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December 9, 2020 CPA2020002 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: CPA2020002 – Maricopa Solar & Storage Project Supervisor District: 5 Applicant: Wood Environment & Infrastructure Solution Inc. Owners: Multiple – See Parcel Exhibit in Planning & Zoning Packet Request: Major Comprehensive Plan Amendment (CPA) to change the land use designation in the Vision 2030 Maricopa County Comprehensive Plan from Rural Development Area to Utilities. CPA approval is by Resolution. Site Location: Generally located between I-10 to the north, Broadway Rd. to the south, 523rd Ave. alignment to the west, 491st Ave. alignment to the east Site Size: Approx. 11,260 acres County Island Status: No Additional Comments: The applicant seeks a Major Comprehensive Plan Amendment to change the land use designation in the Comprehensive Plan to utilities in order to develop a solar installation. The subject site is identified as having Rural Development Area land use designation in the Vision 2030 Maricopa County Comprehensive Plan. All approx. 11,260 acres are designated as Rural Development Area (0-1 d.u./acre). This designation encourages low-density rural residential and agricultural uses. Staff received three (3) letters from adjacent/internal jurisdictions (City of Buckeye, Town of Queen Creek, Pima County) expressing no concerns. AZ Dept. of Game & Fish and AZSHPO commented on the site regarding wildlife and hydrology. These comments will be considered during a future zone change request. Staff received no opposition to this case. December 9, 2020 CPA2020002 Page 2 of 2 Commission Recommendation: On 11/5/20, the Commission voted 6-0 to recommend approval of CPA2020002 subject to conditions ‘a’ – ‘d’: a. Development and use of the site shall be general conformance with the narrative report entitled “Maricopa Solar and Storage Project” dated September 29, 2020 and stamped received September 30, 2020, except as modified by the following conditions. b. Development and use of the site shall be in general conformance with the land use exhibit entitled “Land Use Exhibit” dated September 24, 2020 and stamped received September 30, 2020, except as modified by the following conditions. c. The land use designation of utilities approved as part of case CPA2020002 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 Development Area to Utilities. The proposal by the applicant represents a comprehensive approach to the subject property and will allow the applicant to pursue the proper entitlements pursuant to state law so that they can lawfully operate in unincorporated Maricopa County. This particular proposal is an appropriate plan for the property and is consistent with the overall intention of the comprehensive plan. However, in the event that the zone change or a zone change phase for this particular proposal is not approved by Maricopa County Board of Supervisors (BOS) within five (5) years from the date of Board approval of this comprehensive plan amendment, this amendment shall no longer be effective as the planning justification for this comprehensive plan amendment will no longer be present. In such instance, a change of the land use designation from Utilities to Rural Development Area will occur, and all comprehensive plan land use maps shall be altered to reflect as such, because this represents superior long-range planning by Maricopa County. Presented by: Adam Cannon, Planner Reviewed by: Darren Gerard, AICP, Planning Manager Attachments: 11/5/20 P&Z Packet (63 pages) CPA2020002 Resolution (2 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. CPA2020002 Page 1 of 11 Report to the Planning and Zoning Commission Prepared by the Maricopa County Planning and Development Department Case: CPA2020002 – Maricopa Solar and Storage Project Hearing Date: November 5, 2020 Supervisor District: 5 Applicant: Wood Environment & Infrastructure Solution Inc. Owners: Multiple – See Parcel Exhibit in Attachments Request: Major Comprehensive Plan Amendment (CPA) to change the land use designation in the Vision 2030 Maricopa County Comprehensive Plan from Rural Development Area to Utilities Site Location: Generally located between I-10 to the north, Broadway Rd. to the south, 523rd Ave. alignment to the west, 491st Ave. alignment to the east Site Size: Approx. 11,260 acres Density: N/A County Island: No County Plans: Vision 2030 Maricopa County Comprehensive Plan – Rural Development Area (0-1 d.u./ac.) Municipal Plan: N/A Municipal Comments: Three (3) Letters – Pima County (1), City of Buckeye (1), and Town of Queen Creek (1) – No Concerns Support/Opposition: None received Recommendation: Approve with conditions CPA2020002 Page 2 of 11 Project Summary: 1. Wood Environment & Infrastructure Solutions, Inc. is requesting a Major Comprehensive Plan Amendment (CPA) to change the land use designation in the Vision 2030 Maricopa County Comprehensive Plan from Rural Development Area to Utilities to allow development of a utility-scale solar electric generating project in phases generating approximately 550 megawatts (MWs) of electricity along with battery storage. Due to the size of the project at 11,260 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). 2. The site is comprised of eighty-seven (87) private contiguous parcels. Most properties in the immediate vicinity of the project are privately owned. The applicant’s narrative states that site control options are secured for all of the parcels. 3. Nearly all land used for solar energy projects 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. The current use of the site is for row crop cultivation. Historically, the site was native desert land. A portion of the Centennial Wash is located south of the site and the applicant has stated that no impacts on Centennial Wash or an ancient trail will occur. In addition, the general area contains significant local electrical infrastructure including a power generation facility, substation and a future interconnect line along I-10. 4. Adjacent land uses include vacant, agricultural, industrial (utility plants) and very limited rural residential uses. Previous CPAs for the Almeria Solar Project and Harquahala Solar Project were approved in 2011 under an older land use designation; however, the projects were abandoned. 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 the nearby RE Papago site. The APS Delaney Substation and Harquahala Power Plant are located east of the subject site. The interconnect line associated with the project will connect to the APS Delaney Substation. 5. The narrative asserts that the proposed development meets the Comprehensive Plan Amendment criteria in the following manner: Whether the amendment constitutes an overall improvement to the Comprehensive Plan and is not solely for the good or benefit of a particular landowner or owners at a particular point in time. The narrative states that the Maricopa Solar & Storage Project is in direct alignment with the County’s mission and guiding principles for leadership and strategic priorities. According to the narrative, the project would benefit the state, county, local and regional economy by providing employment for approximately 450-550 construction employees per 18-24 month construction phase for up to 5 construction phases. The project will generate revenue opportunities for local businesses and the energy generated by the site will supply the county, state and wider west/southwest regions with electricity. The applicant will make efforts to hire individuals from the local area and region. Additionally, there will be little transportation infrastructure or water resources CPA2020002 Page 3 of 11 required to serve the site. Therefore, the amendment constitutes an overall improvement to the Vision 2030 Maricopa County Comprehensive Plan and is not solely for the good or benefit of a particular landowner/owners at a particular point in time. Whether the amendment will adversely impact all or a portion of the planning area. A. Altering acceptable land use patterns to the detriment of the plan – According to the narrative, the amendment will not alter any surrounding land uses or land use patterns. The land is currently used as agricultural land. While this land will be unavailable during the life of the project, the land can return to its agricultural function when the project ceases. Moreover, this site is situated 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 costs of the project’s infrastructure needs shall be borne by the applicant. C. Requiring public improvements to roads, sewer, or water systems that are needed to support the planned land uses – The narrative states that the project would require improvements to roads (underground cabling and access), septic and a potable water system associated with the O&M building to support the planned land use. Existing roads will serve the project and any additional project infrastructure needs shall be borne by the applicant. D. Adversely impacting planned uses because of increased traffic – The narrative indicates there would be increased traffic during the construction period (approximately 18-24 months per phase) for the delivery of equipment / supplies and the commuting of the construction work force, but there would be no significant increase in traffic during the operational life of the project following the construction phase. With a small number of staff operating the O&M building during the project’s operating life, 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. Wildlife prevention and mitigation measures will be incorporated into the Specific Plan of Development. Fire hazard risks will be controlled through weed control. Therefore, the project will not affect the livability of the area or health or safety of present and future residents. F. Adversely impacting the natural environment or scenic quality of the area in contradiction to the plan – The applicant states that the project will not significantly impact the natural environment or overall scenic quality of the area. There are CPA2020002 Page 4 of 11 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 such as the Sonoran Desert Tortoise and Gila Monster. 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 part of their submission, a Class 1 Cultural Resources Inventory was completed and submitted to SHPO. The applicant also submitted a Letter of Commitment from Ellwood Land Holdings LLC to the Arizona State Historic Preservation Office (SHPO). SHPO accepted this letter as addressing prior concerns associated with the site. The contents of the letter state that the applicant will work with SHPO on developing a Class II Cultural Resources survey. Satisfaction of SHPO comments are only required at the time of construction permitting. Development will avoid any known archeological sites. Scenic Views The narrative indicates that the solar fields will have a low-profile and will not be located near densely populated areas. The applicant submitted a glint/glare assessment that shows that there will be little reflection from the solar array along existing roads, at two airfields and at residences. Hydrology/Ground Disturbance According to the narrative, hydrologic conditions will be preserved by avoiding the Centennial Wash and in accordance with agency requirements. AZGFD issued comments concerned about surface flows. The applicant will address retention in accordance with Maricopa County agency requirements at the zone change stage of the project. 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 as the plan explicitly identifies encouraging solar energy CPA2020002 Page 5 of 11 development as an important goal and strategy to attract solar and other alternative energy research and development to Maricopa County. In addition to the state, county, local and regional benefits, the narrative asserts that the project displays consistency with the County’s vision to work collaboratively and effectively for residents and the County’s mission to provide regional leadership by encouraging solar energy development. Additionally, the applicant believes that the project aligns with the County’s priorities to leverage resources, plan for effective/efficient infrastructure and manage County resources. The extent to which the amendment is consistent with the specific goals and policies contained within the plan. The applicant’s narrative contains a substantial list of Goals and Policies from the Vision 2030 Maricopa County Comprehensive Plan. This staff report identifies which Goals and Policies the applicant’s narrative addressed. Vision 2030 Maricopa County Comprehensive Plan Land Use Element – Goal 1, Goal 3, Policy 1, Policy 2, Policy 7, Policy 11, Policy 12, Policy 13, Policy 20, Policy 22, Policy 23, Policy 27, Policy 31, Policy 33 Transportation Element – Goal 2, Policy 1, Policy 2, Policy 9, Policy 11, Policy 12, Policy 14 Environment Element – Goal 1, Policy 3, Policy 4, Policy 5, Policy 7 Economic Growth Element – Goal 1, Goal 2, Policy 3, Policy 5, Policy 6, Policy 10 Growth Area Element – Goal 1 Open Space Element – Goal 1, Policy 2 Water Resources Element – Goal 2, Policy 2, Policy 4, Policy 5, Policy 7 Energy Element – Goal 1, Goal 2, Policy 1, Policy 4, Policy 6, Policy 7 Cost of Development Element – Goal 2, Policy 1, Policy 2 Other pertinent information as requested by the Maricopa County Planning Department Staff. The applicant was responsive and provided quality information as requested by Maricopa County Planning Department Staff. CPA2020002 Page 6 of 11 2018 Aerial Map Zoning Map 1 – Rural-43 & Surrounding Districts CPA2020002 Page 7 of 11 Zoning Map 2 – Rural-43, C-2 & Surrounding Districts Land Use Exhibit Excerpt – Current & Proposed Land Use – Rural Development Area to Utilities CPA2020002 Page 8 of 11 Existing On-Site and Adjacent Zoning / Land Use: 6. On-site: Rural-43 & C-2 / Vacant/Agricultural North: Rural-43 / Vacant/Agricultural South: Rural-43 / Vacant/Agricultural East: Rural-43, R-5 & C-2 / Vacant/Agricultural & Industrial (Power Plant) West: Rural-43, C-2 & IND-2 / Vacant/Agricultural & 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/Buckeye 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 Future R/W* Future Classification* Salome Hwy 111’-130’ (full, varies) TBD Minor Collector Harquahala Valley Rd. 40’ – 65’ (half) 65’ Minor Arterial 491st Ave. None Existing 130’ (full) Minor Collector Courthouse/Centennial Rd. 55’ (half) 65’ Minor Arterial Van Buren St. 0’ – 100’ (half) 65’ Minor Arterial Buckeye Rd. None Existing 130’ (full) Minor Collector Lower Buckeye Rd. 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 Plan: 9. Vision 2030 Maricopa County Comprehensive Plan: The entire site (approx. 11,260 acres) is designated as Rural Development Area (0-1 d.u./ac.). The Rural Development Area land use designation encourages low-density rural residential and agricultural uses. Public Participation Summary: 10. The applicant posted the subject site and staff notified all property owners within 300’ of the site. Pursuant to state law, Staff issued enhanced notification letters to all adjacent and internal jurisdictions to Maricopa County, select state and regional agencies and Luke Air Force Base. Staff received three (3) letters from adjacent/internal jurisdictions (City of Buckeye, Town of Queen Creek, Pima County) expressing no concerns. Moreover, state agencies such as Arizona Game & Fish Department and SHPO issued CPA2020002 Page 9 of 11 comments. Those comments have been included in the attachments section and are not actionable until a future Plan of Development stage. 11. According to the Public Participation Results Report submitted by the applicant, the applicant conducted a virtual open house meeting on September 10, 2020 and was advertised for three weeks in advance of the meeting in the Arizona Business Gazette. There were 11 citizen attendees not including staff of the applicant. The applicant received general questions related to leasing/selling property, project screening, jobs/employment, vegetation, infrastructure, project decommissioning, land ownership, property values and technical details about the interconnect line. 12. Additionally, the Public Participation Results Report included a record of all phone calls and their communications and facilitated virtual meeting accessibility for an out-of-state adjacent owner. The majority of these communications were focused on property purchase/lease. There were a couple of concerns about property values and screening. The remainder of these communications were information requests. 13. County Staff received no opposition letters. County Staff did receive a phone call and e-mail from an individual interested in selling/leasing their property to the applicant, but personally disliked the specific representative who approached them about the issue. This individual was given the applicant’s contact information and County Staff forwarded the e-mail to the applicant. According to the summary of communication provided in the Public Participation Results Report, the applicant contacted this individual and gave them information about the project. Please see attachment entitled Adjacent Owner Correspondence. A second e-mail was received from a Jeff Brady with questions about ecological restoration near the finalization of this staff report. County staff contacted Mr. Brady about his question and sent him information to participate in the hearing. Mr. Brady noted in the phone conversation that he is not opposed to the project. Outstanding Concerns from Reviewing Agencies: 14. N/A Staff Analysis: 15. The state and Maricopa County recognize the potential environmental and economic benefits that solar technology can provide. The Maricopa Solar and Storage Project will use photovoltaic technology that generates energy from sun absorption. Photovoltaic technology differs from other techniques that required vast amounts of water to cool the units. In contrast, very little water is utilized for photovoltaic technology. As a result, this development would not pose a threat to groundwater depletion. 16. Staff believes the proposed solar facility is well suited to this rural area. Solar facilities require large amounts of relatively flat land and the vast majority of the subject site is flat. Staff agrees with the applicant that the subject site is suitable due to proximity to electrical transmission lines, nearby stations and substations, and because the surrounding area is undeveloped. Staff agrees with the applicant that the project will not detrimentally affect the visual quality of the area. The applicant engaged in a robust and lengthy public participation process. Additionally, the applicant has corresponded with AZGFD on wildlife preservation. The applicant also submitted a Letter of CPA2020002 Page 10 of 11 Commitment from Ellwood Land Holdings LLC to the Arizona State Historic Preservation Office (SHPO) to conduct a Class II Cultural Resources Survey. SHPO accepted this letter. Since the area is primarily undeveloped vacant land in near proximity to other existing utility-scale solar projects, staff believes there will be minimal impacts to the surrounding area. 17. Promoting the development of solar energy over the past several years in Maricopa County reinforces the County’s interest in promoting the County as an economic leader for solar development. Staff believes the Maricopa Solar and Storage Project would add to this effort in a positive way by providing the potential for 450-550 temporary construction jobs for up to 5 construction phases lasting approximately 18-24 months each. There will also be small number of long-term employment opportunities for County residents. 18. Staff believes the Maricopa Solar and Storage 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: 19. For the reasons outlined in this report, staff recommends the Commission motion for Approval, subject to conditions ‘a’ – ‘d’. a. Development and use of the site shall be general conformance with the narrative report entitled “Maricopa Solar and Storage Project” dated September 29, 2020 and stamped received September 30, 2020, except as modified by the following conditions. b. Development and use of the site shall be in general conformance with the land use exhibit entitled “Land Use Exhibit” dated September 24, 2020 and stamped received September 30, 2020, except as modified by the following conditions. c. The land use designation of utilities approved as part of case CPA2020002 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 Development Area to Utilities. The proposal by the applicant represents a comprehensive approach to the subject property and will allow the applicant to pursue the proper entitlements pursuant to state law so that they can lawfully operate in unincorporated Maricopa County. This particular proposal is an appropriate plan for the property and is consistent with the overall intention of the comprehensive plan. However, in the event that the zone change or a zone change phase for this particular proposal is not approved by Maricopa County Board of Supervisors (BOS) within five (5) years from the date of Board approval of this comprehensive plan amendment, this amendment shall no longer be effective as the planning justification for this comprehensive plan amendment will no longer be present. In such instance, a change of the land use designation from Utilities to Rural CPA2020002 Page 11 of 11 Development Area will occur, and all comprehensive plan land use maps shall be altered to reflect as such, because this represents superior long-range planning by Maricopa County. Presented by: Adam Cannon, Planner Reviewed by: Matthew Holm, AICP, Planning Supervisor Attachments: Case Map (1 page) Land Use Exhibit (reduced 8.5”x11”, 1 pages) Narrative Report (21 pages) Parcel Exhibit (1 page) AZGFD Comments (5 pages) SHPO Comments (2 pages) Applicant Commitment Letter (1 page) MCESD comments (1 page) MCDOT Comments (2 pages) ADOT ROW Project Management Comments (1 page) Town of Queen Creek Comments (1 page) Pima County Comments (1 page) City of Buckeye Comments (1 page) Adjacent Owner Correspondence (13 pages) MARICOPA COUNTY / Maricopa County Planning & Development - Phoenix, AZ 5 Gross Acres: 11260 approx. Generated October 23, 2020 08:11 AM CPA2020002 Application Name: Legal Description Maricopa Solar & Storage Major CPA Applicant Case Address , T1N R08W 06, T1N R08W 07, T1N R08W 18, T1N R08W 19, T1N R09W 01, T1N R09W 11, T1N R09W 12, T1N R09W 13, T1N RICHARD KNOX for WOOD ENVIRONMENT & INFRASTRUCTURE SOLUTIONS, INC Applicant Phone/Email Parcel Primary: 602.733.6113 RICHARD.KNOX@WOODPLC.COM Map scale 1:117,657 Supervisor District No. COMPREHENSIVE PLAN AMENDMENT LEADING TO A ZONING CHANGE FROM RU-43 TO IND-2/LAND USE CHANGE FROM RURAL DEVELOPMENT AREA TO UTILITIES !R Harquahala Valley Rd 499th Ave Centennial Rd Lower Buckeye Rd Van Buren St Harquahala Power Plant Buckeye Rd Thomas Rd Indian School Rd Camelback Rd Salome Rd 507th Ave 491st Ave 483rd Ave Southern Ave Broadway Rd Bethany Home Rd T1N R8W T1N R9W T2N R8W T2N R9W T3N R8W T3N R9W §¨¦ 10 02 36 13 12 05 09 25 32 20 05 31 36 09 33 33 35 17 30 16 08 01 09 30 07 32 05 31 11 32 17 08 21 05 33 29 23 06 16 11 33 20 17 19 27 35 24 29 21 24 32 22 22 28 21 28 34 04 26 21 20 28 29 15 36 29 35 34 02 18 16 01 32 25 12 14 34 31 04 09 13 32 04 06 18 14 15 20 08 27 10 03 07 08 10 23 16 28 03 17 19 26 33 33 04 Path: X:\Projects\2019 Projects\1420192020 Maricopa Solar Plus Storage Project\MXD\CPA_Filing\Final\LAND EXHI\Figure1_LandUseExhibit_11x17.mxd ?¸ 85 Site Location Tonopah Palo Verde NGS Buckeye Glendale Peoria Phoenix £ ¤ 60 §¨¦ 17 §¨¦ 10 Site Vicinity 0 1.25 2.5 Miles ± Land Use Exhibit CPA2020002 Maricopa Solar and Storage Project Maricopa County, Arizona The map shown here has been created with all due and reasonable care and is strictly for use with Wood Project Number 14-2019-2020. This map has not been certified by a licensed land surveyor, and any third party use of this map comes without warranties of any kind. Wood assumes no liability, direct or indirect, whatsoever for any such third party or unintended use. 14-2019-2020 RK 9/24/2020 1 inch= 1.25 miles Job No. PM: Date: Scale: Figure 1 Legend !R Harquahala Power Plant Proposed Project Boundary Existing Land Use Rural Development Area Proposed Land Use Utilities Township/Range Line Section Line Land Ownership Private Land Bureau of Land Management Land Arizona State Trust Land County Land Harquahala Valley Irrigation District Land Existing Land Use !R Harquahala Valley Rd 499th Ave Centennial Rd Lower Buckeye Rd Van Buren St Harquahala Power Plant Buckeye Rd Thomas Rd Indian School Rd Camelback Rd Salome Rd 507th Ave 491st Ave 483rd Ave Southern Ave Broadway Rd Bethany Home Rd T1N R8W T1N R9W T2N R8W T2N R9W T3N R8W T3N R9W §¨¦ 10 02 36 13 12 05 09 25 32 20 05 31 36 09 33 33 35 17 30 16 08 01 09 30 07 32 05 31 11 32 17 08 21 05 33 29 23 06 16 11 33 20 17 19 27 35 24 29 21 24 32 22 22 28 21 28 34 04 26 21 20 28 29 15 36 29 35 34 02 18 16 01 32 25 12 14 34 31 04 09 13 32 04 06 18 14 15 20 08 27 10 03 07 08 10 23 16 28 03 17 19 26 33 33 04 Proposed Land Use CPA2020002 Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project Harquahala Valley, Maricopa County, Arizona Project Name: Maricopa Solar and Storage Project Wood Project No. 1420192020 Wood Project Contact: Richard Knox (602) 733-6113 richard.knox@woodplc.com Prepared for: Ellwood Land Holdings, LLC 150 North Dairy Ashford Rd. Houston, Texas 77079 Prepared by: Wood Environment & Infrastructure Solutions, Inc. 4600 East Washington Street, Suite 600 Phoenix, Arizona 85034-1917 (602) 733-6000 September 29, 2020 CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 1 Table of Contents 1 PART A – EXECUTIVE SUMMARY ........................................................................................................................... 2 1.1 On-site and Regional Location ........................................................................................................................................ 2 1.2 CPA Size and Description of Land Use Types by Acreage ..................................................................................... 3 1.3 Roads/Transportation Systems Serving the Project ................................................................................................. 3 1.4 Suitability with Surrounding Land Uses ........................................................................................................................ 3 2 PART B - WHETHER THE AMENDMENT (OR CONDITION MODIFICATION) 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. ................................................ 4 3 PART C - WHETHER THE AMENDMENT (OR CONDITION MODIFICATION) WILL ADVERSELY IMPACT ALL OR A PORTION OF THE PLANNING AREA BY: ..................................................................................................... 5 3.1 Altering Acceptable Land Use Patterns to the Detriment of the Plan. .............................................................. 5 3.2 Requiring Public Expenditures for Larger and More Expensive Infrastructure............................................... 5 3.3 Requiring Public Improvements to Roads, Sewer, or Water Systems that are Needed to Support the Planned Land Uses. .............................................................................................................................................................. 5 3.4 Adversely Impacting Planned Land Uses Because of Increased Traffic. ........................................................... 6 3.5 Affecting the Livability of the Area or Health or Safety of Present and Future Residents. ........................ 6 3.6 Adversely Impacting the Natural Environment or Scenic Quality of the Area in Contradiction to the Plan. ........................................................................................................................................................................................... 6 4 PART D - WHETHER THE AMENDMENT (OR CONDITION MODIFICATION) IS CONSISTENT WITH THE OVERALL INTENT OF THE COMPREHENSIVE PLAN. ............................................................................................ 7 5 PART E - THE EXTENT TO WHICH THE AMENDMENT (OR CONDITION MODIFICATION) IS CONSISTENT WITH THE SPECIFIC GOALS AND POLICIES CONTAINED WITHIN THE PLAN. ................................................. 8 6 PART F - OTHER PERTINENT INFORMATION AS REQUESTED BY THE MARICOPA COUNTY PLANNING DEPARTMENT STAFF. ........................................................................................................................................... 20 List of Tables Table 1 Consistency with Comprehensive Plan CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 2 1 PART A – EXECUTIVE SUMMARY This narrative report addresses the required information to support the request for a Major Comprehensive Plan Amendment (CPA) for the Maricopa Solar and Storage Project (the project). Ellwood Land Holdings, LLC (Ellwood), as the Applicant, is proposing the construction and operation of an electrical generation facility consisting of solar modules and a battery energy storage system (BESS), collectively referred to as the project. The solar (photovoltaic) modules will be up to 2.0 gigawatt alternating current (GWac) and the BESS will be up to 1.5 gigawatt (i.e., 4-hour duration or 6.0 gigawatt-hour). The solar and BESS portion of the project may be developed in approximately 550-megawatt (MW) phases depending on the results of ongoing electrical grid interconnect efforts. The project would be located on up to 11,260 acres of land in the Harquahala Valley west of Tonopah, in unincorporated Maricopa County (County), Arizona. The project would include up to 5,200,000 solar modules, rated at 490+ watts direct current (dc) per module, and mounted on single-axis trackers. It should be noted that watts per module may vary at the time of construction; however, for planning purposes we have included an approximate module output of 490 watts dc. In addition to the installation of solar modules, the project would include the construction of a project substation, BESS warehouse, and operation and maintenance (O&M) building that would include a connection to a septic system. The project interconnect would be at the Arizona Public Service (APS) Delaney Substation, located approximately 5.5 miles east of the Applicant’s site. The substation, BESS warehouse, and O&M building would be located on up to 100 acres within the Applicant’s site. The project transmission interconnect would be a 500-kilovolt (kV) transmission line on 135- to 200-foot structures above grade within an up to 200-foot right-of-way (ROW). The ROW width may vary depending on availability of ROW. The expected maximum net output, at the proposed point of interconnection from the combined solar modules and BESS is up to 2.0 GWac. The design life of the project is anticipated to be 40 years. 1.1 On-site and Regional Location The Applicant’s site is situated northwest of Saddle Mountain, south of the Big Horn Mountains Wilderness Area, and northeast of the Eagletail Mountains Wilderness Area. The Saddleback Diversion Channel is within 0.5 mile of the eastern boundary of the site. Topographically, the site slopes slightly to the south toward Centennial Wash. Elevations within the site range between approximately 1,065 and 1,230 feet above mean sea level. The site is generally used for irrigated row crop cultivation and was historically native desert land. Some portions of the site are previously disturbed desert land. The site is approximately 12 miles west of Tonopah, within unincorporated Maricopa County, on up to 11,260 acres of land, and is bounded by Interstate 10 to the north, 491st Avenue to the east, Broadway Road to the south, and a point approximately 1.5 miles west of Harquahala Valley Road to the west. Generally, the center of the project is located at 499th Avenue and Thomas Road. The point of interconnection would be at the APS Delaney Substation. The Applicant’s site consists of multiple parcels of land within the following Township (T), Range (R) and Sections: • T2N/R9W: Sections 9, 10, 11, 13, 14, 15, 23, 24, 25, 26, 35, and 36; • T2N/R8W: Section 18; • T1N/R9W: Sections 1, 11, 12, 13, 23, and 24; and • T1N/R8W: Sections, 6, 7, 18, and 19. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 3 The Applicant has secured site control options for all parcels included within the project boundary. A list of all parcels within the project boundary and a list of parcels within 300 feet of the project boundary are available under separate cover. 1.2 CPA Size and Description of Land Use Types by Acreage The request is for a major CPA to change the land use of 11,260 acres from Rural Development Area to Utilities. Land uses within and surrounding the site include rural development, irrigated row crops, scattered rural residences, some commercial, utilities, public uses, and open space (i.e., native desert land). The site is zoned as Rural-43 Zoning District-One Acre Per Dwelling Unit (RU-43; 11,257.93 acres), which allows for both farm and non-farm residential uses, as well as farms and recreational and/or institutional uses. In addition, the site includes land zoned as Intermediate Commercial Zoning District (C-2; 2.07 acres). The Harquahala Power Plant is located east of the site, and the APS Delaney Substation is approximately 5.5 miles east of the site. Various underground pipelines and above-ground electric lines occur in and around the site. 1.3 Roads/Transportation Systems Serving the Project The site is currently accessible from the north off of Interstate 10 at Salome Road, from the west via Harquahala Valley Road, from the east via 491st Avenue, and from the south via Broadway Road, with Courthouse Road bisecting near the middle of the site. Several existing graded and asphalt-paved major/minor/local/farm roads also exist within the site. 1.4 Suitability with Surrounding Land Uses The site is situated in a prime location within the regional electric grid and in a relatively remote area suited for renewable energy development. Two CPAs were approved in 2011 under an older land use designation for solar projects (Almeria Solar Project [CPA2011009] and Harquahala Solar Project [CPA2011002]) within the Applicant’s site. Although these sites were never developed, the suitability of this project with surrounding land uses is demonstrated by the County’s approval of these types of uses (i.e., solar farms); numerous high voltage transmission lines occur near the site; and the Harquahala Power Plant is located immediately east of the site while the APS Delaney Substation is 5.5 miles further east. Further, Recurrent Energy and First Solar are proposing two utility solar projects east of the Applicant’s site and the APS Delaney Substation. The site is relatively flat agricultural land. It is likely that the amount of dust currently generated by these agricultural lands would be reduced with the project, given the lands would no longer be routinely tilled or harvested. Rather, the land would lay fallow beneath solar arrays with minimal ground disturbance or vehicular activity compared to present activities. The project would not generate noise or use water during the production of electricity. The solar array (up to approximately 10 feet above ground when fully tilted) would be noticeable along roads and nearby residences up to one-quarter to one-half mile away, but would blend into the background terrain for sensitive viewers at distances greater than one- half to one mile. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 4 2 PART B - WHETHER THE AMENDMENT (OR CONDITION MODIFICATION) 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 project would constitute an overall improvement to the Comprehensive Plan and is not being developed solely for the good or benefit of a particular landowner or owners. The County places demonstrable value on alternative energy development, as evidenced by the strategic priorities and core principles of the County’s Vison 2030 Comprehensive Plan. Maricopa County explicitly identifies encouraging solar energy development as an important goal, particularly in Economic Growth Policy 10, Energy Goal 2, Energy Policy 6, and Water Resources Policy 5. The project, as a utility-scale renewable energy generation and storage facility, is in direct alignment with the County’s mission and guiding principles for leadership and strategic priorities to leverage its resources to provide for a balanced regional economy. The project would benefit the local, County, state and regional economy by providing employment opportunities for hundreds of experienced professionals per 550-MW phase of construction, each of which would occur over a 2 to 3-year construction window, beginning in 2023-2024, as well as revenue opportunities for local businesses. Further, the electricity generated by the project would be distributed to the regional electrical grid, supplying the county, state and wider west/southwest regions. The generation of solar electricity could also result in improved air quality through reduced emissions for electric generation, providing a benefit to air quality in Maricopa County, aligning with the County’s Environmental Goal 1. Many site characteristics were taken into consideration to ensure the project would be consistent with and upholding the County’s Comprehensive Plan policies and goals, and would enable efficient, responsible development. Amending the Comprehensive Plan to allow for solar energy electric generation in this location represents compatible land use strategy and efficient development patterns near existing electric utilities. The County’s Land Use Goal 1, Land Use Policy 33, and Energy Goal 3 for efficient development patterns would be supported by the project, given the location in an area that allows for efficient interconnection with existing electrical infrastructure (i.e., numerous high voltage transmission lines, the APS Delaney Substation) serving regional electrical load growth. In addition, there are a number of previously approved (but never developed) solar energy generation projects sited in the project, demonstrating consistency in land use and utility siting by the County. The area has a developed road system, such that the need for additional infrastructure would be minimized and the project would not place excess burden on existing infrastructure, and existing and future road alignments would be maintained, supporting the County’s Transportation Goal 2 and Transportation Policy 1 and Policy 2. As a low water use facility (construction = approximately 30,000 gallons per acre and O&M = approximately 200 gallons per acre per year), it does not require water in the generation of electrical power and requires very little water for panel and equipment maintenance, supporting the County’s Water Resources Goal 4 and Water Resources Policy 3 and Policy 5. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 5 The site is relatively flat agricultural or undeveloped land and would require little additional grading for site development, reducing topographic disturbance and directly aligning with the County’s Environmental Policy 8. The majority of the site consists of agricultural and rural development and has not been identified to have known sensitive biological resources or cultural resources, demonstrating compatibility with the County’s Land Use Policy 22 and Policy 27, and Environmental Policy 4. On-going consultation with Arizona State Historic Preservation Office (AZ SHPO) and Arizona Game and Fish Department (AZGFD) will require additional biological and cultural resources analyses. In summary, the project would enable environmentally responsible, efficient land development and electrical generation within the County that would support County, state, and regional residents and the economy. The project would allow for the use of existing powerline corridors, existing road infrastructure and existing energy transmission, and would require minimal disturbance to topography and natural or cultural resources, to generate solar electricity. The project would provide employment and revenue opportunities within the County over a 2- to 3-year construction window for each development phase. These project characteristics uphold the County’s Comprehensive Plan strategies, goals, and policies and constitute an overall improvement to the comprehensive plan, local and regional economy, and regional energy production, that is not solely for the good or benefit of a particular landowner or other project proponent at a particular time. 3 PART C - WHETHER THE AMENDMENT (OR CONDITION MODIFICATION) WILL ADVERSELY IMPACT ALL OR A PORTION OF THE PLANNING AREA BY: 3.1 Altering Acceptable Land Use Patterns to the Detriment of the Plan. The project would not alter acceptable land use patterns that would be detrimental to the Comprehensive Plan. Most of the land uses within the Applicant’s site are associated with agriculture. These land uses would be temporarily unavailable during the life of the project (i.e., 40 years). Agricultural practices could resume at the end of the design life of the project. Other existing land uses within the site include open space (i.e., native desert), utilities, and small pockets of residences. These land uses would continue with the implementation of the project. 3.2 Requiring Public Expenditures for Larger and More Expensive Infrastructure. The project would not require any public expenditures for larger and more expensive infrastructure. The costs of the project’s infrastructure needs, such as gen-tie line and on-site collection lines, and required site access improvements shall be borne by the Applicant. 3.3 Requiring Public Improvements to Roads, Sewer, or Water Systems that are Needed to Support the Planned Land Uses. The project would require improvements to roads (e.g., underground cabling and access), septic, and potable water system associated with the O&M building to support the planned land use. The project area is served by existing roads and the temporary project construction traffic is not anticipated to overburden the existing road system. The costs of the project’s infrastructure needs, such as access road improvements, MCDOT-requested road improvements (e.g., project required underground conduit and wiring, entrance CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 6 road apron), septic, limited temporary and operational water needs and domestic waste, shall be borne by the Applicant. Water for construction and O&M would utilize on-site water wells associated with the project. 3.4 Adversely Impacting Planned Land Uses Because of Increased Traffic. During construction, traffic will increase in the area. However, this would be a temporary impact to the transportation network, lasting approximately 24-36 months per 550-MW phase of construction. If the project is constructed in approximately 550-MW phases, there would be approximately five construction phases, each over a 2 to 3-year period. The project would not affect planned land uses during either construction or operation. Access to all existing land uses within the project area will remain open and unaffected. 3.5 Affecting the Livability of the Area or Health or Safety of Present and Future Residents. The project would not have an impact on livability or health or safety of present or future residences within the project area. Site preparation and construction would generate some emissions due to the use of construction equipment, and would implement dust control measures to minimize fugitive dust emissions. Project operations would not generate air emissions; project maintenance would generate minimal vehicle and equipment emissions and fugitive dust emissions from personnel accessing the project site and utilizing limited vehicles or equipment. The project would be managed in accordance with local, state, and federal regulations to minimize risk and exposure to the public and the environment. Wildfire prevention and mitigation measures would be incorporated into the Specific Plan of Development. All applicable local and county fire laws and regulations will be complied with and all reasonable measures will be taken to prevent fires on the site. Fire hazard risk may be reduced through the control or suppression of weeds. All weed control would be conducted in compliance with County regulations. Herbicides would likely be necessary to control the spread of invasive weeds following construction disturbance as part of an integrated pest management strategy. 3.6 Adversely Impacting the Natural Environment or Scenic Quality of the Area in Contradiction to the Plan. The project would not adversely impact the natural environment or the scenic quality of the area. We have submitted a biological resources report that discusses fauna and flora within the project area (May 29, 2020). Further, the Applicant is in consultation with AZGFD regarding their comments submitted on July 1, 2020. In addition to a field site investigation, the US Fish and Wildlife Service Information for Planning and Consultation website and the AZGFD Online Environmental Review Tool were queried for information on special status species, including federal threatened and endangered species, for the project area. No federally listed species or their associated habitats were identified during this assessment. Native plants protected under Arizona Native Plant Law, administered by the Arizona Department of Agriculture, will be identified on the site prior to construction and relocated or salvaged as required. Native plant removal, relocation, or sale will be noticed as required by Arizona Administrative Code Title 3, Chapter 3, Article II. Further, the project will avoid the Centennial Wash Floodway as well as identified Waters of the United States and wetlands. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 7 A Class I Cultural Resources Inventory consisting of a literature review and site files review was completed for the site and has been submitted (May 29, 2020). Known archeological sites would be avoided. Further, the Applicant is in consultation with the AZ SHPO regarding comments received on June 24, 2020. A Class II Cultural Inventory Report and Sampling Assessment would be completed prior to project construction. Additionally, the State of Arizona requires that the inadvertent discovery, during construction, of human remains and funerary objects be reported to the Director of the Arizona State Museum (ARS 41-865) upon discovery. Finally, the project would not significantly impact the scenic quality of the area. Currently there is electrical infrastructure (e.g., transmission lines, power plant, substations) as well as above-ground electrical distribution lines and transportation networks within the project area and the region. Existing views from within the site will not be significantly obscured, because the height of panels will not obscure scenic views beyond the site. We have also previously submitted a glint/glare assessment (May 29, 2020) that shows that reflections from the solar array along existing roads, at two airfields and at residences would not be adverse. The Applicant understands that the County will require an 80% opacity screen be constructed in areas adjacent to existing residences to minimize visual impact. 4 PART D - WHETHER THE AMENDMENT (OR CONDITION MODIFICATION) IS CONSISTENT WITH THE OVERALL INTENT OF THE COMPREHENSIVE PLAN. Maricopa County places demonstrable value on alternative energy development, as evidenced by the strategic priorities and core principles of the County’s Vison 2030 Comprehensive Plan. Maricopa County explicitly identifies encouraging solar energy development as an important goal, particularly in Economic Growth Policy 10, Energy Goal 2, Energy Policy 6, and Water Resources Policy 5. The County’s strategy encouraging renewable energy development is provided as follows: Renewable Energy Maricopa County has the potential to be a global leader in renewable energy research and development, especially with respect to solar energy. Maricopa County is one of the most productive spots in the world for both photovoltaic and concentrated solar energy generation. Many companies have already discovered this potential, evidenced by the large number of utility-scale plants being planned in unincorporated areas. Because of the economic and environmental benefits Maricopa County supports state and local efforts to attract solar research and development to this region. Strategies - Attract solar and other alternative energy research and development to Maricopa County. The project, a utility-scale renewable energy facility, is in direct alignment with the County’s strategy to support the development of solar electrical generation. The project would benefit the local, County, state and regional economy by providing employment opportunities for hundreds of experienced professionals per 550-MW phase of construction, each of which CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 8 would occur over a 2 to 3-year construction window, beginning in 2023-2024. Spending for construction activities and workers would also provide revenue opportunities to local businesses in the County and state. Further, the electricity generated by the project would be distributed to the regional electrical grid, supplying the county, state and wider region. Environmental benefits of the project include the generation of up to 2.0 GWac and storage of up to 1.5 gigawatt of new solar energy to meet the needs of a growing population in Maricopa County and the state. The generation of solar electricity could also result in improved air quality through reduced emissions for electric generation as well as reduction of dust during agricultural tilling practices, providing a benefit to air quality in Maricopa County, aligning with the County’s Environmental Goal 1. Further, the project displays consistency with the County’s vision to work collaboratively and effectively for its residents and mission to provide regional leadership by encouraging the development of solar energy generation facilities that would provide renewable electricity for residents of the County and larger region. approving the application to enable development of solar energy generation in proximity to existing electrical infrastructure with surrounding land uses. The decision to support this project would directly align with the County’s strategic priorities to leverage its resources, plan for effective and efficient infrastructure, and manage county resources to promote financial stability and economic prosperity for its residents. One of the County’s core principles is to support implementation of the County’s strategic priorities. This project directly supports the County’s strategic priorities, as indicated in the discussion of the specific goals and policies of the Comprehensive Plan in the following section. 5 PART E - THE EXTENT TO WHICH THE AMENDMENT (OR CONDITION MODIFICATION) IS CONSISTENT WITH THE SPECIFIC GOALS AND POLICIES CONTAINED WITHIN THE PLAN. The project will use photovoltaic and battery technology and will require very little water use during operations, with the exception of as-needed maintenance for cleaning the solar panels and equipment and water use associated with the O&M building. Maricopa County recognizes the potential environmental and economic benefits of solar developments within the Comprehensive Plan, as indicated by multiple goals and policies, which are highlighted in Table 1. The Applicant believes the project is well suited for an agricultural area, because it requires large amounts of relatively flat land. Further, proximity to the APS Delaney Substation that provides access to the Palo Verde Nuclear Generating Station makes this location ideal in terms of minimizing the very long electrical interconnects required for the transmission of electricity to the regional electrical grid. Moreover, the area surrounding the APS Delaney Substation, as well as most of the land between the solar array and the APS Delaney Substation, which lies 5.5 miles to the east, is mostly undeveloped. It is recognized that small pockets of residential land use occur mostly west of the solar array, although there are also a few residences east of the project. The existing visual setting has been previously impacted by: agricultural farms and their attendant infrastructure (e.g., water pumps, retention basins, canals, farm roads, and distribution lines); electrical infrastructure including the Harquahala Power Plant, high voltage transmission lines, and electrical substations; flood control structures; and the transportation network (e.g., arterial roads and Interstate 10). CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 9 The project would contribute to the existing visual clutter within the region; however, given the low-profile design of the array, BESS, O&M building, and other ancillary facilities, it is not expected to adversely impact existing views or the existing natural/man-made setting. The most prominent feature on the landscape would be the project’s 500kV interconnect, which would be constructed on structures approximately 135 to 200 feet tall and would be visible. However, this interconnect would occur in an area less developed than the west side of the project and would occur, in part, in an area that already has a 500kV transmission line present (i.e., the Harquahala Power Plant). Finally, the Applicant believes that this project would assist the County in promoting its goal to encourage solar development and the creation of jobs (both temporary construction jobs and permanent O&M jobs) associated with these types of development. The Applicant believes the project is wholly consistent with specific goals and policies within Maricopa County’s Comprehensive Plan. Table 1 includes a complete accounting of relevant comprehensive plan elements, their attendant policies, and the consistency of the project with these policies. The project is overwhelmingly consistent with the intent of the Comprehensive Plan. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 10 Table 1 – Consistency with Comprehensive Plan Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Land Use Element Land Use Goal #1 Achieve balanced and efficient development patterns. Consistent The project is located near existing high voltage transmission lines and a natural gas power plant; amending the Comprehensive Plan to allow for solar energy electric generation in this location represents compatible land use strategy and efficient development patterns near existing electric utilities. Land Use Goal #3 Protect the public health, safety, and well-being. Consistent The project would provide renewable energy generation that could result in improved air quality through reduced emissions from fossil fuel electric generation. The project would be considered a low- intensity use. Land Use Policy #1 Maricopa County supports compliance with its capital improvement and other funding programs, except when reimbursement is made to the County for unplanned costs or when services and infrastructure are funded by private capital. Consistent The project would be funded by private capital. All infrastructure improvements required for the project shall be paid for by the Applicant. Land Use Policy #2 Maricopa County supports phasing plans for new urban development to coordinate such development with new urban services and infrastructure. Consistent The project would be a phased energy infrastructure development and the Applicant will coordinate with County agencies regarding new services and infrastructure. Land Use Policy #7 Maricopa County supports coordinating land use and infrastructure planning with state agencies, counties, and municipalities. Consistent The Applicant will continue to coordinate closely with all applicable local, county, state, and federal agencies throughout development of the project, including the evaluation of enhanced gen-tie routing to adjacent and internal jurisdictions, as well as addressing topics pertaining to land and resource management, public safety, environmental and cultural resources, transportation and infrastructure, economic development, and large-scale solar electrical generation permitting. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 11 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Land Use Policy #11 Where feasible, Maricopa County supports including State Trust land in the planning and design of large-scale urban development. Consistent No State Trust Land is associated with the solar array development, as all development will occur on private lands. The project 500kV interconnect will likely cross State Trust Land. The Applicant has begun initial consultation with ASLD to advance securing a ROW across State Trust Lands. Land Use Policy #12 Maricopa County supports coordinating with state and federal agencies to address safety and security issues associated with new development near the Palo Verde Nuclear Generating Station. Consistent The Applicant has coordinated with Palo Verde Nuclear Generating Station to identify any concerns with the proposed development. No concerns were received. Land Use Policy #13 Where necessary, Maricopa County supports wildfire prevention and mitigation measures in the design of development. Consistent Wildfire prevention and mitigation measures would be incorporated into the Specific Plan of Development. All applicable local and county fire laws and regulations will be complied with and all reasonable measures will be taken to prevent fires in the project. All construction personnel will be instructed on emergency response to fire events; clear away all flammable material for a minimum of 10 feet from areas of operations where a spark, fire, or flame could be generated; equipment parking areas and small stationary engine sites will be cleared of all flammable materials prior to use; gas and oil storage areas will be clearly marked, cleared of all flammable material, “No Smoking” signs will be posted, and all used and discarded oil filters, oily rags, or other waste will be disposed of in an approved manner. The project will reduce fire hazard risk through the control or suppression of weeds, and all weed control would be conducted in compliance with County and State requirements. Land Use Policy #20 Maricopa County supports reducing the impacts of new urban development on existing rural land uses and agriculture. Consistent The project would have no impact on nearby agricultural and rural land uses. At the end of the life of the project, agricultural practices could resume on the site because the underlying soils would have been minimally impacted during the lifetime of the project. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 12 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Land Use Policy #22 Maricopa County supports reducing the impacts of new development in environmentally sensitive areas, including native wildlife (flora and fauna) habitat and corridors. Consistent The project is located in an area away from environmentally sensitive areas, agency dedicated wildlife habitats, and wildlife corridors. No development would occur within the Centennial Wash area, allowing wildlife to continue to use that habitat. Coordination with AZGFD, Arizona Department of Agriculture, and other agencies are ongoing and will be used to refine site development and environmental protective measures. The project would comply with the Arizona Native Plant Law and other regulations associated with the protection of sensitive native wildlife. Land Use Policy #23 Maricopa County supports reducing the impacts of new development on Maricopa County’s regional parks, the Maricopa Trail, and other public open spaces. Consistent The project is located away from, and will not impact, Maricopa County’s regional parks, the Maricopa Trail, or other public open spaces. Land Use Policy #27 Maricopa County supports keeping development out of delineated floodways and, where necessary, 100-year floodplains. Consistent The project will not be developed in a floodway. Further, the project will comply with Maricopa County and federal regulations associated with development in a floodplain. Land Use Policy #31 To promote safe and active communities Maricopa County supports public safety and security features included in the design of new and existing development. Consistent All required safety and security measures will be incorporated into the project. For example the project will be fenced and include nighttime security lighting, all roads will be consistent with County regulations associated with first responder access (turn-around radii, Knox Box, road widths), and fire detection and suppression systems will be in conformance with County Fire Marshal requirements. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 13 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Land Use Policy #33 Maricopa County supports using land use buffers and compatible land use strategies near existing and future high voltage electric utility line corridors. Consistent The project is located near existing high voltage transmission lines and a natural gas power plant. Sufficient buffers, as directed by the County, to provide safety exclusion zones/distancing will be incorporated to not interfere with these existing land uses. A solar farm acts as an efficient buffer by providing further separation from these existing electrical features and surrounding agriculture and rural land uses. Further, all applicable setbacks will be incorporated into the project layout. Transportation Element Transportation Goal #2 Contribute to a safe, seamless and effective transportation system. Consistent The project will support preserving the existing and future road alignments in the project area and will comply with Maricopa Department of Transportation planning objectives. Transportation Policy #1 As necessary, Maricopa County supports preserving future road alignments called for in County- recognized transportation plans, especially mid-section line, section line and arterial roads; parkways; freeways; and interchanges. Consistent The project will support preserving the existing and future road alignments in the project area and will comply with Maricopa Department of Transportation planning objectives. Transportation Policy #2 Maricopa County supports compliance with its Major Streets and Routes Plan. Consistent The project will support preserving the existing and future road alignments in the project area and will comply with Maricopa Department of Transportation planning objectives. Transportation Policy #9 Maricopa County supports balanced and efficient land use patterns that reduce the number and length of vehicle trips. Consistent Once operational, the project site will require minimal staff (2-3 personnel per 8-hour shift [24-hour round the clock staffing]), resulting in few vehicle trips to and from the site. Transportation Policy #11 Maricopa County supports National Ambient Air Quality Standards compliance. Consistent The project would adhere to the National Ambient Air Quality Standards. The project will generate renewable energy that would result in improved air quality through reduced emissions for electric generation as compared to other electric generation technologies. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 14 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Transportation Policy #12 Maricopa County supports improving low volume dirt roads as directed by its PM-10 Dust Abatement Program. Consistent A Dust Abatement Permit will be required prior to project construction. The project will submit a dust control plan to Maricopa County Air Quality department. Use of dirt roads will include implementation of, when and where needed, dust abatement techniques during construction and O&M. Transportation Policy #14 Where necessary, Maricopa County supports roadway planning that promotes identified scenic corridors, wildlife connectivity and linkages. Consistent Ongoing consultation with AZGFD will facilitate identification of pertinent mitigation measures, incorporated into the project design, that provide for wildlife connectivity and linkages. Environment Element Environmental Goal #1 Provide regional leadership to promote all aspects of regional environmental quality. Consistent The project will generate renewable energy that would result in improved air quality through reduced emissions for electric generation, providing a benefit to air quality in Maricopa County. Appropriate protective measures for biological and cultural resources will be implemented to minimize or prevent impacts to these resources. The project will require very little water for construction and operation. Amending the Comprehensive Plan to enable this project would demonstrate responsible leadership to promote regional environmental quality. Environment Policy #3 To help protect water quality, Maricopa County supports compliance with its Drinking Water program and its Water and Wastewater Treatment program. Consistent The project would be consistent with Maricopa County’s Drinking and Wastewater Treatment programs, to provide appropriate water management and treatment to maintain water quality standards as required. Environment Policy #4 Maricopa County supports innovative project design and development techniques that protect important plant and animal habitat and migration corridors. Consistent The project will be designed to avoid impacts to identified agency-designated animal habitats or migration corridors during project construction and O&M. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 15 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Environment Policy #5 As directed by the State Historic Preservation Office and Arizona Game and Fish Department, Maricopa County supports cultural resource and biological surveys being completed – and needed mitigation measures established – prior to new development. Consistent The project would complete required cultural and biological reporting and surveys as directed from the State Historic Preservation Office and Arizona Game and Fish Department. We have previously submitted a Biological Resources Report and Class I Cultural Resources Inventory (May 29, 2020). Appropriate protection measures or mitigation measures will be developed in coordination with the agencies. Environment Policy #7 Where necessary, Maricopa County supports noise reductions in new development design and in the construction of new buildings. Consistent The project would conform to required noise mitigation during construction and would maintain hours of operation consistent with county regulations. The project would not generate noise during the production of electricity. Economic Element Economic Growth Goal #1 Contribute to an effective regional economy. Consistent Because of the high solar resource available in Arizona, and Maricopa County in particular, the project would harness and convert the readily available solar irradiation into an important power resource. The project would employ hundreds of experienced professionals from the local community, Maricopa County and surrounding region per 550MW construction phase which would occur over a 2-3-year construction window, beginning in 2023-2024. Construction workers would purchase food and incidentals at local retail businesses. Construction workers would sleep either at their homes or at local motels. On-site housing would not be provided during construction. Economic Growth Goal #2 Have a diverse and balanced economy to promote long-term stability and economic resiliency. Consistent The project would further expand electric generating resources in the County by harvesting readily available solar irradiation and would provide these resources over the approximately 40-year operational lifetime, providing long-term stability and economic resiliency. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 16 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Economic Growth Policy #3 Maricopa County supports increasing entrepreneurial activities and business formation. Consistent The project would create hundreds of construction jobs per 550 MW constructed) over a seven to nine-year construction window, 2023-2030. Construction workers would purchase food and incidentals at local retail businesses. Construction workers would sleep either at their homes or at local motels. On-site housing would not be provided during construction, providing revenue opportunities for local businesses. Economic Growth Policy #5 Maricopa County supports programs that attract a variety of Basic Sector industry clusters that have long-term, stable growth prospects Consistent The project would employ hundreds of experienced professionals per 550MW construction phase which would occur over a 2-3-year construction window, beginning in 2023-24. As the solar electrical generating and storage sector continues to grow, Maricopa County has the opportunity to expand this sector by supporting this and similar projects. An expanded sector base would attract additional opportunities for business development and worker training programs, providing long-term employment and economic development opportunities. Numerous trades are required for the construction of a utility-scale solar project including electricians, plumbers, mechanics, heavy equipment operators, assemblers, security, administrators and project management. Economic Growth Policy #6 Maricopa County supports efforts to recruit prospective businesses and industries to the County, and efforts to retain existing businesses and industries. Consistent The high solar irradiance of Arizona, in addition to the availability of highly suitable land for development in Maricopa County and the proximity to existing electrical infrastructure, were prime factors that attracted the Applicant to this area. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 17 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Economic Growth Policy #10 Maricopa County supports leveraging its solar resource potential to attract solar-related industries and alternative energy research and development. Consistent Because of the high solar resource and highly suitable land available in Maricopa County for development of solar energy facilities, Maricopa County is a prime location for solar resource development. The project is a utility-scale solar and battery storage project that Maricopa County could use to leverage their leadership in this industry to attract solar-related industries and additional development. Delaney Substation was constructed by APS to attract solar developers to this region to interconnect with the larger electrical grid. Currently within six miles of the project are two other planned utility-scale solar projects (First Solar and Recurrent Energy). Growth Area Element Growth Area Goal #1 Achieve orderly urban growth that is fiscally and environmentally responsible, protects public health and safety and promotes sensible annexation patterns. Consistent This project would enable the County to site utility-scale solar generation near existing electrical infrastructure, in an area that development would result in limited impact to the environment and would provide benefits to air quality in the County, while utilizing a readily available resource to generate electricity for the southwest and western grid – a demonstration of efficient, orderly growth by the County. While this area is currently rural, it provides services and infrastructure that urban growth areas utilize and would provide a foundation for future urban growth patterns to consider. Open Space Element Open Space Goal # 1 Provide regional leadership to promote environmental quality, including the preservation of open, natural park and recreation lands. Consistent This project would enable the County to site utility-scale solar generation near existing electrical infrastructure and agricultural use, in an area that development would result in limited impact to open space lands and would demonstrate efficient, orderly growth. In addition, the project will generate renewable energy that would result in improved air quality through reduced emissions for electric generation, allowing Maricopa County to provide regional leadership in promoting environmental quality through improved air quality in the County. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 18 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Open Space Policy #2 Maricopa County supports dedication and improvement of trail right-of-way within new development, including the Maricopa Trail and Maricopa County Regional Trail System. Consistent While the project does not include trail development, we support the development of recreational resources and connectivity for users, including trail right-of-way and the greater Maricopa County Regional Trail System. It should be noted that the original footprint of the project included land within the Centennial Wash Floodway – this part of the project has been removed and no impacts on Centennial Wash or an ancient trail (i.e., within Centennial Wash) will occur. Water Resources Element Water Resources Goal #2 Provide leadership to promote regional water quality and water use. Consistent The project does not require water in the generation of electrical power and requires very little water for panel and equipment maintenance. By promoting solar electrical generation, the County provides leadership on responsible water use by enabling low-water use infrastructure to provide the southwest and western electrical grid with a renewable source of electricity. Water Resources Policy #2 Maricopa County supports water conservation techniques in the planning and design of new development. Consistent The project does not require water in the generation of electrical power and requires very little water for panel and equipment maintenance. Very little water will be required for construction activities. Water for construction and long term O&M will come from on- site private ground water wells. The approximate water usage for construction is 30,000 gallons per acre and during O&M is 200 gallons per acre per annum. The project will be designed to incorporate feasible water conservation techniques. Water Resources Policy #4 Maricopa County supports compliance with its Drinking Water and Water and Wastewater Treatment Programs. Consistent The project will be consistent with Maricopa County’s Drinking and Wastewater Treatment programs. Water Resources Policy #5 Maricopa County supports low water use solar electric generating technologies. Consistent The project does not require water in the generation of electrical power and requires very little water for panel and equipment maintenance. Panel washing may be required if bi-annual rains are not sufficient or if soiling of panels is excessive due to dust accumulation. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 19 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Water Resources Policy #7 Maricopa County supports low water use and drought-tolerant landscaping. Consistent Any required landscaping for the project would use drought-tolerant low-water-use landscaping. The water to support any required project landscaping would come from on-site private wells. Energy Element Energy Goal #1 Provide leadership to promote regional environmental quality. Consistent The project will provide renewable energy generation that would result in improved air quality through reduced emissions for electric generation, providing a benefit to air quality in Maricopa County. Appropriate protective measures for biological and cultural resources will be implemented to minimize or prevent impacts to these resources. The project will require very little water for construction and operation. Amending the Comprehensive Plan to enable this project would demonstrate responsible leadership to promote regional environmental quality. Energy Goal #2 Make Maricopa County a leader in alternative energy research and development. Consistent The project is a utility-scale solar and storage project. While utility-scale solar is not a “new” technology, the battery energy storage system is a fairly new technology in utility-scale renewable energy generation. Solar industry trends are leaning towards battery storage systems in an effort to maximize the production of stored energy when the sun sets. Energy Policy #1 Maricopa County supports energy efficient design and construction of new development. Consistent The project will utilize current technologies and best practices in all components to support energy efficient design and construction. All project components (e.g., panels, inverters, SCADA, batteries) will utilize leading edge technology to insure the most efficient solar generation and storage system is developed. Energy Policy #4 To limit energy consumption, Maricopa County supports alternative transportation options in new development. Consistent During construction, employees will be encouraged to carpool to the site to reduce the number of personal vehicle trips and emissions. Once operational, the project site will require minimal staff (2-3 personnel per 8-hour shift [24-hour round the clock staffing]), resulting in few vehicle trips to and from the site. CPA2020002 – Major Comprehensive Plan Amendment Application Project Narrative Maricopa Solar and Storage Project September 29, 2020 Page 20 Comprehensive Plan Elements Comprehensive Plan Policies Consistency with Comprehensive Plan Energy Policy #6 Maricopa County supports being a responsible leader in alternative energy research and development. Consistent The project is a utility-scale solar and battery storage project and would facilitate Maricopa County’s continued leadership in alternative energy development. Energy Policy #7 Maricopa County supports efforts to assist businesses and individuals with renewable energy options and energy conservation. Consistent The project is a utility-scale solar and storage project and would provide additional renewable energy options to the southwest and western electrical grid. Cost of Development Element Cost of Development Goal #2 New development pays its proper and reasonable share of the costs of new infrastructure, services, and other public improvements. Consistent The costs of the project’s infrastructure needs, such as gen-tie line, on-site collection lines, road improvements, conduit, limited temporary and operational water needs, and domestic waste shall be borne by the Applicant. Cost of Development Policy #1 Maricopa County supports recouping the costs of its products and services without unfairly burdening those most in need of its products and services. Consistent The project will pay all associated fees required by Maricopa County throughout project development. Cost of Development Policy #2 Maricopa County supports using the preferred funding methods identified in this plan to offset costs of new development. Consistent The project will pay all associated fees required by Maricopa County throughout project development. 6 PART F - OTHER PERTINENT INFORMATION AS REQUESTED BY THE MARICOPA COUNTY PLANNING DEPARTMENT STAFF. During the project’s pre-application meeting on May 12, 2020, the County requested site control options of parcels that constitute the footprint of the project for the zone change portion. Ellwood Land Holdings, LLC (Applicant), and its consultant, Wood, are available to provide any additional information requested by Maricopa County Planning and Development or by the Technical Advisory Committee. Harquahala Valley Rd 499th Ave Centennial Rd Lower Buckeye Rd W Salome Hwy Van Buren St Buckeye Rd Thomas Rd Indian School Rd Camelback Rd Salome Rd 507th Ave 491st Ave 483rd Ave 475th Ave Broadway Rd Bethany Home Rd 467th Ave Courthouse Rd T1N R10W T1N R8W T1N R9W T2N R10W T2N R8W T2N R9W §¨¦ 10 02 30 36 23 13 01 12 05 09 19 25 32 20 05 27 14 13 26 09 24 11 36 33 25 23 17 30 16 08 01 09 30 07 11 05 22 14 31 11 17 08 21 05 29 12 23 18 06 16 11 13 20 17 19 27 31 26 14 12 01 24 35 24 34 26 29 21 24 22 19 22 28 21 28 34 01 04 26 21 20 15 28 29 02 03 15 06 29 14 15 24 02 18 16 01 25 25 12 14 26 04 09 13 32 11 23 35 04 06 01 18 14 15 25 36 24 07 12 22 13 12 20 08 27 02 02 27 10 03 02 03 07 08 10 23 35 16 10 28 30 23 03 17 06 19 10 13 25 07 26 18 33 04 11 Path: X:\Projects\2019 Projects\1420192020 Maricopa Solar Plus Storage Project\MXD\CPA_Filing\Final\ParcelsByLandowner.mxd £ ¤ 85 Site Location Tonopah Palo Verde NGS Buckeye Glendale £ ¤ 60 §¨¦ 10 Site Vicinity 0 1 2 Miles ± Parcels By Landowner Maricopa Solar and Storage Project Maricopa County, Arizona The map shown here has been created with all due and reasonable care and is strictly for use with Wood Project Number 14-2019-2020. This map has not been certified by a licensed land surveyor, and any third party use of this map comes without warranties of any kind. Wood assumes no liability, direct or indirect, whatsoever for any such third party or unintended use. 14-2019-2020 RK 9/10/2020 1 inch= 1 mile Job No. PM: Date: Scale: Legend Proposed Project Boundary Township/Range Line Section Line 506-23-019B 506-23-022 506-18-027 506-28-005A 506-28-032B 506-29-023E 506-28-005B 506-28-034B 506-29-024A 506-28-022 506-29-004 506-29-024B 506-28-024A 506-29-005 506-29-029 506-28-024B 506-29-006B 506-29-030 506-28-028B 506-29-017 506-29-032 506-28-032A 506-29-019 506-29-033 506-23-019C 506-18-020A 506-18-026A 506-23-036B 506-23-036C 506-23-035A 506-23-012C 506-23-012D 506-23-018A 506-23-017A 506-23-017C 506-18-007 506-18-014 506-18-013 506-18-015 506-18-010A 506-18-009A 506-18-012 506-18-011A 506-18-032D 506-18-034A 506-18-029E 506-18-030C 506-18-030D 506-18-025D 506-18-026B 506-18-035C 506-18-035D 506-18-036B 506-18-020B 506-18-23 506-18-019A 506-18-019C 506-30-015G 506-30-015H 506-30-015J 506-29-026A 506-29-025B 506-29-025A 506-29-026B 506-29-016A 506-29-016K 506-29-015D 506-29-027A 506-29-027F 506-29-027E 506-23-038A 506-23-037A 506-29-015A 506-29-015B 506-29-015C 506-29-013G 506-29-018E 506-29-011A 506-29-013A 506-29-031D 506-29-018B 506-29-016L 506-29-012A 506-29-031E 506-29-031G 506-23-020A 506-23-021 WPI-HD4 Farm AZ LLC (556.11 acres) WPI II-Harq Farm AZ, LLC (431.30 acres) Yankee Point LLC (316.83 acres) Barnes Harquahala Farms LLC (180.56 acres) Clarke LLC (160.41 acres) CV Harquahala, LLC (2,894.85 acres) Estate of Vicki Lou Barnes (136.67 acres) Ferguson Grandchildren LLC (320.79 acres) Harquahala Valley Farms, LLC (4,049.93 acres) Salome 282, LLC (274.18 acres) MFG Holding, LLC (220.16 acres) WPI-HD1 Farm AZ LLC (477.50 acres) WPI-HD2 Farm AZ LLC (1,062.16 acres) WPI-HD3 Farm AZ LLC (178.18 acres) September 3, 2020 Mr. Adam Cannon, Planner Maricopa County Planning & Development Department 501 N. 44th Street, Suite 200 Phoenix, AZ 85008 RE: Maricopa Solar and Storage Project Clarifications Dear Mr. Cannon: The Department has reviewed a letter (attached) from David J. Cerasale with Westland Resources dated August 18, 2020. This letter is in regards to the Departments comments on the Comprehensive Plan Amendments associated with the Maricopa Solar and Storage Project submitted to Maricopa County on July 1, 2020. The Department concurs with these clarifications within this letter based on a phone conversation with Westland Resources on July 13, 2020. The Department looks 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.gov if 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) Q:\Jobs\2100's\2122.03\ENV\AZGFD Clarifications\AZGFD Clarifications_08.18.20.docx ENGINEERING AND ENVIRONMENTAL CONSULTANTS 4001 East Paradise Falls Drive | Tucson, Arizona 85712 | 520.206.9585 2020 North Central Avenue, Suite 695 | Phoenix, AZ 85004 | 602.888.7000 1750 South Woodlands Village Blvd, Suite 150 | Flagstaff, Arizona 86001 | 928.225.2218 August 18, 2020 Mr. Andrew Cavalcant Project Evaluation Specialist ARIZONA GAME AND FISH DEPARTMENT 5000 W. Carefree Highway Phoenix, Arizona 85086 Sent via email to: acavalcant@azgfd.gov Re: CLARIFICATIONS FOR AZGFD COMMENTS ON MARICOPA SOLAR AND STORAGE PROJECT WESTLAND PROJECT NO. 2122.03 Dear Mr. Cavalcant: Thank you for taking time to discuss with us Arizona Game and Fish Department’s (AZGFD) comments on the Comprehensive Plan Amendments associated with the Maricopa Solar and Storage Project. Based on our discussion, WestLand Resources, Inc. (WestLand), is providing the following clarifications to AZGFD’s comments based on our conversation. Our understanding is that AZGFD concurs with these clarifications and will draft a letter to Mr. Adam Cannon at the Maricopa County Planning & Development Department documenting their concurrence. Below are the five comments AZGFD provided on the Comprehensive Plan Amendments and the clarifications that we have discussed with you. 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. Response: Based on our conversations, it is our understanding that AZGFD is requesting pre- construction surveys following survey protocols and guidelines provided by the Arizona Burrowing Owl Working Group (AZBOWG) for landowners (available at https://www.azgfd.com/wildlife/speciesofgreatestconservneed/raptor-management/burrowing-owl-mangement/).If present, management actions will be coordinated with U.S. Fish and Wildlife Service. 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 . Response: Based on our conversations, the handling of wildlife during construction of the facility will focus on Sonoran desert tortoise and Gila monster. If these species are encountered during construction, they will be allowed to travel through the site if it is safe to do so. They will be handled only when necessary and moved outside of the project area within 1 mile of its original location. Should Mr. Andrew Cavalcant August 18, 2020 Page 2 Q:\Jobs\2100's\2122.03\ENV\AZGFD Clarifications\AZGFD Clarifications_08.18.20.docx wildlife been required to be moved once the facility is operational, they will be moved outside of the project area and within 1 mile of its original locations if practicable. 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 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. Response: Based on our conversations, no clarifications are needed for this topic. 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. Response: Based on our conversations, we understand that AZGFD will not require bird flight diverters. The key consideration is building power poles to raptor safety standards to minimize electrocution risk per the suggestions provided by https://www.aplic.org/Electocutions.php. 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. Response: Based on our conversations, we understand that AZGFD’s main concern with surface hydrology is with increased surface flows to Centennial Wash and the appropriate placement and sizing of retention basins to address any changes in flows. The project is not anticipated to impact Centennial Wash, whether through water conveyance from the project site or from any land disturbance. If you have any questions or require additional information, please do not hesitate to contact me. Respectfully, WestLand Resources, Inc. David J. Cerasale, PhD Director, Environmental Department Principal and Senior Vice President cc: Richard Knox, Wood Environment & Infrastructure Solutions, Inc. July 1, 2020 Mr. Adam Cannon, Planner Maricopa County Planning & Development Department 501 N. 44th Street, Suite 200 Phoenix, AZ 85008 RE: Maricopa Solar and Storage Project Dear Mr. Cannon: The Arizona Game and Fish Department (Department) has reviewed the Comprehensive Plan Amendments sent to Maricopa County. Ellwood Land Holdings, LLC, the Project Applicant, is proposing the construction and operation of an electrical generation facility consisting of solar modules and a battery energy storage system (BESS), collectively the project. The solar (photovoltaic) modules will be approximately 2.0 gigawatt alternating current (GWac) and the BESS will be 1.5 gigawatt (i.e., 4-hour duration or 6.0 gigawatt-hour).The solar and BESS portion of the project may be developed in 400-megawatt (MW) phases depending on the results of ongoing electrical grid interconnect efforts. The project site would be located on approximately 11,500 acres of land in the Harquahala Valley west of Tonopah, in unincorporated Maricopa County (County), Arizona. 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 . Maricopa Solar and Storage Project July 1, 2020 Page 2 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 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. Thank you for the opportunity to provide comments on this proposed project. The Department looks 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.gov if 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 #M20-06111330 From: David Jacobs To: Adam Cannon (PND); Knox, Richard Subject: Maricopa Solar & Storage CPA2020002 Date: Tuesday, October 6, 2020 2:27:35 PM Adam- Yesterday [Monday, October 5th] I sent you a message stating we had received a letter of commitment on Friday [October 2nd] that formalized the applicant's [Ellwood Land Holdings, LLC] commitment to protect and mitigate potential impacts on cultural resources associated with the Maricopa Solar and Storage Project, and that formal commitment by the applicant Ellwood Land Holdings, LLC, did address our office's concerns regarding the project's potential impacts to cultural resources. I am clarifying this because of the mention of Renewable Power Development, US in Monday's e-mail. For the record, Ellwood Land Holdings, LLC is committing to the Class II activities, not Renewable Power Development, US. If any questions, please contact me at my e-mail address or at 602-542-7140. David Jacobs, Arizona State Historic Preservation Office From: David Jacobs To: Adam Cannon (PND) Subject: CPA2020002 Maricopa Solar and Storage Project Date: Wednesday, June 24, 2020 12:26:40 PM Adam- This project involves a vast amount of acreage [more that 8,000 acres], mostly terrain that our records indicate has not been inventoried for cultural resources. We do know of some prehistoric travel corridors and use of particular areas within the acreage, however, I am not going to suggest all of the over eight thousand acres be systematically surveyed for cultural resources. Rather, a stratified sample survey methodology should be developed by a qualified cultural resources specialist and a survey conducted after the stratified sample survey methodology has been reviewed by our office. Hopefully this will result in a reasonable effort to determine whether the project poses a potential impact to cultural resources situated in the project's more than 8,000 acres. Please contact me [602-542-7140 or djacobs@azstateparks.gov] if you or the applicant have questions regarding this approach. 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: June 8, 2020 TO : Adam Cannon, Planning & Development Dept. Planner FROM: Souren Naradikian, P.E. Senior Civil Engineer SUBJECT: Maricopa Solar and Storage Project CPA. CPA2020002 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 Maricopa Solar and Storage Project CPA. 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 June 8, 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: FW: 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 #3 No comment, at this time. As the property develops, 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) 2 <Laura.Etter@Maricopa.Gov>; Lynndsay ONeill (DOT) <Lynndsay.ONeill@maricopa.Gov>; Matthew Holm (PND) <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: 2nd Submittal - Comprehensive Plan Amendment for Maricopa Solar and Storage Project - CPA2020002 Date: Monday, September 14, 2020 2:30:04 PM Attachments: image002.png image003.png Good Afternoon, 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 Mon, Sep 14, 2020 at 12:25 PM Adam Cannon (PND) <Adam.Cannon@maricopa.gov> wrote: Good afternoon all, This e-mail serves as notification of a 2nd Submittal we have received from Ellwood Land Holdings for a Comprehensive Plan Amendment for the Maricopa Solar and Storage 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 CPA2020002. Please let me know if you have any questions or concerns. 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 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: Adam Cannon (PND) To: Brady, Jeff Subject: FW: Case #: CPA2020002 Date: Monday, October 26, 2020 2:17:00 PM Attachments: image001.png image003.png image004.png Good afternoon Jeff, As per our conversation, I am sending you the hearing information should you like to participate. The Planning and Zoning Commission meeting will take place on Thursday, November 5, 2020 at 9:30 a.m. The Board of Supervisors (BOS) meeting will take place on Wednesday, December 9, 2020 at 9:30 a.m. Attendance at the hearings shall be online/telephonic only. Instructions on attendance and how to submit questions/comments may be found at: www.maricopa.gov/797 one week prior to the hearing date. Please check www.maricopa.gov/agendacenter/ to view the agenda when it becomes available the week prior to the hearing. 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: Brady, Jeff <Jeff.Brady@naes.com> Sent: Monday, October 26, 2020 1:21 PM To: Adam Cannon (PND) <Adam.Cannon@maricopa.gov> Subject: Case #: CPA2020002 Dear Mr. Cannon, With regard to the P& Z meeting scheduled for November 5, 2020, I would like to ask a question about the intent of the solar company to provide funds for ecological restoration in the event of financial closure or end of life of such facility. The desert is a fragile environmant and I would request that any permits allocated to build a solar project also include the amount of predeposited funds to recalim the land and the surronding environment once the use is no longer be utilized for this intent. Jeff Brady Tonopah, AZ 85354 Main (623)748-1229 Cell 520.224.8006 USN Veteran Email Jeff.Brady@NAES.com