CPA2020002 BOS REPORT.PDF

Maricopa County — Formal (2020-12-09)

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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
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Path: X:\Projects\2019 Projects\1420192020 Maricopa Solar Plus Storage Project\MXD\CPA_Filing\Final\LAND EXHI\Figure1_LandUseExhibit_11x17.mxd
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85
Site Location
Tonopah
Palo Verde
NGS
Buckeye
Glendale
Peoria
Phoenix
£
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Site Vicinity
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1.25
2.5
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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
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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
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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