Z2019121 BOS REPORT.PDF

Maricopa County — Formal (2021-09-01)

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September 1, 2021 
Z2019121 
Page 1 of 4 
Report to the Board of Supervisors 
Prepared by the Maricopa County Planning and Development Department 



Board Hearing Date: 
September 1, 2021
Case #/Title:   
 
 
Z2019121 – RE Papago Solar Photovoltaic Power and Energy 
Storage Project
Supervisor Districts: 
4 & 5 
Applicant/Owners:  
RE Papago LLC / Multiple  
Request: 
 
Zone Change from Rural-43 to IND-2 IUPD 
Site Location: 
Generally located between I-10 on the north, Courthouse Rd. 
on the south, 483rd Ave. alignment on the west, and approx. 
2,855’ NE of the intersection of 459th Ave. alignment and 
Salome Hwy. on the east
Site Size: 
Approx. 2,806 acres 
County Island Status: 
No 
Additional
Comments:
The applicant is seeking a Zone Change with Overlay from 
Rural-43 to IND-2 IUPD for the development of a utility-scale 
solar development that will generate approximately 300 
megawatts (MWs) of electricity along with 1200 MWhs of 
battery storage. There is no known public support or 
opposition to the request.  The Arizona Game and Fish 
Department submitted standard comments related to 
protection of local species such as the burrowing owl to be 
addressed at the time of construction permitting.  The City of 
Buckeye had no comments on the request.  As the site abuts 
I-10, Staff routed the proposal to ADOT.  ADOT had no 
comments on the request. 


September 1, 2021 
Z2019121 
Page 2 of 4 
Commission
Recommendation:
On 8/5/21, the Commission voted 7-0 to recommend
approval of Z2019121 subject to conditions ‘a’ – ‘i’:
a.
The initial Plan of Development shall be developed in substantial conformance 
with the Site Plan entitled “RE Papago Solar Photovoltaic Power and Energy 
Storage Project” consisting of 32 full-size sheets, dated June 15, 2021, and stamped 
received July 7, 2021, except that a revised site plan shall be submitted within 30 
days of Board approval that reflects compliance with condition ‘d.4.” as it pertains 
to maximum lot coverage. 
b.
Development of the site shall be in substantial conformance with the Narrative 
Report entitled “Zone Change Narrative”, consisting of 22 pages, dated July 6, 
2021, and stamped received July 6, 2021 except as modified by the following 
conditions except that a revised narrative shall be submitted within 30 days of 
Board approval that reflects compliance with condition ‘d.4.” as it pertains to 
maximum lot coverage.
c.
The following Planning Engineering conditions shall apply: 
1.
Drainage Waiver case DRB2021005 must be approved prior to issuance of 
building permits. 
2.
Detailed Grading and Drainage Plans showing the new site improvements 
must be submitted for the acquisition of building permits. On-site (solar field & 
substation) areas must be designed in such a manner so that flows are 
directed to retention basin(s). Basin overflows must be directed to well-
defined drainage corridors, to the maximum extent possible. 
3.
Owner  or  owner’s  agent  shall  be  responsible  for  identifying  and  procuring 
any permit(s) for disturbance of, or work within delineated jurisdictional 
(Section 404) washes. 
4.
Sizing of the basin spillways must be determined based on the peak 
unattenuated flow rate, based on the proposed site condition, using either 
the Rational Method or DDMSW. Where the retention areas will be comingled 
with offsite flows, the offsite flows must be included in the discharge rate. 
5.
As part of the final design, channelized flow may be required to be dissipated 
(spread) at their outflow locations to match existing downstream conditions. 
6.
Drainage review of planning and/or zoning cases is for conceptual design 
only and does not represent final design approval nor shall it entitle 
applicants to future designs that are not in conformance with Section 1205 
of the Maricopa County Zoning Ordinance and the Maricopa County 
Drainage Policies and Standards. All development and engineering design 
shall be in conformance with Section 1205 of the Maricopa County Zoning 
Ordinance and current engineering policies, standards and best practices 
at the time of application for construction.

September 1, 2021 
Z2019121 
Page 3 of 4 
7.
Any disturbance to Special Flood Hazard Areas (floodplains) will require 
that a Floodplain Use Permit be issued concurrent with the associated 
building permit. 
8.
Pads for inverters, other electrical equipment, and any buildings within a 
Floodplain must be elevated to the regulatory flood elevation or otherwise 
designed to meet the requirements of the Floodplain Use Regulations. All 
development and engineering design shall be in conformance with the 
most current version of the Floodplain Use Regulations for Maricopa 
County.
9.
Project improvements (i.e. electric lines) within and immediately adjacent 
to District owned properties require a Right-of-Way Permit from the Flood 
Control District. 
10.
Future 
right-of-way 
needs, 
dedication, 
preservation, 
and 
offsite 
improvements, shall be addressed during site plan and/or building permit 
review, with the submittal of a traffic impact study, prior to any approvals. 
11.
Driveway accesses to paved MCDOT right-of-ways must be paved for the full 
width of the right-of-way. 
d.
The following IND-2 IUPD Zoning District standards shall apply: 
1. Maximum Electric Transmission Line Height – 140’ 
2. Minimum Side Yard – 0’ 
3. Minimum Rear Yard – 0’  
4. Maximum Lot Coverage – 60% 
5. Parking Spaces Required – None required with a Maricopa County Air Quality 
Department approved dust control plan. High curb and/or bumper guards not 
required. 
6. Landscaping – No landscaping areas required 
7. Sight Visibility Triangles – No sight visibility triangles are required at project site 
entry/access points and road intersection, section line, mid-section line or 
alignment corners 
8. Article 902.91 – All utility uses shall be permitted to be conducted outdoors 
9. Site Enclosure and Screening – 6’ chain-link fencing with 1’ of barbed wire 
permitted
e.
The Owner or Developer shall address and respond to all recommendations of the 
Arizona Game and Fish Department (AZGFD) included in the letter dated May 26, 
2021 at the time of construction permitting.  The response shall be sent to AZGFD 
for review and consideration.  The Zoning Inspector and/or their designee shall 
review the applicant’s response, and any subsequent comments received from 
AZGFD, to determine whether the response issued by the Owner or Developer 
addresses AZGFD comments in good faith.  Should the Zoning Inspector and/or 
their designee decide that the Owner or Developer has not substantially 
addressed AZGFD comments in good faith, the Owner or Developer shall be 
required to propose and implement alternatives to the recommendations made 
by AZGFD.

September 1, 2021 
Z2019121 
Page 4 of 4 
f.
The IND-2 IUPD shall limit the use of the site exclusively to a solar electric generating 
facility including ancillary offices and ancillary uses.  All other site uses shall require 
a Zone Change Major Amendment.   
g.
Noncompliance with any Maricopa County Regulation shall be grounds for 
initiating a revocation of this Zone Change as set forth in the Maricopa County 
Zoning Ordinance.
h.
The property owner/s and their successors waive claim for diminution in value if 
the County takes action to rescind approval due to noncompliance with 
conditions.
i.
The granting of this change in use of the property has been at the request of the 
applicant, with the consent of the landowner.  The granting of this approval allows 
the property to enjoy uses in excess of those permitted by the zoning existing on 
the date of application, subject to conditions.  In the event of the failure to comply 
with any condition, and at the time of expiration of the Zone Change, the property 
shall revert to the zoning that existed on the date of application.  It is, therefore, 
stipulated and agreed that either revocation due to the failure to comply with any 
conditions, or the expiration of the Zone Change, does not reduce any rights that 
existed on the date of application to use, divide, sell or possess the property and 
that there would be no diminution in value of the property from the value it held 
on the date of application due to such revocation or expiration of the Special Use 
Permit.  The Zone Change enhances the value of the property above its value as 
of the date the Zone Change is granted and reverting to the prior zoning results in 
the same value of the property as if the Zone Change had never been granted. 
Presented by: 
 
Adam Cannon, Planner 
Reviewed by: 
 
Darren Gerard, AICP, Planning Manager   
Attachments: 
 
8/5/21 P&Z Packet (77 pages) 
Note: 
8/5/21 Draft P&Z Minutes are not available as of the writing of this report, but can be 
provided upon request later when available.

Z2019121 
Page 1 of 11 
Report to the Planning and Zoning Commission 
Prepared by the Maricopa County Planning and Development Department
Case:
Z2019121 – RE Papago Solar Photovoltaic Power and Energy Storage 
Project 
 
 
 
 
 
Hearing Date: 
August 5, 2021
Supervisor Districts: 
4 & 5
Applicant:
RE Papago LLC 
Owners: 
Multiple 
Request: 
Zone Change from Rural-43 to IND-2 IUPD 
 
  
 
Site Location: 
Generally located between I-10 on the north, Courthouse Rd. on the 
south, 483rd Ave. alignment on the west, and approx. 2,855’ NE of 
the intersection of 459th Ave. alignment and Salome Hwy. on the 
east
Site Size: 
Approx. 2,806 acres 
Density:
N/A 
County Island:  
No 
County Plans: 
Tonopah Arlington Area Plan - Utilities & Maricopa County Vision 
2030 Comprehensive Plan - Utilities 
Municipal Plan: 
N/A 
Municipal Comments: 
City of Buckeye – No Concerns 
Support/Opposition: 
No known support or opposition 
Recommendation: 
Approve with conditions

Z2019121 
Page 2 of 11 
Project Summary: 
1.
RE Papago LLC is requesting a Zone Change from Rural-43 to IND-2 IUPD with a Plan of 
Development for a utility-scale solar development project generating approximately 300 
megawatts (MWs) of electricity along with 1,200 megawatt hours (MWhs) of battery 
storage.  The subject property is designated as a Utilities land use in the Tonopah-Arlington 
Area Plan and Maricopa County Vision 2030 Comprehensive Plan following two Major 
Comprehensive Plan Amendments approved by the Board of Supervisors on December 
11, 2019 and January 20, 2020 respectively. 
2.
The site is comprised of approximately 2,806 acres of thirty-six (36) privately owned 
parcels. The site is not contiguous as the southern and northern portions of the site are 
separated by land owned by the Flood Control District of Maricopa County (FCD).  The 
applicant submitted applications from the owners authorizing the request for the zone 
change.  It is anticipated that the parcels will be merged prior to construction 
permitting.  The applicant is proposing a construction period of 18 to 36 months 
beginning in Quarter 3 of 2022.  Most properties in the immediate vicinity of the project, 
with the exception of the aforementioned land owned by FCD, are privately owned. 
3.
Nearly all land used for solar energy projects like this are developed for the large fields 
of solar collectors that capture the energy through photovoltaic technology. The 
subject site is relatively flat and allows for the development of solar energy with little or 
no additional grading. Washes are present on site and the applicant has committed to 
avoiding washes in conjunction with agency comments.  In addition, the general area 
contains significant local electrical infrastructure including power generation facilities 
(nuclear, gas, and solar), transmission lines, substations, and switchyards.  The project’s 
gen-tie line will transmit power from the project’s substation to APS Delaney Substation. 
4.
The subject site is currently zoned Rural-43.  The applicant is requesting to change the 
zone to IND-2 IUPD.  The base IND-2 zone and requested zoning standards for the IND-2 
IUPD district are listed below: 


Z2019121 
Page 3 of 11 
REGULATION 
BASE ZONING DISTRICT 
REGULATIONS (IND-2) 
PROPOSED ZONING REGULATIONS 
(IND-2 IUPD) 
Max. Height  
40’ 
40’ 
Max. Electric 
Transmission Line 
Height
120’ 
140’ 
Min. Front Yard 
10’ – 25’ 
10’ – 25’ 
Min. Side Yard 
3’ - 10’ 
0’
Min. Rear Yard 
25’ 
0’
Min. Lot Area 
6,000 sq. ft. 
6,000 sq. ft. 
Min. Lot Width 
60’ 
60’ 
Max. Lot Coverage 
60% 
60%
Parking Spaces 
Required
1 per 250 sq. ft. of floor area 
None required with a Maricopa 
County Air Quality Control 
approved dust control plan. High 
curb and/or bumper guard not 
required.
Landscaping
Article 901.4.1: All properties 
abutting a public street shall 
have an open setback area 
which shall be landscaped 
extending for the full width of 
the property 
No landscaping strip required 
Screening
A solid masonry wall not less 
than six feet in height shall be 
required along and adjacent to 
any side or rear property line 
abutting any rural or residential 
zone boundary, or any alley 
abutting such zone boundary. 
Further, any access gates shall 
be constructed of view-
obscuring material to provide 
effective site screening 
6’ minimum chain-link fencing 
(with 1’ of barbwire permitted) 
Sight Visibility 
Triangles
Required
Waive all SVT’s at project site 
entry/exit points and road 
intersection, section-line, mid-
section line or alignment corners 
Article 902.9.1 
All uses except for parking, 
loading, unloading or storage 
shall be conducted within a 
completely enclosed building 
Utility uses are permitted to be 
conducted outside of an 
enclosed building

Z2019121 
Page 4 of 11 
5.
It should be noted that since the applicant is proposing a site plan (required plan of 
development, POD) and although the zone change is a legislative approval, the POD is 
administratively approved. Therefore, POD approval is contingent upon prior rezoning 
approval.
6.
The applicant is requesting to vary setbacks (rear and side), parking spaces required, 
landscaping, sight visibility triangles, site enclosure and screening.  The proposed 
standards are consistent with other similar utility-scale solar facilities in this area of the 
County.
7.
The applicant is requesting to vary the rear and side setbacks to 0’.   
8.
The applicant is requesting to waive landscaping in order to preserve existing 
landscaping (natural desert vegetation).  For screening, the applicant has proposed 
chain-link with 1’ of barbed wire fencing in lieu of a 6’ CMU wall abutting rural or 
residential zoning.  Additionally, the applicant is requesting that site uses be permitted 
outside of an enclosed building as the nature of the use (solar panels) requires the use to 
be conducted outdoors to generate energy. 
9.
The applicant is also requesting to vary required site visibility triangles at all driveways and 
intersecting alignments.  The MCZO specifies that 25’x25’ sight visibility triangles are to be 
provided at the property line where all access points are present and at the corner of 
properties with an intersection.  Sight visibility triangles are unnecessary at alignments 
internal to the site.  Additionally, proposed fencing at the intersecting alignments and 
driveways will not include slats and thus visibility will not be obstructed.  Also, the applicant 
requested that there be no parking or loading spaces as no regularly occupied buildings 
will be placed on site.   


Z2019121 
Page 5 of 11 
Exhibit 1 – 2018 Aerial Map (More Recent Map Not Available) 
Exhibit 2 – Rural-43 Zoning District and Surrounding Zoning Districts

Z2019121 
Page 6 of 11 
Exhibit 3 – Site Plan Excerpt 
Exhibit 4 – Solar Panel Exhibit 


Z2019121 
Page 7 of 11 
Existing On-Site and Adjacent Zoning / Land Use: 
10.
On-site: 
 
Rural-43 / Vacant/Agricultural 
North: 
Rural-43 / Vacant/Agricultural  
South: 
Rural-43 / Vacant/Agricultural 
East: 
Rural-43 & Rural-43 SUP/ Vacant/Agricultural/Industrial (APS Delaney 
 
Substation) 
West: 
Rural-43 / Vacant/Agricultural  
Utilities and Services: 
11.
Water: 
 
Private Well or Hauled Water 
Wastewater: 
Septic 
Electric: 
APS 
School Districts: 
Arlington Valley Elementary School District #47  
 
Buckeye Union High School District #1 
Fire: 
Harquahala Fire District 
Police:  
MCSO 
Solid Waste: 
Republic Services 
Right-of-Way: 
12.
The following table includes existing and proposed half-width right-of-way and the future 
classification based upon the Maricopa County Department of Transportation (MCDOT) 
Major Streets and Routes Plan.  
Street Name 
Existing R/W 
Proposed R/W* 
Future Classification* 
Salome Hwy 
Varies 
130’ (full) 
Minor Arterial 
Indian School Rd 
Varies 
130’ (full) 
Minor Arterial 
Courthouse Rd 
Varies 
65’ (half) 
Minor Arterial 
Indian School Rd (W 
of Salome Hwy 
Varies 
130’ (full) 
Minor Arterial 
483rd Ave 
Varies 
65’ (half) 
Minor Arterial 
Campbell Ave 
Varies 
40’ (half) 
Minor Collector 
475th Ave 
Varies 
65’ (half) 
Minor Arterial 
467th Ave 
Varies 
130’ (full) 
Minor Arterial 
459th Ave 
Varies 
130’ (full) 
Minor Arterial 
471st Ave 
Varies 
80’ (full) 
Minor Collector 
*Right-of-way dedications and preservations will be addressed at the time of 
construction permitting. 
Adopted Plans: 
13.
Maricopa County Vision 2030 Comprehensive Plan & Tonopah/Arlington Area Plan: The 
site is designated as Utilities.  The Utilities designation is for electric generating plants, 
water, and wastewater treatment facilities, associated offices and accessory 
equipment.  Under a Utilities designation, the appropriate zoning district is IND-2.

Z2019121 
Page 8 of 11 
Public Participation Summary: 
14.
The applicant complied with the Maricopa County Citizen Review Process with the 
required posting of the site and notification by first class mail to adjacent property owners 
within 300’ of the subject parcel and interested parties.  The applicant submitted a Public 
Participation Results Report.
15.
According to the Public Participation Results Report, the applicant received 20 inquiries 
from residents and interested parties about the proposed zone change.  A majority of 
the inquiries were information requests or requests for the applicant to purchase property.  
16.
The applicant conducted an open house meeting during the Comprehensive Plan 
Amendment public outreach period on August 21, 2019.  The applicant elected to not 
hold a follow-up meeting for the Zone Change public outreach period as the applicant 
felt the prior meeting was sufficient to address concerns.  There were 5 citizen attendees 
not including staff of the applicant.   
17.
The applicant received general questions during door-to-door outreach related to view, 
property values, construction impacts, construction noise and the potential for increased 
population.  The applicant included a summary of their citizen contacts and the manner 
in which they responded to those questions. 
18.
The Arizona Game and Fish Department submitted standard comments related to 
protection of local species such as the burrowing owl to be addressed at the time of 
construction permitting.  
19.
There is no known opposition or support for the proposed zone change.   
Outstanding Concerns from Reviewing Agencies: 
20.
N/A 
Staff Analysis: 
21.
The state and Maricopa County recognize the potential environmental and economic 
benefits that solar technology can provide.  The RE Papago Solar Photovoltaic Power 
and Energy Storage Project  will use photovoltaic technology that generates energy from 
sun absorption.  Photovoltaic technology differs from other models of solar electric 
generation that require vast amounts of water to cool the units.  In contrast, very little 
water is utilized for photovoltaic technology.  As a result, this development would not 
pose a threat to groundwater depletion.   
22.
Staff believes the proposed solar facility is well suited to this rural area, which requires 
large amounts of relatively flat land.  The majority of the land is flat.  Staff agrees with the 
applicant that the subject site is suitable due to proximity to electrical transmission lines, 
nearby stations and substations, and because the surrounding area is vastly 
undeveloped.  Staff agrees with the applicant that the project will not detrimentally 
affect the visual quality of the area.

Z2019121 
Page 9 of 11 
23.
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 RE Papago Solar Photovoltaic Power and Energy 
Storage Project would add to this effort in a positive way by providing the potential for 
500 temporary construction and operation/maintenance jobs.  There may also be a small 
number of long-term employment opportunities for County residents. 
Recommendation:
24.
For the reasons outlined in this report, staff recommends the Commission motion for 
Approval, subject to conditions ‘a’ – ‘i’. 
a.
The initial Plan of Development shall be developed in substantial conformance 
with the Site Plan entitled “RE Papago Solar Photovoltaic Power and Energy 
Storage Project” consisting of 32 full-size sheets, dated June 15, 2021, and stamped 
received July 7, 2021, except that a revised site plan shall be submitted within 30 
days of Board approval that reflects compliance with condition ‘d.4.” as it pertains 
to maximum lot coverage. 
b.
Development of the site shall be in substantial conformance with the Narrative 
Report entitled “Zone Change Narrative”, consisting of 22 pages, dated July 6, 
2021, and stamped received July 6, 2021 except as modified by the following 
conditions except that a revised narrative shall be submitted within 30 days of 
Board approval that reflects compliance with condition ‘d.4.” as it pertains to 
maximum lot coverage.
c.
The following Planning Engineering conditions shall apply: 
1.
Drainage Waiver case DRB2021005 must be approved prior to issuance of 
building permits. 
2.
Detailed Grading and Drainage Plans showing the new site improvements 
must be submitted for the acquisition of building permits. On-site (solar field 
& substation) areas must be designed in such a manner so that flows are 
directed to retention basin(s). Basin overflows must be directed to well-
defined drainage corridors, to the maximum extent possible. 
3.
Owner  or  owner’s  agent  shall  be  responsible  for  identifying  and  
procuring any permit(s) for disturbance of, or work within delineated 
jurisdictional (Section 404) washes. 
4.
Sizing of the basin spillways must be determined based on the peak 
unattenuated flow rate, based on the proposed site condition, using either 
the Rational Method or DDMSW. Where the retention areas will be 
comingled with offsite flows, the offsite flows must be included in the 
discharge rate. 
5.
As part of the final design, channelized flow may be required to be 
dissipated (spread) at their outflow locations to match existing 
downstream conditions.

Z2019121 
Page 10 of 11 
6.
Drainage review of planning and/or zoning cases is for conceptual design 
only and does not represent final design approval nor shall it entitle 
applicants to future designs that are not in conformance with Section 1205 
of the Maricopa County Zoning Ordinance and the Maricopa County 
Drainage Policies and Standards. All development and engineering design 
shall be in conformance with Section 1205 of the Maricopa County Zoning 
Ordinance and current engineering policies, standards and best practices 
at the time of application for construction. 
7.
Any disturbance to Special Flood Hazard Areas (floodplains) will require 
that a Floodplain Use Permit be issued concurrent with the associated 
building permit. 
8.
Pads for inverters, other electrical equipment, and any buildings within a 
Floodplain must be elevated to the regulatory flood elevation or otherwise 
designed to meet the requirements of the Floodplain Use Regulations. All 
development and engineering design shall be in conformance with the 
most current version of the Floodplain Use Regulations for Maricopa 
County.
9.
Project improvements (i.e. electric lines) within and immediately adjacent 
to District owned properties require a Right-of-Way Permit from the Flood 
Control District. 
10.
Future 
right-of-way 
needs, 
dedication, 
preservation, 
and 
offsite 
improvements, shall be addressed during site plan and/or building permit 
review, with the submittal of a traffic impact study, prior to any approvals. 
11.
Driveway accesses to paved MCDOT right-of-ways must be paved for the 
full width of the right-of-way. 
d.
The following IND-2 IUPD Zoning District standards shall apply: 
1. Maximum Electric Transmission Line Height – 140’ 
2. Minimum Side Yard – 0’ 
3. Minimum Rear Yard – 0’  
4. Maximum Lot Coverage – 60% 
5. Parking Spaces Required – None required with a Maricopa County Air Quality 
Department approved dust control plan. High curb and/or bumper guards not 
required. 
6. Landscaping – No landscaping areas required 
7. Sight Visibility Triangles – No sight visibility triangles are required at project site 
entry/access points and road intersection, section line, mid-section line or 
alignment corners 
8. Article 902.91 – All utility uses shall be permitted to be conducted outdoors 
9. Site Enclosure and Screening – 6’ chain-link fencing with 1’ of barbed wire 
permitted

Z2019121 
Page 11 of 11 
e.
The Owner or Developer shall address and respond to all recommendations of the 
Arizona Game and Fish Department (AZGFD) included in the letter dated May 26, 
2021 at the time of construction permitting.  The response shall be sent to AZGFD 
for review and consideration.  The Zoning Inspector and/or their designee shall 
review the applicant’s response, and any subsequent comments received from 
AZGFD, to determine whether the response issued by the Owner or Developer 
addresses AZGFD comments in good faith.  Should the Zoning Inspector and/or 
their designee decide that the Owner or Developer has not substantially 
addressed AZGFD comments in good faith, the Owner or Developer shall be 
required to propose and implement alternatives to the recommendations made 
by AZGFD. 
f.
The IND-2 IUPD shall limit the use of the site exclusively to a solar electric generating 
facility including ancillary offices and ancillary uses.  All other site uses shall require 
a Zone Change Major Amendment.   
g.
Noncompliance with any Maricopa County Regulation shall be grounds for 
initiating a revocation of this Zone Change as set forth in the Maricopa County 
Zoning Ordinance.
h.
The property owner/s and their successors waive claim for diminution in value if 
the County takes action to rescind approval due to noncompliance with 
conditions.
i.
The granting of this change in use of the property has been at the request of the 
applicant, with the consent of the landowner.  The granting of this approval allows 
the property to enjoy uses in excess of those permitted by the zoning existing on 
the date of application, subject to conditions.  In the event of the failure to comply 
with any condition, and at the time of expiration of the Zone Change, the property 
shall revert to the zoning that existed on the date of application.  It is, therefore, 
stipulated and agreed that either revocation due to the failure to comply with any 
conditions, or the expiration of the Zone Change, does not reduce any rights that 
existed on the date of application to use, divide, sell or possess the property and 
that there would be no diminution in value of the property from the value it held 
on the date of application due to such revocation or expiration of the Special Use 
Permit.  The Zone Change enhances the value of the property above its value as 
of the date the Zone Change is granted and reverting to the prior zoning results in 
the same value of the property as if the Zone Change had never been granted. 
Presented by: 
 
 
Adam Cannon, Planner 
Reviewed by: 
Matthew Holm, AICP, Planning Supervisor 
Attachments:
Case Map (1 page) 
 
Site Plan (reduced 8.5”x11”, 32 pages) 
 
Narrative Report (22 pages) 
 
Engineering Comments (2 pages) 
 
MCESD comments (1 page) 
 
City of Buckeye Comments (2 pages) 
 
AZGFD Comments (3 pages) 
 
ADOT ROW Project Management Comments (3 pages)

MARICOPA COUNTY
/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 2800 approx.
Generated July 26, 2021 15:16 PM
Z2019121
Application Name:
Legal Description
RE Papago Solar Photovoltaic Power and Energy Storage Project
Applicant
Case Address
T02N R08W 028,
CHRISTY HERRON for RE PAPAGO LLC
Applicant Phone/Email
Parcel Primary:506-30-012D
415.501.9418
CHRISTY.HERRON@RECURRENTENERGY.COM
Map scale 1:45,651
Supervisor District No.
506-30-009C,  506-30-009D,  506-30-010+
REQUEST FOR A ZONE CHANGE WITH OVERLAY
5.3585 in

22
15
14
13
12
23
24
19
27
26
30
21
16
28
31
36
35
34
33
SALOME HWY
(GRAVEL)
INDIAN SCHOOL RD
              (GRAVEL)
RANGE 8 WEST
RANGE 7 WEST
W. COURTHOUSE RD
              (PAVED)
20
17
29
32
TOWNSHIP 2 NORTH
TOWNSHIP 1 NORTH
25
FEMA FLOOD
ZONE A
VICINITY MAP
RE PAPAGO SOLAR PV POWER
AND ENERGY STORAGE PROJECT
(CASE # Z2019121)
Located in a portion of Township 2 North, Range 8 West of the Gila and Salt River Base and Meridian, Maricopa County, Arizona

22
SALOME HWY
(GRAVEL)
INDIAN SCHOOL RD (GRAVEL)
15
14
13
23
24
27
26
21
16
28
36
35
34
33
W. COURTHOUSE RD (PAVED)
NAP
NAP
NAP
NAP
NAP
NAP
25
CAMPBELL AVE
467TH AVE
459TH AVE
483RD AVE
PAPAGO FWY (INTERSTATE 10)

22
SALOME HWY
(GRAVEL)
INDIAN SCHOOL RD (GRAVEL)
15
14
13
23
24
27
26
21
16
28
36
35
34
33
W. COURTHOUSE RD (PAVED)
NAP
NAP
NAP
NAP
NAP
NAP
25
CAMPBELL AVE
467TH AVE
459TH AVE
483RD AVE
PAPAGO FWY (INTERSTATE 10)

NAP
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

NAP
NAP
NAP
*
*
*
*
*
*
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

NAP
NAP
*
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

NAP
NAP
NAP
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

NA
NA
NAP
NAP
*
*
*
*
*
*
*
*
*
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

NAP
NAP
NAP
*
*
*
*
*
*
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

*
*
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

*
*
*
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

*
*
*
*
*
KEY MAP
SHEET
C2.7
SHEET
C2.3
SHEET
C2.0
SHEET
C2.6
SHEET
C2.1
SHEET
C2.4
SHEET
C2.5
SHEET
C2.8
SHEET
C2.2
*

EXISTING GRAVEL ROADWAY
NOTES:
ROCK CONSTRUCTION ENTRANCE SHOULD CONTAIN MAXIMUM SIDE SLOPES OF 4:1.
ROCK ENTRANCE SHOULD BE INSPECTED AND MAINTAINED REGULARLY. ROCK
ENTRANCE LENGTH MAY NEED TO BE EXTENDED IN CLAY SOILS.
12' MINIMUM WIDTH
50' MINIMUM LENGTH
45' RADIUS (TYP.)
MIRAFI HP270 GEOTEXTILE OR
APPROVED EQUAL (AS NEEDED)
1" - 3" WELL-GRADED WASHED ROCK
12" MINIMUM DEPTH
SET ROCK ENTRANCE BACK FROM
PAVED ROAD
SEE SHEET DETAIL 3 BELOW

18.00'
8.00'
11.00'
5.00'
VAN ACCESSIBLE
PARKING SPACE
STANDARD ACCESSIBLE PARKING
SPACE

8' WIDE BERM
SEE PLANS FOR ELEVATION
4:1 SIDE SLOPES
WATER RETENTION AREA
BERM PLAN AT OUTLET
1' POND/BASIN
CONTOURS
INSTALL RIP-RAP DOWN TO
THE EXISTING GROUND TIE-IN
FILTER FABRIC
TOP OF BERM ELEVATION
WATER
RETENTION
AREA
EXISTING
GROUND
RIP-RAP D50=9"
FILTER FABRIC
BERM OUTLET
SECTION VIEW
OUTLET PROFILE
OUTLET ELEVATION
BASIN PROFILE
8'
VARIES SEE TABLE
NOTES:
1.     RIP-RAP TO BE D50=9”, CONFORMING TO ADOT SPECIFICATION 913
FOR MATERIAL AND CONSTRUCTION METHODS
RIP-RAP D50=9"
VARIES SEE TABLE
LEVEL SPREADER
L=MINIMUM 10'
4
1
EXISTING
GRADE
EXISTING
GRADE
1
4
D = TBD
COMPACTED GRADE, DITCH
BOTTOM AND SLOPES
W = TBD

ZONE CHANGE NARRATIVE 
RE Papago Photovoltaic Solar Energy Generation 
and Storage Project 
Maricopa County Planning and Development Department 
Z2019121 
Zone Change with Industrial Overlay 
-XO\, 2021

RE Papago Photovoltaic Solar  Energy Generation and Storage Project  
Zone Change with Industrial Overlay Narrative 
page i 
TABLE OF CONTENTS 
1.0  Title Page ........................................................................................................................................................ 1 
1.1  General Location ................................................................................................................................. 1 
2.0  Purpose Of Request ........................................................................................................................................ 2 
3.0  Description Of Proposal ................................................................................................................................. 2 
3.1  Overview ............................................................................................................................................. 2 
3.2  Proposed Uses ..................................................................................................................................... 2 
3.3  Hours Of Operations ........................................................................................................................... 3 
3.4  Project Components ............................................................................................................................ 3 
3.5  Decommissioning And Site Reclamation .......................................................................................... 13 
4.0  Relationship To Surrounding Parcels ............................................................................................................. 14 
4.1  Project Site Parcels ............................................................................................................................ 14 
4.2  Surrounding Parcels .......................................................................................................................... 15 
4.3  Benefits To The Community And Surrounding Area ....................................................................... 15 
4.4  Recent Changes In The Area That Support The Application Request .............................................. 16 
5.0  Location And Accessibility .......................................................................................................................... 16 
5.1  Project Location ................................................................................................................................ 16 
5.2  Accessibility ...................................................................................................................................... 16 
6.0  Circulation System ....................................................................................................................................... 16 
6.1  On-Site .............................................................................................................................................. 16 
6.2  Off-Site .............................................................................................................................................. 17 
7.0  Development Schedule ................................................................................................................................. 17 
8.0  Community Facilities And Services ............................................................................................................. 17 
9.0  Public Utilities And Services ....................................................................................................................... 18 
10.0 Comparison Chart........................................................................................................................................ 19 
 
LIST OF FIGURES 
Figure 1 
Project Vicinity Map ..................................................................................................................... 1 
Figure 2 
Artistic rendering of the AC-coupled/centralized energy storage system option.......................... 7 
 
 
LIST OF TABLES 
Table 1 
Project Site Parcels ...................................................................................................................... 14 
Table 2 
RE Papago Solar Project: Utility Commitments ......................................................................... 18 
Table 3 
RE Papago Solar Project Unit Plan of Development: Proposed Zoning Regulations ................. 19

RE  Papago  Photovoltaic  Solar  Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 1 
 
1.0 TITLE PAGE 
Project Name: RE Papago Photovoltaic Solar Energy Generation and Storage Project 
Case/Tracking #: Z2019121 
 
1.1 
General Location 
The project site is located in the western region of unincorporated Maricopa County, south of Interstate 10 (I-
10) and approximately 5.5 miles west of the community of Tonopah, Arizona. 
 
Figure 1. Project Vicinity Map

RE  Papago  Photovoltaic  Solar  Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 2 
 
2.0 PURPOSE OF REQUEST 
RE Papago LLC, the project applicant, seeks a Zone Change with Overlay from Maricopa County to construct, 
operate, maintain, and eventually decommission a solar photovoltaic (PV) electricity-generating and energy 
storage facility and associated infrastructure collectively referred to as the RE Papago Photovoltaic Solar Energy 
Generation and Storage Project (project). The project as proposed would generate 300 megawatts (MW) of 
alternating current (AC) electricity and up to 1,200 megawatt-hours (MWh) of energy storage on approximately 
2,805.23 acres of privately owned land currently zoned as “RURAL-43” (Rural Zoning District—One Acre Per 
Dwelling Unit) in unincorporated Maricopa County, requiring a Zone Change with Overlay to change the zoning 
designation to IND-2 with an Industrial Unit Plan of Development (IUPD). 
 
3.0 DESCRIPTION OF PROPOSAL 
3.1 
Overview 
The proposed project would consist of the following development activities: 
x 
Site preparation, including mowing/removal of vegetation and grading (as necessary) 
x 
Installation of PV solar arrays, including approximately 1,396,000 PV modules, and steel support 
structures, transformers, and up to 93 electrical inverters 
x 
Installation of approximately 19,000 feet of both underground and overhead 34.5-kilovolt (kV) electric 
collection lines to connect the two non-contiguous parts of the project site, as well as to connect parts 
of the site to the project substation 
x 
Construction of one electrical substation and appurtenant equipment in the southeast portion of the site 
as shown on Sheet C3.2 of the Site Plan 
x 
Construction of a 500-kV generation intertie electric transmission line (gen-tie line) less than 0.3 mile 
in length consisting of metal transmission towers, conductors, insulators, optical fiber cables, and safety 
equipment which would connect (“tie-in”) to Arizona Public Service’s existing Delaney Substation 
adjacent to the project site to bring solar-generated power to the nearby regional electricity grid 
x 
Installation of an energy storage system at size up to 1,200 MWh, consisting of battery or flywheel 
enclosures and electrical cabling and appurtenant equipment. If batteries are selected, up to 360 battery 
containers would be installed 
x 
Construction of temporary and permanent project site perimeter fencing and access gates 
x 
Construction of temporary and permanent on-site access roads for construction and maintenance 
activities 
x 
Construction of other necessary infrastructure, including one permanent operation and maintenance 
(O&M) building, a supervisory control and data acquisition (SCADA) system, and a meteorological 
data system 
 
3.2 
Proposed Uses 
The project would be constructed to provide clean and efficient renewable energy to the regional electric grid. 
The project would generate up to 300 MW of AC electricity, and up to 1,200 MWh of energy storage. The project 
is compatible with nearby land uses as it is located adjacent to the Delaney Substation, multiple existing high 
voltage electric utility lines, as well as the likely corridor for the future Ten West Link high-voltage electric 
transmission line, proposed to be in service by 2021. Electricity produced from this project would provide clean 
energy for up to approximately 57,000 homes.

RE  Papago  Photovoltaic  Solar  Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 3 
 
3.3 
Hours of Operations 
Once operational, project solar generation would occur during daylight hours. During the longest days of the year, 
this would be from 5:30 am to 8:00 pm. With an energy storage system, stored electricity would also be 
transmitted to the grid at other times when needed. O&M activities would occur during the lifetime of the project 
and would include occasional cleaning of PV modules and replacement/repair of project equipment and 
components as needed. These activities would typically occur during normal daytime business hours between 
7:00 am and 5:00 pm. 
 
3.4 
Project Components 
Below is a description of the individual project components. 
 
3.4.1 
Preconstruction Activities and Site Preparation 
Preconstruction activities include surveying and staking for various project features such as driveways, array 
blocks, utility trenches, equipment pads, and support structures. Temporary work areas would also be laid out. 
 
Site preparation activities that occur prior to general construction include site clearing and grading, preparation 
of construction staging areas, and construction of the main internal driveways. 
 
3.4.1.1 
Clearing and Grading 
Prior to construction, the site would be cleared of vegetation and graded and compacted to the minimum extent 
needed. Site clearing and soil preparation would occur incrementally and would not commence until the area is 
needed for construction or equipment access. Vegetative cover would be retained for as long as possible, with 
overall ground disturbance minimized to the maximum extent practicable. 
 
Large areas of the site would undergo grading for the installation of drainage basins and related structures. Final 
grades would be designed to provide for positive drainage, as described in On-site Drainage Areas below (3.4.14). 
 
3.4.1.2 
Construction Staging Areas 
One or two main staging areas would be located within the site footprint and would likely be located in the 
northwest or southwest portions of the site. The staging area or areas would be used for construction offices, worker 
parking, a first-aid station, material and equipment storage and assembly, and a parking area for vehicles and 
equipment. Additional staging areas may be located throughout the site for temporary material storage and 
assembly during construction. The staging areas would encompass up to 10 acres and would be secured with an 
8-foot-high fence. As needed, temporary power would be provided via mobile generators or local distribution lines. 
 
3.4.1.3 
Temporary Roads and Driveways 
Temporary roads and driveways would be installed for use during construction; some of these roads and 
driveways would be established as permanent features prior to the start of project operation. Temporary driveway 
aprons to points of ingress/egress during construction may be up to 80 feet wide to accommodate construction 
traffic. 
 
3.4.2 
Permanent Project Site Entrances and Internal Roads 
The project’s on-site circulation would include project entrances and internal roads. Roads would be compacted, 
may include gravel or equivalent, and would be designed according to Maricopa County standards, rules, and 
guidance. Road construction would typically proceed as follows: the ground would be grubbed (cleared of 
vegetation), scarified (loosened), moisture conditioned, compacted, and graded with a crown in the center.

RE  Papago  Photovoltaic  Solar  Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 4 
 
Several agricultural canals cross the project site. During construction and operation of the solar facility, the bed 
and banks of the canals would be completely avoided and would remain outside of the project site fences. 
 
All roads would be constructed to be consistent with facility maintenance requirements and Maricopa County’s 
Rural Metro Fire Department (RMFD) standards, the standards of the Harquahala Fire District (HFD), and/or any 
other applicable standards. 
 
Any required road improvements would be developed in coordination with the Maricopa County Department of 
Transportation (MCDOT) and would be subject to MCDOT requirements, as well as all applicable requirements 
of the Maricopa County Air Quality Department, the Maricopa County Flood Control District (FCD), and the 
Maricopa County Planning and Development Department. 
 
3.4.3 
PV Modules and Support System 
Most of the project site would be occupied by solar PV modules and support structures. The ultimate decision for 
the module types and racking systems would depend on market conditions and environmental factors. Solar 
thermal technology is not being considered. 
 
Types of modules that may be installed include crystalline silicon (abbreviated as c-Si), amorphous silicon 
(abbreviated as a-Si), thin-film (including cadmium telluride [abbreviated as CdTe or “cad tel”] and copper indium 
gallium diselenide technologies [abbreviated as CIGS]), or any other commercially available PV technology. 
Module mounting systems that may be installed are likely to include tracking technology but could be fixed tilt 
depending on the PV modules ultimately selected. Multiple types of modules and racking systems may be installed 
across the site. 
 
The PV modules would be manufactured at an off-site location and transported to the project site. Module faces 
would be minimally reflective, dark in color, and highly absorptive. 
 
Modules would be arranged on-site in long strings called rows. For single-axis tracking systems, the length of each 
row of modules would be approximately 300 feet along the north/south axis. For fixed-tilt systems, a row consists 
of multiple tables (4 modules high by 10 modules wide, depending on design), each table approximately 65 feet 
along the east/west axis, with 1-foot spacing between each table. Spacing between each row would be a minimum 
of 14 feet. The solar module arrays would generate electricity directly from sunlight, and electricity would be 
collected to a single point at the project substation. 
 
Structures supporting the PV modules would consist of steel piles (e.g., cylindrical pipes, H-beams, or similar). 
Tracking arrays would be oriented along a north-south axis, with modules tracking east to west to follow the 
movement of the sun. Fixed-tilt arrays would be oriented along an east-west axis, with modules facing generally 
south. The total height of the module system measured from ground surface would be up to 12 feet. For fixed-tilt 
systems, the modules would be fixed at an approximate 20- to 60-degree angle or as otherwise determined 
necessary during final project design. Details in Sheet C3.0 of the Site Plan show typical elevation drawings of 
solar panels and tracking systems. 
 
Where excavations are required, the majority of proposed construction activities would be limited to less than 6 
feet in depth; however, some excavations, such as those undertaken for the installation of electricity collection 
poles and dead-end structures, may reach depths of 20 feet or more. 
 
3.4.3.1 
Solar PV System Installation 
Prior to the installation of solar arrays, the perimeter of each project area would be securely fenced and gated to 
prevent unauthorized access. Perimeter fencing would consist of 6-foot-high chain-link galvanized metal fence 
topped by 3 strands of barbed wire approximately 1 foot high. Fence posts would be spaced approximately 10 
feet apart, drilled and grouted or driven pneumatically into the soil profile up to an estimated 5 feet deep.

RE  Papago  Photovoltaic  Solar  Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 5 
 
 
Construction of the solar arrays would begin with installation of the steel piles (e.g., cylindrical pipes, H-beams, 
or similar), which would be driven into the soil using pneumatic techniques, similar to a hydraulic rock hammer 
attachment on the boom of a rubber-tired backhoe excavator. The piles would typically be spaced 10 feet apart. 
For a single-axis tracking system, piles typically would be installed to a reveal height of approximately 4 feet 
above grade, while for a fixed-tilt system the reveal height would vary based on the racking configuration specified 
in the final design. For some single-axis tracking systems and for all fixed- tilt systems, a galvanized metal racking 
system, which secures the PV modules to the installed foundations, would then be field-assembled and attached 
according to the manufacturer’s guidelines. 
 
Modules would be electrically connected into module strings using wiring secured to the module racking system. 
Underground cables, either rated for direct bury or installed inside a polyvinyl chloride (PVC) conduit, would 
convey the DC electricity from the modules via combiner boxes located throughout the PV arrays to inverters to 
convert the DC power to AC. The output voltage of the inverters would be stepped up to 34.5 kV, the collection 
system voltage, via transformers located in close proximity to the inverters. 
 
3.4.4 
Electric (34.5-kV) Collection Lines 
The 34.5-kV collection cables would be buried underground or installed overhead on wood poles typically 50 feet 
tall and up to 70 feet tall at up to 250-foot intervals. Pole diameters would typically be 12 to 14 inches. 
Underground collection line cables to connect arrays would be installed using ordinary trenching techniques, 
which typically include a rubber-tired backhoe excavator or trencher. Wire depths would be in accordance with 
local, state, and federal requirements and would likely be buried at a minimum of 18 inches below grade by 
excavating a trench approximately 3 to 6 feet wide to accommodate the conduits or direct buried cables. After 
excavation, cable rated for direct burial or cables installed inside a PVC conduit would be installed in the trench, 
and the excavated soil would likely be used to fill the trench and lightly compressed. All cabling excavations 
would be to a maximum depth of 10 feet. 
 
If parcels comprising the project site are not located contiguous to one another, the applicant will secure easements 
on adjacent land (outside of the public right-of-way [ROW]) for the installation of collection lines as needed. The 
applicant intends to apply for an easement and ROW permit to accommodate 34.5-kV collection lines across 
property owned by the FCD of Maricopa County in order to connect two non-contiguous areas of the project site. 
Final design will be determined upon detailed engineering and consultation with the FCD, but the collection lines 
are preliminarily anticipated to consist of two (2) parallel double-circuit pole lines. Each set of poles would hold 
two circuits consisting of three vertically stacked 34.5-kV cables on each side of the pole, along with one grounding 
wire along the top of the poles. The poles are anticipated to have a height of between 65 and 80 feet depending 
upon clearances required by the FCD as the lines cross the Saddleback Flood Retarding Structure. 
 
3.4.5 
Inverters and Transformers 
The project would be designed and laid out in approximately 2-MW increments, which would include an inverter 
equipment area measuring either approximately 40 feet by 25 feet (in the event that the energy storage system is 
AC coupled) or approximately twice this size (in the event that the energy storage system is DC coupled). Up to 
93 inverters would be installed. Each 2-MW increment would include an inverter-transformer station constructed 
on a concrete pad or steel skid and centrally located within the PV arrays. Each inverter-transformer station would 
contain a DC combiner (which would collect DC electrical power from the PV modules), up to 4 inverters, a 
transformer, an auxiliary power transformer, an energy storage enclosure (in the event of DC-coupled energy 
storage), and a switchboard approximately 8 to 11 feet high. Refer to Sheet C3.4 of the Site Plan for a typical 
inverter-transformer station. 
 
All electrical inverters and transformers would be placed on concrete foundation structures or steel skids. In lieu 
of steel skids or pre-cast concrete foundations, foundations for the transformer and inverter locations would be 
formed with plywood and reinforced with structural rebar and would use poured-in-place concrete.

RE  Papago  Photovoltaic  Solar  Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 6 
 
 
3.4.6 
Project Substation and Gen-tie 
The project would also include one electrical substation, which would receive electricity from consolidated 
medium-voltage cables from the collection system and step the voltage up to 500 kV via one or two high voltage 
transformer banks consisting of up to four individual transformers as well as switchgear and related substation 
facilities. The substation area would include an electrical control building. A conceptual elevation of the control 
building enclosure is shown in Sheet C3.2 of the Site Plan. The substation would be located in the southeastern 
portion of the site near the Delaney substation, as shown on Sheet C2.8. 
 
The project’s generator intertie electric transmission line or “gen-tie” would then transmit the power at a voltage 
of 500 kV from the project substation to the project point of interconnection at Delaney Substation. The gen-tie 
would be supported by up to four high-voltage support structures consisting of a combination of A-frame dead-
end structures and either H-frames, monopoles, or three-poles. The number of support structures would be kept 
to the minimum needed based on potential engineering constraints. The preferred gen-tie route would run straight 
east-west, but there is a possibility that a turning structure could be required. The support structures are anticipated 
to be approximately 126 feet in height but not more than 140 feet in height, as shown on Sheet C3.5. The design 
and height of the support structures would be refined as building permit applications are completed. Because 
support structures up to 140 feet in height would be required due to electrical design considerations, the applicant 
is also seeking a variance to the County’s requirements that structures to support electric transmission lines 
observe a maximum height of 120 feet (Article 1111.7 of the Maricopa County Zoning Ordinance). This variance 
is reflected in the proposed Plan of Development for the project, as described in Table 3 (RE Papago Solar Project 
Unit Plan of Development: Proposed Zoning Regulations) at the end of this Narrative. The applicant also plans 
to submit an application to the Arizona Corporation Commission for a Certificate of Environmental Compatibility 
(CEC) for the proposed gen-tie line and project substation.  
 
Telecommunications infrastructure at the project substation would include the installation of an antenna and may 
include the installation of a telecommunications tower up to 100 feet high.  
 
3.4.6.1    Installation of Substation and Gen-Tie 
The substation area would be graded and compacted to an approximately level grade. Concrete pads would be 
constructed on site as foundations for substation equipment, and the remaining area would be graveled to a 
maximum depth of approximately six inches. The substation would be surrounded by an up-to 8-foot- high chain 
link fence topped with one foot of barbed wire. 
 
For the gen-tie connection, overhead structure foundations would be installed by excavating foundation holes to 
a depth of approximately 35 feet using a truck-mounted drill rig. The size of the footprint for construction of the 
pole foundation would be approximately 100 square feet. Poles/support structures would be delivered on a flat-bed 
trailer and hoisted into place by a crane. The annular space between poles and holes would be backfilled with 
concrete or soil. Conductors would be strung between poles with heavy-duty trucks. 
 
3.4.7 
Energy Storage System 
The project could include, at the applicant’s option, a battery or flywheel storage system capable of storing up to 
1,200 MWh of electricity and conducting energy to the regional electricity grid. The storage system would consist 
of battery or flywheel banks housed in electrical enclosures and buried electrical conduit. The project would use 
commercially available energy storage technology. Options could include but would not be limited to lithium-ion 
(Li-ion) batteries, flow batteries, sodium sulfur, or mechanical fly wheels. Battery systems are operationally silent 
(except for noise that could be generated by heating, ventilation, and air conditioning [HVAC] systems that may 
be required), and flywheel systems have a noise rating of 45 A-weighted decibels (dBA). Standard HVAC systems 
have a noise rating ranging from 60 to 68 dBA. 
 
The energy storage system would either be dispersed throughout the project site, connected to the PV array via DC

RE  Papago  Photovoltaic  Solar  Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 7 
 
(DC coupled), or concentrated in one location on the site, connected to the PV array via AC (AC coupled). 
Whether a DC-coupled system or an AC-coupled system is chosen for installation will depend on market 
conditions and the availability of commercial options. 
 
For a DC-coupled system, energy storage containers and a DC to DC converter/optimizer would be co-located at 
the inverter equipment areas throughout the site. These containers would include an HVAC system and 
monitoring, controls, and operational management systems that will maintain normal battery operation and 
provide alerts in the case of malfunction. 
 
For an AC-coupled system, the same energy storage containers with related equipment (minus the DC to DC 
converter/optimizer) would be grouped together in one area on the site. The energy storage system would not be 
housed in a building. Refer to Sheet C3.1 of the Site Plan for conceptual battery storage and inverter details. 
Figure 2 shows the conceptual renderings of the potential appearance of a centralized (AC-coupled) battery 
storage system. 
 
 
Figure 2. Artistic rendering of the AC-coupled/centralized energy storage system option. 
 
The energy storage system monitoring, controls, and operational management systems would connect to the 
overall solar facility management system and use sensors to monitor the performance of the energy storage 
system, detect malfunctions or conditions requiring maintenance, and provide plant operators with notification of 
these conditions in real time. The containers will include fire suppression systems, as necessary, for Li-ion battery 
systems. Flow battery containers would include secondary containment, as necessary, for circulating fluid 
systems. 
 
Energy from the storage system would be conducted to the grid through the PV system inverters in the case of a 
DC-coupled system or directly to the grid from the storage system in the case of an AC-coupled system. With the 
use of bi-directional inverters with electricity backflow preventers, both DC-coupled and AC-coupled energy 
storage systems could also be charged by the electrical grid (as well as being charged by the PV modules) and 
therefore provide grid support.

RE  Papago  Photovoltaic  Solar  Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 8 
 
 
3.4.7.1    Energy Storage System Installation 
Construction of the energy storage systems would include 1) site preparation; 2) installation of the foundations, 
structures, and systems; and 3) installation of the inverters, substation, and connection. 
 
If the energy storage system is DC-coupled, the energy storage equipment would be co-located at the inverter and 
transformer equipment areas within the individual array blocks throughout the site. Site preparation would likely 
occur during installation of the inverter and transformer equipment areas. Each energy storage equipment area 
would include battery enclosures on concrete foundations. 
 
For an AC-coupled system, the energy storage equipment, including battery storage containers on concrete 
foundations, power conversion equipment, and electrical collection, would be concentrated in a single location 
most likely near the project substation. The total area of an AC-coupled system would be less than 17 acres. The 
site would be cleared and graded prior to installation. The energy storage system would be largely assembled off-
site and delivered to the project site for final installation. Heavy trucks and other equipment would be used to 
deliver and install the infrastructure and battery or flywheel enclosures. After a system is installed, it would be 
tested and commissioned. 
 
The energy storage system may be installed during installation of the PV arrays, or it could be installed later while 
the facility is in operation. 
 
3.4.8 
Construction Schedule and Workforce 
Construction of the various project components discussed above could occur simultaneously, sequentially, or 
some combination thereof. Construction of the project would commence as early as Quarter 3 (Q3) of 2022. 
Active construction is anticipated to last approximately 18 months, with the total construction duration potentially 
taking place over the course of up to 36 months. Construction is anticipated to be undertaken in phases that may 
overlap one another, including an initial site preparation phase, a phase during which the PV modules and energy 
storage system would be installed, and a final phase during which the inverters, transformers, substation and 
electrical collection system would be installed. The anticipated construction processes, schedule, and workforce 
are further described in this section. 
 
The majority of the labor force is expected to come from the surrounding communities with an average round-
trip commute of 130 miles, and a maximum round-trip commute of up to 170 miles. All workers are expected to 
come from within Phoenix’s metropolitan area. There would be an estimated workforce of 240 to 500 full-time 
employees during construction. 
 
Construction equipment would generally operate between the hours of 7:00 a.m. and 7:00 p.m., Monday through 
Friday, for up to a maximum of eight hours per piece of equipment, daily. Weekend construction work is not 
expected to be required, but may occur on occasion, depending on schedule considerations. 
 
However, to meet schedule demands, it may be necessary to work early morning, evening, or nights and on 
weekends during certain construction phases. Varying work hours can also improve the work environment by 
allowing work to be completed during more favorable temperatures. For safety reasons, certain construction tasks, 
including final electrical terminations, may be performed after dark when no electricity is being produced by the 
PV modules. All construction work, including any weekend work, would comply with the policies and 
requirements established by Maricopa County, including the Maricopa County Noise Ordinance. 
 
3.4.9 
Construction Access, Equipment, and Traffic 
Access to the eastern part of the project site would be provided via I-10 (Exit 94), West Salome Highway, and 
West Indian School Road. Access to the western part of the project site would be provided via the same exit from 
I-10, West Salome Highway, West Courthouse Road, 491st Avenue, and other numbered streets in the area of the

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parcels. 
 
All materials for the project’s construction would be delivered by truck. The majority of truck traffic would occur 
on designated truck routes and major streets. Flatbed trailers and trucks would be used to transport construction 
equipment and materials to the site. Project components would be assembled on-site. Traffic resulting from 
construction activities would be temporary and could occur as workers and materials are transported to and from 
the project site. Materials deliveries during construction would travel up to 85 miles one way from the source to 
the project site. 
 
Anticipated daily peak-hour vehicle trip volumes and equipment to be used for each construction phase are 
presented in the Traffic Impact Study included as part of this application. Typical equipment will include pickup 
trucks, bulldozers, water trucks, and gravel trucks. Any required road improvements for construction activities 
would be developed in coordination with MCDOT and would be subject to MCDOT requirements, as well as all 
applicable requirements of the Maricopa County Air Quality Department, the Maricopa County FCD, and the 
Maricopa County Planning and Development Department. 
 
3.4.10 Personnel Training 
3.4.10.1 
Biological Resources 
Prior to construction, a qualified biologist would be retained by the project applicant or construction contractor 
to conduct environmental awareness training for project construction personnel. Such training would 
communicate information related to the protection of sensitive biological resources that might be present at the 
project site and would include: 
x 
A description of species of concern and associated habitats 
x 
The general provisions of applicable environmental regulations and the need to adhere to the 
provisions of the regulations 
x 
General measures being implemented to conserve the species of concern as they relate to the project 
x 
A discussion of the defined access routes to the project site and project site boundaries within which 
project activities must be accomplished 
 
Construction employees would strictly limit their activities, vehicles, equipment, and construction materials to the 
project footprint, designated staging areas, and routes of travel. The construction areas would be the minimal area 
necessary to complete the project and would be specified in the construction plans. Construction areas would be 
demarcated on-site, and employees would be instructed to limit activities to these areas. 
 
3.4.10.2 
Cultural Resources 
Prior to construction, a qualified archeologist would conduct a training program for construction personnel. The 
training program would inform the construction personnel about the possibility of encountering buried cultural 
resources and the proper procedures should cultural resources be encountered. 
 
3.4.10.3 
Fire Prevention, Suppression, and Safety Program 
The project applicant would coordinate with the RMFD and/or HFD to provide training for personnel to safely 
interrupt electrical power in the event of emergency incidents requiring fire suppression or rescue activities. 
 
To minimize fire risk, combustible vegetation or agricultural products on and around the project site boundary 
would be actively managed by the project owner or its affiliates. Combustible vegetation would either be limited 
in height or removed, consistent with fire-safe requirements and dust control standards of the Maricopa County 
Air Quality Control District for solar electrical generation facilities. 
 
The project applicant would also implement the following measures during project construction and operation:

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x 
All applicable Maricopa County standards and requirements would be followed to ensure accessibility 
and ground clearance of emergency vehicles (e.g., fire engines) 
x 
Smoking would be prohibited at the project site, except within designated areas 
x 
Work crews would be required to park vehicles away from flammable vegetation such as dry grass and 
brush. At the end of each workday, heavy equipment would be required to be parked over mineral soil, 
asphalt, or concrete, where available, to reduce the risk of fire 
x 
All heavy equipment would be required to include mechanisms for fire suppression, including spark 
arresters or turbo-charging (which eliminates sparks in exhaust) and fire extinguishers 
 
3.4.11 Perimeter Fencing and Gates 
Perimeter fencing would be installed around the project site with gates located at key access points for both the 
construction and O&M phases of the project. All fencing and gates would be installed according to the 
specifications and requirements established by Maricopa County within the Maricopa County Zoning Ordinance. 
Proposed locations of all fencing and gates are illustrated on figures within the Site Plan provided as part of this 
application. 
 
3.4.12 Site Security and Outdoor Lighting 
Security cameras would be installed along the perimeter of the project site within the project footprint and/or at 
the inverters. Cameras will be mounted on poles approximately 20 feet in height and will face inward to monitor 
on-site activity. 
 
Outdoor lighting shall comply with Section 1112 of the Zoning Ordinance and all other County standards, 
regulations, and requirements. Lighting would be installed at the substation per utility requirements, along 
perimeter fencing, at the facility entrances and interior gates, at the O&M facilities, at the inverter and transformer 
equipment areas, and at the substations/switching stations. Exterior lighting would be shielded and directed 
downward to minimize the potential for glare or spillover onto adjacent properties. Lighting may be either motion 
activated or light sensitive to automatically come on in the evening and shut off in the morning. 
 
3.4.13 Permanent Buildings 
Ancillary facilities such as the O&M building, septic system and leach field, exterior lighting, signage, SCADA, 
telecommunications, and meteorological data collection system may also be installed with the solar arrays. 
 
3.4.13.1 
O&M Building 
An O&M building to accommodate up to ten permanent O&M staff would be required for the project. The building 
would be approximately 2,000 square feet in size (approximately 40 feet by 50 feet by 15 feet high at its tallest 
point) and located near the project substation. The O&M building would include permanent plumbing and 
restroom facilities for use by the staff. Additional personnel occasionally on-site to perform periodic module 
washing (up to four times per year) would be provided with portable restrooms on the project site as well as 
bottled water for drinking and hand washing. The O&M building would be constructed on a concrete foundation. 
 
3.4.13.2 
Control Enclosures for Relay and SCADA Equipment 
The project would include a comprehensive SCADA system to allow remote monitoring of facility operation 
and/or remote control of critical components. The fiber optic or other cabling required for the monitoring system 
typically would be installed in buried conduit leading to a SCADA system cabinet centrally located within the 
project site or a series of appropriately located SCADA system cabinets constructed within the O&M buildings. 
The dimensions of each cabinet would be approximately 20 feet long by 8 feet wide by 9 feet high. External 
telecommunications connections to the SCADA system cabinets could be provided through wireless or hard-wired 
connections to locally available commercial service providers. The SCADA system would interconnect to a fiber

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optic network. Some trenching work may be required to bury fiber optic cables, or such cables may be installed 
on overhead poles. 
 
Through the SCADA system, operations staff would be on-call to respond to alerts generated by the monitoring 
equipment at the project site and would analyze collected data on an ongoing basis to schedule maintenance. 
Facility outputs and performance would be measured against forecast production to identify equipment failure or 
abnormalities. Attributes that would be monitored include amount of energy generated, equipment (for example, 
inverters and combiners) failure, and weather. 
 
3.4.13.3 
Septic System 
A septic system may be installed adjacent to the O&M building to support the restroom facilities and sewage needs 
of the permanent staff at the O&M building during operation. If a septic system is proposed, approval of septic 
system plans will be sought from Maricopa County prior to building permit approval. Personnel who are on-site 
to perform module washing (up to four times per year) would be provided with portable restrooms serviced by a 
licensed provider. Anticipated peak flow is less than 300 gallons into the leach field per day during project 
operation. No surface discharges are proposed, other than natural stormwater runoff. 
 
3.4.14 On-site Drainage Areas 
On-site drainage areas have been delineated, and retention basins are proposed in each to provide the required 
storage to accommodate the runoff volume from the specified storm event (see Drainage Report). Although none 
are currently proposed, if the final design contains retention basins with ponding depths greater than 3 feet, these 
basins will be equipped with a perimeter fence. Final grading plans will specify the location, elevation, and volume 
of each on-site retention basin. A combination of percolation and/or dry wells may be used to drain the basins 
within 36 hours. 
 
Basins have been designed as berms, which will provide storage up gradient of the basins. Solar panels will be 
located within the basin areas, elevated sufficiently to avoid the ponded water. 
 
3.4.15 Operation and Maintenance 
Upon commissioning, the project would enter the operation phase. The solar modules at the site would operate 
during daylight hours 7 days per week, 365 days per year. The energy storage system would store and dispatch 
power during both daylight and non-daylight hours as required by grid operators year-round. 
 
Operational activities at the project site would include: 
x 
Solar module washing 
x 
Vegetation, weed, and pest management 
x 
Security 
x 
Responding to automated electronic alerts based on monitored data, including actual versus expected 
tolerances for system output and other key performance metrics 
x 
Occasional equipment repair and replacement 
x 
Communicating with customers, transmission system operators, and other entities involved in facility 
operations 
 
3.4.15.1 
O&M Workforce 
Up to 10 permanent staff could be on the site at any given time for ongoing facility maintenance and repairs. The 
duration of scheduled maintenance activities would vary in accordance with the required task but could involve up 
to 25 workers full time for up to 2 weeks up to 4 times a year for module washing and a similar number and 
duration for workers regularly visiting the site for routine maintenance activities, including maintenance of the 
energy storage system. On intermittent occasions, up to 40 workers could be remotely dispatched to the site if

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repairs or replacement of equipment were needed in addition to module washing. A record of inspections would 
be kept on-site. The maximum number of staff on-site at any time would be 75 (10 permanent staff and 65 
temporary staff). The personnel and time required for emergency maintenance would vary in accordance with the 
necessary response. 
 
The operational labor force is expected to be from the Phoenix metropolitan area with a maximum anticipated 
commute of 85 miles one way. 
 
3.4.15.2 
Site Maintenance 
Project site maintenance would be largely conducted during daytime hours. Equipment repairs and preventative 
maintenance could take place in the early morning or evening when the plant would be producing the least amount 
of energy. Key program elements would include maintenance activities undertaken by staff at the on-site O&M 
building and on-site maintenance as required to clear weeds for ground-mount systems. 
 
Maintenance typically would include module repairs; module washing; maintenance of transformers, inverters, 
high-voltage systems, and other electrical equipment as needed; maintenance of the substation, including the 
oil/water separator system; and road and fence repairs. Visual inspections of the transformers and the oil/water 
separator system would be conducted monthly. On-site vegetation would be managed to ensure access to all areas 
of the site. 
 
Solar modules would be washed as needed (up to four times each year) using light utility vehicles with tow-behind 
water trailers, as needed, to maintain optimal electricity production. No chemical cleaners would be used for 
module washing. 
As part of ongoing O&M, the energy storage system would be inspected once a year at minimum. Regular 
preventative maintenance would include checking security of DC and AC connections; replacement of fans, filters, 
and pumps as required or recommended; fire suppression system inspection as required; and validating 
measurements of key electrical and environmental sensors. 
 
Typical equipment used during O&M would include pickup trucks, tractors, and portable water trailers. 
 
3.4.15.3 
Fire Prevention, Suppression, and Safety Program 
During the O&M phase of the project, the Fire Prevention, Suppression, and Safety Program, including all training 
and practices, would be consistent with those described above under construction activities. 
 
3.4.15.4 
Site Safety and Security Plan 
The project is proposed in an unincorporated area of Maricopa County, where law enforcement responsibility and 
services are provided by the Maricopa County Sheriff’s Office. The project is designed to avoid placing additional 
burden on the resources of the Maricopa County Sheriff’s Office through the implementation of the following 
Security Plan. 
 
CONTROLLED ACCESS 
 
The solar facility would be accessed by gated entrances equipped with KnoxBox or similar emergency access 
systems. The entrances would feature locked gates approximately 7 feet high. 
 
LIGHTING 
 
Motion sensitive, directional security lights would be installed to provide adequate illumination around the 
substation areas, each inverter cluster, at gates, and along perimeter fencing. All lighting would be shielded and 
directed downward to minimize the potential for glare or spillover onto adjacent properties. All lighting also would 
conform to applicable Maricopa County rules and regulations for outdoor lighting.

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OTHER SECURITY MEASURES 
 
Off-site security personnel could be dispatched during nighttime hours or could be on-site, depending on security 
risks and operating needs. Infrared security cameras, motion detectors, and/or other similar technology would be 
installed to allow for monitoring of the site through review of live footage 24 hours per day, 7 days per week. 
Such cameras or other equipment would be placed along the perimeter of the facility and/or at the inverters. 
Security cameras located at the inverters would be posted on poles approximately 20 feet high. 
 
SIGNAGE 
 
During all phases of the project, signage for safety and identification would be posted around the perimeter of the 
project site. No large billboards or other forms of advertising signage are proposed. All signage would conform to 
Maricopa County requirements. 
 
3.4.15 Water Requirements 
During the construction phase, it is anticipated that up to 350 acre-feet of water would be used for dust suppression 
and other purposes. Water used during construction could come from an on-site well, a nearby well, or could be 
trucked to the site from a source within 60 miles of the site. 
 
During the O&M phase (which could last up to 40 years), up to approximately 10 acre-feet of water would be 
required per year for module washing and maintenance and for the O&M building restroom facilities. 
 
3.5 
Decommissioning and Site Reclamation 
3.5.1 
Decommissioning of Facilities 
The project is anticipated to have an operating life of up to 40 years. After this period, the project would be either 
repowered or decommissioned. Project decommissioning would involve the removal of above-grade facilities, 
buried electrical conduit, and all concrete foundations. Equipment would be repurposed off-site, recycled, or 
disposed of in a landfill as appropriate. Some or most of the PV modules would be recycled or repurposed. 
 
After the operating life of the project is complete, the energy storage system would be decommissioned along 
with the rest of the solar facility. Some or most battery components would be recycled, and other components 
may be disposed of as hazardous waste, depending on available technology. Li-ion batteries and their constituent 
parts will likely be recycled. Some batteries may have the capacity to be reused at the end of the operating life of 
the project. 
 
Decommissioning would take approximately 13 months to complete and would occur in 3 phases: Phase 1 would 
involve shutting down the systems and removing hazardous materials and wiring; Phase 2 would include 
removing the PV modules, inverters, and substations; and Phase 3 would include removing site fencing and 
driveways and the final soils reclamation process. 
 
Decommissioning would involve the use of heavy equipment similar to that used for construction. Appropriate 
hazardous materials control and erosion control measures would be used throughout the decommissioning 
process. It is anticipated that such controls would be substantially similar to those implemented during 
construction, although the intensity of activities would be lower. 
 
3.5.2 
Site Reclamation 
All roads, driveways, and other areas compacted during original construction or by equipment used for 
decommissioning would be tilled in a manner adequate to restore the sub-grade material to the proper density and

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depth consistent with adjacent properties. Low areas would be filled with clean, compatible sub-grade material. 
After proper sub-grade depth is established, locally sourced topsoil would be placed to a depth and density 
consistent with adjacent properties. Locally sourced compost would be applied to the topsoil, and revegetation 
with native seeds or plantings would be accomplished. 
 
4.0 RELATIONSHIP TO SURROUNDING PARCELS 
4.1 
Project Site Parcels 
The size of the Zoning with Overlay change is 2805.23 acres. All parcels in the project footprint are currently zoned 
RURAL-43 and designated “Utilities” on the Comprehensive Plan Map. To accommodate the proposed 
development, the zoning designation would be converted to IND-2 with an IUPD. Table 1 below lists individual 
parcels. 
 
Table 1. Project Site Parcels 
ASSESSOR’S PARCEL NUMBER 
ACRES 
506-30-009C 
34.08 
506-30-009D 
34.78 
506-30-010 
160.06 
506-30-012D 
40.04 
506-30-012E 
40.04 
506-30-013A 
92.31 
506-30-022A 
159.96 
506-30-022B 
80.00 
506-30-023 
320.34 
506-31-001 
139.98 
506-31-002 
159.32 
506-31-003B 
80.14 
506-31-003C 
80.11 
506-31-003D 
41.80 
506-31-003F 
39.45 
506-31-003G 
39.46 
506-31-003H 
39.41 
506-31-005 
320.66 
506-31-006A 
160.39 
506-31-006C 
120.13 
506-31-007G 
51.41 
506-31-010B 
39.97 
506-31-010C 
80.02 
506-31-010D 
55.05 
506-31-010E 
53.40 
506-31-010F 
60.35 
506-31-011F 
11.51 
506-31-011G 
11.49 
506-31-012A 
76.27

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506-31-014E 
51.14 
506-31-058B 
22.08 
506-31-059 
40.01 
506-31-060A 
19.99 
506-31-060F 
5.02 
506-31-060G 
5.02 
506-31-061 
40.04 
TOTAL: 
2805.23 
 
4.2 
Surrounding Parcels 
The subject property is located adjacent to the Delaney Substation, minimizing the amount of additional power 
lines required to facilitate connection to the regional electrical system. The project site is also located near an 
existing energy generation facility, the Harquahala Generating Station, 1 mile west of the proposed project site at 
the intersection of Thomas Road and 491st Avenue. Thus, the project site is bookended to the west by the 
Harquahala Generating Station and to the east by the Delaney Substation; with the construction of the project, the 
lands between these two significant pieces of energy infrastructure would be consistent with the surrounding 
context of energy generation. 
 
The project site is bisected by property owned and managed by the Maricopa County FCD, and there are canals 
and roads within the project site that are within the Harquahala Valley Irrigation District’s ROW. This project 
would avoid development within floodplains, with the exception of the proposed 34.5-kV electrical collection 
lines described in section 3.4.4 of this Narrative that would span the floodplain in order to connect two non-
contiguous portions of the project. The applicant, RE Papago LLC, intends to obtain an easement and ROW 
permit from the FCD of Maricopa County for these collection lines as well as for any construction activities that 
traverse the real property of the FCD of Maricopa County. RE Papago LLC will also avoid all development in 
the Harquahala Valley Irrigation District’s ROW (extending generally 25 feet from the centerline of irrigation 
canals) and seek a perpetual agreement with the Harquahala Valley Irrigation District for use of roads in the 
Harquahala Valley FCD’s ROW. 
 
Other adjacent land uses include industrial and rural. Adjacent to the north of the project, the majority of the land 
is administered by the Arizona State Lands Department (ASLD).  All land use to the north of the project is 
classified as Rural Density (0-1) and is zoned as RU-43 (Rural).  Adjacent the east of the project, all land is 
administered by the ASLD, with the exception of the APS-owned Delaney Substation located adjacent the 
southeast corner of the project.  All land use here is designated as Rural Density (0-1) and is zoned as RU-43.  
Adjacent to the south of the project, the majority of land is administered by the ASLD, the FCD of Maricopa 
County and the BLM.  Land use to the south of the project is classified as a mix of Rural Density (0-1) and 
Industrial, and is zoned as RU-43, C-2 (Intermediate Commercial) and C-3 (General Commercial).  Adjacent to 
the west of the project, land use is classified as a mix of Rural Density (0-1), Rural Development Area and 
Industrial (adjacent to the southwest corner of the project).  All zoning adjacent to the west of the project is zoned 
as RU-43. The project, as proposed, will be compatible with both industrial and surrounding residential uses. The 
project would not produce, use, store, transport, or dispose of hazardous materials as defined in Title 40, Part 335 
of the Code of Federal Regulations. Materials such as fuels, inverter coolant, transformer oil, and batteries 
installed as part of the energy storage system would be used during construction, operation, and decommissioning 
of the proposed project. These materials are subject to local, state, and federal regulations to minimize risk and 
exposure to the public and to the environment. 
 
4.3 
Benefits to the Community and Surrounding Area 
4.3.1 
Economic Benefits 
During recently conducted public involvement activities for the Major Comprehensive Plan Amendment and the

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Zone Change applications, one important public interest voiced by those who participated was the availability of 
jobs created as a result of the project for interested local citizens. The project as proposed will create the need for 
a variety of new skilled jobs. Project construction is anticipated to take up to 24 months but could last up to 36 
months and will need an estimated workforce of 240 to 500 full-time employees. During operations, there will be 
up to 10 permanent full-time employees for ongoing facility management, up to 25 part-time employees for 
regularly scheduled module washing and routine maintenance activities, and up to 40 employees on an intermittent 
basis for equipment replacement or repair. 
 
4.3.2 
Environmental Benefits 
The project is a 300-MW solar electric generating and storage facility, which will increase the amount of 
renewable energy available to a growing Maricopa County. Tangible environmental benefits from the project 
include a reduction in greenhouse gas emissions over the life of the project as well as a corresponding reduction 
in emissions that adversely impact air quality. The applicant and its consultant, Transcon Environmental, have 
also completed initial screenings in the area of the project for biological resources and cultural resources and have 
determined that the subject property does not contain unique habitats, threatened or endangered species, or 
important cultural resources. There will not be significant adverse impacts to the natural environment. Visually, 
the infrastructure associated with the solar energy generation and storage will be low lying; thus, the impacts to 
scenic quality will be limited and highly localized. Additionally, the project will benefit air quality in Maricopa 
County and beyond. 
 
4.4 
Recent Changes in the Area That Support the Application Request 
In addition to the zoning change requested, RE Papago LLC received approval for a Major Comprehensive Plan 
Amendment and a related General Comprehensive Plan Amendment for the subject project. This is in line with a 
number of other recently approved Comprehensive Plan Amendments for solar energy generation surrounding, 
abutting, and immediately adjacent to the proposed project site, including the Sun Valley North, Sun Valley 
South, Harquahala Solar, and Almeria Solar projects. 
 
5.0 LOCATION AND ACCESSIBILITY 
5.1 
Project Location 
The project site is located in the western region of unincorporated Maricopa County, south of I-10 and 
approximately 5.5 miles west of the community of Tonopah, Arizona. The project site’s location is generally 
north of West Courthouse Road, northwest of the Delaney Substation and the junction of West Courthouse Road 
and West Salome Highway, east of 491st Avenue, and south of I-10. Indian School Road and West Salome 
Highway extend through parts of the project site. 
 
5.2 
Accessibility 
As the project is located immediately south of I-10, it is anticipated that I-10 would serve as the primary corridor 
for both construction traffic and operational traffic serving the proposed project. From I-10, the primary arterial 
roads that will be used to access the project site are existing roads, including West Salome Road, Indian School 
Road, and West Courthouse Road. From these arterial roads, there are a number of smaller, existing roads, both 
named and unnamed, that traverse the project site, which are anticipated to be used and improved for construction 
and ongoing operations of the project. 
 
6.0 CIRCULATION SYSTEM 
6.1 
On-Site 
On-site access would consist of only those required for vehicle access and maintenance activities. Roads would 
typically be constructed to be 14 feet-wide or less and would be paved or graveled as needed for access and dust

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control during construction and O&M phases. 
 
There are no existing access roads within the project on-site boundaries and thus, no improvements are necessary. 
 
6.2 
Off-Site 
The MCDOT has requested ROW dedications/reservations along the following alignments, which the applicant, 
RE Papago LLC, has agreed to: 
x 
Salome Highway: dedicate to 130 feet (65 feet either side of road centerline) (existing ROW is 66 feet 
total) 
x 
Salome Highway through APNs 506-31-059 and 506-31-061: dedicate to 130 feet (65 feet either side 
of road centerline) 
x 
Indian School Road (west of Salome Highway): preserve 25 feet half-width and/or 50 feet full- width 
x 
Indian School Road along parcel APN 506-31-059: dedicate to 65 feet 
x 
Indian School Road along parcel APN 506-31-005: dedicate to 65 feet 
x 
467th Avenue: preserve 65 feet half-width 
x 
Campbell Avenue east from Salome Highway to 267th Avenue: preserve 25 feet 
 
There would be no significant increase in traffic during the operational life of the project that would require road 
improvements. There would be an increase in the level of traffic during the up to 36 months required for project 
construction. This increased traffic would result primarily from the delivery of equipment and supplies and the 
commuting of the construction workforce. A detailed traffic impact analysis has been completed as part of the 
zoning change process and is included in the application package. RE Papago LLC has agreed to financial 
responsibility for repair of roads used during construction, including bonding for such work, so that there is no 
public expenditure required for transportation infrastructure associated with the project. 
 
7.0  DEVELOPMENT SCHEDULE 
Below is an indicative schedule for development: 
x 
Q3 2021—Attain all required approvals and permits which may include, but not be limited to the 
following: Zone Change with Industrial Overlay, Major Comprehensive Plan Amendment, General 
Comprehensive Plan Amendment, CEC, FCD Easement and ROW Permit, air quality permit/approval, 
Section 404, etc. 
x 
Q3 2022—Construction starts (earliest anticipated) 
x 
Q2 2024—Construction complete. Operations begin. (earliest anticipated) 
x 
2024 to 2064—O&M Phase (up to 40 years). 
 
8.0  COMMUNITY FACILITIES AND SERVICES 
The proposed project area is located within the Arlington #47 school district in the Buckeye Union High School 
District #201. 
 
The project site is located in a rural and relatively undeveloped area of Maricopa County. No additional 
amenities or public parks exist within or near to the project area.

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9.0  PUBLIC UTILITIES AND SERVICES 
Table 2. RE Papago Solar Project: Utility Commitments 
UTILITIES 
AGENCY 
Water 
N/A (water used during construction could come from an on-site well, a 
nearby well, or could be trucked to the site from a source within 60 miles of 
the site) 
Wastewater Disposal 
N/A (wastewater generated at the project site would be treated with an on-
site wastewater treatment facility, such as a septic tank system) 
Fire Protection 
Harquahala Fire Department 
Police Protection 
Maricopa County Sheriff's Office 
Electric Service 
Arizona Public Service 
Natural Gas Service 
N/A 
Telephone Service 
AT&T 
Refuse/Solid Waste Disposal 
Republic Services 
N/A = Not applicable

RE  Papago  Photovoltaic  Solar Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 19 
 
10.0 COMPARISON CHART 
Table 3. RE Papago Solar Project Unit Plan of Development: Proposed Zoning Regulations 
REGULATION 
BASE ZONING DISTRICT 
REGULATIONS (IND-2) 
PROPOSED ZONING 
DISTRICT 
REGULATIONS  
(IND-2 IUPD) 
JUSTIFICATION 
Min. Side Yard 
3-10’ 
0’ 
No homes are adjacent to any side yards of the project 
parcels. A 0-foot setback for side yards that are not 
adjacent to streets or road dedications/ preservations would 
make more site area available for energy production. 
Min. Rear Yard 
25’ 
0’ 
No homes are adjacent to any side yards of the project 
parcels. Setbacks of 0 feet make more site area available 
for energy production. 
Min. Lot Area 
6000 sq. ft. 
6000 sq. ft. 
N/A 
Min. Lot Width 
60’ 
60’ 
N/A 
Max. Lot Coverage 
60% 
Max. 60%, solar panels do 
not count towards the lot 
coverage total 
Including solar panels in the lot coverage calculation 
would limit the total energy generation of the project. 
Screening 
A solid masonry wall not less than six feet in 
height shall be required along and adjacent to 
any side or rear property line abutting any 
rural or residential zone boundary, or any 
alley abutting such zone boundary. Further, 
any access gates shall be constructed of view-
obscuring material to provide effective site 
screening. 
6’ minimum chain-link 
fencing (with 1’ of 
barbwire permitted) 
Because of the low profile of the solar PV panels and because 
the site is not located near any population centers or heavily 
travelled roads, landscaping, solid walls or other screening 
methods would not be required to mitigate a visual impact. 
 
The proposed solar PV panel arrays would be visible from 
viewpoints along public roads including West Salome 
Highway and Indian School Road, but would be located on 
relatively flat lands, and would not block or obscure landscape 
views through the site. Chain-link fencing would be consistent 
with other solar energy developments in the area.  
Landscaping 
5’-20’ landscaping strip required along road 
frontages 
No landscaping strip 
required 
Installing a landscaping strip on the site along all road 
frontages would be cost prohibitive. The project is 
designed to minimize the disruption of natural vegetation 
as much as possible. Existing natural vegetation will 
remain undisturbed along front setback areas.

RE  Papago  Photovoltaic  Solar Energy  Generation  and  Storage  Project  
Zone Change with Industrial Overlay Narrative 
page 20 
 
REGULATION 
BASE ZONING DISTRICT 
REGULATIONS (IND-2) 
PROPOSED ZONING 
DISTRICT 
REGULATIONS  
(IND-2 IUPD) 
JUSTIFICATION 
Sight Visibility 
Triangles (SVTs) 
25’ x 25’ SVT required at all access points 
and intersection corners 
Waive all SVT’s at project 
site entry/exit points and 
road intersection, section-
line, mid-section line or 
alignment corners 
Fencing at intersections will be open chain-linked and 
therefore, visibility will be maintained. Most alignments 
and section lines are internal to the Project site footprint. 
No access to the Project site parcels would occur at 
intersections.  
Parking 
Paved parking required. High curb or bumper 
guard required for parking areas. 
Paved parking not 
required with approved 
dust control plan from 
Maricopa County Air 
Quality Control. High curb 
and/or bumper guard not 
required. 
Onsite parking would be limited to the O&M building. No 
paved surfaces are planned within areas near to where the 
O&M building would be constructed. Onsite parking will 
not be located near property lines. 
Max. Electric 
Transmission Line 
Structure Height 
120’ 
140’ 
Utility pole heights up to 140 feet are requested because 
utility structures 120 feet or less in height may be 
infeasible due to final electrical design considerations. The 
applicant’s current preliminary, conceptual designs 
indicate that high-voltage dead-end structures up to 127 
feet in height may be required, as shown on Sheet C3.2 of 
the Site Plan; however, final design has not been 
determined yet and the gen-tie may require structures up to 
140 feet in height. The applicant requests the flexibility to 
make the necessary adjustments, as needed, for future final 
designs. 
Additional 
Regulations 
All uses except for parking, loading, 
unloading or storage shall be conducted within 
a completely enclosed building. 
Utility uses are permitted 
to be conducted outside of 
an enclosed building.  
The 2,000-square foot Operations and Maintenance 
(O&M) building would be the sole staffed structure on the 
site. The operating uses of the site include energy 
generation and storage, which would take place within the 
solar PV arrays and Battery Energy Storage System 
(BESS), respectively, and would not take place within 
enclosed structures (with the exception of the unstaffed 
project substation and SCADA/control system enclosure).

Robert Fedorka, P.E. 
Planning & Development 
301 W. Jefferson Ave., Suite 170 
Phoenix, Arizona 85003 
Phone: (602) 506-7151 
www.maricopa.gov/planning 
Email address: 
Bob.Fedorka@Maricopa.gov 
  
Maricopa County 
Planning & Development Department 
Engineering Plan Review 
  
 
 
 
Date:    
July 26, 2021 
 
Memo To: Darren Gerard, AICP, Department of Planning & Development 
 
Attn: 
Adam Cannon, Planner, Planning & Development Services 
 
 
From: 
Robert 
Fedorka, 
P.E., 
Engineering 
Supervisor, 
Planning 
& 
Development Services 
 
cc: 
Michael Norris, P.E., Engineering Manager, Planning & Development 
 
Subject:   
Z2019121 Zone Change (IUPD) for RE Papago PV Solar Energy 
Project 
 
(E3-Rev Memo) 
Job Site Address: T2N R8W Parts of Sections 13, 14, 21, 22, 24-28 & 33 
  
Engineering plan review (DPR, FCD and PND Transportation) has reviewed the Zone 
Change application routed for review on 04/26/2021 (3rd submittal), and has no 
objections subject to the conditions noted below: 
 
1. 
Drainage Waiver case DRB2021005 must be approved prior to issuance of 
building permits. 
 
2. 
Detailed Grading and Drainage Plans showing the new site improvements must 
be submitted for the acquisition of building permits. On-site (solar field & 
substation) areas must be designed in such a manner so that flows area directed 
to retention basin(s). Basin overflows must be directed to well defined drainage 
corridors, to the maximum extent possible. 
 
3. 
Owner  or  owner’s  agent  shall  be  responsible  for  identifying  and  procuring 
any permit(s) for disturbance of, or work within delineated jurisdictional (404) 
washes. 
 
4. 
Sizing of the basin spillways must be determined based on the peak 
unattenuated flow rate, based on the proposed site condition, using either the 
Rational Method or DDMSW. Where the retention areas will be comingled with 
offsite flows, the offsite flows must be included in the discharge rate, 
 
5. 
As part of the final design, channelized flow may be required to be dissipated 
(spread) at their outflow locations to match existing downstream conditions. 
 
6. 
Drainage review of planning and/or zoning cases is for conceptual design 
only and does not represent final design approval nor shall it entitle applicants 
to future designs that are not in conformance with Section 1205 of the Maricopa

County Zoning Ordinance and the Maricopa County Drainage Policies and 
Standards. All development and engineering design shall be in conformance 
with Section 1205 of the Maricopa County Zoning Ordinance and current 
engineering policies, standards and best practices at the time of application for 
construction. 
 
7. 
Any disturbance to Special Flood Hazard Areas (floodplains) will require that 
a Floodplain Use Permit be issued concurrent with the associated building 
permit. 
 
8. 
Pads for inverters and other electrical equipment; and any buildings within a 
Floodplain must be elevated to the regulatory flood elevation or otherwise 
designed to meet the requirements of the Floodplain Use Regulations. All 
development and engineering design shall be in conformance with the most 
current version of the Floodplain Use Regulations for Maricopa County. 
 
9. 
Project improvements (i.e. electric lines) within and immediately adjacent to 
District owned properties require a Right-of-Way Permit from the Flood 
Control District. 
 
10. 
Future right-of-way needs, dedication, preservation, and offsite improvements, 
shall be addressed during site plan and/or building permit review, with the 
submittal of a traffic impact study, prior to any approvals. 
 
11. 
Driveway accesses to paved MCDOT right-of-ways must be paved for the full 
width of the right-of-way. 
 
Please contact me if you have any questions or require any additional information.

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:
July 19, 2021   
TO :
Adam Cannon, Planning & Development Dept.
Planner
FROM:
Souren Naradikian, P.E.
Senior Civil Engineer
SUBJECT:
Zone change from RU-43 to IND-2 IUPD. Z2019121
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 request is for Zone change from 
RU-43 to IND-2 IUPD at APN # 304-29-051A. Water will be provided by private
well, MCESD has no concerns. Wastewater services septic, MCESD has concerns. 
The applicant must obtain NOID prior to construction permit approval. Please 
contact ONSITE WASTEWATER PROGRAM 602-506-0372 to obtain NOID.
Based on the above, MCESD raised no objection to this project to the Planning & 
Development Department in Accela on July 19, 2021 and can allow the project to 
proceed at this time subject to the following stipulations:
Stipulations: 
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.

From:
Robert Busick
To:
Adam Cannon (PND)
Subject:
Z2019121 - 3rd Submittal - RE: Papago PV Solar Energy Project
Date:
Monday, April 26, 2021 10:32:27 AM
Attachments:
image003.png
Hello, Adam,
Regarding case Z2019121: after reviewing the associated documents, the City of Buckeye has no
comment.
Thank you,
ROBERT BUSICK | PLANNER I | DEVELOPMENT SERVICES
CITY OF BUCKEYE | 530 EAST MONROE AVENUE, BUCKEYE, AZ 85326
| O: 623.349.6242 | C: 623.414.2066 |
RBUSICK@BUCKEYEAZ.GOV
CITY HALL HOURS: MON-THURS 7AM-6PM
CLOSED ON FRIDAYS
WWW.BUCKEYEAZ.GOV
This message contains confidential information and is intended only for the individual(s)
addressed in the message. If you are not the named addressee, you should not disseminate,
distribute, or copy this e-mail. If you are not the intended recipient, you are notified that
disclosing, distributing, or copying this e-mail is strictly prohibited.

From:
Robert Busick
To:
Adam Cannon (PND)
Subject:
Z2019121 - 2nd Submittal - RE: Papago PV Solar Energy Project
Date:
Thursday, September 3, 2020 4:06:57 PM
Attachments:
image001.png
Hello, Adam:
Regarding case Z2019121, after reviewing the associated documents, the City of Buckeye has no
comment.
Thank you,
Robert Busick  | Planner I
City of Buckeye | Development Services
530 E Monroe Ave| Buckeye, Arizona 85326
P 623-349-6242 | rbusick@buckeyeaz.gov
Monday-Thursday 7am-6pm CLOSED FRIDAYS
2020 Census – Everyone Counts in Buckeye! – ¡Todos Cuentan en Buckeye! – www.icount2020.info
This message contains confidential information and is intended only for the individual(s)
addressed in the message. If you are not the named addressee, you should not disseminate,
distribute, or copy this e-mail. If you are not the intended recipient, you are notified that
disclosing, distributing, or copying this e-mail is strictly prohibited.

May  26,  2021   
  
Mr.  Adam  Cannon   
Maricopa  County  Planning  &  Development  Department   
501  N.  44th  Street,  Suite  200   
Phoenix,  AZ  85008   
  
Electronically  submitted  to:  adam.cannon@maricopa.gov   
  
RE:  Papago  PV  Solar  Energy  Project   
  
  
Dear  Mr.  Cannon:   
  
At  the  request  of  Maricopa  County,  the  Arizona  Game  and  Fish  Department  (Department)  has  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
reviewed  the  Zone  Change  Narrative  for  the  proposed  solar  facility  in  unincorporated  Maricopa  
 
 
 
 
 
 
 
 
 
 
 
 
 
County,  south  of  I-10  and  approximately  5.5  miles  west  of  the  community  of  Tonopah,  Arizona.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  Department  understands  that  RE  Papago  LLC  (Recurrent  Energy)  is  proposing  the  
 
 
 
 
 
 
 
 
 
 
 
 
development  of  a  photovoltaic  solar  facility,  with  the  construction  of  one  electrical  substation,  
 
  
 
 
 
 
 
 
 
 
 
 
associated  overhead  and  underground  34.5  kV  electric  lines,  and  an  energy  storage  system  on  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
approximately  2,791.2  acres  of  privately  owned  land.   
  
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  and  protect  Arizona’s  diverse  fish  and  wildlife  resources  and  manage  for  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
safe,  compatible  outdoor  recreation  opportunities  for  current  and  future  generations.  Similarly,  
 
 
 
 
 
 
 
 
 
 
 
the  Department  recognizes  the  importance  of  planning  efforts  that  contribute  to  the  county  and  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
the  state’s  economic  growth  needs  and  opportunities  to  develop  renewable  energy  locations.  The  
 
 
 
 
 
 
  
 
 
 
 
 
Department  recognizes  that  appropriate  coordination,  proper  planning,  and  voluntary  
 
 
 
 
 
 
 
 
 
implementation  of  best  management  practices  allow  projects  to  be  developed  that  avoid,  
 
 
 
 
 
 
 
 
 
 
 
 
minimize,  or  mitigate  potential  impacts  to  wildlife  habitat  and  populations.   
  
  
To  the  extent  possible,  the  Department  encourages  pre-construction  surveys  and  monitoring  to  
 
 
 
 
 
 
 
 
 
 
 
 
determine  species  presence  as  referenced  in  our  Guidelines  for  Solar  Development  in  Arizona .  
 
 
 
 
 
 
 
 
 
 
 
 
 
The  Department  is  available  to  review  survey  designs,  provide  input  on  developing  
 
 
 
 
 
 
 
 
 
 
 
 
best-management  practices,  and  are  available  to  assist  in  developing  this  economically-important  
 
 
 
 
  
  
 
 
 
facility  while  also  minimizing  any  potential  impacts  to  wildlife  during  construction  and  operation  
 
 
 
 
 
 
  
 
 
 
 
 
of  the  facility.   
  
  
Based  on  Department  data,  a  portion  of  the  project  area  has  been  used  by  the  10J  designated,  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
experimental  nonessential  population  of  the  endangered  Sonoran  pronghorn.  Sonoran  pronghorn

Papago  PV  Solar  Energy   
May  26,  2021   
Page  2   
have  specific  habitat  requirements  based  on  their  life  history  and  survival  strategy.  This  
 
 
 
 
 
 
 
 
 
 
 
 
 
population  is  relatively  new  and  its  range  is  expanding  into  previously  unused  areas.  Based  on  
  
 
 
 
 
  
 
 
 
 
 
 
 
the  proposed  location  of  the  project,  the  Department  would  welcome  the  opportunity  to  work  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
with  Maricopa  County  and  Recurrent  Energy  to  minimize  any  potential  impacts  to  Sonoran  
 
 
 
 
 
 
 
 
 
 
 
 
 
pronghorn.  The  Department  recommends  the  following  measures  to  avoid  and  minimize  
 
 
 
 
 
 
 
 
 
 
 
potential  impacts:   
  
●
Coordination  between  the  Department  and  Recurrent  Energy  prior  to  construction  
 
 
 
 
 
 
 
 
 
 
activities  in  order  to  exchange  information  on  current  Sonoran  pronghorn  use  in  the  
 
 
 
 
 
 
 
 
 
 
 
 
 
project  area.   
  
●
If  pronghorn  are  detected  during  construction  activities,  please  notify  the  US  Fish  and  
 
 
 
 
 
 
 
 
 
 
 
 
 
Wildlife  Service,  Arizona  Ecological  Services  Office  (AESO)  and  the  Department’s  
 
 
 
 
 
 
 
 
 
 
Sonoran  Pronghorn  Program  Lead  ( jbright@azgfd.gov )  as  soon  as  possible.   
  
The  Sonoran  desert  tortoise  ( Gopherus  morafkai )  is  a  Candidate  species  for  listing  under  the  
 
 
 
 
 
 
  
 
 
 
 
 
 
ESA  and  has  been  recorded  within  the  vicinity  of  your  project. .  The  Department  recommends  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
conducting  a  survey  for  Sonoran  desert  tortoise  within  suitable  habitat,  in  accordance  with  the  
  
 
 
 
 
 
 
 
 
 
 
 
 
Desert  Tortoise  Survey  Guidelines  for  Environmental  Consultants, to  determine  the  
 
 
 
 
 
 
 
 
 
 
presence/absence  of  this  species.  If  tortoises  are  identified  during  the  survey,  please  refer  and  
 
 
 
  
 
 
 
 
 
 
 
 
 
adhere  to  The  Recommended  Standard  Mitigation  Measures  For  Projects  In  Sonoran  Desert  
 
 
 
 
 
 
 
 
 
 
 
 
Tortoise  Habitat  and  Guidelines  For  Handling  Sonoran  Desert  Tortoises  Encountered  On  
 
 
 
 
 
 
 
 
 
 
 
Development 
 Projects. 
 All 
 of 
 these 
 documents 
 can 
 be 
 found 
 at  
 
 
 
 
 
 
 
 
 
 
https://www.azgfd.com/wildlife/nongamemanagement/tortoise/.   
  
The  western  burrowing  owl  ( Athene  cunicularia  hypugaea )  is  a  special  status  species  that  is  
 
 
 
 
 
 
 
  
 
 
 
  
regulated  under  the  Migratory  Bird  Treaty  Act  (MBTA).  If  suitable  habitat  for  this  species  is  
 
 
 
 
 
 
 
  
 
 
 
 
  
present  within  or  adjacent  to  your  project  area,  the  Department  recommends  conducting  an  
 
 
 
 
 
 
 
 
 
 
 
 
 
occupancy  survey  for  western  burrowing  owls  to  determine  if  this  species  occurs  within  your  
 
 
 
 
 
 
 
  
 
 
 
 
 
project  footprint.  Guidelines  for  conducting  this  survey  are  found  in  Burrowing  Owl  Project  
 
 
 
 
 
 
 
 
 
 
 
 
 
Clearance  Guidance  for  Landowners  which  can  be  accessed  on-line  through  the  Department’s  
 
 
 
 
 
 
 
 
 
 
 
 
website.  Please  note  that  the  survey  should  be  conducted  by  a  surveyor  that  is  certified  by  the  
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
Department.  If  an  active  burrowing  owl  burrow  is  detected,  please  contact  the  Department  and  
  
 
 
 
 
  
 
 
 
 
 
 
the  U.S.  Fish  and  Wildlife  Service  for  direction,  in  accordance  with  the  Burrowing  Owl  Project  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Clearance  Guidance  for  Landowners .   
  
The  Department  would  like  to  provide  the  following  general  recommendations:   
●
During  construction  activities,  if  wildlife  such  as  the  Sonoran  desert  tortoise  are  
 
 
 
 
 
 
 
 
 
 
 
 
encountered,  please  contact  the  Department  to  discuss  relocation.  This  also  applies  to  any  
 
 
 
 
  
 
 
 
 
  
 
wildlife  that  may  need  to  be  removed  from  the  facility  once  it  is  operational.  The  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Department  requests  the  facility  provide  an  annual  report  of  any  animal  
 
 
 
 
 
 
 
 
 
 
 
sightings/occurrences  during  the  construction  and  operation  of  the  facility.  Additionally,  
 
 
 
 
 
 
 
 
 
 
please  share  wildlife  related  mortalities  from  facility  operation(s)  to  pep@azgfd.gov.   
●
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

Papago  PV  Solar  Energy   
May  26,  2021   
Page  3   
surface  flows,  both  in  washes  and  across  uplands,  could  lead  to  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.   
  
●
Artificial  night  lighting,  may  attract  insects  and  the  species  that  prey  on  them  (e.g.  bats).  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
It  could  also  impair  the  ability  of  nocturnal  animals  to  navigate.  The  Department  
 
 
 
 
 
 
 
 
 
 
 
 
 
recommends  using  only  the  minimum  amount  of  light  needed  for  safety.  If  feasible,  
 
 
 
 
 
 
 
 
 
 
 
 
 
narrow  spectrum  lighting  is  wildlife-friendly  and  should  be  used  as  often  as  possible  to  
 
 
  
 
 
 
 
 
 
 
 
 
 
minimize  the  number  of  species  affected  by  lighting.  It  is  also  beneficial  that  all  lighting  
 
 
 
 
 
 
 
   
 
 
 
 
 
is  shielded,  canted,  or  cut  to  minimize  the  amount  of  upward  shining  light.   
  
●
Birds  of  prey  such  as  raptors,  owls,  vultures,  and  eagles  are  vulnerable  to  electrocution  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and  powerline  strikes  during  construction  and  operation.  There  are  a  number  of  design  
 
 
 
 
 
 
 
 
  
 
 
 
features  that  can  minimize  these  impacts  to  these  important  species.  Tuk  Jacobson  is  the  
 
 
 
 
 
 
 
 
 
 
 
  
 
Department’s  raptor  expert  and  will  be  willing  to  share  information  on  best  management  
 
 
 
 
 
 
 
 
 
 
 
 
 
practices;  he  can  be  contacted  at  KJacobson@azgfd.gov  or  623-236-7575.  
  
●
Power  poles  can  serve  as  perches  for  many  birds  of  prey  and  there  are  design  features  for  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
structures  that  can  reduce  impacts  to  these  important  species.  Another  possible  alternative  
 
 
 
 
  
 
 
 
 
 
 
to  reduce  mortality  is  using  bird  flight  diverters  to  decrease  avian  mortalities.  Again,  Mr.  
 
 
  
 
 
 
 
 
 
 
 
 
 
Jacobson  has  expertise  in  all  of  the  best  management  practices  and  would  be  available  to  
 
 
 
 
 
 
 
 
 
 
 
 
 
  
share  his  knowledge  in  the  pre-design  phase  of  this  project.   
  
  
  
Thank  you  for  the  opportunity  to  provide  comments  on  this  proposed  project.  The  Department  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
looks  forward  to  continued  communications  with  Maricopa  County  and  Recurrent  Energy  
 
 
 
 
 
 
 
 
 
 
 
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)   
 
Tyler  Williford,  Habitat  Program  Manager,  Region  IV  (twilliford @azgfd.gov )   
  
AGFD  #M21-04264750

From:
Peggy Fehlman
To:
Adam Cannon (PND); Gerardo Ramirez
Subject:
Fwd: 3rd Submittal - RE: Papago PV Solar Energy Project
Date:
Monday, April 26, 2021 9:15:02 AM
Attachments:
image002.png
image003.png
image.png
image001.png
Good Morning,
Thank you for the Notification about the Papago PV Solar Energy Project.
It looks as though this project has a small portion that is over the I-10, west of 443rd Ave.
That area is in our Southwest District so I am forwarding your email to Gerardo Ramirez who is over the permits for the southwest district.
He will help you going forward or put you in touch with the correct department moving forward.
Kind Regards,
Peggy Fehlman
Right of Way Coordinator
ADOT Central District
2140 W. Hilton Avenue
Phoenix, AZ 85009
(602)712-6622 Office
www.azdot.gov
---------- Forwarded message ---------
From: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Date: Mon, Apr 26, 2021 at 7:28 AM
Subject: 3rd Submittal - RE: Papago PV Solar Energy Project
To: tvcc.events@gmail.com <tvcc.events@gmail.com>, dmheisler1@aol.com <dmheisler1@aol.com>, ronsatt@ev1.net <ronsatt@ev1.net>,
swilken@azmag.gov <swilken@azmag.gov>, vwolfley@azmag.gov <vwolfley@azmag.gov>, redletter@azdot.gov <redletter@azdot.gov>,
Robert Rowley (EMG) <ROBERT.ROWLEY@maricopa.gov>, todd.williams@aps.com <todd.williams@aps.com>, Bruce Monson (EMG)
<Bruce.Monson@maricopa.gov>, charlotte.shields@aps.com <charlotte.shields@aps.com>, travis.icard@aps.com <travis.icard@aps.com>,
Richard Peel (EMG) <Richard.Peel@maricopa.gov>, Madison Wisler (EMG) <Madison.Wisler@maricopa.gov>, bhurley@buhsd.org
<bhurley@buhsd.org>, chadt@arlingtonk8.org <chadt@arlingtonk8.org>, thogan@buckeyeaz.gov <thogan@buckeyeaz.gov>,
graham.symmonds@gwresources.com <graham.symmonds@gwresources.com>, tonopahvalleycc@yahoo.com <tonopahvalleycc@yahoo.com>,
gritter@azgfd.gov <gritter@azgfd.gov>, Andrew Cavalcant <acavalcant@azgfd.gov>, steve_spangle@fws.gov <steve_spangle@fws.gov>,
mkillian@azda.gov <mkillian@azda.gov>, rick.moreau@aztvcc.org <rick.moreau@aztvcc.org>, l_thompson@mcso.maricopa.gov
<l_thompson@mcso.maricopa.gov>, contact@fosmaz.org <contact@fosmaz.org>, azshpo@azstateparks.gov <azshpo@azstateparks.gov>,
lc1@azdeq.gov <lc1@azdeq.gov>, Rerickson@azdot.gov <Rerickson@azdot.gov>, paul.katz@azag.gov <paul.katz@azag.gov>,
david.mckay@az.usda.gov <david.mckay@az.usda.gov>, johnson.kathleen@epa.gov <johnson.kathleen@epa.gov>, ssandell@hfdaz.org
<ssandell@hfdaz.org>
Cc: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Good morning all,
This e-mail serves as notification of a third submittal we have received for a Zone Change with Overlay from RU-43 to IND-2 IUPD for the RE:
Papago PV Solar Energy 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 Zone Change case number Z2019121.

Please let me know if you have any questions or concerns.
Best regards,
Adam Cannon
Planner
Maricopa County Planning & Development Department
501 N. 44th Street, Suite 200, Phoenix, AZ 85008
Desk: 602-372-0292
adam.cannon@maricopa.gov

From:
Cindy Wiener
To:
Adam Cannon (PND)
Subject:
Re: Z2019121 - 2nd Submittal - RE: Papago PV Solar Energy Project
Date:
Wednesday, September 9, 2020 10:14:01 AM
Attachments:
image003.png
image004.png
Good Morning,
Thank you for your notice for the above-referenced development. ADOT
is neutral on this matter. As such, ADOT has no comment.
Kind Regards,
Cindy L. Wiener,
Right of Way Agent Consultant
On Thu, Sep 3, 2020 at 2:13 PM Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
wrote:
Good afternoon all,
This e-mail serves as notification of a second submittal we have received for a Zone Change
with Overlay from RU-43 to IND-2 IUPD for the RE: Papago PV Solar Energy 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 Zone Change case number Z2019121.  Please let me know if you have any
questions or concerns.
Best regards,
Adam Cannon
Planner
Maricopa County Planning & Development
Department
501 N. 44th Street, Suite 200, Phoenix, AZ 85008
Desk: 602-372-0292
adam.cannon@maricopa.gov