08.CPA250006 PZ Staff Report
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CPA250006
Page 1 of 9
Report to the Planning and Zoning Commission
Prepared by the Maricopa County Planning and Development Department
Case:
CPA250006 – Harquahala Sun III-V
Hearing Date:
November 6, 2025
Supervisor District:
5
Applicant:
Keith Nichter, Kimley-Horn
Owners:
CV Harquahala, LLC; Katherine Vallee; CV Farming, LLC; Daniel Thelander,
CLB Real Property Holding Co., LLC; JRS JCK, LLC; Fontana Land
Associates, LLC; Gulf Stream Properties, LLC; HV160 Land, LLC; HV218
Land, LLC; and ASLD
Request:
Major Comprehensive Plan Amendment (CPA) to modify the land use
designation listed in the Vision 2030 Comprehensive Plan from Rural
Development Area to Utilities
Site Location:
Generally located at the NWC of 499th Ave. and Baseline Rd. in the
Harquahala Valley area
Site Size:
Approx. 5,461.35 acres
Density:
N/A
County Island:
No
County Plan:
Rural Development Area (RDA)
Municipal Plan:
N/A
Municipal Comments:
None received to date
Support/Opposition:
None known
Recommendation:
Approve
CPA250006
Page 2 of 9
Project Summary:
1.
The applicant, on behalf of the property owners, is requesting a Major Comprehensive Plan
Amendment (CPA) of the County’s Vision 2030 Comprehensive Plan RDA to Utilities for the
expansion of a planned solar energy generation and energy storage facility. The expansion site
subject to this request consists of 5,461 acres generally located at the northwest corner of 499th
Ave. and Baseline Rd. in the Harquhala Valley area. Once a determination is made on the CPA
application the applicant, on behalf of the property owners, will process a zone change with
overlay from Rural-43 and Rural-190 to IND-2 IUPD. The main intention of this CPA request is to
conserve and protect existing farms and other open land uses to fosters orderly growth in rural
areas that prevent urban - rural land use conflicts. The applicant argues that once the lifetime of
the solar generation facility has run out, then the land can be brought back as open space or back
to agricultural uses since t minimal impact to the site’s underlying soils
2.
This CPA request will accommodate the expansion of Harquahala Sun, a developing solar energy
generation/energy storage facility. On December 7, 2022, the Board of Supervisors approved a
Major Comprehensive Plan Amendment from RDA to Utilities on 9,033.17 acres for Harquhala
Sun III with (CPA2022010). Subsequently, on July 24, 2024, the Board of Supervisors approved a
zone change from Rural-43 and Rural-190 to IND-2 IUPD for Harquahala Sun III a 500 MW solar
energy generation/energy storage facility. Staff met with this applicant on July 1, 2025 to discuss
the first review comment of this CPA request in a Technical Advisory Committee Meeting.
3.
The applicant’s narrative report 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.
Energy resources significantly impact economic development by contributing to the region’s
overall attractivity on basic and corresponding employment sectors, especially regarding
research and development of emerging markets. Moreover, surplus development opportunities
function as incubators for innovations that positively affect all economic segments.
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 CPA request will not alter the acceptable land use patterns in the planning area in
an adverse detriment of the plan. The proposed change in land use is consisted with existing
approved utility land use patterns and subsequent zone change requests on the adjacent
properties. The infrastructure investment and development within this part of the planning area
make this request a more suitable and logical location for a solar energy generation facility
within a remote area of the County.
The Amendment will not adversely impact all or a portion of the planning area by requiring
public expenditures for larger and more expensive infrastructure.
Any expenditures for larger and more expensive infrastructure that will be required because of
this development shall be borne by the developer. This includes roadways and electric
transmission improvements.
CPA250006
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The Amendment will not adversely impact all or a portion of the planning area by adversely
impacting planned uses because of increased traffic.
Existing and planned uses surrounding the site are not anticipated to be impacted due to an
increase of traffic. Any increased traffic will be limited to the construction and initial
development of the solar energy generation facility, but this will be temporary.
The Amendment will not adversely impact all or a portion of the planning area by affecting the
livability of the area or health or safety of present and future residents.
The CPA request will not adversely affect area residents, since there are relatively few residents
in this part of the County. Site preparation and lifetime of the future solar energy generation
facility will not include hazardous activities, materials, or processes. Any noise impacts will be
limited construction activities that will take place during limited specified hours. Any fugitive
dust control will be implemented during initial construction and operation of the facility.
Moreover, the facility will comply with all local or fire codes during initial construction and
operation of the facility.
The Amendment will not adversely impact all or a portion of the planning area by adversely
impacting the natural environment or scenic quality of the area in contradiction to the plan.
Most of this expansion site has been disturbed to accommodate agricultural uses and is not
anticipated to generate adverse impacts to the natural environment or scenic quality of the
area. Preliminary site investigation of the expansion site has not identified any significant,
unique, or critical wildlife habitats, protected flora/fauna species, or significant cultural
resources. The developer will conduct onsite investigations and implement appropriate
protective measures if warranted. Additionally, the developer has been engaged with AZGFD
throughout the development of the adjacent Harquahala Sun I, II, and III sites. The developer
recognized that appropriate coordination, proper planning, and implementation of best
management practices allow project to be developed that avoid, minimize, or mitigate potential
impacts to wildlife and recreational access during development and operation of the facilities.
Furthermore, the developer will continue to work closely with AZGFD throughout the
development of this future facility and abide by any requests by AZGFD, such as recommended
surveys and monitoring identified species onsite.
4.
The applicant’s narrative report asserts that the proposed development meets the specific goals
and policies contained within the plan in the following manner:
a.
Land Use Policy #7: Maricopa County supports coordinating land use and infrastructure
planning with state agencies, counties, and municipalities.
Coordination has occurred directly with the County Planning and Development,
Environmental Services, Department of Transportation, AZGFD. Feedback from state
agencies, other counties, and municipalities located near the project site via the County’s
enhanced notification process. Additional coordination will occur with these groups in
addition to the State Historic Preservation Office (SHPO) and the State’s Department of
Agriculture (AZDA). Coordination includes preparation of necessary reports and
considerations for the natural resources of the area.
CPA250006
Page 4 of 9
b. Land Use Policy #20: Maricopa County supports reducing the impacts of new urban
development on existing rural land uses and agriculture.
The project is a land use that is already found in the surrounding area, reducing the impact
on nearby rural land uses. Furthermore, at the end of the life of the project, rural land uses
could continue due to the minimal impact to the site’s underlying soils.
c.
Environmental Policy #2: To help improve air quality Maricopa County supports balanced
and efficient land use patterns where different uses are proximate rather than separate:
This request supports air quality by proposing an alternative energy use that decreases
emissions that result from electricity produced by fossil fuels. Compared to other types
of electric generation, solar generation facilities significantly decreases carbon dioxide
emissions and eliminates other pollutants that are generated from fossil fuels.
d. Economic Growth Goal #1: Contribute to an effective regional economy:
The physical development of the site will employ hundreds of specialized construction
and skilled trade workers from adjacent areas to the site and various municipalities
throughout the County. Local business will be supported by these workers commuting to
the site or lodging near the site for many months.
e.
Economic Growth Policy #10: Maricopa County supports leveraging its solar resource
potential to attract solar-related industries and alternative energy research and
development:
More accessible energy sources will attract energy dependent employment sectors to the
region and allow existing basic sector industries to reinvest energy savings into
expansions, research and development, and retrofitting activities to increase productivity
in response to growing demands and competition in the regional and national share of
their respective industries. Increasing the supply of locally generated renewable energy
increases the attractiveness of the region on the demand for technological innovations to
meet the demand for additional skilled and specialized workers. There will also be an
increase in the demand for specialized workers to respond to changes and innovations in
the solar powered generation industry and in the development of spin off applications in
the manufacturing, transportation, and research/development industries.
f.
Growth Areas Policy #1: Maricopa County supports consistent implementation of its
urban growth area except in the noted instances.
The proposed Project is considered industrial requiring large amounts of land to operate
that do not require a corresponding level of urban services and infrastructure and can be
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.
g. Water Resources Goal #4: Increase water conservation:
The switch in land use from agriculture to solar will significantly contribute to water
conservation in the county. The Project will utilize photovoltaic (PV) modules to generate
CPA250006
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electricity. PV technology is the most water-efficient solar generation technology
available. The Applicant recognizes that the proposed site receives a high degree of solar
radiation and that water supplies in the vicinity are limited. The Project will implement
water conservation measures while utilizing water-efficient technology. Solar uses
roughly 835 gallons of water per acre per year where agriculture uses roughly 3,340
gallons of water per acre per year. Solar plants use approximately 25% of water required
for a similar parcel of land growing alfalfa or other agricultural uses. Construction peak
water usage would be roughly 5,690 acre feet per year and Operations & Maintenance
building water usage would be roughly 54 acres feet per year for the Harquahala Sun
facility.
h. Energy Goal #2: Make Maricopa County a leader in alternative energy research and
development.
The Project provides the opportunity to implement, test, and evaluate the efficiencies of
the most current PV solar generation equipment and battery energy storage systems.
Evaluation of their operational performance is key to the research and development of
more efficient equipment and related processes. An operational facility provides
opportunities to implement advances in the associated technologies over the life of the
Project. Approval of the facility provides opportunities to test storage systems in response
to increasing demands for the use of stored energy.
i.
Open Space Goal #1: Provide regional leadership to promote environmental quality:
Despite the Project being mostly disturbed for agricultural purposes, it encourages the
preservation of natural open space in the form of drainage corridors and wildlife linkages.
The Project, which is adjacent to the Centennial Wash, will conduct onsite investigations
and implement appropriate protective measures as needed for biological and
historical/archaeological resources to either avoid or mitigate impacts on the natural
environment, in coordination with the SHPO and AZGFD. This project will be developed to
avoid, minimize, or mitigate potential impacts to wildlife and recreational access during
development and operation of the facilities. This coordination will continue in a more
detailed fashion with the subsequent zone change and plan of development to minimize
any potential impacts to the surrounding wildlife including proper treatment or
preservation of drainage ways and wildlife corridors.
CPA250006
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Aerial image & surrounding environs
Area Land Use Designation
CPA250006
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Land Use Exhibits (Current and Proposed)
CPA250006
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Existing On-Site and Adjacent Zoning/ Land Use:
5.
On-site:
Rural-43 & Rural-190 / Agriculture and natural desert
North:
IND-2 IUPD & Rural-43 / Agriculture and natural desert
South:
Rural-43; Rural-190 & IND-2 IUPD / Agriculture and natural desert
East:
Rural-190 / Agriculture and natural desert
West:
Rural-190 / Natural Desert
Utilities and Services:
6.
Water:
Private wells or hauled water
Wastewater:
Private septic system
School District:
Arlington Unified School District
Fire:
Harquahala Valley Fire District
Police:
MCSO
Right-of-Way:
7.
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 that final determination of the preservation of right-
of-way or dedication of right-of-way will be determined by MCDOT with the Zone Change and/or
Plan of Development. Currently, MCDOT wishes that all perimeter section lines reserve a half
width right-of-way of 55’ and perimeter mid-section lines reserve a half width right-of-way of 40’.
Street Name
Half-width
Existing R/W
Half-width
Reserved R/W
Future Classification
499th Ave.
0’
40’
Collector Roadway
507th Ave.
0’
55’
Arterial Roadway
519th Ave.
0’
40’
Collector Roadway
523rd Ave.
0’
40’
Collector Roadway
531st Ave.
0’
55’
Arterial Roadway
539th Ave.
0’
55’
Arterial Roadway
547th Ave.
0’
55’
Collector Roadway
551st Ave.
0’
55’
Collector Roadway
Lower Buckeye Rd.
0’
55’
Arterial Roadway
Elwood St.
0’
40’
Collector Roadway
Broadway Rd.
0’
55’
Arterial Roadway
Southern Ave.
0’
55’
Arterial Roadway
Baseline Rd.
0’
55’
Minor Arterial Roadway
Westwing Pass
0’
40’
Collector Roadway
Eagletail Rd./Dobbins Rd.
0’
55’
Minor Arterial Roadway
Turtleback Mountain Rd.
0’
55’
Arterial Roadway
Adopted Plan:
8.
Vision 2030 Comprehensive Plan (adopted 1/13/16): The plan designates this site as Rural
Development Area (RDA) with a maximum density of one dwelling unit per acre.
CPA250006
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Public Participation Summary:
9.
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. According the applicant’s citizen participation results report, the applicant
received four responses with general questions about the request; however, the applicant has not
received any opposition or support for this request. As of the writing of this report, staff has not
received any comments from the public.
Outstanding Concerns from Reviewing Agencies:
10.
N/A
Staff Analysis:
11.
Maricopa County and Arizona recognizes that solar energy generation has several environmental
and economic benefits. This site will be part of an expansion of the Harquahala Sun solar
generation facility which uses solar panels to absorb sunlight throughout the day and invert this
energy into the electric grid. One benefit of this technology is that water is not required to generate
power or cool equipment and will not contribute to the depletion of the area’s aquafers. During
the night, battery storage systems to store the electricity generated from the solar panels during
the daylight hours will be part of this expanded solar generation facility.
16.
The proposed solar electric generation facility will be well suited to this isolated portion of the
County. These types of facilities require large amounts of relatively flat land, and most of the
subject site is flat. Another benefit of this site is its proximity to electrical transmission lines,
power stations, and electrical substations. According to the applicant, the development of the
entire Harquahala Sun project will require 400-600 temporary skilled construction workers as well
as technicians and other specialists. The applicant believes, the number of workers to the site
will be a benefit to the local economy and benefit local retail. However, once the facility is online
there will be limited amount of employes on-site, which will not impact the local roadways or any
of the few adjacent residences. The applicant has clearly demonstrated in their narrative report
that this request is consistent with and meets the goals and policies of the Comprehensive Plan.
Recommendation:
12.
Staff recommends the Commission adopt a motion and recommend that the Board of
Supervisors approve CPA250006.
Presented by:
Martin Martell, Planner
Reviewed by:
Rachel Applegate, Planning Supervisor
Attachments:
Case Map (1 page)
Land Use Exhibit (reduced 8.5”x11”, 4 pages)
Narrative Report (23 pages)
MCDOT comments (2 page)
Pima County comments (1 page)
AZG&F comments (18 pages)
/
Maricopa County Planning & Development - Phoenix, AZ
5
Gross Acres: 5,934 approx.
Generated October 27, 2025 10:37 AM
CPA250006
Application Name:
Legal Description
HARQUAHALA SUN III-V ADDITIONAL LAND
Applicant
Case Address
Keith Nichter
54630 W HIGHLAND AVE
Applicant Phone/Email
Parcel Primary:506-27-007F
(602) 313-7206
keith.nichter@kimley-horn.com
TONOPAH, AZ 85354
Map scale 1:84,501
Supervisor District No.
Major Comprehensive Plan Amendment to change the land use designation of ±5,222.51 acres from Rural
Development Area to Utilities to allow for additional development areas to be added to the previously
T01N R10W
T01S R10W
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S 499TH AVE
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W BASELINE RD
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
S 539TH AVE
S 539TH AVE
W DOBBINS RD
W DOBBINS RD
S 507TH AVE
S 507TH AVE
W ELLIOT RD
W ELLIOT RD
S 547TH AVE
S 547TH AVE
W SOUTHERN AVE
W SOUTHERN AVE
W EAGLETAIL RD
W EAGLETAIL RD
W TURTLEBACK MOUNTAIN RD
W TURTLEBACK MOUNTAIN RD
W BROADWAY RD
W BROADWAY RD
S 491ST AVE
S 491ST AVE
S 531ST AVE
S 531ST AVE
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
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W LOWER BUCKEYE RD
S 499TH AVE
S 539TH AVE
W BASELINE RD
W LOWER BUCKEYE RD
S 499TH AVE
S 539TH AVE
W BASELINE RD
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
S 539TH AVE
S 539TH AVE
W DOBBINS RD
W DOBBINS RD
S 507TH AVE
S 507TH AVE
W ELLIOT RD
W ELLIOT RD
S 547TH AVE
S 547TH AVE
W SOUTHERN AVE
W SOUTHERN AVE
W EAGLETAIL RD
W EAGLETAIL RD
W TURTLEBACK MOUNTAIN RD
W TURTLEBACK MOUNTAIN RD
W BROADWAY RD
W BROADWAY RD
S 491ST AVE
S 491ST AVE
S 531ST AVE
S 531ST AVE
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
W BUCKEYE RD
W BUCKEYE RD
N
0'
0.5 MILE
1 MILE
HARQUAHALA SUN III-V-ADDITIONAL LAND
MARICOPA COUNTY, AZ
DRAWN BY: JK
SCALE: APPROX.
T01S R09W
T01S R08W
EXISTING CPA LAND USE - RURAL DEVELOPMENT AREA
PROPOSED CPA LAND USE - UTILITIES
T01S R09W
T01S R08W
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LANDUSE-UTILITIES
(+/-9,047.58 AC.)
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LANDUSE-UTILITIES
(+/-9,047.58 AC.)
HARQUAHALA SUN II
SOLAR SITE-CPA2022015
EXISTING LANDUSE - UTILITIES
(+/-2,717.76 AC.)
HARQUAHALA SUN II
SOLAR SITE-CPA2022015
EXISTING LANDUSE - UTILITIES
(+/-2,717.76 AC.)
EXISTING/PROPOSED CPA LAND USE DESIGNATIONS
RURAL DEVELOPMENT AREA
LEGEND
UTILITIES
BUREAU OF LAND
MANAGEMENT (BLM)
ARIZONA STATE LAND
DEPARTMENT (ASLD)
TOWNSHIP / RANGE LINE
HARQUAHALA SUN III-V SITE
EXISTING UTILITIES AREA
(+/-9,047.58 AC.)
PROPOSED ASLD AREA
(+/-2,636.00 AC.)
HARQUAHALA SUN III-V
ADDITIONAL LAND/
PROPOSED UTILITIES AREA (+/-5,461.35 ACRES)
PROPOSED PRIVATE LAND AREA
(+/-2,825.35 AC.)
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LANDUSE-UTILITIES
(+/-9,047.58 AC.)
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LANDUSE-UTILITIES
(+/-9,047.58 AC.)
MAJOR CPA-APPLICATION (
CASE #: CPA250006) 7/15/2025
RECEIVED 6. AUG 25
CPA250006 - 2. SUB
T01N R10W
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T01N R09W
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S 539TH AVE
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S 499TH AVE
S 539TH AVE
W BASELINE RD
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
S 539TH AVE
S 539TH AVE
W DOBBINS RD
W DOBBINS RD
S 507TH AVE
S 507TH AVE
W ELLIOT RD
W ELLIOT RD
S 547TH AVE
S 547TH AVE
S 555TH AVE
S 555TH AVE
W SOUTHERN AVE
W SOUTHERN AVE
W EAGLETAIL RD
W EAGLETAIL RD
W TURTLEBACK MOUNTAIN RD
W TURTLEBACK MOUNTAIN RD
W BROADWAY RD
W BROADWAY RD
S 491ST AVE
S 491ST AVE
S 531ST AVE
S 531ST AVE
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
W BUCKEYE RD
W BUCKEYE RD
N
0'
HARQUAHALA SUN III-V ADDITIONAL LAND
MARICOPA COUNTY, AZ
DRAWN BY: JK
SCALE: APPROX.
2,000'
4,000'
EXISTING CPA LAND USE - RURAL DEV. AREA
RURAL DEVELOPMENT AREA
LEGEND
UTILITIES
BUREAU OF LAND
MANAGEMENT (BLM)
ARIZONA STATE LAND
DEPARTMENT (ASLD)
TOWNSHIP / RANGE LINE
HARQUAHALA SUN III-V SITE
EXISTING UTILITIES AREA
(+/-9,047.58 AC.)
HARQUAHALA SUN II
SOLAR SITE-CPA2022015
EXISTING LANDUSE - UTILITIES
(+/-2,717.76 AC.)
HARQUAHALA SUN II
SOLAR SITE-CPA2022015
EXISTING LANDUSE - UTILITIES
(+/-2,717.76 AC.)
MAJOR CPA-APPLICATION (
CASE #: CPA250006) 7/15/2025
EXISTING CPA LAND USE DESIGNATIONS
EXISTING ASLD AREA
(+/-2,636.00 AC.)
HARQUAHALA SUN III-V
ADDITIONAL LAND/
PROPOSED UTILITIES AREA (+/-5,461.35 ACRES)
EXISTING PRIVATE LAND AREA
(+/-2,825.35 AC.)
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LAND USE-UTILITIES
(+/-9,047.58 AC.)
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LAND USE-UTILITIES
(+/-9,047.58 AC.)
T01N R10W
T01S R10W
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CENTENNIAL WASH
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W LOWER BUCKEYE RD
S 499TH AVE
S 539TH AVE
W BASELINE RD
W LOWER BUCKEYE RD
S 499TH AVE
S 539TH AVE
W BASELINE RD
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
S 539TH AVE
S 539TH AVE
W DOBBINS RD
W DOBBINS RD
S 507TH AVE
S 507TH AVE
W ELLIOT RD
W ELLIOT RD
S 547TH AVE
S 547TH AVE
S 555TH AVE
S 555TH AVE
W SOUTHERN AVE
W SOUTHERN AVE
W EAGLETAIL RD
W EAGLETAIL RD
W TURTLEBACK MOUNTAIN RD
W TURTLEBACK MOUNTAIN RD
W BROADWAY RD
W BROADWAY RD
S 491ST AVE
S 491ST AVE
S 531ST AVE
S 531ST AVE
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
W BUCKEYE RD
W BUCKEYE RD
N
0'
HARQUAHALA SUN III-V ADDITIONAL LAND
MARICOPA COUNTY, AZ
DRAWN BY: JK
SCALE: APPROX.
2,000'
4,000'
PROPOSED CPA LAND USE - UTILITIES
PROPOSED CPA LAND USE DESIGNATIONS
HARQUAHALA SUN II
SOLAR SITE-CPA2022015
EXISTING LANDUSE - UTILITIES
(+/-2,717.76 AC.)
HARQUAHALA SUN II
SOLAR SITE-CPA2022015
EXISTING LANDUSE - UTILITIES
(+/-2,717.76 AC.)
RURAL DEVELOPMENT AREA
LEGEND
UTILITIES
BUREAU OF LAND
MANAGEMENT (BLM)
ARIZONA STATE LAND
DEPARTMENT (ASLD)
TOWNSHIP / RANGE LINE
HARQUAHALA SUN III-V SITE
EXISTING UTILITIES AREA
(+/-9,047.58 AC.)
PROPOSED ASLD AREA
(+/-2,636.00 AC.)
HARQUAHALA SUN III-V
ADDITIONAL LAND/
PROPOSED UTILITIES AREA (+/-5,461.35 ACRES)
PROPOSED PRIVATE LAND AREA
(+/-2,825.35 AC.)
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LAND USE-UTILITIES
(+/-9,047.58 AC.)
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LAND USE-UTILITIES
(+/-9,047.58 AC.)
MAJOR CPA-APPLICATION (
CASE #: CPA250006) 7/15/2025
T01N R10W
T01S R10W
T01N R09W
T01S R09W
T01N R09W
T01S R09W
T01N R08W
T01S R08W
CENTENNIAL WASH
CENTENNIAL WASH
30
28
27
26
25
31
32
33
34
35
36
19
20
21
22
23
18
17
16
15
14
13
30
29
28
27
26
31
32
33
34
35
19
20
21
22
23
18
17
16
15
14
06
05
02
01
06
05
04
03
02
07
08
09
10
11
12
07
08
09
10
11
07
08
09
10
11
12
07
08
09
10
11
18
17
16
15
14
13
18
17
16
15
14
26
25
35
36
23
24
14
13
02
01
11
12
11
12
14
13
04
03
24
29
APN: 506-27-037
ASLD - TORREY PINES DEV
LLC/ETAL LEASE #01-40645
APN: 506-27-038
ASLD - TORREY PINES DEV
LLC/ETAL LEASE #01-40645
APN: 506-28-017
ASLD - TORREY PINES DEV
LLC/ETAL LEASE # 01-1501
APN: 506-28-042
ASLD - TORREY PINES DEV
LLC/ETAL LEASE # 01-34994
APN: N/A (30 01N 09W)
ARIZONA STATE LAND
DEPARTMENT (ASLD)
APN: N/A (25 01N 10W)
ARIZONA STATE LAND
DEPARTMENT (ASLD)
APN: N/A (24 01N 10W)
ARIZONA STATE LAND
DEPARTMENT (ASLD)
APN: N/A (13 01N 10W)
ARIZONA STATE LAND
DEPARTMENT (ASLD)
APN: 506-27-001A
DANIEL W THELANDER
TRUST
APN: 506-27-008A
CLB REAL PROPERTY
HOLDING COMPANY LLC
APN: 506-27-008C
CLB REAL PROPERTY
HOLDING COMPANY LLC
APN: 506-27-007F
CLB REAL PROPERTY
HOLDING COMPANY LLC
APN: 506-27-008D
CLB REAL PROPERTY
HOLDING COMPANY LLC
APN: 506-27-007B
JRS JCK
LLC
APN: 506-27-007D
JRS JCK
LLC
APN: 506-27-035B
VALLEE
KATHERINE M TR
APN: 506-27-026
BAL-2020 LLC/FONTANA
LAND ASSOCIATIES LLC
APN:506-27-024A
BAL-2020 LLC/FONTANA
LAND ASSOCIATIES LLC
APN:506-27-024B
APN:506-27-021
BEUS ANNETTE/FONTANA
LAND ASSOCIATIES LLC
APN:506-27-022
APN:506-27-028
APN:506-27-023
APN:506-27-027
APN:506-27-025
APN: 401-57-014
CV FARMING LLC
APN: 401-56-023
CV FARMING LLC
APN:401-56-005H
APN: 401-57-010A
HV 160 LAND LLC
APN: 401-56-005A
HV 218 LAND LLC
APN: 401-56-004B
HV 218
LAND LLC
APN: 401-57-642
APN: 401-57-641
APN: 401-57-644
APN: 401-57-643
APN: 401-57-646
APN: 401-57-645
GULF STREAM
PROPERTIES LLC
APN:401-57-625
CV HARQUAHALA LLC
APN:401-57-623
APN:401-57-624
APN:401-57-622
APN:401-57-008K
APN:401-56-005G
HV 218 LAND LLC
APN:401-57-629A
APN:401-57-628A
CV HARQUAHALA LLC
APN:401-57-627B
APN:401-57-627C
CV HARQUAHALA LLC
APN:401-57-626C
APN:401-57-626D
APN:401-57-628B
APN: 506-25-024
HARQ ET
320 LLC
NOT A PART
W LOWER BUCKEYE RD
S 499TH AVE
S 539TH AVE
W BASELINE RD
W LOWER BUCKEYE RD
S 499TH AVE
S 539TH AVE
W BASELINE RD
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
S 539TH AVE
S 539TH AVE
W DOBBINS RD
W DOBBINS RD
S 507TH AVE
S 507TH AVE
W ELLIOT RD
W ELLIOT RD
S 547TH AVE
S 547TH AVE
S 555TH AVE
S 555TH AVE
W SOUTHERN AVE
W SOUTHERN AVE
W EAGLETAIL RD
W EAGLETAIL RD
W TURTLEBACK MOUNTAIN RD
W TURTLEBACK MOUNTAIN RD
W BROADWAY RD
W BROADWAY RD
S 491ST AVE
S 491ST AVE
S 531ST AVE
S 531ST AVE
S HARQUAHALA VALLEY RD
S HARQUAHALA VALLEY RD
W BUCKEYE RD
W BUCKEYE RD
N
0'
HARQUAHALA SUN III-V ADDITIONAL LAND
MARICOPA COUNTY, AZ
DRAWN BY: JK
SCALE: APPROX.
2,000'
4,000'
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LAND USE-UTILITIES
(+/-9,047.58 AC.)
HARQUAHALA SUN III-V
SOLAR SITE-CPA2022010
EXISTING LAND USE-UTILITIES
(+/-9,047.58 AC.)
LEGEND
BUREAU OF LAND
MANAGEMENT (BLM)
ARIZONA STATE LAND
DEPARTMENT (ASLD)
TOWNSHIP / RANGE LINE
HARQUAHALA SUN III-V SITE
EXISTING UTILITIES AREA
(+/-9,047.58 AC.)
EXISTING ASLD AREA
(+/-2,636.00 AC.)
HARQUAHALA SUN III-V
ADDITIONAL LAND/
PROPOSED UTILITIES AREA (+/-5,461.35 ACRES)
EXISTING PRIVATE LAND AREA
(+/-2,825.35 AC.)
HARQUAHALA SUN II
SOLAR SITE-CPA2022015
EXISTING LANDUSE - UTILITIES
(+/-2,717.76 AC.)
HARQUAHALA SUN II
SOLAR SITE-CPA2022015
EXISTING LANDUSE - UTILITIES
(+/-2,717.76 AC.)
OWNERSHIP MAP
OWNERSHIP
MAJOR CPA-APPLICATION (
CASE #: CPA250006) 7/15/2025
Page 0
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1001 West Southern Avenue Suite 131, Mesa, AZ 85210
480 207 2666
ADDITIONAL LAND
05/30/2025, REVISED 07/15/2025
HARQUAHALA SUN III-V
MAJOR COMPREHENSIVE PLAN AMENDMENT
PROJECT NARRATIVE
CASE #: CPA250006
RECEIVED 6. AUG 25
CPA250006 - 2. SUB
Page 1
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480 207 2666
Table of Contents
A. EXECUTIVE SUMMARY ....................................................................................................... 2
I. ON-SITE AND REGIONAL LOCATION ............................................................................................ 6
II. CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY ACREAGES....................................... 6
III. ROADS/TRANSPORTATION SYSTEMS SERVING THE PROPOSED PROJECT ........................ 7
IV. SUITABILITY WITH SURROUNDING LAND USES......................................................................... 7
EXISTING SURROUNDING SOLAR (UTILITY) LAND USE APPROVALS .......................................... 8
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............... 9
C. THE AMENDMENT WILL NOT ADVERSELY IMPACT ALL OR A PORTION OF THE
PLANNING AREA BY: ........................................................................................................ 10
I.
ALTERING ACCEPTABLE LAND USE PATTERNS TO THE DETRIMENT OF THE PLAN. .... 10
II.
REQUIRING
PUBLIC
EXPENDITURES
FOR
LARGER
AND
MORE
EXPENSIVE
INFRASTRUCTURE. ............................................................................................................................ 11
III.
REQUIRING PUBLIC IMPROVEMENTS TO ROADS, SEWER, OR WATER SYSTEMS THAT
ARE NEEDED TO SUPPORT THE PLANNED LAND USES. ............................................................. 11
IV.
ADVERSELY IMPACTING PLANNED USES BECAUSE OF INCREASED TRAFFIC. ............. 11
V.
AFFECTING THE LIVABILITY OF THE AREA OR HEALTH OR SAFETY OF PRESENT AND
FUTURE RESIDENTS. ........................................................................................................................ 12
VI.
ADVERSELY IMPACTING THE NATURAL ENVIRONMENT OR SCENIC QUALITY OF THE
AREA IN CONTRADICTION TO THE PLAN. ...................................................................................... 12
D. WHETHER THE AMENDMENT IS CONSISTENT WITH OVERALL INTENT OF THE
COMPREHENSIVE PLAN:.................................................................................................. 13
E. THE EXTENT TO WHICH THE AMENDMENT IS CONSISTENT WITH THE SPECIFIC
GOALS AND POLICIES CONTAINED WITHIN THE PLAN. ............................................... 14
F. COMPREHENSIVE PLAN AMENDMENT MAP EXHIBIT.................................................... 23
G. COMPREHENSIVE PLAN AMENDMENT LEGAL DESCRIPTIONS EXHIBITS .................. 24
APPENDIX - A ‘Site Parcels’ ………………………………………………………..…………………25
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A. EXECUTIVE SUMMARY
Kimley-Horn (the “Agent”), on behalf of Harquahala Complex HoldCo LLC, (the, “Applicant”) with permission
of the property owners listed below in Table 1 - Harquahala Sun III-V Additional Land Area, is requesting
a Major Comprehensive Plan Amendment (CPA) of the Vision 2030 Comprehensive Plan to change the
land use designation of ±5,461.35 acres (±2,636.0 acres of ASLD & ±2,825.35 acres of privately owned
land) from Rural Development Area to Utilities to allow for additional development areas to be added to the
previously approved Harquahala Sun III-V Photovoltaic Solar Energy Generation and Storage Project
(Case #’s: CPA2022010 & Z2023131). The CPA request will be accompanied by a subsequent Zone
Change with Overlay request to rezone the underlying parcels from RU-43 and RU-190 to the IND-2 IUPD.
Table 1 - Harquahala Sun III-V Additional Land Area
APN
OWNER
SEC./TOWN./RANGE ACREAGE
ARIZONA STATE LAND DEPARTMENT AREA
N/A
ASLD
13 01N 10W
80.00
N/A
ASLD
24 01N 10W
320.00
N/A
ASLD
25 01N 10W
320.00
N/A
ASLD
30 01N 09W
320.00
506-28-017
ASLD - TORREY PINES DEV LLC/ETAL LEASE # 01-1501 34 01N 09W
316.00
506-27-037
ASLD - TORREY PINES DEV LLC/ETAL LEASE #01-40645 32 01N 09W
480.00
506-27-038
ASLD - TORREY PINES DEV LLC/ETAL LEASE #01-40645 32 01N 09W
160.00
506-28-042
ASLD - TORREY PINES DEV LLC/ETAL LEASE # 01-34994 36 01N 09W
640.00
ASLD LAND 2,636.00
PRIVATE LAND AREA
506-27-035B VALLEE KATHERINE M TR
29 01N 09W
160.00
401-57-014
CV FARMING LLC
04 01S 09W
314.92
401-56-023
CV FARMING LLC
03 01S 09W
323.12
506-25-024
HARQ ET 320 LLC
18 01N 09W
318.79
506-27-001A DANIEL W THELANDER TRUST
19 01N 09W
80.00
506-27-008A CLB REAL PROPERTY HOLDING COMPANY LLC
19 01N 09W
79.81
506-27-008D CLB REAL PROPERTY HOLDING COMPANY LLC
19 01N 09W
80.00
506-27-008C CLB REAL PROPERTY HOLDING COMPANY LLC
19 01N 09W
80.00
506-27-007F CLB REAL PROPERTY HOLDING COMPANY LLC
19 01N 09W
80.00
506-27-007B JRS JCK LLC
19 01N 09W
80.00
506-27-007D JRS JCK LLC
19 01N 09W
80.00
506-27-026
BAL-2020 LLC/FONTANA LAND ASSOCIATIES LLC
29 01N 09W
160.00
506-27-024A BAL-2020 LLC/FONTANA LAND ASSOCIATIES LLC
29 01N 09W
40.00
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1001 West Southern Avenue Suite 131, Mesa, AZ 85210
480 207 2666
506-27-024B BAL-2020 LLC/FONTANA LAND ASSOCIATIES LLC
29 01N 09W
40.00
506-27-023
BAL-2020 LLC/FONTANA LAND ASSOCIATIES LLC
29 01N 09W
20.00
506-27-028
BAL-2020 LLC/FONTANA LAND ASSOCIATIES LLC
29 01N 09W
10.00
506-27-025
BAL-2020 LLC/FONTANA LAND ASSOCIATIES LLC
29 01N 09W
10.00
506-27-022
BAL-2020 LLC/FONTANA LAND ASSOCIATIES LLC
29 01N 09W
20.00
506-27-027
BAL-2020 LLC/FONTANA LAND ASSOCIATIES LLC
29 01N 09W
10.00
506-27-021
BEUS ANNETTE/FONTANA LAND ASSOCIATIES LLC 29 01N 09W
10.00
401-57-641
GULF STREAM PROPERTIES LLC
09 01S 09W
26.41
401-57-642
GULF STREAM PROPERTIES LLC
09 01S 09W
26.40
401-57-643
GULF STREAM PROPERTIES LLC
09 01S 09W
26.36
401-57-644
GULF STREAM PROPERTIES LLC
09 01S 09W
26.37
401-57-645
GULF STREAM PROPERTIES LLC
09 01S 09W
13.46
401-57-646
GULF STREAM PROPERTIES LLC
09 01S 09W
13.46
401-57-622
CV HARQUAHALA LLC
09 01S 09W
38.60
401-57-623
CV HARQUAHALA LLC
09 01S 09W
38.50
401-57-624
CV HARQUAHALA LLC
09 01S 09W
40.45
401-57-625
CV HARQUAHALA LLC
09 01S 09W
38.95
401-57-008K CV HARQUAHALA LLC
09 01S 09W
1.74
401-57-627B CV HARQUAHALA LLC
09 01S 09W
37.49
401-57-627C CV HARQUAHALA LLC
09 01S 09W
2.19
401-57-626C CV HARQUAHALA LLC
09 01S 09W
35.27
401-57-626D CV HARQUAHALA LLC
09 01S 09W
4.40
401-57-628B CV HARQUAHALA LLC
09 01S 09W
26.59
401-57-629A CV HARQUAHALA LLC
09 01S 09W
26.46
401-57-628A CV HARQUAHALA LLC
09 01S 09W
27.54
401-57-010A HV 160 LAND LLC
09 01S 09W
160.00
401-56-005H HV 218 LAND LLC
10 01S 09W
9.03
401-56-005G HV 218 LAND LLC
10 01S 09W
9.03
401-56-005A HV 218 LAND LLC
10 01S 09W
120.00
401-56-004B HV 218 LAND LLC
10 01S 09W
80.00
PRIVATE LAND 2,825.35
TOTAL LAND AREA 5,461.35
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Exhibit A – Approved Harquahala Sun III-V Project
Harquahala Sun III-V is an approved ±9,047.58-acre Photovoltaic Solar Energy Generation and Storage
Project that received unanimous Board of Supervisors approval for a Major CPA, from Rural Development
Area to Utilities, on December 7, 2022 with a subsequent Zone Change with Overlay, from RU-43 and RU-
190 to the IND-2 IUPD with a Plan of Development (POD), approval on July 24, 2024.
Major CPA Approval – 12/07/2022
Zone Change with Overlay Approval – 07/24/2024
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kimley-horn.com
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Similarly, the Applicant proposes to entitle this additional land to expand the previously approved
Harquahala Sun III-V boundary to construct, operate, and maintain a solar photovoltaic (PV) and battery
power plant with associated infrastructure on the overall ±14,508.93-acre site.
Exhibit B – Proposed Harquahala Sun III-V Additional Land Area
The Harquahala Sun III-V additional land (the “Project”) will be added into the planned three (3) phases of
hybrid solar PV and battery power plant development. Each phase of the project will include solar modules
mounted on single axis trackers, inverters to convert direct current into grid-compatible alternating current,
transformers to increase the voltage of the electricity generated, and battery energy storage system. The
Project will also include a 500 kV utility substation(s) and one or more small buildings to house
telecommunication equipment. The Project is expected to interconnect to the transmission grid at the
Delaney Substation operated by Arizona Public Service (APS) or a similar facility. Off-site supporting
improvements, infrastructure, and/or uses are expected to include up to a 200-foot-wide gen-tie route
corridor that extends approximately 10 miles through private land and to the Project substation(s).
The proposed Major Comprehensive Plan Amendment (CPA), in support of the ±5,461.35-acres of the
Project, will not adversely impact the planning area in part nor portion. Approval of the proposed CPA,
subsequent rezone and associated development plans for the proposed Project will not generate undue
nor unmitigated impacts to the following areas of consideration identified in the Comprehensive Plan, which
include, but are not specifically limited to: land use; public transportation system improvements; drainage
and/or stormwater management; environmental considerations (air & water quality, potable water &
wastewater treatment), areas of geologic concern, hazard, and/or significance; plant and wildlife
habitat/migration environs and/or patterns; aviation and military installation operations and flight
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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210
480 207 2666
paths/patterns; economic growth; growth areas; open space, water resources; energy; and/or the cost of
development.
Issues relating to these are addressed by the required reports, plans, and analysis submitted in support of
the CPA and subsequent rezone application.
I. ON-SITE AND REGIONAL LOCATION
The proposed Project is located southwest of Saddle Mountain, and northeast of the Eagle Tail
Mountains in Township 1 North, Range 9 and 10 West. The site is approximately 20 miles west of
the City of Buckeye, Arizona in unincorporated Maricopa County, Arizona with parcels lying south of
the intersection of W Lower Buckeye Rd and S Harquahala Valley Rd which generally bisects the
site. The Project area is generally bound on the north side, just south of W Lower Buckeye Rd, on
the west side by S 539th Ave, on the east side by S 487th and on the south by Elliot Rd.
The CPA is inclusive of fifty-one (51) parcels which are held under twelve (12) separate ownerships.
The subject properties are mostly being used for irrigated agricultural uses or vacant. A detailed list
of the parcels considered under this CPA are listed in Appendix A.
II. CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY ACREAGES
The CPA request is inclusive of fifty-one (51) parcels totaling ±5,461.35 acres in the Rural
Development Area which is intended to conserve and protect farms and other 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 and RU-190 zoning districts have
residential densities of one (1) dwelling unit per acre (du/ac) and 0.22 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.
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III. ROADS/TRANSPORTATION SYSTEMS SERVING THE PROPOSED PROJECT
The roadway network serving the proposed Project from the I-10 corridor includes the I-10/Salome
Highway interchange that connects Salome Hwy to Harquahala Valley Rd. The site can be accessed
from the I-10/ Salome Highway interchange. Salome Highway provides connections to Harquahala
Valley Road which extends southerly past W. Lower Buckeye Road to the site. Primary access to the
site is via Harquahala Valley Road which generally bisects the irregular shaped site with W. Lower
Buckeye Road near the northern side, 539th Ave alignment on the west side, 487th Ave alignment on
the east side and W Elliot Rd as the southernmost boundary. There are a number of smaller, existing
roads, both named and unnamed, that traverse the Project site, which are anticipated to be used and
improved for construction and ongoing operations of the Project. Site access will be identified with
the zone change and plan of development applications. Final access locations will be determined in
accordance with access management policies and permitting requirements of Maricopa County.
Properties within the Project area are located south of W Lower Buckeye Road, east of 547th Ave,
west of 499th Ave and north of W Dobbins/Eagletail Rd.
There would be no significant increase in traffic during the operational life of the Project that would
require road improvements. There would be a relatively minor increase in the level of traffic during
the approximately 30 months required for each phase of Project construction. This increased traffic
is expected to be fewer than 100 trips during single peak morning and evening hours, primarily for
the delivery of equipment and supplies and the commuting of the construction workforce. A traffic
impact study will be completed as part of the zone change process associated with the Project. The
Applicant has agreed to financial responsibility for repair of existing roads used during construction,
including bonding for such work, so that there is not public expenditure for transportation
infrastructure associated with the Project.
IV. SUITABILITY WITH SURROUNDING LAND USES
The surrounding area is characterized by active and passive agricultural land uses, natural gas-
powered electric generation facilities, solar powered electric generation facilities, and native desert
lands. The dominant private land use within the area surrounding the current CPA is solar generation
facilities, which occurs on parcels or combinations of parcels totaling several hundred to thousands
of acres in irregular configurations. Other surrounding land uses include publicly owned and managed
Local, State, and Federal Lands. These include lands controlled by the Maricopa Flood Control
District, Arizona State Land Trust, and Bureau of Land Management. Other surrounding land uses
include vacant and active agricultural uses with limited and sparse distribution of privately owned
parcels used for residential purposes within the surrounding area. Additionally, Luke Air Force Base
(LAFB) is known to have military training routes out in this area. Under the Department of Defense
(DOD) Clearinghouse process, energy projects greater than 199’ above ground level are required to
go through a Formal Review. With the limited proposed power poles around +/150’, the Applicant has
coordinated with LAFB and submitted under the Informal Review DOD Clearinghouse process during
the previous zone change approvals. Additionally, through further coordination during the subsequent
zone change, the Project will continue to coordinate with LAFB to ensure compatibility.
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1001 West Southern Avenue Suite 131, Mesa, AZ 85210
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Property owners and residents will be notified of the project and efforts will be made to identify
concerns over visual impacts and incorporate effective mitigation and screening of the site against
any residential boundaries.
Considerations for buffering and screening of the Project and mitigation of visual impacts during
construction and operational activities. Screening and mitigation of visual impacts will be addressed
in greater detail at the rezone and plan of development submittals.
Site parcels will be enclosed by perimeter security fencing located along each phase project
boundaries and adjacent rights of way. No fencing will impede or otherwise enclose existing roads
within the project boundaries.
The proposed additional land will be added to the Harquahala Sun III-V project which looks to expand
upon the current improvements currently being constructed as a part of the previously approved
Harquahala Sun (CPA2021007/Z2021111) and Harquahals Sun II projects (CPA2022015/
Z2022214). Additionally, the proposed Utility land use contemplated by the Project CPA is compatible
with other similar approved and implemented solar Projects within the general area. Associated
facilities within this area include approved CPA’s for Utility (solar) land uses, PV solar generation
facilities, utility corridors, transmission lines and a utility substation. Many of the surrounding parcels
around the Project boundary have been subject to previous CPA approvals, as listed below in Table
2 - Existing Surrounding Solar (Utility) Land Use Approvals.
Table 2 - 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
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
These adjacent and surrounding CPA approvals have established a primary alternative energy
corridor that Harquahala Sun III-V additional land looks to build upon.
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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), Major 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 changing market conditions and to address the increasing
demands of growth to the public infrastructure needs, specifically energy generation and consumption
demands within the local economy.
As stated, and reinforced in the Plan, the supply of energy is essential to the region’s transportation and
manufacturing sectors. 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 and even surplus opportunities function as an incubator for
innovations within all segments of the local, regional, and state economy.
The Project will add to the job creation in the construction, contracting, administrative, and project
management fields during the construction and implementation of each Project phase. Operation of the site
will employ zero full-time employees daily. Routine maintenance activities will require up to 15 part-time or
seasonal employees and up to 20 employees for equipment repair and replacement as needed per phase.
In addition to providing in state construction jobs and long-term technical careers, local projects like this will
help contribute to the regional economy by providing tax revenue and by using local engineering and
development contractors in Maricopa County.
Harquahala Sun III-V additional lands support the county and greater region within the state by providing
additional renewable energy resources, battery storage for local energy reliability and resiliency. The
location and surrounding utility land uses minimize impacts to neighbors and lessen the impact to the
environment based on proximity to the APS Delaney Substation by minimizing very long electrical
interconnects. The electricity generated through these facilities would be distributed to the regional electrical
grid, supplying the county, state and wider west/southwest regions while directly benefitting Arizona
corporations seeking competitively priced renewable energy and looking to add new clean energy
resources to power the record number of people and companies moving to the state. Specifically, consistent
with their 2020 Clean Energy Commitment, Arizona Public Service Co. (APS) is looking to add additional
clean energy resources to its diverse power supply and has issued a request for proposals (RFP) to supply
renewable energy, which the Project will respond to.
This Project is intended to promote and incentivize the production and delivery of renewable 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 sustainable, renewable, and
economically 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 Project is in direct support of this stated goal, the implementation of which is evidenced by the current
approved CPA and rezoning of property within the current Project vicinity for solar Projects. The need for
this Project is established by growing demand for renewable energy as evidenced by the APS RFP and
Arizona’s Renewable Portfolio Standard (RPS). RPS are policies designed to increase the use of renewable
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energy sources for electricity generation. These policies require or encourage electricity suppliers to provide
their customers with a stated minimum share of electricity from eligible renewable resources. Most states,
including Arizona, have enacted their own RPS programs to diversify their energy resources, promote
domestic energy production and encourage economic development. Arizona has set their standards for
investor-owned utilities at 45% by 2030 and 100% by 2050.
Approval of the Project strengthens the overall energy production output within Maricopa County. The
increased local production over time will create energy surplus within the market resulting in a reduction of
cost and consumption by additional sectors of the local and regional economy. Project approval facilitates
a larger Regional share of renewable energy generation activities within the national production mix thereby
promoting energy independence throughout related national industries and markets.
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 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 land use patterns and subsequent zone change requests. Previous land use approvals
should not be construed to 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 solar powered generation.
The single Renewable Energy Strategy in the Plan promotes/encourages the “[attraction] of solar and
other alternative energy research and development to Maricopa County.” Approval of the CPA is
consistent with this strategy and the utility pattern that has been established in the Project area by
recent BOS approvals in favor of large-scale solar powered generation facilities within this remote area.
Increasing the county’s investment (in terms of land use planning) in local solar powered generation
facilities and infrastructure has a long-term tangible impact of lowering costs of energy production,
delivery, and consumption. This goal is achieved in part by increasing local/regional energy
production/generation. The increased supply has a proportionate impact on the accessibility of the
resource and encourages integration of applied uses and transitions away from reliance on outdated
and inefficient modes of energy generation and transmission creating efficiencies in these areas.
Increased supply and efficiencies will promote increased integration into the market for various sectors
of the economy (housing, manufacturing, transportation, etc.).
The CPA to change the land use from Rural Development Area to Utilities to accommodate the
proposed solar facility is in substantial conformance with renewable energy policies identified in the
Plan, addressed in the Energy Goal and Policy Considerations in Section D of this report.
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II. REQUIRING
PUBLIC
EXPENDITURES
FOR
LARGER
AND
MORE
EXPENSIVE
INFRASTRUCTURE.
Any and all 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 roads 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 applicant,
and none of these options would require improvements to public water systems.
Water for the limited construction period will be sourced from an on-site well, a nearby well, or delivered
from the Harquahala Valley Irrigation District. Neither water storage tanks nor holding ponds are
expected to be needed or placed within the adjacent road ROW. During the O&M phase, up to
approximately 10 acre-feet of water would be required per year for module washing and maintenance.
The Project will be consistent with Maricopa County’s water and wastewater treatment programs during
all phases of the development.
Underground wet/dry utility service or transmission lines within adjacent right-of-way will be solely at
the developer’s expense. Required on-site water and wastewater service and/or treatment for
construction, operations, and maintenance, activities will be the sole financial burden of the developer.
Required services and the developer’s plan of provision will meet county and state requirements for
water and on-site wastewater disposal criteria, permitting, and monitoring standards.
IV. ADVERSELY IMPACTING PLANNED USES BECAUSE OF INCREASED TRAFFIC.
Existing and planned uses surrounding the site which are dependent on the surrounding transportation
system are not anticipated to be impacted due to increased traffic. Planned uses on-site will not be
adversely impacted due to increased traffic. Increased traffic will be limited to construction and
implementation activities associated with this Project and not from others. The Project will keep existing
access points to nearby owners open and available during the construction phases. It is not anticipated
that surrounding approved, but not yet implemented solar utility Projects will begin construction
activities at the same time as the Project. During the construction period less than 100 additional ADT
are expected for each phase of Project construction; therefore, per the MCDOT Traffic Impact Study
Manual, a traffic statement will be required for each phase of the proposed site. A traffic impact study
will be provided in support of the necessary zone change and plan of development 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
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larger type of master plan developments. At that time, a clearer Projection of traffic impacts will be
available which will consider construction and operational ADT, construction haul routes, necessary
ROW dedications, and road improvements.
V. AFFECTING THE LIVABILITY OF THE AREA OR HEALTH OR SAFETY OF PRESENT AND
FUTURE RESIDENTS.
The 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 relatively few residences in the 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 and erosion control measures, BMP’s to include appropriate dust control and mitigation
of dust on unpaved roads. Standard operational activities conform to applicable noise ordinances. Fire
hazard and wildfire mitigation will be addressed with the plan of development. The Project will comply
with all applicable local and county fire laws and regulations. All reasonable measures will be taken to
prevent fires on the site including the control or suppression of weeds. If necessary, all weed control
would be in compliance with county regulations. The CPA will not result in undue or unmitigated social,
visual, traffic, air quality, water quality, or other impacts which may have a disproportionate affecting
the livability of the area.
VI. ADVERSELY IMPACTING THE NATURAL ENVIRONMENT OR SCENIC QUALITY OF THE
AREA IN CONTRADICTION TO THE PLAN.
The Project site has mostly been disturbed to accommodate agricultural uses and is not anticipated to
generate adverse impacts to the natural environment or the scenic quality of the area. Preliminary site
investigations have not identified any significant, unique, or critical wildlife habitats, endangered and/or
protected flora/fauna species, or significant cultural resources within the Project area.
The Project team will conduct onsite investigations and implement appropriate protective measures as
needed for biological and historical/archaeological resources to either avoid or mitigate impacts to the
natural environment, in coordination with the Arizona State Historic Preservation Office (SHPO) and
Arizona Game and Fish Department (AZGFD). The Applicant has been engaged with AZGFD,
throughout the past years of project approvals and construction of Harquahala Sun and Harquahala
Sun II, and 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 continue to meet with AZGFD and this coordination will continue in a more
detailed fashion with the subsequent zone change and plan of development to minimize any potential
impacts to the surrounding wildlife including proper treatment or preservation of drainage ways and
wildlife corridors. Specific to wildlife, AZGFD has recommended surveys and monitoring to identify the
species in the area. Based on previous approvals, it is known that this site is located south and west of
the known big horn sheep movement patterns in the area which occur to the north and east through
the Saddle Mountain range. Best management practices have been and will continue to be introduced
to address Avian safety. Future 500 kv lines do not pose significant threat to avian species because of
their spacing due to voltage. However, in general the Project team will follow best practices in the
industry to protect avian species such as adhering to APLIC standards. Our biologist team has reviewed
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these designs and indicated that these power lines pose an almost negligible risk to avian species.
Additionally, a burrowing owl survey will be required prior to final plan approval.
As discussed in the transportation sections, no major offsite road or transportation network
improvements are required to support the Project. Dust control measures will be provided to protect air
quality during construction activities. Ground disturbing activities may also require dust mitigation,
erosion control BMPs, 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 and will require little to no grading for access, PV pedestals, or supporting
accessory equipment or storage structures. Construction activities will implement accepted BMP’s for
solar PV facility development, which include minimum ground disturbance and non-disturbance of
existing low-lying vegetation and vegetation 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 have minor visual impacts to surrounding areas and properties. The solar arrays will extend
to an approximate 10-foot vertical height (typical) when panels are nearly vertical during sunrise and
sunset. The site will be screened with a minimum 6-foot fence to provide separation and security.
Details of proposed fencing will be provided with subsequent zone change and plan of development
applications and finalized through coordination and input from residents and impacted property owners.
No adverse or otherwise unmitigated impacts to the natural environment or scenic quality of the area
are anticipated.
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 pending zone change and 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 region’s fast paced growth and associated development issues. A lot has changed since 1997, including
a relevant update to introduce energy efficiency and renewable energy into the 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
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Comprehensive Plan, which is a planning mechanism that looks to balance this future growth with 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, the Project land use change helps support the implementation
of Maricopa County’s mission statement and strategic priorities by providing fiscally responsible alternative
energy 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 Project 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 promote an efficient use of land, energy and
financial resources. Specifically, the renewable energy and solar uses are discussed throughout Vision
2030 responding to Maricopa County’s ability to be one of the most productive spots int the world for solar
energy generation as discussed in the plan. These references provide measurable policies and strategies
to further the Economic Growth, Water Resources and Energy elements, 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.
The Project meets the overall intent of the Maricopa County Comprehensive Plan Vision 2030 by providing
a future need in renewable energy, 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 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 Development
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The Project 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 Project is a low impact land use, consistently found in the
area, that provides renewable energy generation to the region.
The Project requires minimal water usage, minimal traffic,
minimal operational employment or activity and no wastewater.
Additionally, it improves air quality and will provide necessary
ROW dedications, circulation, screening, and appropriate buffers.
Altogether, this passive land use will help contribute to the public
health, safety and well-being of the area.
Land Use Policy #7: Maricopa
County supports coordinating land
use and infrastructure planning with
state
agencies,
counties,
and
municipalities.
Land Use Policy #7 (Cont’d):
The process requires ongoing coordination with local, state, and
federal agencies to ensure protections of public services, utilities,
infrastructure, and natural resources. Coordination 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 has been
received as well through Maricopa County’s enhanced notification
process. Additional coordination will occur 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 Project is a land use already found in the surrounding area,
reducing the impact on nearby agricultural and rural land uses.
Additionally, at the end of the life of the project, agricultural uses
could continue on the site due to the flat terrain and minimal
impact to underlying soils.
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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.
Initial analysis hasn’t identified any flora or fauna species
requiring special mitigation or preservation. 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 AND POLICY CONSIDERATIONS
COMP PLAN ELEMENT
(GOALS/POLICIES)
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 Project will
further this priority by addressing some of their related concerns
specific to the preservation of road alignments and air pollution.
The Project will be responsible for ROW dedication of the
necessary roadway alignments, as indicated by MCDOT from its
respective boundaries to comply with the Maricopa County
Transportation Plan and road/ROW dedication standards of the
county. Exceptions will be negotiated with MCDOT and
authorized by the MC BOS and may require specific development
agreements to memorialize terms of negotiated dedications,
preservation, and/or and deferments or exemptions. Because no
full-time employees are proposed on-site, outside of the limited
construction traffic, the Project provides a use that will limit
automobile usage and reduce air pollution.
Transportation Goal #2: Contribute
to a safe, seamless and effective
transportation system.
The Project will support a safe, seamless, and effective
transportation system by dedicating and/or 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.
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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
Environment
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 solar research and development to this region is
due to the environmental benefits. The Project would further
Maricopa County’s potential to be a leader in renewable energy
research and development, with respect to solar energy, 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 Project approvals,
reports, plans, and permits will be prepared, for all on-site and
off-site Project activities and phases, 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.
The Project 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 significantly decrease carbon
dioxide emissions and eliminate sulfur, nitrous oxides, and
mercury
emissions
generated
by
conventional
electric
generation facilities. Additionally, compared to the current
agricultural uses on-site, this Project which will treated to reduce
potential fugitive dust will improve local air quality impacts from
fugitive dust emissions.
Environment 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.
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Environment 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.
Environment 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 as 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.
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 a
construction period which is anticipated to occur from
approximately 2023 through 2025. 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.
Economic
Growth
Policy
#5:
Maricopa County supports programs
that attract a variety of Basic Sector
industry clusters that have long-term,
stable growth prospects.
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Economic
Growth
Policy
#10:
Maricopa County supports leveraging
its solar resource potential to attract
solar-related
industries
and
alternative
energy
research
and
development.
More accessible energy sources will attract energy dependent
employment sectors to the region and allow existing basic sector
industries to reinvest energy savings into expansions, research
and development, and retrofitting activities to increase
productivity in response to growing demands and competition in
the regional and national share of their respective industries.
Increasing the supply of locally generated renewable energy
increases the attractiveness of the region on the demand for
technological innovations to meet the demand for additional
skilled and specialized workers. There will also be an increase
in the demand for specialized workers to respond to changes
and innovations in the solar powered generation industry and in
the development of spin off applications in the manufacturing,
transportation, and research/development industries.
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 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 applicant’s expenditures
to utilize existing infrastructure and to obtain necessary
easements to interconnect to the electrical grid.
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
requiring large amounts of land to operate that do 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.
Page 20
kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210
480 207 2666
WATER RESOURCES GOAL AND POLICY CONSIDERATIONS
COMP PLAN ELEMENT
(GOALS/POLICIES)
CPA CONSISTENCY/JUSTIFICATION
Water Resources Goal #4: Increase
water conservation.
The switch in land use from agriculture to solar will significantly
increase water conservation in the county. The Project will utilize
photovoltaic (PV) modules to generate electricity. PV technology
is the most water-efficient solar generation technology available.
The Applicant recognizes that the proposed site receives a high
degree of solar radiation and that water supplies in the vicinity
are limited. The Project will implement water conservation
measures while utilizing water-efficient technology. Solar uses
roughly 835 gallons of water per acre per year where agriculture
uses roughly 3,340 gallons of water per acre per year. Solar
plants use approximately 25 percent of water required for a
similar parcel of land growing alfalfa or other agricultural uses.
Construction Peak Water Usage would be roughly 5,690 AF/YR
and Operations & Maintenance Water Usage would be roughly
54 AF/YR for the Harquahala Sun III-V facility.
Water
Resources
Policy
#2:
Maricopa County supports water
conservation
techniques
in
the
planning
and
design
of
new
development.
The Project will include a comprehensive Water Conservation
Plan with established BMPs for water conservation. The
Project’s water-conscious design and implementation is
consistent with the applicable water goals and policies of the
Comprehensive Plan.
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 Project will maintain compliance with Maricopa County’s
wastewater treatment programs during the construction activity
period. The Project as proposed will not have wastewater
demands or discharge. A septic system will be used if an O&M
building is required. Alternatively, portable restroom facilities will
be provided for employee use during the implementation and
operational phases.
Water
Resources
Policy
#5:
Maricopa County supports low water
use
solar
electric
generating
technologies.
The Project will require very little water except for maintenance
for cleaning the solar panels and equipment. This water will
either be hauled to the site during construction and operation or
obtained from existing wells on-site or new wells permitted
through the Arizona Department of Water Resources (ADWR),
as needed. Water hauled to the site would be from permitted
sources.
Water
Resources
Policy
#7:
Maricopa County supports low water
use and drought tolerant landscaping.
If landscape treatments are required to provide visual buffering,
they will be selected from drought tolerant xeric species which
will require low water use to establish and maintain.
Page 21
kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210
480 207 2666
ENERGY GOAL AND POLICY CONSIDERATIONS
COMP PLAN ELEMENT
(GOALS/POLICIES)
CPA CONSISTENCY/JUSTIFICATION
Energy Goal #1:
Provide
leadership
to
promote
regional environmental quality.
The Project will have a long-term environmental impact of
improving air quality by reducing emissions associated with
conventional electric energy generation. The county has
adopted environmental performance standards intended to
preserve and sustain biologic, cultural, and environmental
resources of the region which are evidence of the county’s
regional leadership role in the promotion of environmental
quality.
Energy Goal #2:
Make Maricopa County a leader in
alternative
energy
research
and
development.
The Project provides the opportunity to implement, test, and
evaluate the efficiencies of the most current PV solar generation
equipment and battery energy storage systems. Evaluation of
their operational performance is key to the research and
development of more efficient equipment and related processes.
An operational facility provides opportunities to implement
advances in the associated technologies over the life of the
Project. Approval of the facility provides opportunities to test
storage systems in response to increasing demands for the use
of stored energy.
Energy Policy #6:
Maricopa County supports being a
responsible leader in alternative
energy research and development.
The Project will be reflective of the Maricopa County Board of
Supervisor’s regional and statewide leadership in the attraction,
promotion, and delivery of renewable energy resources and
infrastructure.
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.
Page 22
kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210
480 207 2666
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.
Despite the Project being mostly disturbed for agricultural
purposes, it encourages the preservation of natural open space
in the form of drainage corridors and wildlife linkages. The
Project, which is adjacent to the Centennial Wash, will conduct
onsite investigations and implement appropriate protective
measures as needed for biological and historical/archaeological
resources to either avoid or mitigate impacts to the natural
environment, in coordination with the Arizona State Historic
Preservation Office (SHPO) and Arizona Game and Fish
Department (AZGFD). This project will be developed to avoid,
minimize, or mitigate potential impacts to wildlife and
recreational access during development and operation of the
facilities. This coordination will continue in a more detailed
fashion with the subsequent zone change and plan of
development to minimize any potential impacts to the
surrounding wildlife including proper treatment or preservation of
drainage ways and wildlife corridors.
(The remainder of this page is left intentionally blank)
MCDOT Comments – CPA250006 – APN 506-28-017, 46 parcels, and 4 ASLD parcels –
Harquahala Sun III, IV, and V – Major CPA
• MCDOT is currently working with the developer of Harquahala Sun to determine
their preservation and dedication requirements through a right of way reservation
action request. Depending on the outcome of this application the following
requirements may change.
• Baseline Road in T1N R9W Section 34 is classified as a future minor arterial typically
requiring fee dedication of a 55-foot half street from the section line.
o There appears to be an easement for 65-feet and due to the state land
boundary, only preservation of a minimum 55-feet is required at this time.
• Baseline Road in T1N R9W Section 32 is classified as a future minor arterial typically
requiring fee dedication of a 55-foot half street from the section line.
o Due to the state land boundary, only preservation is required at this time.
• Baseline Road in T1N R9W Section 36 is classified as a future minor arterial
requiring preservation of a 55-foot half street from the section line.
• Eagletail Road / Dobbins Road is classified as a future minor arterial requiring
preservation of a 55-foot half street from the section line.
• 539th Avenue is classified as a future minor arterial requiring preservation of a 55-
foot half street from the section line.
• Any additional dedication and offsite improvement requirements will be determined
by MCDOT Traffic based on a submitted TIA/TIS to Permit Center at
https://maricopacountyaz-energovweb.tylerhost.net/apps/selfservice#/home.
o If a TIA/TIS has been previously submitted, approval is valid for one year. If
review for construction is not underway within this time period, MCDOT may
request an updated traffic report to assess any changes in condition.
• All other 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
1105.
• 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.
Thank you,
Drew Sigado
Planning Project Manager
Department of Transportation
Engineering Division
2901 West Durango Street Phoenix, Arizona 85009
O: 602-506-7223
E: Drew.Sigado@Maricopa.gov
[ Maricopa.Gov ]
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June 12, 2025
SENT VIA EMAIL
Martin Martell, Planner
Maricopa County Planning and Development Department
301 W. Jefferson Street, Suite 170
Phoenix, AZ 85003
Subject:
CPA250006 Major Comprehensive Plan Amendment – Harquahala Sun III, IV, & V
Dear Mr. Martell:
Thank you for the opportunity to review and comment on Maricopa County Major Comprehensive
Plan Amendment CPA250006 - Harquahala Sun III, IV, & V, land use change from Rural Densities
to Utilities on ± 5,541.35 acres, for an expansion of an existing large-scale solar farm and battery
storage system.
The Harquahala Sun III, IV, & V major comprehensive plan amendment area is located in a
remote agricultural area of the county approximately 8 miles south of Interstate 10, 18 miles west
of the Palo Verde Generating Station, and about 60 miles west of central Phoenix.
The proposed solar energy generation and storage project expansion is in a region of high solar
exposure, proximity to other existing solar energy farms and adequate energy transmission
infrastructure. The project should have minimal impact on surrounding properties while the
generation of renewable energy would be a benefit to the region.
Pima County Development Services Department, Planning Division has no opposition to the
proposed major comprehensive plan amendments.
Sincerely,
Anita McNamara, AICP
Planner II
Pima County Development Services Department, Planning Division
June 30, 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:
CPA250006 - Harquahala Sun III-V
Dear Mr. Martell:
The Arizona Game and Fish Department (Department) appreciates the opportunity to review the
proposed CPA250006 - Harquahala Sun III-V Solar (Project). The Department understands that
Kimley-Horn, on behalf of Harquahala Complex HoldCo LLC (Harquahala LLC), has requested
a Major Comprehensive Plan Amendment (CPA) of the Maricopa County Vision 2030
Comprehensive Plan to change the land use designation of approximately 5,541 acres of land
from Rural Development Area to Utilities to allow for additional development areas of the
previously approved Harquahala Sun III-V solar project. Following the CPA request, Harquahala
LLC will be applying for a Zone Change with Overlay to rezone the underlying parcels from
RU-43 and RU-190 (Rural Residential Use) to IND-2 IUPD (Industrial Use). It is understood
that Harquahala LLC proposes to expand the original Harquahala Sun III-V project area to
construct, operate, and maintain an additional photovoltaic (PV) solar facility with a battery
energy storage system (BESS) and associated infrastructure on approximately 2,636 acres of
Arizona State Land Department (ASLD) lands and 2,905 acres of private land, approximately 20
miles west of the City of Buckeye in Maricopa County, Arizona. The Project area consists of
multiple parcels of land south of Interstate 10, bound on the west side by S 539th Ave and on the
east side by S 487th Ave, in a mix of agricultural land and undisturbed Sonoran desert scrub
habitat. An approximately 10-mile 500 kV generation intertie (gen-tie) transmission line would
connect the facility to the Arizona Public Service operated Delaney Substation.
Under Title 17 of the Arizona Revised Statutes, the Department, by and through the Arizona
Game and Fish Commission, has jurisdictional authority and public trust responsibilities to
conserve and protect the state fish and wildlife resources. In addition, the Department manages
threatened and endangered species through authorities of Section 6 of the Endangered Species
Act and the Department’s Section 10(a)(1)(A) permit. It is the mission of the Department to
conserve and protect Arizona's diverse fish and wildlife resources and manage for safe,
compatible outdoor recreation opportunities for current and future generations.
AZGFD – Harquahala Sun III-V - CPA250006
June 30, 2025
Page 2
The Department recognizes the importance of planning efforts to develop renewable energy
locations that contribute to regional and state economic growth needs and would like to work
closely with Harquahala LLC, Kimley-Horn, 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 allow projects to be
developed that avoid, minimize, or offset potential impacts to wildlife and recreational access
during development and operation of the facilities. For your consideration, the Department
provides the following comments based on the agency's statutory authorities, public trust
responsibilities, and special expertise related to wildlife resources and recreation.
Arizona has recently seen an increase in the number of proposed and in-development renewable
energy generation projects and associated infrastructure. A number of solar energy projects have
been built or proposed within the vicinity of this Project, including the previously approved
Harquahala Sun projects I-III and the Maricopa Energy Center. Although each of these projects
individually may have a minimal impact on the broader landscape, these projects cumulatively
could result in loss of habitat, impact wildlife movements, and affect wildlife-related recreation.
Additionally, long-term effects to wildlife can extend several kilometers beyond the footprint of
a solar project area (Sawyer et al. 2022 ). It is important to consider all potential cumulative
1
effects and to evaluate this Project in association with other projects in the area. Department staff
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. These surveys should be of sufficient duration and intensity to adequately assess all
habitat types and potential wildlife species occurrence in and adjacent to the Project area.
Department staff are available to assist Harquahala LLC and Kimley-Horn in determining
appropriate surveys to conduct, as well as recommend design features and best management
practices that can help minimize potential impacts. Based on the information provided, the
Department offers the following recommendations to reduce potential impacts to wildlife and
habitat; additional information can be found in Guidelines for Solar Development in Arizona :
2
● The endangered Sonoran pronghorn has been documented within 5 miles of the Project
vicinity, and the Project area is within the 10(j) designated, experimental nonessential
recovery area for the Sonoran pronghorn. Pronghorn could occur in the Project area and
adjacent lands.The Department would like to work with Harquahala LLC to minimize
any potential impacts to this species. The Department requests coordination prior to
construction activities in order to exchange information on current Sonoran pronghorn
use in the Project area. If pronghorn are detected during Project activities, please notify
the U.S. Fish and Wildlife Service (USFWS) and the Department’s Sonoran Pronghorn
3
Program Lead (rgardner@azgfd.gov) as soon as possible.
● The Sonoran desert tortoise, which is a federal and state species of special concern, has
been documented within 5 miles of the Project area. The Department recommends
3 https://www.fws.gov/office/arizona-ecological-services/contact-us
2 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/
FinalSolarGuidelines03122010.pdf
1 https://esajournals.onlinelibrary.wiley.com/doi/10.1002/fee.2498
AZGFD – Harquahala Sun III-V - CPA250006
June 30, 2025
Page 3
conducting surveys for Sonoran desert tortoise within suitable habitat to determine the
presence of this species. The Sonoran Desert Tortoise Conservation Guidelines provide
4
protocols for these surveys. If this species is detected, please refer to this document for
guidelines on handling tortoises and recommended measures to avoid, minimize, or offset
impacts to this species resulting from development activities.
● The western burrowing owl, a special status species that is regulated under the Migratory
Bird Treaty Act (MBTA), has been documented within 5 miles of the Project area. The
Department recommends conducting occupancy surveys for this species in advance of the
design phase to understand distribution of burrowing owls in the Project site; avoidance
of a large burrowing owl population may be advisable over removal or other conservation
measures. Guidelines for conducting this survey are found in Burrowing Owl Project
Clearance Guidance for Landowners . Please note that the survey should be conducted
5
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 USFWS for direction, in accordance with the guidelines.
● Large-scale solar PV facilities can result in bird mortality due to habitat loss, collision
with panels, attraction due to an optical illusion of water, and unknown causes (Kosciuch
et al. 2020 ). The Department recommends conducting avian surveys during the planning
6
stage in order to better understand species presence and to inform potential conservation
measures. Point counts are the preferred method for breeding bird surveys. These surveys
are conducted twice a year during the peak breeding season, which is January through
June in this area; McLaren et al. (2019) outline protocols. In addition, LeConte’s
7
Thrashers have been documented within 5 miles of the Project area, and the Project area
may also contain suitable habitat for Bendire’s Thrashers. Additional surveys for these
thrashers, two bird species of conservation concern, are recommended per the Desert
Thrasher Working Group (DTWG). Please reference the DTWG’s Conservation of
Bendire’s and LeConte’s Thrashers at Solar Development Sites which outlines how to
8
determine occupancy of thrashers and design considerations if present.
● The Department also recommends conducting surveys for nesting birds prior to
vegetation removal and/or construction activities that occur during the breeding season.
The vegetation within the Project area may provide nesting opportunities for avian
species that are regulated under the Migratory Bird Treaty Act (MBTA). If it is
anticipated the Project will not be in compliance with MBTA, the Department
recommends contacting the USFWS for technical assistance.
● Burrowing species could occur within the Project area and could be influenced by
construction activities and by loss of habitat. Surveys for these species are recommended
to determine their presence and to inform pre-construction activities. Department staff are
available to assist in identifying suitable conservation measures, such as one-way
8 https://borderlandsbirds.org/wp-content/uploads/2024/09/Desert-Thrasher-Solar-Recommendations-1.0.pdf
7 https://drive.google.com/drive/folders/1SF-iNJ8yc8YD0s3Uogbu-gOGxS39ADUP
6 https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0232034
5 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/nongame/eagles/BurrowingOwl
ClearanceProtocol_2009.pdf
4 https://azgfd-portal-wordpress-pantheon.s3.us-west-2.amazonaws.com/wp-content/uploads/2025/01/16114611/
Rubke-2024.-Sonoran-Desert-Tortoise-Conservation-Guidelines.pdf
AZGFD – Harquahala Sun III-V - CPA250006
June 30, 2025
Page 4
exclosures on burrows that allow wildlife to exit the burrows and disperse to adjacent
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
Project is adjacent to Centennial Wash, which is an identified Maricopa County Wildlife
Movement Area, and the landscape in which this Project is proposed provides important
movement pathways for wildlife. The Department would like to meet with Harquahala LLC and
Kimley-Horn to discuss opportunities to incorporate wildlife connectivity into the Project design,
including the following:
● The Department recommends incorporating open unfenced corridors across the Project
area into the Project design in order to facilitate wildlife movement. It is beneficial to
include upland habitat in these corridors, as well as maintaining the ephemeral washes
that occur in the Project area in their natural state without fencing or other barriers to
wildlife movement. These washes serve multiple functions in the ecosystem, including
landscape-level conveyance corridors for wildlife movement. The Department
recommends a minimum corridor width of approximately 1,300 feet.
● The Department’s Wildlife Compatible Fencing Guidelines provide information on how
9
fencing impacts wildlife, ways to design fencing to prevent wildlife entanglement and
impalement, and to ensure wildlife movement is not restricted. Department personnel are
available as resources to help determine appropriate fencing design and layout that will
achieve its objective while reducing impact on wildlife, such as leaving a 6–8-inch gap
between the ground surface and bottom of the fence to allow for smaller wildlife species
to move freely through the area and make use of any habitat within the Project 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
potential to occur within the Project area; please reference the attached HDMS report
(HGIS-25279) for a complete list of species previously documented within a 5 mile
radius. If wildlife are encountered during Project activities, the Department recommends
moving them out of harm’s way, no more than 0.25 mile outside the Project boundary
within similar habitat. Please note that the Arizona State Wildlife Action Plan was
recently updated, and the Department has an interactive website, Arizona Wildlife
Conservation Strategy , that includes the most recent list of SGCN to help navigate and
10
identify conservation opportunities.
● The Department understands that there will be minimal grading of the Project area and, to
the extent possible, habitat features underneath the panels including vegetation and soils
will be retained. As stated in the project narrative, the topography in the majority of the
site is flat and would require minimal trimming of shrubs and existing vegetation to
install the panels. Keeping the existing soil and root structures intact would serve to
10 https://awcs.azgfd.com
9 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/
110125_AGFD_fencing_guidelines.pdf
AZGFD – Harquahala Sun III-V - CPA250006
June 30, 2025
Page 5
minimize erosional run-off and help reduce biodiversity loss within the site (Grodsky and
Hernandez 2020 ).
11
● If trenching or digging of large holes will occur, the Department recommends that
trenching/digging and backfilling crews work together to minimize the number of open
holes/trenches at any given time. Where trenches/holes cannot be backfilled immediately,
the Department recommends escape ramps be constructed in each hole and at least every
90 meters in trenches. Escape ramps can be short lateral trenches or wooden planks
sloping to the surface, and ramp slopes should be less than 45 degrees (1:1). Trenches or
holes that have been left open should be inspected for animals and animals removed prior
to backfilling.
● The Department appreciates that the project team has committed to following the Avian
Power Line Interaction Committee (APLIC) guidelines for new power lines, which can
be found in the current version of Suggested Practices for Avian Protection on Power
Lines and Reducing Avian Collisions with Power Lines. Large bodied birds, such as
hawks, owls, vultures, and eagles, may be vulnerable to line strikes and electrocution
during construction and operation of power lines and substations; power poles can also
serve as perches for large-bodied birds. These potential impacts can be avoided or
minimized by following the APLIC guidelines which include designing the power lines
with enough space between energized components to reduce the likelihood of a bird
electrocution or installing bird flight diverters in sections of line where elevated bird
strikes are anticipated (e.g. lines over water bodies or in the path of colonial roosting
locations). The Department’s Raptor Coordinator, who can be contacted at
raptors@azgfd.gov or 623-236-7575, can provide further information on specific design
features and best management practices.
● Artificial lighting could impair the ability of nocturnal animals to navigate (e.g., owls,
migratory birds, bats, and other nocturnal mammals) and may affect wildlife behavior
and populations (Davies et. al. 2013 ). The Department recommends using only the
12
minimum amount of light needed for safety. If feasible, “warmer” narrow spectrum
lighting (amber, orange, red) is wildlife-friendly and should be used as often as possible
to minimize the number of species affected by lighting. It is also beneficial that all
lighting is shielded, canted, or cut to minimize the amount of upward shining light.
● Please ensure the Project complies with Arizona Native Plant Law regulations. A
13
Native Plant Inventory may need to be conducted to identify, record, and coordinate plant
salvage efforts for species that are Protected under the Arizona Native Plant Law.
● To minimize the potential introduction or spread of exotic invasive species, including
aquatic and terrestrial plants, animals, insects, and pathogens, the Department encourages
taking precautions to wash and/or decontaminate equipment before entering and leaving
the Project site. See the Arizona Department of Agriculture website for a list of
14
prohibited and restricted noxious weeds and the Arizona Native Plant Society for
15
recommendations on how to control them. To view a list of documented invasive species
15 https://aznps.com/invas
14 https://agriculture.az.gov/pestspest-control/agriculture-pests/noxious-weeds
13 https://agriculture.az.gov/plantsproduce/native-plants
12 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3657119
11 https://www.nature.com/articles/s41893-020-0574-x
AZGFD – Harquahala Sun III-V - CPA250006
June 30, 2025
Page 6
or to report invasive species in or near the Project area, visit iMapInvasives , which is a
16
national cloud-based application for tracking and managing invasive species.
○ Stinknet is a highly invasive noxious winter weed native to South Africa, and is
extremely flammable when dry. Stinknet (also known as globe chamomile) has
heavily infested Maricopa, Pinal, and Pima counties and is expanding into Yuma,
Yavapai, and Gila counties. Infestations spread rapidly along highways and open
fields in residential areas. Emergence starts in late November and plants can
continue to germinate and emerge through May in wet years. In order to minimize
the spread of this plant it is critical that any new infestations are identified and
quickly managed. Additional information is available through the Southwest
Vegetation Management Association , the Sonoran Desert Cooperative Weed
17
Management Area , or the Arizona Native Plant Society .
18
19
● If disturbed areas will be re-vegetated with drought-tolerant species to provide visual
buffering, as mentioned in the Project narrative regarding Water Resources Policy #7 in
the Maricopa County Vision 2030 Comprehensive Plan, the Department recommends
revegetating with native drought-tolerant species that represent the natural surrounding
landscape. Landscaping with native plants can help support wildlife and pollinator
species in the area while reducing dust and erosion. In addition, the applicable land
management agencies should be consulted regarding guidelines for revegetation efforts.
Thank you for the opportunity to provide input on CPA250006 - Harquahala Sun III-V. For
further coordination, please contact Teigan Williams at tstruck@azgfd.gov or 928-341-4069.
Sincerely,
Danielle Klaas
Regional Supervisor - Region IV
cc:
Callie Cavalcant - Habitat, Evaluation, and Lands Branch Chief
AZGFD #M25-06105651
19 http://aznps.com
18 https://www.sdcwma.org/species/stinknet.php
17 https://www.swvma.org/
16 https://imap.natureserve.org/imap/services/page/map.html
Arizona Environmental Online Review Tool Report
Arizona Game and Fish Department Mission
To conserve Arizona's diverse wildlife resources and
manage for safe, compatible outdoor recreation
opportunities for current and future generations.
The Department requests further coordination to provide project/species specific recommendations.
Please use the Project Evaluation Form to submit your project to the Project Evaluation Program
at PEP@azgfd.gov.
Project Name:
Harquahala Sun III-V (Maricopa Co. CPA250006)
Project Type:
Energy Production/Storage/Transfer, Energy Production (generation), photovoltaic solar facility
(new/expansion)
Project ID:
HGIS-25279
Project Description:
"Kimley-Horn, on behalf of Harquahala Complex HoldCo LLC, (Applicant) with permission of the [private]
property owners, is requesting a Major Comprehensive Plan Amendment (CPA) of the Vision 2030
Comprehensive Plan to change the land use designation of ±5,541.35 acres (±2,636.0 acres of ASLD &
±2,905.35 acres of privately owned land) from Rural Development Area to Utilities to allow for additional
development areas to be added to the previously approved Harquahala Sun III-V Photovoltaic Solar Energy
Generation and Storage Project (Case #'s: CPA2022010 & Z2023131). The CPA request will be accompanied
by a subsequent Zone Change with Overlay request to rezone the underlying parcels from RU-43 and RU-190 to
the IND-2 IUPD." The Project is located approximately 20 miles west of the City of Buckeye, situated around the
intersection of Baseline Road and S 539th Ave. The Project is on mostly previously disturbed agricultural land,
with some undeveloped Sonoran scrub habitat in the westernmost parcels.
Contact Person:
Calle Hinkle
Organization:
Arizona Game & Fish
On Behalf Of:
MARICOPA
Page 1 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Disclaimer:
1. This Environmental Review is based on the project study area that was entered. The report must be
updated if the project study area, location, or the type of project changes.
2. This is a preliminary environmental screening tool. It is not a substitute for the potential knowledge
gained by having a biologist conduct a field survey of the project area. This review is also not intended to
replace environmental consultation (including federal consultation under the Endangered Species Act),
land use permitting, or the Departments review of site-specific projects.
3. The Departments Heritage Data Management System (HDMS) data is not intended to include potential
distribution of special status species. Arizona is large and diverse with plants, animals, and
environmental conditions that are ever changing. Consequently, many areas may contain species that
biologists do not know about or species previously noted in a particular area may no longer occur there.
HDMS data contains information about species occurrences that have actually been reported to the
Department. Not all of Arizona has been surveyed for special status species, and surveys that have been
conducted have varied greatly in scope and intensity. Such surveys may reveal previously
undocumented population of species of special concern.
4. Arizona Wildlife Conservation Strategy (AWCS), specifically Species of Greatest Conservation Need
(SGCN), represent potential species distribution models for the State of Arizona which are subject to
ongoing change, modification and refinement. The status of a wildlife resource can change quickly, and
the availability of new data will necessitate a refined assessment.
Locations Accuracy Disclaimer:
Project locations are assumed to be both precise and accurate for the purposes of environmental review. The
creator/owner of the Project Review Report is solely responsible for the project location and thus the correctness
of the Project Review Report content.
Page 2 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Recommendations Disclaimer:
1. The Department is interested in the conservation of all fish and wildlife resources, including those
species listed in this report and those that may have not been documented within the project vicinity as
well as other game and nongame wildlife.
2. Recommendations have been made by the Department, under authority of Arizona Revised Statutes
Title 5 (Amusements and Sports), 17 (Game and Fish), and 28 (Transportation).
3. Potential impacts to fish and wildlife resources may be minimized or avoided by the recommendations
generated from information submitted for your proposed project. These recommendations are preliminary
in scope, designed to provide early considerations on all species of wildlife.
4. Making this information directly available does not substitute for the Department's review of project
proposals, and should not decrease our opportunity to review and evaluate additional project information
and/or new project proposals.
5. Further coordination with the Department requires the submittal of this Environmental Review Report with
a cover letter and project plans or documentation that includes project narrative, acreage to be impacted,
how construction or project activity(s) are to be accomplished, and project locality information (including
site map). Once AGFD had received the information, please allow 30 days for completion of project
reviews. Send requests to:
Project Evaluation Program, Habitat Branch
Arizona Game and Fish Department
5000 West Carefree Highway
Phoenix, Arizona 85086-5000
Phone Number: (623) 236-7600
Fax Number: (623) 236-7366
Or
PEP@azgfd.gov
6. Coordination may also be necessary under the National Environmental Policy Act (NEPA) and/or
Endangered Species Act (ESA). Site specific recommendations may be proposed during further
NEPA/ESA analysis or through coordination with affected agencies.
Page 3 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Page 4 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Page 5 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Page 6 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Page 7 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Special Status Species Documented within 5 Miles of Project Vicinity
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Antilocapra americana sonoriensis
Sonoran Pronghorn
LE,XN
S
1
Athene cunicularia hypugaea
Western Burrowing Owl
S
S
2
Buteo swainsoni
Swainson's Hawk
2
Crotalus pyrrhus
Speckled Rattlesnake
2
Falco mexicanus
Prairie Falcon
2
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1
Incilius alvarius
Sonoran Desert Toad
2
Macrotus californicus
California Leaf-nosed Bat
S
2
Toxostoma lecontei
LeConte's Thrasher
S
2
Note: Status code definitions can be found at https://www.azgfd.com/wildlife-conservation/on-the-ground-
conservation/state-wildlife-action-plan/state-wildlife-action-plan-status-definitions/.
Special Areas Documented that Intersect with Project Footprint as Drawn
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Centennial Wash
Maricopa County Wildlife Movement
Area - Riparian/Wash
Harquahala Plain
Conservation Opportunity Area
Note: Status code definitions can be found at https://www.azgfd.com/wildlife-conservation/on-the-ground-
conservation/state-wildlife-action-plan/state-wildlife-action-plan-status-definitions/.
Species of Greatest Conservation Need Predicted that Intersect with Project Footprint as Drawn, based on
Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Ammospermophilus harrisii
Harris' Antelope Squirrel
2
Anaxyrus microscaphus
Arizona Toad
S
2
Anthus spragueii
Sprague's Pipit
2
Antilocapra americana sonoriensis
Sonoran Pronghorn
LE,XN
S
1
Aquila chrysaetos
Golden Eagle
BGA
S
2
Artemisiospiza nevadensis
Sagebrush Sparrow
3
Asio otus
Long-eared Owl
2
Athene cunicularia hypugaea
Western Burrowing Owl
S
S
2
Auriparus flaviceps
Verdin
2
Botaurus lentiginosus
American Bittern
2
Calcarius ornatus
Chestnut-collared Longspur
2
Calypte costae
Costa's Hummingbird
2
Campylorhynchus brunneicapillus
Cactus Wren
2
Charadrius montanus
Mountain Plover
2
Coccyzus americanus
Yellow-billed Cuckoo (Western DPS)
LT
S
S
1
Colaptes chrysoides
Gilded Flicker
S
2
Page 8 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Species of Greatest Conservation Need Predicted that Intersect with Project Footprint as Drawn, based on
Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Corynorhinus townsendii pallescens Pale Townsend's Big-eared Bat
S
S
1
Empidonax wrightii
Gray Flycatcher
2
Eumops perotis californicus
Greater Western Bonneted Bat
S
2
Falco mexicanus
Prairie Falcon
2
Falco peregrinus anatum
American Peregrine Falcon
S
S
1
Falco sparverius
American Kestrel
2
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1
Incilius alvarius
Sonoran Desert Toad
2
Lanius ludovicianus
Loggerhead Shrike
2
Lasiurus cinereus
Hoary Bat
2
Lasiurus xanthinus
Western Yellow Bat
S
2
Macrotus californicus
California Leaf-nosed Bat
S
2
Megascops kennicottii
Western Screech-owl
2
Melanerpes uropygialis
Gila Woodpecker
2
Melospiza lincolnii
Lincoln's Sparrow
2
Micrathene whitneyi
Elf Owl
3
Myotis velifer
Cave Myotis
S
2
Myotis yumanensis
Yuma Myotis
2
Nyctinomops femorosaccus
Pocketed Free-tailed Bat
2
Passerculus sandwichensis
Savannah Sparrow
2
Perognathus amplus
Arizona Pocket Mouse
2
Phrynosoma solare
Regal Horned Lizard
2
Pooecetes gramineus
Vesper Sparrow
2
Rana yavapaiensis
Lowland Leopard Frog
S
S
1
Spizella breweri
Brewer's Sparrow
2
Tadarida brasiliensis
Brazilian Free-tailed Bat
2
Thomomys bottae subsimilis
Harquahala Southern Pocket Gopher
2
Toxostoma bendirei
Bendire's Thrasher
2
Toxostoma lecontei
LeConte's Thrasher
S
2
Species of Economic and Recreation Importance Predicted that Intersect with Project Footprint as Drawn
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Callipepla gambelii
Gambel's Quail
Odocoileus hemionus
Mule Deer
Pecari tajacu
Javelina
Puma concolor
Mountain Lion
Zenaida asiatica
White-winged Dove
Zenaida macroura
Mourning Dove
Page 9 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
Project Type: Energy Production/Storage/Transfer, Energy Production (generation), photovoltaic solar facility
(new/expansion)
Project Type Recommendations:
During the planning stages of your project, please consider the local or regional needs of wildlife in regards to movement,
connectivity, and access to habitat needs. Loss of this permeability prevents wildlife from accessing resources, finding
mates, reduces gene flow, prevents wildlife from re-colonizing areas where local extirpations may have occurred, and
ultimately prevents wildlife from contributing to ecosystem functions, such as pollination, seed dispersal, control of prey
numbers, and resistance to invasive species. In many cases, streams and washes provide natural movement corridors
for wildlife and should be maintained in their natural state. Uplands also support a large diversity of species, and it is
important to identify and conserve upland wildlife movement corridors. In addition, maintaining biodiversity and
ecosystem functions can be facilitated through improving designs of structures, fences, roadways, and culverts to
promote passage for a variety of wildlife species. Guidelines for many of these can be found at:
https://www.azgfd.com/wildlife-conservation/planning-for-wildlife/planning-for-wildlife-wildlife-friendly-guidelines/.
Consider impacts of outdoor lighting on wildlife and develop measures or alternatives that can be taken to increase
human safety while minimizing potential impacts to wildlife. Artificial lighting could impair the ability of nocturnal animals
to navigate (e.g., owls, migratory birds, bats, and other nocturnal mammals) and may affect wildlife behavior and
populations. The AZGFD recommends using only the minimum amount of light needed for safety, especially in areas
immediately adjacent to open space or undeveloped lands. The AZGFD encourages the use of motion sensing lighting
and narrow spectrum lighting (amber or warm tones typically 2700 Kelvin or lower) wherever possible to lower the range
of species affected by lighting. Also, please consider shielding, canting, or cutting all lighting, where possible, to ensure
that light reaches only areas needing illumination and to minimize impacts to nocturnal wildlife.
Minimize the potential introduction or spread of exotic invasive species, including aquatic and terrestrial plants, animals,
insects and pathogens. Precautions should be taken to wash and/or decontaminate all equipment utilized in the project
activities before entering and leaving the site. See the Arizona Department of Agriculture website for a list of prohibited
and restricted noxious weeds at https://www.invasivespeciesinfo.gov/ and the Arizona Native Plant Society
https://aznps.com/invas for recommendations on how to control these species. To view a list of documented invasive
species or to report invasive species in or near your project area visit iMapInvasives - a national cloud-based application
for tracking and managing invasive species at https://imap.natureserve.org/imap/services/page/map.html.
To build a list: zoom to your area of interest, use the identify/measure tool to draw a polygon around your area of
interest, and select “See What’s Here” for a list of reported species. To export the list, you must have an
account and be logged in. You can then use the export tool to draw a boundary and export the records in a csv
file.
Evaluate potential impacts to wildlife and fish species due to changes in access to water, water quality, quantity,
chemistry, temperature, and alteration to flow regimes (timing, magnitude, duration, and frequency of floods). Minimize
impacts to springs, in-stream flow, and consider irrigation improvements to decrease water use. If dredging is a project
component, consider timing the project to minimize impacts to spawning fish and other aquatic species. Wash, drain, and
dry equipment to reduce the spread of exotic invasive species. AZGFD recommends early coordination with the Project
Evaluation Program (PEP@azgfd.gov) for projects that could impact water resources, wetlands, streams, springs, and/or
riparian habitats.
The AZGFD recommends that wildlife surveys are conducted to determine if noise-sensitive species, such as birds or
mammals, occur within the project area. Avoidance or minimization measures could include conducting project activities
outside of breeding seasons.
Page 10 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
The AZGFD recommends following the Avian Power Line Interaction Committee (APLIC) guidelines for new power lines,
which can be found in the current version of Suggested Practices for Avian Protection on Power Lines and Reducing
Avian Collisions with Power Lines. Large bodied birds, such as hawks, owls, vultures, and eagles, may be vulnerable to
line strikes and electrocution during construction and operation of power lines and substations; power poles can also
serve as perches for large-bodied birds. These potential impacts can be avoided or minimized by following the APLIC
guidelines which include designing the power lines with enough space between energized components to reduce the
likelihood of a bird electrocution or installing bird flight diverters in sections of line where elevated bird strikes are
anticipated (e.g. lines over water bodies or in the path of colonial roosting locations). The AZGFD’s Raptor Coordinator,
who can be contacted at raptors@azgfd.gov or 623-236-7575, can provide further information on specific design features
and best management practices.
The AZGFD recommends that a qualified biologist conduct a survey for nesting birds within the project area prior to
removal or trimming of trees/vegetation, if the removal or trimming occurs during the breeding season (the Project
Evaluation Program can be contacted at PEP@azgfd.gov or 623-236-7600 to determine the appropriate breeding
season within the project area). Trees and/or vegetation within the project area may provide nesting opportunities for
avian species that are regulated under the Migratory Bird Treaty Act (MBTA) and protected under state law. If it is
anticipated the project will not be in compliance with MBTA, the AZGFD recommends contacting the U.S. Fish and
Wildlife Service (https://www.fws.gov/office/arizona-ecological-services) for technical assistance. The USFWS will
provide options to comply with the MBTA.
Vegetation restoration projects (including treatments of invasive or exotic species) should have a completed site-
evaluation plan (identifying environmental conditions necessary to re-establish native vegetation), a revegetation plan
(species, density, method of establishment), a short and long-term monitoring plan, including adaptive management
guidelines to address needs for replacement vegetation.
Project Location and/or Species Recommendations:
Analysis indicates that your project is located in the vicinity of an identified Conservation Opportunity Area (COA).
While there are many areas in Arizona that present abundant conservation opportunities, COAs are specific areas on the
landscape that the Department identified as having the greatest potential for conservation efforts. COAs were identified
using species and habitat data, the presence of unique landscape features, and Departmental expertise. COAs range in
size, scope, and focal species and/or habitats and are strictly a non-regulatory conservation tool for the public and our
conservation partners to consider. For more information regarding this particular COA near your project area and the
Department's suggestions for potential conservation efforts, please visit the COA profile at
https://awcs.azgfd.com/conservation-opportunity-areas.
Analysis indicates that your project is located in the vicinity of an identified wildlife habitat connectivity feature. The
County-level Stakeholder Assessments contain five categories of data (Barrier/Development, Wildlife Crossing Area,
Wildlife Movement Area- Diffuse, Wildlife movement Area- Landscape, Wildlife Movement Area- Riparian/Washes) that
provide a context of select anthropogenic barriers, and potential connectivity. The reports provide recommendations for
opportunities to preserve or enhance permeability. Project planning and implementation efforts should focus on
maintaining and improving opportunities for wildlife permeability. For information pertaining to the linkage assessment
and wildlife species that may be affected, please refer
to: https://www.azgfd.com/wildlife-conservation/planning-for-wildlife/planning-for-wildlife-identifying-corridors/.
Please contact the Project Evaluation Program (pep@azgfd.gov) for specific project recommendations.
Page 11 of 12
Arizona Game and Fish Department
project_report_harquahala_sun_iii_v_marico_88893_91549.pdf
Project ID: HGIS-25279
Review Date: 6/9/2025 03:21:22 PM
HDMS records indicate that one or more Listed, Proposed, or Candidate species or Critical Habitat (Designated or
Proposed) have been documented in the vicinity of your project. The Endangered Species Act (ESA) gives the US Fish
and Wildlife Service (USFWS) regulatory authority over all federally listed species. Please contact USFWS Ecological
Services Offices at https://www.fws.gov/office/arizona-ecological-services or:
Phoenix Main Office
Tucson Sub-Office
Flagstaff Sub-Office
9828 North 31st Avenue #C3
201 N. Bonita Suite 141
SW Forest Science Complex
Phoenix, AZ 85051-2517
Tucson, AZ 85745
2500 S. Pine Knoll Dr.
Phone: 602-242-0210
Phone: 520-670-6144
Flagstaff, AZ 86001
Fax: 602-242-2513
Fax: 520-670-6155
Phone: 928-556-2157
Fax: 928-556-2121
HDMS records indicate that Sonoran Desert Tortoise have been documented within the vicinity of your project area.
Please review the Tortoise Handling Guidelines found at https://s3.amazonaws.com/azgfd-portal-
wordpress/PortalImages/files/wildlife/2014%20Tortoise%20handling%20guidelines.pdf.
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