03.CPA250002_04. Z250015 PZ Staff Report

Maricopa County — Planning & Zoning (2025-11-06)

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CPA250002 & Z250015
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Report to the Planning and Zoning Commission
Prepared by the Maricopa County Planning and Development Department
Cases:
CPA250002 & Z250015 – Harquahala Energy Generation & Industrial 
Complex
Hearing Date:
November 6, 2025
Supervisor District:
5
Applicant:
Keith Nichter, Kimley-Horn
Owners:
DL Landco, LLC; Ben Fatto, LP; Gluck, LP; GYP Harquahala Holdings, LLC; 
Klaus Jurgen Bolle Rainer, TR; David Marion, RT; Copia Land Holdings, LLC; 
Daniel Arredondo, RT; Stegner, FT; Schuetze FT; and CLB Partners, LLC;
  
Requests: 
1)
General Comprehensive Plan Amendment (CPA) of Vision 2030 
Comprehensive Plan land use designation on 70% of the site from Rural 
Development Area (0-1 du/ac) to Utilities 
2) 
Zone change with overlay from IND-2 IUPD and Rural-43 
to IND-2 IUPD 
 
Site Location:
Generally located at the NWC of 499th Ave. and Camelback Rd. in the 
Harquahala Valley area
 
Site Size:
Approximately 638 acres for the general CPA  area and approximately 917 
acres for the entire site
Density:
N/A
County Island: 
No
County Plan:
Rural Development Area (RDA) and CPA2020002 to Utilities
Municipal Plan:
N/A
Municipal Comments:
None received to date 
Support/Opposition:
None known
Recommendations:
1) 
Approve 
2) 
Approve with conditions

CPA250002 & Z250015
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Project Summary:
1.
The applicant, on behalf of the property owners, is requesting a general CPA of the County’s Vision 
2030 Comprehensive Plan from RDA to Utilities on 70% of the 917 acre site to match the Utilities 
land use designation found on the rest of the site, which is already designated as Utilities. This 
request will enable the entire site to be under a single land use designation to accommodate 
energy generation and data storage facilities.
2.
Subsequently, the applicant is requesting a zone change with overlay from IND-2 IUPD and Rural-
43 to IND-2 IUPD for not only solar generation and battery storage systems (BESS), but also data 
storage facilities. This site would utilize the energy produced from the adjacent Maricopa Energy 
Center and Harquahala Sun that was approved to provide solar energy generation with BESS. The 
adjacent solar generation/BESS facilities will provide most of the electricity the data storage 
facilities will need  to power and cool this use. According to the applicant, data centers are 
becoming critical infrastructure in today’s digital world, this campus looks to address the growing 
need  by providing the storage, processing, and transmission of large volumes of data generated 
every second.  Also, according to the applicant, data centers support everything from financial 
transactions, healthcare systems, emergency services to communications. The primary reason 
for this request on this site is the fact that this site is very isolated with virtually few residents in 
this part of the County.  Another reason is this site is and will be surrounded by electrical 
infrastructure that will be able to power data storage facilities.   
3.
On December 9, 2020, the Board of Supervisors approved a Major CPA to designate the original 
30% of this site as Utilities (CPA2020002). On May 8, 2024, the Board approved a zone change of 
that same area to IND-2 IUPD (Z2023133). They’re now rezoning the remainder of the 4,265 acre 
site for an energy generation facility known as Maricopa Energy Center. On May 20, 2025, a 
technical advisory committee meeting was held to discuss the first review comments with the 
applicant. 
4.
The general CPA narrative asserts that the proposed development meets the Comprehensive Plan 
Amendment criteria in the following manner:
Whether the Amendment constitutes an overall improvement to the Comprehensive Plan and is 
not solely for the good or benefit of a particular landowner or owners at a particular point in 
time. 
This Project is intended to promote and incentivize the production and delivery of energy 
resources that meet and otherwise support consumption needs of existing and emerging markets 
which benefit the regional and state economies and tax bases. The availability of efficient energy 
and the resulting cost savings, both immediate and overtime, creates opportunity for 
reinvestment of public and private capital back into the local and regional economy.
The Amendment will not adversely impact all or a portion of the planning area by altering 
acceptable land use patterns to the detriment of the plan.
The proposed General CPA will not alter the acceptable land use patterns in the planning area in 
an adverse manner to the detriment of the plan. The proposed change in land use is consistent 
with existing approved utility and industrial land use patterns in the area. Previous land use 
approvals should not be construed to future precedents, nor obligate future Board of Supervisor 
decisions. However, the infrastructure investment and development within this portion of the

CPA250002 & Z250015
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planning area make the Project site a more suitable and logical location for future development 
of industrial and power generation uses.
Any expenditures for larger and more expensive infrastructure that are required because of the 
development shall be borne by the developer. Improvements for adjacent access roads, as 
coordinated with the county, will be borne solely at the expense of the developer proportionate to 
the impacts placed on the transportation network. Any public or private electric transmission 
infrastructure improvement costs needed in support of the Project will be borne solely by the 
developer.
Given the proximity to the Interstate 10, the remoteness of the site and the lack of surrounding 
development, existing and planned uses surrounding the site which are dependent on the 
surrounding transportation system are not anticipated to be impacted due to the minimal traffic 
impact associated with the Project.
The General CPA will not adversely affect the livability of the area or health or safety of present 
and future residents of the area. As previously discussed, there are no residences in the 
immediate area. Site preparation, construction, or operation will not include any hazardous 
activities, materials, processes, or outputs. Noise impacts would be limited construction activities 
during specified construction hours. Fugitive dust control will be achieved during construction 
and operational periods by implementation of proper grading, erosion control measures, and best 
management practices (BMP’s) to include appropriate dust control and mitigation of dust on 
unpaved roads. Standard operational activities will conform to applicable noise ordinances. Fire 
hazard and wildfire mitigation will be addressed with the subsequent plan of development. The 
facility will comply with all applicable local and county fire laws and regulations.
Given the Project site location, adjacent to the busy Interstate 10 thoroughfare, and the significant 
amount of industrial project approvals in the surrounding area, it is not anticipated that the 
proposed land use will generate adverse impacts to the natural environment or the scenic quality 
of the area.
5.
The narrative asserts that the proposed development meets the specific goals and policies 
contained within the plan in the following manner: 
a.
Land Use Goal #3: Protect public health, safety and well-being: The proposed facility and 
the Utilities land use designation match the industrial character of the surrounding area. 
The Project, like much of the surrounding solar developments, is a low impact land use 
that requires minimal water usage and produces minimal traffic. It will contribute to much 
needed employment opportunities and efficient energy while helping maintain long-term 
financial stability through the generation of revenues and tax base contributions for 
Maricopa County. The Project will provide fiscally responsible employment and alternative 
energy services and effective and efficient infrastructure to implement delivery of 
necessary data services that help promote and contribute to a healthy community that 
residents can enjoy.
b.
Land Use Policy #22: Maricopa County supports reducing the impacts of new 
development on environmentally sensitive areas, including native flora and fauna habitat 
and corridors: The facility does not include environmentally sensitive areas requiring 
avoidance or mitigation that we are aware of currently. All development activities will 
remain compliant with applicable environmental regulations requiring flora/fauna habitat 
and/or environmental protection or relocation. Ongoing coordination with the appropriate

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agencies, including AZGFD, SHPO and AZDA, throughout the facilities life cycle will ensure 
appropriate site treatments and regulatory compliance with applicable environmental 
policies, protocols, and regulations.
c.
Transportation Goal #1: Promote and protect public health through a safe transportation 
system: This use will further this priority by addressing some of the related concerns 
specific to the preservation of road alignments and air pollution. The developer will be 
responsible for right-of-way preservation of the necessary roadway alignments with 
MCDOT. Because data centers and energy production produce significantly lower traffic 
volumes than other industrial uses, outside of the limited construction traffic, this facility 
will provide a use that will limit  automobile usage and reduce air pollution.
d.
      Environmental Policy #2: To help improve air quality Maricopa County supports balanced 
and efficient land use patterns where employment, retail and residential land uses are 
proximate rather than separate: The developer supports improved air quality by proposing 
an alternative energy use that decreases emissions that result from electricity produced 
by fossil fuels. Compared to other power producers, solar powered plants and associated 
battery electric storage facility developments significantly decrease carbon dioxide 
emissions and eliminate sulfur, nitrous oxides, and mercury emissions generated by 
conventional electric generation facilities. 
e.
      Economic Growth Policy #6: The County supports efforts to recruit prospective business 
and industries to the County: Development of this project will focus on the growing data 
industry, providing high-tech, and environmentally friendly employment opportunities in 
information technology and energy production. Addressing this need will create vital 
digital infrastructure in this industry that is seeing huge investments, with a growing focus 
on sustainable infrastructure to meet this unprecedented demand. The data storage 
facility will include buildings containing computing and networking hardware, along with 
power and cooling infrastructure. Facilities such as these are required to store, process, 
manage, and distribute massive quantities of data, for modern communication, telehealth, 
remote work, media streaming, energy, healthcare, retail, aviation, automotive, 
entertainment, and government operations. These facilities will be supported by additional 
infrastructure such as power generation, energy distribution, and storage systems. 
Investing in cleaner natural gas energy generation promotes local economic opportunities 
rather than reliance on distant energy sources.
f.
      Water Resource Goal #4: Increase water conservation: Over the recent years, the switch 
to utilities and industrial land uses within this surrounding area has resulted in a 
significant decrease in agricultural uses, which is a heavy water user. Additionally, the 
developer will look to continue to these water conservation goals. The proposed data 
centers and energy generation uses are generally low staffed resulting in minimal potable 
water needs. Additionally, they will encourage innovative cooling technologies for 
operational purposes. Construction peak water usage and operations & maintenance 
water usage would be significantly less than a residential community or agricultural use. 
g.
      Energy Goal #1: Provide leadership to promote regional environmental quality: This 
facility will have a long-term impact on improving environmental quality by contributing to 
numerous sustainability goals including reduced water consumption in electricity 
generation and decarbonization of the grid by providing essential resource adequacy 
capacity and reliability, thus enabling acceleration of the retirement of coal-fired power 
generation assets. Natural gas energy generation offers benefits including being the

CPA250002 & Z250015
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cleanest-burning fuel, producing significantly fewer air pollutants and greenhouse gases 
than other alternatives, while offering high efficiency and reliability for generating 
electricity.  
6.
The data storage facility will operate daily 24 hours per day.  Each building of the data center will 
house digital servers, switches, and telecommunications equipment. To maintain optimal 
conditions, systems such as generators, batteries, electrical distribution, and cooling systems are 
used to regulate heat and airflow throughout the building. The data center will employ technicians 
with specialized expertise who will monitor and maintain the data systems either on site or 
remotely.  At this time the number of employees, type of screening, types of lighting, number of 
driveways, and amount of parking needed has not been finalized and will be determined in the 
Plan of Development stage. 
7.
Since data storage facilities are large water users to cool data storage equipment, the developer 
will ensure that water efficient designs will be utilized for this campus. This is stated in the 
attached letter, dated October 14, 2025, “The data storage facility is expected to use hybrid 
alternative cooling technology which allow for dry cooling during significant portion of the year to 
reduce annual water usage…..’   ‘The developer will be evaluating setting up a closed loop liquid 
system to minimize water consumption.” Other than cooling the data storage equipment, the data 
storage facility will require very little water for domestic water use and for fire protection. The 
applicant states that the developer anticipates on utilizing hauled water for some uses and 
working with the water rights holders in the Harquahala Basin if needed.  
8.
The IUPD proposes to vary several of the IND-2 zoning district’s development standards as listed 
in the table below.  Most of the requested varied standards are to match what was previously 
varied in the Maricopa Energy Center IUPD to maintain conformity.  One standard that is being 
varied that differs, is a reduced parking for data centers because they typically have a smaller 
number of employees per floor area square footage.  Another request is to increase the maximum 
structure height as data centers generally have tall parapets to screen rooftop equipment that will 
be used to cool the data storage servers. 
REGULATION
BASE ZONING DISTRICT 
REGULATIONS (IND-2)
PROPOSED ZONING DISTRICT 
REGULATIONS (IND-2 IUPD)
Maximum Height 
40'
                        103’
Minimum Front Yard
10'-25’*
10’ – 25’* None for solar panel 
arrays & 100’ for BESS
Minimum Side Yard
None & 5’**
5’** None for solar panel arrays 
& 100’ for BESS 
Minimum Street-side Yard
10'**
10’** None for solar panel 
arrays & 100’ for BESS
Minimum Rear Yard
None & 25'**
None & 25’** None for solar 
panel arrays & 100’ for BESS
Minimum Lot Area
6,000 sq. ft.
             6,000 sq. ft.
Minimum Lot Width *
60'
                   60'
Maximum Lot Coverage
60%
60%, solar panel arrays are not 
calculated as lot coverage
Parking Spaces
1 space per 600 sq. ft. of 
floor area of an industrial 
building 
Energy generation/energy 
storage: none required
Data Center: 1 per 1,000 sq. ft. 
of the ground floor then 1 per

CPA250002 & Z250015
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5,500 sq. for each remaining 
floor
Paving Regulations 
Driveways & parking areas 
must be paved
Driveways & parking areas must 
be paved, except for energy 
generation/energy storage 
which shall be stabilized 
decomposed granite with an 
approved MCAQ dust control 
plan 
Loading & Unloading 
1 space for every 10,000 
sq. ft. of an industrial 
building 
Minimum of 1 space for every 
building and none required for 
energy generation/energy 
storage facility
Sight Visibility Triangles
No obstruction over 2’ in 
height with the triangle 
No obstruction over 2’ in height 
with the triangle.  Energy 
generation/energy storage: 
None
Uses/Building Enclosures
All uses except for 
parking, loading, 
unloading, or storage 
shall be conducted inside 
an enclosed building
All uses except for parking, 
loading, unloading, storage, 
electrical generation, electrical 
storage, electrical transmission, 
and data center infrastructure 
shall be conducted inside an 
enclosed building. 
Screening
Min. 6’ tall solid wall 
around the perimeter & to 
screen outdoor industrial 
uses. 
Min. 6’ tall chain link 
fencing/gates without attached 
screening materials with 1’ of 
attached barbed wire on top of 
any fence.  Max. 12’ tall 
aluminum anti-climb fencing 
shall be allowed inside a 
required setback. Special 
wildlife compatible fencing shall 
be allowed if warranted by 
AZG&F Dept. 
Maximum Electrical 
Transmission Support 
Structures
                       120’
                        196’
Aerial photos of subject site

CPA250002 & Z250015
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Aerial image & surrounding environs

CPA250002 & Z250015
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CPA250002 & Z250015
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                                                                                                Land Use Exhibit 
                                                                                Portion of the Zoning Exhibit

CPA250002 & Z250015
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                                                                       Zoning Map 
                                                                  Land Use Designations

CPA250002 & Z250015
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Existing On-Site and Adjacent Zoning / Land Use:
9.
On-site:
Rural-43 & IND-2 IUPD / Natural desert & vacant
North:
Rural-43 / Natural desert
South:
Rural-43 / Agricultural & vacant
East:
Rural-43 & IND-2 IUPD / Natural desert
West:
IND-2 IUPD & Rural-43 / Agricultural & natural desert
Utilities and Services:
10.
Water:
Hauled water and well
Wastewater:
Septic system
School Districts:
Buckeye Union High School District
Arlington School District
Fire:
Harquahala Valley Fire District
Police: 
MCSO 
Right-of-Way:
11.
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.  It should be noted without a precise site plan nor a traffic study, right-
of-way preservation or right-of-way dedication cannot be determined at this time.  MCDOT is 
requesting that all perimeter section lines shall reserve a half-width right-of-way of 55’ and all 
perimeter mid-section lines shall reserve a half-width right-of-way of 40’. Moreover, any adjacent 
setback to these perimeter section and mid-section lines shall be added to the reserved half-width 
right-of-way. 
Street Name
Half-width 
Existing R/W
Half-width 
Proposed R/W
Future Classification
Salome Hwy. (north half)
        65’
         65’
          Principle Arterial Roadway
Salome Hwy. (south half)
        65’
         65’
          Principle Arterial Roadway
Adopted Plan:
12.
Vision 2030 Comprehensive Plan (adopted 1/13/16): The plan designates this site as Rural 
Development Area with a maximum density of one dwelling unit per gross acre, suitable for 
agricultural related uses and residential land uses. On 30% of this site has a designated land use 
of Utilities, via CPA2020002 major CPA.   
Public Participation Summary:
13.
The applicant complied with the requirements of the citizen review process with the required 
posting of the site and notification by first class mail to interested parties and adjacent property 
owners within 300’ of the subject parcel. Signs were posted on the site, in accordance with 
applicable regulations. As to the writing of this report, neither applicant nor staff have received 
any support or opposition from the public.
Outstanding Concerns from Reviewing Agencies:
14.
N/A

CPA250002 & Z250015
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Staff Analysis:
15.
Staff supports the general CPA designating on the entirety of the site for Utilities land uses. This 
creates one unified designated land use for the entire site to accommodate the rezoning and 
proposed use. 
16.
This proposal to expand the footprint of the Maricopa Energy Center into adjacent parcels and 
state trust land. It will facilitate expansion of solar power generation, power storage, and data 
center facilities to an ever growing electrical and data demand. The demand for data storage 
continues to increase to keep up with the needs of internet servers, artificial intelligence, 
healthcare, and many other needs. Placing a data center in this location adjacent to the Maricopa 
Energy Center equates to 30,000 acres of solar power generation that will, once fully on-line, 
produce enough power for a data storage facility with surplus energy to provide to the electric 
grid. Another benefit of placing a data storage facility at an isolated site with very few residents 
nearby is that the noise produced from the facility will not adversely impact residential 
neighborhoods. 
17.
Data storage facilities use large amounts of water to cool the heated servers that are 
storing/transmitting the data. However, technology is evolving to address this issue with 
alternative methods, such as liquid immersion cooling fluids, geothermal cooling, dry cooling, and 
heat re-use systems. The site is outside the Phoenix Active Management Area and is located over 
an aquifer within the Harquahala Valley Irrigation District that has been used for agriculture for 
many years. This  water may potentially provide water to cool the facility but will equate to less 
water consumption than the previous agricultural use of the land if alternative data server cooling 
is utilized. Staff supports this request does recognize concern over water use. As a condition of 
this request the developer must demonstrate the use of alternative cooling systems that do not 
use water to cool overheated servers. The CPA narrative report does mention that the developer 
will encourage innovative cooling technologies for operational purposes that does not need water 
for cooling. This was furthered in a correspondence received from the applicant that mentioned 
that alternatives such as a closed loop liquid cooled systems will be used for this facility. Staff’s 
position is that this facility is appropriate but that alternative cooling methods should be utilized 
that do not require high water use as a cooling method, especially when there will be only a few 
workers on site at any one time. 
18.
Staff recommend the Commission adopt a motion recommend that the Board of Supervisors 
approve CPA250002. 
19.
Staff recommends the Commission adopt a motion recommending that the Board of Supervisors 
approve Z250015 subject to the following conditions ‘a’ – ‘l’:
a.
Development of the site shall be in substantial conformance with the Zoning Exhibit 
entitled “Harquahala Energy Generation & Industrial Campus (HEGIC)“, consisting of two 
full-size sheets, dated September 16, 2025 , and stamped received October 6, 2025, except 
as modified by the following conditions. Staff may determine slight refinements to remain 
in substantial conformance with the approved site plan.  Minor and major amendments to 
the site plan will be determined in accordance with Chapter 3 of the Maricopa County 
Zoning Ordinance.
b.
Development of the site shall be in substantial conformance with the Narrative Report 
entitled “Harquahala Energy Generation & Industrial Campus”, consisting of 11 pages,

CPA250002 & Z250015
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dated September 16, 2025, and stamped received October 6, 2025, except as modified by 
the following conditions.
c.
The following Planning Engineering conditions shall apply:
1.
Without the submittal of a precise plan of development, no development approval 
is inferred by this review, including, but not limited to number of proposed building 
lots/units, drainage design, access and roadway alignments. These items will be 
addressed as development plans progress and are submitted to the County for 
further review and/or entitlement.
2.
Each phase of development will require a plan of development and Traffic Impact 
Study. Each phase must be able to stand alone with respect to site infrastructure, 
including utilities, access and storm water management.
3.
Salome Highway is classified as a principal arterial requiring fee dedication of a
65-foot half street from the center line, total 130-feet. With the submittal of a Plan 
of Development on this site the applicant shall provide, at applicant’s expense, an 
American Land Title Association(“ALTA”) Owner’s Policy of Title Insurance 
showing title vested in Maricopa County, a political subdivision of the State of 
Arizona.
4.
Any additional dedication and offsite improvement requirements will be 
determined by MCDOT Traffic based on a submitted TIA/TIS to Permit Center at 
https://www.maricopa.gov/6003/Maricopa-Countys-New-Permit-Center and if a 
Traffic Impact Analysis/Traffic Impact Study has been previously submitted, the 
Traffic Impact Analysis/Traffic Impact Study must be less than one year old. 
5.
All perimeter section line and mid-section line alignments of the proposed 
development require the setback lines to start from a future half street Right-of-
Way of 55’ for section lines and 40’ for mid-section lines (respectively) per the 
Maricopa County Zoning Ordinance Section 1105.
6.
Applicant is to notify ADOT of proposed project through the Red Letter Process, 
RedLetter@azdot.gov , due to the proximity to the Interstate-10 Freeway.
7.
The above comments do not include identification of utilities or underground 
facilities within or adjacent to the required right-of-way that may have prior rights 
and/or require relocation.
8.
Engineering review of re-zone cases is conceptual in nature. All development and 
engineering design shall be in conformance with Section 1205 of the Maricopa 
County Zoning Ordinance; Drainage Policies and Standards; Floodplain 
Regulations for Maricopa County; MCDOT Roadway Design Manual; and current 
engineering policies, standards and best practices at the time of application for 
construction.
d.
With the submittal of any Plan of Development for a data storage facility, the applicant 
shall incorporate water efficient designs, which may include hybrid alternative cooling 
technologies, to reduce annual water usage.

CPA250002 & Z250015
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e.
The IUPD overlay is applied to restrict the use of the site. The IUPD shall limit the use of 
the site exclusively to solar electric generating facilities, gas generation facility, battery 
energy storage system (BESS) and data storage facilities, including ancillary offices, 
ancillary uses, and existing agricultural uses. Any other uses of the site shall require a 
zone change major amendment.
f.
Unless waived or modified by the County, the applicant or developer shall implement the 
best practices and any recommendations by the Arizona Game and Fish Department 
(AZGFD). The Zoning Inspector and/or their designee shall review whether these best 
practices are being implemented in accordance with the letter following the issuance of 
relevant permits and periodically as needed through either the inspection process or 
communication with AZGFD. Should the Zoning Inspector and/or their designee decide 
that the owner or developer has not substantially undertaken these best practices in good 
faith, the owner or developer shall not receive final permits or certificate of occupancy 
until the best practices are implemented.
g.
Administrative approval of a plan of development will be required prior to approval and 
issuance of construction permits to develop and establish use of the site. 
h.
Prior to issuance of a building permit, written confirmation will be required from the 
emergency fire protection jurisdiction having authority that the facility has been designed 
in accordance with their regulations and requirements, and that emergency fire protection 
service will be provided to the facility. Prior to issuance of the certificate of occupancy, 
local fire protection jurisdiction review and approval will be required.
i.
The developer must submit any project narrative to the Department of Defense Siting 
Clearinghouse for Energy, Installations, and Environmental for review at the following site: 
osd.dod-siting-clearinghouse@mail.mil prior to the submittal of any Plan of Development. 
j.
The following IND-2 IUPD standards shall apply: 
1.
There shall be a maximum structure height of 103’.
2.
There shall be no minimum setbacks for solar panel arrays and there shall be 
minimum setbacks of 100’ for battery electric storage systems. 
3.
Solar panel arrays shall not be calculated as lot coverage. 
4.
There shall be no parking required for solar generation facilities, gas generation 
facility, or battery storage facilities. 
5.
Data storage facilities shall provide one parking space for every 1,000 sq. ft. of 
floor area for the ground floor and one parking space for every 5,000 sq. ft. of floor 
area for each additional story. 
6.
Driveways and parking areas of solar generation, gas gereration, and battery 
storage facilities shall use decomposed granite with an approved dust control plan 
by MCAQ to minimize dust pollution from these surfaces. 
7.
There shall be a minimum of one loading/unloading space per building and none 
for solar energy generation, gas generation, and battery storage facilities.

CPA250002 & Z250015
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8.
There shall be no sight-visibility-triangles at any ingress/egress points along 
streets, or at the intersection of any section or mid-section line intersection 
alignments for solar generation, gas generation, and battery storage facilities. 
9.
All uses except for parking, loading, unloading, storage, electric generation, electric 
storage, electric transmission, and data center infrastructure shall be conducted 
within a completely enclosed building. 
10.
There shall be a minimum 6’ tall chain link fencing without attached screening 
materials along the perimeter of the site and outdoor industrial uses for screening.  
The fence shall provide 1’ of barbed wire atop of these 6’ tall fences and there shall 
be a maximum fence height of 12’ for any fence. If warranted by AZG&F 
Department these fences can be modified to allow wildlife to pass through these 
fences. 
11.
There shall be a maximum height of 196’ for structures that hold up electrical 
transmission lines, except with respect to structures that hold up electrical 
transmission lines, there shall be a maximum structure height of 103’.
k. 
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. 
l.
The granting of this change in use of the property has been at the request of the applicant, 
with the consent of the landowner.  The granting of this approval allows the property to 
enjoy uses in excess of those permitted by the zoning existing on the date of application, 
subject to conditions.  In the event of the failure to comply with any condition, the property 
may be considered for revocation to the zoning that existed on the date of application.  It 
is, therefore, stipulated and agreed that either revocation due to the failure to comply with 
any conditions, does not reduce any rights that existed on the date of application to use, 
divide, sell or possess the property and that there would be no diminution in value of the 
property from the value it held on the date of application due to such revocation of the 
Zone Change.  The Zone Change enhances the value of the property above its value as 
of the date the Zone Change is granted and reverting to the prior zoning results in the 
same value of the property as if the Zone Change had never been granted.
Presented by:
Martin Martell, Planner
Reviewed by:
Rachel Applegate, Planning Supervisor
Attachments:
CPA Case Map (1 page)
ZC Case Map (1 page
CPA Land Use Exhibit (reduced 8.5”x11”, 3 pages)
CPA Narrative Report (20 pages)
Zoning Exhibit (2 pages) 
ZC Narrative Report (11 pages)
MCESD comments (2 pages)
DPR comments (2 pages)
LAFB comments (1 page)
AZG&FD comments (6 pages)
Correspondence concerning Water Use (2 pages)

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Maricopa County Planning & Development - Phoenix, AZ
5
Gross Acres: 642 approx.
Generated October 27, 2025 11:07 AM
CPA250002
Application Name:
Legal Description
Harquahala Energy Generation & Industrial Campus
Applicant
Case Address
2N 9W 11, 2N 9W 13, 2N 9W 12
Keith Nichter
50219 W GLENDALE AVE
Applicant Phone/Email
Parcel Primary:506-18-018A
(602) 313-7206
keith.nichter@kimley-horn.com
TONOPAH, AZ 85354
Map scale 1:25,185
Supervisor District No.
A proposed General Comprehensive Plan Amendment from ‘Rural Development Area’ to ‘Utilities’ for the
Harquahala Energy Generation & Industrial Campus for 626.8 acres of land.

/
Maricopa County Planning & Development - Phoenix, AZ
5
Gross Acres: 949 approx.
Generated October 27, 2025 12:13 PM
Z250015
Application Name:
Legal Description
Harquahala Energy Generation & Industrial Campus
Applicant
Case Address
2N 9W 13, 2N 9W 12, 2N 9W 11
Keith Nichter
50219 W GLENDALE AVE
Applicant Phone/Email
Parcel Primary:506-18-018A
(602) 313-7206
keith.nichter@kimley-horn.com
TONOPAH, AZ 85354
Map scale 1:25,185
Supervisor District No.
A proposed zone change with Overlay from from ‘RU-43’ (Rural) and IND-2 IUPD (Light Industrial) to
IND-2 IUPD (Light Industrial) for the Harquahala Energy Generation & Industrial Campus for 1,023 acre

506-18-018A
506-18-029F
506-18-017D
506-18-016B
506-18-016C
506-18-022R
506-18-022F
506-18-022S
506-18-022L
506-18-022M
506-18-022N
506-18-
024B
T2N R9W
T2N R8W
11
14
13
18
17
12
07
08
ARIZONA STATE LAND
DEPARTMENT
(ASLD)
BUREAU
OF LAND
MANAGEMENT
(BLM)
ARIZONA STATE LAND
DEPARTMENT
(ASLD)
N HARQUAHALA VALLEY RD
N HARQUAHALA VALLEY RD
W SALOME HWY
W SALOME HWY
W CAMELBACK RD
W CAMELBACK RD
N 499TH AVE
N 499TH AVE
N 507TH AVE
N 507TH AVE
N 491ST AVE
N 491ST AVE
INTERSTATE 10 (I-10)
INTERSTATE 10 (I-10)
506-18-023
506-18-022K
506-18-022J
506-18-018A
NOT A PART
506-18-
019A
506-18-019C
506-18-
024A
506-18-019B
W SALOME HWY
W SALOME HWY
HARQUAHALA ENERGY
GENERATION &
INDUSTRIAL CAMPUS
HARQUAHALA ENERGY
GENERATION &
INDUSTRIAL CAMPUS
MARICOPA
ENERGY
CENTER (MEC)
MARICOPA
ENERGY
CENTER (MEC)
N
0'
DRAWN BY: JK
SCALE: APPROX.
600
1,200'
PROPOSED LAND USE DESIGNATION
MARICOPA COUNTY, AZ
PROPOSED CPA LAND USE DESIGNATION
03/03/2025
HARQUAHALA ENERGY GENERATION & INDUSTRIAL CAMPUS
RURAL DEVELOPMENT AREA
LEGEND
UTILITIES
ARIZONA STATE LAND
DEPARTMENT (ASLD)
BUREAU OF LAND
MANAGEMENT (BLM)
TOWNSHIP/RANGE
HARQUAHALA ENERGY
GENERATION & INDUSTRIAL CAMPUS
CPA AREA
(+/-637.86 AC.)
10
11
12
13
HARQUAHALA ENERGY
GENERATION & INDUSTRIAL CAMPUS
ZONE CHANGE AREA
(+/-917.36 AC.)
Received 21. APR 25
CPA250002 - 1. Sub

506-18-018A
506-18-029F
506-18-017D
506-18-016B
506-18-016C
506-18-022R
506-18-022F
506-18-022S
506-18-022L
506-18-022M
506-18-022N
506-18-
024B
T2N R9W
T2N R8W
11
14
13
18
17
12
07
08
ARIZONA STATE LAND
DEPARTMENT
(ASLD)
BUREAU
OF LAND
MANAGEMENT
(BLM)
ARIZONA STATE LAND
DEPARTMENT
(ASLD)
N HARQUAHALA VALLEY RD
N HARQUAHALA VALLEY RD
W SALOME HWY
W SALOME HWY
W CAMELBACK RD
W CAMELBACK RD
N 499TH AVE
N 499TH AVE
N 507TH AVE
N 507TH AVE
N 491ST AVE
N 491ST AVE
INTERSTATE 10 (I-10)
INTERSTATE 10 (I-10)
506-18-023
506-18-022K
506-18-022J
506-18-018A
NOT A PART
506-18-
019A
506-18-019C
506-18-
024A
506-18-019B
W SALOME HWY
W SALOME HWY
HARQUAHALA ENERGY
GENERATION &
INDUSTRIAL CAMPUS
HARQUAHALA ENERGY
GENERATION &
INDUSTRIAL CAMPUS
MARICOPA
ENERGY
CENTER (MEC)
MARICOPA
ENERGY
CENTER (MEC)
N
0'
DRAWN BY: JK
SCALE: APPROX.
600
1,200'
EXISTING LAND USE DESIGNATION
RURAL DEVELOPMENT AREA
LEGEND
UTILITIES
ARIZONA STATE LAND
DEPARTMENT (ASLD)
BUREAU OF LAND
MANAGEMENT (BLM)
TOWNSHIP/RANGE
HARQUAHALA ENERGY
GENERATION & INDUSTRIAL CAMPUS
CPA AREA
(+/-637.86 AC.)
10
11
12
13
HARQUAHALA ENERGY
GENERATION & INDUSTRIAL CAMPUS
ZONE CHANGE AREA
(+/-917.36 AC.)
MARICOPA COUNTY, AZ
EXISTING CPA LAND USE DESIGNATION
03/03/2025
HARQUAHALA ENERGY GENERATION & INDUSTRIAL CAMPUS
Received 21. APR 25
CPA250002 - 1. Sub

506-18-018A
506-18-029F
506-18-017D
506-18-016B
506-18-016C
506-18-022R
506-18-022F
506-18-022S
506-18-022L
506-18-022M
506-18-022N
506-18-
024B
T2N R9W
T2N R8W
11
14
13
12
ARIZONA STATE LAND
DEPARTMENT
(ASLD)
W CAMELBACK RD
W CAMELBACK RD
N 499TH AVE
N 499TH AVE
N 507TH AVE
N 507TH AVE
INTERSTATE 10 (I-10)
INTERSTATE 10 (I-10)
506-18-023
506-18-022K
506-18-022J
506-18-018A
NOT A PART
506-18-
019A
506-18-019C
506-18-
024A
506-18-019B
W SALOME HWY
W SALOME HWY
HARQUAHALA ENERGY
GENERATION &
INDUSTRIAL CAMPUS
HARQUAHALA ENERGY
GENERATION &
INDUSTRIAL CAMPUS
MARICOPA
ENERGY
CENTER (MEC)
MARICOPA
ENERGY
CENTER (MEC)
506-18-018A
506-18-029F
506-18-017D
506-18-016B
506-18-016C
506-18-022R
506-18-022F
506-18-022S
506-18-022L
506-18-022M
506-18-022N
506-18-
024B
T2N R9W
T2N R8W
11
14
13
12
ARIZONA STATE LAND
DEPARTMENT
(ASLD)
W CAMELBACK RD
W CAMELBACK RD
N 499TH AVE
N 499TH AVE
N 507TH AVE
N 507TH AVE
INTERSTATE 10 (I-10)
INTERSTATE 10 (I-10)
506-18-023
506-18-022K
506-18-022J
506-18-018A
NOT A PART
506-18-
019A
506-18-019C
506-18-
024A
506-18-019B
W SALOME HWY
W SALOME HWY
HARQUAHALA ENERGY
GENERATION &
INDUSTRIAL CAMPUS
HARQUAHALA ENERGY
GENERATION &
INDUSTRIAL CAMPUS
MARICOPA
ENERGY
CENTER (MEC)
MARICOPA
ENERGY
CENTER (MEC)
N
0'
DRAWN BY: JK
SCALE: APPROX.
600
1,200'
PROPOSED LAND USE DESIGNATION
EXISTING LAND USE DESIGNATION
BLM
BLM
ASLD
ASLD
MARICOPA COUNTY, AZ
EXISTING/PROPOSED CPA LAND USE DESIGNATION
03/03/2025
HARQUAHALA ENERGY GENERATION & INDUSTRIAL CAMPUS
RURAL DEVELOPMENT AREA
LEGEND
UTILITIES
ARIZONA STATE LAND
DEPARTMENT (ASLD)
BUREAU OF LAND
MANAGEMENT (BLM)
TOWNSHIP/RANGE
HARQUAHALA ENERGY
GENERATION & INDUSTRIAL CAMPUS
CPA AREA
(+/-637.86 AC.)
10
11
12
13
HARQUAHALA ENERGY
GENERATION & INDUSTRIAL CAMPUS
ZONE CHANGE AREA
(+/-917.36 AC.)
Received 21. APR 25
CPA250002 - 1. Sub

kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Vicinity Map 
 
General Location: The proposed Project is located in an unincorporated portion of western Maricopa County. 
The site, currently vacant, is located 11 miles west of Tonopah, at the SEC of Salome Highway and Harquahala 
Valley Road, in the Harquahala Valley area in Township 2 North, Range 9 West, Sections 11,12 & 13. 
 
 
 
 
 Revised: 09/16/2025 
HARQUAHALA ENERGY GENERATION 
& INDUSTRIAL CAMPUS 
CASE #: CPA250002                                                                              
REQUEST: General Comprehensive Plan Amendment from Rural Densities (0-1) 
to Utilities on Approximately ±637.86 Acres 
NARRATIVE REPORT 
RECEIVED 6.OCT 25
CPA250002 -- 2.SUB

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1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
 
 
 
 
 
 
TABLE OF CONTENTS 
A. EXECUTIVE SUMMARY ..................................................................................... Error! Bookmark not defined. 
I. ON-SITE AND REGIONAL LOCATION .................................................................................................................................... 4 
II. CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY ACREAGE ................................................................................. 4 
III. ROADS/TRANSPORTATION SYSTEMS SERVING THE PROPOSED PROJECT ............................................................... 4 
IV. SUITABILITY WITH SURROUNDING USES ......................................................................................................................... 5 
B. WHETHER THE AMENDMENT CONSTITUTES AN OVERALL IMPROVEMENT TO THE 
COMPREHENSIVE PLAN AND IS NOT SOLELY FOR THE GOOD OR BENEFIT OF A 
PARTICULAR LANDOWNER OR OWNERS AT A PARTICULAR POINT IN TIME .................................. 7 
C. THE AMENDMENT WILL NOT ADVERSELY IMPACT ALL OR A PORTION OF THE PLANNING 
AREA BY: *EACH CRITERION IS ADDRESSED SEPARATELY WITH THE CRITERIA LISTED AND 
GENERAL RESPONSES TO THE CRITERIA CITED AS SUBHEADINGS IN THE PROCEEDING 
SUBSECTIONS BELOWS: ................................................................................................................................... 8 
I. ALTERING ACCEPTABLE LAND USE PATTERNS TO THE DETRIMENT OF THE PLAN .................................................... 8 
II. REQUIRING PUBLIC EXPENDITURES FOR LARGER AND MORE EXPENSIVE INFRASTRUCTURE ............................... 9 
III. REQUIRING PUBLIC IMPROVEMENTS TO ROADS, SEWER, OR WATER SYSTEMS THAT ARE NEEDED TO 
SUPPORT THE PLANNED LAND USES ................................................................................................................................... 10 
IV. ADVERSELY IMPACTING PLANNED USES BECAUSE OF INCREASED TRAFFIC ......................................................... 10 
V. AFFECTING THE LIVABILITY OF THE AREA OR HEALTH OR SAFETY OF PRESENT AND FUTURE RESIDENTS ...... 11 
VI. ADVERSELY IMPACTING THE NATURAL ENVIRONMENT OR SCENIC QUALITY OF THE AREA IN CONTRADICTION 
TO THE PLAN ............................................................................................................................................................................ 11 
D. WHETHER THE AMENDMENT IS CONSISTENT WITH OVERALL INTENT OF THE 
COMPREHENSIVE PLAN: .................................................................................................................................. 12 
E. THE EXTENT TO WHICH THE AMENDMENT IS CONSISTENT WITH THE SPECIFIC GOALS AND 
POLICIES CONTAINED WITHIN THE PLAN: ................................................................................................. 13 
F. COMPREHENSIVE PLAN AMENDMENT EXHIBITS ................................................................................ 20 
G. COMPREHENSIVE PLAN AMENDMENT LEGAL DESCRIPTIONS EXHIBITS ................................. 21 
APPENDIX A: SITE PARCELS .......................................................................................................................... 22 
 
 
PROJECT TEAM
 
DEVELOPER  
 
         PLANNING/ENTITLEMENTS         ENGINEERING 
 
Harquahala Campus LLC              Kimley-Horn 
 
                  Kimley-Horn 
 
Contact: Dallas Pugh        
         Contact: Keith Nichter                    Contact: Brett Stroup  
619.208.0853  
 
         602.313.7206 
 
                  480.561.1438 
Dallas.Pugh@Copiapower.com            Keith.Nichter@Kimley-Horn.com          Brett.Stroup@Kimley-Horn.com

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1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
A. EXECUTIVE SUMMARY 
Kimley-Horn, on behalf of Harquahala Campus LLC (the “Applicant”) with the permission of the subject nine (9) 
property owners, identified in Appendix A, is requesting a General Comprehensive Plan Amendment of the Vision 
2030 Comprehensive Plan, with the Maricopa County Planning & Development Department, to change the land 
use designation on a portion of (±637.86 acres) the Project from Rural Development Area to Utilities to match the 
surrounding approvals. The General CPA request is accompanied by a concurrent Zone Change with Overlay 
request to rezone the underlying parcels from RU-43 & IND-2 IUPD to IND-2 IUPD to allow for the development of 
the ±917.36-acre Harquahala Energy Generation & Industrial Campus (HEGIC) (the “Project”), as a part of the 
overall Maricopa Energy Center (MEC) project.   
In addition to the utility-scale solar energy generation and battery energy storage system (BESS) uses currently 
allowed within the surrounding MEC project, this proposal will look to make a significant investment within Maricopa 
County, providing residents with crucial digital services, with the development of data centers along with additional 
energy generation uses such as gas generating facilities and other ancillary uses. 
With data centers becoming critical infrastructure in today’s digital world, HEGIC looks to address this growing need 
by providing for the storage, processing, and transmission of the massive volumes of data that are generated every 
second. As individuals, businesses, and governments increasingly rely on cloud computing, streaming services, e-
commerce, remote work, and connected devices, the need for secure, reliable, and high-performance computing 
environments has never been greater. This development of data centers will support everything from financial 
transactions and healthcare systems to emergency services and communications, acting as the backbone of the 
global digital economy. Without addressing the need for these uses, modern digital services and technologies 
simply could not function. 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 1 – Site Context Map – Existing Comprehensive Plan Land Uses

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1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
I. ON-SITE AND REGIONAL LOCATION 
HEGIC is approximately 11 miles west of Tonopah within the Harquahala Valley area and is located south 
of Interstate 10 (I-10), north of the Camelback Road and between 499th Avenue and 507th Avenue, as 
shown in Exhibit 1 – Site Context Map – Existing Zoning,  in Township 2 North, Range 9 West, sections 11, 
12, & 13.    
II. CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY ACREAGES 
The General CPA is inclusive of thirteen (13) parcels which are held under nine (9) owners. The cumulative 
area of the property included in the General CPA request is ±637.86 acres. The parcels considered under 
this General CPA are listed in Appendix A. 
The existing land use designation for the site is Rural Densities (0-1) which is intended to conserve and 
protect open land uses, foster orderly growth in rural and agricultural areas, to prevent urban and 
agricultural land use conflicts, and to encourage sustainable development. The current RU-43 zoning 
district is intended to have residential densities of one (1) dwelling unit per acre (du/ac). Principal permitted 
uses in the Rural zoning districts include both farming and non-farming related residential uses, farms, and 
recreational and institutional uses. The proposed Utilities land use and corresponding IND-2 IUPD (Light 
Industrial) zoning will be consistent with surrounding approvals necessary to develop the proposed energy 
generation & industrial campus. 
III. ROADS/TRANSPORTATION SYSTEMS SERVING THE PROPOSED 
PROJECT 
The roadway network serving the proposed Project from the Interstate 10 corridor includes the I-10/Salome 
Highway interchange that connects to the Salome Highway which provides access to 499th and 507th 
Avenues south to Camelback Road. Specific site access points will be identified with the subsequent Plan 
of Development with final access locations, as coordinated with MCDOT, in accordance with access 
management policies and permitting requirements of Maricopa County. 
HEGIC will, at a minimum, preserve 65’ half street right-of-way for Salome Highway and a minimum of 55’ 
half street(s) right-of-way for Camelback Road, 507th Avenue and 499th Avenue. Per Maricopa County 
Zoning Ordinance Section 1105, HEGIC will provide the necessary setbacks starting from the future half 
street rights-of-way of 65’ and 55’ respectively. Offsite improvements and any additional right-of-way 
needed will be determined by MCDOT Traffic Design and MCDOT Permits based on the submittal of a 
TIA/TIS during the Plan of Development phase. Final dedication, preservation, alignments, terminations, 
and vacations of unneeded ROW will be determined in negotiation with MCDOT. 
Internal circulation is planned via a network of private driveways and maintenance and service drive aisles 
to provide vehicular access to the proposed facilities. For all solar, BESS and energy generation uses, 
driveway aprons (as specified by MCDOT), shall be paved with a minimum asphalt millings bound with a 
liquid binding emulsifier, or comparable, with the remainder of the typical 20’ internal drives being 
compacted decomposed granite (DG), or similar road base material to minimize imperviousness and 
stormwater runoff, as proposed with an approved dust control permit from Maricopa County Air Quality

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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
Control. Construction and maintenance of the drives will conform to applicable requirements of the 
Maricopa County Air Quality Control Department  
HEGIC’s proposed reduced parking requirements, as a part of the concurrent IUPD, are because the 
operational model of the proposed uses differ significantly from traditional industrial facilities. Data centers 
are highly automated and require less on-site staff, even in large-scale operations. Unlike office buildings 
or warehouses that experience high employee density and regular customer or vendor traffic, data centers 
typically have a smaller, rotating crew of technicians, engineers, and security personnel on duty at any 
given time. Requiring standard industrial parking ratios, based on square footage rather than actual staffing 
needs, results in excessive, unused paved areas that waste land, increase stormwater runoff, and reduce 
overall site efficiency. A more appropriate, reduced parking standard would better reflect real-world usage, 
minimize environmental impacts, and support smarter land use planning. 
IV. SUITABILITY WITH SURROUNDING LAND USES 
As seen in Table B – Surrounding Adjacent General Land Descriptions, the Project is vacant property 
surrounded by other vacant and agricultural lands. HEGIC would look to complement the other land uses 
in the greater Harquahala Valley area which include a host of existing and planned renewable energy 
production centers, battery energy storage facilities and industrial uses. These uses take advantage of the 
areas remoteness and existing infrastructure, anchored by the nearby Harquahala Power Plant located a 
few miles to the south. 
Table B – Surrounding Adjacent General Land Descriptions 
Direction 
Zoning 
Land Use Designation 
Current Use  
Site 
IND-2 IUPD/RU-43 
Utilities/Rural Development Areas 
Vacant 
North 
RU-43 
Rural Development Areas 
Vacant/Interstate 10 
East 
IND-2 IUPD/RU-43 
Utilities/Rural Development Areas 
Vacant 
South 
RU-43 
Rural Development Areas 
Agricultural/Vacant 
West 
IND-2 IUPD/RU-43 
Utilities/Rural Development Areas 
Agricultural/Vacant 
With this proper planning and strategic site selection, HEGIC addresses the primary concern associated 
with the increasing regional demand for data centers: the risk of developments encroaching upon residential 
and commercial areas, thereby disrupting neighboring communities. In response, Harquahala Campus LLC 
is committed to developing a master-planned campus that offers a cohesive framework for future data 
center construction and energy generation—strategically located to minimize community impact and 
maximize access to critical infrastructure.

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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
HEGIC looks to expand upon the ongoing 
improvements being constructed as a part of the 
recently approved Maricopa Energy Center 
(CPA2020002, Z2023133, PD240017) project. 
In addition to MEC, many of the surrounding 
parcels around the Project have been subject to 
previous entitlements and approvals, by the 
Board of Supervisors, including the Applicants 
Harquahala Sun projects. Overall, there are 
roughly 
30,000 
acres 
of 
Utility/Industrial 
approvals within the immediate Harquahala 
Valley area, making HEGIC a natural fit for this 
location. In addition to improving reliability, co-
locating with solar and BESS infrastructure 
supports 
long-term 
cost 
savings 
and 
sustainability goals. Additionally, offering more 
energy generation options provides significant 
operational, 
environmental, 
and 
economic 
advantages. Data centers operate around the 
clock and require a highly reliable power supply. 
It also reduces reliance on traditional utilities 
and mitigates exposure to unreliable energy 
sources. From a land-use and planning 
perspective, solar farms and battery systems 
complement data center campuses well, as they 
generate limited traffic and noise. This strategic 
pairing 
demonstrates 
a 
commitment 
to 
responsible 
development. 
Ultimately, 
this 
synergy promotes faster project deployment, energy independence, and sensitivity to the surrounding 
community. 
In addition to these planned utility and industrial developments, as shown in Exhibit 2 – Surrounding 
Utilities/Industrial Land Uses and Table C – Existing Surrounding Solar (Utility) Land Use Approvals, the 
surrounding area is mainly characterized by active and passive agricultural land uses, Bureau of Land 
Management (BLM) and Arizona State Land Department (ASLD) owned and managed lands, native desert 
lands along with a few sparsely distributed residential land uses.  
The proposed General CPA and Zone Change with Overlay to allow for uses permitted in the IND-2 zoning 
district including solar electric generating facilities, battery energy storage system (BESS), ancillary offices, 
data centers, electrical distribution facilities, roof and ground mounted mechanical and solar systems, gas 
generating facilities, substations, other power equipment, and water storage and treatment are compatible 
with the approved and/or implemented mixture of surrounding approvals. These approvals include solar 
projects, BESS, a hydrogen facility, utility corridors, transmission lines, substations, a gas generation power 
plant and industrial uses all within an approximately 5-mile radius of the Project site. Also, compared to 
residential development, permissible under the current zoning, the data center requires fewer public 
services and infrastructure support. Similar to these approvals, no landscaping is proposed or required. 
Other site details will be coordinated during the subsequent Plan of Development (POD) submittal including 
Exhibit 2 – Surrounding Utilities/Industrial Land Uses

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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
further coordination with the Arizona Game and Fish Department based on the development of the specific 
site plan. Additionally, because this area is near several military training routes (MTRs) in the area, the 
Project will be submitted for an informal review through the DoD Siting Clearinghouse for Energy, 
Installations, and Environment 
Moreover, the Project aligns with the County’s 2030 Vision by fostering a high-tech economic environment 
offering quality employment opportunities available to residents in the county’s far west region. Jobs within 
the data center sector typically offer strong wages, with many roles accessible to local residents who 
possess relevant technical skills. Overall, job opportunities in computer and information technology-related 
fields are projected to grow at a rate well above the national average. 
Table C – Existing Surrounding Solar (Utility) Land Use Approvals 
Project 
Location (Township/Range) 
Maricopa Solar and Storage Project 
T1N R8W; T1N R9W; T2N R8W; T2N R9W 
Harquahala Sun 
T1N R9W 
Harquahala Sun II and III 
T1N R9W 
Saddle Mountain Solar I and II 
T1N R9W 
Eagletail Solar Farm 
T1S R9W 
Areva Solar AZ II 
T2N R7W 
Almeria Solar 
T2N R8W 
Sun Valley North 
T2N R8W 
Sun Valley South 
T2N R8W 
Maricopa Energy Center 
T2N R8W; T2N R9W 
Papago Solar 
T2N R8W 
Tonopah Photovoltaic 
T2N R8W 
 
B. WHETHER 
THE 
AMENDMENT 
CONSTITUTES 
AN 
OVERALL 
IMPROVEMENT TO THE COMPREHENSIVE PLAN AND IS NOT SOLELY 
FOR THE GOOD OR BENEFIT OF A PARTICULAR LANDOWNER OR 
OWNERS AT A PARTICULAR POINT IN TIME. 
Per the Vision 2030 Maricopa County Comprehensive Plan (2016), Comprehensive Plan Amendments should 
improve the county’s overall condition and not undermine the plan’s core principles. The Plan recognizes the need 
to redesignate land uses in response to dynamic, flexible, and constantly changing markets and businesses, 
understanding that that information technology is fundamental to all types of businesses. The HEGIC amendment 
looks to further the plans policies to promote economic growth and to address the increasing demands of this growth 
related to the public infrastructure needs, specifically energy generation and consumption demands within the local 
economy.  
Energy resources significantly impact economic development by contributing to the region’s overall attractivity on 
basic and corresponding non-basic employment, primary and secondary employment sectors and markets, and 
research and development within existing and emerging markets and industries. Additionally, energy availability

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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
and even surplus opportunities function as an incubator for innovations within all segments of the local, regional, 
and state economy.  
This Project is intended to promote and incentivize the production and delivery of energy resources that meet and 
otherwise support consumption needs of existing and emerging markets which benefit the regional and state 
economies and tax bases. The availability of efficient energy and the resulting cost savings, both immediate and 
over time, creates opportunity for reinvestment of public and private capital back into the local and regional 
economy. 
The proposed data centers are specialized facilities designed for the centralized management of electronic data. 
These campuses consist of buildings equipped with computing and networking hardware, as well as power and 
cooling infrastructure. Their primary function is to store, process, manage, and distribute vast quantities of data 
while ensuring secure and reliable access. These facilities play a vital role in modern life, enabling communication, 
telehealth, remote work, and media streaming. They're also essential to sectors like energy, healthcare, retail, 
aviation, automotive, entertainment, and government operations. 
Operating 24/7, data centers can be supported by additional infrastructure such as power generation, energy 
distribution, and storage systems. Inside, they can house servers, switches, and telecommunications gear. To 
maintain optimal conditions, systems such as generators, batteries, electrical distribution, and cooling systems are 
used to regulate heat and airflow. 
Technicians with specialized expertise monitor and manage these systems in accordance with best practices and 
manufacturer guidelines. Many modern centers can have automated systems to oversee real-time performance 
and ensure consistent uptime, excluding planned downtime for maintenance or upgrades. Given the high 
investment in both infrastructure and technology, these facilities maintain strict physical security measures in the 
form of perimeter fencing, controlled access, and on-site personnel. 
Development of HEGIC will represent a significant investment within the County. In addition to permanent campus 
employment, the Project will generate substantial economic activity during its development, including hundreds of 
construction, utility, and support service jobs. Once operational, HEGIC will contribute significantly to the local 
economy through both real and property taxes, helping to fund public services and infrastructure within Maricopa 
County.   
C. THE AMENDMENT WILL NOT ADVERSELY IMPACT ALL OR A PORTION 
OF THE PLANNING AREA BY: *EACH CRITERION IS ADDRESSED 
SEPARATELY WITH THE CRITERIA LISTED AND GENERAL RESPONSES 
TO THE CRITERIA CITED AS SUBHEADINGS IN THE PROCEEDING 
SUBSECTIONS BELOW: 
I. ALTERING ACCEPTABLE LAND USE PATTERNS TO THE 
DETRIMENT OF THE PLAN. 
The proposed General CPA will not alter the acceptable land use patterns in the planning area in an adverse 
manner to the detriment of the plan. The proposed change in land use is consistent with existing approved 
utility and industrial land use patterns in the area. Previous land use approvals should not be construed to

Page 9 
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1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
imply future precedents, nor obligate future Board of Supervisor decisions. However, the infrastructure 
investment and development within this portion of the planning area make the Project site a more suitable 
and logical location for future development of industrial and power generation uses.  Approval of the 
General CPA is consistent with this strategy and the utility and industrial pattern that has been established 
in the surrounding area by recent BOS approvals in favor of industrial, large-scale power generation and 
storage facilities within this remote area. Additionally, the remote location and surrounding land uses 
minimize impacts to neighbors and lessen the impact to the environment based on proximity to the 
surrounding infrastructure. 
The land use change from Rural Densities (0-1) to Utilities, to accommodate the proposed uses, is in 
substantial conformance with economic growth and energy policies identified in the Plan, increasing the 
county’s investment (in terms of land use planning) in local cloud-based infrastructure, power generation 
and storage facilities. HEGIC will have a long-term tangible impact addressing the need to store, process, 
and distribute vast amounts of digital data and lowering the costs of energy production, delivery, and 
consumption.  
II. REQUIRING PUBLIC EXPENDITURES FOR LARGER AND MORE 
EXPENSIVE INFRASTRUCTURE. 
Any expenditures for larger and more expensive infrastructure that are required as a result of the 
development shall be borne by the developer. Improvements for adjacent access road, as coordinated with 
the county, will be borne solely at the expense of the developer proportionate to the impacts placed on the 
transportation network. Any public or private electric transmission infrastructure improvement costs needed 
in support of the Project will be borne solely by the developer. 
III. REQUIRING PUBLIC IMPROVEMENTS TO ROADS, SEWER, OR 
WATER SYSTEMS THAT ARE NEEDED TO SUPPORT THE 
PLANNED LAND USES. 
The amendment will not adversely impact the planning area by requiring public improvements to roads, 
sewer, or water system needed to support the planned land uses. The provision of these services will be 
the responsibility of the developer in a manner that does not detract or negatively impact the availability, 
delivery, and/or use of existing services within the planning area. All costs for public improvements or 
services necessary to support the planned development will be borne solely by the developer. 
Options for construction and operational water needs is currently under examination by the developer, and 
none of these options would require improvements to public water systems.  
Any expenditures for roadway, sewer or water infrastructure that are required as a result of the development 
shall be borne by the developer. Unless otherwise coordinated with County staff during the subsequent 
plan of development, given alternative cooling technologies available and limited employees on-site, the 
proposed data centers are planned to operate without public water/sewer sources. Service(s) to the Project 
site will be provided by the following providers. Water for construction purposes will be transported to the 
site.

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Table D – Public Utilities and Services 
UTILITY/SERVICE 
AGENCY/PROVIDER 
Water 
Hauled / Well 
Sewer 
Septic / Accessible portable restroom facilities, for solar, BESS and 
energy generation, as needed for maintenance activities. In the event 
that a future O&M building is built and/or permanent employees are 
present on the site wastewater will be treated by septic. 
Electric Service  
Arizona Public Service 
Fire Protection (including EMS 
and Ambulatory Services) 
Harquahala Valley Fire District 
Police Protection 
Maricopa County Sheriff Office 
Refuse (Waste Management) 
Republic Services 
Telephone 
American Telephone and Telegraph (AT&T) Co 
Irrigation 
Harquahala Valley Irrigation District 
IV. ADVERSELY 
IMPACTING 
PLANNED 
USES 
BECAUSE 
OF 
INCREASED TRAFFIC.  
Given the proximity to the Interstate 10, the remoteness of the site and the lack of surrounding development, 
existing and planned uses surrounding the site which are dependent on the surrounding transportation 
system are not anticipated to be impacted due to the minimal traffic impact associated with the Project. The 
proposed Project is one of high fiscal impact with a low physical impact. Data centers and energy generation 
generate significantly less traffic than residential, commercial and office uses. As noted, HEGIC is 
committed to ensuring that any road improvements, as coordinated with the county, are constructed at the 
time such improvements are warranted. A traffic statement has been provided in support of the concurrent 
zone change application and review process. A traffic statement is a scaled down and simplified version of 
the traffic impact study and is intended for smaller Projects that will have lesser impacts on existing traffic 
as compared to the larger type of master plan developments. The Project team will continue to coordinate 
with the county and MCDOT during the subsequent plan of development review to identify access points, 
improvements and necessary ROW preservations. 
V. AFFECTING THE LIVABILITY OF THE AREA OR HEALTH OR 
SAFETY OF PRESENT AND FUTURE RESIDENTS. 
The General CPA will not adversely affect the livability of the area or health or safety of present and future 
residents of the area. As previously discussed, there are no residences in the immediate area. Site 
preparation, construction, or operation will not include any hazardous activities, materials, processes, or 
outputs. Noise impacts would be limited construction activities during specified construction hours. Fugitive 
dust control will be achieved during construction and operational periods by implementation of proper 
grading, erosion control measures, and best management practices (BMP’s) to include appropriate dust 
control and mitigation of dust on unpaved roads. Standard operational activities will conform to applicable 
noise ordinances. Fire hazard and wildfire mitigation will be addressed with the subsequent plan of 
development. HEGIC will comply with all applicable local and county fire laws and regulations. The General

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CPA will not result in undue or unmitigated social, visual, traffic, air quality, water quality, or other impacts 
which may impact the livability of the area. 
VI. ADVERSELY IMPACTING THE NATURAL ENVIRONMENT OR 
SCENIC QUALITY OF THE AREA IN CONTRADICTION TO THE 
PLAN.   
Given the Project site location, adjacent to the busy Interstate 10 thoroughfare, and the significant amount 
of industrial project approvals in the surrounding area, is not anticipated that the proposed land use will 
generate adverse impacts to the natural environment or the scenic quality of the area.  
The Project team will conduct necessary onsite investigations and implement appropriate protective 
measures as needed for biological resources to either avoid or mitigate impacts to the natural environment, 
in coordination with the Arizona Game and Fish Department (AZGFD). The Project team recognizes that 
appropriate coordination, proper planning, and implementation of best management practices allow 
projects to be developed that avoid, minimize, or mitigate potential impacts to wildlife and recreational 
access during development and operation of the facilities. The Project team will coordinate with AZGFD 
through the review of the subsequent plan of development to minimize any potential impacts to the 
surrounding wildlife including proper treatment or preservation of drainage ways and wildlife corridors. 
Based on similar surrounding approvals, AZGFD will recommend surveys and monitoring to identify the 
species in the area and best management practices will be introduced to address potential impacts and 
safety.  
Dust control measures will be provided to protect air quality during construction activities. Ground disturbing 
activities may also require dust mitigation, erosion control BMP’s, and select soils stabilization or 
enhancement where existing erosion is encountered to maintain compliance with local, state, and federal 
air and water quality standards. 
The site is predominately flat limiting the need for excessive grading. Construction activities will implement 
accepted BMP’s for development, which include minimum ground disturbance and non-disturbance of 
existing low-lying vegetation and vegetation, where feasible, for erosion control purposes. Vegetation may 
require mowing to heights approved by the fire district or other environmental agencies to maintain 
appropriate levels of fire mitigation and erosion control.  
The site will be secured with fencing to provide separation and security. Details of proposed fencing will be 
provided with subsequent plan of development applications and finalized through coordination and input 
from the necessary reviewing agencies.  
The larger surrounding area is characterized by active and passive agricultural land uses, Bureau of Land 
Management (BLM) and Arizona State Land Department (ASLD) owned and managed lands, natural gas-
powered electric generation facilities, solar powered electric generation facilities, and native desert lands. 
The predominant surrounding private land uses within the area is Utilities as designated by approved 
Comprehensive Plan Amendments which have changed the underlying future land uses from Rural 
Densities (0-1) to Utilities. No adverse or otherwise unmitigated impacts to the natural environment or 
scenic quality of the area are anticipated.

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The site will be surveyed prior to construction activities to identify plant/vegetation species which are 
protected by the Arizona Department of Agriculture under the Arizona Native Plant Law. Protected plant life 
and/or vegetation will be relocated or otherwise salvaged. All activities associated with the removal, 
relocation, or sale of protected plants/vegetation will comply with the notice requirements of Title 3, Chapter 
3, Title II, of the Arizona Administrative Code. 
Additional detailed analysis of environmental impacts will occur with the plan of development submittals. 
Any identified impacts will be evaluated together with Planning and other staff within affected local, state, 
federal regulatory agencies and corresponding county departments and agencies, and participating 
stakeholders to identify appropriate mitigation strategies and/or other acceptable offsetting measures. The 
Project will maintain compliance with applicable Maricopa County Air Quality Department permitting and 
operational standards, including conformance with U.S. Environmental Protection Agency (EPA), and 
Arizona Department of Environmental Quality. 
D. WHETHER THE AMENDMENT IS CONSISTENT WITH OVERALL INTENT 
OF THE COMPREHENSIVE PLAN: 
Maricopa County’s original Comprehensive Plan was adopted in 1997 as a sensible approach to addressing the 
regions fast paced growth and associated development issues. A lot has changed since these adoptions in terms 
of digital infrastructure and energy generation, including a relevant update to introduce energy efficiency into the 
plan into the Comprehensive Plan in 2007, and the county looks to build on the past and lessons learned to 
experience continued smart growth and achieve a healthy, vibrant and prosperous future. This can be seen 
throughout the county’s current Vision 2030 Comprehensive Plan, which is a planning mechanism that looks to 
balance this future growth with evolving technology and a high quality of life. The Comprehensive Plan looks to 
achieve this balance by providing policies and recommendations on how to protect public health and safety, promote 
stable economic growth, maintain a healthy environment, provide adequate community services, and ensure that 
tax money is spent efficiently. These policies and recommendations also guide Maricopa County’s decisions 
regarding future development, and for when changes to this plan are justified.  
Applicant initiated changes to the comprehensive plan, like this change in land use designation, may occur with 
Board approval to account for changing conditions provided that such revisions benefit the county as a whole. This 
benefit can be weighed through the goals and policies of a series of plan elements, which each address a subject 
that affects the county’s quality of life. While each element is distinct, combined they reinforce the county’s strategic 
priorities and the core principles of Vision 2030, and promote consistent interpretation and implementation of its 
policies and recommendations.  
Consistent with the county’s core principles, this land use change helps support the implementation of Maricopa 
County’s mission statement and strategic priorities by providing fiscally responsible energy generation services and 
effective and efficient infrastructure to implement delivery of services that help promote and contribute to a healthy 
community that residents can enjoy. The General CPA will maintain the county’s comprehensive plan approach to 
ensure that the land use request is understandable, measurable, consistent, practical and promotes efficiency.  
This narrative, and more specifically the goal and policy analysis below, lays out the expectations for future growth 
and development of the utilities designation, which promotes an efficient use of land, energy and financial resources. 
The Vision 2030 plan realizes that markets and businesses are dynamic, flexible, and constantly changing and that 
information technology is fundamental to all types of businesses. Additionally, the energy uses are discussed

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throughout the plan responding to Maricopa County’s ability to be one of the most productive spots int the world for 
energy generation as discussed in the plan. These references provide measurable policies and strategies for infill, 
balanced land use, cost of development goals, water conservation goals, and economic development goals, as 
described below, while complementing the growth and development related issues and goals of the remaining plan 
elements. Overall, this approach allows the Project to consider the county’s past decisions provided within Vision 
2030 to provide practical and informed decisions to avoid future problems. 
This Project provides a land use that is compatible with the surrounding area that meets the overall intent of the 
Maricopa County Comprehensive Plan Vision 2030 by supporting the strategy to adapt to the new economy, while 
addressing the need for energy generation, which has been identified as a strategic priority, that benefits the region 
and county as a whole. Additionally, this Project will improve the quality of life as identified in the goals and policies 
of the Comprehensive Plan as discussed in the following section.   
E. THE EXTENT TO WHICH THE AMENDMENT IS CONSISTENT WITH THE 
SPECIFIC GOALS AND POLICIES CONTAINED WITHIN THE PLAN. 
Maricopa County’s Vision 2030 Comprehensive Plan considers growth-related topics that will affect the county’s 
future. The following nine (9) plan elements, which include the four (4) Tonopah/Arlington Area Plan elements (Land 
Use, Transportation, Environment, Economic Growth), examine key issues that shape the goals and policies that 
Maricopa County uses to implement its mission, vision, strategic priorities and make informed and effective 
decisions.   
 
Land Use 
 
Transportation 
 
Environment 
 
Economic Growth 
 
Growth Areas 
 
Open Space 
 
Water Resources 
 
Energy 
 
Cost of Developme
 
HEGIC and the Utilities land use designation are affirmed by many of the goals, objectives, and policies identified 
within these identified plan elements. The relevant goals, objectives, and policies contained in the Comprehensive 
Plan are listed below with specific examples and guarantees of how each is relevant to the proposed use and why 
it is consistent. 
LAND USE GOALS AND POLICIES 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Land Use Goal #3: Protect 
public health, safety and well-
being  
The HEGIC Project and the Utilities land use designation match the industrial 
character of the surrounding area. The Project, like much of the surrounding 
solar developments, is a low impact land use that requires minimal water 
usage and produces minimal traffic. It will contribute to much needed 
employment opportunities and efficient energy while helping maintain long-
term financial stability through the generation of revenues and tax base 
contributions for Maricopa County. The Project will provide fiscally responsible 
employment and alternative energy services and effective and efficient 
infrastructure to implement delivery of necessary data services that help 
promote and contribute to a healthy community that residents can enjoy.

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Land Use Policy #7: Maricopa 
County supports coordinating 
land 
use 
and 
infrastructure 
planning with state agencies, 
counties, and municipalities.  
 
The process requires ongoing coordination with local, state, and federal 
agencies to ensure protections of public services, utilities, infrastructure, and 
natural resources. Coordination is either expected or has occurred directly 
with Maricopa County Planning and Zoning, Environmental Services, the 
Maricopa County Department of Transportation, and Arizona Game and Fish 
Department (AZGFD). Feedback from state agencies, other counties and 
municipalities located in close proximity to the Project will be received as well 
through Maricopa County’s enhanced notification process. Additional 
coordination will occur both on this site and with the associated gen-tie with 
these groups in addition to the State Historic Preservation Office (SHPO) and 
Arizona Department of Agriculture (AZDA). The coordination includes 
preparation of necessary reports and considerations for the provision as well 
as protection of natural resources and public services including, but not limited 
to, water resources (ground/surface water supplies), flora and fauna impacts, 
air and water quality, and stormwater impacts, open spaces, buffering and 
screening, and transportation facilities and rights-of-way. 
Land Use Policy #20: Maricopa 
County supports reducing the 
impacts 
of 
new 
urban 
development on existing rural 
land uses and agriculture. 
The Utilities land use and industrial zoning is already found in the surrounding 
area, reducing the impact on nearby agricultural and rural land uses.  
Land Use Policy #22: Maricopa 
County supports reducing the 
impacts of new development on 
environmentally sensitive areas, 
including native flora and fauna 
habitat and corridors.  
 
The Project does not include environmentally sensitive areas requiring 
avoidance or mitigation that we are aware of at this time. All development 
activities will remain compliant with applicable environmental regulations 
requiring flora/fauna habitat and/or environmental protection or relocation. 
Ongoing coordination with the appropriate agencies, including AZGFD, SHPO 
and AZDA, throughout the Project life cycle will ensure appropriate site 
treatments and regulatory compliance with applicable environmental policies, 
protocols, and regulations. 
 
 
TRANSPORTATION GOALS & 
POLICY CONSIDERATIONS
CPA CONSISTENCY/JUSTIFICATION 
 
Transportation 
Goal 
#1: 
Promote and protect public 
health 
through 
a 
safe 
transportation system.  
 
One of Maricopa County’s strategic priorities is creating a safe, efficient and 
effective transportation system. The HEGIC Project will further this priority by 
addressing some of the related concerns specific to the preservation of road 
alignments and air pollution. The Project will be responsible for ROW 
preservation of the necessary roadway alignments, as indicated by MCDOT 
from its respective boundaries to comply with the Maricopa County 
Transportation Plan and road/ROW preservation/dedication standards of the 
county. Any exceptions will be negotiated with MCDOT and authorized by the 
MC BOS to memorialize terms of negotiated dedications, preservation, and/or 
and deferments or exemptions. Because data centers and energy production 
produce significantly lower traffic volumes than other industrial uses, outside 
of the limited construction traffic, HEGIC provides a use that will limit 
automobile usage and reduce air pollution.

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Transportation 
Goal 
#2: 
Contribute to a safe, seamless 
and 
effective 
transportation 
system.  
The Project will support a safe, seamless, and effective transportation system 
by preserving required ROW in support of future road alignments as 
coordinated with MCDOT in a manner consistent with Departmental planning 
objectives and the Maricopa County Transportation Plan. 
Transportation 
Goal 
#3: 
Coordinate land use decisions 
with transportation investments 
to help the county exercise 
sound financial management 
and build the county’s fiscal 
strength.  
All transportation improvements required to support the planned use, or any 
expansion thereof will be borne solely by the developer, subject to all required 
agreements, financial assurances and/or performance bonds. 
Transportation 
Policy 
#11: 
Maricopa 
County 
supports 
National Ambient Air Quality 
Standards 
(NAAQS) 
compliance.  
The Project will maintain compliance with National Ambient Air Quality 
Standards throughout development phases. Operation of the Project will result 
in lower overall emissions. 
Transportation 
Policy 
#12: 
Maricopa 
County 
supports 
improving low volume dirt roads 
as directed by its PM-10 Dust 
Abatement Program.  
The Project will maintain compliance with the permitting and operational 
standards of the Maricopa County Air Quality Department dust control 
requirements as governed by activities regulated by a dust control permit or 
Rule 310.01. 
 
ENVIRONMENTAL GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES)
CPA CONSISTENCY/JUSTIFICATION 
Environmental 
Goal 
#1: 
Provide regional leadership to 
promote all aspects of regional 
environmental quality.  
 
One of the reasons Maricopa County supports state and local efforts to attract 
energy research and development to this region is due to the environmental 
benefits. HEGIC would further Maricopa County’s potential to be a leader in 
energy research and development, with respect to energy generation, and 
would benefit their Green Government Program to help protect the 
environment with a use that promotes low water usage and better air quality. 
Additionally, throughout the HEGIC approvals, reports, plans, and permits will 
be prepared, for all on-site and off-site Project activities, to identify areas of 
environmental concern, demonstrate proposed methods of mitigation and 
compliance, and identify compliance with environmental performance criteria.
 
Environmental Policy #2: To 
help 
improve 
air 
quality 
Maricopa 
County 
supports 
balanced and efficient land use 
patterns 
where 
employment, 
retail and residential land uses 
are proximate rather 
than separate. 
HEGIC supports improved air quality by proposing an alternative energy use 
that decreases emissions that result from electricity produced by fossil fuels. 
Compared to other power producers, solar powered plants and associated 
BESS developments significantly decrease carbon dioxide emissions and 
eliminate sulfur, nitrous oxides, and mercury emissions generated by 
conventional electric generation facilities. Additionally, this Project which will 
treated to reduce potential fugitive dust will improve local air quality impacts 
from fugitive dust emissions.

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Environmental Policy #3: 
To help protect water quality 
Maricopa 
County 
supports 
compliance with its Drinking 
Water program and its Water 
and 
Wastewater 
Treatment 
program.  
 
The Project as proposed is consistent with and will maintain compliance with 
Maricopa County Drinking and Wastewater Treatment program including 
water supply of the Maricopa County Environmental Health Code. As 
proposed, drinking water will be delivered by truck. If a local well is required 
for water use, such well will comply with local and state permitting, operations, 
monitoring, and recharge requirements. The Project, as proposed, will not 
have wastewater demands or discharge. A septic system will be used if an 
O&M building is required. 
Environmental 
Policy 
#4: 
Maricopa 
County 
supports 
innovative Project design and 
development techniques that 
protect and mitigate damage to 
important 
plant 
and 
animal 
habitat and migration corridors.  
 
The Project will be designed to minimize, avoid, and/or mitigate negative 
impacts to flora and fauna habitat and wildlife migration corridors during 
implementation and operational activities. Comments from the Arizona Game 
and Fish Department (AZGFD) will be addressed in a manner consistent with 
the intent of this policy, which may include preservation and/or relocation of 
impacted flora and/or fauna species. Best management practices will be 
employed to address flora/fauna impacts. 
Environmental Policy #5: As 
directed by SHPO and Arizona 
Game and Fish Department, 
Maricopa 
County 
supports 
cultural resource and biological 
surveys being completed – and 
needed 
mitigation 
measures 
established – prior to new 
development.   
Cultural and biological reporting and surveys associated with this Project, if 
required by the State Historic Preservation Office (SHPO) and AZGFD, will be 
submitted with the zone change and plan of development application to 
identify sensitive areas requiring protection, preservation, and/or mitigation of 
impacts to respective natural, biologic, and/or cultural resources. Mitigation 
identified by these or by the respective agency’s staff or other guidance 
documents will be adhered to during implementation, and operation of the use.
 
ECONOMIC GROWTH GOAL AND POLICY CONSIDERATIONS
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Economic Growth Goal #1: 
Contribute 
to 
an 
effective 
regional economy. 
 
 
Economic Growth Policy #5:  
Maricopa 
County 
supports 
programs that attract a variety of 
Basic Sector industry clusters 
that 
have 
long-term, 
stable 
growth prospects. 
The physical development of the site will employ hundreds of specialized 
construction and skilled trade workers and laborers from unincorporated areas 
and incorporated municipalities within Maricopa County. Construction 
activities will generate employment opportunities for qualified workers over 
years of construction. Local businesses including, but not limited to retail, food 
service, gas station/convenience, and hospitality businesses will be supported 
by workers commuting to the site or lodging near the site for short/long terms 
during their respective periods of construction activities. No construction 
camps or on-site housing are proposed during the implementation 
(construction) phase of the Project. The Project would generate revenues and 
contribute to the tax base for Maricopa County, and would allow for the use of 
clean, safe, affordable, and efficient energy. This energy will provide 
substantial resources for power providers servicing the growing Arizona 
population centers, contributing to grid resilience and reliability. The Project 
will also be a key contributor to decarbonization of the grid by enabling

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acceleration of the retirement of coal-fired power generation assets. This will 
help meet the growing power demand from new manufacturing and 
employment uses locating in Maricopa County, facilitating job creation and 
supporting new residential growth.  
 
Economic Growth Policy #6: 
Maricopa 
County 
supports 
efforts to recruit prospective 
 businesses and industries to 
the county, and efforts to re-tain 
existing 
businesses 
and 
industries. 
Development of this Project will focus on the growing data industry, providing 
high-tech, and environmentally friendly employment opportunities in 
information technology and energy production. Addressing this need will 
create vital digital infrastructure in this industry that is seeing huge 
investments, with a growing focus on sustainable infrastructure to meet this 
unprecedented demand. HEGIC would include buildings containing 
computing and networking hardware, along with power and cooling 
infrastructure. Centers such as these are required to store, process, manage, 
and distribute massive quantities of data, for modern communication, 
telehealth, remote work, media streaming, energy, healthcare, retail, aviation, 
automotive, entertainment, and government operations. These data centers 
will be supported by additional infrastructure such as power generation, 
energy distribution, and storage systems. Investing in cleaner natural gas 
energy generation promotes local economic opportunity rather than reliance 
on distant energy sources. 
 
GROWTH AREA’S GOAL AND POLICY CONSIDERATIONS
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Growth 
Areas 
Goal 
#1: 
Achieve orderly urban growth 
that 
is 
fiscally 
and 
environmentally 
responsible, 
protects public health and safety 
and 
promotes 
sensible 
annexation patterns. 
The Project is located near existing and approved energy generation facilities 
and has convenient access to existing electrical infrastructure, major 
transmission corridors, and a major electrical substation. Proximity to existing 
transmission lines, corridors, and easements reduces the developer’s 
expenditures to utilize existing infrastructure and to obtain necessary 
easements to interconnect to the electrical grid. Construction and operational 
activities will maintain compliance with applicable environmental criteria, 
regulations, and permitting to ensure protection of biologic and natural 
resources.  
Growth 
Areas 
Policy 
#1: 
Maricopa 
County 
supports 
consistent implementation of its 
urban growth area except in the 
noted instances.   
The proposed Project is considered an industrial land use that does not 
require a corresponding level of urban services and infrastructure and can be 
located in rural remote areas. As the plan recommends, this land use is 
acceptable outside the urban growth area. These uses could include electric 
generating facilities, proving grounds and test facilities, agriculturally oriented 
businesses, and other rural-type industrial uses on a case-by-case basis.

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WATER RESOURCES GOAL AND POLICY CONSIDERATIONS
COMP PLAN ELEMENT 
(GOALS/POLICIES)
CPA CONSISTENCY/JUSTIFICATION 
Water Resources Goal #4:  
Increase water conservation. 
Over the recent years, the switch to utilities and industrial land uses within this 
surrounding area has resulted in a significant decrease in agricultural uses, 
which is a heavy water user. Additionally, HEGIC will look to continue to these 
water conservation goals. The proposed data centers and energy generation 
uses are generally low staffed resulting in minimal potable water needs. 
Additionally, they will encourage innovative cooling technologies for 
operational purposes. Construction peak water usage and operations & 
maintenance water usage would be significantly less than a residential 
community or agricultural use. 
Water Resources Policy #2: 
Maricopa County supports water 
conservation techniques in the 
planning and design of new 
development. 
Unless otherwise coordinated with County staff during the subsequent POD, 
given alternative cooling technologies available and limited employees on-
site, the proposed data centers are planned to operate without public 
water/sewer sources. Water for construction purposes will be transported to 
the site. 
Water Resources Policy #4: 
Maricopa 
County 
supports 
compliance with its Drinking 
Water 
and 
Water 
and 
Wastewater 
Treatment 
Programs. 
Drinking water will be delivered by truck. If a local well is required for water 
use, such well will comply with local and state permitting, operations, 
monitoring, and recharge requirements. 
The developers will coordinate with the county, during the development of the 
subsequent plan of development, to maintain compliance with Maricopa 
County’s water and wastewater treatment programs.   
Water Resources Policy #7: 
Maricopa County supports low 
water use and drought tolerant 
landscaping.   
In order to preserve water use within this remote area, no landscaping is 
required or proposed for this industrial use. If landscape treatments were to 
be used, they would be selected from drought tolerant xeric species which will 
require low water use to establish and maintain. 
 
ENERGY GOAL AND POLICY CONSIDERATIONS
COMP PLAN ELEMENT 
(GOALS/POLICIES)
CPA CONSISTENCY/JUSTIFICATION 
Energy Goal #1: 
Provide leadership to promote 
regional environmental quality.  
 
HEGIC will have a long-term impact on improving environmental quality by 
contributing to numerous sustainability goals including reduced water 
consumption in electricity generation and decarbonization of the grid by 
providing essential resource adequacy capacity and reliability, thus enabling 
acceleration of the retirement of coal-fired power generation assets. Natural 
gas energy generation offers benefits including being the cleanest-burning 
fuel, producing significantly fewer air pollutants and greenhouse gases than 
other alternatives, while offering high efficiency and reliability for generating 
electricity.

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Energy Policy #6: 
Maricopa County supports being 
a 
responsible 
leader 
in 
alternative energy research and 
development. 
HEGIC will be reflective of the Maricopa County Board of Supervisor’s 
regional and statewide leadership in the attraction, promotion, and delivery of 
energy resources and infrastructure. The proposed energy generation on-site 
will complement the surrounding large scale solar facilities that have become 
a focus in this area. Natural gas plants can start and stop quickly, providing 
reliable, on-demand power to stabilize the grid and cover for the intermittency 
of alternative sources like solar. 
COST OF DEVELOPMENT GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Cost of Development Goal #2: 
New 
development 
pays 
its 
proper and reasonable share of 
the costs of new infrastructure, 
services 
and 
other 
public 
improvements. 
All Project costs, including, but not limited to, on-site improvements, gen-tie 
line 
infrastructure 
and 
connections, 
collection 
lines, 
off-site 
road 
improvements, and water and wastewater treatment service, shall be borne 
solely by the developer. 
Cost of Development Policy 
#2: Maricopa County supports 
recouping 
the costs 
of 
its 
products and services without 
unfairly burdening those most in 
need 
of 
its 
products 
and 
services.
All development costs will be borne solely by the developer, including, but not 
limited to, applicable fees for service, impact fees, performance bonds and 
sureties, and property taxes. 
OPEN SPACE GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Open Space Goal #1: Provide 
regional leadership to promote 
environmental quality, including 
the preservation of open, natural 
park and recreation lands. 
The Project is located away from, and will not impact, Maricopa County’s 
regional parks, trails, or other public recreation. Furthermore, this Project 
would allow for industrial and energy generation uses near existing electrical 
infrastructure and similar uses, in an area where development would result in 
limited impact to open space lands and would demonstrate efficient, orderly 
growth.

Page 22 
kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
APPENDIX – A “SITE PARCELS” 
Table A – Parcel/Ownership Data: 
APN's 
Ownership 
Assessor S.F.
Acres 
T/R 
Sect. Existing 
Zoning 
Exist. Land Use 
Designation 
1 
506-18-016B Ben Fatto L P/Gluck 
LP/ ETAL 
5,623,288.00
129.09 
2N 9W
12 
RU-43 
Rural Development 
Area 
2 
506-18-016C Ben Fatto L P/Gluck 
LP/ ETAL 
4,283,688.00
98.34 
2N 9W
12 
RU-43 
Rural Development 
Area 
3 506-18-029F -
Portion Of 
Ben Fatto L P/Gluck 
LP/ ETAL 
2,679,475.71
61.51 
2N 9W
11 
RU-43 
Rural Development 
Area 
4 
506-18-017d
GYP Harquahala 
Holdings LLC 
5,822,324.00
133.66 
2N 9W
12 
RU-43 
Rural Development 
Area 
5 506-18-018A -
Portion Of 
Bolle Klaus Jurgen 
Rainer TR 
1,579,288.40
36.26 
2N 9W
12 
RU-43 
Rural Development 
Area 
6 
506-18-019B
DL Landco, LLC 
871,200.00 
20.00 
2N 9W
13 
RU-43 
Rural Development 
Area 
7 
506-18-022N
DL Landco, LLC 
1,742,400.00
40.00 
2N 9W
13 
RU-43 
Rural Development 
Area 
8 
506-18-024B
DL Landco, LLC 
871,200.00 
20.00 
2N 9W
13 
RU-43 
Rural Development 
Area 
9 
506-18-022F
David G Marion 
Revocable Trust 
849,420.00 
19.50 
2N 9W
13 
RU-43 
Rural Development 
Area 
10
506-18-022L
Copia Land 
Holdings LLC 
849,420.00 
19.50 
2N 9W
13 
RU-43 
Rural Development 
Area 
11 506-18-022M
Daniel Arredondo 
Revocable Trust 
871,200.00 
20.00 
2N 9W
13 
RU-43 
Rural Development 
Area 
12
506-18-022R
Stegner Family 
Trust 
871,200.00 
20.00 
2N 9W
13 
RU-43 
Rural Development 
Area 
13
506-18-022S
Schuetze Trust 
871,200.00 
20.00 
2N 9W
13 
RU-43 
Rural Development 
Area 
Harquahala Energy Generation & 
Industrial Campus General CPA 
Totals (13 Parcels) 
27,785,304.11
637.86

HARQUAHALA ENERGY
GENERATION & INDUSTRIAL
CAMPUS (HEGIC)
©
PRELIMINARY -
NOT FOR
CONSTRUCTION
ZONING EXHIBIT
FOR
HARQUAHALA ENERGY GENERATION &
INDUSTRIAL CAMPUS (HEGIC)
CASE #: Z250015
A PORTION OF SECTIONS 11, 12, AND 13, TOWNSHIP 2 NORTH, RANGE 9 WEST,
AND A PORTION OF SECTION 18, TOWNSHIP 2 NORTH, RANGE 8 WEST OF THE
GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, ARIZONA
C1.0
PROJECT SITE
NORTH
N.T.S
APPLICANT
VICINITY MAP
PLANNER AND CIVIL ENGINEER
LEGAL DESCRIPTIONS
LEGAL DESCRIPTIONS CTD.
DEVELOPMENT STANDARDS TABLE
REGULATION
BASE IND-2 ZONING REGULATION
PROPOSED IND-2 IUPD ZONING REGULATIONS
MAX. HEIGHT
40'
103'
MIN. FRONT YARD SETBACK
10'-25'
10'-25'; 0' FOR SOLAR PANEL ARRAYS; 100’ FOR BESS
CONTAINERS
MIN. SIDE YARD SETBACK
0'-10'
0'-10'; 0' FOR SOLAR PANEL ARRAYS; 100’ FOR BESS
CONTAINERS
MIN. REAR YARD SETBACK
0'-25'
0'-25'; 0' FOR SOLAR PANEL ARRAYS; 100’ FOR BESS
CONTAINERS
MIN. LOT AREA
6,000 SQ. FT.
6,000 SQ. FT.
MIN. LOT WIDTH
60’
60’
MAX. LOT COVERAGE
60%
60%, SOLAR PANEL ARRAYS ARE NOT CALCULATED
AS LOT COVERAGE.
PARKING REGULATIONS
ARTICLE 1102.1.5: ONE PER 600 SQ.FT
OF FLOOR AREA; 5% OF PARKING
SPACES SHALL BE HANDICAPPED
PARKING SPACES.
BESS/ENERGY GENERATION: NONE REQUIRED. DATA
CENTER: ONE PER 1,000 SF OF FLOOR AREA FOR THE
FIRST 10,000 SQ.FT. AND THEN ONE PER 5,500 SQ.FT.
OF REMAINING FLOOR AREA.
PAVING REGULATIONS
DRIVEWAYS AND PARKING AREAS
SHALL BE PAVED.
BESS/ENERGY GENERATION: STABILIZED
DECOMPOSED GRANITE WITH APPROVED GRANITE
WITH AN APPROVED MCAQ DUST CONTROL PLAN FOR
DRIVEWAYS AND PARKING AREAS.
LOADING & UNLOADING
ONE SPACE FOR EVERY 10,000 SQ.FT OF
FLOOR AREA.
MINIMUM OF ONE SPACE PER BUILDING. BESS/
ENERGY GENERATION: NONE REQUIRED
SITE VISIBILITY TRIANGLES
(SVT’S)
NO OBSTRUCTIONS OVER 2' (H) WITHIN
25'X25' SVT'S.
NO OBSTRUCTIONS OVER 2' (H) WITHIN 25'X25' SVT'S.
BESS/ENERGY GENERATION: NO SVT’S AT PROJECT
SITE ENTRY/EXIT POINTS, SECTION LINE AND
MIDSECTION LINE INTERSECTING ALIGNMENTS.
USES/BUILDING
ENCLOSURES
ALL USES EXCEPT FOR PARKING,
LOADING, UNLOADING OR STORAGE
SHALL BE CONDUCTED WITHIN A
COMPLETELY ENCLOSED BUILDING.
ALL USES EXCEPT FOR PARKING, LOADING,
UNLOADING, STORAGE, ELECTRIC GENERATION,
ELECTRIC STORAGE, ELECTRIC TRANSMISSION, AND
DATA CENTER INFRASTRUCTURE SHALL BE
CONDUCTED WITHIN A COMPLETELY ENCLOSED
BUILDING.
SITE ENCLOSURE AND
SCREENING
MINIMUM 6' TALL SOLID WALL AROUND
THE PERIMETER AND TO SCREEN
OUTDOOR INDUSTRIAL USES.
MINIMUM 6’ TALL CHAIN LINK FENCING AND GATES
WITHOUT ATTACHED SCREENING MATERIAL AROUND
THE PERIMETER OF THE SITE AND TO SCREEN
OUTDOOR INDUSTRIAL USES. WILDLIFE-COMPATIBLE
FENCING SHALL BE ALLOWED IF WARRANTED BY
AZG&FD. 1’ OF BARBED WIRE FENCING SHALL BE
PERMITTED ON TOP OF ANY CHAIN LINK FENCE.
MAXIMUM 12’ TALL ALUMINUM ANTI-CLIMB FENCING
SHALL BE ALLOWED.
MAXIMUM ELECTRICAL
TRANSMISSION LINE HEIGHT
ARTICLE 111.7: 120’
196’
ZONING EXHIBIT
HEGIC NORTH ZONING EXHIBIT
1
6/30/25
CHS
INDUSTRIAL UNIT PLAN OF DEVELOPMENT (IUPD)
HEGIC NORTH ZONING EXHIBIT
2
9/16/25 CHS
RECEIVED 6. OCT 25
  Z250015 -- 3. SUB

SALOME HWY
CAMELBACK RD
499TH AVE
INTERSTATE 10 (I-10) HWY
ADOT ROW
DKT 65333, PG. 127
HWY ESMT DOC
2004-0894249
HWY ESMT DOC
2002-0808291
ROW BK 540,
PG 30
ROW BK 540,
PG 30
25' UTILITY ESMT
DOC 2019-315466
CL TELE ESMT
BK 79, PG. 117
100' WATER ESMT
DOC 2021-350967
ESMT DKT 12014, PG 1158
PRIVATE ROAD ESMT
(NO WIDTH GIVEN)
8' ELEC ESMT
DKT 8160, PG 3
8' ELEC ESMT
DKT 8200, PG 102
CL ELEC LINES ESMT
DKT 1718, PG 251
BK 309, PG 44
CL ELEC LINES AND
POLES ESMT
DKT 1718, PG 242
DKT 1897, PG 385
CL GAS ESMT
DKT 2954, PG 53
CL ELEC ESMT
DKT 1718, PG 284
CL GAS ESMT
DKT 2954, PG 53
40' INGRESS/EGRESS ESMT
DOC 2005-1744048
HWY ESMT
DOC 2001-0116365
MCDOT ROW
DOC 2001 PG
1150595
CL ARIZONA
PUBLIC SERVICE
COMPANY ROW
DKT 1897, PG. 385
65' ROAD DECLARED
BK 350, PG 2
PORTION OF APN:
506-18-029F
OWNER: BEN FATTO
L P/GLUCK LP/ ETAL
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-016B
OWNER: BEN FATTO LIMITED
PARTNERSHIP/VIEL GLUCK LLC
LAND USE: VACANT
ZONING: RU-43
PORTION OF APN: 506-18-018A
OWNER: BOLLE KLAUS JURGEN RAINER TR
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-017D
OWNER: GYP HARQUAHALA HOLDINGS LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-016C
OWNER: BEN FATTO LIMITED
PARTNERSHIP/VIEL GLUCK LLC
LAND USE: VACANT
ZONING: IND-2 IUPD
APN: 506-18-023
OWNER: DL LANDCO LLC
LAND USE: VACANT
ZONING: IND-2 IUPD
APN: 506-18-022R
OWNER: STEGNER FAMILY TRUST
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022S
OWNER: SCHUETZE TRUST
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022F
OWNER: DAVID G MARION
REVOCABLE TRUST
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-019B
OWNER: DL LANDCO LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-019C
OWNER: DL LANDCO LLC
LAND USE: VACANT
ZONING: IND-2 IUPD
APN: 506-18-019A
OWNER: DL LANDCO LLC
LAND USE: VACANT
ZONING: IND-2 IUPD
APN: 506-18-022J
OWNER: CLB PARTNERS LLC
LAND USE: VACANT
ZONING: IND-2 IUPD
APN: 506-18-022M
OWNER: DL LANDCO LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022N
OWNER: DL LANDCO LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022K
OWNER: CLB PARTNERS LLC
LAND USE: VACANT
ZONING: IND-2 IUPD
APN: 506-18-022L
OWNER: COPIA LAND HOLDINGS LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-024B
OWNER: DL LANDCO LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-024A
OWNER: DL LANDCO LLC
LAND USE: VACANT
ZONING: IND-2 IUPD
13
SEC 13
EC
SEC 13
SE
SE
W
R9W
R9
N, 
T2N
T
R9W
T2N, R9
R W
N
2
R9W
R9
SEC 12
SEC 12
C
T2N, R9W
T2N, R9W
SEC 11
11
C 11
11
1
T2N, R9W
R9W
APN: 506-18-030C
OWNER: HARQUAHALA VALLEY FARMS LLC
LAND USE: AGRICULTURAL
ZONING: IND-2 IUPD
APN: 506-18-030D
OWNER: HARQUAHALA VALLEY FARMS LLC
LAND USE: AGRICULTURAL
ZONING: IND-2 IUPD
APN: 506-18-020B
ALA VALLEY
L
OWNER: HARQUAHALA V
O
FARMS LLC
D USE: AGRICULTURAL
A
LAND USE
ZONING: IND-2 IUPD
APN: 506-18-020A
OWNER: FERGUSON
GRANDCHILDREN LLC
USE: AGRICULTURAL
A
LAND USE
L
ZONING: IND-2 IUPD
APN: 506-18-029C
AHALA
QUAHALA
OWNER: HARQUA
OWNER: HARQUA
VALLEY FARMS LLC
VA
VA
ND USE: VACANT
USE
SE
U E: 
US
LAND U
D U
ZONING: RU-43
4
U-43
4
APN: 506-18-036B
OWNER: HARQUAHALA VALLEY FARMS LLC
LAND USE: AGRICULTURAL
ZONING: IND-2 IUPD
APN: 506-23-018A
3 018
: 506
AP
OWNER: HARQUAHALA VALLEY
FARMS LLC
LAND USE: AGRICULTURAL
ZONING: RU-43
APN: 506-23-017A
OWNER: HARQUAHALA VALLEY
FARMS LLC
LAND USE: AGRICULTURAL
ZONING: RU-43
SEC 14
T2N, R9W
APN: 506-30-015E
OWNER: COURTHOUSE AG
HOLDINGS LLC
LAND USE: AGRICULTURAL
ZONING: RU-43
APN: 506-30-003
OWNER: COURTHOUSE AG
HOLDINGS LLC
LAND USE: AGRICULTURAL
ZONING: RU-43
APN: 506-30-015H
OWNER: MEC PHASE 2 LLC
LAND USE: VACANT
ZONING: IND-2 IUPD
APN: 506-18-022G
OWNER: LUANGELS
FOUNDATION INC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022E
OWNER: ALLEN MOLLOY
REVOCABLE TRUST
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022U
OWNER: VERIZON
WIRELESS (VAW) LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022A
OWNER: DOUGHERTY FAMILY TRUST
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022B
OWNER: JLB & DJB FAMILY TRUST
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022Q
OWNER: JACKSON DAVID S
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-022P
OWNER: VERIZON WIRELESS (VAW) LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-30-022T
OWNER: VERIZON WIRELESS (VAW) LLC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-017E
HALA
ARQUAH LA
ALA
OWNER: LANGLEY HARQU
O
TR
C/JACK SIMAS T
VALLEY LLC/JAC
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-018B
OWNER: JOHNSON CHARLES L &
CAROL LAND USE: VACANT
ZONING: RU-43
APN: 506-18-029E
OWNER: HARQUAHALA VALLEY
FARMS LLC
LAND USE: AGRICULTURAL
ZONING: IND-2 IUPD
31' CL ELEC LINES
AND POLES ESMT
DKT 1897, PG 385
RESERVED RIGHT-OF-WAY
DOCUMENT 89-0540749
AND DOCUMENT 1987-100427
EASEMENT (WIDTH
UNDETERMINED)
DOCKET 12014, PAGE 1158
(ITEM 165)
40' RIGHT-OF-WAY AND EASEMENT
FOR COMMUNICATION SYSTEMS
DOCKET BOOK 78 OF MISC, PAGE 531
EASEMENT (WIDTH
UNDETERMINED)
DOCKET 12014,
PAGE 1158 (ITEM
176)
RESERVED RIGHT-OF-WAY
DOCUMENT 89-540749
DOCUMENT 87-100443
RESERVED RIGHT-OF-WAY
DOCUMENT 89-540749
(EXHIBIT A-2-PRCL 2)
DOCUMENT 87-100443
(EXHIBIT A-PRCL 2)
26' EASEMENT
FOR GAS MAIN
AND ENGINE SITE
DK 2888 PG 210
APN: 506-18-034A
OWNER: HARQUAHALA
VALLEY FARMS LLC
LAND USE: AGRICULTURAL
ZONING: IND-2 IUPD
APN: 506-18-035C
OWNER: HARQUAHALA
VALLEY FARMS LLC
LAND USE: AGRICULTURAL
ZONING: IND-2 IUPD
APN: 506-23-012C
OWNER: HARQUAHALA VALLEY FARMS LLC
LAND USE: AGRICULTURAL
ZONING: RU-43
100' WIDE WATER EASEMENT
DOCUMENT 2019-310056 &
DOCUMENT 2019-466804 (ITEM 181)
APN: 506-18-032D
OWNER: HARQUAHALA VALLEY
FARMS
LAND USE: AGRICULTURAL
ZONING: IND-2 IUPD
EASEMENT WATER
WELL USAGE
DOCKET 12014, PAGE
1158 (ITEM 247)
ESMT BK 64, PG 274
APPROX. CENTERLINE
LOCATION TELE ESMT
BOOK 80, PAGE 457
APN: 506-18-930
OWNER: ARIZONA PUBLIC SERVICE CO.
LAND USE: VACANT
ZONING: RU-43
OWNER: ARIZONA STATE
LAND DEPARTMENT
LAND USE: VACANT
ZONING: RU-43
ORTION OF APN: 506-18-018A
NOT A PART - PO
KLAUS JURGEN RAINER TR
OWNER: BOLLE
D USE: VACANT
LAND US
LAN
ONING: RU-43
ZO
APN: 506-18-029B
8
6-
AP
B
QUAHALA
U
OWNER: HARQUA
U
R
R: HARQ
FARMS LLC
S LLC
VALLEY FAR
LAND USE: VACANT
ZONING: RU-43
APN: 506-18-016D
8-0
PN
OWNER: BEN FATTO LIMITED
T
A
R B
P/VIEL GLUCK LLC
L
V
PARTNERSHIP/VIE
V
ERS
AND USE: VACANT
V
E
AN
LAND
AN
ZONING: RU-43
R
G
Z
NOT A PART -
N
PN:
APN:
RTION OF AP
RTION OF AP
OR
ORT
O
PO
POR
PO
PORT
506-18-029F
50
506
50
506
06
NE
NE
NER:
R BEN FATTO
E
OWNE
WNE
LUC
UC
UCK 
K LP/ETAL
UCK
L P/GLU
L
U
ND USE: VA
VA
VA
VACA
C NT
ND
VAC
LAND
N
ZONING: RU-43
43
NG
N
4
T2N R9W
T2N R8W
T2N R9W
T2N R8W
507TH AVE
HARQUAHALA ENERGY
GENERATION & INDUSTRIAL
CAMPUS (HEGIC)
©
PRELIMINARY -
NOT FOR
CONSTRUCTION
C1.1
HEGIC NORTH ZONING EXHIBIT
1
6/30/25 CHS
GENERAL NOTES
BASIS OF BEARING
FLOOD INFORMATION
SITE SUMMARY
UTILITY & SERVICE SUMMARY
LEGEND
NORTH
ZONING EXHIBIT
HEGIC NORTH ZONING EXHIBIT
2
9/16/25 CHS

kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
Vicinity Map 
General Location: The proposed Project is located in an unincorporated portion of western Maricopa County. 
The site, currently vacant, is located 11 miles west of Tonopah, at the SEC of Salome Highway and Harquahala 
Valley Road, in the Harquahala Valley area in Township 2 North, Range 9 West, Sections 11,12 & 13. 
 Revised: 09/16/2025 
HARQUAHALA ENERGY GENERATION 
& INDUSTRIAL CAMPUS 
CASE #: Z2500015      
REQUEST: Zone Change with Overlay from RU-43 and IND-2 IUPD to IND-2 
IUPD On Approximately +/- 917.36 Acres 
NARRATIVE REPORT

Page 2 
kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
 
 
 
 
 
 
TABLE OF CONTENTS 
1. PURPOSE OF REQUEST ....................................................................................................................... 3 
2. DESCRIPTION OF PROPOSAL ............................................................................................................ 4 
3. RELATIONSHIP TO SURROUNDING PROPERTIES ....................................................................... 5 
4. LOCATION AND ACCESSIBILITY ........................................................................................................ 7 
Location:...................................................................................................................................................... 7 
Access: ........................................................................................................................................................ 7 
5. CIRCULATION SYSTEM ......................................................................................................................... 8 
Off-site Circulation (Access) .................................................................................................................... 8 
On-site Circulation ..................................................................................................................................... 8 
Parking and Loading ................................................................................................................................. 8 
6. DEVELOPMENT SCHEDULE ................................................................................................................ 9 
7. COMMUNITY FACILITIES AND SERVICES ....................................................................................... 9 
8. PUBLIC UTILITIES AND SERVICES .................................................................................................... 9 
TABLE 1: INDUSTRIAL UNIT PLAN OF DEVELOPMENT ................................................................... 10 
 
 
 
 
 
 
 
 
PROJECT TEAM
 
DEVELOPER  
 
         PLANNING/ENTITLEMENTS         ENGINEERING 
 
Harquahala Campus LLC              Kimley-Horn 
 
                  Kimley-Horn 
 
Contact: Dallas Pugh        
         Contact: Keith Nichter                    Contact: Brett Stroup  
619.208.0853  
 
         602.313.7206 
 
                  480.561.1438 
Dallas.Pugh@Copiapower.com            Keith.Nichter@Kimley-Horn.com          Brett.Stroup@Kimley-Horn.com 
TABLES AND EXHIBITS
 
Table A – Parcel/Ownership Data 
                             
Table B – Surrounding Adjacent General Land Descriptions  
Table C – Existing Surrounding Solar (Utility) Land Use Approvals 
Table D – Public Utilities and Services 
  
Exhibit 1 – Site Context Map – Existing Zoning  
Exhibit 2 – Surrounding Utilities/Industrial Land Uses

Page 3 
kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
1. PURPOSE OF REQUEST 
Kimley-Horn, on behalf of Harquahala Campus LLC (the “Applicant”) with the permission of the following ten (10) 
property owners, as listed in Table A – Parcel/Ownership Data, is seeking a proposed Zone Change with Overlay 
from RU-43 & IND-2 IUPD to IND-2 IUPD, with the Maricopa County Planning & Development Department, to allow 
for the development of the ±917.36-acre Harquahala Energy Generation & Industrial Campus (HEGIC) (the 
“Project”), as a part of the overall Maricopa Energy Center (MEC) project. The rezoning application is accompanied 
by a concurrent application for a General Comprehensive Plan Amendment of the Vision 2030 Comprehensive Plan 
to change the land use designation on a portion of (±637.86 acres) the Project from Rural Development Area to 
Utilities to match the surrounding approvals.  
In addition to the utility-scale solar energy generation and battery energy storage system (BESS) uses currently 
allowed within the surrounding MEC project, this proposal will look to make a significant investment within Maricopa 
County, providing residents with crucial digital services, with the development of data centers, as shown in Table 
1: Industrial Unit Plan of Development, along with additional energy generation uses such as gas generating 
facilities and other ancillary uses. 
With data centers becoming critical infrastructure in today’s digital world, HEGIC looks to address this growing need 
by providing for the storage, processing, and transmission of the massive volumes of data that are generated every 
second. As individuals, businesses, and governments increasingly rely on cloud computing, streaming services, e-
commerce, remote work, and connected devices, the need for secure, reliable, and high-performance computing 
environments has never been greater. This development of data centers will support everything from financial 
transactions and healthcare systems to emergency services and communications, acting as the backbone of the 
global digital economy. Without addressing the need for these uses, modern digital services and technologies 
simply could not function. 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 1 – Site Context Map – Existing Zoning

Page 4 
kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
2. DESCRIPTION OF PROPOSAL
The Harquahala Energy Generation & Industrial Campus is approximately 11 miles west of Tonopah within the 
Harquahala Valley area and is located south of Interstate 10 (I-10), north of the Camelback Road and between 
499th Avenue and 507th Avenue, as shown in Exhibit 1 – Site Context Map – Existing Zoning. The Project is made 
up of the following nineteen (19) vacant parcels:   
Table A – Parcel/Ownership Data: 
APN's 
Ownership 
Assessor S.F.
Acres 
T/R 
Sect.
Existing 
Zoning
Exist. Land Use 
Designation
1 
506-18-016B Ben Fatto L P/Gluck LP/ ETAL
5,623,288.00 
129.09 2N 9W 12 
RU-43 
Rural Development Area 
2 
506-18-016C Ben Fatto L P/Gluck LP/ ETAL
4,283,688.00 
98.34 
2N 9W 12 
RU-43 
Rural Development Area 
3 
506-18-029F -
Portion Of
Ben Fatto L P/Gluck LP/ ETAL 
2,679,475.71 
61.51 
2N 9W 11 
RU-43 
Rural Development Area 
4 
506-18-017d 
GYP Harquahala Holdings LLC
5,822,324.00 
133.66 2N 9W 12 
RU-43 
Rural Development Area 
5 
506-18-018A -
Portion Of
Bolle Klaus Jurgen Rainer TR 
1,579,288.40 
36.26 
2N 9W 12 
RU-43 
Rural Development Area 
6 
506-18-019A DL Landco, LLC
1,742,400.00 
40.00 
2N 9W 13 
IND-2 IUPD 
Utilities 
7 
506-18-019B DL Landco, LLC
871,200.00 
20.00 
2N 9W 13 
RU-43 
Rural Development Area 
8 
506-18-019C DL Landco, LLC
871,200.00 
20.00 
2N 9W 13 
IND-2 IUPD 
Utilities 
9 
506-18-022N DL Landco, LLC
1,742,400.00 
40.00 
2N 9W 13 
RU-43 
Rural Development Area 
10
506-18-023 
DL Landco, LLC
6,969,600.00 
160.00 2N 9W 13 
IND-2 IUPD 
Utilities 
11
506-18-024A DL Landco, LLC
871,200.00 
20.00 
2N 9W 13 
IND-2 IUPD 
Utilities 
12
506-18-024B DL Landco, LLC
871,200.00 
20.00 
2N 9W 13 
RU-43 
Rural Development Area 
13
506-18-022F 
David G Marion Revocable Trust
849,420.00 
19.50 
2N 9W 13 
RU-43 
Rural Development Area 
14
506-18-022J 
CLB Partners LLC
871,200.00 
20.00 
2N 9W 13 
IND-2 IUPD 
Utilities 
15
506-18-022K CLB Partners LLC
849,420.00 
19.50 
2N 9W 13 
IND-2 IUPD 
Utilities 
16
506-18-022L 
Copia Land Holdings LLC
849,420.00 
19.50 
2N 9W 13 
RU-43 
Rural Development Area 
17
506-18-022M Daniel Arredondo Revocable Trust 
871,200.00 
20.00 
2N 9W 13 
RU-43 
Rural Development Area 
18
506-18-022R Stegner Family Trust 
871,200.00 
20.00 
2N 9W 13 
RU-43 
Rural Development Area 
19
506-18-022S 
Schuetze Trust 
871,200.00 
20.00 
2N 9W 13 
RU-43 
Rural Development Area 
Harquahala Energy Generation & Industrial Campus 
Totals (19 Parcels) Totals 
39,960,324.11 917.36 
The proposed data centers are specialized facilities designed for the centralized management of electronic data. 
These campuses consist of buildings equipped with computing and networking hardware, as well as power and 
cooling infrastructure. Their primary function is to store, process, manage, and distribute vast quantities of data 
while ensuring secure and reliable access. These facilities play a vital role in modern life, enabling communication, 
telehealth, remote work, and media streaming. They're also essential to sectors like energy, healthcare, retail, 
aviation, automotive, entertainment, and government operations. 
Operating 24/7, data centers can be supported by additional infrastructure such as power generation, energy 
distribution, and storage systems. Inside, they can house servers, switches, and telecommunications gear. To 
maintain optimal conditions, systems such as generators, batteries, electrical distribution, and cooling systems are 
used to regulate heat and airflow.

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Construction of the proposed data centers will represent a significant investment within the County. All materials 
coatings, finishes, and colors, where practicable, will be selected to be attractive and blend facility components. 
Selection of color palettes will be selected from factory specifications and options provided by the respective 
manufacturers. Color palette selection will conform to generally accepted and adopted industry standards. The color 
palette of the exterior of any building shall minimize heat absorption and glare but match the natural environment 
as much as possible. Other than the standards within the proposed IUPD table, it is the Applicants’ intent that all 
future buildings comply with the applicable Maricopa County’s building design standards. Building design will be 
evaluated within future plan reviews. 
Technicians with specialized expertise monitor and manage these systems in accordance with best practices and 
manufacturer guidelines. Many modern centers can have automated systems to oversee real-time performance 
and ensure consistent uptime, excluding planned downtime for maintenance or upgrades. Given the high 
investment in both infrastructure and technology, these facilities maintain strict physical security measures in the 
form of perimeter fencing, controlled access, and on-site personnel. 
In addition to permanent campus employment, the project will generate substantial economic activity during its 
development, including hundreds of construction, utility, and support service jobs. Once operational, the site will 
contribute significantly to the local economy through both real and property taxes, helping to fund public services 
and infrastructure within Maricopa County.   
3. RELATIONSHIP TO SURROUNDING PROPERTIES
As seen in Table B – Surrounding Adjacent General Land Descriptions, the Project is vacant property surrounded 
by other vacant and agricultural lands. HEGIC would look to complement the other land uses in the greater 
Harquahala Valley area which include a host of existing and planned renewable energy production centers, battery 
energy storage facilities and industrial uses. These uses take advantage of the areas remoteness and existing 
infrastructure, anchored by the nearby Harquahala Power Plant located a few miles to the south. 
Table B – Surrounding Adjacent General Land Descriptions 
Direction
Zoning 
Land Use Designation 
Current Use 
Site 
IND-2 IUPD/RU-43 
Utilities/Rural Development Areas 
Vacant 
North 
RU-43 
Rural Development Areas 
Vacant/Interstate 10 
East 
IND-2 IUPD/RU-43 
Utilities/Rural Development Areas 
Vacant 
South 
RU-43 
Rural Development Areas 
Agricultural/Vacant 
West 
IND-2 IUPD/RU-43 
Utilities/Rural Development Areas 
Agricultural/Vacant 
With this proper planning and strategic site selection, HEGIC addresses the primary concern associated with the 
increasing regional demand for data centers: the risk of developments encroaching upon residential and commercial 
areas, thereby disrupting neighboring communities. In response, Harquahala Campus LLC is committed to 
developing a master-planned campus that offers a cohesive framework for future data center construction and 
energy generation—strategically located to minimize community impact and maximize access to critical 
infrastructure.

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Harquahala Energy Generation & Industrial Campus 
looks to expand upon the ongoing improvements being 
constructed as a part of the recently approved Maricopa 
Energy Center (CPA2020002, Z2023133, PD240017) 
project. In addition to MEC, many of the surrounding 
parcels around the Project have been subject to 
previous entitlements and approvals, by the Board of 
Supervisors, including the Applicants Harquahala Sun 
projects. Overall, there are roughly 30,000 acres of 
Utility/Industrial 
approvals 
within 
the 
immediate 
Harquahala Valley area, making HEGIC a natural fit for 
this location. In addition to improving reliability, co-
locating with solar and BESS infrastructure supports 
long-term cost savings and sustainability goals. 
Additionally, offering more energy generation options 
provides significant operational, environmental, and 
economic advantages. Data centers operate around the 
clock and require a highly reliable power supply. It also 
reduces reliance on traditional utilities and mitigates 
exposure to unreliable energy sources. From a land-use 
and planning perspective, solar farms and battery 
systems complement data center campuses well, as 
they generate limited traffic and noise. This strategic 
pairing demonstrates a commitment to responsible 
development. Ultimately, this synergy promotes faster 
project 
deployment, 
energy 
independence, 
and 
sensitivity to the surrounding community. 
In addition to these planned utility and industrial developments, as shown in Exhibit 2 – Surrounding 
Utilities/Industrial Land Uses and Table C – Existing Surrounding Solar (Utility) Land Use Approvals, the 
surrounding area is mainly characterized by active and passive agricultural land uses, Bureau of Land Management 
(BLM) and Arizona State Land Department (ASLD) owned and managed lands, native desert lands along with a 
few sparsely distributed residential land uses.  
The proposed Zone Change with Overlay and General CPA to allow for uses permitted in the IND-2 zoning district 
including solar electric generating facilities, battery energy storage system (BESS), ancillary offices, data centers, 
electrical distribution facilities, roof and ground mounted mechanical and solar systems, gas generating facilities, 
substations, other power equipment, and water storage and treatment are compatible with the approved and/or 
implemented mixture of surrounding approvals. These approvals include solar projects, BESS, a hydrogen facility, 
utility corridors, transmission lines, substations, a gas generation power plant and industrial uses all within an 
approximately 5-mile radius of the Project site. Also, compared to residential development, permissible under the 
current zoning, the data center requires fewer public services and infrastructure support. Similar to these approvals, 
no landscaping is proposed or required. Other site details will be coordinated during the subsequent Plan of 
Development (POD) submittal including further coordination with the Arizona Game and Fish Department based on 
the development of the specific site plan. Additionally, because this area is near several military training routes 
Exhibit 2 – Surrounding Utilities/Industrial Land Uses

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(MTRs) in the area, the Project will be submitted for an informal review through the DoD Siting Clearinghouse for 
Energy, Installations, and Environment 
Moreover, the Project aligns with the County’s 2030 Vision by fostering a high-tech economic environment offering 
quality employment opportunities available to residents in the county’s far west region. Jobs within the data center 
sector typically offer strong wages, with many roles accessible to local residents who possess relevant technical 
skills. Overall, job opportunities in computer and information technology-related fields are projected to grow at a 
rate well above the national average. 
Table C – Existing Surrounding Solar (Utility) Land Use Approvals 
Project 
Location (Township/Range) 
Maricopa Solar and Storage Project 
T1N R8W; T1N R9W; T2N R8W; T2N R9W 
Harquahala Sun 
T1N R9W 
Harquahala Sun II and III 
T1N R9W 
Saddle Mountain Solar I and II 
T1N R9W 
Eagletail Solar Farm 
T1S R9W 
Areva Solar AZ II 
T2N R7W 
Almeria Solar 
T2N R8W 
Sun Valley North 
T2N R8W 
Sun Valley South 
T2N R8W 
Maricopa Energy Center 
T2N R8W; T2N R9W 
Papago Solar 
T2N R8W 
Tonopah Photovoltaic 
T2N R8W 
4. LOCATION AND ACCESSIBILITY
Location: 
The Project site is currently vacant, located 11 miles west of Tonopah, south of Interstate 10, north of Camelback 
Road, between 499th Avenue and 507th Avenue in Township 2 North, Range 9 West, sections 11, 12, & 13. 
Access: 
The Project is located south of Interstate 10, approximately 30 miles west of the State Route 85 (SR 85)
connection to I-10.
The proposed site will be accessed regionally from Interstate 10 (I-10). Local access to the site will be provided
by Salome Highway.
I-10 has a functional classification from ADOT of principal arterial in the vicinity of the project area. It is an east-
west aligned roadway with two lanes in each direction and unpaved shoulders. The speed limit on this roadway
is 75 mph.
Salome Highway is paved at its connection to I-10 but is mostly unpaved in the vicinity of the project area. It is
classified as a minor collector by ADOT and has a future classification of minor collector by MCDOT.
Harquahala Valley Road has a functional classification from ADOT of minor collector, running north-south through
the center of the MEC project site. The road is paved and has a speed limit of 50. The MCDOT future classification
for this roadway is a minor arterial.

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Camelback Road is not functionally classified around the project site. It is an unpaved road that runs east west 
through the project site and connects Harquahala Valley Road and Salome Highway. MCDOT does not classify 
this roadway in the future in proximity to the site but classified the roadway as a minor arterial further east.
499th Avenue is not functionally classified around the project site. It is a north-south aligned paved roadway with 
a future classification from MCDOT as a minor collector.
507th Avenue is not functionally classified near the project site. It is a north-south aligned paved roadway with a 
future classification from MCDOT as a major collector.
Access to the site will be established by a variety of full-access driveways determined during the subsequent Plan 
of Development.
Maricopa County Department of Transportation (MCDOT) requires that driveways be spaced a minimum of 250 
feet from adjacent intersections on major collector roadways. 
5. CIRCULATION SYSTEM
Off-site Circulation (Access) 
The roadway network serving the proposed Project from the Interstate 10 corridor includes the I-10/Salome Highway 
interchange that connects to the Salome Highway which provides access to 499th and 507th Avenues south to 
Camelback Road. Specific site access points will be identified with the subsequent Plan of Development with final 
access locations, as coordinated with MCDOT, in accordance with access management policies and permitting 
requirements of Maricopa County. 
Harquahala Energy Generation & Industrial Campus will, at a minimum, preserve 65’ half street right-of-way for 
Salome Highway and a minimum of 55’ half street(s) right-of-way dedication for Camelback Road, 507th Avenue 
and 499th Avenue. Per Maricopa County Zoning Ordinance Section 1105, HEGIC will provide the necessary 
setbacks starting from the future half street rights-of-way of 65’ and 55’ respectively. Offsite improvements and any 
additional right-of-way needed will be determined by MCDOT Traffic Design and MCDOT Permits based on the 
submittal of a TIA/TIS during the Plan of Development phase. Final dedication, preservation, alignments, 
terminations, and vacations of unneeded ROW will be determined in negotiation with MCDOT. 
On-site Circulation 
Internal circulation is planned via a network of private driveways and maintenance and service drive aisles to provide 
vehicular access to the proposed facilities. For all solar, BESS and energy generation uses, driveway aprons (as 
specified by MCDOT), shall be paved with a minimum asphalt millings bound with a liquid binding emulsifier, or 
comparable, with the remainder of the typical 20’ internal drives being compacted decomposed granite (DG), or 
similar road base material to minimize imperviousness and stormwater runoff, as proposed with an approved dust 
control permit from Maricopa County Air Quality Control. Construction and maintenance of the drives will conform 
to applicable requirements of the Maricopa County Air Quality Control Department  
Parking and Loading 
HEGIC’s proposed reduced parking requirements, as a part of this IUPD, are because the operational model of the 
proposed uses that differ significantly from traditional industrial facilities. Data centers are highly automated and 
require less on-site staff, even in large-scale operations. Unlike office buildings or warehouses that experience high 
employee density and regular customer or vendor traffic, data centers typically have a smaller, rotating crew of 
technicians, engineers, and security personnel on duty at any given time. Requiring standard industrial parking 
ratios, based on square footage rather than actual staffing needs, results in excessive, unused paved areas that

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waste land, increase stormwater runoff, and reduce overall site efficiency. A more appropriate, reduced parking 
standard would better reflect real-world usage, minimize environmental impacts, and support smarter land use 
planning. 
6. DEVELOPMENT SCHEDULE
Following approval of the concurrent Zone Change with Overlay and General Comprehensive Plan Amendment 
applications, the Applicant would submit a separate Plan of Development application for administrative review. 
Pending POD approval and subsequent permit approvals, the Applicant would move forward with an initial phase 
of the development with the size and scope subject to market conditions at the time of approvals. 
7. COMMUNITY FACILITIES AND SERVICES
The Project is not anticipated to generate any adverse impacts to the listed school districts. The Project is located 
within the following district boundaries: 

Western Maricopa Education Center (MEC) Technical School District (District Ward No. 2)

Buckeye Union High School District No. 1

Arlington School District No. 47
8. PUBLIC UTILITIES AND SERVICES
Unless otherwise coordinated with County staff during the subsequent POD, given alternative cooling technologies 
available and limited employees on-site, the proposed data centers are planned to operate without public 
water/sewer sources. Service(s) to the Project site will be provided by the following providers. Water for construction 
purposes will be transported to the site.  
Table D – Public Utilities and Services 
UTILITY/SERVICE 
AGENCY/PROVIDER 
Water 
Hauled / Well 
Sewer 
Septic / Accessible portable restroom facilities, for solar, BESS and 
energy generation, as needed for maintenance activities. In the event 
that a future O&M building is built and/or permanent employees are 
present on the site wastewater will be treated by septic. 
Electric Service 
Arizona Public Service 
Fire Protection (including EMS and 
Ambulatory Services) 
Harquahala Valley Fire District 
Police Protection 
Maricopa County Sheriff Office 
Refuse (Waste Management) 
Republic Services 
Telephone 
American Telephone and Telegraph (AT&T) Co 
Irrigation 
Harquahala Valley Irrigation District

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TABLE 1: INDUSTRIAL UNIT PLAN OF DEVELOPMENT 
Development Standards Table 
Regulation 
Base IND-2 Zoning Regulation 
Proposed IND-2 IUPD 
Zoning Regulations 
Max. Height 
40' 
103' 
Min. Front Yard Setback
10'-25' 
10'-25'; 0' for solar panel arrays; 100’ for BESS 
containers 
Min. Side Yard Setback
0'-10' 
0'-10'; 0' for solar panel arrays; 100’ for BESS 
containers 
Min. Rear Yard Setback
0'-25' 
0'-25'; 0' for solar panel arrays; 100’ for BESS 
containers 
Min. Lot Area 
6,000 sq. ft. 
6,000 sq. ft. 
Min. Lot Width 
60’ 
60’ 
Max. Lot Coverage 
60% 
60%, solar panel arrays are not calculated as lot 
coverage. 
Parking Regulations 
One per 600 sq.ft of floor area; 5% 
of parking spaces shall be 
handicapped parking spaces. 
BESS/Energy Generation: None required. Data 
Center: One per 1,000 sf of floor area for the first 
10,000 sq.ft. and then One per 5,500 sq.ft. of 
remaining floor area. 
Paving Regulations 
Driveways and Parking areas shall 
be paved. 
BESS/Energy Generation: Stabilized decomposed 
granite with approved granite with an approved 
MCAQ dust control plan for Driveways and Parking 
areas. 
Loading & Unloading 
One space for every 10,000 sq.ft 
of floor area. 
Minimum of one space per building. BESS/Energy 
Generation: None required 
Site Visibility Triangles 
(SVT’s) 
No obstructions over 2' (h) within 
25'x25' SVT's. 
No obstructions over 2' (h) within 25'x25' SVT's. 
BESS/Energy Generation: No SVT’s at project site 
entry/exit points, section line and midsection line 
intersecting alignments.

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Uses/Building 
Enclosures 
All uses except for parking, 
loading, unloading or storage shall 
be conducted within a completely 
enclosed building. 
All uses except for parking, loading, unloading, storage, 
electric generation, electric storage, electric 
transmission, and data center infrastructure shall be 
conducted within a completely enclosed building. 
Site Enclosure and 
Screening 
Minimum 6' tall solid wall around 
the perimeter and to screen 
outdoor industrial uses. 
Minimum 6’ tall chain link fencing and gates without 
attached screening material around the perimeter of 
the site and to screen outdoor industrial uses. 
Wildlife-compatible fencing shall be allowed if 
warranted by AZG&FD. 1’ of barbed wire fencing 
shall be permitted on top of any chain link fence. 
Maximum 12’ tall aluminum anti-climb fencing shall 
be allowed. 
Maximum Electrical 
Transmission Line 
Height 
120’ 
196’ 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(The remainder of this page is left intentionally blank)

Page | 1  
 
 
Subdivision 
Infrastructure  
& Planning Program 
301 W. Jefferson St. 
Phoenix, AZ 85003 
 
S u b d i vi s io n @ m a ri co p a .go v 
e s d .m a r i c o pa .g o v 
 
 
 
 
 
The Maricopa County Environmental Services Department (MCESD) has completed review 
for the Harquahala Energy Generation and Industrial Campus planning case(s). Please note 
the following MCESD requirements for site development: 
 
Drinking Water –  
Per the Safe Drinking Water Act, any water system that supplies more than 25 people or 15 
service connections per day for at least 60 days per year is classified as a Public Water 
System (PWS).  
• 
If the above criteria are met, a Public Water System application and a New Source 
Approval application are required and must be submitted to the MCESD’s Drinking 
Water Program. A water quality analysis report will be required with submittal and is 
good within one-year of testing. 
 
An Approval to Construct application is required to be submitted to the MCESD’s Treatment 
Program for all PWS water treatment facilities. 
• 
For questions, please contact the Water/Wastewater Treatment Program at (602) 
372-2861 or email treatmentplantprogram@maricopa.gov 
 
An Approval to Construct application is required to be submitted to the MCESD’s 
Subdivision & Infrastructure Program for all PWS water system infrastructure. 
• 
For questions, please contact the Subdivision and Infrastructure Program at (602) 
506-1058 or email subdivision@maricopa.gov 
 
For additional Drinking Water related questions, please contact the Drinking Water program 
at (602) 506-6935 or by email at sdwquestions@maricopa.gov. 
 
Project Name: Harquahala Energy 
Generation and Industrial Campus 
Primary Contact Name: Keith Nichter 
Planning Application Type: Zone Change 
with Overlay 
APN(s): 506-18-18A, 506-18-019B, 506-
18-022S 
Reviewer: Elliott Wheaton, P.E. 
Email: Elliott.Wheaton@maricopa.gov 
Phone: 602-376-6035 
Planner Name: Martin Martell 
Planning Case #: Z250015 
Date: May 16, 2025 
 
Water and Waste Management Division

Page | 2  
 
 
Onsite Wastewater (Septic) –  
A Notice of Intent to Discharge application for a septic system is required for any 
construction. The application must be submitted to the MCESD Onsite Wastewater 
Program. 
• 
Wastewater is not permitted to discharge to an adjacent parcel’s septic system. 
• 
If conducting food service in unincorporated Maricopa, a grease trap will be 
required by Onsite Wastewater program. 
• 
Setback requirements must be maintained per Arizona Administrative Code, Title 
18, Chapter 9, Article 312, C (Features Requiring Setbacks). 
 
Projected flows between 3000 and 24,000 gallons per day require a 4.23 General Permit and 
may require nitrogen treatment. 
 
For Onsite Wastewater related questions, please contact the Onsite Program at (602) 506-
6666 or by email at septicquestions@maricopa.gov. 
 
Additional Notes –  
*It should be noted that this document does not approve the referenced project. Comments are provided 
for the benefit of the applicant for MCESD permit requirements and as an advisory to Maricopa County 
Planning and Development Department. 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 current regulations at the time of application.

Page 1 of 2 
 
 
 
 
 
 
 
 
 
 
 
James Philbin, PE 
Planning & Development 
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003 
Phone: (602) 372-4362 
www.maricopa.gov/planning 
Email address: 
james.philbin@maricopa.gov 
Planning & Development 
 
Engineering Plan Review 
Date:    
May 19, 2025 
 
Memo To: Darren Gerard, AICP, Planning Manager, Department of Planning & 
Development 
 
Attn: 
Martin Martell, Planner, Planning & Development Services 
 
 
From: 
James Philbin, P.E., Plans Examiner Engineer, Planning & 
Development Services 
 
cc: 
Bob Fedorka, P.E., Engineering Manager, Planning & Development 
 
Subject:   
Z250015 - Zone Change (RU-43 to IND-2 IUPD) 
 
(E1 Memo) 
Job Site Address: 50219 W Glendale Ave. Tonopah, AZ 85354 
 
APN(s): 506-18-018A, 022S; -019B; -016C; -024B; -022K; -019A; -024A; -022F; -
023 -022N; -029F; -016B; -022J; -022M; -022L; -017D; -019C; -016D; -
016D; -022R 
 
This application is to specify zoning for future development and does not include a 
Plan of Development. 
 
PND Engineering Plan Review (DPR, FCD and PND Transportation) has reviewed the 
1st submittal of the Zone Change application routed for review on April 21, 2025, and 
has no objections subject to the following conditions: 
 
1. Without the submittal of a precise plan of development, no development approval 
is inferred by this review, including, but not limited to number of proposed building 
lots/units, drainage design, access and roadway alignments. These items will be 
addressed as development plans progress and are submitted to the County for 
further review and/or entitlement. 
 
2. Each phase of development will require a plan of development and Traffic Impact 
Study.  Each phase must be able to stand alone with respect to site infrastructure, 
including utilities, access and storm water management. 
 
3. Salome Highway is classified as a principal arterial requiring fee dedication of a 
65-foot half street from the center line, total 130-feet. 
• 
Applicant is required to provide, at applicant’s expense, an American Land 
Title Association(“ALTA”) Owner’s Policy of Title Insurance showing title 
vested in Maricopa County, a political subdivision of the State of Arizona.

Page 2 of 2 
  
4. Any additional dedication and offsite improvement requirements will be 
determined by MCDOT Traffic based on a submitted TIA/TIS to Permit Center at 
https://www.maricopa.gov/6003/Maricopa-Countys-New-Permit-Center . 
• 
If a TIA/TIS has been previously submitted, the TIA/TIS must be less than 
one year old. 
 
5. All perimeter section line and mid-section line alignments of the proposed 
development require the setback lines to start from a future half street Right-of-
Way of 55- and 40-feet (respectively) per the Maricopa County Zoning Ordinance 
Section 11-05. 
 
6. Applicant to notify ADOT of proposed project through the Red Letter Process, 
RedLetter@azdot.gov, due to the proximity to the I-10. 
 
7. The above comments do not include identification of utilities or underground 
facilities within or adjacent to the required right-of-way that may have prior rights 
and/or require relocation. 
 
8. Engineering review of re-zone cases is conceptual in nature. All development and 
engineering design shall be in conformance with Section 1205 of the Maricopa 
County Zoning Ordinance; Drainage Policies and Standards; Floodplain 
Regulations for Maricopa County; MCDOT Roadway Design Manual; and current 
engineering policies, standards and best practices at the time of application for 
construction. 
 
Please contact me if you have any questions or require any additional information.

DEPARTMENT OF THE AIR FORCE 
AIR EDUCATION AND TRAINING COMMAND 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3 June 2025 
Mr. Mark James 
Interim Director, Community Initiatives Team 
56th Fighter Wing 
14185 W. Falcon Street 
Luke AFB AZ 85309-1629 
 
 
Mr. Martin Martell 
Maricopa County Planning & Development Department 
501 North 44th Street, Suite 200 
Phoenix, AZ 85008 
 
RE:  CPA250002, Z250015; Harquahala Energy Generation Complex 
 
Dear Mr. Martell 
 
 
Thank you for the opportunity to comment on the Harquahala Energy Generation Complex 
application.  This proposal will allow the addition of data center use along with their ancillary uses, which 
includes electric transmission, generation and distribution facilities and power storage facilities, within this 
917-acre portion of the project. The site, currently vacant, is located 11 miles north-west of Tonopah, south of 
I-10 and north of the Camelback Road, between 499th Avenue and 507th Avenue in Maricopa County, AZ 
 
This project is located underneath or near several military training routes (MTRs) in the area; 
therefore, please ensure the project is submitted for an informal review through the DoD Siting Clearinghouse 
for Energy, Installations, and Environment by sending the project narrative for review to:  osd.dod-siting-
clearinghouse@mail.mil.   
 
If applicable, it should be noted that certain investments and real estate transactions within the military 
installation footprint of Luke AFB may be subject to review by the Committee on Foreign Investment in the 
United States (CFIUS) to determine the effect of such transactions on the national security of the United 
States.  The CFIUS regulations, Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) 
provisions, and related resources can be found on the Department of the Treasury’s website: 
http://www.treasury.gov/cfius. 
 
 
If you have any questions, please contact me at (623) 856-6175. 
 
             Sincerely 
 
 
 
  
 
 
 
 
 
 
             MARK C. JAMES 
 
cc: 
Colonel Matthew Johnston, Deputy Commander, 56th Fighter Wing 
Ms. Demetria Themistocles, General Law Attorney, 56th Fighter Wing 
 
SIGN

‭June 11, 2025‬
‭Mr. Martin Martell‬
‭Planning & Development‬
‭Maricopa County‬
‭301 W. Jefferson St., Suite 170‬
‭Phoenix, AZ 85003‬
‭Electronically submitted to:‬‭Martin.Martell@maricopa.gov‬
‭RE:‬
‭CPA250002 & Z250015 - Harquahala Energy Generation & Industrial Campus‬
‭Dear Mr. Martell:‬
‭The‬‭Arizona‬‭Game‬‭and‬‭Fish‬‭Department‬‭(Department)‬‭appreciates‬‭the‬‭opportunity‬‭to‬‭review‬‭the‬
‭Pre-Application‬‭Narrative‬‭for‬‭a‬‭Comprehensive‬‭Plan‬‭Amendment‬‭(CPA)‬‭and‬‭Zone‬‭Change‬‭with‬
‭Overlay‬‭for‬‭the‬‭Harquahala‬‭Energy‬‭Generation‬‭&‬‭Industrial‬‭Campus‬‭(Project).‬‭The‬‭Department‬
‭understands‬ ‭that‬ ‭Kimley-Horn,‬ ‭on‬ ‭behalf‬ ‭of‬ ‭Maricopa‬ ‭Energy‬ ‭Center,‬ ‭LLC,‬ ‭has‬ ‭requested‬ ‭a‬
‭pre-application‬ ‭meeting‬ ‭with‬ ‭the‬ ‭Maricopa‬ ‭County‬ ‭Planning‬ ‭&‬ ‭Development‬ ‭Department‬ ‭to‬
‭discuss‬‭the‬‭process‬‭involved‬‭in‬‭permitting‬‭an‬‭energy‬‭generation‬‭and‬‭industrial‬‭campus‬‭as‬‭a‬‭part‬
‭of‬‭the‬‭larger‬‭Maricopa‬‭Energy‬‭Center‬‭(MEC)‬‭project.‬‭It‬‭is‬‭understood‬‭that‬‭changing‬‭the‬‭zoning‬
‭of‬‭the‬‭Project‬‭area‬‭from‬‭RU-43‬‭(Rural)‬‭and‬‭IND-2‬‭IUPD‬‭(Light‬‭Industrial),‬‭to‬‭IND-2‬‭IUPD,‬‭and‬
‭changing‬ ‭the‬ ‭land‬ ‭use‬ ‭designation‬ ‭through‬ ‭the‬ ‭CPA‬ ‭from‬ ‭‘Rural‬ ‭Development‬ ‭Area’‬ ‭to‬
‭‘Utilities’,‬‭will‬‭allow‬‭for‬‭the‬‭addition‬‭of‬‭data‬‭center‬‭use‬‭and‬‭other‬‭ancillary‬‭uses‬‭such‬‭as‬‭electric‬
‭transmission,‬ ‭generation,‬ ‭distribution,‬ ‭and‬ ‭power‬ ‭storage‬ ‭facilities,‬ ‭alongside‬ ‭the‬ ‭solar‬ ‭and‬
‭battery‬‭energy‬‭storage‬‭of‬‭the‬‭MEC.‬‭The‬‭Project‬‭is‬‭located‬‭on‬‭approximately‬‭917‬‭acres‬‭of‬‭private‬
‭land‬ ‭directly‬ ‭adjacent‬ ‭to‬ ‭the‬ ‭MEC,‬ ‭which‬ ‭is‬ ‭11‬ ‭miles‬ ‭north-west‬ ‭of‬ ‭Tonopah‬‭between‬‭499th‬
‭Avenue‬ ‭and‬ ‭507th‬ ‭Avenue,‬ ‭just‬‭south‬‭of‬‭the‬‭I-10‬‭and‬‭north‬‭of‬‭Camelback‬‭Road,‬‭in‬‭primarily‬
‭undisturbed Sonoran desert scrub habitat.‬
‭Under‬ ‭Title‬ ‭17‬ ‭of‬ ‭the‬‭Arizona‬‭Revised‬‭Statutes,‬‭the‬‭Department,‬‭by‬‭and‬‭through‬‭the‬‭Arizona‬
‭Game‬ ‭and‬ ‭Fish‬ ‭Commission,‬ ‭has‬ ‭jurisdictional‬ ‭authority‬ ‭and‬ ‭public‬ ‭trust‬ ‭responsibilities‬ ‭to‬
‭conserve‬‭and‬‭protect‬‭the‬‭state‬‭fish‬‭and‬‭wildlife‬‭resources.‬‭In‬‭addition,‬‭the‬‭Department‬‭manages‬
‭threatened‬‭and‬‭endangered‬‭species‬‭through‬‭authorities‬‭of‬‭Section‬‭6‬‭of‬‭the‬‭Endangered‬‭Species‬
‭Act‬ ‭and‬ ‭the‬ ‭Department’s‬ ‭Section‬ ‭10(a)(1)(A)‬ ‭permit.‬ ‭It‬ ‭is‬ ‭the‬‭mission‬‭of‬‭the‬‭Department‬‭to‬
‭conserve‬ ‭and‬ ‭protect‬ ‭Arizona's‬ ‭diverse‬ ‭fish‬ ‭and‬ ‭wildlife‬ ‭resources‬ ‭and‬ ‭manage‬ ‭for‬ ‭safe,‬
‭compatible‬ ‭outdoor‬ ‭recreation‬ ‭opportunities‬ ‭for‬ ‭current‬ ‭and‬ ‭future‬ ‭generations.‬ ‭For‬ ‭your‬
‭consideration,‬‭the‬‭Department‬‭provides‬‭the‬‭following‬‭comments‬‭based‬‭on‬‭the‬‭agency's‬‭statutory‬
‭authorities,‬ ‭public‬ ‭trust‬‭responsibilities,‬‭and‬‭special‬‭expertise‬‭related‬‭to‬‭wildlife‬‭resources‬‭and‬
‭recreation.‬

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‭Page‬‭2‬
‭The‬ ‭Department‬ ‭recognizes‬ ‭the‬ ‭importance‬ ‭of‬ ‭planning‬ ‭efforts‬ ‭to‬ ‭develop‬ ‭renewable‬ ‭energy‬
‭locations‬‭that‬‭contribute‬‭to‬‭regional‬‭and‬‭state‬‭economic‬‭growth‬‭needs‬‭and‬‭would‬‭like‬‭to‬‭work‬
‭closely‬ ‭with‬ ‭Kimley-Horn,‬ ‭Maricopa‬ ‭Energy‬ ‭Center,‬ ‭LLC,‬ ‭and‬ ‭Maricopa‬ ‭County‬ ‭during‬ ‭the‬
‭planning‬ ‭and‬ ‭development‬ ‭of‬ ‭this‬ ‭facility.‬ ‭The‬ ‭Department‬ ‭recognizes‬ ‭that‬ ‭appropriate‬
‭coordination,‬ ‭proper‬ ‭planning,‬ ‭and‬ ‭voluntary‬ ‭implementation‬ ‭of‬ ‭best‬ ‭management‬ ‭practices‬
‭allow‬‭projects‬‭to‬‭be‬‭developed‬‭that‬‭avoid,‬‭minimize,‬‭or‬‭offset‬‭potential‬‭impacts‬‭to‬‭wildlife‬‭and‬
‭recreational‬‭access‬‭during‬‭development‬‭and‬‭operation‬‭of‬‭the‬‭facilities.‬‭For‬‭your‬‭consideration,‬
‭the‬ ‭Department‬ ‭provides‬ ‭the‬ ‭following‬ ‭comments‬ ‭based‬‭on‬‭the‬‭agency's‬‭statutory‬‭authorities,‬
‭public trust responsibilities, and special expertise related to wildlife resources and recreation.‬
‭Arizona‬‭has‬‭recently‬‭seen‬‭an‬‭increase‬‭in‬‭the‬‭number‬‭of‬‭proposed‬‭and‬‭in-development‬‭renewable‬
‭energy‬‭generation‬‭projects‬‭and‬‭associated‬‭infrastructure.‬‭A‬‭number‬‭of‬‭solar‬‭energy‬‭projects‬‭have‬
‭been‬ ‭built‬ ‭or‬ ‭proposed‬ ‭within‬ ‭the‬ ‭vicinity‬ ‭of‬ ‭this‬ ‭Project.‬ ‭Although‬ ‭each‬ ‭of‬ ‭these‬ ‭projects‬
‭individually‬‭may‬‭have‬‭a‬‭minimal‬‭impact‬‭on‬‭the‬‭broader‬‭landscape,‬‭these‬‭projects‬‭cumulatively‬
‭could‬‭result‬‭in‬‭loss‬‭of‬‭habitat,‬‭impact‬‭wildlife‬‭movements,‬‭and‬‭affect‬‭wildlife-related‬‭recreation.‬
‭Additionally,‬‭long-term‬‭effects‬‭to‬‭wildlife‬‭can‬‭extend‬‭several‬‭kilometers‬‭beyond‬‭the‬‭footprint‬‭of‬
‭a‬ ‭solar‬ ‭project‬ ‭area‬ ‭(‬‭Sawyer‬ ‭et‬‭al.‬‭2022‬‭).‬‭It‬‭is‬‭important‬‭to‬‭consider‬‭all‬‭potential‬‭cumulative‬
1
‭effects‬‭and‬‭to‬‭evaluate‬‭this‬‭Project‬‭in‬‭association‬‭with‬‭other‬‭projects‬‭in‬‭the‬‭area.‬‭Department‬‭staff‬
‭are‬ ‭available‬ ‭to‬ ‭assist‬ ‭in‬ ‭identifying‬ ‭potential‬ ‭cumulative‬ ‭impacts‬ ‭to‬ ‭wildlife‬ ‭and‬ ‭associated‬
‭voluntary conservation measures that can be implemented for the Project.‬
‭The‬ ‭Department‬ ‭recommends‬ ‭conducting‬ ‭surveys‬ ‭in‬ ‭the‬ ‭Project‬ ‭area‬ ‭to‬ ‭determine‬ ‭species‬
‭presence.‬‭These‬‭surveys‬‭should‬‭be‬‭of‬‭sufficient‬‭duration‬‭and‬‭intensity‬‭to‬‭adequately‬‭assess‬‭all‬
‭habitat‬ ‭types‬ ‭and‬ ‭potential‬ ‭wildlife‬ ‭species‬ ‭occurrence‬ ‭in‬ ‭and‬ ‭adjacent‬ ‭to‬ ‭the‬ ‭Project‬ ‭area.‬
‭Department‬‭staff‬‭are‬‭available‬‭to‬‭assist‬‭in‬‭determining‬‭appropriate‬‭surveys‬‭to‬‭conduct‬‭as‬‭well‬‭as‬
‭recommend‬ ‭design‬ ‭features‬ ‭and‬ ‭best‬ ‭management‬ ‭practices‬ ‭that‬ ‭can‬ ‭help‬ ‭minimize‬ ‭potential‬
‭impacts.‬ ‭Based‬ ‭on‬ ‭the‬ ‭information‬ ‭provided,‬ ‭the‬ ‭Department‬ ‭offers‬ ‭the‬ ‭following‬
‭recommendations‬‭to‬‭reduce‬‭potential‬‭impacts‬‭to‬‭wildlife‬‭and‬‭habitat;‬‭additional‬‭information‬‭can‬
‭be found in‬‭Guidelines for Solar Development in Arizona‬‭:‬
2
‭●‬ ‭The‬‭Sonoran‬‭desert‬‭tortoise,‬‭which‬‭is‬‭a‬‭federal‬‭and‬‭state‬‭species‬‭of‬‭special‬‭concern,‬‭has‬
‭been‬ ‭documented‬ ‭within‬ ‭3‬ ‭miles‬ ‭of‬ ‭the‬ ‭Project‬ ‭area.‬ ‭The‬ ‭Department‬ ‭recommends‬
‭conducting‬ ‭surveys‬‭for‬‭Sonoran‬‭desert‬‭tortoise‬‭within‬‭suitable‬‭habitat‬‭to‬‭determine‬‭the‬
‭presence‬‭of‬‭this‬‭species.‬‭The‬‭Sonoran‬‭Desert‬‭Tortoise‬‭Conservation‬‭Guidelines‬ ‭provide‬
3
‭protocols‬‭for‬‭these‬‭surveys.‬‭If‬‭this‬‭species‬‭is‬‭detected,‬‭please‬‭refer‬‭to‬‭this‬‭document‬‭for‬
‭guidelines‬‭on‬‭handling‬‭tortoises‬‭and‬‭recommended‬‭measures‬‭to‬‭avoid,‬‭minimize,‬‭or‬‭offset‬
‭impacts to this species resulting from development activities.‬
‭●‬ ‭The‬‭western‬‭burrowing‬‭owl,‬‭a‬‭special‬‭status‬‭species‬‭that‬‭is‬‭regulated‬‭under‬‭the‬‭Migratory‬
‭Bird‬‭Treaty‬‭Act‬‭(MBTA),‬‭has‬‭been‬‭documented‬‭within‬‭3‬‭miles‬‭of‬‭the‬‭Project‬‭area.‬‭The‬
‭Department‬‭recommends‬‭conducting‬‭occupancy‬‭surveys‬‭for‬‭this‬‭species‬‭in‬‭advance‬‭of‬‭the‬
‭3‬‭https://azgfd-portal-wordpress-pantheon.s3.us-west-2.amazonaws.com/wp-content/uploads/2025/01/16114611/Rubke-2024.-‬
‭Sonoran-Desert-Tortoise-Conservation-Guidelines.pdf‬
‭2‬‭https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/‬
‭FinalSolarGuidelines03122010.pdf‬
‭1‬‭https://esajournals.onlinelibrary.wiley.com/doi/10.1002/fee.2498‬

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‭Page‬‭3‬
‭design‬‭phase‬‭to‬‭understand‬‭distribution‬‭of‬‭burrowing‬‭owls‬‭in‬‭the‬‭Project‬‭site;‬‭avoidance‬
‭of‬‭a‬‭large‬‭burrowing‬‭owl‬‭population‬‭may‬‭be‬‭advisable‬‭over‬‭removal‬‭or‬‭other‬‭conservation‬
‭measures.‬ ‭Guidelines‬ ‭for‬ ‭conducting‬ ‭this‬ ‭survey‬ ‭are‬ ‭found‬ ‭in‬ ‭Burrowing‬ ‭Owl‬‭Project‬
‭Clearance‬‭Guidance‬‭for‬‭Landowners‬‭.‬‭Please‬‭note‬‭that‬‭the‬‭survey‬‭should‬‭be‬‭conducted‬
4
‭by‬ ‭a‬ ‭surveyor‬ ‭who‬ ‭is‬ ‭certified‬ ‭by‬ ‭the‬ ‭Department‬ ‭or‬ ‭has‬ ‭similar‬ ‭training‬ ‭and‬
‭qualifications.‬ ‭If‬ ‭an‬ ‭active‬ ‭burrowing‬ ‭owl‬ ‭burrow‬ ‭is‬ ‭detected,‬ ‭please‬ ‭contact‬ ‭the‬
‭Department‬ ‭and‬ ‭the‬ ‭U.S.‬ ‭Fish‬ ‭and‬ ‭Wildlife‬ ‭Service‬ ‭(USFWS)‬ ‭for‬ ‭direction,‬ ‭in‬
5
‭accordance with the guidelines.‬
‭●‬ ‭Golden‬ ‭eagles,‬ ‭which‬ ‭are‬ ‭regulated‬ ‭under‬ ‭the‬ ‭Bald‬ ‭and‬ ‭Golden‬ ‭Eagle‬ ‭Protection‬ ‭Act‬
‭(BGEPA),‬ ‭could‬ ‭occur‬ ‭within‬‭the‬‭Project‬‭vicinity.‬‭If‬‭uncertain‬‭about‬‭the‬‭effects‬‭of‬‭the‬
‭Project‬ ‭on‬ ‭eagles,‬‭or‬‭if‬‭it‬‭is‬‭anticipated‬‭the‬‭Project‬‭will‬‭not‬‭be‬‭in‬‭compliance‬‭with‬‭the‬
‭BGEPA,‬‭the‬‭Department‬‭recommends‬‭contacting‬‭the‬‭USFWS‬‭for‬‭technical‬‭assistance,‬‭as‬
‭well‬‭as‬‭the‬‭Department’s‬‭Raptor‬‭Coordinator‬‭at‬‭raptors@azgfd.gov‬‭or‬‭623-236-7575.‬‭The‬
‭USFWS‬‭and‬‭the‬‭Department‬‭will‬‭provide‬‭options‬‭to‬‭comply‬‭with‬‭the‬‭BGEPA,‬‭such‬‭as‬
‭conservation measures to avoid or minimize adverse effects on the eagles.‬
‭●‬ ‭The‬ ‭Project‬ ‭area‬ ‭contains‬ ‭suitable‬ ‭habitat‬ ‭for‬‭Bendire’s‬‭and‬‭LeConte’s‬‭Thrashers,‬‭two‬
‭bird‬ ‭species‬ ‭of‬ ‭conservation‬ ‭concern,‬ ‭and‬ ‭LeConte’s‬ ‭thrashers‬ ‭have‬ ‭been‬‭documented‬
‭within‬‭3‬‭miles‬‭of‬‭the‬‭Project‬‭area.‬‭Surveys‬‭for‬‭these‬‭thrashers‬‭are‬‭recommended‬‭per‬‭the‬
‭Desert‬‭Thrasher‬‭Working‬‭Group‬‭(DTWG).‬‭Please‬‭reference‬‭the‬‭DTWG’s‬‭Conservation‬‭of‬
‭Bendire’s‬‭and‬‭LeConte’s‬‭Thrashers‬‭at‬‭Solar‬‭Development‬‭Sites‬ ‭which‬‭outlines‬‭how‬‭to‬
6
‭determine occupancy of thrashers and design considerations if present.‬
‭●‬ ‭The‬ ‭Department‬ ‭recommends‬ ‭conducting‬ ‭avian‬ ‭surveys‬ ‭during‬ ‭the‬ ‭planning‬ ‭stage‬ ‭in‬
‭order‬ ‭to‬ ‭better‬ ‭understand‬ ‭species‬ ‭presence‬ ‭and‬ ‭to‬ ‭inform‬ ‭potential‬ ‭conservation‬
‭measures‬‭.‬‭Point‬‭counts‬‭are‬‭the‬‭preferred‬‭method‬‭for‬‭breeding‬‭bird‬‭surveys.‬‭These‬‭surveys‬
‭are‬ ‭conducted‬ ‭twice‬ ‭a‬ ‭year‬ ‭during‬ ‭the‬ ‭peak‬ ‭breeding‬ ‭season,‬ ‭which‬ ‭is‬ ‭mid-January‬
‭through‬‭mid-May‬‭in‬‭this‬‭area;‬‭McLaren‬‭et‬‭al.‬‭(2019)‬ ‭outline‬‭protocols.‬‭The‬‭Department‬
7
‭also‬‭recommends‬‭conducting‬‭surveys‬‭for‬‭nesting‬‭birds‬‭prior‬‭to‬‭vegetation‬‭removal‬‭and/or‬
‭construction‬‭activities‬‭that‬‭occur‬‭during‬‭the‬‭breeding‬‭season.‬‭The‬‭vegetation‬‭within‬‭the‬
‭Project‬‭area‬‭may‬‭provide‬‭nesting‬‭opportunities‬‭for‬‭avian‬‭species‬‭that‬‭are‬‭regulated‬‭under‬
‭the‬‭MBTA.‬‭If‬‭it‬‭is‬‭anticipated‬‭the‬‭Project‬‭will‬‭not‬‭be‬‭in‬‭compliance‬‭with‬‭the‬‭MBTA,‬‭the‬
‭Department recommends contacting the USFWS for technical assistance.‬
‭●‬ ‭Burrowing‬ ‭species‬ ‭could‬ ‭occur‬ ‭within‬ ‭the‬ ‭Project‬ ‭area‬ ‭and‬ ‭could‬ ‭be‬ ‭influenced‬ ‭by‬
‭construction‬‭activities‬‭and‬‭by‬‭loss‬‭of‬‭habitat.‬‭Surveys‬‭for‬‭these‬‭species‬‭are‬‭recommended‬
‭to‬‭determine‬‭their‬‭presence‬‭and‬‭to‬‭inform‬‭pre-construction‬‭activities.‬‭Department‬‭staff‬‭are‬
‭available‬ ‭to‬ ‭assist‬ ‭in‬ ‭identifying‬ ‭suitable‬ ‭conservation‬ ‭measures,‬ ‭such‬ ‭as‬ ‭one-way‬
‭exclosures‬ ‭on‬ ‭burrows‬ ‭that‬‭allow‬‭wildlife‬‭to‬‭exit‬‭the‬‭burrows‬‭and‬‭disperse‬‭to‬‭adjacent‬
‭lands in advance of construction.‬
‭Maintaining‬ ‭habitat‬ ‭connectivity‬ ‭is‬ ‭a‬ ‭priority‬ ‭for‬ ‭the‬ ‭Department,‬ ‭and‬ ‭wildlife‬ ‭movement‬
‭corridors‬ ‭are‬ ‭important‬ ‭for‬ ‭wildlife‬ ‭to‬ ‭respond‬ ‭to‬ ‭changing‬ ‭environmental‬ ‭conditions.‬ ‭This‬
‭7‬‭https://drive.google.com/drive/folders/1SF-iNJ8yc8YD0s3Uogbu-gOGxS39ADUP‬
‭6‬‭https://borderlandsbirds.org/wp-content/uploads/2024/09/Desert-Thrasher-Solar-Recommendations-1.0.pdf‬
‭5‬‭https://www.fws.gov/office/arizona-ecological-services/contact-us‬
‭4‬‭https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/nongame/eagles/BurrowingOwlClearanceProtocol‬
‭_2009.pdf‬

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‭Page‬‭4‬
‭Project‬‭falls‬‭within‬‭a‬‭Maricopa‬‭County‬‭Wildlife‬‭Movement‬‭Area,‬‭and‬‭the‬‭landscape‬‭in‬‭which‬‭this‬
‭Project‬ ‭is‬ ‭proposed‬ ‭may‬‭provide‬‭important‬‭movement‬‭pathways‬‭for‬‭wildlife.‬‭The‬‭Department‬
‭would‬‭like‬‭to‬‭meet‬‭with‬‭Kimley‬‭Horn‬‭and‬‭Maricopa‬‭Energy‬‭Center,‬‭LLC‬‭to‬‭discuss‬‭opportunities‬
‭to incorporate wildlife connectivity into the Project design, including the following:‬
‭●‬ ‭Ephemeral‬ ‭washes‬‭serve‬‭multiple‬‭functions‬‭in‬‭the‬‭ecosystem‬‭including‬‭landscape-level‬
‭conveyance‬‭corridors‬‭for‬‭wildlife‬‭movement,‬‭and‬‭there‬‭are‬‭a‬‭number‬‭of‬‭washes‬‭that‬‭flow‬
‭through‬‭the‬‭Project‬‭area.‬‭To‬‭the‬‭extent‬‭possible‬‭and‬‭in‬‭alignment‬‭with‬‭Land‬‭Use‬‭Policies‬
‭#22‬ ‭and‬ ‭#27,‬ ‭and‬ ‭Environmental‬ ‭Policy‬ ‭#4‬ ‭of‬ ‭Maricopa‬ ‭County’s‬ ‭Vision‬ ‭2030‬
‭Comprehensive‬ ‭Plan,‬ ‭the‬ ‭Department‬ ‭recommends‬ ‭incorporating‬ ‭design‬ ‭features‬ ‭that‬
‭maintain‬‭these‬‭washes‬‭in‬‭their‬‭natural‬‭state‬‭and‬‭without‬‭barriers‬‭(e.g.,‬‭fencing)‬‭in‬‭order‬‭to‬
‭reduce‬‭potential‬‭effects‬‭to‬‭vegetation‬‭and‬‭wildlife‬‭distribution‬‭and‬‭abundance‬‭beyond‬‭the‬
‭Project area.‬
‭●‬ ‭The‬‭Department’s‬‭Wildlife‬‭Compatible‬‭Fencing‬‭Guidelines‬ ‭provide‬‭information‬‭on‬‭how‬
8
‭fencing‬‭impacts‬‭wildlife,‬‭how‬‭to‬‭ensure‬‭wildlife‬‭movement‬‭is‬‭not‬‭restricted,‬‭and‬‭ways‬‭to‬
‭design‬‭fencing‬‭to‬‭prevent‬‭wildlife‬‭entanglement‬‭and‬‭impalement.‬‭Department‬‭personnel‬
‭are‬‭available‬‭as‬‭resources‬‭to‬‭help‬‭determine‬‭appropriate‬‭fencing‬‭design‬‭and‬‭layout‬‭that‬
‭will‬‭achieve‬‭its‬‭objective‬‭while‬‭reducing‬‭impact‬‭on‬‭wildlife,‬‭such‬‭as‬‭leaving‬‭a‬‭6–8-inch‬
‭gap‬ ‭between‬ ‭the‬ ‭ground‬ ‭surface‬ ‭and‬‭bottom‬‭of‬‭the‬‭fence‬‭to‬‭allow‬‭for‬‭smaller‬‭wildlife‬
‭species‬‭to‬‭move‬‭freely‬‭through‬‭the‬‭area‬‭and‬‭make‬‭use‬‭of‬‭any‬‭habitat‬‭within‬‭the‬‭Project‬
‭boundary.‬
‭Finally,‬ ‭the‬ ‭Department‬ ‭offers‬ ‭the‬ ‭following‬ ‭general‬ ‭recommendations‬ ‭to‬ ‭reduce‬ ‭potential‬
‭impacts to wildlife and habitat during construction and operation of the facility:‬
‭●‬ ‭A‬ ‭variety‬ ‭of‬ ‭other‬ ‭Arizona‬ ‭Species‬ ‭of‬ ‭Greatest‬ ‭Conservation‬ ‭Need‬ ‭(SGCN)‬ ‭have‬ ‭the‬
‭potential‬‭to‬‭occur‬‭within‬‭the‬‭Project‬‭area;‬‭please‬‭reference‬‭the‬‭attached‬‭HDMS‬‭report‬‭for‬
‭a‬ ‭complete‬ ‭list.‬ ‭If‬ ‭wildlife‬ ‭are‬ ‭encountered‬ ‭during‬ ‭Project‬ ‭activities,‬ ‭the‬ ‭Department‬
‭recommends‬‭moving‬‭them‬‭out‬‭of‬‭harm’s‬‭way,‬‭no‬‭more‬‭than‬‭0.25‬‭mile‬‭outside‬‭the‬‭Project‬
‭boundary‬‭within‬‭similar‬‭habitat.‬‭Please‬‭note‬‭that‬‭the‬‭Arizona‬‭State‬‭Wildlife‬‭Action‬‭Plan‬
‭was‬‭recently‬‭updated,‬‭and‬‭the‬‭Department‬‭has‬‭an‬‭interactive‬‭website,‬‭Arizona‬‭Wildlife‬
‭Conservation‬‭Strategy‬‭,‬‭that‬‭includes‬‭the‬‭most‬‭recent‬‭list‬‭of‬‭SGCN‬‭to‬‭help‬‭navigate‬‭and‬
9
‭identify conservation opportunities.‬
‭●‬ ‭If‬ ‭trenching‬ ‭or‬ ‭digging‬ ‭of‬ ‭large‬ ‭holes‬ ‭will‬ ‭occur,‬ ‭the‬ ‭Department‬ ‭recommends‬ ‭that‬
‭trenching/digging‬‭and‬‭backfilling‬‭crews‬‭work‬‭together‬‭to‬‭minimize‬‭the‬‭number‬‭of‬‭open‬
‭holes/trenches‬‭at‬‭any‬‭given‬‭time.‬‭Where‬‭trenches/holes‬‭cannot‬‭be‬‭backfilled‬‭immediately,‬
‭the‬‭Department‬‭recommends‬‭escape‬‭ramps‬‭be‬‭constructed‬‭in‬‭each‬‭hole‬‭and‬‭at‬‭least‬‭every‬
‭90‬ ‭meters‬ ‭in‬ ‭trenches.‬ ‭Escape‬ ‭ramps‬ ‭can‬ ‭be‬ ‭short‬ ‭lateral‬ ‭trenches‬ ‭or‬ ‭wooden‬ ‭planks‬
‭sloping‬‭to‬‭the‬‭surface,‬‭and‬‭ramp‬‭slopes‬‭should‬‭be‬‭less‬‭than‬‭45‬‭degrees‬‭(1:1).‬‭Trenches‬‭or‬
‭holes‬‭that‬‭have‬‭been‬‭left‬‭open‬‭should‬‭be‬‭inspected‬‭for‬‭animals‬‭and‬‭any‬‭animals‬‭removed‬
‭prior to backfilling.‬
‭●‬ ‭Artificial‬ ‭lighting‬‭could‬‭impair‬‭the‬‭ability‬‭of‬‭nocturnal‬‭animals‬‭to‬‭navigate‬‭(e.g.,‬‭owls,‬
‭migratory‬ ‭birds,‬ ‭bats,‬ ‭and‬ ‭other‬‭nocturnal‬‭mammals)‬‭and‬‭may‬‭affect‬‭wildlife‬‭behavior‬
‭9‬‭https://awcs.azgfd.com‬
‭8‬‭https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/‬
‭110125_AGFD_fencing_guidelines.pdf‬

‭CPA250002 & Z250015 - Harquahala Energy Generation & Industrial Campus‬
‭June 11, 2025‬
‭Page‬‭5‬
‭and‬ ‭populations‬ ‭(‬‭Davies‬ ‭et.‬ ‭al.‬ ‭2013‬ ‭).‬ ‭The‬ ‭Department‬ ‭recommends‬ ‭using‬ ‭only‬ ‭the‬
10
‭minimum‬ ‭amount‬ ‭of‬ ‭light‬ ‭needed‬ ‭for‬ ‭safety.‬ ‭If‬ ‭feasible,‬ ‭“warmer”‬ ‭narrow‬ ‭spectrum‬
‭lighting‬‭(amber,‬‭orange,‬‭red)‬‭is‬‭wildlife-friendly‬‭and‬‭should‬‭be‬‭used‬‭as‬‭often‬‭as‬‭possible‬
‭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.‬
‭●‬ ‭The‬ ‭information‬ ‭provided‬ ‭indicates‬ ‭that‬ ‭the‬ ‭Project‬ ‭may‬ ‭include‬ ‭retention‬ ‭basins‬ ‭at‬
‭multiple‬‭locations‬‭in‬‭the‬‭Project‬‭area.‬‭If‬‭rip-rap‬‭is‬‭required‬‭for‬‭the‬‭construction‬‭of‬‭on-site‬
‭retention‬ ‭basins‬ ‭or‬‭large-scale‬‭drainage‬‭needs,‬‭burying‬‭and‬‭back-filling‬‭with‬‭topsoil‬‭or‬
‭other‬‭substrate‬‭would‬‭allow‬‭wildlife‬‭to‬‭move‬‭through‬‭the‬‭basins‬‭as‬‭rip-rap‬‭is‬‭difficult‬‭for‬
‭many‬ ‭species‬ ‭to‬ ‭traverse.‬ ‭Department‬ ‭staff‬ ‭remain‬ ‭available‬ ‭to‬ ‭assist‬ ‭in‬ ‭identifying‬
‭potential‬‭impacts‬‭to‬‭wildlife‬‭and‬‭conservation‬‭measures‬‭to‬‭minimize‬‭potential‬‭impacts‬‭in‬
‭development or construction of erosion structures.‬
‭●‬ ‭Stinknet‬ ‭is‬ ‭a‬ ‭highly‬ ‭invasive‬ ‭noxious‬ ‭winter‬ ‭weed‬ ‭native‬ ‭to‬ ‭South‬ ‭Africa,‬ ‭and‬ ‭is‬
‭extremely‬‭flammable‬‭when‬‭dry.‬‭Stinknet‬‭(also‬‭known‬‭as‬‭globe‬‭chamomile)‬‭has‬‭heavily‬
‭infested‬‭Maricopa,‬‭Pinal,‬‭and‬‭Pima‬‭counties‬‭and‬‭is‬‭expanding‬‭into‬‭Yuma,‬‭Yavapai,‬‭and‬
‭Gila‬‭counties.‬‭Infestations‬‭spread‬‭rapidly‬‭along‬‭highways‬‭and‬‭open‬‭fields‬‭in‬‭residential‬
‭areas.‬ ‭Emergence‬ ‭starts‬ ‭in‬ ‭late‬ ‭November‬ ‭and‬ ‭plants‬ ‭can‬ ‭continue‬ ‭to‬ ‭germinate‬ ‭and‬
‭emerge‬ ‭through‬ ‭May‬ ‭in‬ ‭wet‬ ‭years.‬ ‭In‬ ‭order‬ ‭to‬ ‭minimize‬ ‭the‬ ‭spread‬‭of‬‭this‬‭plant‬‭it‬‭is‬
‭critical‬ ‭that‬ ‭any‬ ‭new‬ ‭infestations‬ ‭are‬ ‭identified‬ ‭and‬ ‭quickly‬ ‭managed.‬ ‭Additional‬
‭information‬ ‭is‬ ‭available‬ ‭through‬ ‭the‬ ‭Southwest‬ ‭Vegetation‬ ‭Management‬‭Association‬ ‭,‬
11
‭the‬‭Sonoran‬‭Desert‬‭Cooperative‬‭Weed‬‭Management‬‭Area‬ ‭,‬‭or‬‭the‬‭Arizona‬‭Native‬‭Plant‬
12
‭Society‬ ‭.‬
13
‭●‬ ‭Please‬ ‭ensure‬ ‭the‬ ‭Project‬ ‭complies‬ ‭with‬ ‭Arizona‬ ‭Native‬ ‭Plant‬ ‭Law‬
‭regulations.‬ ‭A‬
14
‭Native‬‭Plant‬‭Inventory‬‭may‬‭need‬‭to‬‭be‬‭conducted‬‭to‬‭identify,‬‭record,‬‭and‬‭coordinate‬‭plant‬
‭salvage efforts for species that are Protected under the Arizona Native Plant Law.‬
‭●‬ ‭To‬ ‭minimize‬ ‭the‬ ‭potential‬ ‭introduction‬ ‭or‬ ‭spread‬ ‭of‬‭exotic‬‭invasive‬‭species,‬‭including‬
‭aquatic‬‭and‬‭terrestrial‬‭plants,‬‭animals,‬‭insects,‬‭and‬‭pathogens,‬‭the‬‭Department‬‭encourages‬
‭taking‬‭precautions‬‭to‬‭wash‬‭and/or‬‭decontaminate‬‭equipment‬‭before‬‭entering‬‭and‬‭leaving‬
‭the‬‭site.‬‭See‬‭the‬‭Arizona‬‭Department‬‭of‬‭Agriculture‬‭website‬ ‭for‬‭a‬‭list‬‭of‬‭prohibited‬‭and‬
15
‭restricted‬‭noxious‬‭weeds‬‭and‬‭the‬‭Arizona‬‭Native‬‭Plant‬‭Society‬ ‭for‬‭recommendations‬‭on‬
16
‭how‬‭to‬‭control‬‭them.‬‭To‬‭view‬‭a‬‭list‬‭of‬‭documented‬‭invasive‬‭species‬‭or‬‭to‬‭report‬‭invasive‬
‭species‬‭in‬‭or‬‭near‬‭the‬‭Project‬‭area,‬‭visit‬‭iMapInvasives‬ ‭,‬‭which‬‭is‬‭a‬‭national‬‭cloud-based‬
17
‭application for tracking and managing invasive species.‬
‭●‬ ‭The‬ ‭Department‬ ‭recommends‬‭revegetating‬‭disturbed‬‭areas‬‭with‬‭native‬‭drought-tolerant‬
‭species‬‭that‬‭represent‬‭the‬‭natural‬‭surrounding‬‭landscape.‬‭Landscaping‬‭with‬‭native‬‭plants‬
‭can‬ ‭help‬ ‭support‬ ‭wildlife‬ ‭and‬ ‭pollinator‬ ‭species‬ ‭in‬ ‭the‬ ‭area‬ ‭while‬ ‭reducing‬ ‭dust‬ ‭and‬
‭17‬‭https://imap.natureserve.org/imap/services/page/map.html‬
‭16‬‭https://aznps.com‬‭/‬‭invas‬
‭15‬‭https://agriculture.az.gov/pestspest-control/agriculture-pests/noxious-weeds‬
‭14‬‭https://agriculture.az.gov/plantsproduce/native-plants‬
‭13‬‭http://aznps.com‬
‭12‬‭https://www.sdcwma.org/species/stinknet.php‬
‭11‬‭https://www.swvma.org/‬
‭10‬‭https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3657119‬

‭CPA250002 & Z250015 - Harquahala Energy Generation & Industrial Campus‬
‭June 11, 2025‬
‭Page‬‭6‬
‭erosion.‬ ‭In‬ ‭addition,‬ ‭the‬ ‭applicable‬ ‭land‬ ‭management‬ ‭agencies‬ ‭should‬ ‭be‬ ‭consulted‬
‭regarding guidelines for revegetation efforts.‬
‭Thank‬‭you‬‭for‬‭the‬‭opportunity‬‭to‬‭provide‬‭input‬‭on‬‭Maricopa‬‭County‬‭CPA250002‬‭&‬‭Z25015‬‭-‬
‭Harquahala‬ ‭Energy‬ ‭Generation‬ ‭&‬ ‭Industrial‬ ‭Campus.‬ ‭For‬‭further‬‭coordination,‬‭please‬‭contact‬
‭Teigan Williams at‬‭tstruck@azgfd.gov‬‭or (928) 341-4069.‬
‭Sincerely,‬
‭Callie Cavalcant‬
‭Habitat, Evaluation, and Lands Branch Chief‬
‭cc:‬
‭Danielle Klaas. Regional Supervisor, Yuma‬
‭AZGFD #M25-05131148‬

This Message Is From an External Sender
This message came from outside your organization. Please use caution when corresponding outside the
county.
From:
Nichter, Keith
To:
Martin Martell (PND)
Subject:
RE: Question About Harquahala Energy Generation & Industrial Campus
Date:
Tuesday, October 14, 2025 4:41:59 PM
Attachments:
image001.png
Martin –
Thank you for the comments.
 
Copia is working with our data center customers to ensure we build data centers with water
efficient designs in Maricopa County and Arizona. The data center is expected at a
minimum to use hybrid alternative cooling technologies, allowing for dry cooling during a
significant portion of the year to reduce annual water usage. We are working with our
tenants and operators to evaluate closed loop liquid cooled systems to further minimize
water consumption, consistent with our goal to deliver high-performance facilities that
conserve resources while maintaining reliability and sustainability across all campuses.
Separate from cooling – the data center will require extremely small amounts of water for
domestic use and fire protection.
 
Copia anticipates using hauled water as an option for some uses, but at a minimum will be
utilized during construction. Copia works closely with the water rights holders in the
Harquahala Basin and has secured adequate water supply to support construction and
operation of the data center. Water quality assessments were completed and results
indicated suitability for both domestic and operational uses.
 
As Copia advances through designs with our tenants and partners, Copia is committed to
providing a plan of development and detailed basis of design report for water use that
documents compliance with local and state regulations. Additionally, we are open to a
condition as we discussed. Happy to discuss further!
 
As usual, appreciate your time!
Thanks,
Keith
602.313.7206
 
From: Martin Martell (PND) <Martin.Martell@Maricopa.Gov> 
Sent: Thursday, October 9, 2025 4:43 PM
To: Nichter, Keith <Keith.Nichter@kimley-horn.com>
Subject: RE: Question About Harquahala Energy Generation & Industrial Campus
 
Good evening Keith,
 
I’m writing the staff report for the above case for adding data center next to Maricopa
Energy Center.  I know that the issue of water usage will come up with management. You
know the reputation that data centers need a large volume of water to cool the overworked
servers.  The narrative states that water will be hauled and wells will be need to supply this

site water.   Additionally, I know that there are alternatives to using water to cool the servers
(e.g. liquid immersion cooling fluids, geothermal cooling, dry cooling, and heat re-use
systems).  I looked throughout the narrative and the issue of cooling the servers of the data
center was not mentioned. 
 
Is the plan to use alternative cooling systems that do not use groundwater from below the
site or large amounts of hauled imported water? 
 
Best regards,   
 
Martin Martell
Planner
PLANNING & DEVELOPMENT
PLANNING
Office:   602-506-6533
Martin.Martell@maricopa.gov     
MARICOPA.GOV 
 
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Comprehensive Plan – a document which guides growth and
development for the next decade and beyond. 
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