarms, module isolaƟon and cell temperature.  
• 
OperaƟon of E-Stops and Disconnect switches.  
• 
Coordinate Field Switching  
• 
Coordinate IsolaƟon of auxiliary power supply  
• 
If and when BESS Container doors should be opened  
• 
Recommended suppression agents.  
• 
Post-Incident OperaƟons  
• 
Administering Decommissioning Plan

Page 
9 of 14 
 
 
 
AYPA POWER Proposal  
SecƟon 8.2 Unified Command Structure  
Sample Unified Command Structure. Low frequency / high hazard incidents such as a BESS Emergency 
will not be managed by one individual Incident Commander. The command structure will include all the 
stakeholders necessary to miƟgate risk and ensure the safety of first responders. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Admin/Finance 
Chief 
 
LogisƟcs Chief 
Planning Chief 
OperaƟons Chief 
Public 
Information 
Officer 
FRA SME 
Remote 
Safety Officer 
Fire Department 
AYPA BESS SME 
Police Department

Page 
10 of 14 
 
 
 
AYPA POWER Proposal  
SecƟon 8.3 Incident Command Structure  
Sample Incident Command Structure 
 
 
SecƟon 9 – RESPONSE TACTICS  
SecƟon 9.1 Site Plan 
 
MAP 
 
 
 
 
 
Fire Dept 
Suppression 
BESS RestoraƟon 
Decommissioning 
Vendor 
Establish 
Decommissioning 
Area 
Insurance Carrier 
Establish 
Investigation Area 
BESS Engineering 
Field Switching 
Admin/Finance 
Chief 
LogisƟcs Chief 
 
Planning Chief 
OperaƟons Chief 
Public Information 
Officer 
CSI (SESS) Remote 
 
Safety Officer 
 
Fire Department 
AYPA BESS SME 
Police Department

Page 
11 of 14 
 
 
 
AYPA POWER Proposal  
SecƟon 9.2 EvacuaƟon  
Site Personnel: The BESS facility is not normally staffed, however, once an alarm is received all personnel 
shall exit the facility. They should proceed to the main entrance or predesignated rally point to conduct 
an accountability rollcall as required by OSHA 29 CFR 1910.38 or local regulaƟons. Upon arrival of the 
fire services, the primary concern is life safety. Note: Personnel should not re-enter the site unƟl the 
arrival of the fire department.  
SecƟon 9.3 Staging  
• 
Site Personnel: Personnel should not encroach within 100 feet of the Container that is in alarm 
mode when within the site walls.  
• 
Fire Department: Upon arrival, fire department units should stage all apparatus unƟl the scene 
size-up has been completed. Staging should be upwind at a minimum of 100 feet from the doors on the 
trouble container.  
• 
ConsideraƟon should be given to assigning a Staging Officer within the Incident Command 
Structure to manage parking. Impeding roadway traffic can have significant consequences if an injury 
were to occur and an ambulance could not access or leave the site.  
SecƟon 9.4 Personal ProtecƟve Equipment (PPE) 
•  
Electrical Switching: OSHA requires a hazard assessment under 29 CFR 1910.269 to idenƟfy FR 
clothing and insulated PPE required to conduct switching operaƟons. Follow relevant local regulaƟons 
for non-OSHA regulated countries. 
•  
Fire OperaƟons: Fire services personnel engaged in operaƟons that can expose members to 
heat, flame, flammable gas and chemical hazards shall use NFPA 1971 structural firefighƟng equipment 
along with an SCBA for respiratory protecƟon. 
SecƟon 9.5 Exposure Control 
•  
UL9540a Large Scale Fire TesƟng suggests that cell failure will not propagate beyond the module. 
In the remote event that a container becomes fully involved in fire, consideraƟon may be given to 
providing exposure protecƟon to adjacent BESS containers or MV Skids as required. During the 
applicaƟon of water streams for exposure protecƟon, the potenƟal exists to contact energized electrical 
components in the trouble container. 
SecƟon 9.6 Size-Up  
Status Briefing: Upon arrival, the fire officer will look for the BESS SME to obtain a status briefing which 
should provide a snapshot of exisƟng condiƟons and at a minimum should cover the following:  
• 
Accountability: Locate and evacuate all non-essenƟal site personnel.  
• 
Exclusion Zone: Establish an exclusion zone of 100 feet around the trouble container to manage 
the safety of members if an explosion should occur. Containers have been ouƞited with an explosion

Page 
12 of 14 
 
 
 
AYPA POWER Proposal  
control measure however, we must assume if this system was to fail the doors on the Container can be 
come projecƟles.  
• 
Exposures: Conduct a visual assessment to idenƟfy fire impingement on surrounding equipment, 
similar should be done with a thermal imaging gun and record temperatures. Reading should be taken 
every 15 minutes unƟl readings begin to decrease. UƟlize the BMS system to idenƟfy any rise in 
temperature of surrounding equipment that would require exposure control. Tank water from the 
apparatus may be applied in intermitent burst and should follow the guidance provided in Table 8.  
• 
Electrical Hazards: BESS/SME shall ensure the troubled equipment has been electrically isolated 
through SCADA or field switching.  
• 
Chemical Hazards: Stage all department members and apparatus upwind of the incident and 
remain cognizant of changing wind condiƟons and manage accordingly. A fully involved container can 
result in the failure of the thermal management system which will introduce freon into the fire scenario 
and discharge plume.  
• 
Batery Management System: BMS shall be reviewed to determine trending rise in temperature 
of cells/modules surrounding the trouble module. Temperature should be recorded and evaluated every 
15 minutes to determine if propagaƟon into adjacent modules has occurred.  
SecƟon 10 – POST INCIDENT OPERATIONS  
SecƟon 10.1 PPE  
While operaƟng near trouble equipment, the fire services personnel should remain in NFPA 1971 
structural firefighƟng gear with respiratory protecƟon and facility personnel should don the appropriate 
PPE for arc flash hazards associated with potenƟal stranded energy condiƟons and an SCBA unƟl a Post-
Fire Assessment has been completed.  
SecƟon 10.2 Lock Out / Tag Out  
Once emergency condiƟons have concluded, prior to accessing the trouble container or removing any 
modules. E-Stops and disconnect switches shall be locked or tagged out as required by OSHA 29 CFR 
1910.147 or local regulaƟons.  
SecƟon 10.3 Stray Voltage  
• 
DC/AC Stray Voltage: Prior to removing modules, the container enclosure, racks, and modules 
should be assessed for stray voltage. In the event that stray voltage is idenƟfied; standard response 
tacƟcs would focus on isolaƟng the source potenƟal. However, stranded energy may be the source of the 
stray voltage. In response, rubberized PPE outlined under 29 CFR 1910.269 or local electrical safety 
standards should be used unƟl the source of the stray voltage has been eliminated.  
• 
Stray Voltage TesƟng: To accurately assess this condiƟon a mulƟmeter must be used along with a 
ground reference.  
SecƟon 10.4 Thermal Exposure Assessment

Page 
13 of 14 
 
 
 
AYPA POWER Proposal  
• 
IniƟal Thermal Scan: Scan and record with a thermal imaging camera module temperature in 
each rack. The batery management system (BMS) will serve as an excellent guide in terms of evaluaƟng 
thermal impact on cells/modules within the trouble container. If this system is not viable use a thermal 
imaging camera.  
• 
Thermal Trending: Rescan and record every 15 minutes over the course of 1 hour to idenƟfy any 
rise in temperature above 20 F. Module(s) that have greater than a 20 F rise in temperature may have 
cells beginning to vent causing the increased temperature. If this condiƟon is observed, leave the area 
and stage upwind maintaining a 50-foot standoff distance. Let modules stand for 1-hour and rescan 
temperature.  
• 
End of Useful Life: Although Cells/Modules may not have reached a VenƟng or Thermal Runaway 
temperature we must evaluate Modules that were operaƟng outside their normal range. Modules that 
are beyond their useful life must be idenƟfied so that are not re-energized during the repair / 
restoraƟons process. Cells/Modules with temperatures above 40C/104F should be removed for disposal.  
SecƟon 10.5 Air Sampling  
• 
Air sampling will serve as an excellent indicator to determine if there is sƟll acƟve venƟng of cells 
within the BESS. The prevalent off gases observed during 9540a TesƟng are Hydrogen, Carbon Monoxide 
and Carbon Dioxide. The absence of those gases within the BESS container or the downward trending of 
gas concentraƟons would be an indicator that the situaƟon may be placed under control thus releasing 
the fire services and entering the decommissioning phase.

Page 
14 of 14 
 
 
 
AYPA POWER Proposal  
SecƟon 11 Training 
As required by code, training and familiarizaƟon tours should be conducted annually for members of 
the first response community along with BESS response personnel. The following topics should be 
covered in the training program: 
• 
System Overview 
o Equipment & DefiniƟons 
o Batery Types, Chemistry & Geometry 
• 
Batery Management System 
• 
DetecƟon & Suppression 
• 
Emergency System Shutdown 
• 
Hazards 
o Chemical 
o Electrical 
o Explosion (NFPA 68/69) 
• 
Suppression Agents 
o Product/Pattern/Pressure 
o Safe Standoff Distances 
o Agents & Fires 
o Exposure Control 
• 
Response TacƟcs 
o Module VenƟng/Fire 
o PCS Inverter Failure/Fire 
o Step-Up Transformer Fire 
o Breaker Failure 
• 
Post-Fire OperaƟons 
o Lock-Out Tag-Out 
o Stray Voltage TesƟng 
o Thermal Assessment 
o Air Monitoring

Page 1 of 1
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.gov
Planning & Development
Engineering Plan Review
Date:  
February 27, 2024
Memo To:
Darren Gerard, AICP, Planning Manager, Department of Planning & 
Development
Attn:
Joel Landis, Planner, Planning & Development Services
From:
Anh Harambasic, P.E., Engineering Reviewer, Planning & 
Development Services
cc:
Bob Fedorka, P.E., Engineering Manager, Planning & Development
Subject:  
Z2024012 - Zone Change with Overlay Battery Storage. From C-2 to 
Light Industrial (IND-2)
Job Site Address: SEC of Olive Avenue and Cotton Lane 
APN(s):
501-05-005S,501-05-005U,501-05-005R,501-05-005M
This application is to specify zoning with overlay for future development and does not 
include a Plan of Development.
PND Engineering Plan Review (DPR, FCD and PND Transportation) has reviewed the 
1st submittal of the Zone Change application routed for review and has no objections 
subject to the following conditions:
1. 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.
2. A traffic impact study must be submitted with future entitlement (POD or 
Preliminary Plat) application(s).
3. Engineering review of re-zone cases is conceptual in nature. All development and 
engineering design shall be in conformance with Section 1205 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.
Please contact me if you have any questions or require any additional information.

DATE:  
September 10, 2024 
 
TO: 
 Planning & Zoning Commission   
 
From: 
 Joel Landis, Planner  
 
SUBJECT: 
 Z2024012 – Saguaro BESS    
 
 Agenda Item: 6 
 
 
 
Since the publishing of the staff report, staff has conversed with the applicant regarding the 
proposed conditions of approval being presented to the Commission. Staff understands the 
applicant wishes to propose alternative conditions compared to what is the staff report. 
Therefore, this case will be moved to the regular agenda to allow for staff and applicant 
presentations. Additionally, staff has been provided an updated case map from our GIS team. 
 
The following is the proposed changes the applicant would like the Commission to consider: 
 
d. 
The following IND-2 IUPD zoning regulations will apply: 
 
2. Setbacks (minimums) 
i. Min. Front yard (west): 100’ 91’ 
ii. Min. Side yard (north): 100’ 70’ 
iii. Min. Side Yard (south): 100’ 173’ 
iv. Min. Rear Yard (east): 100’ 
v. Min. from existing, permitted residential uses: 500’ 173’ 
 
 
Attachments: 
 
Updated Case Map (1 page)

/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 31 approx.
Generated August 22, 2024 10:57 AM
Z2024012
Application Name:
Legal Description
Applicant
Case Address
Applicant Phone/Email
Parcel Primary:
Map scale 1:5,354
Supervisor District No.
Parkway BESS Facility
jhall@roselawgroup.com
16835 W Olive Ave. Wadell, AZ 85355
Jennifer Hall, Rose Law Group for 
Desert Forrest Nursery LLC. 
S36, T3N, R2W