CPA2020001 BOS REPORT.PDF

Maricopa County — Formal (2020-12-09)

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December 9, 2020 
CPA2020001 
Page 1 of 2 
Report to the Board of Supervisors 
Prepared by the Maricopa County Planning and Development Department 
 
 
 
Board Hearing Date: 
December 9, 2020 
 
Case #/Title:   
 
 
CPA2020001 – Sun Streams Expansion Solar Project 
 
Supervisor Districts: 
4 & 5 
 
Applicant:  
Sun Streams Expansion, LLC 
 
Owners: 
Arizona State Land Department, West Valley I, II, III & IV LTD 
Partnership 
 
Request: 
Major Comprehensive Plan Amendment (CPA) to change 
the land use designations in the Tonopah-Arlington Area Plan 
and the Old US Highway 80 Area Plan from Rural and Small 
Lot Residential to Utilities. CPA approval is by Resolution. 
 
Site Location: 
Generally located between the 323rd Ave. alignment to the 
east, 351st Ave. to the west, Union Pacific Railroad to the 
south, Southern Avenue to the north 
 
Site Size: 
Approx. 3,221 acres 
 
County Island Status: 
No 
Additional 
Comments: 
The 
applicant 
seeks 
a 
Major 
Comprehensive 
Plan 
Amendment to change land use designations in the 
Comprehensive Plan to utilities in order to develop a solar 
installation. The subject site is identified as having Rural and 
Small Lot Residential land uses in the Old U.S. Highway 80 Area 
Plan and Tonopah-Arlington Area Plan. The ASLD land 
(approx. 2,597 acres) is designated as Rural or as having a 
density of 1 dwelling unit or less per acre (0-1 d.u./ac.)  The six 
privately-owned parcels (approx. 624 acres) are designated 
as Small Lot Residential or as having a density of 2 to 5 
dwelling units per acre (2-5 d.u./ac.). Staff received four (4) 
letters from adjacent/internal jurisdictions (City of Buckeye, 
Town of Queen Creek, Pima County, Town of Carefree) 
expressing no concerns.  AZ Dept. of Game & Fish 
commented on the site regarding wildlife and hydrology.  
These comments will be considered during a zone change 
request.  Staff received five (5) letters of support and eight (8) 
opposition letters.  Concerns included aesthetics and 
property values.

December 9, 2020 
CPA2020001 
Page 2 of 2 
Commission  
 
Recommendation: 
On 11/5/20, the Commission voted 6-0 to recommend 
approval of CPA2020001 subject to conditions ‘a’ – ‘d’: 
  
a. 
Development and use of the site shall be in general compliance with the narrative 
report entitled “Sun Streams Expansion Solar Project” dated September 28, 2020 
and stamped received September 28, 2020, except as modified by the following 
conditions.  
 
b. 
Development and use of the site shall be in general compliance with the land use 
exhibit entitled “Sun Streams Expansion” dated October 5, 2020 and stamped 
received October 5, 2020, except as modified by the following conditions. 
 
c. 
The land use designation of utilities approved as part of case CPA2020001 shall be 
subject to the time limits set forth in the subsequent zone change. 
 
d. 
The applicant is proposing to develop a photovoltaic solar electric generating 
facility which, pursuant to the Maricopa County Comprehensive Plan, 
necessitates a change in the land use designation from Rural and Large Lot 
Residential to Utilities. The proposal by the applicant represents a comprehensive 
approach to the subject property and will allow the applicant to pursue the 
proper entitlements pursuant to state law so that they can lawfully operate in 
unincorporated Maricopa County. This particular proposal is an appropriate plan 
for the property and is consistent with the overall intention of the comprehensive 
plan. However, in the event that the zone change or a zone change phase for this 
particular proposal is not approved by Maricopa County Board of Supervisors 
(BOS) within five (5) years from the date of Board approval of this comprehensive 
plan amendment, this amendment shall no longer be effective as the planning 
justification for this comprehensive plan amendment will no longer be present. In 
such instance, a change of the land use designation from Utilities to Rural and 
Small Lot Residential will occur, and all comprehensive plan land use maps shall 
be altered to reflect as such, because this represents superior long-range planning 
by Maricopa County.  
 
 
Presented by: 
 
Adam Cannon, Planner 
Reviewed by: 
 
Darren Gerard, AICP, Planning Manager   
 
Attachments: 
 
11/5/20 P&Z Packet (101 pages) 
 
 
CPA2020001 Resolution (2 pages) 
 
 
CPA2020001 New Opposition Correspondence (6 pages) 
 
 
Note: 
11/5/20 Draft P&Z Minutes are not available as of the writing of this report, but can 
be provided upon request later when available.

CPA2020001 
Page 1 of 11 
Report to the Planning and Zoning Commission 
Prepared by the Maricopa County Planning and Development Department 
 
 
 
Case: 
CPA2020001 – Sun Streams Expansion Solar Project 
 
 
 
 
Hearing Date: 
November 5, 2020 
 
Supervisor Districts: 
4 & 5  
  
 
Applicant: 
Sun Streams Expansion, LLC 
 
Owners: 
Arizona State Land Department, West Valley I, II, III & IV LTD 
Partnership 
   
Request: 
Major Comprehensive Plan Amendment (CPA) to change the land 
use designations in the Tonopah-Arlington Area Plan and the 
Old US Highway 80 Area Plan from Rural and Small Lot 
Residential to Utilities 
 
  
 
Site Location: 
Generally located between the 323rd Ave. alignment to the 
east, 351st Ave. to the west, Union Pacific Railroad to the south, 
Southern Avenue to the north 
 
  
Site Size: 
Approx. 3,221 acres 
 
Density: 
N/A 
 
County Island:  
No 
 
 
County Plans: 
Tonopah Arlington Area Plan – Rural (0-1 d.u./ac.) and  
 
Old U.S. Highway 80 Area Plan - Rural (0-1 d.u./ac.) & Small Lot 
Residential (2-5 d.u./ac.) 
 
Municipal Plan: 
N/A 
 
Municipal Comments: 
Four (4) Letters – Pima County (1), City of Buckeye (1), Town of Queen 
Creek (1), Town of Carefree (1) – No Concerns 
 
Support/Opposition: 
Five (5) Support Letters, Two (2) Opposition Letters, Three (3) Neutral 
Letters 
 
Recommendation: 
Approve with conditions

CPA2020001 
Page 2 of 11 
Project Summary: 
 
1. 
Sun Streams Expansion, LLC is requesting a Major Comprehensive Plan Amendment 
(CPA) to change the land use designations in Tonopah-Arlington Area Plan and the Old 
US Highway 80 Area Plan from Rural and Small Lot Residential to Utilities to allow 
development of a utility-scale solar project generating approximately 385 megawatts 
(MWs) of electricity along with battery storage.  Due to the size of the project at 3,221 
acres, a Major CPA is required. The applicant will subsequently be required to obtain a 
Zone Change with Overlay (including a precise Plan of Development) to IND-2 IUPD as 
part of the entitlement process within five (5) years (on a phase or for the entirety of the 
development). As of the writing of this staff report, the applicant has made a Zone 
Change with Overlay request. 
 
2. 
The site is comprised of approximately 2,597 acres of contiguous ASLD land.  The 
remainder of the site is comprised of six (6) private contiguous parcels comprising 
approximately 624 acres. Most properties in the immediate vicinity of the project are 
privately owned. 
 
3. 
Nearly all land used for solar energy projects like this are developed for the large fields of 
solar collectors that capture the energy through photovoltaic technology. The subject 
site is relatively flat and allows for the development of solar energy with little or no 
additional grading. Washes are present on site and the applicant has committed to 
avoiding washes to the extent possible in conjunction with agency comments.  In 
addition, the general area contains significant local electrical infrastructure including 
power generation facilities (nuclear, gas, and solar), transmission lines, substations, and 
switchyards.   
 
4. 
Adjacent land uses include vacant, agricultural and/or rural residential uses.  In addition, 
there are a number of other approved Comprehensive Plan Amendments for solar 
energy generation in the near vicinity to the proposed project site, including existing and 
potential future Sun Streams Solar Farms, and the Mesquite Solar Farm. The APS Redhawk 
substation and Hassyampa Switchyard are also nearby. The gen-tie line associated with 
the project will connect to the existing Chukar Substation located adjacent to the 
Hassyampa Switchyard.  
 
5. 
The narrative asserts that the proposed development meets the Comprehensive Plan 
Amendment criteria in the following manner:  
 
Whether the amendment constitutes an overall improvement to the Comprehensive Plan 
and is not solely for the good or benefit of a particular landowner or owners at a particular 
point in time.  
 
The narrative states that the Sun Streams Expansion Solar Project will help in the 
furtherance of establishing Western Maricopa County as a leader in alternative energy 
research and development in consistency with the Comprehensive Plan’s strategies and 
policies to promote renewable energy production and use in the County.  The project 
will generate tax and lease revenue for state trust beneficiaries including public schools 
and has the potential to provide up to 800 construction jobs with above-average wages 
throughout a 2-year construction period.  The applicant will make efforts to hire 
individuals from the local area and region.  Thus, the amendment constitutes an overall

CPA2020001 
Page 3 of 11 
improvement to the Old U.S. Highway 80 Area Plan and the Tonopah/Arlington Area Plan 
and is not solely for the good or benefit of a particular landowner/owners at a particular 
point in time. 
 
Whether the amendment will adversely impact all or a portion of the planning area.  
 
A. 
Altering acceptable land use patterns to the detriment of the plan – According to 
the narrative, the amendment will not alter any surrounding land uses or land use 
patterns as the subject property has a similar land use pattern to other large-scale 
solar installations and energy utility installations in the area.  This type of energy 
production does not introduce high-intensity noise, traffic or air emissions or impact 
land for agricultural production. Moreover, it is situated near other solar 
developments and comprises a key use-sector of unincorporated Maricopa 
County including utilities (solar and electric generating stations), agriculture and 
rural-residential. 
 
B. 
Requiring public expenditures for larger or more expensive infrastructure - The 
narrative states that the project would not require public expenditures for larger 
or more expensive infrastructure.  The Sun Streams Expansion Solar Project shall be 
responsible for funding and developing any public infrastructure improvements 
necessary to serve the project. 
 
C. 
Requiring public improvements to roads, sewer, or water systems that are needed 
to support the planned land uses – The narrative asserts there would be no 
significant increase in traffic during the operational life of the project that would 
require road improvements. The project would also not require the development 
of any additional public water resources or sewer systems on the subject property 
or in the area in contrast to current uses.  Should public improvements be required, 
the Sun Streams Expansion Solar Project shall be responsible for funding and 
developing any public infrastructure improvements necessary to serve the project. 
 
D. 
Adversely impacting planned uses because of increased traffic – The narrative 
indicates there would be increased traffic during the construction period 
(approximately 24 months) for the delivery of equipment / supplies and the 
commuting of the construction work force, but there would be no significant 
increase in traffic during the operational life of the project.  The applicant included 
a traffic memo with their submittal; however, it will be reviewed as part of the Zone 
Change submittal.  With a small operational staff during the project’s operating 
life (approximately 8 employees), planned uses overall will not be adversely 
impacted. 
 
E. 
Affecting the livability of the area or health or safety of present and future residents 
– During the construction period, dust control measures shall be utilized to minimize 
fugitive dust generation.  Air emissions will occur from construction equipment; 
however, long-term air-quality will improve because of the project.  Additionally, 
the project will follow federal, state and local regulations regarding the 
production, use, storage, transport or disposal of hazardous materials.  Therefore, 
the project will not affect the livability of the area or health or safety of present 
and future residents.

CPA2020001 
Page 4 of 11 
F. 
Adversely impacting the natural environment or scenic quality of the area in 
contradiction to the plan – The applicant states that the project will not significantly 
impact the natural environment or overall scenic quality of the area.  There are 
key measures of responsibility that demonstrate an applicant’s commitment to 
avoiding adverse impacts to the natural environment and scenic quality of a site.  
These measures are subjective in a sense, but may include animals, plants, 
historical resources, scenic views and hydrology/ground disturbance.  
 
Animals 
The applicant has conducted pre-construction wildlife surveys to identify habitats 
for creatures.  The Arizona Game and Fish Department (AZGFD) has commented 
on the proposed project regarding measures to protect wildlife encountered on 
the site.  Satisfaction of those comments are only required at the Zone Change 
with Overlay stage (where a precise Plan of Development is required). Any night 
lighting that is used will be directed downward and shielded in order to prevent 
impacts to animals relying on darkness to interpret surroundings.  The applicant 
has also stated that transmission lines will be constructed in consultation with 
AZGFD to prevent electrocution of birds.   
 
Plants 
The applicant will salvage or dispose of protected native plants in accordance 
with AAC Title 3, Chapter 3, Article 11. 
 
 
Historical Resources 
As per State Historic Preservation Office requirements, the applicant has 
conducted a detailed cultural resources assessment for the site.  Per comments 
provided by David Jacobs of SHPO, SHPO found “no historic properties 
affected”.  The comments also stated that these comments are appropriate for 
a future zone change on the site.   
 
Scenic Views 
The narrative indicates that the solar fields will have a low-profile and will not be 
located near densely populated areas. Site improvements will be in keeping with 
other Sun Streams projects in the area. 
 
 
Hydrology/Ground Disturbance 
According to the narrative, hydrologic conditions will be preserved by avoiding 
major wash/drainage outlets to the extent possible and in accordance with 
agency requirements.  Grading will occur at appropriate slopes associated with 
the project and for other appropriate facilities.  The applicant does not anticipate 
a need for new roads. 
 
Whether the amendment is consistent with the overall intent of the Comprehensive Plan. 
 
The applicant’s narrative states that the request is consistent with the overall intent of the 
Comprehensive Plan by encouraging growth in suitable areas, developing an efficient 
transportation system, maintaining a healthy environment and creating a diverse 
economy.  The applicant feels that the utilities designation is consistent with the overall 
intent as it contributes to energy development growth in an appropriate part of the 
County, does not negatively affect the local transportation system and would help

CPA2020001 
Page 5 of 11 
provide direct economic benefit through jobs (approximately 800 construction jobs) and 
ASLD lease revenue. 
 
The extent to which the amendment is consistent with the specific goals and policies 
contained within the plan. 
 
The applicant’s narrative contains a substantial list of Goals and Policies from the Old U.S. 
Highway 80 Area Plan and the Tonopah/Arlington Area Plan. This staff report identifies 
which Goals and Policies the applicant’s narrative addressed. 
 
Old U.S. Highway 80 Area Plan 
 
Land Use – Goal L1, Objective L1.1, Policy L1.1.9, Objective L1.4, Policy L1.4.3 
 
Transportation – Policy T1.1.5, Policy T1.1.6, Policy T1.1.7 
 
Environment/Environmental Effects – Goal E1, Objective E1.1., Policy E1.1.1, Policy E1.1.2, 
Policy E1.1.6, Policy E1.1.7, Policy E1.1.8, Policy E1.2.4, Objective E1.3, Policy E1.3.3, 
Objective E1.4, Policy E1.4.1, Policy E1.4.2, Policy E1.4.3, Policy E1.4.4 
 
Economic Development – Goal ED1, Objective ED1.1, Policy ED1.1.1 
 
Growth Areas –Objective G1.2, Policy G1.2.3 
 
Open Space – Goal O1, Objective O1.3, Objective O1.6 
 
Water Resources – Goal W1, Goal W2 
 
Cost of Development – Goal C1 
 
Tonopah/Arlington Area Plan 
 
Land Use – Land Use Element Goal, Objective L.1, Policy L1.3, Policy L1.5, Policy L1.6, 
Policy L1.7, Objective L.2, Policy L2.2 
 
Transportation – Transportation Element Goal, Objective T.1, Policy T1.4, Policy T1.6 
 
Environment/Environmental Effects – Environment Element Goal 1, Environment Element 
Goal 2, Objective E1, Policy E1.1, Policy E1.2, Policy E1.3, Policy E1.5, Objective E2, Policy 
E2.1, Policy E2.2, Policy E2.3, Policy E2.4, Policy E2.6, Objective E3, Policy E3.1, Policy E3.5, 
Objective E4, Policy E4.1 
 
Economic Development – Economic Development Element Goal, Policy ED1.7 
 
Other pertinent information as requested by the Maricopa County Planning Department 
Staff. 
 
The applicant was responsive and provided quality information as requested by 
Maricopa County Planning Department Staff.

CPA2020001 
Page 6 of 11 
2020 Aerial Map 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Rural-43 Zoning Map & Surrounding Districts

CPA2020001 
Page 7 of 11 
 
Land Use Exhibit Excerpt 1 – Current Land Use – Rural & Small Lot Residential 
 
Land Use Exhibit Excerpt 2 – Proposed Land Use - Utilities

CPA2020001 
Page 8 of 11 
 
Existing On-Site and Adjacent Zoning / Land Use: 
 
6. 
On-site: 
 
Rural-43 / Vacant/Agricultural 
North: 
Rural-43 / Vacant/Agricultural with Scattered Rural Residential 
South: 
Rural-43 / Vacant/Agricultural 
East: 
Rural-43 / Vacant/Agricultural with Scattered Rural Residential 
West: 
Rural-43 / Vacant/Agricultural with Scattered Rural Residential 
 
 
Utilities and Services: 
 
7. 
Water: 
Private Well or Hauled Water 
Wastewater: 
Septic 
School Districts: 
Arlington Valley Elementary School District #47  
 
Buckeye Union High School District #1 
 
Saddle Mountain Unified School District #90 
Fire: 
Tonopah Valley Fire District 
Police:  
MCSO  
 
Right-of-Way: 
 
8. 
The following table includes existing and future right-of-way* and the future classification* 
based upon the Maricopa County Department of Transportation (MCDOT) Major Streets 
and Routes Plan.   
 
Street Name 
Existing R/W 
Proposed R/W* 
Future Classification* 
Salome Hwy 
80’ (full) 
130’ 
Minor Arterial 
Baseline Rd. 
0-65’ (half) 
65’ 
Minor Arterial 
Southern Ave. 
None Existing 
65’(half) 
Minor Collector 
Dobbins Rd. 
80’ (full) 
130’ 
Minor Arterial 
331st Ave. 
0’ - 55’ (half) 
65’ 
Minor Arterial 
339th Ave. 
0’ – 65’ (half) 
65’ 
Minor Arterial 
351st Ave. 
0’ – 55’ (half) 
65’ 
Minor Arterial 
 
*Required dedication and future classification of ROW is tentative and subject to change 
and will be established by MCDOT during a future Plan of Development review. 
 
Adopted Plans: 
 
9. 
Old U.S. Highway 80 Area Plan: The ASLD land is designated as Rural (0-1 d.u./ac.) and 
Small Lot Residential (2-5 d.u./ac.).  The six privately-owned parcels are designated as 
Small Lot Residential (2-5 d.u./ac.). 
 
10. 
Tonopah/Arlington Area Plan: The ASLD land is designated as Rural or as having a density 
of 1 dwelling unit or less per acre (0-1 d.u./ac.). 
 
Public Participation Summary: 
 
11. 
The applicant posted the subject site and staff notified all property owners within 300’ of 
the site.  Pursuant to state law, Staff issued enhanced notification letters to all adjacent 
and internal jurisdictions to Maricopa County, select state and regional agencies and

CPA2020001 
Page 9 of 11 
Luke Air Force Base. Staff received four (4) letters from adjacent/internal jurisdictions (City 
of Buckeye, Town of Queen Creek, Pima County, Town of Carefree) expressing no 
concerns.  Moreover, state agencies such as Arizona Game & Fish Department and SHPO 
issued comments.  Those comments have been included in the attachments section and 
are not actionable until a future Plan of Development stage. 
 
12. 
According to the Public Participations Results Report, the applicant conducted a virtual 
open house meeting on September 10, 2020.  There were 19 citizen attendees not 
including staff of the applicant.  The applicant received general questions related to 
project lifespan/decommissioning, property values, wildlife/pests, project fencing, heat 
increase and road use/repair.  Additionally, the applicant included a summary of their 
citizen contacts and the manner in which they responded to those questions. 
 
13. 
County Staff received five (5) support letters.  The first letter was from a law firm 
representing the owners of the privately owned parcels that comprise 624 acres of the 
subject site.  The support letter suggested that the project would result in increased 
property tax revenue, construction jobs and would provide emission-free energy to the 
state.  The second letter was from Deanna K. Kupcik, President/CEO of the Buckeye 
Valley Chamber of Commerce.  The letter noted that the “economic and social benefits 
of this project outweigh any perceived impacts”.  The three other support letters from 
Blount, McCarthy Building Companies and Nuclear Vision LLC expressed their support for 
the solar development and the potential jobs/economic benefits the development 
could provide.  
 
14. 
Staff received two (2) opposition letters.  The first letter was from a Mr. Dave Masch who 
had concerns with the aesthetics of the site and public notification.  County Staff gave 
process information to correct Mr. Masch’s assumptions.  County Staff did not receive a 
reply back and forwarded the contact information to the applicant.  The applicant also 
attempted to reach out to Mr. Masch, but were unsuccessful in receiving a reply back.  
Mr. Masch did not identify in his letter the location of his residence.  No further 
communications from Mr. Masch were received.  Mr. Masch was notified via his provided 
e-mail address of the date and time and virtual registration instructions for the Planning 
& Zoning Commission meeting.  The second opposition letter was from Shannon and Amir 
Seyeden and is concerned with property value diminution.  This letter came at the time 
of staff report finalization and was forwarded to the applicant.  Staff sent the individuals 
an acknowledgment and information about upcoming hearings. 
 
15. 
Additionally, staff was made aware of an individual potentially opposed to the project; 
however, Staff did not receive an opposition letter from this individual.  Staff forwarded 
the contact information of the individual to the applicant.  According to the Public 
Participation Results Report, the applicant contacted the individual and answered 
questions about the height and aesthetics of the solar panels. 
 
16. 
Staff received three (3) neutral information requests.  These requests did not indicate 
opposition and wanted more information about the project.  The applicant contacted 
both and answered their questions.   A third individual sent an information request and 
stated that they have questions.  The individual spoke with the applicant and answered 
questions about the case. 
 
Outstanding Concerns from Reviewing Agencies:

CPA2020001 
Page 10 of 11 
 
17. 
N/A 
 
Staff Analysis: 
 
18. 
The state and Maricopa County recognize the potential environmental and economic 
benefits that solar technology can provide.  The Sun Streams Expansion Solar Project will 
use photovoltaic technology that generates energy from sun absorption.  Photovoltaic 
technology differs from other models of solar electric generation that require vast 
amounts of water to cool the units.  In contrast, very little water is utilized for photovoltaic 
technology.  As a result, this development would not pose a threat to groundwater 
depletion.   
  
19. 
Staff believes the proposed solar facility is well suited to this rural area, which requires 
large amounts of relatively flat land.  The majority of the land is flat.  Staff agrees with the 
applicant that the subject site is suitable due to proximity to electrical transmission lines, 
nearby stations and substations, and because the surrounding area is vastly 
undeveloped.  Staff agrees with the applicant that the project will not detrimentally 
affect the visual quality of the area.  The applicant is willing to be a good neighbor as 
they expressed their willingness to work with AZGFD on wildlife preservation and have 
already received comments from SHPO indicating that there are “no historic properties 
affected” on the site following a survey submitted by the applicant.  Since the area is 
primarily undeveloped vacant land in near proximity to other existing utility-scale solar 
projects, staff believes there will be minimal impacts to the surrounding area. 
 
20. 
Promoting the development of solar energy over the past several years in Maricopa 
County reinforces the County’s interest in promoting the County as an economic leader 
for solar development. Staff believes the Sun Streams Expansion Solar Project would add 
to this effort in a positive way by providing the potential for 800 temporary construction 
and operation/maintenance jobs.  There will also be small number of long-term 
employment opportunities for County residents.  
 
21. 
Staff believes the Sun Streams Expansion Solar Project is consistent with and meets the 
goals and policies of the Comprehensive Plan. Staff’s position is that this project, as 
proposed and as governed by the recommended conditions, represent proper long-
term land use planning in the region and for Maricopa County as a whole. 
 
Recommendation: 
 
22. 
For the reasons outlined in this report, staff recommends the Commission motion for 
Approval, subject to conditions ‘a’ – ‘d’. 
 
a. 
Development and use of the site shall be in general compliance with the narrative 
report entitled “Sun Streams Expansion Solar Project” dated September 28, 2020 
and stamped received September 28, 2020, except as modified by the following 
conditions.  
 
b. 
Development and use of the site shall be in general compliance with the land use 
exhibit entitled “Sun Streams Expansion” dated October 5, 2020 and stamped 
received October 5, 2020, except as modified by the following conditions.

CPA2020001 
Page 11 of 11 
 
c. 
The land use designation of utilities approved as part of case CPA2020001 shall be 
subject to the time limits set forth in the subsequent zone change. 
 
d. 
The applicant is proposing to develop a photovoltaic solar electric generating 
facility which, pursuant to the Maricopa County Comprehensive Plan, 
necessitates a change in the land use designation from Rural and Large Lot 
Residential to Utilities. The proposal by the applicant represents a comprehensive 
approach to the subject property and will allow the applicant to pursue the 
proper entitlements pursuant to state law so that they can lawfully operate in 
unincorporated Maricopa County. This particular proposal is an appropriate plan 
for the property and is consistent with the overall intention of the comprehensive 
plan. However, in the event that the zone change or a zone change phase for this 
particular proposal is not approved by Maricopa County Board of Supervisors 
(BOS) within five (5) years from the date of Board approval of this comprehensive 
plan amendment, this amendment shall no longer be effective as the planning 
justification for this comprehensive plan amendment will no longer be present. In 
such instance, a change of the land use designation from Utilities to Rural and 
Small Lot Residential will occur, and all comprehensive plan land use maps shall 
be altered to reflect as such, because this represents superior long-range planning 
by Maricopa County.  
 
Presented by: 
Adam Cannon, Planner 
Reviewed by: 
Matthew Holm, AICP, Planning Supervisor 
 
Attachments: 
Case Map (1 page) 
 
Land Use Exhibit (reduced 8.5”x11”, 2 pages) 
 
Legal Description for ASLD Land (1 page) 
 
Narrative Report (55 pages) 
 
AZGFD Comments (2 pages) 
 
SHPO Comments (2 pages) 
 
MCESD comments (1 page) 
 
MCDOT Comments (2 pages) 
 
ADOT ROW Project Management Comments (1 page) 
 
ASLD Letter (2 pages) 
 
Town of Queen Creek Comments (1 page) 
 
Pima County Comments (1 page) 
 
City of Buckeye Comments (2 pages) 
 
Town of Carefree Comments (1 page) 
 
Support Correspondence (6 pages) 
 
Opposition Correspondence (4 pages) 
 
Neutral Correspondence (6 pages)

MARICOPA COUNTY
/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 3221 approx.
 
Generated October 16, 2020 13:25 PM
CPA2020001
Application Name:
Legal Description
SUN STREAMS EXPANSION SOLAR PROJECT
Applicant
Case Address
, T1N R05W 32, T1N R05W 33, T1N R05W 34, T1S R05W 04, T1S R05W 09, T1S R05W 17, T1S R05W 18
RANDY SCHROEDER for ENVALUE
   
Applicant Phone/Email
Parcel Primary:
303.819.3313
RSCHROEDER@ENVALUE.US
  
Map scale 1:45,742
Supervisor District No.
SUN STREAMS EXPANSION SOLAR PROJECT

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S.P.R.R.
Sun Streams Expansion
Industrial
Rural Densities (0-1)
Small Lot Residential (2-5)
Rural Densities (0-1)
Large Lot Residential (1-2)
Industrial
W Southern Ave
W Southern Ave
W Southern Ave
W Salome Hwy
Dobbins Rd
331st Ave
Baseline Rd
355th Ave
351st Ave
339th Ave
Elliot Rd
Ward Rd
319th Ave
Old US Highway 80
351st Ave
Legend
Map
Extent
ARIZONA
Phoenix
Maricopa County
Author:  rnc
Date: 10.05.20
SUN STREAMS EXPANSION
Map Extent: Maricopa County, Arizona
LAND USE EXHIBIT 
EXISTING PLAN LAND USE
0
0.25
0.5
Miles
°
State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit:  Foot US
Planned Land Use
Railroad
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Existing 500 kV Transmission
 Line
Road
Rural Densities (0-1)
Small Lot Residential (2-5)
Large Lot Residential (1-2)
Industrial
Sun Streams Expansion
Boundary between Old US Highway
 80 and Tonopah/Arlington Plans
Tonopah/
Arlington
Area Plan
Old US
Highway 80
Area Plan
Case No:  CPA2020001
Date: 10/5/20

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S.P.R.R.
Sun Streams Expansion
Industrial
W Southern Ave
W Southern Ave
W Southern Ave
W Salome Hwy
Dobbins Rd
331st Ave
Baseline Rd
355th Ave
351st Ave
339th Ave
Elliot Rd
Ward Rd
319th Ave
Old US Highway 80
351st Ave
Legend
Map
Extent
ARIZONA
Phoenix
Maricopa County
Author:  rnc
Date: 08.31.20
SUN STREAMS EXPANSION
Map Extent: Maricopa County, Arizona
Proposed Land Use Designations
0
0.25
0.5
Miles
°
State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit:  Foot US
Planned Land Use
Railroad
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!
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Existing 500 kV Transmission
 Line
Road
Rural Densities (0-1)
Small Lot Residential (2-5)
Large Lot Residential (1-2)
Industrial
Sun Streams Expansion
Boundary between Old US Highway
 80 and Tonopah/Arlington Plans
Tonopah/
Arlington
Area Plan
Old US
Highway 80
Area Plan
Utilities

LEGAL DESCRIPTION OF SUN STREAMS EXPANSION PROPERTY 
SUBJECT TO ARIZONA STATE LANDS COMMERCIAL LEASE  
APPLICATION 03-120611 
 
 
The Land referred to herein below is situated in the County of Maricopa, State of Arizona, and is 
described as follows: 
 
 
ALL OF SECTION 32, TOWNSHIP 1 NORTH, RANGE 5 WEST OF THE GILA AND SALT RIVER BASE AND 
MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE NORTHWEST QUARTER AND THE SOUTH HALF OF SECTION 33, TOWNSHIP 1 NORTH, RANGE 5 
WEST OF THE GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE WEST HALF OF SECTION 34, TOWNSHIP 1 NORTH, RANGE 5 WEST OF THE GILA AND SALT RIVER 
BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE WEST HALF AND THAT PORTION OF THE NORTHEAST QUARTER, LYING SOUTH OF THE WEST 
SALOME HIGHWAY OF SECTION 4, TOWNSHIP 1 SOUTH, RANGE 5 WEST OF THE GILA AND SALT RIVER 
BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE NORTHWEST QUARTER AND THAT PORTION OF THE NORTHEAST QUARTER, LYING NORTH OF 
THE UPRR PROPERTY AND THAT PORTION OF THE SOUTH HALF OF SECTION 9, LYING NORTH OF THE 
UPRR PROPERTY, TOWNSHIP 1 SOUTH, RANGE 5 WEST OF THE GILA AND SALT RIVER BASE AND 
MERIDIAN, MARICOPA COUNTY, ARIZONA.  
 
THE WEST HALF OF THE EAST HALF OF SECTION 34, TOWNSHIP 1 NORTH, RANGE 5 WEST OF THE 
GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE EAST HALF OF THE SOUTHEAST QUARTER OF SECTION 34, TOWNSHIP 1 NORTH, RANGE 5 WEST 
OF THE GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THAT PORTION OF THE EAST HALF OF SECTION 18, TOWNSHIP 1 SOUTH, RANGE 5 WEST, OF THE 
GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA, THAT IS SITUATED 
NORTH OF THE UNION PACIFIC RAILROAD.

SUN STREAMS EXPANSION SOLAR PROJECT  
Application for a Major Comprehensive Plan Amendment 
CPA2020001 
Narrative Report 
Submitted by: 
Sun Streams Expansion, LLC 
Contact: Louis De Rosa 
833-367-7890
SunStreamsExpansion@firstsolar.com 
Submitted to: 
Maricopa County 
Planning and Development Department 
Initial Submittal: May 27, 2020 
Revised Date: September 2, 2020 
Revised Date: September 28, 2020

TABLE OF CONTENTS 
 
 
EXECUTIVE SUMMARY ................................................................................................................... 1 
Onsite and Regional Location ......................................................................................................... 1 
CPA Size and Description of Land Use Types by Acreages ............................................................. 2 
Roads and Transportation Systems Serving the Proposed Project ................................................ 3 
Suitability with Surrounding Land Uses .......................................................................................... 3 
Proposed Use ................................................................................................................................. 3 
 
NARRATIVE RESPONSE .................................................................................................................. 5 
Whether the Amendment Constitutes an Overall Improvement to the Comprehensive Plan  ..... 5 
Whether the Amendment Will Adversely Impact All or a Portion of the Planning Area ............... 6 
Whether the Amendment is Consistent with the Overall Intent of the Comprehensive Plan  ...... 7 
The Extent to Which the Amendment is Consistent with the Specific Goals and Policies 
Contained Within the Plans ............................................................................................................ 7 
 
OLD US HIGHWAY 80 AREA PLAN .................................................................................................. 8 
 
TONOPAH / ARLINGTON AREA PLAN .......................................................................................... 16 
 
Other Pertinent Information as Requested by the Maricopa County Staff.................................. 21 
 
 
                                                                                  FIGURES 
 
      
FIGURE 1 – Location of Comprehensive Plan Amendment 
FIGURE 2 – Existing CPA Area Exhibit 
FIGURE 3 – Existing Zoning Exhibit 
FIGURE 4 – Existing Land Ownership in the Project Vicinity 
FIGURE 5 – Roads Providing Access in the Project Area 
FIGURE 6 – Utility Uses in the Project Area 
 
 
 
 
                                                                                  APPENDICES 
 
 
Appendix A – Legal Description of Lands Included in the CPA 
Appendix B – Sensitive Species Review

1 
 
 
                                                          NARRATIVE REPORT 
                                Sun Streams Expansion Solar Project 
                                 Comprehensive Plan Amendment 
 
This narrative report addresses the required information to support the request for a Comprehensive 
Plan Amendment (CPA) for the Sun Streams Expansion Solar Project (Project), a photovoltaic (PV) solar 
energy facility with battery energy storage located on land in unincorporated western Maricopa County 
near the emerging energy generation core around the Palo Verde Nuclear Generating Station (PVNGS) 
area. This CPA request will facilitate the future rezoning request for the Project. 
 
EXECUTIVE SUMMARY 
 
The Sun Streams Expansion Project is located near Old US Highway 80, about 2 miles north/northwest of 
the community of Arlington in an area adjacent to industrially designated land. The Project is an 
extension of the existing solar and energy development in the area and would cover approximately 
3,221 acres including both Arizona State Trust Land (approximately 2,597 acres) and private land 
(approximately 624 acres). The general location is shown on Figure 1. 
 
This application requests a Major Comprehensive Plan Amendment (CPA) to change the current land use 
designation in two area plans - the Old U.S. Highway 80 Area Plan and the Tonopah/Arlington Area Plan - 
for the entire 3,221-acre Subject Property from the current designations of “Rural Densities (0-1 
d.u./acre)” and “Small Lot Residential (2-5 d.u./acre)” to “Utilities”. The lands that are the subject of this 
application are located within Sections 32, 33, and 34, Township 1 North, Range 5 West and Sections 4, 
8, 9, and 18, Township 1 South, Range 5 West. 
 
The proposed site for the Sun Streams Expansion Solar Project is east and north of the Sun Streams I 
through IV Solar projects which were approved by the Maricopa County Board of Supervisors (BOS) over 
the past couple of years. Figures 2 and 3 show the current planned land uses and zoning for the Sun 
Streams Expansion parcels and surrounding area and the Land Use Exhibit shows the land use categories 
that would result from approval of this CPA. 
 
ONSITE AND REGIONAL LOCATION 
 
The Sun Streams Expansion Project is located in a part of Maricopa County covered by two area plans: 
the “Tonopah/Arlington Area Plan” that was approved in 2000 and the “Old U.S. Highway 80 Area Plan” 
that was adopted in 2007. Prior to completion of the Old U.S. Highway 80 Area Plan in 2007, the Project 
area was entirely within the Arlington/Tonopah Area Plan planning area. Currently, the 
Arlington/Tonopah Area Plan Land Use Map covers the portions of the site north of Baseline Road and 
the Old U.S. Highway 80 Area Plan Land Use Map covers the southern portion of the site south of 
Baseline Road. 
 
Currently, most of both planning areas remain unincorporated, with the closest municipality being the 
City of Buckeye. There are few residences in the general area. According to the Old U.S. Highway 80 
Area Plan, the 1990 census showed a population of 800 increasing to 1,150 by the 2000 census for the

2 
 
 
Old U.S. Highway 80 Area Plan planning area and a population of 1,792 increasing to 2,666 for the 
Tonopah/Arlington Area Plan planning area. 
 
The subject property is located south of Southern Avenue, near the intersection of Salome Highway and 
339th Avenue, and north of Old US Highway 80. The Subject Property is about 2.75 miles east of the 
PVNGS. 
 
CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY ACREAGES 
 
Land ownership in the general area is a mix of private land, state land, and some federal land managed 
by the Bureau of Land Management (BLM). Most of the land in the immediate vicinity of the Sun 
Streams Expansion Project is under private and state ownership. Approximately 2,597 acres of the plan 
amendment area are state lands managed by the Arizona State Land Department (ASLD) and 
approximately 624 acres are private lands.  
 
This application requests a CPA to change the land use designations of the Old U.S. Highway 80 and 
Tonopah/Arlington Area Plans on approximately 3,221 acres from Rural Densities (0-1 d.u./acre) and 
Small Lot Residential (2-5 d.u./acre) to Utilities to support a future rezoning request for the proposed 
facility. More specifically, the request is for: 
 
• Approximately 2,503 acres from Rural Densities (0-1 d.u./acre) to Utilities 
• Approximately 718 acres from Small Lot Residential (2-5 d.u./acre) to Utilities 
 
Figure 2 shows the current land use designations in the Sun Streams Expansion Project area as currently 
designated in the Old U.S. Highway 80 Area Plan and Tonopah/Arlington Area Plan. The general legal 
description of the land included in this CPA application is:  
 
Township 1N Range 5W: 
 
• Section 32 
• W ½ and SE ¼ of Section 33 
• W ½, SE ¼, and W ½ NE ¼ of Section 34 
 
Township 1S Range 5W: 
 
• W ½, part of NE ¼ of Section 4 lying south of W Salome Hwy 
• All of Section 8 lying north of railroad 
• Part of N ½ and Part of SW ¼ of Section 9 lying north of railroad 
• Part of NE ¼ of Section 18 lying north of railroad                  
 
A more detailed legal description of the State and private lands included in this application are included 
in Appendix A. 
 
Figure 3 shows the current zoning designation for the area (RU-43).

3 
 
 
This application is authorized by ASLD and Sun Streams Expansion, LLC (Applicant) is in the process of 
obtaining the necessary lease for the State parcels from the ASLD and purchasing the privately-owned 
parcels for the Project. Figure 4 shows the land ownership in the project area. 
 
ROADS AND TRANSPORTATION SYSTEMS SERVING THE PROPOSED PROJECT 
 
Access to the Project site would be provided via existing public roads. Access to the northern portion of 
the site would be from 331st and 339th Avenues, Salome Highway, and Baseline Road. Access to the 
southern portion of the site would be from Salome Highway, 355th Avenue, Elliott Road, and Dobbins 
Road. These roads that would provide access are shown on Figure 5. Future development of the Project, 
like the other existing utilities projects in the area, will have little impact on these roadways as its peak 
daily trips would occur during construction activities, after which there will be very few full-time workers 
during operations. Trip generation from the Utilities land use category and proposed utility-scale solar 
project would be far less than that that generated by residential development that could occur under 
the current designation. 
 
SUITABILITY WITH SURROUNDING LAND USES 
 
Most of the land in the immediate vicinity of the Sun Streams Expansion Project are private and state 
land. The land use in this immediate area is rural with nearby large lot residential, small lot residential, 
and industrial uses. The utility / industrial uses include the Palo Verde Nuclear Generating Station 
(PVNGS), the existing Sun Streams I solar project, the approved Sun Streams II through IV solar projects, 
the Southern Pacific Railroad, and the Hassayampa Switching Station, along with the associated 
transmission lines and other needed infrastructure shown on Figure 6. The focus of the area on 
electrical energy production is clearly established by the presence of these facilities as well as the 
supporting power transmission lines and substations in the area. 
 
The broader area around the site includes additional rural, large lot residential, small lot residential, and 
utility uses including other solar projects and transmission lines, as well as agricultural and former 
agricultural properties some of which have been converted to open space through the conversion of 
water rights from agricultural use to industrial uses associated with the non-renewable power 
generation plants in the area. As a passive use with limited on-site staffing (once constructed), the 
proposed utility-scale solar project will be compatible with the other uses immediately to the west, 
utilizing existing electrical transmission facilities.  
 
PROPOSED USE 
 
The Applicant is proposing the development of the Sun Streams Expansion Project, a PV solar generation 
facility with energy storage and associated facilities. At this time, the Applicant estimates that the 
Project will generate approximately 385 megawatts (MWs) of solar generation and up to 385 MWs of 
battery storage. As it is planned to be built in a single phase, the Project would have this capacity for the 
designed 30-year lifetime of the Project. In general, the Sun Streams Expansion Project would occur on 
all the property identified in this application except in floodways, required setbacks, and any easements 
or other rights-of-way. 
 
The individual PV modules will be mounted on single axis trackers on steel support structures that are 
anchored to or driven into the ground. The Sun Streams Expansion Project would electrically

4 
 
 
interconnect via a new gen-tie line to the existing Chukar Substation located adjacent to the existing 
Hassayampa Switchyard. 
 
As with most PV solar facilities, there would be limited staffing during operations, with up to 8 employees 
expected to visit the site daily. Traffic generation would be minimal after construction is completed and 
there would be limited demand for water, as encouraged by the Comprehensive Plan’s Water Resources 
Policy #51.  
 
 
 
 
 
 
1 “Maricopa County supports low water use solar electric generating technologies’” (Page 100).

5 
 
 
NARRATIVE RESPONSE 
 
Below are responses to each of the Major Comprehensive Plan Amendment questions in the 
Comprehensive Plan Amendment Application Checklist (Checklist) that are relevant to this 
Comprehensive Plan Amendment request. Note that the Checklist question is provided in bold text, with 
the answer/response below each. 
 
WHETHER THE AMENDMENT CONSTITUTES AN OVERALL IMPROVEMENT TO THE COMPREHENSIVE 
PLAN AND IS NOT SOLELY FOR THE GOOD OR BENEFIT OF A PARTICULAR LANDOWNER OR OWNERS AT 
A PARTICULAR POINT IN TIME 
 
Amending the Old U.S. Highway 80 Area Plan and Tonopah/Arlington Area Plan to the Utilities Land Use 
designation furthers the broadly stated goals of each Plan as is described more fully in this narrative and 
consequently, is not solely for the benefit of a particular landowner at a particular point in time.   
Instead, the proposed amendment constitutes an improvement to the Comprehensive Plan and these 
Area Plans by revising the land use designations to align with the Plan goals.  Western Maricopa County 
continues to experience significant utility-scale solar energy development. The Sun Streams Expansion 
Project will further establish Western Maricopa County as leader in alternative energy research and 
development consistent with the Plan that includes strategies2 and policies3  to promote renewable 
energy development and use in the County. 
 
The land is not currently utilized for agricultural production and is an unlikely candidate for residential 
development in the foreseeable future given the lack of proximity to the necessary public infrastructure 
that would be necessary to facilitate such development. Further, the Utilities designation and 
subsequent rezoning to facilitate the solar development will, through the lease of State lands, generate 
needed revenue for the trust beneficiaries which includes public schools. 
 
Nearly all the land used for the proposed solar energy project would contain large fields of solar panels 
that capture the energy from the sun for conversion into electricity. This would be a passive use and 
would require very little water and very few operational personnel and associated traffic. Its low profile 
would minimize effects on views / vistas of the surrounding mountains. In addition, the Project is 
expected to provide up to 800 jobs at peak with above-average wages during the approximately 2-year 
construction period. The Project would make efforts to hire from the local area and surrounding region. 
The Project is expected to generate tax and annual lease revenues to the State Trust beneficiaries which 
includes public schools in Arizona. Collectively, these factors make it compatible with the rural and rural 
residential uses in the area and will benefit Western Maricopa as a whole. 
 
For the reasons described above and those described below, amending the Old U.S. Highway 80 Area 
Plan and the Tonopah/Arlington Area Plan to allow for the proposed use of the Subject Property for 
solar energy generation would constitute an improvement to each of the Area Plans and the overall 
Comprehensive Plan. 
 
2 “Attract solar and other alternative energy research and development to Maricopa County.” – Strategies, Page 
104 and “Encourage low water use solar electric generating technologies.” – Strategies, Page 99. 
3 “Economic Growth Policy #10: Maricopa County supports leveraging its solar resource potential to attract solar-
related industries and alternative energy research and development.” – Page 80 and “Water Resources Policy #5: 
Maricopa County supports low water use solar electric generating technologies.” – Page 100

6 
 
 
WHETHER THE AMENDMENT WILL ADVERSELY IMPACT ALL OR A PORTION OF THE PLANNING AREA 
BY: 
• 
Altering acceptable land use patterns to the detriment of the plan - The proposed amendment 
furthers the evolving Industrial and Utilities land use pattern emanating from the property’s 
proximity to the PVNGS and the U.P.R.R. as demonstrated on Figure 6.   The development of this 
area for large-scale solar energy use will continue a very low traffic-generating land use pattern 
consistent with the other adjacent and nearby energy and utility uses that are already 
designated for Utilities as solar sites. It would also be compatible with nearby rural-density 
residential and agricultural uses. 
• 
Requiring public expenditures for larger or more expensive infrastructure - The proposed use 
would not require any additional public infrastructure that would require public expenditures. 
The Project is expected to generate tax and annual lease revenues to the State Trust 
beneficiaries which includes public schools in Arizona. While no public improvements are 
expected, the Project shall be responsible for funding and developing any public infrastructure 
improvements necessary to serve the Project. 
• 
Requiring public improvements to roads, sewer, or water systems that are needed to support 
the planned land uses - There would be no significant increase in traffic during the operational 
life of the Sun Streams Expansion Solar Project that would require road improvements by the 
County. The Project would also not require the development of any public water resources or 
sewer systems on the Subject Property or in the area. This contrasts with the road, sewer, and 
water systems that would be required to develop the Property under the current Residential 
Land Use Designations. While no public improvements are expected, the Project shall be 
responsible for funding and developing any public infrastructure improvements necessary to 
serve the Project. 
• 
Adversely impacting planned uses because of increased traffic - There would be a short-term 
increased traffic during the construction period (expected to be approximately 24 months) for 
the delivery of equipment / supplies and the commuting of the construction work force. Once 
construction is completed, there would be no significant increase in traffic during the 
operational life of the Sun Streams Expansion Project beyond what exists today because of the 
small operational workforce required (approximately 8 workers).  This is outlined in the traffic 
statement included with the application.  
• 
Affecting the livability of the area or health and safety of present and future residents - The 
proposed use of the subject lands for solar energy generation would not impact the livability, 
health and safety of those individuals in the vicinity of the Sun Streams Expansion Project. It 
would not utilize or store hazardous materials. Any materials associated with the battery energy 
storage system would be contained within the system and not be regularly transported to/from 
the site. It would not generate significant emissions or have other potential negative effects on 
health and safety and could actually reduce fugitive dust emissions during operations compared 
to current undeveloped conditions. 
• 
Adversely Impacting the natural environment or scenic quality of the area in contradiction to 
the plan – Similar to the current Residential land use designations, the Utilities designation 
proposed will not contradict the environmental goals or scenic qualities of this area. There are 
no critical plant or wildlife habitats on the site or surrounding area (per data provided by AGFD 
and USFWS in Appendix B). As requested by AGFD, the applicant will conduct surveys for the 
western burrowing owl and, if present, work with the agencies to minimize impacts to this 
sensitive species. The proposed solar panel fields have a relatively low profile, would be located 
on relatively flat lands located low on the landscape, and would not be located near any densely

7 
 
 
populated areas. The Sun Streams Expansion Project would have areas where it would be 
adjacent to some local public roads, but site improvements are no taller than 13 feet similar to 
other development in the area.  
 
WHETHER THE AMENDMENT IS CONSISTENT WITH THE OVERALL INTENT OF THE COMPREHENSIVE 
PLAN 
 
The overall intent of the Comprehensive Plan is to promote healthy communities by encouraging growth 
in suitable areas, development of an efficient transportation system, maintaining a healthy 
environment, and creating a diverse economy. The proposed Utilities designation is consistent with that 
overall intent as it would contribute to the growth of energy development in an appropriate part of the 
County, would not negatively affect the local transportation system, would not have significant 
environmental impacts, and would help provide economic growth directly via jobs during construction 
and operations, as well as by providing funding (via the ASLD lease) that supports the state’s educational 
system (which enhances future statewide economic competitiveness). 
 
THE EXTENT TO WHICH THE AMENDMENT IS CONSISTENT WITH THE SPECIFIC GOALS AND POLICIES 
CONTAINED WITHIN THE PLAN 
 
The Utilities designation would be consistent with many of the goals, objectives, and policies identified 
in both Area Plans and the Comprehensive Plan. The relevant goals, objectives, and policies contained in 
both current plans are listed below followed by a description of how each is relevant to the proposed 
use and, if so, why it would be consistent.

8 
 
 
OLD U.S. HIGHWAY 80 AREA PLAN 
 
Land Use 
 
Goal L1: Promote efficient land development that is compatible with adjacent land uses, is well 
integrated with the transportation system, and is sensitive to the natural environment. 
 
The amendment would be consistent with this goal as it would be compatible with adjacent uses (large 
lot rural dwellings, agricultural and utility-scale solar-power production), would have no long-term 
effects on the transportation system  (minimal traffic generation), and would not result in significant 
effects to the natural environment as described in the sections above and below. 
 
Objective L1.1: Encourage orderly, efficient, and functional development patterns. 
 
The development contemplated by the amendment would complement the existing and planned 
development patterns in the area by further consolidating energy and utility uses and being compatible 
with the other primary uses in the area - utility designated lands used for solar and other forms of power 
generation and transmission.  
 
Policy L1.1.9: Encourage cooperation and coordination among the Arizona Department of 
Homeland Security, Maricopa County Department of Emergency Management, PVNGS, and 
other power plants to ensure security and compatibility with adjacent land uses and associated 
infrastructure. 
 
The proposed Sun Streams Expansion Project will work with Maricopa Emergency Management, 
PVNGS, as well as the regional utilities to ensure security and compatibility with nearby land uses 
and infrastructure.  By encouraging utility-scale development around PVNGS, the security 
opportunity is enhanced by reducing residential density in the vicinity. 
 
Objective L1.4: Preserve the scenic and where appropriate, the rural character of the Old U.S. Highway 
80 planning area. 
 
Solar energy development would not be expected to affect the visual quality of the area. The proposed 
PV solar panels have a relatively low profile and would be located on relatively flat lands located low on 
the landscape, so would not be expected to affect views of the local mountains. It would not be located 
near any population centers or heavily travelled roads in most areas. Because of the relatively remote 
nature of the site and the low profile of the proposed panels, the Project would not be expected to be 
visible from most areas. The proposed use would minimally significantly impact scenic quality.

9 
 
 
Policy L1.4.3: Discourage urban commercial, residential, industrial development in rural 
designated areas of the Old U.S. Highway 80 planning area. 
 
This area contains existing land uses that include several existing energy generation and 
transmission facilities in the area. Also, the proposed solar facility is a passive land use that would 
have minimal impact to surrounding properties. Energy-generation projects such as the proposed 
project have the potential to discourage urban-style commercial and residential uses by 
establishing areas of development with no density and minimal employee traffic. Also, at the end 
of its useful life (approximately 30 years), the facility could be decommissioned and the site 
transitioned to other rural land uses as appropriate at that time. 
 
Transportation 
 
Policy T1.1.5: Support the Maricopa County Major Streets and Routes Plan and its requirements for 
construction and dedication of roads. 
 
As required by Maricopa County Department of Transportation (MCDOT), efforts to obtain land 
preservation for roadways would be conducted during the rezoning process for the Project. 
 
Policy T1.1.6 Communicate and coordinate with the Maricopa County Department of Emergency 
Management regarding new development to ensure compatibility with PVNGS designated evacuation 
routes. 
 
The proposed Sun Streams Expansion Project will work with the County Department of Emergency 
Management and PVNGS to ensure compatibility with PVNGS evacuation routes.  Due to the low-traffic 
nature of the land use, the development of the Project will not contribute to congestion of evacuation 
routes. 
 
Policy T1.1.7: Encourage new development within 10 miles of PVNGS to coordinate with the 
Emergency Planning Department at PVNGS regarding its Outdoor Warning Siren System. The 
installation of additional sirens may be necessary. 
 
The proposed Sun Streams Expansion Project is within 3 miles of the PVNGS and will work with PVNGS to 
ensure safety and security. 
 
Environment / Environmental Effects 
 
Goal E1: Promote development that mitigates adverse environmental impacts on the natural and 
cultural environment, preserves highly valued wildlife habitat, minimizes flooding and drainage 
problems, and protects historical and archaeological resources. 
 
The proposed Utilities designation would have minimal impacts to the natural and cultural environment 
as the ground disturbance associated with the development of a solar field would help minimize flooding 
and drainage issues- especially when compared with the typical development patterns associated with 
residential development and lot-splitting that could occur in place of a comprehensive development 
pattern. According to data obtained from the Arizona Game and Fish Department (AGFD) and US Fish 
and Wildlife Service (USFWS) included in Appendix B of this report there is no identified critical or highly

10 
 
 
valued wildlife habitat on the subject lands. As requested by AGFD, the applicant will conduct surveys for 
the western burrowing owl and, if present, work with the agencies to minimize impacts to this sensitive 
species. Drainage and flooding patterns would be incorporated into final development plans to ensure 
that habitats are not negatively impacted and only minimal work will be required (i.e. for installation of 
crossings and minor erosion control). Based on cultural resource surveys. results of which have been 
provided to ASLD and the State Historic Preservation Office (SHPO), the subject lands also do not have 
significant historical or archaeological resources. 
 
Objective E1.1: Encourage development that is compatible with natural environmental features. 
The Property that is subject to the proposed amendment does not contain significant natural features. 
The most prominent natural features in the Project area are the drainage ways that cross the site and 
the larger of these would be avoided by development. 
 
Policy E1.1.1: Encourage land uses and development designs that are compatible with 
environmentally sensitive areas such as the Palo Verde-Saguaro community, floodplains, 
significant washes, hillsides, protected wildlife species habitat, scenic areas, and unstable 
geologic and soil conditions. 
 
The subject properties do not contain the environmentally sensitive areas listed below: 
• 
The Palo Verde-Saguaro community does not occur in the area (per Figure 12 of the 
Tonopah – Arlington Area Plan),  
• 
There are no hillsides (per Figure 10 of the Tonopah – Arlington Area Plan),  
• 
There is no protected wildlife species habitat (per data provided by AGFD and USFWS in 
Appendix B), 
• 
There are no designated scenic areas on or near the project site,  
• 
There are no unstable geologic and soil conditions – according to Figure 10 of the Old US 
Highway Area Plan, soils in the project area are part of the Gunsight-Rillito-Chuckawalla 
Association which are deep and moderately deep, moderately drained, nearly level, 
gravelly to extremely gravelly, loamy soils.  
 
The site does contain larger drainages (washes with corresponding floodways) on the subject 
properties and these would for the most part be avoided by development.  
 
Policy E1.1.2: Encourage building envelopes and localized grading to minimize blading and cut 
and fill in environmentally sensitive areas and leave the remaining portion of the lot 
undisturbed. 
 
Proposed development would not occur in sensitive areas. All lands planned for development are 
relatively flat which will minimize necessary grading.   
 
Policy E1.1.6: Encourage the preservation of washes in their natural state. 
 
The largest of the washes on site would be avoided and left in their natural state to the extent 
possible. Development would not occur within the floodways and most of floodplains as will be 
detailed in the upcoming plan of development to be submitted as part of the rezoning / IUPD for 
Project. If any work is necessary in small parts of the floodplains, appropriate approvals would be

11 
 
 
obtained from the Maricopa County Flood Control District and will be developed in accordance 
with applicable regulations. 
 
Policy E1.1.7: Edges of major washes or rivers should remain undisturbed. 
 
The largest of the washes on site would be avoided and left in their natural state to the extent 
possible as will be shown on the upcoming plan of development site plan to be submitted as part 
of the rezoning / IUPD for Project. Development within the floodways and most of floodplains 
would be avoided. If any work is necessary in small parts of the floodplains, appropriate approvals 
would be obtained from the Maricopa County Flood Control District. 
 
Policy E1.1.8: Encourage property owners to consult with the Maricopa County Planning & 
Development Drainage Review division prior to land division to adequately plan for local 
washes and landforms. 
 
The development on the Subject Property would be subject to all applicable requirements of the 
Drainage Review Division and Maricopa County Flood Control District and the Utilities designation 
will discourage the possibility of future “wildcat” subdivisions. 
 
 
Policy E1.2.4: Prior to development, excavation, or grading, request that developers submit a 
letter from the Arizona Historic Preservation Officer stating that the proposed land 
development will have no effect on historical or cultural resources. 
 
No significant historical resources are expected on the Subject Property based on cultural resource 
surveys. Results of these surveys have been provided to the SHPO via the ASLD as part of the ASLD 
leasing process. Both agencies will review the report to ensure that the proposed land 
development will have no effect on historical or cultural resources. 
 
Objective E1.3: Improve air quality, water quality, and reduce noise impacts. 
 
This proposed amendment would be expected to result in improved air quality relative to fugitive dust 
emissions. Air quality impacts from fugitive dust emissions from the subject lands would occur during 
construction but could be lessened from current conditions during operations by the development of the 
Project. After development of the solar field, the presence of the solar panels would reduce wind 
velocities at ground level and the ground surface could be treated as needed to reduce potential fugitive 
dust. This could also reduce the amount of fugitive dust from these lands that would affect local air 
quality. The Project will comply with all dust control requirements of Maricopa County. In addition, 
development of a solar generation project would have a net general benefit to air quality by off-setting 
fossil-fired energy production that it would replace.  
 
Stormwater quality would likewise be expected to improve due to the application of stormwater 
management practices as part of the Project. There would be no significant noise nuisances associated 
with the operation of the proposed Project as it is a passive land use.

12 
 
 
 
Policy E1.3.3: Discourage the construction of new dirt roads where feasible by encouraging 
common access that is agreed to by end users. Encourage revegetation of abandoned dirt roads. 
 
Access to the Sun Streams Expansion site will be via existing public roads. Access to the northern 
portion of the site would be from 331st and 339th Avenues, Salome Highway, and Baseline Road. 
Access to the southern portion of the site would be from Salome Highway, 355th Avenue, Elliott 
Road, and Dobbins Road. These roads that would provide access are shown on Figure 5. None of 
these roads would be expected to require upgrades. Any roads developed within the Subject 
Property as part of the Sun Streams Expansion Project would be treated and managed to minimize 
fugitive dust as specified in an approved dust control plan that would be obtained from Maricopa 
County Air Quality Control. The Project is not expected to require development or improvement of 
access roads on neighboring private or state-owned properties. Even though the Project would not 
require additional public infrastructure or services, the Project is expected to generate tax and 
annual lease revenues to the State Trust beneficiaries which includes public schools in Arizona. 
 
Objective E1.4: Preserve significant habitat areas for wildlife and native plant species. 
 
There is no significant or unique plant or wildlife habitat on the Subject Property per data provided by 
AGFD and USFWS in Appendix B. As requested by AGFD, the applicant will conduct surveys for the 
western burrowing owl and, if present, work with the agencies to minimize impacts to this species.  Any 
impacts to protected native plants will be conducted in accordance with the requirements of Title 3, 
Chapter 3 of Article 11 of Arizona Administrative Code regarding Arizona Native Plants. 
 
Policy E1.4.1: Support natural drainage corridors and protective buffering techniques along 
significant wash systems where new development is proposed, to provide flood control, 
preserve wildlife corridors, and protect open space. 
 
The Project will incorporate the avoidance and buffering of the largest of the washes on site which 
would be left in their natural state to the extent possible as will be shown on the upcoming plan of 
development site plan to be submitted as part of the rezoning / IUPD for Project. Development and 
placement of structures within the floodways and most of floodplains would be avoided. If any 
work is necessary in small parts of the floodplains, appropriate approvals would be obtained from 
the Maricopa County Flood Control District. 
 
Policy E1.4.2: Encourage protection of sensitive, threatened, or endangered plant and animal 
species. 
 
No critical habitats of sensitive species are known to occur on the subject lands per data provided 
by AGFD and USFWS in Appendix B. To ensure that no impacts to these species will occur, the 
USFWS and AGFD will continue to be consulted. Any impacts to protected native plants will be 
conducted in accordance with the requirements of Title 3, Chapter 3 of Article 11 of Arizona 
Administrative Code regarding Arizona Native Plants. 
 
Policy E1.4.3: Encourage cooperation with the Arizona Game and Fish Department (AGFD} and 
the U.S. Fish and Wildlife Service to help prevent encroachment on riparian scrub habitat 
and/or channels associated with significant local wash systems.

13 
 
 
The Applicant will consult and cooperate with AGFD and USFWS regarding the significant local 
washes in the area. The larger washes on the subject properties would for the most part be 
avoided by development. 
 
         Policy E1.4.4: Encourage the use of native vegetation replacement. 
          
 Grading and earthwork would be minimized to the extent possible. Within the solar field, existing 
vegetation would be treated by mowing. Mowing would cut vegetation to a height of less than 12 
inches without affecting topography or below-ground root systems allowing the existing native 
vegetation to re-establish. In areas where the terrain is not suitable for mowing, rubber-tired 
tractors with disking equipment, drum rollers, and limited use of scrapers would remove 
vegetation and perform micro-grading, a practice known as “disk and roll.” In areas where the 
topography is not suitable for either mowing or disk and roll, the site would be graded using 
conventional equipment. Any revegetation efforts that may be needed on the subject lands would 
be conducted using native species.  
 
Economic Development 
 
Goal ED1: Promote a growing, balanced, efficient, and diversified economy, consistent with available 
resources, that enhances quality employment opportunities, improves quality of life, and is sensitive 
to the natural and cultural environment. 
 
The proposed amendment would promote economic growth and efficiency in the area and would be 
compatible with the area environment and resources as discussed in the sections above. 
 
Objective ED1.1: Encourage quality employment opportunities by supporting efforts that encourage 
business formation and expansion. 
 
The Sun Streams Expansion Project is expected to provide f up to 800 jobs at peak with above-average 
wages during the approximately 2-year construction period for the Project. These workers would receive 
job training and skills that would be applicable to future similar projects.  Once constructed, the facility 
will be mostly automated and will require up to 8 operational employees.  
 
Policy ED1.1.1: Encourage rural type, light industrial development near Palo Verde NGS and 
along the railroad. 
 
The Sun Streams Expansion Project would be a light industrial use as a utility use and would occur 
along the railroad and near the Palo Verde NGS and other power and transmission facilities in the 
area.  The map change requested implements this Policy directive.

14 
 
 
Growth Areas  
 
Objective G1.2: Ensure that future growth is coordinated in an efficient manner with stakeholder 
input. 
 
Stakeholder input regarding the proposed project will be obtained through implementation of the Public 
Participation Plan and as a Major Amendment, the details of this request have been routed to state and 
local agencies to ensure broad and coordinated input. 
 
Policy G1.2.3: Continue to update the Old U.S. Highway 80 Area Plan with input from local 
organizations and area residents to determine appropriate growth areas, if any, and make changes as 
necessary. 
 
The proposed amendment implements this policy as the development of Western Maricopa County has 
emerged as a major solar development area due to proximity to PVNGS, transmission lines and rail.  
Amendments to the Plan are contemplated for scenarios such as this, which have occurred over time and 
with input from local stakeholders. 
 
Open Space 
 
Goal O1: Maintain and, where necessary, encourage expanding the open space system for Maricopa 
County to address public access, connectivity, education, preservation, buffering, quantity, quality, 
and diversity for regionally significant open spaces. 
 
The Project would maintain the natural condition of the major drainages in the area used for habitat / 
connectivity by wildlife. The larger drainages (washes with corresponding floodways) on the subject 
properties would for the most part be avoided by development. 
 
Objective O1.3: Protect and enhance environmentally sensitive areas, including existing natural 
washes; steep slopes; historical, cultural, and archaeological resources; view corridors; sensitive 
desert; and significant wildlife habitat and ecosystems. 
 
The subject properties do not contain the environmentally sensitive areas listed below: 
• 
There are no steep slopes (per Figure 10 of the Tonopah – Arlington Area Plan),  
• 
There is no protected wildlife species habitat (per data provided by AGFD and USFWS in 
Appendix B), 
• 
There are no designated scenic view corridors on or near the project site (per the Old US 
Highway 80 Area Plan),  
• 
The subject lands do not have significant historical or archaeological resources based on cultural 
resource surveys, results of which have been provided to ASLD and the SHPO  
 
The site does contain larger drainages (washes with corresponding floodplains) and these would be 
avoided by development to the extent practicable as will be detailed in the upcoming plan of 
development site plan to be submitted as part of the rezoning / IUPD for Project.

15 
 
 
Objective O1.6: Promote the economic, environmental, and quality of life benefits of natural open 
space. 
 
Policy O1.6.1: Encourage communication efforts with stakeholders to share information and 
discuss current issues and development applications. 
 
Communication with stakeholders will occur through implementation of the Citizen Participation 
Plan. 
 
Water Resources 
 
Goal W1: Promote development that makes conservative use of renewable water supplies such as 
effluent, surface water, and Central Arizona Project water when feasible, as well as nonrenewable 
sources like groundwater. 
 
The development of the Project would conservatively use available water. Water would be used during 
the estimated 24-month construction period primarily to control fugitive dust emissions. Water would be 
used during the 30-year operational period. PV solar projects do not require water to generate electricity. 
The facility does not require significant staff, so substantial water is not required on-site for employee 
needs during operation. The panels will be required to be cleaned periodically so water would likely be 
used for that purpose on an ongoing basis following completion of construction. Water needs would be 
provided via development of an on-site well or having water trucked to the site. 
 
Goal W2: Reduce the impacts of development on water quality. 
 
The development will comply with stormwater management requirements and will not result in 
detrimental impacts on water quality. Stormwater management practices at the Sun Streams Expansion 
Project could result in improvements to local water quality relative to the uncontrolled conditions that 
currently exist on these properties. 
 
Cost of Development 
 
All goals, objectives and policies associated with this plan topic deal with projects that require new 
public infrastructure, facilities, and services. Since the proposed development associated with this 
amendment would not require additional infrastructure, facilities, or services, these issues would not be 
impacted by this amendment but the goal of this element is addressed below. 
 
Goal C1: Ensure that new development pays its fair and proportional share of the cost of additional 
public facility and service needs generated by new development. 
 
The proposed use would not require any additional public infrastructure, so no additional expenditures 
are expected to be required. Once constructed, the Project would not increase demand for schools, public 
utilities, or public services. Even though the Project would not require additional public infrastructure or 
services, The Project is expected to generate tax and annual lease revenues to the State Trust 
beneficiaries which includes public schools in Arizona. In addition, the Project shall be responsible for 
funding and developing any public infrastructure improvements necessary to serve the Project.

16 
 
 
TONOPAH/ARLINGTON AREA PLAN 
Land Use 
 
Land Use Element Goal: Promote efficient land development that is compatible with adjacent land 
uses, is well integrated with the transportation system, and is sensitive to the natural environment. 
 
The amendment will be consistent with this goal as it would be compatible with adjacent uses, will have 
no long-term effects on the transportation system, and would not result in significant effects to the 
natural environment as described in the sections above and below. 
 
Objective L1: a. Create orderly, efficient, and functional development patterns. b. Create high quality 
residential, commercial, and industrial land developments that are compatible with adjacent land 
uses. 
 
The development contemplated by the amendment would complement the existing and planned 
development patterns in the area by further consolidating energy and utility uses in the area around the 
PVNGS and being compatible with the other primary uses in the area. 
 
Policy L1.3: Encourage land developers to cooperate with residents, and homeowner’s 
associations during any development review process for construction near the property 
holdings of those residents and homeowner’s associations. 
 
The proposed Sun Streams Expansion Project will coordinate with nearby resident associations 
during the review process of the Project as provided for in the accompanying Citizen Participation 
Plan. In addition, residents within 300’ of the Project will be noticed through mailings and signs 
will be posted at the Project site to inform them of the Project.  Any feedback received will be 
considered as the development plans move forward.  
 
Policy L1.5: Review development proposals along major streets and adjacent to existing and 
approved land uses to determine compatibility with those uses. 
 
The existing and planned land uses adjacent to the subject lands are primarily rural and rural 
residential. The operation of the proposed PV solar project would not create substantial noise or 
traffic. Its low profile would minimally affect the scenic quality of the area. Therefore, the Sun 
Steams Expansion Project would be expected to be compatible with adjacent uses and will not 
impact the major streets adjacent to the Property in the same manner that a Residential 
development would. 
 
Policy L1.6: Discourage the location of commercial or industrial developments in locations 
specified for development with rural density land uses. 
 
This amendment would encourage the location of Utility-scale development in the locations called 
for in the Plan- near PVNGS and rail corridors.  PV solar generation facilities are a passive use 
without significant operational employment or activity and as a result, also complement a rural 
environment and will serve as an appropriate transition to the surrounding rural-density land uses.

17 
 
 
Policy L1.7: Encourage light industrial development in the vicinity of the Palo Verde Nuclear 
Generating Station. 
 
The property is within 3 miles of PVNGS and is therefore “in the vicinity” of the Plan where light 
industrial development is encouraged.  The Sun Streams Expansion Project would be similar to a 
light industrial/utility use (with fewer impacts usually associated with such uses) and would be 
compatible with this land use designation, adjacent land uses, and CPAs. The concentration of 
energy development that has occurred in this area encourages other compatible uses and the 
Project supports growth of that use. 
 
Objective L2: Provide for a functional, efficient and cost-effective system of utilities, facilities and 
services to serve county population and employment centers. 
 
The renewable energy generated by the proposed Project would directly contribute to the efficiency and 
cost-effectiveness of utilities, facilities, and services that support the population and employment in 
Maricopa County. Electricity generated by PV projects are cost-competitive with other sources and also 
off-sets generation previously provided by fossil-fueled sources.  The development of solar at this scale 
will assist the parts of Maricopa County where employment centers are being developed that require 
additional power sources.  The Utilities designation encourages the development of a green power 
source that will serve the County population and large employment centers. 
 
Policy L2.2: Where possible and appropriate, in the design and construction of new 
development, preserve natural drainage ways, including the Hassayampa River, major washes, 
and open space corridors. 
 
Natural drainage ways, including the Hassayampa River, and the other most prominent drainage 
ways that cross the area would be avoided by development. Smaller drainages would be 
incorporated into final development plans to ensure to the extent possible that they are not 
negatively impacted. There are no open space corridors within the Project area. 
 
Transportation 
 
Transportation Element Goal: Provide an efficient, cost-effective, integrated, accessible, 
environmentally sensitive, and safe countywide multi-modal system that addresses existing and 
future roadway networks, as well as promotes transit, bikeways, and pedestrian travel. 
 
The Sun Streams Expansion Project is supportive of this goal. 
Objective T1: Establish a circulation system that provides for the safe, convenient and efficient 
movement of goods and people throughout Maricopa County. 
 
The proposed Project would be accessed from existing roadways via several points to provide access to 
specific parts of the site during construction and operation. The Project is not expected to significantly 
burden or require significant improvements to roads. Construction traffic would be managed by the 
construction contractor via implementation of a traffic management plan designed to efficiently and 
safely control the flow of traffic during this time period. The proposed Project would have no long-term 
effects on the transportation system and no negative effects on traffic during operations. This is 
summarized in the traffic statement that accompanied the CPA application.

18 
 
 
Policy T1.4: Support efforts to provide all-weather travel over washes where justified. 
 
Major drainages and washes would be avoided to the extent possible by the Project and existing 
all-weather travel over washes would not be impacted. 
 
Policy T1.6 Where appropriate, support efforts to obtain land dedication for roadways during 
rezoning and subdivision processes. 
 
As required by Maricopa County Department of Transportation (MCDOT), efforts to obtain land 
preservation for roadways would be conducted during the rezoning process for the Project.  
 
Environment 
 
Environment Element Goal 1: Promote development that considers adverse environmental impacts on 
the natural and cultural environment, preserves highly valued open space, and remediates areas 
contaminated with hazardous materials. 
 
The proposed amendment would have minimal impacts to the natural and cultural environment because 
there are no significant or highly valued wildlife habitat or open space on the subject lands. The applicant 
will work with applicable agencies having jurisdiction to minimize impacts to the western burrowing owl. 
Based on survey results, the subject lands also do not contain significant cultural resources. The subject 
lands are not known to be contaminated with hazardous materials nor would hazardous materials be 
stored or utilized on site. 
 
Environment Element Goal 2: Improve air quality and reduce noise impacts. 
 
The proposed amendment could result in improved air quality relative to fugitive dust emissions due to 
potential reduction in wind velocities at the ground surface and treatment of soils. There would be no 
significant noise emissions associated with operation of the proposed Project. 
 
Objective E1: Encourage developments that are compatible with natural environmental features and 
which do not lead to their destruction. 
 
The subject properties do not contain significant natural environmental features such as hillsides, 
protected wildlife species habitats, or scenic areas. As mentioned above, the larger drainage features on 
these lands would for the most part be avoided by development.  
 
Policy E1.1: In order to minimize adverse impacts of hillside development, the submittal of land 
development applications on lands with slopes of 15 percent or greater should be discouraged. 
 
The proposed Project will be developed in accordance with any applicable Hillside regulations. It 
would not be located on lands with slopes of 15 percent or greater.

19 
 
 
Policy E1.2: Encourage land uses and development designs that are compatible with 
environmentally sensitive areas such as parks, open space, floodplains, hillsides, wildlife 
habitat, scenic areas, and unstable geologic and soil conditions. 
 
The subject properties do not include nor would be adjacent to environmentally sensitive areas 
such as parks, open space, hillsides, critical wildlife habitats, or scenic areas. Unstable 
geologic/soil conditions would be avoided to the extent possible and appropriate engineering 
considerations would be incorporated into the Project design if needed. The larger drainages on 
these lands would for the most part be avoided. Any development that would occur within a 
floodplain would be conducted in accordance with the requirements of the Maricopa County Flood 
Control District.  
 
Policy E1.3: Encourage compatible land use relationships with sources of excessive noise. 
 
Operation of the proposed Project will not be associated with any significant noise emissions and 
is a complementary land use adjacent to the rail corridors that emit noise. 
 
Policy E1.5: Encourage land uses and development designs that are compatible with soil 
conditions which have severe development constraints such as within the Cherioni Rock 
outcrop area located in the southwestern portion of the planning area, the Casa Grande Harqua 
located in the southeast portion of the planning area, and the Carrizo-Brios and Carrizo 
associates which are located along the eastern edge of the planning area. 
 
The Sun Streams Expansion Project would be located on the Casa Grande-Harqua soil association 
and could possibly include the Carrizo-Brios soil association along the eastern edge of amendment 
area (according to Figure 9 of the Tonopah-Arlington Area Plan). The Carrizo-Brios Association 
occurs along the Hassayampa River and the project would avoid development within this drainage 
– both the floodway and most of the associated floodplain as will be detailed in the upcoming plan 
of development site plan to be submitted as part of the rezoning / IUPD for Project. The Casa 
Grande – Harqua soils are relatively flat and would not provide a constraint to solar development. 
Appropriate engineering considerations would be incorporated into project design as needed to 
address any identified issues associated with these soils that could affect project development.  
 
Objective E2: Protect and preserve existing water resources and minimize flood hazards. 
 
The development of the Project would not use significant existing water resources during operations. The 
panels could be cleaned periodically so water could be used for that purpose. The facility does not require 
significant staff for operations, so substantial water is not required on-site for employee needs during 
operation. There are limited drainages on these lands that would for the most part be avoided. Any 
development that would occur in a floodplain would be conducted in accordance with the requirements 
of the Maricopa County Flood Control District. 
 
Policy E2.1: Support Flood Control District policies, drainage regulations, and floodplain 
regulations for all development within the County. 
 
As noted above, there are limited drainages on the subject property that would for the most part 
be avoided. Any development that would occur in a floodplain or drainage would be conducted in 
accordance with the requirements of the Maricopa County Flood Control District.

20 
 
 
 
Policy E2.2: Encourage cooperation with the Flood Control District to minimize land 
development conflicts and achieve compatibility with the development and implementation of 
Area Drainage Master Plan Studies and other relevant investigations. 
 
The Sun Streams Expansion Project will cooperate with the Flood Control District to minimize 
development conflicts and achieve compatibility with any Area Drainage Master Plan Studies and 
other investigations. 
 
Policy E2.3: Discourage the location of structures that would alter current storm water drainage 
patterns and which would increase water ponding and sheetflow in areas of extremely flat land 
and areas currently susceptible to sheetflow. 
 
The proposed Project will avoid larger drainages to the extent possible. Structures associated with 
the proposed Project will not be located such that existing storm water drainage patterns would 
be altered. 
 
Policy E2.4: Limit the location of land uses, which rely on direct extraction of groundwater to 
where subsidence is neither an existing condition nor is projected to occur in the future. 
 
The proposed Project would possibly use groundwater for construction water (primarily for dust 
control) during construction of the Project and possibly limited amounts to support the operations 
of the Project. If groundwater is used, the Applicant will work with ADWR to obtain any required 
approvals or review as needed. The Project area is not within an area of known subsidence in 
Maricopa County. 
 
Policy E2.6: Encourage the use of drought tolerant and low water consumptive landscape 
materials. 
 
The Sun Streams Expansion Project would not incorporate landscaping, outside of revegetation (if 
necessary). If revegetation is required, native species that are drought tolerant and low water 
consumptive would be utilized.  
 
Objective E3: Preserve existing habitat areas of wildlife and/or desert plant species. 
 
No critical habitats of sensitive animal or plant species are known to occur on the subject lands. To 
ensure no impacts would occur, the AGFD and USFWS would be consulted. 
 
Policy E3.1: Encourage the protection of threatened and endangered species. 
 
No critical habitats of threatened and endangered species are known to occur on the subject lands 
per data provided by AGFD and USFWS in Appendix B. As requested by AGFD, the applicant will 
conduct surveys for the western burrowing owl and, if present, work with the agencies to minimize 
impacts to this species.

21 
 
 
Policy E3.5: Encourage the preservation and/or restoration of riparian habitats. 
 
The Project would not be located on any riparian habitats. The larger drainages (washes with 
corresponding floodways) on the subject properties would for the most part be avoided by 
development. 
 
Objective E4: Protect historical and archaeological resources. 
 
Based on survey results, the subject lands do not contain any significant historical or archaeological 
resources. 
 
Policy E4.1: Prior to development, excavation, or grading, require that an applicant submit a 
letter from the Arizona State Historical Preservation Office stating that the proposed land 
development will have no effect on historical and cultural resources. 
 
Based on the results of site surveys, the subject lands do not contain any significant historical or 
archaeological resources. The cultural resource survey report has been provided to the Arizona 
State Historical Preservation Office (SHPO) via ASLD as part of the leasing process for State lands. 
A letter from SHPO will be provided prior to development. 
 
Economic Development 
 
Economic Development Element Goal: Promote a growing, balanced, efficient, and diversified 
economy, consistent with available resources, that enhances quality employment opportunities, 
improves quality of life, and is sensitive to the natural and cultural environment. 
 
The proposed amendment would promote continuing economic growth and efficiency in the area and be 
compatible with the area environment and resources as discussed in the sections above.  
 
Policy ED1.7: Require that future industrial and commercial development be adequately 
screened from public view. 
 
The proposed solar energy development would not be expected to affect the visual quality of the 
area. The proposed PV solar panels have a relatively low profile and would be located on 
relatively flat lands located low on the landscape, so would not be expected to be visible from 
most areas or affect views of the local mountains.  Subdivided lots abut the subject property in 
many locations as shown on Figure 4. Most of the subdivided lots within the area are not 
developed but some existing residences abut the site along Elliott Road, Dobbins Road, 
Sunland/Southern Avenue, and South 331st Avenue. In these areas, visual screening would be 
provided by adding slats to the Project perimeter fence. This fence treatment would be of an 
appropriate color consistent with the surrounding environment and would obstruct the view of 
the Project from the residential properties while minimally impacting local visual quality. 
 
 
OTHER PERTINENT INFORMATION AS REQUESTED BY THE MARICOPA COUNTY PLANNING 
DEPARTMENT STAFF 
None at this time.

G:\Sunstreams/MXD's/Sun Streams Expansion
SUN STREAMS EXPANSION
Author:  rnc
Date: 07-22-20
FIGURE 1
PROJECT LOCATION
Map Extent: Maricopa County, Arizona
State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit:  Foot US
State Highway
Legend
Sun Streams Expansion
Map
Extent
ARIZONA
Phoenix
Maricopa County
ARLINGTON
BUCKEYE
PALO VERDE
TONOPAH
PALO VERDE
NUCLEAR
GENERATING STATION
Sun Streams
Expansion
§¨¦
10
U
V
85
U
V
85
85
Oglesby
Sun Valley
0
0.5
1
1.5
2
Miles
°
Interstate Highway

G:\Sunstreams/MXD's/Sun Streams Expansion
SUN STREAMS EXPANSION
Author:  rnc
Date: 07-21-20
FIGURE 2 
CURRENT PLAN LAND USE
Map Extent: Maricopa County, Arizona
State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit:  Foot US
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!
!
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!
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!
U.P.R.R.
Sun Streams Expansion
Rural Densities (0-1)
Industrial
Small Lot Residential (2-5)
Large Lot Residential (1-2)
Industrial
W Salome Hwy
331st Ave
Dobbins Rd
Baseline Rd
355th Ave
351st Ave
319th Ave
339th Ave
Elliot Rd
Narramore Rd
Ward Rd
W Old Us Highway 80
Arlington School Rd
355th Ave
351st Ave
W Southern Ave
W Southern Ave
0
1,0002,0003,0004,0005,000
Feet
°
Legend
!
!
!
Existing 500 kV Transmission
 Line
Road
Railroad
Sun Streams Expansion 
Area Plan Boundary  
Map
Extent
ARIZONA
Phoenix
Maricopa County
Planned Land Use
Rural Densities (0-1)
Small Lot Residential (2-5)
Large Lot Residential (1-2)
Industrial
TONOPAH- ARLINGTON 
AREA PLAN
OLD US HIGHWAY 80 
AREA PLAN

G:\Sunstreams/MXD's/Sun Streams Expansion
SUN STREAMS EXPANSION
Author:  rnc
Date: 07-21-20
FIGURE 3
EXISTING ZONING
Map Extent: Maricopa County, Arizona
State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit:  Foot US
U.P.R.R.
Sun Streams Expansion
IND-2
RU-43
RU-43
SUP - Solar
IND-3
RU-43
IND-2
RU-190
W Salome Hwy
331st Ave
Dobbins Rd
Baseline Rd
355th Ave
351st Ave
319th Ave
339th Ave
Elliot Rd
Narramore Rd
Ward Rd
W Old Us Highway 80
Arlington School Rd
355th Ave
351st Ave
W Southern Ave
W Southern Ave
0
1,0002,0003,0004,0005,000
Feet
°
Legend
Existing Zoning
!
!
!
Existing 500 kV Transmission
     Line
Road
RU-43
RU-190
IND-2
IND-3
Sun Streams Expansion
Special Use Permit- Solar
Railroad
Map
Extent
ARIZONA
Phoenix
Maricopa County

G:\Sunstreams/MXD's/Sun Streams Expansion
SUN STREAMS EXPANSION
Author:  rnc
Date: 07-22-20
FIGURE 4
SITE LOCATION
WITH PARCELS
Map Extent: Maricopa County, Arizona
State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit:  Foot US
U.P.R.R.
Sun Streams Expansion
ARIZONA STATE 
TRUST LAND
ARIZONA STATE 
TRUST LAND
APN: 40142030D
APN: 40142030B
APN: 40142030C
APN: 40142032
APN: 40142031
APN: 40142033
W Salome Hwy
331st Ave
Dobbins Rd
Baseline Rd
351st Ave
319th Ave
339th Ave
Narramore Rd
Ward Rd
W Old Us Highway 80
351st Ave
W Southern Ave
W Southern Ave
0
1,000
2,000
3,000
4,000
5,000
Feet
°
Legend
!
!
!
Existing 500 kV Transmission
     Line
Road
Sun Streams Expansion
Parcel Boundary
Railroad
Map
Extent
ARIZONA
Phoenix
Maricopa County
Jurisdictional Land Ownership
Bureau of Land Management
     Land
State Land

ELLIOT RD
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WINTERSBURG RD
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INTERSTATE
ARIZONA
10
339TH AVE
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ARLINGTON
ELEMENTARY SCHOOL
ARLINGTON
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ARLINGTON
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ARLINGTON
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ARLINGTON
ELEMENTARY SCHOOL
PALO VERDE NUCLEAR
POWER PLANT
PALO VERDE NUCLEAR
POWER PLANT
PALO VERDE NUCLEAR
POWER PLANT
PALO VERDE NUCLEAR
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PALO VERDE NUCLEAR
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POWER PLANT
331ST AVE
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SALOME HWY
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RAILROAD
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2141 E. HIGHLAND AVE., STE. 250
PHOENIX, AZ 85016
P: 602.490.0535 / F: 602.368.2436
   Figure 5 - Local Roads

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#*
#*
#*
#*
")
")
")
")
U.P.R.R.
W Southern Pacific Trl
Salome Hwy
351st Ave
W Old Hwy 80
ARLINGTON
Baseline Rd
Dobbins Rd
Elliot Rd
Narramore Rd
Southern Ave
Broadway Rd
Lower Buckeye Rd
339th Ave
331st Ave
355th Ave
Wintersburg Rd
Arlington School Rd
387th Ave
Palo Verde
Substation
Sunstreams
Expansion
Red Hawk
Power Station
Palo Verde
Nuclear
Gen. Station
Arlington Valley
Energy Facility
Mesquite Power
Generating Station
Maricopa
County
Mesquite Solar
Sunstreams I
Sunstreams IV
Sunstreams I
Sunstreams II
Arlington Valley
Solar Energy II
Arlington Valley
Solar Project II
Sunstreams III
Sunstreams IV
Sunstreams II
Arlington Valley
Solar Project
Arlington Valley
Solar Project
Hassayampa I
Solar
Sunstreams PVS
Legend
Map
Extent
ARIZONA
Phoenix
Maricopa County
Author:  rnc
Date: 08.31.20
SUN STREAMS EXPANSION
Map Extent: Maricopa County, Arizona
Figure 6
Nearby Energy Projects /
Infrastructure
0
1
2
Miles
°
State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit:  Foot US
Substation / Switchyard
#*
Existing Generating Station
")
!
!
!
Existing 500 kV Transmission
 Line
Railroad
County Boundary
Sun Streams Expansion
     Solar Project Site
Road
Existing Solar Project Site

APPENDIX A 
 
LEGAL DESCRIPTION

LEGAL DESCRIPTION OF SUN STREAMS EXPANSION PROPERTY 
SUBJECT TO ARIZONA STATE LANDS COMMERCIAL LEASE  
APPLICATION 03-120611 
 
 
The Land referred to herein below is situated in the County of Maricopa, State of Arizona, and is 
described as follows: 
 
 
ALL OF SECTION 32, TOWNSHIP 1 NORTH, RANGE 5 WEST OF THE GILA AND SALT RIVER BASE AND 
MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE NORTHWEST QUARTER AND THE SOUTH HALF OF SECTION 33, TOWNSHIP 1 NORTH, RANGE 5 
WEST OF THE GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE WEST HALF OF SECTION 34, TOWNSHIP 1 NORTH, RANGE 5 WEST OF THE GILA AND SALT RIVER 
BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE WEST HALF AND THAT PORTION OF THE NORTHEAST QUARTER, LYING SOUTH OF THE WEST 
SALOME HIGHWAY OF SECTION 4, TOWNSHIP 1 SOUTH, RANGE 5 WEST OF THE GILA AND SALT RIVER 
BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE NORTHWEST QUARTER AND THAT PORTION OF THE NORTHEAST QUARTER, LYING NORTH OF 
THE UPRR PROPERTY AND THAT PORTION OF THE SOUTH HALF OF SECTION 9, LYING NORTH OF THE 
UPRR PROPERTY, TOWNSHIP 1 SOUTH, RANGE 5 WEST OF THE GILA AND SALT RIVER BASE AND 
MERIDIAN, MARICOPA COUNTY, ARIZONA.  
 
THE WEST HALF OF THE EAST HALF OF SECTION 34, TOWNSHIP 1 NORTH, RANGE 5 WEST OF THE 
GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THE EAST HALF OF THE SOUTHEAST QUARTER OF SECTION 34, TOWNSHIP 1 NORTH, RANGE 5 WEST 
OF THE GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA. 
 
THAT PORTION OF THE EAST HALF OF SECTION 18, TOWNSHIP 1 SOUTH, RANGE 5 WEST, OF THE 
GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA, THAT IS SITUATED 
NORTH OF THE UNION PACIFIC RAILROAD.

APPENDIX B 
 
SENSITIVE SPECIES REVIEW

Sun Streams Expansion Solar Project 
Special Status Species Review 
METHODS  
 
Information was obtained from the U.S. Fish and Wildlife Service (USFWS) and the Arizona 
Game and Fish Department (AGFD) regarding the potential occurrence of special status species 
within the Project Study Area for the Sun Streams Expansion Solar Project (Figure 1). Special 
status plant and wildlife species are subject to regulations under the authority of Federal and State 
agencies. Special status species that could be associated with the proposed Project include those 
species that are listed by the USFWS as federally endangered, threatened, proposed, or candidate 
species under the Endangered Species Act of 1973 (ESA), Section 4, as amended; listed as Wildlife 
of Special Concern by the Arizona Game and Fish Department (AGFD); or protected under the 
Arizona Native Plant Law (ANPL) administered by the Arizona Department of Agriculture 
(AZDA). Descriptions of these special status species are summarized below: 
• Endangered species, protected under the ESA, are those species in danger of extinction 
throughout all or a significant portion of their range.   
• Threatened species, protected under the ESA, are those species likely to become 
endangered in the foreseeable future.   
• Proposed species are those species recommended for listing under Section 4 of the ESA.  
• Candidate species are those species for which the USFWS has sufficient information on 
their biological status and threats to propose them as endangered or threatened under the 
ESA, but has precluded the development of a proposed listing regulation because of other 
higher priority listing activities. Candidate species are not protected under the ESA.  
• USFWS Species of Concern is an informal term that refers to those species that the USFWS 
believes may be in need of concentrated conservation actions. Conservation actions, such 
as monitoring, vary depending on the health of the populations and degree and types of 
threats. USFWS Species of Concern receive no legal protection under the ESA and the use 
of the term does not necessarily mean that the species will eventually be proposed for 
listing as a threatened or endangered species. 
• AGFD Species of Greatest Conservation Need (SGCN) are species determined to be 
vulnerable in at least one of the following eight criteria: extirpated from Arizona, federal 
or state status, declining status, disjunct status, demographic status, concentration status, 
fragmentation status, and distribution status, as described by the AGFD's listing of 
Wildlife of Special Concern in Arizona (WSCA, updated October 15, 2019).  
 
The USFWS Information for Planning and Consulting (IPaC) was accessed and the USFWS 
generated a report listing proposed, candidate, threatened, and endangered species (TECP) and 
other resources that could potentially occur within the project area (USFWS 2020) and is 
included as Exhibit A. Critical habitats are specific areas that contain the physical or biological 
features that are essential to the conservation of listed species and that could need special 
management or protection. As shown on page 2 of the IPaC report, no critical habitats occur at 
this location. The USFWS has identified zero plant species and 6 wildlife species (1 mammal, 4 
birds and 1 fish) with federal status that have the potential to occur within the project area:

Sonoran pronghorn (Antilocarpa americana sonoriensis), California least tern (Sterna antillarum 
browni), southwestern willow flycatcher (Empidonax traillii extimus), yellow-billed cuckoo 
(Coccyzus americanus, Yuma Ridgway’s rail (Rallus obsoletus yumanensis) and desert pupfish 
(Cyprinodon macularius). As shown on Table 1, none of these federally listed species is 
expected to occur on the project site because of lack of suitable habitat. 
 
An AGFD On-line Project Evaluation Program (PEP) search was also completed for the Project 
on May 26, 2020 (AGFD 2020) and is included as Exhibit B. The information provided in the 
PEP is used to guide preliminary decisions and assessments of proposed land development, 
management, and conservation projects, while incorporating fish and wildlife resource needs or 
features. The PEP indicated that the following nine species of concern are known to occur within 
five miles of the Sun Streams Expansion Solar Project: straw-top cholla (Opuntia echinocarpa), 
western burrowing owl (Athene cunicularia hypugaea), yellow-billed cuckoo, southwestern 
willow flycatcher, Sonoran collared lizard (Crotaphytus nebrius), Sonoran desert tortoise 
(Gopherus morafkai), lowland leopard frog (Lithobates yavapaiensis), Yuma Ridgway’s rail, and 
Le Conte’s thrasher (Toxostoma lecontei).  
 
Table 1 summarizes the potential for these species to occur in the vicinity of the Project, listed 
by common name, scientific name, and status. Also included is the likelihood of each to occur on 
the Project site. As shown, because of lack of suitable habitat, only two of the wildlife species 
identified in the PEP, the western burrowing owl and LeConte’s thrasher, have the potential to 
occur on the site. One plant species, Straw-top cholla, could also potentially occur.  
 
As requested by AGFD, the applicant will conduct pre-construction surveys for the western 
burrowing owl and, if present, work with the agencies and apply measures identified by AGFD 
in the PEP to minimize impacts. Potential impacts to the thrasher would be minimized by 
implementation of appropriate conservation measures under the Migratory Bird Treaty Act 
(MBTA). The Straw-top cholla is a salvage-restricted plant and, if present on the site, it would be 
addressed as required under the ANPL.

Table 1 
SPECIAL STATUS SPECIES AND POTENTIAL TO OCCUR ON PROJECT SITE 
Species 
Protection Status1 
Potential to Occur in Project Study Area 
(Justification)4 
Common name 
Scientific name 
ESA2 
Arizona 
SGCN3 
Plants 
Straw-top Cholla 
Opuntia echinocarpa 
-- 
SR 
Yes (Potentially suitable habitat present) 
Mammals 
Sonoran Pronghorn 
Antilocapra americana sonoriensis 
EXPN 
1A 
No (Project site outside known geographic 
range) 
Birds 
Yellow-billed Cuckoo 
(Western DPS) 
Coccyzus americanus occidentalis 
T 
1A 
No (No suitable nesting or foraging 
habitat) 
Western Burrowing Owl 
Athene cunicularia hypugaea 
SC 
1B 
Yes (Potentially suitable nesting and 
foraging habitat present) 
Yuma Clapper Rail (Yuma 
Ridgeway’s Rail)  
Rallus longirostris yumanensis 
E 
1A 
No (No suitable nesting or foraging 
habitat) 
California Least Tern 
Sterna antillarum browni 
E 
-- 
No (Habitat) 
Southwestern Willow 
Flycatcher 
Empidonax traillii extimus 
E 
1A 
No (No suitable nesting or foraging 
habitat) 
Le Conte’s Thrasher 
Toxostoma lecontei 
-- 
1B 
Yes (Potentially suitable nesting and 
foraging habitat present) 
Reptiles 
Sonoran Collared Lizard 
Crotaphytus nebrius 
-- 
1B 
No (Habitat) 
Sonoran Desert Tortoise 
Gopherus morafkai 
-- 
1A 
No (Habitat) 
Amphibians 
Lowland Leopard Frog 
Lithobates yavapaiensis 
SC 
1A 
No (Habitat) 
Fish 
Desert Pupfish 
Cyprinodon macularius 
E 
 
No (Habitat) 
1 E=Endangered, T=Threatened, PT = Proposed Threatened, C=Candidate, EXPN=Experimental Population, Non-Essential, SC=Species of Concern, DM= Delisted taxon, recovered, 
and being monitored for the first five years, WSC=Wildlife of Special Concern, SR=Salvage Restricted, HS=Highly Safeguarded 
2 USFWS 2019 
3  AGFD 2019 
4 Elevation means the species does not have the potential to occur because the Project Site is not within its elevation requirements. Habitat means the Project Site is within the species 
elevation requirements but there is no suitable or potential habitat for the species. References are provided in the References Section.

References 
Arizona Game and Fish Department (AGFD). 2020. Arizona’s On-line Environmental Review 
Tool. [Web Page] Located at http://www.azgfd.gov/hgis/. Project ID: HGIS-11229. 
Accessed: May 26, 2020. 
U.S. Fish and Wildlife Service (USFWS). 2020. Information for Planning and Consultation 
Resource List, List of Species. [Web Page] Located at http://www. http://ecos.fws.gov/ipac/. 
Accessed: May 26, 2020.

Exhibit A 
 
USFWS IPac Report

IPaC resource list
This report is an automatically generated list of species and other resources such as critical habitat (collectively referred to as trust resources) under
the U.S. Fish and Wildlife Service's (USFWS) jurisdiction that are known or expected to be on or near the project area referenced below. The list may
also include trust resources that occur outside of the project area, but that could potentially be directly or indirectly a!ected by activities in the project
area. However, determining the likelihood and extent of e!ects a project may have on trust resources typically requires gathering additional site-
speci"c (e.g., vegetation/species surveys) and project-speci"c (e.g., magnitude and timing of proposed activities) information.
Below is a summary of the project information you provided and contact information for the USFWS o#ce(s) with jurisdiction in the de"ned project
area. Please read the introduction to each section that follows (Endangered Species, Migratory Birds, USFWS Facilities, and NWI Wetlands) for
additional information applicable to the trust resources addressed in that section.
Location
Maricopa County, Arizona
Local o#ce
Arizona Ecological Services Field O#ce
! (602) 242-0210
" (602) 242-2513
9828 North 31st Ave
#c3
Phoenix, AZ 85051-2517
http://www.fws.gov/southwest/es/arizona/
http://www.fws.gov/southwest/es/EndangeredSpecies_Main.html
Endangered species
This resource list is for informational purposes only and does not constitute an analysis of project level impacts.
The primary information used to generate this list is the known or expected range of each species. Additional areas of in$uence (AOI) for species are
also considered. An AOI includes areas outside of the species range if the species could be indirectly a!ected by activities in that area (e.g., placing a
dam upstream of a "sh population, even if that "sh does not occur at the dam site, may indirectly impact the species by reducing or eliminating water
$ow downstream). Because species can move, and site conditions can change, the species on this list are not guaranteed to be found on or near the
project area. To fully determine any potential e!ects to species, additional site-speci"c and project-speci"c information is often required.
Section 7 of the Endangered Species Act requires Federal agencies to "request of the Secretary information whether any species which is listed or
proposed to be listed may be present in the area of such proposed action" for any project that is conducted, permitted, funded, or licensed by any
Federal agency. A letter from the local o#ce and a species list which ful"lls this requirement can only be obtained by requesting an o#cial species list
from either the Regulatory Review section in IPaC (see directions below) or from the local "eld o#ce directly.
For project evaluations that require USFWS concurrence/review, please return to the IPaC website and request an o#cial species list by doing the
following:
1. Draw the project location and click CONTINUE.
2. Click DEFINE PROJECT.
3. Log in (if directed to do so).
4. Provide a name and description for your project.
5. Click REQUEST SPECIES LIST.
U.S. Fish & Wildlife Service
IPaC Information for Planning and Consultation

Listed species and their critical habitats are managed by the Ecological Services Program of the U.S. Fish and Wildlife Service (USFWS) and the
"sheries division of the National Oceanic and Atmospheric Administration (NOAA Fisheries ).
Species and critical habitats under the sole responsibility of NOAA Fisheries are not shown on this list. Please contact NOAA Fisheries for species under
their jurisdiction.
1. Species listed under the Endangered Species Act are threatened or endangered; IPaC also shows species that are candidates, or proposed, for
listing. See the listing status page for more information.
2. NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an o#ce of the National Oceanic and Atmospheric Administration
within the Department of Commerce.
The following species are potentially a!ected by activities in this location:
Mammals
Birds
Fishes
Critical habitats
Potential e!ects to critical habitat(s) in this location must be analyzed along with the endangered species themselves.
THERE ARE NO CRITICAL HABITATS AT THIS LOCATION.
Migratory birds
1
2
NAME
STATUS
Sonoran Pronghorn Antilocapra americana sonoriensis
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecp/species/4750
EXPN
NAME
STATUS
California Least Tern Sterna antillarum browni
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecp/species/8104
Endangered
Southwestern Willow Flycatcher Empidonax traillii extimus
There is !nal critical habitat for this species. Your location is outside the critical habitat.
https://ecos.fws.gov/ecp/species/6749
Endangered
Yellow-billed Cuckoo Coccyzus americanus
There is proposed critical habitat for this species. Your location is outside the critical habitat.
https://ecos.fws.gov/ecp/species/3911
Threatened
Yuma Ridgways (clapper) Rail Rallus obsoletus [=longirostris] yumanensis
No critical habitat has been designated for this species.
https://ecos.fws.gov/ecp/species/3505
Endangered
NAME
STATUS
Desert Pup"sh Cyprinodon macularius
There is !nal critical habitat for this species. Your location is outside the critical habitat.
https://ecos.fws.gov/ecp/species/7003
Endangered
Certain birds are protected under the Migratory Bird Treaty Act and the Bald and Golden Eagle
Protection Act .
Any person or organization who plans or conducts activities that may result in impacts to
migratory birds, eagles, and their habitats should follow appropriate regulations and consider
implementing appropriate conservation measures, as described below.
1. The Migratory Birds Treaty Act of 1918.
2. The Bald and Golden Eagle Protection Act of 1940.
1
2

MIGRATORY BIRD INFORMATION IS NOT AVAILABLE AT THIS TIME
Tell me more about conservation measures I can implement to avoid or minimize impacts to migratory birds.
Nationwide Conservation Measures describes measures that can help avoid and minimize impacts to all birds at any location year round. Implementation of these
measures is particularly important when birds are most likely to occur in the project area. When birds may be breeding in the area, identifying the locations of any active
nests and avoiding their destruction is a very helpful impact minimization measure. To see when birds are most likely to occur and be breeding in your project area, view
the Probability of Presence Summary. Additional measures and/or permits may be advisable depending on the type of activity you are conducting and the type of
infrastructure or bird species present on your project site.
What does IPaC use to generate the migratory birds potentially occurring in my speci!ed location?
The Migratory Bird Resource List is comprised of USFWS Birds of Conservation Concern (BCC) and other species that may warrant special attention in your project location.
The migratory bird list generated for your project is derived from data provided by the Avian Knowledge Network (AKN). The AKN data is based on a growing collection of
survey, banding, and citizen science datasets and is queried and "ltered to return a list of those birds reported as occurring in the 10km grid cell(s) which your project
intersects, and that have been identi"ed as warranting special attention because they are a BCC species in that area, an eagle (Eagle Act requirements may apply), or a
species that has a particular vulnerability to o!shore activities or development.
Again, the Migratory Bird Resource list includes only a subset of birds that may occur in your project area. It is not representative of all birds that may occur in your project
area. To get a list of all birds potentially present in your project area, please visit the AKN Phenology Tool.
What does IPaC use to generate the probability of presence graphs for the migratory birds potentially occurring in my speci!ed location?
The probability of presence graphs associated with your migratory bird list are based on data provided by the Avian Knowledge Network (AKN). This data is derived from a
growing collection of survey, banding, and citizen science datasets .
Probability of presence data is continuously being updated as new and better information becomes available. To learn more about how the probability of presence graphs
are produced and how to interpret them, go the Probability of Presence Summary and then click on the "Tell me about these graphs" link.
How do I know if a bird is breeding, wintering, migrating or present year-round in my project area?
To see what part of a particular bird's range your project area falls within (i.e. breeding, wintering, migrating or year-round), you may refer to the following resources: The
Cornell Lab of Ornithology All About Birds Bird Guide, or (if you are unsuccessful in locating the bird of interest there), the Cornell Lab of Ornithology Neotropical Birds
guide. If a bird on your migratory bird species list has a breeding season associated with it, if that bird does occur in your project area, there may be nests present at some
point within the timeframe speci"ed. If "Breeds elsewhere" is indicated, then the bird likely does not breed in your project area.
What are the levels of concern for migratory birds?
Migratory birds delivered through IPaC fall into the following distinct categories of concern:
1. "BCC Rangewide" birds are Birds of Conservation Concern (BCC) that are of concern throughout their range anywhere within the USA (including Hawaii, the Paci"c
Islands, Puerto Rico, and the Virgin Islands);
2. "BCC - BCR" birds are BCCs that are of concern only in particular Bird Conservation Regions (BCRs) in the continental USA; and
3. "Non-BCC - Vulnerable" birds are not BCC species in your project area, but appear on your list either because of the Eagle Act requirements (for eagles) or (for non-
eagles) potential susceptibilities in o!shore areas from certain types of development or activities (e.g. o!shore energy development or longline "shing).
Although it is important to try to avoid and minimize impacts to all birds, e!orts should be made, in particular, to avoid and minimize impacts to the birds on this list,
especially eagles and BCC species of rangewide concern. For more information on conservation measures you can implement to help avoid and minimize migratory bird
impacts and requirements for eagles, please see the FAQs for these topics.
Details about birds that are potentially a"ected by o"shore projects
For additional details about the relative occurrence and abundance of both individual bird species and groups of bird species within your project area o! the Atlantic Coast,
please visit the Northeast Ocean Data Portal. The Portal also o!ers data and information about other taxa besides birds that may be helpful to you in your project review.
Alternately, you may download the bird model results "les underlying the portal maps through the NOAA NCCOS Integrative Statistical Modeling and Predictive Mapping of
Marine Bird Distributions and Abundance on the Atlantic Outer Continental Shelf project webpage.
Bird tracking data can also provide additional details about occurrence and habitat use throughout the year, including migration. Models relying on survey data may not
include this information. For additional information on marine bird tracking data, see the Diving Bird Study and the nanotag studies or contact Caleb Spiegel or Pam Loring.
What if I have eagles on my list?
If your project has the potential to disturb or kill eagles, you may need to obtain a permit to avoid violating the Eagle Act should such impacts occur.
Additional information can be found using the following links:
Birds of Conservation Concern http://www.fws.gov/birds/management/managed-species/
birds-of-conservation-concern.php
Measures for avoiding and minimizing impacts to birds
http://www.fws.gov/birds/management/project-assessment-tools-and-guidance/
conservation-measures.php
Nationwide conservation measures for birds
http://www.fws.gov/migratorybirds/pdf/management/nationwidestandardconservationmeasures.pdf

Proper Interpretation and Use of Your Migratory Bird Report
The migratory bird list generated is not a list of all birds in your project area, only a subset of birds of priority concern. To learn more about how your list is generated, and
see options for identifying what other birds may be in your project area, please see the FAQ “What does IPaC use to generate the migratory birds potentially occurring in my
speci"ed location”. Please be aware this report provides the “probability of presence” of birds within the 10 km grid cell(s) that overlap your project; not your exact project
footprint. On the graphs provided, please also look carefully at the survey e!ort (indicated by the black vertical bar) and for the existence of the “no data” indicator (a red
horizontal bar). A high survey e!ort is the key component. If the survey e!ort is high, then the probability of presence score can be viewed as more dependable. In contrast,
a low survey e!ort bar or no data bar means a lack of data and, therefore, a lack of certainty about presence of the species. This list is not perfect; it is simply a starting
point for identifying what birds of concern have the potential to be in your project area, when they might be there, and if they might be breeding (which means nests might
be present). The list helps you know what to look for to con"rm presence, and helps guide you in knowing when to implement conservation measures to avoid or minimize
potential impacts from your project activities, should presence be con"rmed. To learn more about conservation measures, visit the FAQ “Tell me about conservation
measures I can implement to avoid or minimize impacts to migratory birds” at the bottom of your migratory bird trust resources page.
Facilities
National Wildlife Refuge lands
Any activity proposed on lands managed by the National Wildlife Refuge system must undergo a 'Compatibility Determination' conducted by the
Refuge. Please contact the individual Refuges to discuss any questions or concerns.
THERE ARE NO REFUGE LANDS AT THIS LOCATION.
Fish hatcheries
THERE ARE NO FISH HATCHERIES AT THIS LOCATION.
Wetlands in the National Wetlands Inventory
Impacts to NWI wetlands and other aquatic habitats may be subject to regulation under Section 404 of the Clean Water Act, or other State/Federal
statutes.
For more information please contact the Regulatory Program of the local U.S. Army Corps of Engineers District.
Please note that the NWI data being shown may be out of date. We are currently working to update our NWI data set. We recommend you verify these
results with a site visit to determine the actual extent of wetlands on site.
This location overlaps the following wetlands:
Data limitations
The Service's objective of mapping wetlands and deepwater habitats is to produce reconnaissance level information on the location, type and size of these resources. The
maps are prepared from the analysis of high altitude imagery. Wetlands are identi"ed based on vegetation, visible hydrology and geography. A margin of error is inherent in
the use of imagery; thus, detailed on-the-ground inspection of any particular site may result in revision of the wetland boundaries or classi"cation established through
image analysis.
The accuracy of image interpretation depends on the quality of the imagery, the experience of the image analysts, the amount and quality of the collateral data and the
amount of ground truth veri"cation work conducted. Metadata should be consulted to determine the date of the source imagery used and any mapping problems.
Wetlands or other mapped features may have changed since the date of the imagery or "eld work. There may be occasional di!erences in polygon boundaries or
classi"cations between the information depicted on the map and the actual conditions on site.
Data exclusions
Certain wetland habitats are excluded from the National mapping program because of the limitations of aerial imagery as the primary data source used to detect wetlands.
These habitats include seagrasses or submerged aquatic vegetation that are found in the intertidal and subtidal zones of estuaries and nearshore coastal waters. Some
FRESHWATER POND
PUBF
RIVERINE
R4SBC
R5UBH
R5UBFx
A full description for each wetland code can be found at the National Wetlands Inventory website

deepwater reef communities (coral or tuber"cid worm reefs) have also been excluded from the inventory. These habitats, because of their depth, go undetected by aerial
imagery.
Data precautions
Federal, state, and local regulatory agencies with jurisdiction over wetlands may de"ne and describe wetlands in a di!erent manner than that used in this inventory. There
is no attempt, in either the design or products of this inventory, to de"ne the limits of proprietary jurisdiction of any Federal, state, or local government or to establish the
geographical scope of the regulatory programs of government agencies. Persons intending to engage in activities involving modi"cations within or adjacent to wetland
areas should seek the advice of appropriate federal, state, or local agencies concerning speci"ed agency regulatory programs and proprietary jurisdictions that may a!ect
such activities.

Exhibit B 
 
AGFD PEP Report

Arizona Environmental Online Review Tool Report
Arizona Game and Fish Department Mission
To conserve Arizona's diverse wildlife resources and manage for safe, compatible outdoor recreation
opportunities for current and future generations.
Project Name:
Sun Streams Expansion
Project Description:
Potential solar project
Project Type:
Energy Storage/Production/Transfer, Energy Production (generation), photovoltaic solar facility (new)
Contact Person:
Patrick Golden
Organization:
Heritage Environmental Consultants
On Behalf Of:
CONSULTING
Project ID:
HGIS-11229
Please review the entire report for project type and/or species recommendations for the location
information entered. Please retain a copy for future reference.
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Arizona Game and Fish Department
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Project ID: HGIS-11229
Review Date: 5/26/2020 09:34:31 AM
Disclaimer: 
1. This Environmental Review is based on the project study area that was entered. The report must be
updated if the project study area, location, or the type of project changes.
2. This is a preliminary environmental screening tool. It is not a substitute for the potential knowledge
gained by having a biologist conduct a field survey of the project area. This review is also not intended to
replace environmental consultation (including federal consultation under the Endangered Species Act),
land use permitting, or the Departments review of site-specific projects.
3. The Departments Heritage Data Management System (HDMS) data is not intended to include potential
distribution of special status species. Arizona is large and diverse with plants, animals, and
environmental conditions that are ever changing. Consequently, many areas may contain species that
biologists do not know about or species previously noted in a particular area may no longer occur there.
HDMS data contains information about species occurrences that have actually been reported to the
Department. Not all of Arizona has been surveyed for special status species, and surveys that have been
conducted have varied greatly in scope and intensity. Such surveys may reveal previously
undocumented population of species of special concern.
4. HabiMap Arizona data, specifically Species of Greatest Conservation Need (SGCN) under our State
Wildlife Action Plan (SWAP) and Species of Economic and Recreational Importance (SERI), represent
potential species distribution models for the State of Arizona which are subject to ongoing change,
modification and refinement. The status of a wildlife resource can change quickly, and the availability of
new data will necessitate a refined assessment.
Locations Accuracy Disclaimer:
Project locations are assumed to be both precise and accurate for the purposes of environmental review. The
creator/owner of the Project Review Report is solely responsible for the project location and thus the correctness
of the Project Review Report content.
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Project ID: HGIS-11229
Review Date: 5/26/2020 09:34:31 AM
Recommendations Disclaimer:
1. The Department is interested in the conservation of all fish and wildlife resources, including those
species listed in this report and those that may have not been documented within the project vicinity as
well as other game and nongame wildlife.
2. Recommendations have been made by the Department, under authority of Arizona Revised Statutes
Title 5 (Amusements and Sports), 17 (Game and Fish), and 28 (Transportation).
3. Potential impacts to fish and wildlife resources may be minimized or avoided by the recommendations
generated from information submitted for your proposed project. These recommendations are preliminary
in scope, designed to provide early considerations on all species of wildlife.
4. Making this information directly available does not substitute for the Department's review of project
proposals, and should not decrease our opportunity to review and evaluate additional project information
and/or new project proposals.
5. Further coordination with the Department requires the submittal of this Environmental Review Report with
a cover letter and project plans or documentation that includes project narrative, acreage to be impacted,
how construction or project activity(s) are to be accomplished, and project locality information (including
site map). Once AGFD had received the information, please allow 30 days for completion of project
reviews. Send requests to:
Project Evaluation Program, Habitat Branch
Arizona Game and Fish Department
5000 West Carefree Highway
Phoenix, Arizona 85086-5000
Phone Number: (623) 236-7600
Fax Number: (623) 236-7366
Or
PEP@azgfd.gov
6. Coordination may also be necessary under the National Environmental Policy Act (NEPA) and/or
Endangered Species Act (ESA). Site specific recommendations may be proposed during further
NEPA/ESA analysis or through coordination with affected agencies
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Project ID: HGIS-11229
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project_report_sun_streams_expansion_35986_37166.pdf
Project ID: HGIS-11229
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project_report_sun_streams_expansion_35986_37166.pdf
Project ID: HGIS-11229
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project_report_sun_streams_expansion_35986_37166.pdf
Project ID: HGIS-11229
Review Date: 5/26/2020 09:34:31 AM
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Arizona Game and Fish Department
project_report_sun_streams_expansion_35986_37166.pdf
Project ID: HGIS-11229
Review Date: 5/26/2020 09:34:31 AM
Special Status Species Documented within 5 Miles of Project Vicinity
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Athene cunicularia hypugaea
Western Burrowing Owl
SC
S
S
1B
Coccyzus americanus
Yellow-billed Cuckoo (Western DPS)
LT
S
1A
Crotaphytus nebrius
Sonoran Collared Lizard
1B
Empidonax traillii extimus
Southwestern Willow Flycatcher
LE
1A
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1A
Lithobates yavapaiensis
Lowland Leopard Frog
SC
S
S
1A
Opuntia echinocarpa
Straw-top Cholla
SR
Rallus obsoletus yumanensis
Yuma Ridgway's Rail
LE
1A
Toxostoma lecontei
LeConte's Thrasher
S
1B
Note: Status code definitions can be found at https://www.azgfd.com/wildlife/planning/wildlifeguidelines/statusdefinitions/
. 
Special Areas Documented within the Project Vicinity
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Hassayampa River
Maricopa County Wildlife Movement
Area - Riparian/Wash
Important Connectivity Zone
Wildlife Connectivity
Note: Status code definitions can be found at https://www.azgfd.com/wildlife/planning/wildlifeguidelines/statusdefinitions/
. 
Species of Greatest Conservation Need Predicted within the Project Vicinity based on Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Aix sponsa
Wood Duck
1B
Ammospermophilus harrisii
Harris' Antelope Squirrel
1B
Anaxyrus microscaphus
Arizona Toad
SC
S
1B
Anaxyrus retiformis
Sonoran Green Toad
S
1B
Anthus spragueii
Sprague's Pipit
SC
1A
Aquila chrysaetos
Golden Eagle
BGA
S
1B
Athene cunicularia hypugaea
Western Burrowing Owl
SC
S
S
1B
Botaurus lentiginosus
American Bittern
1B
Buteo regalis
Ferruginous Hawk
SC
S
1B
Calypte costae
Costa's Hummingbird
1C
Castor canadensis
American Beaver
1B
Chilomeniscus stramineus
Variable Sandsnake
1B
Cistothorus palustris
Marsh Wren
1C
Colaptes chrysoides
Gilded Flicker
S
1B
Coluber bilineatus
Sonoran Whipsnake
1B
Corynorhinus townsendii pallescens Pale Townsend's Big-eared Bat
SC
S
S
1B
Crotalus tigris
Tiger Rattlesnake
1B
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Arizona Game and Fish Department
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Project ID: HGIS-11229
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Species of Greatest Conservation Need Predicted within the Project Vicinity based on Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Crotaphytus nebrius
Sonoran Collared Lizard
1B
Empidonax traillii extimus
Southwestern Willow Flycatcher
LE
1A
Euderma maculatum
Spotted Bat
SC
S
S
1B
Eumops perotis californicus
Greater Western Bonneted Bat
SC
S
1B
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1A
Haliaeetus leucocephalus
Bald Eagle
SC,
BGA
S
S
1A
Heloderma suspectum
Gila Monster
1A
Incilius alvarius
Sonoran Desert Toad
1B
Kinosternon sonoriense sonoriense
Desert Mud Turtle
S
1B
Lasiurus blossevillii
Western Red Bat
S
1B
Lasiurus xanthinus
Western Yellow Bat
S
1B
Leptonycteris yerbabuenae
Lesser Long-nosed Bat
SC
1A
Lepus alleni
Antelope Jackrabbit
1B
Lithobates yavapaiensis
Lowland Leopard Frog
SC
S
S
1A
Macrotus californicus
California Leaf-nosed Bat
SC
S
1B
Melanerpes uropygialis
Gila Woodpecker
1B
Melospiza lincolnii
Lincoln's Sparrow
1B
Melozone aberti
Abert's Towhee
S
1B
Micrathene whitneyi
Elf Owl
1C
Micruroides euryxanthus
Sonoran Coralsnake
1B
Myotis velifer
Cave Myotis
SC
S
1B
Myotis yumanensis
Yuma Myotis
SC
1B
Nyctinomops femorosaccus
Pocketed Free-tailed Bat
1B
Oreoscoptes montanus
Sage Thrasher
1C
Oreothlypis luciae
Lucy's Warbler
1C
Passerculus sandwichensis
Savannah Sparrow
1B
Perognathus longimembris
Little Pocket Mouse
No
Status
1B
Phrynosoma solare
Regal Horned Lizard
1B
Rallus obsoletus yumanensis
Yuma Ridgway's Rail
LE
1A
Setophaga petechia
Yellow Warbler
1B
Sphyrapicus nuchalis
Red-naped Sapsucker
1C
Spizella breweri
Brewer's Sparrow
1C
Sturnella magna
Eastern Meadowlark
1C
Tadarida brasiliensis
Brazilian Free-tailed Bat
1B
Toxostoma lecontei
LeConte's Thrasher
S
1B
Troglodytes pacificus
Pacific Wren
1B
Vireo bellii arizonae
Arizona Bell's Vireo
1B
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Project ID: HGIS-11229
Review Date: 5/26/2020 09:34:31 AM
Species of Greatest Conservation Need Predicted within the Project Vicinity based on Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Vulpes macrotis
Kit Fox
No
Status
1B
Species of Economic and Recreation Importance Predicted within the Project Vicinity
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Callipepla gambelii
Gambel's Quail
Pecari tajacu
Javelina
Puma concolor
Mountain Lion
Zenaida asiatica
White-winged Dove
Zenaida macroura
Mourning Dove
Project Type: Energy Storage/Production/Transfer, Energy Production (generation), photovoltaic solar facility
(new)
Project Type Recommendations:
During the planning stages of your project, please consider the local or regional needs of wildlife in regards to movement,
connectivity, and access to habitat needs. Loss of this permeability prevents wildlife from accessing resources, finding
mates, reduces gene flow, prevents wildlife from re-colonizing areas where local extirpations may have occurred, and
ultimately prevents wildlife from contributing to ecosystem functions, such as pollination, seed dispersal, control of prey
numbers, and resistance to invasive species. In many cases, streams and washes provide natural movement corridors
for wildlife and should be maintained in their natural state. Uplands also support a large diversity of species, and should
be contained within important wildlife movement corridors. In addition, maintaining biodiversity and ecosystem functions
can be facilitated through improving designs of structures, fences, roadways, and culverts to promote passage for a
variety of wildlife. Guidelines for many of these can be found
at: https://www.azgfd.com/wildlife/planning/wildlifeguidelines/.
Consider impacts of outdoor lighting on wildlife and develop measures or alternatives that can be taken to increase
human safety while minimizing potential impacts to wildlife. Conduct wildlife surveys to determine species within project
area, and evaluate proposed activities based on species biology and natural history to determine if artificial lighting may
disrupt behavior patterns or habitat use. Use only the minimum amount of light needed for safety. Narrow spectrum bulbs
should be used as often as possible to lower the range of species affected by lighting. All lighting should be shielded,
canted, or cut to ensure that light reaches only areas needing illumination.
Minimize potential introduction or spread of exotic invasive species. Invasive species can be plants, animals (exotic
snails), and other organisms (e.g., microbes), which may cause alteration to ecological functions or compete with or prey
upon native species and can cause social impacts (e.g., livestock forage reduction, increase wildfire risk). The terms
noxious weed or invasive plants are often used interchangeably. Precautions should be taken to wash all equipment
utilized in the project activities before leaving the site. Arizona has noxious weed regulations (Arizona Revised Statutes,
Rules R3-4-244 and R3-4-245). See Arizona Department of Agriculture website for restricted plants, 
https://agriculture.az.gov/. Additionally, the U.S. Department of Agriculture has information regarding pest and invasive
plant control methods including: pesticide, herbicide, biological control agents, and mechanical control, 
https://www.nrcs.usda.gov/wps/portal/nrcs/detailfull/national/water/quality/?cid=stelprdb1044769 The Department
regulates the importation, purchasing, and transportation of wildlife and fish (Restricted Live Wildlife), please refer to the
hunting regulations for further information https://www.azgfd.com/hunting/regulations.
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Project ID: HGIS-11229
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Minimization and mitigation of impacts to wildlife and fish species due to changes in water quality, quantity, chemistry,
temperature, and alteration to flow regimes (timing, magnitude, duration, and frequency of floods) should be evaluated.
Minimize impacts to springs, in-stream flow, and consider irrigation improvements to decrease water use. If dredging is a
project component, consider timing of the project in order to minimize impacts to spawning fish and other aquatic species
(include spawning seasons), and to reduce spread of exotic invasive species. We recommend early direct coordination
with Project Evaluation Program for projects that could impact water resources, wetlands, streams, springs, and/or
riparian habitats.
The Department recommends that wildlife surveys are conducted to determine if noise-sensitive species occur within the
project area. Avoidance or minimization measures could include conducting project activities outside of breeding
seasons.
For any powerlines built, proper design and construction of the transmission line is necessary to prevent or minimize risk
of electrocution of raptors, owls, vultures, and golden or bald eagles, which are protected under state and federal laws.
Limit project activities during the breeding season for birds, generally March through late August, depending on species
in the local area (raptors breed in early February through May). Conduct avian surveys to determine bird species that
may be utilizing the area and develop a plan to avoid disturbance during the nesting season. For underground
powerlines, trenches should be covered or back-filled as soon as possible. Incorporate escape ramps in ditches or
fencing along the perimeter to deter small mammals and herptefauna (snakes, lizards, tortoise) from entering ditches. In
addition, indirect affects to wildlife due to construction (timing of activity, clearing of rights-of-way, associated bridges and
culverts, affects to wetlands, fences) should also be considered and mitigated.
Based on the project type entered, coordination with State Historic Preservation Office may be required
(http://azstateparks.com/SHPO/index.html).
Based on the project type entered, coordination with U.S. Fish and Wildlife Service (Migratory Bird Treaty Act) may be
required (http://www.fws.gov/southwest/es/arizona/).
Vegetation restoration projects (including treatments of invasive or exotic species) should have a completed site-
evaluation plan (identifying environmental conditions necessary to re-establish native vegetation), a revegetation plan
(species, density, method of establishment), a short and long-term monitoring plan, including adaptive management
guidelines to address needs for replacement vegetation.
The Department requests further coordination to provide project/species specific recommendations, please
contact Project Evaluation Program directly at PEP@azgfd.gov. 
Project Location and/or Species Recommendations:
HDMS records indicate that one or more native plants listed on the Arizona Native Plant Law and Antiquities Act have
been documented within the vicinity of your project area. Please contact:
Arizona Department of Agriculture
1688 W Adams St.
Phoenix, AZ 85007
Phone: 602.542.4373
https://agriculture.az.gov/sites/default/files/Native%20Plant%20Rules%20-%20AZ%20Dept%20of%20Ag.pdf starts on
page 44
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HDMS records indicate that one or more Listed, Proposed, or Candidate species or Critical Habitat (Designated or
Proposed) have been documented in the vicinity of your project. The Endangered Species Act (ESA) gives the US Fish
and Wildlife Service (USFWS) regulatory authority over all federally listed species. Please contact USFWS Ecological
Services Offices at http://www.fws.gov/southwest/es/arizona/ or:
 
Phoenix Main Office
Tucson Sub-Office
Flagstaff Sub-Office
9828 North 31st Avenue #C3
201 N. Bonita Suite 141
SW Forest Science Complex
Phoenix, AZ 85051-2517
Tucson, AZ 85745
2500 S. Pine Knoll Dr.
Phone: 602-242-0210
Phone: 520-670-6144
Flagstaff, AZ 86001
Fax: 602-242-2513
Fax: 520-670-6155
Phone: 928-556-2157
 
 
Fax: 928-556-2121
 
 
 
HDMS records indicate that Western Burrowing Owls have been documented within the vicinity of your project area.
Please review the western burrowing owl resource page at: 
https://www.azgfd.com/wildlife/speciesofgreatestconservneed/burrowingowlmanagement/.
HDMS records indicate that Sonoran Desert Tortoise have been documented within the vicinity of your project area.
Please review the Tortoise Handling Guidelines found at: https://www.azgfd.com/wildlife/nongamemanagement/tortoise/
Analysis indicates that your project is located in the vicinity of an identified wildlife habitat connectivity feature. The 
County-level Stakeholder Assessments contain five categories of data (Barrier/Development, Wildlife Crossing Area,
Wildlife Movement Area- Diffuse, Wildlife movement Area- Landscape, Wildlife Movement Area- Riparian/Washes) that
provide a context of select anthropogenic barriers, and potential connectivity. The reports provide recommendations for
opportunities to preserve or enhance permeability. Project planning and implementation efforts should focus on
maintaining and improving opportunities for wildlife permeability. For information pertaining to the linkage assessment
and wildlife species that may be affected, please refer
to: https://www.azgfd.com/wildlife/planning/habitatconnectivity/identifying-corridors/.
Please contact the Project Evaluation Program (pep@azgfd.gov) for specific project recommendations.
Analysis indicates that your project is located in the vicinity of an identified wildlife habitat connectivity feature.
The Statewide Wildlife Connectivity Assessment’s Important Connectivity Zones (ICZs) represent general areas
throughout the landscape which contribute the most to permeability of the whole landscape. ICZs may be used to help
identify, in part, areas where more discrete corridor modeling ought to occur. The reports provide recommendations for
opportunities to preserve or enhance permeability. Project planning and implementation efforts should focus on
maintaining and improving opportunities for wildlife permeability. For information pertaining to the linkage assessment
and wildlife species that may be affected, please refer
to: https://s3.amazonaws.com/azgfd-portal-wordpress/azgfd.wp/wp-
content/uploads/0001/01/23120719/ALIWCA_Final_Report_Perkl_2013_lowres.pdf.
Please contact the Project Evaluation Program (pep@azgfd.gov) for specific project recommendations.
Powered by TCPDF (www.tcpdf.org)
Page 12 of 12

July  1,  2020 
 
Mr.  Adam  Cannon,  Planner 
Maricopa  County  Planning  &  Development  Department 
501  N.  44th  Street,  Suite  200 
Phoenix,  AZ  85008 
 
RE:  Sun  Streams  Expansion  Project 
 
Dear  Mr.  Cannon: 
 
The  Arizona  Game  and  Fish  Department  (Department)  has  reviewed  the  Comprehensive  Plan 
 
 
 
 
 
 
 
 
 
 
 
 
Amendments  sent  to  Maricopa  County.  It  is  our  understating  Sun  Streams  Expansions,  LLC  is 
 
 
 
 
   
 
 
 
 
 
  
proposing  the  development  of  a  PV  solar  generation  facility  with  energy  storage  and  associated 
 
 
 
  
 
 
 
 
 
 
 
 
 
facilities.  It  is  estimated  that  the  Project  will  generate  approximately  450  megawatts  (MWs)  of 
   
 
 
 
 
 
 
 
 
 
 
 
solar  generation  and  up  to  300  MWs  of  battery  storage  with  a  total  footprint  of  3,225  acres.  A 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
  
new  high  voltage  utility  line  would  be  needed  from  the  site  to  the  Chukar  Substation  located  just 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
east  of  the  existing  Hassayampa  Switchyard,  approximately  2  miles  west  of  the  southern  portion 
 
 
 
 
 
 
  
 
 
 
 
 
 
of  the  Project  site.  
 
Under  Title  17  of  the  Arizona  Revised  Statutes,  the  Department,  by  and  through  the  Arizona 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Game  and  Fish  Commission  (Commission),  has  jurisdictional  authority  and  public  trust 
 
 
 
 
 
 
 
 
 
 
 
responsibilities  for  management  of  the  state's  fish  and  wildlife  resources.  It  is  the  mission  of  the 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
Department  to  conserve  Arizona’s  diverse  fish  and  wildlife  resources  and  manage  for  safe, 
 
 
 
 
 
 
 
 
 
 
 
 
 
compatible  outdoor  recreation  opportunities  for  current  and  future  generations.  Therefore,  the 
 
 
 
 
 
 
 
 
 
 
 
Department  recommends  the  following  be  considered  to  minimize  the  potential  impacts  to 
 
 
 
 
 
 
 
 
 
 
 
 
wildlife  habitat  and  populations  resulting  from  the  development  and  operation  of  the  facility: 
 
1. Surveys  should  be  conducted  for  western  burrowing  owl.  Burrowing  owls  commonly  use 
 
 
 
 
 
 
 
 
 
 
 
 
the  berms  along  agriculture  fields  to  create  their  burrows.  Survey  protocols  and 
 
 
 
 
 
 
 
 
 
 
 
 
guidelines  exist  at  https://www.azgfd.com/wildlife/planning/wildlifeguidelines/.  If  they 
 
 
 
 
 
 
are  present,  contact  the  US  Fish  and  Wildlife  Service  for  further  direction. 
2. If  wildlife  is  encountered  during  construction  of  the  facility,  it  should  be  moved  outside 
 
  
 
 
 
 
 
  
 
 
 
 
the  project  area  within  1  mile  of  its  original  location.  A  scientific  collecting  permit  is 
 
 
 
  
 
 
 
 
 
 
 
 
  
required  for  this  activity.  A  permit  can  be  obtained  by  emailing  Scpermit@azgfd.gov  for 
 
 
 
  
 
 
 
 
 
 
 
 
more  information.  If  wildlife  will  need  to  be  removed  from  the  facility  once  it  is 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
operational,  annual  renewal  of  the  permit  will  be  required.  Additionally,  any  wildlife 
 
 
 
 
 
 
 
 
 
 
 
 
mortalities  should  be  reported  to  Andrew  Cavalcant  at  acavalcant@azgfd.gov . 
3. Artificial  night  lighting,  which  may  be  intensified  by  the  collection  mirrors,  may  attract 
 
 
 
 
 
 
 
 
 
 
 
 
 
insects  and  the  species  that  prey  on  them  (e.g.  bats).  It  could  also  impair  the  ability  of 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
nocturnal  animals  to  navigate  and  may  negatively  affect  reptile  populations.  The

Sun  Streams  Expansion  Project 
July  1,  2020 
Page  2 
Department  recommends  using  only  the  minimum  amount  of  light  needed  for  safety. 
 
 
 
 
 
 
 
 
 
 
 
 
Narrow  spectrum  bulbs  should  be  used  as  often  as  possible  to  lower  the  range  of  species 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
affected  by  lighting.  All  lighting  should  be  shielded,  canted,  or  cut  to  ensure  that  light 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
reaches  only  areas  needing  illumination.  
4. For  any  powerlines  built,  proper  design  and  construction  of  the  transmission  line  is 
 
 
 
 
 
 
 
 
 
 
 
 
 
necessary  to  prevent  or  minimize  risk  of  electrocution  of  raptors,  owls,  vultures,  and 
 
 
 
 
 
 
 
 
 
 
 
 
 
golden  or  bald  eagles,  which  are  protected  under  state  and  federal  laws.  The  Department 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
requests  perching  structures  be  minimized  to  the  extent  possible  to  reduce  impacts  to  prey 
 
 
 
 
  
 
 
  
 
  
 
species  within  the  vicinity  of  the  line.  Additionally,  it  is  recommended  to  consider  using 
 
 
 
 
 
 
 
   
 
 
 
 
bird  flight  diverters.  If  not,  the  Department  requests  an  impact  analysis  for  potential 
 
 
 
 
 
 
 
 
 
 
 
 
 
increases  in  avian  mortality  that  could  result  from  this  line.  
5. The  Department  is  concerned  about  the  impacts  that  may  occur  to  water  resources  from 
 
  
 
 
 
 
 
 
 
 
 
 
 
the  project,  specifically  surface  hydrology.  Sonoran  desert  habitats  and  its  associated 
 
 
 
 
 
 
 
 
 
 
 
fauna  are  highly  dependent  on  the  minimal  precipitation  received  each  year.  The  resulting 
 
 
 
 
 
 
 
 
 
 
 
 
 
sheet  flows  contribute  significantly  to  the  hydrology  of  areas  where  rain  events  often 
 
 
 
 
 
 
 
 
 
 
 
 
 
occur  in  isolated  patches.  Any  disruptions  to  surface  flows,  both  in  washes  and  across 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
uplands,  could  lead  to  broad  scale  mortality  of  desert  vegetation  and  potentially  change 
 
 
 
 
 
 
 
 
 
 
 
 
 
wildlife  species  distributions  and  abundance  beyond  the  project  footprint.  The 
 
 
 
 
 
 
 
 
 
 
Department  recommends  avoiding  all  washes  and/or  changing  the  hydrology  of  the  site. 
 
 
 
 
 
 
 
 
 
 
 
 
If  this  isn’t  feasible,  the  Department  requests  an  impact  analysis  be  conducted  to  assess 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
up  and  down  stream  impacts  that  may  result  from  changes  in  flows.  Retention  basins  may 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
need  to  be  installed  and should  be  of  an  appropriate  size  based  on  the  water  infiltration 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
rate  for  the  soil  types  to  mitigate  excessive  runoff.  
6. Evaporation  ponds  could  lead  to  inadvertent  poisoning  and/or  accidental  drowning  of 
 
 
 
 
 
 
 
 
 
 
 
wildlife.  The  Department  recommends  fencing  the  perimeter  and  placing  screens  on  the 
 
 
 
 
 
 
 
 
 
 
 
 
top  to  prevent  wildlife  from  entering.  Additionally,  the  Department  recommends 
 
 
 
 
 
 
 
 
 
 
monitoring  ponds  for  toxicity  and  developing  contingency  plans  should  wildlife  mortality 
 
 
 
 
 
 
 
 
 
 
 
or  toxicity  occurs.  
Thank  you  for  the  opportunity  to  provide  comments  on  this  proposed  project.  We  look  forward  to 
 
 
 
 
  
 
 
 
 
 
 
 
 
  
continued  communications  with  the  county  and  the  applicant  regarding  project  development  and 
 
 
 
 
 
 
 
 
 
 
 
 
implementation.  Please  contact  me  at  623-236-7222  or  ACavalcant@azgfd.govif  you  have  any 
 
 
 
 
 
 
 
 
 
 
 
questions,  or  would  like  to  further  discuss  our  concerns  and  recommendations.  
 
Sincerely, 
 
Andrew  Cavalcant  
Project  Evaluation  Project  Specialist,  Habitat  Branch 
 
Cc 
Ginger  Ritter,  Project  Evaluation  Program  Supervisor  AGFD  (gritter@azgfd.gov) 
 
Kelly  Wolff,  Habitat  Program  Manager,  Region  VI  AGFD  (kwolf@azgfd.gov) 
 
AGFD  #M20-06011238

From:
David Jacobs
To:
Adam Cannon (PND)
Subject:
CPA2020001 Sun Streams Expansion Solar Project
Date:
Friday, June 5, 2020 11:38:01 AM
Adam-
The Arizona State Historic Preservation Office recently received notification of an application,
CPA2020001, of the Sun Streams Expansion Solar Project for review.  Our records indicate
the acreage involved in the expansion has not been inventoried for cultural resources, and we
recommend a qualified cultural resources specialist systematically survey the acreage in order
to locate and evaluate any cultural resources that may be present.  The applicant should be
reminded of the Arizona State Law A.R.S. § 41-865; it requires that if human remains or
burial goods are encountered during any ground-disturbing activities on private lands, work in
the immediate vicinity must cease and the Director of the Arizona State Museum promptly
notified.
Our office looks forward to receiving a survey report for review, and appreciate your
cooperation with this office in considering impacts to cultural resources situated in Arizona.  If
you have any questions, please contact me at 602-542-7140 or djacobs@azstateparks.gov.
David Jacobs, Arizona State Historic Preservation Office

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

Subdivision Infrastructure & 
Planning Program 
1001 N. Central Avenue #150 
Phoenix, Arizona 85004 
Phone: (602) 506-1058 
Fax: (602) 506-5813  
TDD 602 506 6704 
Maricopa County 
Environmental Services Department 
Water and Waste Management 
DATE: 
May 29, 2020   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TO : 
Adam Cannon, Planning & Development Dept. 
 
 
Planner 
 
 
 
FROM: 
Souren Naradikian, P.E. 
 
 
Senior Civil Engineer 
 
SUBJECT: 
Sun Streams Solar Major CPA. CPA2020001 
 
The Maricopa County Environmental Services Department (MCESD) has reviewed 
documents received from the Maricopa County Planning and Development 
Department for the above referenced project. This project is a Comprehensive Plan 
Amendment to the Old U.S. Highway 80 Area Plan to allow for a proposed Sun 
Streams Solar Major CPA Expansion. The development would not result in use of 
ground water or CAP water. There will be no staff on site and sewer service will not 
be needed. The parcel is not located in the urbanized unincorporated area and is 
therefore, not regulated by the Maricopa County Stormwater Quality Program. 
 
Based on the above, MCESD raised no concerns about this project to the Planning 
& Development Department in Accela Automation on May 29, 2020 and can allow the 
project to proceed at this time subject to the following stipulations: 
 
Stipulations:  
None.  
 
It should be noted that this document does not approve the referenced project.  
Comments are provided only as advisory to Maricopa County Planning and 
Development Department to assist staff to prepare a staff report.  Other Maricopa 
County agencies may have additional requirements. Final review and approval will be 
made through Planning and Development Department procedures. Applicant may 
need to submit separate applications to the Maricopa County Environmental Services 
Department for approval of proposed facilities regulated by the Department.  Review 
of any such application will be based on regulations in force at the time of application.

1
Adam Cannon (PND)
To:
Rachel Applegate (PND)
Subject:
RE: 7/7/20 TAC Agenda 
From: Angela Horn (DOT) <Angela.Horn@maricopa.Gov>  
Sent: Tuesday, June 30, 2020 12:54 PM 
To: Rachel Applegate (PND) <Rachel.Applegate@Maricopa.Gov> 
Cc: Bob Fedorka (PND) <Bob.Fedorka@Maricopa.Gov>; Lynndsay ONeill (DOT) <Lynndsay.ONeill@maricopa.Gov> 
Subject: RE: 7/7/20 TAC Agenda  
 
Hi Rachel,  
 
Please see comments below from Systems Planning.  
 
Item #1  
 
Dobbins Road is a Principal Arterial that requires 65 feet.  
 
There are several mid‐section and section line alignments that traverse this area. A site plan should be 
submitted to MCDOT for evaluation of future ROW requirements.   
 
 
Did I provide excellent service? Tell us how we are doing.  
 
Angela Horn 
Senior Planner 
Transportation Systems Management 
Office: 602.506.4176  
Maricopa County Department of Transportation 
2901 West Durango Street ▪ Phoenix, Arizona 85009 
angela.horn@maricopa.gov 
 
 
 
 
 
 
 
 
 
From: Rachel Applegate (PND)  
Sent: Tuesday, June 30, 2020 10:23 AM 
To: Angela Horn (DOT) <Angela.Horn@maricopa.Gov>; Bob Fedorka (PND) <Bob.Fedorka@Maricopa.Gov>; Charles Hart 
(PND) <Charles.Hart@Maricopa.Gov>; Cristina Arzaga (BOS) <Cristina.Arzaga@Maricopa.Gov>; Darren V. Gérard (PND) 
<Darren.Gerard@Maricopa.Gov>; David Galaviz ‐ RISCX <dgalaviz@risc.maricopa.gov>; Denise Lacey (DOT) 
<Denise.Lacey@Maricopa.Gov>; Erica Romero (RED) <Erica.Romero@Maricopa.Gov>; Jason Mahkovtz (DOT) 
<Jason.Mahkovtz@Maricopa.Gov>; Jen Pokorski (PND) <Jen.Pokorski@Maricopa.Gov>; Jessica May (DOT) 
<Jessica.May@Maricopa.Gov>; Joseph Mueller (PND) <Joseph.Mueller@Maricopa.Gov>; Kathy Semder (COA) 
<Kathy.Semder@Maricopa.Gov>; Kelly Roy (DOT) <Kelly.Roy@Maricopa.Gov>; Kimera Caswell (PND) 
<Kimera.Caswell@Maricopa.Gov>; Larry Morden (PND) <Larry.Morden@Maricopa.Gov>; Laura Etter (BOS) 
<Laura.Etter@Maricopa.Gov>; Lynndsay ONeill (DOT) <Lynndsay.ONeill@maricopa.Gov>; Matthew Holm (PND)

2
<Matthew.Holm@Maricopa.Gov>; Michael Norris (PND) <Michael.Norris@Maricopa.Gov>; Michele Kogl (DOT) 
<Michele.Kogl@Maricopa.Gov>; Michelle Montijo (BOS) <Michelle.Montijo@Maricopa.Gov>; Nicole Bendle (BOS) 
<Nicole.Bendle@Maricopa.Gov>; Page Gonzales (BOS) <Page.Gonzales@maricopa.gov>; Rick BOHAN ‐ SHARED 
MAILBOX <richardbohan@mail.maricopa.gov>; Scott Isham (BOS) <Scott.Isham@Maricopa.Gov>; Souren Naradikian 
(ENV) <Souren.Naradikian@Maricopa.Gov>; Stacey Lapp (PND) <Stacey.Lapp@Maricopa.Gov>; Tom Ewers (PND) 
<Tom.Ewers@Maricopa.Gov> 
Subject: 7/7/20 TAC Agenda  
 
Reviewing agencies,  
 
Attached with this e‐ mail includes the July 7th TAC agenda. Please coordinate review comments with the assigned 
planner.  
 
Thanks,  
Rachel Applegate 
Senior Planner  
Planning & Development 
602‐372‐0318 
Rachel.Applegate@maricopa.gov  
 
 
 
    
Rachel Applegate 
Senior Planner  
Maricopa County Planning & Development Department 
501 N. 44th Street, Suite 200, Phoenix, AZ 85008 
Desk: 602‐372‐0318 | Fax: 602‐506‐3711 
Rachel.Applegate@maricopa.gov

From:
Cindy Wiener
To:
Adam Cannon (PND)
Subject:
Re: CPA2020001 - 2nd Submittal - Sun Streams Expansion Solar Project
Date:
Wednesday, September 9, 2020 10:41:45 AM
Attachments:
image002.png
image003.png
Good Morning,
Thank you for your notice for the above-referenced development. ADOT
is neutral on this matter. As such, ADOT has no comment.
Kind Regards,
Cindy L. Wiener,
Right of Way Agent Consultant
On Thu, Sep 3, 2020 at 2:41 PM Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
wrote:
Good afternoon all:
This e-mail serves as notification of an application we have received from Sun Streams
Expansion, LLC for a Comprehensive Plan Amendment for the Sun Streams Expansion
Solar Project. Applicable documents for review are available on the Online Permit Manager
at: https://accela.maricopa.gov/CitizenAccessMCOSS/Default.aspx. You can search for the
case by using the CPA case number CPA2020001.
Best regards,
Adam Cannon
Planner
Maricopa County Planning & Development Department
501 N. 44th Street, Suite 200, Phoenix, AZ 85008
Desk: 602-372-0292
adam.cannon@maricopa.gov

Douglas A. Ducey 
Governor
Lisa A. Atkins 
Commissioner
Serving Arizona’s Schools and Public Institutions Since 1915 
www.azland.gov
Arizona State Land Department 
1616 West Adams, Phoenix, AZ 85007 
(602)542-4631
April 30, 2020 
Charlie Johnson
First Solar Development, LLC 
135 Main Street, 6th Floor 
San Francisco, CA 94105 
RE: State Trust land located in T1N, R5W Sections 32, 33, 34 and T1S, R5W Sections 4, 9
Maricopa County 
ASLD Commercial Lease Application KE# 03-120611-99-100 
Sun Streams Expansion, LLC, Maricopa County Comprehensive Plan Amendment and 
Rezoning 
Dear Mr. Johnson:
The Arizona State Land Department (the “Department” or “ASLD”) has received your request for 
permission to act as authorized agent for the Department to apply to Maricopa County (the 
“Jurisdiction”) for a Maricopa County Comprehensive Plan Amendment (CPA) and Rezoning (the 
“Entitlements”) on State Trust land described above, to change the use from Rural Zoning (RU-
43) to Industrial with an Industrial Unit Plan of Development (IND-2 IUPD for a Photovoltaic
Solar Project, as described in your email to ASLD dated April 2, 2020.
First Solar Development, LLC/Sun Streams Expansion, LLC its employees, representatives, 
agents, and/or consultants (hereinafter “Applicant”) therefore, has the Department’s 
consent to file for the Entitlements as required by the Jurisdiction, subject to the following 
conditions and understandings.
1.
Applicant shall pay all costs associated with the Entitlements and shall not be
reimbursed by the Department or by any subsequent purchaser at auction.
2.
Applicant, their employees, representatives, agents, and/or consultants shall be
permitted to act as the Department’s agents to procure the Entitlements and any related
permits or approvals which may be required (the “Entitlement Process”), subject to
final review and approval by the Department.
3.
Applicant shall diligently pursue the satisfaction of all Entitlements. Further, it shall
respond to all inquiries by the Department as to the status of the Entitlement Process
and provide regular updates without formal request.

First Solar Development, LLC/Sun Streams Expansion, LLC 
April 30, 2020 
Page 2 
 
4. 
Prior to beginning the Entitlement Process, the Applicant shall provide the Department 
with an outline of the proposal and a timeline for the process which identifies key dates 
with the Jurisdiction or other jurisdictional agency staff and project hearing dates with 
any agency or jurisdiction.  All documentation, including, but not limited to: land use 
plans, engineering drawings, application materials and development agreements, shall 
be submitted to the Department for approval prior to the date the documentation is filed 
with the approving jurisdiction.  A copy of the application shall be submitted to the 
Department on the same day it is filed with the Jurisdiction or other jurisdictional 
agency. 
 
5. 
The Department staff shall be invited, but not required to attend, all meetings with the 
various agencies, elected officials, and the Jurisdiction as the Entitlements are 
processed through relevant hearings.  A minimum of five (5) business days’ notice shall 
be provided to Department staff in advance of any meeting.  
 
6. 
Applicant shall submit to the Department all staff reports and draft stipulations that will 
be considered by the Jurisdiction on the day they are received by the Applicant, and at 
least ten (10) business days before each public meeting or hearing, if possible.  
 
7. 
As additional consideration for the grant of this permission, all Entitlements and/or 
rights and permits obtained pursuant to the described applications are the property of 
the Department and will only be transferred to the successful bidder, if any, at the time 
the land is auctioned for sale or lease at some point in the future.   
 
8. 
The Jurisdiction is authorized to enter and inspect the subject property. 
 
9. 
This authorization may be revoked at any time without notice and in no way creates an 
obligation on the part of the Department of any kind. 
 
All information will be provided to Raymond Moore, Sales and Commercial Leasing with a copy 
to Karen Dada, Planning and Engineering Section. 
 
The Department appreciates your consideration in this matter and looks forward to working with 
you through this process.  Please contact Raymond Moore at 602-364-1126 or rmoore@azland.gov 
if you have any questions. 
 
Sincerely, 
 
 
Mark Edelman, AICP 
Director, Planning and Engineering 
 
cc: 
Raymond Moore, ASLD Sales & Commercial Leasing 
 
Karen Dada, ASLD Planning & Engineering

July 2, 2020 
 
 
 
 
 
 
 
 
SENT VIA EMAIL 
 
 
Adam Cannon, Planner 
Maricopa County Planning and Development Department  
501 N. 44th Street, Suite 200 
Phoenix, AZ  85008 
 
Subject: 
 
CPA2019014: Major Comprehensive Plan Amendment - Vulcan Solar Project 
CPA2020001: Major Comprehensive Plan Amendment - Sun Streams Expansion Project 
CPA2020002: Major Comprehensive Plan Amendment - Maricopa Solar & Storage Project 
 
Dear Adam: 
 
Thank you for the opportunity to review and comment on Maricopa County Major Comprehensive 
Plan Amendments CPA2019014, CPA2020001 and CPA2020002 for a number of solar energy 
projects in the county.  
 
The three projects are located approx. 40-50 miles west of downtown Phoenix, AZ. The region is 
characterized by undeveloped desert areas, agriculture and sparse rural residential development. 
The region has a number of power generating stations (Palo Verde Generating Station, 
Harquahala Power Plant, Mesquite Generating Station, Redhawk Power Plant) and the proposed 
projects may be able to take advantage of existing power transmission infrastructure. 
 
The addition of solar energy generation and storage projects should have minimal impact on 
surrounding properties and generation of renewable energy would be a benefit to the region. Pima 
County Development Services Department, Planning Division has no opposition to the proposed 
major comprehensive plan amendments. 
 
 
Sincerely, 
 
Mark Holden, AICP 
Principal Planner 
Pima County Development Services Department, Planning Division

From:
Edward Boik
To:
Adam Cannon (PND)
Cc:
Terri Hogan
Subject:
Major Comp Plan Amendments
Date:
Wednesday, July 1, 2020 1:24:09 PM
The City of Buckeye has no comment regarding case #’s: CPA2020001, CPA2020002, CPA2019014. 
Please include the City on any future notices related to rezoning or entitling the project sites.
 
Ed Boik, AICP, Principal Planner
City of Buckeye, AZ
P: 623.349.6207
C: 623.693.0723
E: eboik@buckeyeaz,gov
 
This message contains confidential information and is intended only for the individual(s)
addressed in the message. If you are not the named addressee, you should not disseminate,
distribute, or copy this e-mail. If you are not the intended recipient, you are notified that
disclosing, distributing, or copying this e-mail is strictly prohibited.

From:
Robert Busick
To:
Adam Cannon (PND)
Subject:
CPA2020001 - 2nd Submittal - Sun Streams Expansion Solar Project
Date:
Thursday, September 3, 2020 4:00:44 PM
Attachments:
image001.png
Good afternoon, Adam:
 
Regarding case CPA2020001, after reviewing the associated documents, the City of Buckeye has no
comment.
 
Thank you,
 
Robert Busick  | Planner I
City of Buckeye | Development Services
530 E Monroe Ave| Buckeye, Arizona 85326
P 623-349-6242 | rbusick@buckeyeaz.gov
 
  
 
Monday-Thursday 7am-6pm CLOSED FRIDAYS
2020 Census – Everyone Counts in Buckeye! – ¡Todos Cuentan en Buckeye! – www.icount2020.info
 
This message contains confidential information and is intended only for the individual(s)
addressed in the message. If you are not the named addressee, you should not disseminate,
distribute, or copy this e-mail. If you are not the intended recipient, you are notified that
disclosing, distributing, or copying this e-mail is strictly prohibited.

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

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

Issue #: 185988  
Citizen
Information:
Last Name: MASCH  
First Name: DAVE  
Phone Number: N/A  
Email Address: davemasch@outlook.com  
Permit #: CPA2020001  
  
details 
 
Organization: Planning and Development    history  
 
 
Submitted By
: Baldonado, Rosemary on 24-Aug-2020 8:35PM     602-506-5128    history  
 
Division ID: PNDDevServ - Development Services  
Subject: Case # CPA2020001 Zoning Case# TBD   
  
Description: To Whom it may concern, 
 
I am once again writing you to find out the Status of Case # 2020001 
We the residents of Tonopah are very interested in the intent of this 
project, I can assure you that we do not want another Hickman’s fiasco 
here is our community, and that we are all opposed to rezoning residential 
lots to commercial for the implantation of ugly useless solar fields. 
 
Please respond with: 
Why did you purposefully excluded the hearing date that goes against 
governmental policy? 
We Demand to be provided the hearing date and a comprehensive reason 
why the hearing date was excluded... (it better be better than "Covid").  
Why are you holding this hearing downtown (62 miles away) instead of at a 
location closer to the site so that residents could be in attendance? Like 
maybe the Saddle Mountain School Board Room. 
We Demand a new notice be placed immediately that includes the hearing 
date so residents can make arrangements to attend! 
I would also recommend you do radio & television ads advising residents of 
the hearing date since you were so underhanded in the notification.  
 
As a concerned citizen I request that you complete an internal audit of your 
Planning & Development staff to ensure that discipline comes to those 
individuals responsible for ensuring that local residents would be unaware.  
This land absolutely needs to remain RU-43!!! 
  
Contact 
Type: Email  
Division
Type: Development Services

SubType 1: Planning   
 
SubType 2:  
 
SubType 3:  
 
SubType 4:  
 
Assigned To: CustomerService, PND  on 24-Aug-2020 8:35PM       details  
 
Adj Time 
Open: 01:09  
  
Total Time 
Open: 01:09  
Issue Status:
Open
    history  
 
Priority: Medium  
Responsibility
Next Action: Planning  on 24-Aug-2020 8:35PM      details  
 
Supporting Info
Notes  
  
  
Cannon,
Adam:
25-Aug-2020
7:09AM 
Emailed copy of Issue to davemasch@outlook.com,  
Good morning Mr. Masch, 
I hope you are well.  Thank you for your inquiry. 
I believe that you have some misconceptions about the process so I wanted to 
reach out to you to clarify it for you. 
1) We received an application for this Comprehensive Plan Amendment as part of 
an annual process.  Applicants do not immediately get scheduled for hearing 
when they submit an application.  The application goes through a review period 
and before it is given hearing dates, the application must address technical 
concerns of Maricopa County agencies.  All cases that go before the Planning and 
Zoning Commission and Board of Supervisors go through this same process and 
again hearing dates are not set until the applicant is able to address agency 
concerns.

2) Once hearing dates are established, you will be notified directly as you have 
reached out to us.  In addition, once the applicant has received sign-off, they will 
update the signs with hearing dates.  This is part of the standard process. 
3) Due to COVID concerns, the hearing may be conducted virtually; however, if 
restrictions are lifted then it is expected that the hearing will take place in the 
Board of Supervisors auditorium in downtown Phoenix.  This location is where all 
hearings (COVID excepting) take place.  Maricopa County is very large and there 
are other matters besides this case that the governing boards consider across the 
entirety of the County.   
4) You may also view the case at the online portal: 
https://accela.maricopa.gov/CitizenAccessMCOSS/Default.aspx.  Search for 
the case using the Comprehensive Plan Amendment case number 
CPA2020001. 
5) I will contact the applicant to have them reach out to you about the 
content of the case.   
Thank you.  Please contact me if you have any further questions about the 
process.  All questions regarding case content should be directed to the 
applicant. 
Best regards, 
Adam Cannon

Issue #: 184131  
Citizen
Information:
Last Name: Woloshin  
First Name: Steve  
Phone Number: 602-980-7603  
Email Address: stevew@ping.com  
Permit #: CPA2020001  
  
details 
 
Organization: Planning and Development    history  
 
 
Submitted By
: Crawford, Roxanne on 20-Jul-2020 8:35AM        history  
 
Division ID: PNDDevServ - Development Services  
Subject: Project Inquiry SUN STREAMS EXPANSION SOLAR PROJECT   
  
Description: caller is wanting to know what the Zoning requirements are for the project. 
He is a home owner near the project and is curious about this  
  
Contact 
Type: Phone  
Division
Type: Development Services   
 
SubType 1: Planning   
 
SubType 2:  
 
SubType 3:  
 
SubType 4:  
 
Assigned To: CustomerService, PND  on 20-Jul-2020 8:35AM       details  
 
Adj Time 
Open: 00:52  
  
Total Time 
Open: 00:52  
Issue Status:
Open
    history

Priority: Medium  
Responsibility
Next Action: Planning  on 20-Jul-2020 8:57AM      details  
 Zoning Plan Review  on 20-Jul-2020 8:35AM      details  
 
Supporting Info
Notes  
  
  
Cannon, Adam:
20-Jul-2020
9:27AM 
Emailed copy of Issue to stevew@ping.com 
Good morning Steve, 
Thank you for your inquiry.  This project is not a zoning request at this 
stage.  The first step is for an applicant to seek and obtain a Comprehensive 
Plan Amendment (CPA) approval to change the land use from Rural to 
Utilities.  In the event CPA approval is received, the applicant will move forward 
with requesting a zone change.  This zone change request is tailored to a 
specific plan of development and zoning requirements may be varied. 
 Applicable documents for case review are available on the Online Permit Manager at: 
https://accela.maricopa.gov/CitizenAccessMCOSS/Default.aspx.  You can search for the case by 
using the Comprehensive Plan Amendment case number CPA2020001.  
I will have the applicant reach out to you in order to answer questions you may have about the 
project. 
 Best regards, 
 Maricopa County Planning and Development

Issue #: 184189  
Citizen
Information:
Last Name: GARCIA  
First Name: JOSEPH  
Phone Number: 623 680-8984  
Email Address: joseph.agarnica45@gmail.com  
Permit #: CPA2020001  
  
details 
 
Organization: Planning and Development    history  
 
 
Submitted By
: Baldonado, Rosemary on 20-Jul-2020 5:52PM     602-506-5128    history  
 
Division ID: PNDDevServ - Development Services  
Subject: Fwd: information   
  
Description: ---------- Forwarded message --------- 
From: Joseph Garnica <joseph.agarnica45@gmail.com> 
Date: Mon, Jul 20, 2020 at 2:22 PM 
Subject: information 
To: <pdplanner@mail.maricopa> 
 
Hi, 
 
I am reaching out to see if you can give me some information on what this 
development is going to be. I attached a photo with information on it. The 
property is located on Salome Hwy & 339th Ave. We have property just 
adjacent to this location on the north.  
 
There are several more signs down the street on Salome Hwy and on 339th 
Ave. 
 
 
Thank you, 
 
Joseph Garnica 
623-680-8984 
  
Contact 
Type: Email  
Division
Type: Development Services   
 
SubType 1: Planning   
 
SubType 2:

SubType 3:  
 
SubType 4:  
 
Assigned To: CustomerService, PND  on 20-Jul-2020 5:52PM       details  
 
Adj Time 
Open: 01:03  
  
Attachments: ISSUETRAK___184189.PNG   20-Jul-2020 5:52PM 
  
Total Time 
Open: 01:03  
Issue Status:
Open
    history  
 
Priority: Medium  
Responsibility
Next Action: Planning  on 20-Jul-2020 5:52PM      details  
 
Supporting Info
Notes  
  
  
Cannon, Adam:
21-Jul-2020
7:03AM 
Emailed copy of Issue to joseph.agarnica45@gmail.com 
Good morning Joseph, 
Thank you for your inquiry.  
Applicable documents for case review are available on the Online Permit Manager at: 
https://accela.maricopa.gov/CitizenAccessMCOSS/Default.aspx.  You can search for the case by 
using the Comprehensive Plan Amendment case number CPA2020001.  
I will have the applicant reach out to you in order to answer questions you may have about the 
project. 
 Best regards, 
 Maricopa County Planning and Development

From:
Adam Cannon (PND)
To:
Mariela Resendez
Cc:
Adam Cannon (PND)
Subject:
RE: CPA2020001 -- Public Hearing Question
Date:
Thursday, October 22, 2020 7:18:00 AM
Attachments:
image001.png
image002.png
image003.png
Good morning Mariela,
 
If the questions are process related with the case or related to participation at the hearing, you can
contact me at my information below or send questions by e-mail.  If the questions are about the
content of the project, please direct those to sunstreamsexpansion@firstsolar.com or 833-367-
7890. 
 
Best regards,
 
  
Adam Cannon
Planner
Maricopa County Planning & Development Department
501 N. 44th Street, Suite 200, Phoenix, AZ 85008
Desk: 602-506-3301
adam.cannon@maricopa.gov
 
 
From: Mariela Resendez <mariela.resendez@gmail.com> 
Sent: Wednesday, October 21, 2020 7:22 PM
To: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Subject: CPA2020001 -- Public Hearing Question
 
Hello Adam, 
 
I was wondering if you could tell me where I could submit questions in regards to the Sun
Streams Expansion Solar Project. 
 
We only have a couple of questions that we wish to be addressed. 
 
Thank you, 
 
Mariela Resendez 
623-455-0832