TA250001 PZ Handout Memo

DATE:  
November 5, 2025 
 
TO: 
 Planning & Zoning Commission   
 
From: 
 Rachel Applegate, Planning Supervisor  
 
SUBJECT: 
 TA250001 – Maricopa County Zoning Ordinance Update  
 
 Agenda Item: #12 
 
 
 
MCZO Update – Chapter 6 – Article 603.10  
Staff received an e-mail from Chief Robert Olmstead with the Arizona Fire Medical Authority 
regarding the proposed regulation for Battey Energy Storage Systems (BESS).  Chief Olmstead 
commented that the AFMA is supportive of the regulation as proposed with the 100’/500’ 
setback as shown in MCZO Update Draft #2.  
 
Chief Olmstead indicates that all 10 completed BESS facilities in the AFMA area are using the 
100’ BESS cabinet setback from property lines with one site that has a 400’ and 470’ setback from 
BESS cabinets to residential homes,  all other sites include a setback of more than 500’. Attached 
with the e-mail includes the 2018 IFC – AMA Local Amendments and AFMA BESS Permitting 
Guide dated November 2025. 
 
MCZO Update – Chapter 3 – Article 305.6 
Staff received an e-mail from Andrew Yancy with Bergin, Frakes, Smalley & Oberholtzer, PLLC with 
recommendations to the Plan of Development (POD) expiration and solar project perimeter 
treatment. The e-mail states the language matches up to the City of Buckeye regulations which 
were recently approved.  The request is for the POD to change the 2 years timeframe to 3 years, 
unless otherwise stated in the POD approval. The request also states prior to expiration the 
applicant can file unlimited requests for a 1 year time extension to be authorized by the Planning 
& Development Director.  
 
• 
Staff notes this language does not impact only solar projects, but all Plan of Development 
projects which includes a requirement for a POD with multi-family, commercial, industrial 
and high noise accident potential zoned properties.  
 
The second request is associated with Solar Project perimeter treatment to include a new 
subsection. The draft language would allow alternative uses for wall, buffer and landscaping for 
utility-scale solar generation, BESS or other renewable energy systems based upon the use low 
visibility from public view and remote location.  
 
• 
Staff notes, typically these type of projects require a zone change with overlay to Industrial 
and thus the perimeter treatment is typically requested as part of the IUPD.

Staff received a request from Rhonda Buss with the Arizona State Land Department regarding 
various section of the MCZO update. Staff responded to address the comments and 
questions.  
 
 
Attachments: 
 
Arizona Fire Medical Authority comments (34 pages) 
 
 
 
Andrew Yancy comments (3 pages)  
 
 
 
Arizona State Land Department comments (3 pages)

This Message Is From an External Sender
This message came from outside your organization. Please use caution when corresponding outside the
county.
From:
Robert Olmstead
To:
Mark Sipes (PND); kenneth.diamond@ruralmetrofire.net; jmcmenemy@hfdaz.org
Cc:
Rachel Applegate (PND)
Subject:
Re: [EXTERNAL:] MCZO Update - BESS Facilities - Emergency Fire Evaluation
Date:
Tuesday, November 4, 2025 4:03:54 PM
Attachments:
image001.png
Outlook-31y0ovmz.png
2018 IFC - AFMA Local Amendments.pdf
AFMA BESS Permitting - Novemer 2025.pdf
Mark,
Thank you for the opportunity to comment.  The Arizona Fire & Medical Authority is
supportive of a 100'/500' setback.  All ten of the completed BESS facilities in AFMA's
area are utilizing a 100' BESS cabinet setback from the property line in order to achieve a
remote installation under the code and alleviate the requirement for a suppression
system.  We have one installation near the APS Westwing substation that has five homes
that are between 400' and 470' of setback from the BESS cabinet, but all others have a
setback of more than 500'.
North County and South County fire & medical districts have additional code
requirements in our local amendments that are derived from both NFPA 855 and IFC
2018 Chapter 12.  The Buckeye Valley fire & medical district does not have an adopted
code and defers to the state fire code.
I am attaching both our local amendments as well as the BESS guidance document we
share with development teams in order to clarify our requirements for a BESS project.  If
you have any additional questions or I can provide any clarification, please let me know.
Best Regards,
Robert Olmstead

This message is intended only for the named recipient(s). If you are not the intended recipient(s), you are
notified that the dissemination, distribution or copying of this message is strictly prohibited. If you receive
this message in error, or are not the named recipient(s), please notify the sender either at the above e-mail
address or telephone the Arizona Fire & Medical Authority (AFMA) at (623) 544-5400. Thank You.
To ensure compliance with Arizona's open meeting laws, members of the North County, South County
and/or Arizona Fire & Medical Authority's Board of Directors who have received this message may reply
directly to the sender but must not correspond with or send a copy of their reply regarding this message to
any other members of their respective Board(s). Recipients of this message who are not Board members
must not forward this message to any of the North County, South County or AFMA Board Members.
 
From: Mark Sipes (PND) <Mark.Sipes@maricopa.gov>
Sent: Tuesday, November 4, 2025 8:33 AM
To: Robert Olmstead <Rolmstead@AFMA.Az.gov>; kenneth.diamond@ruralmetrofire.net
<kenneth.diamond@ruralmetrofire.net>; jmcmenemy@hfdaz.org <jmcmenemy@hfdaz.org>
Cc: Rachel Applegate (PND) <Rachel.Applegate@Maricopa.Gov>
Subject: [EXTERNAL:] MCZO Update - BESS Facilities - Emergency Fire Evaluation
 
 WARNING: This email originated from outside of AFMA. DO NOT respond, click links or open attachments unless
you can verify this outside sender and trust that the content is safe.
Good Morning Chiefs,
 
I am forwarding the following message from our Planning Supervisor regarding BESS
facilities soliciting feedback related to separation distances.  There are thousands of
acres or solar and BESS facilities located in the County. Some are several miles away
from residential properties while others are located adjacent to them. I am sending this
email to you three since the majority of the BESS facilities that Maricopa County has
entitled and permitted are located in your fire districts. If you believe that another fire
district should be included, please forward this to their fire marshal and copy Rachel and
me.

As additional information, Maricopa County did not adopt NFPA 855 when we adopted
the 2018 I-codes. We direct the applicants for BESS facilities to the FAHJ.
 
Thank you in advance for your prompt responses as Rachel has a presentation
scheduled for Thursday 6 November and would like to include your feedback for
reference.
 
We currently are working on the Maricopa County Zoning Ordinance update and
are requesting your evaluation and analysis on Battery Energy Storage System
(BESS) facilities. As part of the update to the Ordinance we have included BESS
as new emerging technology with a recommendation to establish safety
regulations for BESS facilities to include a 100’ from all lot lines and 500’
minimum separation from battery enclosures from residential structures.
 
As part of this process for public input we have received several comments from
energy generation industry representatives regarding the inclusion of setback and
separation distance from residential uses.
 
Historically, Planning and Development has been including the 100’ setback from
lot lines and 500’ distance from existing residential uses with proposed BESS
facilities as part of the zone change with overlay as conditions of approval. 
Planning & Development as part of entitlement review started evaluating the
battery structures with a minimum setback of 100’ from lot lines to isolate the
structure for emergency firefighting staging and refuge area. The 500’ separation
is for life safety issues with potential toxic fumes and noxious/poisonous fumes
in the event of a fire can dissipate in the air prior to reaching residential sites.
Planning & Development will refer to the regulatory fire agency for
review/comment with these applications. 
 
We like to receive your thoughts or comments on the Maricopa County Zoning
Ordinance Update – Draft version 1 with your expertise and safety standards
regarding the proposed 100’ and 500’ minimum separation.
 
You are welcome to comment on the MCZO Update – Draft Version 1 – BESS is
listed in the Definition section (Chapter 2, page 3) and located within Chapter 6 –
use Table (Chapter 6, page 27). We are also working with the consultant to update
the language for version 2 of the Ordinance to include the following language:
 
603.10.  - Battery Energy Storage Systems  - Include the distancing of

100' from all lot lines and 500' minimum separation for battery enclosures
from residential structures.
 
We currently have the public comment period open until 10/17 on our website to
comment on version 1, but you are welcome to provide input/comment or share
with other fire district representatives. We are planning on taking version 2 of the
Ordinance to the November 6th Planning & Zoning Commission.
 
If you could provide us your feedback and input, that will assist in evaluating the
setback and separation for emergency response as part of the draft language to
present to the Planning & Zoning Commission and Board of Supervisors.
 
Thank you in advance for your assistance. Please feel free to contact me if you
have any questions. 
 
Rachel Applegate
Planning Supervisor
Planning & Development
301 W. Jefferson St. Suite 170 Phoenix, AZ 85003
O: 602-372-0318
[ Maricopa.Gov ]
Facebook | Instagram | Twitter | YouTube | LinkedIn
 
 
Respectfully,
 
Mark Sipes. PE, SE, CBO
Chief Building Official
Planning & Development
301 W. Jefferson Ave., Suite 170 Phoenix, AZ 85003
O: 602-506-7145
E: mark.sipes@maricopa.gov
[ Maricopa.Gov ]
Facebook | Instagram | Twitter | YouTube |LinkedIn
 
Maricopa County is developing the Framework 2040 Comprehensive Plan – a document which guides growth and
development for the next decade and beyond.  Visit Framework 2040 to learn how to participate, attend meetings and be
heard!
 
Additionally, the Maricopa County Zoning Ordinance is being updated. Visit MCZO Update to learn more and comment on
changes to the ordinance.

ARIZONA FIRE & MEDICAL AUTHORITY 
 
2018 International Fire Code  
Adoption with Amendments 
 
Effective September 22, 2020

Arizona Fire & Medical Authority 
The Governing Boards of the North County Fire & Medical District and South County Fire & Medical District 
approved the adoption of an Intergovernmental Agreement forming the first Fire & Medical Authority in 
Maricopa County, Arizona. The new Arizona Fire & Medical Authority (Authority) was established pursuant 
to Arizona Revised Statutes governing a Joint Powers Authority (JPA). 
 
The Authority covers more than 275 square miles and proudly serves over 75,000 residents within the 
communities of Coldwater Ranch, Corte Bella, Cross River, Dos Rios, Pinnacle Peak County Island, Rancho 
Cabrillo, Rancho Silverado, Rio Sierra, Sun City West, Sun Lakes, Sundero, Tonopah, Wittmann and many 
other areas of Maricopa County. 
 
 
2018 International Fire Code Adoption and Amendments 
 
The International Fire Code (IFC) 2018 Edition is hereby adopted by the Arizona Fire & Medical Authority 
(Authority) Governing Board for the purpose of establishing minimum requirements consistent with 
nationally recognized good practice for providing a reasonable level of life safety protection from the 
hazards of fire, explosion or dangerous conditions in new and existing buildings, structures, and premises. 
  
The International Fire Code as adopted and amended herein shall be enforced by the Authority Fire 
Marshal, who shall operate under the supervision of the Authority Fire Chief.  
 
The 2018 edition of the International Fire Code (2018 IFC) along with the Amendments shall be known as 
the “Arizona Fire & Medical Authority Fire Code” or “Authority Fire Code”. 
 
The 2018 International Fire Code is hereby amended by the Authority Governing Board in the following 
respects:

1 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
CHAPTER 1  
ADMINISTRATION 
 
SECTION 101 
SCOPE AND GENERAL REQUIREMENTS 
 
Amend section 101.1 as follows: 
 
[A] 101.1 Title. This regulation shall be known as the 2018 International Fire Code with Arizona 
Fire & Medical Authority Amendments, hereinafter referred to or cited as “this code”, or the 
Arizona Fire & Medical Authority Fire Code.   
 
Delete and replace section 101.2.1 as follows: 
 
[A] 101.2.1 Appendices. The following appendices are adopted and amended as part of this Code 
by the Arizona Fire & Medical Authority (Authority): B, C, D, E, F, I, J as added and/or amended. 
 
Appendix B 
Fire-Flow Requirements for Buildings 
Appendix C 
Fire Hydrant Locations and Distribution 
Appendix D 
Fire Apparatus Access Roads 
Appendix E  
Hazard Categories  
Appendix F  
Hazard Ranking  
Appendix I  
Fire Protection Systems—Noncompliant Conditions 
Appendix J  
Building Information Sign 
 
A. The International Mechanical Code, 2018 Edition, as published and copyrighted by the 
International Code Council, including all appendices. 
 
B. The International Building Code, 2018 Edition, as published and copyrighted by the 
International Code Council, including all appendices. 
 
C. The International Fuel Gas Code, 2018 Edition, as published and copyrighted by the 
International Code Council, including all appendices. 
 
D. The International Residential Code, 2018 Edition, as published and copyrighted by the 
International Code Council, including all appendices. 
 
E. The most recent Edition of the National Fire Codes and Standards published by the National 
Fire Protection Association (NFPA), and the most recent edition of the NFPA Life Safety Code.

2 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
SECTION 104 
GENERAL AUTHORITY AND RESPONSIBILITY 
 
Section 104.1.1 is hereby added as follows: 
 
104.1.1 Assuming Jurisdiction of Fire Prevention Standards. Pursuant to A.R.S. §48.805.B 4; 
Enforce the fire code adopted by the district, if any, and assist the office of the state fire 
marshal in the enforcement of fire protection standards of this state within the fire district 
including enforcement of a nationally recognized fire code if expressly authorized by the Office 
of the State Fire Marshal. 
 
Section 104.10 is hereby deleted and replaced with the following language: 
 
104.10 Fire Investigations. The Authority shall investigate or cause to be investigated the origin, 
cause and circumstance of each and every fire within the Authority and coming to the Authority’s 
attention.  If the fire appears to the Fire Investigator that such fire is of suspicious origin, the Fire 
Investigator shall notify the appropriate law enforcement agency and shall secure the site until 
the law enforcement agency takes control of the site. Information relating to trade secrets or 
processes shall not be made part of the public record unless directed by a court of law. 
 
SECTION 105 
PERMITS 
 
Amend Section 105.6.2 as follows: 
 
Section 105.6.2 Amusement Building is amended as follows: 
 
Amusement building and events.  An operational permit is required for any amusement building or 
event. 
 
SECTION 106 
FEES 
 
Add Section 106.7 as follows: 
 
106.7 Operational Permit and Licensure Permit Fees.  The Fire Chief or his or her designee shall 
charge an Operational Permit Fee or Licensure Permit Fee for each fire code compliance 
inspection relating to the issuance of the permit.  The fee amount shall be in accordance with the 
fee schedule established by Governing Board Resolution. The type of permit will be based on the 
type of occupancy classification.

3 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
SECTION 107 
INSPECTIONS 
 
Add Section 107.5 as follows: 
 
107.5 Reinspection. A reinspection fee may be assessed for each permitted inspection or 
reinspection when such portion of work for which inspection is called, is not complete or when 
corrections called for are not made. If the items that were identified during the first reinspection 
of a particular phase are not corrected at the time of the reinspection, the permit will be locked 
out and further inspections will not be scheduled until a reinspection fee is paid. Reinspection 
fees may also be assessed when: 
 
1. The permit is not posted or otherwise available on the work site. 
2. The approved plans are not readily available to the inspector. 
3. Access to the site is not provided on the date for which the inspection is scheduled. 
4. A competent responsible party representative is not on-site at time of inspection. 
5. Significant deviations from the approved plans are found that have not been approved by 
the fire code official.  
6. The correct address is not provided so that an inspection can be made as scheduled.  
 
Each reinspection will be assessed this fee. This procedure will be repeated on each phase of the 
installation and inspection process.  
 
 
SECTION 109 
BOARD OF APPEALS 
 
Amend Section 109.1 as follows: 
 
[A] 109.1 Appeals. Whenever an applicant disputes the application or interpretation of this Code 
by Authority staff, a written appeal may be filed with the Authority Fire Chief within 14 calendar 
days.   
 
1. The appeal will be heard by the fire chief or an authorized representative within 10 
working days of the receipt of the appeal. 
2. Adequate information shall be provided by the applicant on the Petition of Appeal to fully 
describe the condition(s) in question. 
3. The fire chief shall consult with the fire code official, and/or an authorized representative 
as deemed appropriate, to provide additional information regarding the appeal. 
4. The applicant may, but is not required to, meet with the fire chief or a designated 
representative to discuss the appeal.

4 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
5. If the appeal is denied, the applicant shall comply with the requirement(s) of the fire code 
or file an appeal with the Authority Governing Board within 30 calendar days from the 
date the appeal was denied. 
 
 
 
SECTION 110 
VIOLATIONS 
 
Section 110.4 hereby is deleted and replaced with the following language: 
 
110.4 Violation Penalties.  Persons who shall violate a provision of this Code or shall fail to comply 
with any of the requirements thereof or who shall erect, install, alter, repair or do work in 
violation of the approved construction documents or directive of the fire code official, or of a 
permit or certificate used under provisions of this Code, shall be guilty of a Class 1 misdemeanor 
punishable by a fine of not more than $2,500.00 dollars or by imprisonment not exceeding six 
months, or both such fine and imprisonment. Such fine and imprisonment shall be at the 
discretion of the court.  Each day that a violation continues after due notice has been served shall 
be deemed a separate offense. 
 
 
SECTION 112 
STOP WORK ORDER 
 
Amend Section 112.4 as follows: 
 
112.4 Failure to Comply Any person who shall continue any work after having been served with 
a stop-work order, except only such work that person was directed to perform to remove a 
violation or unsafe condition, shall be liable to a fine of not less than $500.00 dollars or more than 
$2,500.00 dollars.  
 
CHAPTER 5 
FIRE SERVICE FEATURES 
 
SECTION 503 
FIRE APPARATUS ACCESS ROADS 
 
Section 503.4 hereby is deleted and replaced with the following language:

5 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
503.4 Obstruction of fire apparatus access roads.  Excluding authorized emergency vehicles, fire 
apparatus access roads shall not be obstructed in any manner, including the parking of vehicles.  
The minimum widths and clearances established by Section 503.2.1 through 503.2.8 shall be 
maintained at all times.   
  
 
SECTION 505 
FIRE APPARATUS ACCESS ROADS 
 
Amend Section 505.1 as follows: 
 
Section 505.1 Address identification is amended as follows: 
 
New and existing buildings shall have approved address numbers, building numbers or building 
identification placed in a position that is plainly legible and visible from the street or road fronting 
the property.  These numbers shall contrast with their background. Where required by the fire code 
official, address numbers shall be provided in additional approved locations to facilitate emergency 
response. Address numbers shall be numbers or alphabetical letters. Numbers shall be a minimum 
of 6 inches high with a minimum stroke width of 0.5 inches. Address numbers should be 
proportionate to building size, and larger numbers may be required by the fire code official to 
facilitate emergency response. 
 
SECTION 506 
KEY BOXES 
 
Section 506.1.3 is hereby added as follows: 
 
506.1.3 Key Boxes. The lock box, must be an approved model utilized by the Authority and shall 
be installed 30” to 60” above finished grade. Authorized lock box order forms are available at the 
Authority’s Administrative Office during normal business hours. 
 
 
SECTION 507 
FIRE PROTECTION WATER SUPPLIES 
 
Amend Section 507.1 as follows:  
 
Section 507.1 Required Water Supply. Is amended by adding the following: 
 
In areas where municipal or private water supply is not available, NFPA 1142 Standard on Water 
Supplies for Suburban and Rural Fire Fighting, may be utilized to calculate required fire flows.

6 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
 
CHAPTER 9 
FIRE PROTECTION AND LIFE SAFETY SYSTEMS 
 
SECTION 901 
GENERAL 
 
Amend Section 901.2 as follows: 
 
Section 901.2 Construction Documents is amended by adding the following: 
 
Automatic sprinkler system plans shall be submitted bearing a review certification and signature 
of a minimum level III NICET Certified Engineering Technician or Engineer’s stamp. Fire sprinkler 
plans for high-piled combustible storage occupancies shall require a registered fire protection 
engineer stamp.  Fire alarm system plans shall be submitted bearing a review certification and 
signature of a minimum level III NICET Technician or Arizona registrant.  
 
 
Amend Section 901.6.3 as follows: 
 
Section 901.6.3 Records is amended to read as follows: 
 
Records of all system inspections, tests, and maintenance required by the referenced standards 
shall be maintained, and reports of system deficiencies shall be forwarded to the authority having 
jurisdiction.  
 
Add Section 901.11 as follows: 
901.11 Clearance Around Fire-Protection Systems and Equipment. A minimum 3-foot (92 cm) 
clear space shall be maintained for access to fire protection equipment, including control valves 
and control panels, when fire protection equipment is not located within a dedicated room.

7 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
SECTION 903 
AUTOMATIC SPRINKLER SYSTEMS 
 
Section 903.2, delete and replace with the following language: 
 
Section 903.2 Where Required.  All new commercial occupancies, as defined by the International 
Building Code, for which a building or construction permit is obtained, shall be protected 
throughout the entire structure by a fully automatic sprinkler system.  Exception: R-3 occupancies 
less than 5,000 square feet gross or where fire-flow requirements of Appendix B of the 
International Fire Code cannot be attained. Installation of the sprinkler system shall be in 
accordance with the requirements of NFPA 13, unless otherwise approved by the Fire Chief or his 
or her designee. 
 
Existing buildings, structures, and occupancies will not require retrofitting with fire sprinkler 
systems to meet current code standards unless: 
 
1. Building fire resistance has decreased; or 
2. Building area has increased more than 2,500 square feet; or 
3. Building occupant load has increased; or 
4. Fire or other structural damage in buildings exceeds 20% of the square footage; or 
5. Fire or other structural damage in buildings exceeds 20% of the building valuation; or 
6. As determined by the Fire Chief and his or her designee. 
 
 
SECTION 905 
STANDPIPE SYSTEMS 
 
Section 905.3.1, delete and replace with the following language: 
 
905.3.1 Building Height. Class I standpipe systems, as defined in section 902.1 of the International 
Fire Code, 2018 edition, “Standpipe System, Classes of” shall be installed throughout buildings 
where the floor level of the highest story is one floor above the lowest level of fire department 
apparatus access, or where the floor level of the lowest story is one floor below the highest level 
of fire department apparatus access.

8 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
SECTION 907 
FIRE ALARM AND DETECTION SYSTEMS 
 
Section 907.2, delete and replace with the following language: 
 
Section 907.2 Where Required – New Buildings and Structures.  All new commercial occupancies 
(any structure other than one- and two-family dwelling) for which a building or construction 
permit is obtained shall be protected throughout the entire structure by a fully automatic fire 
alarm system. Installation of the fire alarm system shall be in accordance with the requirements 
of NFPA 72, unless otherwise approved by the Fire Chief or his or her designee. All fire alarms 
shall be addressable systems with Class “A” wiring. An approved fully automatic fire detection 
system shall be installed in accordance with the provisions of this Code and with NFPA 72.  
Monitoring shall be by a central station as defined by NFPA 72 Section 3.3.193.1. Devices, 
combinations of devices, appliances, and equipment shall comply with Section 907.1.2. The 
automatic fire detectors shall be smoke detectors, except that an approved alternative type of 
detectors shall be installed in spaces such as boiler rooms, utility rooms and janitor closets with 
water heater and sink, where, during normal operation, products of combustion are present in 
sufficient quantity to actuate a smoke detector. 
 
SECTION 912 
FIRE DEPARTMENT CONNECTIONS 
 
Section 912.2, delete and replace with the following language: 
 
912.2 Location.  With respect to hydrants, driveways, buildings, and landscaping, fire department 
connections shall be so located that fire apparatus and hose connected to supply the system will 
not obstruct access to the buildings for other fire apparatus. The location of the fire department 
connections shall be remote from the building and 36” above grade. Additionally, the fire 
department connection shall be located no closer than 30 feet or not further than 70 feet from a 
hydrant.

9 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
CHAPTER 12 
ENERGY SYSTEMS 
 
SECTION 1201 
SCOPE 
 
Amend Section 1201.1 as follows: 
 
1201.1 Scope. The provisions of this Chapter shall apply to the installation, operation, and 
maintenance of energy systems used for generating or storing energy 
 
SECTION 1203 
EMERGENCY AND STANDBY POWER SYSTEMS 
 
Amend Section 1203.1.1 as follows:  
 
1203.1.1 Stationary Generators. Stationary emergency and standby power generators required 
by this Code shall be listed in accordance with UL 2200. Associated flammable or combustible 
liquid tanks shall also comply with IFC Chapters 50 and 57. 
 
SECTION 1204 
SOLAR PHOTOVOLTAIC POWER SYSTEMS 
 
Add Sections 1204.1.1 through 1204.1.3 as follows: 
 
1204.1.1 Permits. Permits shall be obtained for solar voltaic systems in accordance with Section 
105.7.21  
 
Exception: Solar photovoltaic systems with less than 3 Kw alternating current nameplate 
rating.   
 
1204.1.2 Marking. Marking is required on the interior and exterior direct-current (DC) conduit, 
enclosures, race- ways, cable assemblies, junction boxes, combiner boxes, and disconnects. 
 
1204.1.2.1 Materials. The materials used for marking shall be reflective, weather-resistant, and 
suitable for the environment. Marking as required in Sections 1204.1.2 through 1204.1.6 shall 
have all letters capitalized with a minimum height of 3/8 inch (9.5 mm) white on red background. 
 
1204.1.2.2 Marking Content. The marking shall contain the words “WARNING: PHOTOVOLTAIC 
POWER SOURCE.”

10 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
1204.1.2.3 Main Service Disconnect. The marking shall be placed adjacent to the main service 
disconnect in a location clearly visible from the location where the disconnect is operated. 
 
1204.1.3 Location of Marking. Marking shall be placed on interior and exterior DC conduit, 
raceways, enclosures and cable assemblies every 10 feet (3,048 mm), within 1 foot (305 mm) of 
turns or bends and within 1 foot (305 mm) above and below penetrations of roof/ceiling 
assemblies, walls or barriers. 
 
Amend Section 1204.2 as follows:  
 
1204.2 Access and Pathways. Roof access, pathways, and spacing requirements shall be provided 
in accordance with Sections 1204.2.1 through 1204.3.3. Pathways shall be over areas capable of 
supporting firefighters accessing the roof. Pathways shall be located in areas with minimal 
obstructions, such as vent pipes, conduit or mechanical equipment. Residential structures shall 
be designed so that each photovoltaic array is not greater than 150 feet (45,720 mm) by 150 feet 
(45,720 mm) in either axis. 
 
Section 1204.2.1, delete and replace with the following language: 
 
1204.2.1 Solar Photovoltaic Systems for Group R-3 Buildings. Solar photovoltaic systems for 
Group R-3 buildings shall comply with Sections 1204.2.1.1 through 1204.2.1.5. 
 
 
1204.2.1.1 Roof Access Points. Roof access points shall be located in areas that do not require 
the placement of ground ladders over openings such as windows or doors and located at strong 
points of building construction in locations where the access point does not conflict with 
overhead obstructions such as tree limbs, wires, or signs. 
 
1204.2.1.2 Residential Buildings with Hip Roof Layouts. Panels or modules installed on 
residential buildings with hip roof layouts shall be located in a manner that provides two 3-foot-
wide (914 mm) clear access pathway from the eave to the ridge on each roof slope where panels 
or modules are located.  
 
1204.2.1.3 Residential Buildings with a Single Ridge. Panels/modules installed on residential 
buildings with a single ridge shall be located in a manner that provides two 3-foot-wide (914 mm) 
access pathways from the eave to the ridge on each roof slope where panels/modules are 
located. 
 
1204.2.1.4 Residential Buildings with Roof Hips and Valleys. Panels or modules installed on 
residential buildings with roof hips and valleys shall be located not closer than 18 inches (457 
mm) to a hip or a valley where panels or modules are to be placed on both sides of a hip or valley. 
Where panels are to be located on only one side of a hip or valley that is of equal length, the 
panels shall be permitted to be placed directly adjacent to the hip or valley.

11 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
1204.2.1.5 Residential Building Smoke Ventilation. Panels/modules installed on residential 
buildings shall be located no higher than 3 feet (914 mm) below the ridge in order to allow for 
fire department smoke ventilation operations. 
 
Amend Section 1204.3 as follows:  
 
1204.3 Other Than Group R-3 Buildings. Access to systems for buildings, other than those 
containing Group R-3 occupancies, shall be provided in accordance with Sections 1204.3.1 
through 1204.3.3. 
 
Exception: Where it is determined by the fire code official that the roof configuration is similar 
to that of a Group R-3 occupancy, the residential access and ventilation requirements in 
Sections 1204.2.1.1 through 1204.2.1.5 are a suitable alternative. 
 
Amend Section 1204.3.2 as follows:  
 
1204.3.2 Interior Pathways. Interior pathways shall be provided between array sections to meet 
the following requirements: 
 
1. Pathways shall be provided at intervals not greater than 150 feet (45,720 mm) throughout 
the length and width of the roof. 
2. A pathway not less than 4 feet (1,219 mm) wide in a straight line to roof standpipes or 
ventilation hatches. 
3. A pathway not less than 4 feet (1,219 mm) wide around roof access hatches, with no fewer 
than one such pathway to a parapet or roof edge. 
4. The pathway shall be over areas capable of supporting the live load of firefighters accessing 
the roof. 
5. The centerline axis pathways shall be provided in both axes of the roof. Centerline axis 
pathways shall run where the roof structure is capable of supporting the live load of 
firefighters accessing the roof. 
 
Amend Section 1204.3.3 as follows: 
 
1204.3.3 Smoke Ventilation. The solar installation shall be designed to meet the following 
requirements:  
 
3. Arrays shall be not greater than 150 feet (45 720 mm) by 150 feet (45 720 mm) in the distance 
in either axis in order to create opportunities for fire department smoke ventilation operations.

12 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
SECTION 1206 
ELECTRICAL ENERGY STORAGE SYSTEMS 
 
Amend Section 1206.2 as follows:  
 
1206.2 Stationary Storage Battery Systems. Stationary storage battery systems having capacities 
exceeding the values shown in Table 1206.2 shall comply with Section 1206.2.1 through 
1206.2.13.6, as applicable. Approved signage is required for all installations.  
 
Amend Section 1206.2.1 as follows:  
 
1206.2.1 Permits. Permits shall be obtained for the construction of stationary storage battery 
systems with a capacity of 3 kWh or more, in accordance with Section 105.7.2. 
 
Amend Section 1206.2.3 as follows: 
 
1206.2.3 Hazard Mitigation Analysis. A failure modes and effects analysis (FMEA) or other 
approved hazard mitigation analysis shall be provided in accordance with Section 104.7.2 under 
any of the following conditions. 
 
4. Where required by the fire code official. 
 
Amend Section 1206.2.3.1 as follows: 
 
1206.2.3.1 Fault Condition. The hazard mitigation analysis shall evaluate the consequences of 
the following modes, and others deemed necessary by the fire code official. Only single failure 
modes shall be considered.  
 
 
8. Failure of temperature control.  
 
Amend Section 1206.2.8.3 as follows: 
 
1206.2.8.3 Stationary Battery Arrays. Storage batteries, prepackaged stationary storage battery 
systems and pre-engineered stationary storage battery systems shall be segregated into stationary 
battery arrays not exceeding 50 kWh (180 megajoules) each. Each stationary battery array shall be 
spaced not less than 3 feet (914 mm) from other stationary battery arrays and from walls in the 
storage room or area. The storage arrangements shall comply with Chapter 10. 
 
2. Listed pre-engineered stationary storage battery systems and prepackaged stationary storage 
battery systems shall not exceed 250 kWh (900 megajoules) each, where approved by the fire 
code official.

13 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
Amend Section 1206.2.8.7.1 as follows: 
 
1206.2.8.7.1 Separation. Stationary storage battery systems located outdoors shall be 
separated by a minimum of 10 feet (3,048 mm) from the following: 
 
Amend Section 1206.2.8.7.2 as follows: 
 
1206.2.8.2 Separation. Rooms containing stationary storage battery systems shall be separated 
from other areas of the building in accordance with Section 509.1 of the International Building 
Code. Battery systems shall be allowed to be in the same room with the equipment they 
support. 
 
TABLE 1206.2.8.7 OUTDOOR INSTALLATIONS 
Compliance Required 
Remote Installations 
Installations 
Near Exposures  
General Installation 
Requirements 
Yes 
Yes 
Size and separation 
No 
Yes a 
Smoke and automatic fire 
detection  
Yes 
Yes 
Fire suppression systems 
Yes b 
Yes 
Maximum enclosure size 
Yes 
Yes 
Vegetation control 
Yes 
Yes 
Means of egress 
separation 
Yes 
Yes 
Clearance to exposures 
Yes 
Yes 
Technology specific 
protection 
Yes 
Yes 
  
a. In outdoor walk-in units, spacing is not required between energy storage systems units and the walls of the enclosure.  
b. Where approved by the fire code official, fire suppression systems are permitted to be omitted. 
 
  
Amend Section 1206.2.11.3 as follows:  
 
1206.2.11.3 Exhaust Ventilation. Where required by Table 1206.2.10, ventilation of rooms 
containing stationary storage battery systems shall be provided in accordance with the 
International Mechanical Code and one of the following:

14 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
1. The ventilation system shall be designed to limit the maximum concentration of flammable gas 
to 10 percent of the lower flammability limit, or for hydrogen, 1.0 percent of the total volume 
of the room. 
2.  Continuous ventilation shall be provided at a rate of not less than 1 cubic foot per minute (cfm) 
per square foot [0.00508 m3/(s • m2)] of floor area, but not less than 150 cfm (4 m3/min). The 
exhaust system shall be designed to provide air movement across all parts of the floor for gases 
having a vapor density greater than air and across all parts of the vaulted ceiling for gases having 
a vapor density less than air.  
 
TABLE 1206.2.10 BATTERY TECHNOLOGY SPECIFIC 
Compliance Required b 
Battery Technology 
Other Battery Storage Systems 
and Battery Technologies b 
 
Lead-
acid 
Ni-Cad & Ni-
MH 
Lithium-ion 
Flow 
 
Exhaust ventilation 
Yes 
Yes 
Yes 
Yes 
Yes 
Spill control and neutralization 
Yes c 
Yes c 
No 
Yes 
Yes 
Explosion control 
Yes a 
Yes a 
Yes 
Yes 
Yes 
Safety Caps 
Yes 
Yes 
No 
Yes 
Yes 
Thermal runaway 
Yes d 
Yes 
Yes e 
Yes 
Yes e 
a. 
Not required for lead-acid and nickel cadmium batteries at facilities under the exclusive control of communications utilities 
that comply with NFPA 76 and operate at less than 50 VAC and 60 VDC.  
b. 
Protection shall be provided unless documentation acceptable to the fire code official is provided in accordance with 2018 
International Fire Code Section 104.7.2 that provides justification why the protection is not necessary based on the technology 
used.  
c. 
Applicable to vented (i.e. flooded) type nickel cadmium and lead acid batteries.  
d. 
Not required for vented (i.e. flooded) type lead acid batteries.  
e. 
The thermal runaway protection is permitted to be part of a battery management system that has been evaluated with the 
battery as part of the evaluation to UL 1973. 
 
 
Add Section 1206.4 as follows: 
 
1206.4 Energy Storage System in Group R-3 and R-4 Occupancies. Energy storage systems in Group 
R-3 and R-4 occupancies shall be installed and maintained in accordance with this section. The 
temporary use of an owner or occupant's electric-powered vehicle as an energy storage system 
shall be in accordance with this section. 
 
Exception: Energy storage systems in Group R-3 and R-4 occupancies with a capacity of 3 kWh 
or less.

15 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
Add Section 1206.4.3 as follows:  
1206.4.3 Location. Energy storage systems shall only be installed in the following locations: 
 
1. Detached garages and detached accessory structures. 
2. Attached garages separated from the dwelling unit living space and sleeping units in accordance 
with Section 406.3.2 of the International Building Code. 
3. Outdoors on exterior walls in accordance with IFC 1206.4.3.1 
4. Other locations with fire code official approval. 
 
Add Section 1206.4.3.1 as follows: 
 
1206.4.3.1 Exterior Wall and Outdoor Installations.  Energy storage systems shall be permitted to 
be installed outdoors on exterior walls of buildings or on the ground where all of the following 
conditions are met: 
 
1. The maximum energy capacity of individual energy storage system units shall not exceed 20 
kWh. 
2. The installation is in accordance with zoning setback requirements. 
3. The energy storage system shall be installed in accordance with the manufacturer's instructions 
and their listing. 
4. Individual energy storage system units shall be separated from each other by not less than 3 
feet (914 mm). 
5. The energy storage system shall be separated from doors, windows, operable openings into 
buildings, or HVAC inlets by at least 5 feet (1,524 mm). 
 
Exception: Where approved by the fire code official, smaller separation distances in Items 4 and 
5 may be permitted based on large scale fire testing

16 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
Add Sections 1206.4.4 through 1206.4.9 as follows: 
 
1206.4.4 Energy Ratings. Individual energy storage systems units shall have a maximum rating of 
20 kWh. The aggregate rating structure shall not exceed:  
 
1. 80 kWh on exterior walls. 
2. 80 kWh outdoors on the ground. 
 
1206.4.5 Electrical installation. Energy storage system shall be installed in accordance with NFPA 
70. Inverters shall be listed and labeled in accordance with UL 1741 or provided as part of the UL 
9540 listing. Systems connected to the utility grid shall use inverters listed for utility interaction. 
 
 
1206.4.6 Fire Detection. Rooms and areas within dwellings units, sleeping units and attached 
garages in which energy storage systems are installed shall be protected by smoke alarms in 
accordance with Section 907.2.10. A heat detector listed and interconnected to the smoke alarms 
shall be installed in locations within dwelling units, sleeping units and attached garages where 
smoke alarms cannot be installed based on their listing. 
 
1206.4.7 Protection From Impact. Stationary storage battery systems installed in a location subject 
to vehicle damage shall be protected by approved barriers. Appliances in garages shall also be 
installed in accordance with Section 304.3 of the International Mechanical Code. 
 
1206.4.8 Ventilation. Indoor installations of energy storage systems that include batteries that 
produce hydrogen or other flammable gases during charging shall be provided with ventilation in 
accordance with Section 1206.2.11.3. 
 
1206.4.9 Toxic and Highly Toxic Gas.  Energy storage systems that have the potential to release 
toxic or highly toxic gas during charging, discharging and normal use conditions shall not be installed 
within Group R-3 or R-4 occupancies. 
 
  
 
CHAPTER 33 
FIRE SAFETY DURING CONSTRUCTION AND DEMOLITION 
 
Section 3310.1.1 is hereby added as follows: 
 
Section 3310.1.1 Access Road Signs.  During construction, approved signs shall be erected and 
located to direct emergency responders into and through the construction site.

17 
 
 
 
2018 International Fire Code Amendments 
Adopted September 22, 2020 
Authority Resolution No. AF20-0922-1 
APPENDIX B 
FIRE-FLOW REQUIREMENTS FOR BUILDINGS 
 
SECTION B105 
FIRE-FLOW REQUIREMENTS FOR BUILDINGS 
 
Amend Section B105.1 (2) as follows: 
 
Table B105.1 (2) REFERENCE TABLE is amended by adding Footnote “C” as follows: 
Footnote C: In special circumstances, where the municipal or rural water supply will not provide 
the required 1,500 gpm, the fire code official may accept a lesser amount.  
 
APPENDIX D 
FIRE APPARATUS ACCESS ROADS 
 
SECTION D103 
MINIMUM SPECIFICATIONS 
 
 
Appendix D, Section D103.6.1.1 is hereby added as follows: 
 
D103.6.1.1 Fire Lane.  In addition to Section D103.6 Signs, Fire Lane curbs may be painted red in 
color on the top and outward face of the curb and shall be marked with the words “NO PARKING 
– FIRE LANE” in 4-inch white block letters on the top and vertical face of the curb spaced every 
30 feet on center, when approved by the fire code official.

ARIZONA FIRE & MEDICAL AUTHORITY 
Protecting life and property and enhancing the well-being of all those we serve 
 
 
 
 
18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
Arizona Fire & Medical Authority (AFMA) Utility-Scale 
Battery Energy Storage System (BESS) Permitting Guide 
SECTION 1: Introduction and Regulatory Framework 
 
1.1 Purpose, Applicability, and Scope 
This document provides comprehensive, mandatory guidance for the permitting, installation, operation, 
and eventual decommissioning of utility-scale Battery Energy Storage System (BESS) installations within 
the jurisdiction of the Arizona Fire & Medical Authority (AFMA). This guidance integrates requirements 
from multiple state and national sources to establish a single, authoritative reference for project 
managers and construction teams. These requirements apply to all stationary BESS installations 
exceeding 20 kWh of aggregate energy capacity. 
 
1.2 Applicable Codes and Standards 
All installations SHALL comply with the following minimum standards. Where conflicts exist between 
these documents or with local amendments, the most stringent requirement, as determined by the Fire 
Code Official (AHJ), SHALL govern: 
● 2018 International Fire Code (IFC), specifically Chapter 12 (Energy Systems), with all local AFMA 
amendments. 
● NFPA 855, Standard for the Installation of Stationary Energy Storage Systems (2023 Edition). 
● NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing (2024 Edition). 
● NFPA 70, National Electrical Code (NEC-2026 Edition). 
● NFPA 1142, Standard on Water Supplies for Suburban and Rural Fire Fighting (2022 Edition). 
 
1.3 Jurisdictional Authority and Equivalence of Safety 
Per IFC 104.7.2, the Fire Code Official is authorized to require reports, investigations, and analyses to 
fully assess and mitigate risks associated with new technologies. For BESS facilities that are under the 
exclusive control of an electric utility, the operator SHALL nonetheless demonstrate, through 
engineering analysis and supporting documentation, that the system provides a level of safety 
equivalent to or exceeding that required by IFC Chapter 12 and NFPA 855. This requires a performance-
based demonstration of compliance.

18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
 
Table 1: Key Regulatory Compliance Checklist (IFC 2018 vs. AFMA Enhanced Standard) 
IFC Section / NFPA 
Requirement 
Compliance Documentation 
Required 
AFMA Standard 
UL 9540A Large-Scale Testing 
Full Test Report (Cell, Module, 
Unit, Installation) 
Mandatory 
HMA and FRA 
FMEA, FRA, and Plume 
Modeling Report 
Mandatory, Enhanced 
Requirements (See Section 3) 
IFC 1203.3 Critical Circuit 
Protection 
Electrical Plan showing 1-hour 
rated survivability 
Mandatory 
NFPA 4 Integrated Testing 
Final Test Plan and Results 
Mandatory Pre-
Commissioning (See Section 7) 
 
SECTION 2: Pre-Construction and Permitting Process 
 
2.1 Initial Discussion and Site Plan Review 
A preliminary meeting with the AFMA Fire Marshal’s Office is a mandatory prerequisite to substantial 
design commitment. The applicant must present the initial site plan, discuss the project scope, and 
specifically identify the selected battery chemistry and the corresponding NFPA 855 technology 
classification. This presentation must also detail the intended use of the UL 9540A testing tiers used to 
justify separation distances and engineered mitigation systems. 
 
2.2 Site plan review elements 
The site plan will be reviewed to evaluate compliance with IFC 2018 and AFMA local amendments.  The 
elements evaluated include, but are not limited to: 
• 
Two means of ingress/egress 
• 
Minimum 20’ road surface width

ARIZONA FIRE & MEDICAL AUTHORITY 
Protecting life and property and enhancing the well-being of all those we serve 
 
 
 
 
18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
• 
Inner and outer radii of turns/corners of road 
• 
Minimum 24’ gate width 
• 
Hydrant placement and spacing in installations with municipal water availability 
• 
Energy cabinet set-backs from O&M building, site boundaries, etc. 
 
2.3 Plan Submittal Requirements 
The following full, stamped plans must be submitted concurrently for initial review and approval: 
● BESS Installation Plans: Detailed site layout, specific dimensions for BESS arrays, ancillary 
equipment, fire apparatus access roads, and detailed separation distances (per IFC 1206.2.8.7). 
● Civil Plans: Plans for site grading, erosion control, and infrastructure (e.g., access roads and pads) 
certified to support the weight of heavy fire apparatus (75,000lb). 
● NFPA 1142 Water Supply Plan: Detailed location, tank specifications, calculated capacity 
justification (Section 6), and pad specifications. 
● Hazard Mitigation Analysis (HMA): Full report as defined in Section 3. 
 
2.4 Deferred Submittals Protocol 
Deferred submittals (items submitted after initial construction permit issuance) SHALL include all design 
criteria, flow calculations, overall system functionality, and performance specifications. Deferred 
submittals may include: 
● Fire Protection Plans: Comprehensive design documents for all fire detection, alarm, and 
suppression systems, demonstrating compliance with the worst-case scenario findings of the 
HMA/FRA. 
● O&M Buildings 
○ If the O&M building is a manufactured building in an above-ground set AFMA requires a 
reporting fire alarm system and will require a plan submittal.  If the building is an in-
ground set of a manufactured building or a slab-on-grade stick built building a fire alarm 
and fire suppression system will be required in both North County and South County 
Fire & Medical districts. 
● NFPA 1142 Tank: specifications, water pump specifications if included.

18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
 
SECTION 3: Hazard Mitigation Analysis (HMA) and Fire Risk Assessment (FRA) 
Requirements 
 
Per IFC 104.7.2 and NFPA 855 Section 4.14, a comprehensive analysis prepared by a qualified third-party 
professional engineer or specialist is mandatory. The HMA SHALL be segmented into two components: 
the Failure Modes and Effects Analysis (FMEA) for equipment and the site-specific Fire Risk Assessment 
(FRA). The HMA must be reviewed and approved prior to the issuance of a permit. 
 
3.1 Documentation and UL 9540A Requirements 
The HMA documentation must define the specific edition of NFPA 855 utilized for the project. 
Furthermore, complete UL 9540A test documentation is required, covering all four testing tiers: cell, 
module, unit, and installation/rack level. This testing validation is critical for justifying all proposed 
safety measures, particularly containment and separation distances. 
 
3.2 Failure Modes Analysis (FMEA) 
The analysis must evaluate the consequences of failure modes as required by IFC 1206.2.3.1, expanded 
to address modern BESS complexities. This includes, but is not limited to: 
● Thermal runaway condition in a single battery, module, or array. 
● Failure of the energy management system or any protection system not covered by the product 
listing FMEA. 
● Failure of required protection systems, including smoke detection, fire-extinguishing systems, gas 
detection, and ventilation. 
● Failure of temperature control systems, such as HVAC or liquid cooling loops. 
● External events such as voltage surges or short circuits on the load side. 
 
3.3 Toxic Gas and Thermal Plume Modeling Requirements  
The consequence analysis MUST include a dispersion modeling report detailing the potential hazards 
associated with toxic and flammable gas releases, with specific focus on Hydrogen Fluoride (HF) and 
Carbon Monoxide (CO), which are characteristic byproducts of Li-ion battery thermal runaway. 
In rural jurisdictions with long response times and limited initial personnel, the period before manual 
intervention or system isolation can occur is extended. If fire response is significantly delayed, the 
duration over which the toxic plume can travel downwind is increased, potentially magnifying the

ARIZONA FIRE & MEDICAL AUTHORITY 
Protecting life and property and enhancing the well-being of all those we serve 
 
 
 
 
18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
impact radius and increasing the risk to remote residential or commercial receptors. To mitigate this 
heightened public risk, AFMA mandates conservative, worst-case dispersion modeling. 
The modeling approach SHALL utilize sequential meteorology data (not just generic stability class) and 
must employ a robust approach (e.g., the 100th percentile or Peak concentration over a minimum 
three-year period) to define the toxic endpoint. The acceptance criteria SHALL explicitly require 
demonstration that IDLH (Immediately Dangerous to Life or Health) or AEGL-3 levels are not reached at 
the nearest identified public receptor (e.g., lot line, residential structure, public way) under these 
worst-case conditions, thereby scientifically justifying the required separation distances and/or 
engineered mitigation systems. 
 
3.4 Analysis Approval Requirements 
The HMA/FRA must demonstrate the following compliance criteria: 
● Fires or explosions SHALL be contained within the cabinet or compartment of origin, validated by 
the relevant UL 9540A testing tier. 
● Toxic and highly toxic gases SHALL NOT reach IDLH levels at the nearest designated public 
exposure. 
● Flammable gases released during normal operation SHALL NOT exceed 25% of the Lower 
Flammable Limit (LFL). 
Table 2: Required HMA Acceptance Criteria for Consequence Modeling 
Hazard Condition 
Acceptance Criteria 
(IFC/NFPA Standard) 
AFMA Enhanced Requirement 
(Rural Focus) 
Fire/Explosion Propagation 
Contained within 
cabinet/compartment of 
origin. 
Demonstrated by UL 9540A 
Unit-Level test. 
Toxic Gas Release (HF, CO) 
Shall not reach IDLH levels 
beyond the isolation zone. 
Modeling SHALL employ 100th 
percentile meteorological

18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
 
conditions to demonstrate 
IDLH levels do not reach the 
nearest public receptor 
(residence, business, public 
way). 
Thermal Flux/Heat Release 
Shall not adversely impact 
adjacent stored materials or 
structures. 
Heat flux modeling SHALL 
demonstrate exposure levels 
below 1.0 kW/m at property 
lines and adjacent structures. 
Flammable Gas Release 
Shall not exceed 25% of LFL 
(Normal operation). 
Continuous ventilation system 
and 24/7/365 gas detection 
monitoring are required. 
 
SECTION 4: Technical Design Requirements for BESS Installations 
 
4.1 General Listing and Critical Circuit Requirements 
All systems must be listed to UL 9540 (System Listing) and all battery modules must be listed to UL 1973 
(Module Listing). Furthermore, any critical electrical circuits required for the survivability of fire 
detection, alarm systems, emergency lighting, or emergency shutdown controls SHALL be protected 
using construction or cables certified to maintain a fire-resistance rating of not less than 1 hour, in strict 
accordance with IFC 1203.3. 
 
4.2 Size, Segregation, and Separation 
To limit the potential energy density of any single fire event, all installations must adhere to strict 
segregation and spacing rules: 
● Storage batteries SHALL be segregated into stationary battery arrays not exceeding 50 kWh each. 
● Each array SHALL be spaced not less than 3’ (914mm) from other arrays and walls. 
● Listed pre-engineered systems may be permitted up to 250 kWh, provided the AHJ grants specific 
approval based on supporting UL 9540A unit-level data demonstrating zero propagation at the 
required separation distance.

ARIZONA FIRE & MEDICAL AUTHORITY 
Protecting life and property and enhancing the well-being of all those we serve 
 
 
 
 
18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
4.3 Outdoor Separation Distances 
For non-remote installations, the BESS must be separated by a minimum of 10’ from lot lines, public 
ways, buildings, stored combustible materials, and other exposure hazards. For installations deemed 
remote, separation distances SHALL be a minimum of 100’. 
Any request for reduction of the prescriptive 10’ separation distance (down to a code-minimum of 3’ 
requires specific justification. The reduction request SHALL be justified by the HMA/FRA, which must 
include large-scale fire and fault condition testing (UL 9540A installation-level data) demonstrating that 
radiant heat flux is maintained below critical levels (e.g., 1.0 Kw/m) at the proposed reduced boundary. 
The burden of proof rests solely with the design team to show that heat exposure will not adversely 
impact adjacent structures. 
 
4.4 Fire Detection and Suppression Systems 
● Detection: Either smoke or heat detection is required. Alarm signals SHALL be transmitted 
immediately to a 24-hour monitoring station. 
● Suppression: A fire suppression system appropriate to the battery technology SHALL be installed 
for non-remote installations. The design of this system SHALL be based on the worst-case scenario 
determined in the HMA. Note that recent standards suggest moving away from non-water-based 
suppression as a primary method for certain high-density technologies, thus any proposal utilizing 
such agents requires exceptional performance documentation. 
● Ventilation: The ventilation system shall be designed to limit the maximum concentration of 
flammable gas to 25 percent of the lower flammability limit, or for hydrogen, 1.0 percent of the 
total volume of the room. IFC 1206.2.11.3. 
 
SECTION 5: Fire Department Access, Operational Safety, and Remote Response 
(Rural Focus) 
5.1 Fire Apparatus Access and Staging 
● Access Roads: Access roads must comply with Appendix D of the 2018 IFC and SHALL be 
constructed to reliably support fire apparatus weighing up to 75,000 lb. 
● Dedicated Staging Area: A dedicated first responder staging area SHALL be provided outside the 
BESS perimeter fence.

18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
 
○  The staging area dimension SHALL be a minimum of 50’ x 100’, and the surface SHALL 
be 95% compacted and capable of supporting 75,000lb 
○ The responder alarm panel SHALL be placed immediately adjacent to this staging area. 
■ The responder alarm cabinet SHALL contain the following documents and 
information to assist responding units; 
■ A map of the project site with labels identifying major site elements 
■ A detailed step-by-step explanation of the use of the alarm system, 
cameras, etc. 
■ A copy of the facility emergency response plan for reference 
■ Contact information for the responsible parties for the installation 
○ If an NFPA 1142 tank is required it SHALL be placed immediately adjacent to but not 
within the 50’ x 100’ responder staging area. 
 
5.2 Emergency Shutdown (LOTO) and Site Controls 
Emergency shutdown controls must be clearly identified and accessible. While OSHA standards govern 
the removal of Lockout/Tagout (LOTO) devices by authorized employees, emergency response 
mandates rapid energy isolation for fire department safety. 
The Emergency Response Plan (ERP) MUST include clear, documented procedures allowing the AHJ (Fire 
Code Official or Incident Commander) to initiate or confirm the remote or local emergency shutdown 
(disconnect) and subsequently verify isolation. The plan must detail the steps for AHJ-directed LOTO 
removal/confirmation in the event the authorized employee is unreachable, ensuring subsequent 
notification protocols are met before facility work resumes. 
The Emergency Responder Panel SHALL contain copies of site plans, the ERP/EOP, safety data sheets 
(SDS) for battery chemistry, and explicit, simplified LOTO and shutdown procedures written specifically 
for fire department use. 
 
5.3 Mandatory 24/7/365 Remote Monitoring and System Access 
For remote, unattended utility-scale facilities, continuous remote monitoring is mandatory to 
compensate for delayed fire department arrival and limited on-site personnel. 
● Required Data Streams: Remote monitoring SHALL provide real-time data on system status, fault 
codes, thermal monitoring (e.g., infrared camera feeds or thermal sensor arrays) within or near 
BESS enclosures, and the status of flammable and toxic gas detection systems. This proactive

ARIZONA FIRE & MEDICAL AUTHORITY 
Protecting life and property and enhancing the well-being of all those we serve 
 
 
 
 
18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
monitoring will allow the Fire Department to initiate the appropriate remote isolation measures 
before physical arrival. 
5.4 Isolation Zone Requirements 
Given the hazards of thermal runaway and the dispersal of gas plumes, especially considering the time 
delay before manual intervention, the facility operator SHALL adhere to a minimum initial isolation zone 
of 330’ (100m) for large commercial/utility BESS incidents. The Emergency Response Plan (ERP) must 
detail the procedures for establishing and enforcing this isolation zone immediately upon confirmation 
of a thermal runaway event. 
 
 
SECTION 6: NFPA 1142 Water Supply Logistics for Rural Response 
Where municipal water supplies are unavailable or inadequate, a static water supply is mandatory, 
designed specifically to support sustained firefighting operations in a rural setting where reliance is 
placed on tender shuttle operations. 
6.1 Water Supply Volume Justification 
The required water volume is NOT based on generalized building area formulas, but on the calculated 
operational demand for BESS incident management: exposure protection and external cooling during 
the critical stabilization period. 
The minimum volume required is 30,000 gallons. This volume is derived from AFMA’s operational 
capability and NFPA 1142 principles for sustained exposure protection, requiring 250 gpm total 
flow(equivalent to 2 – 1.75” handlines @ 125 gpm each) maintained for a duration of 120 minutes (2 
hours). This two-hour duration provides the necessary buffer capacity for fire crews to establish a 
continuous water shuttle operation in a long-response rural area. 
 
6.2 Dry Hydrant and Pad Specifications 
Infrastructure specifications must ensure rapid, safe water drafting operations using heavy apparatus: 
● Apparatus Pad: A reinforced concrete pad, minimum 30’ x 20’, capable of supporting 75,000lb, 
SHALL be provided adjacent to the dry hydrant connection. This guarantees structural stability for

18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
 
the pumper/tender during drafting operations. 
● Dry Hydrant Connection: A 4” discharge, positioned 18-24” above grade with 3.5” male National 
Standard Thread (NST). 
● Hard Suction Storage: A 10’ section of 4.5” hard-suction hose with 3.5” Female NST threads on 
both ends SHALL be stored in a marked, UV-protected enclosure adjacent to the dry hydrant. 
● Tender Fill Connection: A separate female 2.5” NST fill connection, placed on the water tank 180 
degrees opposite the dry hydrant pad, SHALL be provided for refilling tenders/tankers using the 
static supply, ensuring continuous water shuttle operations without interfering with drafting 
operations. 
 
SECTION 7: Inspection, Integrated Testing, and Commissioning 
 
7.1 Required Construction and Acceptance Inspections 
Inspections will be conducted at various stages, including underground work, foundation/pad 
installations, BESS equipment installation, NFPA 1142 tank, and all fire protection and alarm systems. 
Acceptance testing of all fire protection systems and commissioning of BESS systems per manufacturer 
requirements are required prior to final approval. 
 
7.2 Mandatory NFPA 4 Integrated Systems Testing (IST) 
BESS safety relies on complex, integrated control logic where detection of a fault condition (e.g., thermal 
runaway) by the Battery Management System (BMS) must seamlessly trigger subsequent safety 
measures (e.g., ventilation activation, suppression system initiation). Component testing alone is 
insufficient to verify these dependencies. 
Therefore, AFMA SHALL mandate NFPA 4 Integrated Systems Testing (IST) to prove the seamless 
integration of all mechanical, electrical, and life safety systems. A preliminary NFPA 4 IST plan detailing 
test methods and scenario testing (e.g., simulating a detection trigger and verifying the resulting, 
complex activation chain) is mandatory prior to the issuance of the Fire Certificate of Occupancy. 
7.3 Required Pre-Commissioning Fire Department Drill 
Prior to final approval and commissioning, a mandatory on-site emergency response drill SHALL be 
conducted by the facility owner/operator, involving AFMA personnel. This drill is necessary to ensure 
first responders are fully familiarized with the site layout, access roads, emergency controls, LOTO 
procedures, staging area, and water supply location, thereby verifying the practical effectiveness of the 
Emergency Response Plan (ERP).

ARIZONA FIRE & MEDICAL AUTHORITY 
Protecting life and property and enhancing the well-being of all those we serve 
 
 
 
 
18818 N. Spanish Garden Drive, Sun City West, AZ 85375 ⦁ P (623) 544-5400 ⦁ F (623) 544-5455 ⦁ www.afma.az.gov 
The Arizona Fire & Medical Authority proudly serves the communities of Coldwater Ranch, Corte Bella, Cross River,  
Dos Rios, Marisol Ranch, Pinnacle Peak County Island, Rancho Cabrillo, Rancho Silverado,  
Rio Sierra, Sun City West, Sundero, Sun Lakes, and Wittmann 
SECTION 8: Documentation, Emergency Planning, and Long-Term Compliance 
8.1 Emergency Response Plan (ERP) and Emergency Operations Plan (EOP) 
The Emergency Response Plan (ERP), tailored for external first responders, and the Emergency 
Operations Plan (EOP), outlining procedures for on-site personnel, SHALL be completed during 
construction and submitted prior to final inspection, adhering to NFPA 855 guidelines. The ERP must 
explicitly detail firefighting strategies (e.g., sustained defensive operations and cooling rates) and 
protocols for remote LOTO, isolation zone establishment, and contact procedures. 
 
SECTION 9: Contact Information and Resources 
Arizona Fire & Medical Authority 
Address: 18818 N. Spanish Garden Drive, Sun City West, AZ 85375 
Phone: (623) 544-5400 
Website: www.afma.az.gov 
 
Fire Marshal's Office 
For questions regarding plan review, inspections, or code requirements: 
 
Nic Jones, Deputy Fire Marshal 
njones@afma.az.gov 
928-486-6102 
 
Robert Olmstead, Deputy Chief / Fire Marshal 
rolmstead@afma.az.gov 
480-250-5999

This Message Is From an External Sender
This message came from outside your organization. Please use caution when corresponding outside the
county.
From:
Andrew Yancey
To:
Darren Gerard (PND)
Cc:
Ronald Quarles (PND); Adam Cannon (PND); Rachel Applegate (PND)
Subject:
RE: County Code Update
Date:
Tuesday, November 4, 2025 5:30:17 PM
Attachments:
image001.png
Thank you, Darren.  I appreciate the insight.  I’ve included below redlines to 2 sections that
address POD expirations and perimeter treatment for solar projects (which are addressed in
Section 906.3).  Both of these mark ups are nearly identical to provisions that Buckeye City
Council just approved.  I’m happy to discuss further.  Thank you for your consideration.
 
POD Expirations
305.6.  For all development subject to a POD, and approved POD and subsequent building
permits are required prior to the commencement of any construction or development on the
site. The applicant shall ensure that required building permits for the site or first phase shall
be issued within two (2) three (3) years of the date of approval of the POD, unless otherwise
stated in the POD approval. Prior to the date of expiration, the applicant may file a single
request unlimited requests via a Minor Amendment application for a one (1) year time
extension authorized by the Director of Planning and Development. If the time frame has
expired, the applicant shall submit a new POD application.
 
Solar Project Perimeter Treatment
Add a new sub-section 906.3.4 and bump the current 906.3.4 to 906.3.5:  906.3.4. 
Alternatives to wall, buffer, and landscaping requirements for industrial districts may be
approved by the Planning and Development Department as part of a POD application for a
utility-scale solar generation, BESS, or other renewable energy system project based on
the use’s low visibility from public view, remote location, or where wall, buffer, or
landscaping alternatives would be consistent with the character of the surrounding area.
 
 
Andrew D. Yancey, Esq.
Partner
Bergin, Frakes, Smalley & Oberholtzer, PLLC
4343 East Camelback Road, Suite 210
Phoenix, Arizona 85018
Direct: 602.899.0217
Cell: 619.540.3375
Fax: 602.888.7856

From: Darren Gerard (PND) <Darren.Gerard@Maricopa.Gov> 
Sent: Tuesday, November 4, 2025 11:32 AM
To: Andrew Yancey <ayancey@bfsolaw.com>
Cc: Ronald Quarles (PND) <ronald.quarles@maricopa.gov>; Adam Cannon (PND)
<Adam.Cannon@maricopa.gov>; Rachel Applegate (PND) <Rachel.Applegate@Maricopa.Gov>
Subject: RE: County Code Update
 
Andrew: many items are pushed back for further analysis and review during “phase two” next
year.  However, if you re-send any specific edits to the persons copied on here we can look at
potential revisions in the document going forward to the BOS.  Thx, DG
 
From: Andrew Yancey <ayancey@bfsolaw.com> 
Sent: Tuesday, November 4, 2025 11:20 AM
To: Darren Gerard (PND) <Darren.Gerard@Maricopa.Gov>
Cc: Ronald Quarles (PND) <ronald.quarles@maricopa.gov>; Adam Cannon (PND)
<Adam.Cannon@maricopa.gov>
Subject: RE: County Code Update
 
HI Darren – I left you a voicemail yesterday but wanted to follow up on email with the P&Z hearing for this text amendment quickly approaching. Would you be able to give me a quick call at 619. 540 3375 on this? It looks like all the
 
HI Darren – I left you a voicemail yesterday but wanted to follow up on email with the P&Z
hearing for this text amendment quickly approaching.  Would you be able to give me a quick
call at 619.540 3375 on this?  It looks like all the items I had commented on remained
unchanged, so I wanted to see if I could get a better understanding of staff’s position prior to
the public hearing.  In particular, I was looking at the perimeter treatment for solar projects
and POD expiration timeframes.  Thank you.
 
 
Andrew D. Yancey, Esq.
Partner
Bergin, Frakes, Smalley & Oberholtzer, PLLC
4343 East Camelback Road, Suite 210
Phoenix, Arizona 85018
Direct: 602.899.0217
Cell: 619.540.3375
Fax: 602.888.7856
 
 
 
 
From: Darren Gerard (PND) <Darren.Gerard@Maricopa.Gov> 
Sent: Monday, October 13, 2025 10:38 AM

To: Andrew Yancey <ayancey@bfsolaw.com>
Cc: Ronald Quarles (PND) <ronald.quarles@maricopa.gov>; Adam Cannon (PND)
<Adam.Cannon@maricopa.gov>
Subject: RE: County Code Update
 
Andrew: yes. I’ll ask Ron/Adam with this email to schedule a Teams meeting. DG
 
From: Andrew Yancey <ayancey@bfsolaw.com> 
Sent: Monday, October 13, 2025 6:38 AM
To: Darren Gerard (PND) <Darren.Gerard@Maricopa.Gov>
Subject: County Code Update
 
Hi Darren – Is it possible for us to jump on the phone for a few minutes early this week? I’ve got a couple items on the code update that I’m hoping to discuss. And I think written comments on the draft this week will be more
 
Hi Darren – Is it possible for us to jump on the phone for a few minutes early this week?  I’ve got
a couple items on the code update that I’m hoping to discuss.  And I think written comments
on the draft this week will be more productive if we can go over them briefly first.  Please let
me know if there is a good time that would work for you.  I don’t think more than 10-15 minutes
would be necessary.  Thanks.
 
Andrew D. Yancey, Esq.
Partner
Bergin, Frakes, Smalley & Oberholtzer, PLLC
4343 East Camelback Road, Suite 210
Phoenix, Arizona 85018
Direct: 602.899.0217
Cell: 619.540.3375
Fax: 602.888.7856

From:
Adam Cannon (PND)
To:
Rhonda Buss
Cc:
Karen Dada; Rachel Applegate (PND); Ronald Quarles (PND)
Subject:
RE: ASLD Maricopa County Zoning Code Draft #2 Comments
Date:
Wednesday, November 5, 2025 10:05:12 AM
Attachments:
image001.png
ASLD Matrix.pdf
Good morning Rhonda,
 
Thank you for ASLD’s comments.  I am copying this over to the team.
 
Also, there are some questions I can answer for you in your comments:
 
1. The grayed out areas are areas where the uses are not permitted (with caveats re: C-S
zoning district, which is a specialty district).  Originally we had used the term “NP” to
denote this, but that changed to graying out the boxes. 
2. We would not prohibit food and beverage or light retail in C-S.  When we prepared the
use table, you will notice on page 6-8 we merged the old shopping center use into
general retail: “retail sale of merchandise, services, recreational and otherwise, parking
area and other facilities customarily considered shopping center uses”.  We would
consider both food and beverage and light retail uses to be allowed in C-S.
3. General retail is not something that the County is considering at this time for R-5 and C-
1 zoning districts.  All of the uses (save C-S) that were consolidated into the General
Retail category were basically a large bulk of C-2 uses in the existing ordinance.
4. There are many comments we are receiving associated with BESS, such that we may
look at BESS matters in far more detail in a future phase.  In general, we consider it to be
industrial (permitted by right in IND-2 and IND-3 zoning districts) as it is associated with
utilities, data centers and energy generation (solar in particular).  There are also
potential impacts – various local fire marshals consider BESS units to be a serious fire
risk and some industry folks believe less regulation is needed.  That said, we are
listening to a variety of comments right now and anticipate addressing BESS at the PZ
hearing tomorrow.
5. You will be pleased to know we have added a parking study that allows for parking
requirements for industrial, commercial and multifamily uses to be reduced based on
certain criteria such as transportation demand management.  This is located in 802.3.4.
 
Best regards,
 
Adam Cannon, AICP
Senior Planner
Planning & Development
301 W Jefferson St. Phoenix, AZ 85003
O: 602-372-0292
E: adam.cannon@maricopa.gov

This Message Is From an External Sender
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county.
[ Maricopa.Gov ]
Facebook | Instagram | Twitter | YouTube | LinkedIn
 
Maricopa County is developing the Framework 2040 Comprehensive Plan – a document which guides growth and
development for the next decade and beyond.  Visit Framework 2040 to learn how to participate, attend meetings and be
heard!
 
Additionally, the Maricopa County Zoning Ordinance is being updated. Visit MCZO Update to learn more and comment on
changes to the ordinance.
 
 
 
From: Rhonda Buss <rbuss@azland.gov> 
Sent: Wednesday, November 5, 2025 6:55 AM
To: Adam Cannon (PND) <Adam.Cannon@maricopa.gov>
Cc: Karen Dada <kdada@azland.gov>
Subject: ASLD Maricopa County Zoning Code Draft #2 Comments
 
Good morning Adam, Thank you for the opportunity to review Maricopa County Zoning Code Draft #2. We appreciate your time and for explaining the County’s interpretation of the POD with respect to the use table. ASLD offers the attached comments. 
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ZjQcmQRYFpfptBannerEnd
Good morning Adam,
 
Thank you for the opportunity to review Maricopa County Zoning Code Draft #2. We
appreciate your time and for explaining the County’s interpretation of the POD with
respect to the use table. ASLD offers the attached comments. All page numbers
referenced on the comment form are from the PDF of the document.
We are happy to discuss any comments. Please reach out with any questions or items
the County may wish to discuss.
Thank you,
  Rhonda Buss, AICP
  Planner III
  1110 W. Washington St
  Phoenix, AZ 85007
  602-542-3126
  land.az.gov | Facebook | Twitter/X

Zoning Code Update Draft #2 Review 
Comment Form 
 
 
 
 
 
 
Page 1 of 1 
Name: Rhonda Buss 
Email: rbuss@azland.gov 
Title and Organization: Planner III, ASLD 
# 
Document 
Location 
Concerns/Comments 
Comment 
Number 
Section, 
Page #, Etc.  
ASLD concern/comment. 
1 
 
ASLD comments are offered below, and we are happy to discuss any comments.  
 
2 
Page 123 
Please define what the grayed-out area is in the use table legend. 
3 
Page 126 
Food and Beverage is allowed with a POD in R-5 and grayed out in C-S. C-S lends itself to allowing food and beverage use subject to a 
POD especially since it is allowed in R-5. 
4 
Page 128 
General Retail is grayed out in the R-5-C-1 districts. Given the nature of the use, ASLD advocates for General Retail as a permitted use 
in these zoning districts, excluding C-O.  
5 
Page 130 
Light Retail is grayed out in in the C-S district. The definition of light retail seems to serve the intent of this district and should be 
considered as being subject to a POD under this district. 
6 
Page 138 
Once constructed, BESS and Data Center facilities are passive uses. ASLD supports including BESS & Data Center uses in both C-2 & 
IND-2 subject to a POD. 
7 
Pages 206 & 
208 
A 75-foot average setback is large. Please retain the existing density bonus or provide for a TDR/cluster development by right that can 
accommodate the setback, height, and other overlay restrictions. 
8 
Page 234 
ASLD proposes that the parking table establish the standards with an exception that allows for a parking reduction if supported by a 
parking study by a licensed professional. This will help in assessing specific parking needs of a project. 
9