03. 04. CPA240008 Z240026 PZ Staff Report
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CPA240008 and Z240026 Page 1 of 11 Report to the Planning and Zoning Commission Prepared by the Maricopa County Planning and Development Department Cases: CPA240008 & Z240026 – Pinyon Solar Project Hearing Date: September 11, 2025 Supervisor District: 5 Applicant: Colin Mann, Avantus Owner: Sonoran Monument Holdings LLC, Pravorn Gary MTR/Barry O Tr, Jimenez Roy. Requests: 1. General Comprehensive Plan Amendment (CPA) from Rural Development Area to Utilities 2. Zone Change with Overlay from Rural-190 to IND-2 IUPD Site Location: Generally located west of the SWC of 91st Ave. and Schumacher Ln. in the Goodyear/Mobile area Site Size: Approximately 241 acres Density: N/A County Island: No County Plan: Vision 2030 Comprehensive Plan: Rural Development Area (RDA) Municipal Plan: N/A Municipal Comments: N/A Support/Opposition: N/A Recommendations: 1. Approve (CPA2024003) 2. Approve with conditions (Z2024040) CPA240008 and Z240026 Page 2 of 11 Project Summary: 1. The applicant, Avantus, is seeking a CPA to change the land use designation of 241 acres in the Mobile area to Utilities and a and an associated rezoning to IND-2 IUPD to facilitate the future development of a utility scale solar project. A Plan of Development will be subsequently processed for administrative approval as prerequisite for construction permitting. 2. The total project is comprised of approximately 2,029 acres, 241 acres of which are privately owned land within unincorporated Maricopa County. The remaining 1,788 acres is BLM land located within both the City of Goodyear and unincorporated Maricopa County. The applicant is coordinated with the City of Goodyear for the portion of the project located within their jurisdiction. The City of Goodyear has determined that solar project is allowed without a change of zoning. Additionally, the portion of the project site that is BLM land within unincorporated Maricopa County is not included with this rezoning request. The applicant, however, will process the entitlements for the project with BLM specifically, subject to an agreement outlining design features, BMPs, and other environmental protection measures. This request was routed to the City of Goodyear, and they have not provided any comments. Regional Context of the site 3. Development of the site would be comprised of photovoltaic panel arrays and electrical collection systems. The applicant states the facility would include multiple solar arrays, comprised of parallel strings of photovoltaic solar modules, inverter stations, and enclosed or canopied transformers. The site would include a battery energy storage system (BESS) facility that would occupy approximately 24 acres near the project’s substation an would consist of equipment CPA240008 and Z240026 Page 3 of 11 housed in stackable metal structures, 15 feet in height. The O&M building would be a prefabricated structure. 4. The site will be accessed via existing roads, the primary access is anticipated to be via 83rd Ave., Schumacher Ln, and local roads. Access to the southern portion of the site will be via Fulcar Rd and 83rd Ave. 5. The applicant is requesting to deviate specific developments standards of the base zoning district in order to facilitate the development of the site and to adapt to industry standards similar to other projects in the county. The following table depicts the base IND-2 standards and the proposed IND-2 IUPD standards with deviations shown in bold text: REGULATION BASE ZONING DISTRICT REGULATIONS (IND-2) PROPOSED ZONING DISTRICT REGULATIONS (IND-2 IUPD) Maximum Height 40’ 40’ Minimum Front Yard 10’ – 25’ 10’ – 25’* Minimum Side Yard 3’ – 10’ 0’ – 10’ ** Minimum Rear Yard 25’ 0’ – 25’*** Min. Lot Area 6,000 SF 6,000 SF Min. Lot Width 60’ 60’ Max. Lot Coverage 60% 60% (solar panels not to be counted as lot coverage) Landscaping N/A None required Paving Article 1102.7.1. For other than one single-family dwelling unit or one mobile home on a lot of record, any parking area must be paved or in the alternative surfaced with aggregate base course material. Alternative surfacing materials or methods approved by Maricopa County Air Quality to minimize dust pollution such as but not limited to, compacted native soil or aggregate base course, may be used in driveways and parking areas. Parking Spaces See parking regulations No required parking Screening A solid masonry wall not less than six feet in height shall be required along and adjacent to any side or rear property line abutting any rural or residential zone boundary, or any alley abutting such zone boundary. Further, any access gates shall be constructed of view- obscuring material to provide effective site screening. Chain link fencing and gates will be allowed at the Project perimeter. Fencing and gates will be comprised of 1 foot of barbed wire strands atop min. 7 feet of chain link. Uses MCZO Article 902.2 Use of the site shall be limited to utility scale solar generation an ancillary buildings [solar photovoltaic (PV) panels, battery energy storage system (BESS), access roads, operations and maintenance (O&M) building, and substation * 10’ abutting a local roadway; 15’ abutting a midsection roadway; 20’ abutting section line roadway; and 25’ at an intersection abutting a rural zone district. ** 5’ abutting a rural zoning district; 10’ for a corner lot abutting a rural zoning district; and 3’ if provided. *** 25’ abutting a rural zoning district CPA240008 and Z240026 Page 4 of 11 6. Because the site is limited to utility infrastructure, the applicant is proposing no parking and that pavement surfaces be waived with an approved dust control plan from Maricopa County Air Quality Control.. 7. No landscaping or screening is proposed. The applicant is proposing a chain link fence topped with barbed wire in lieu of a 6’ CMU wall abutting rural/residential zoning district or uses. The applicant has coordinated with Arizona Fish and Game to develop fencing with small gaps along the ground to allow for small wildlife to traverse across the site. 2025 Aerial Image of the Site CPA240008 and Z240026 Page 5 of 11 Zoning of the Site and Adjacent Properties 8. The narrative asserts that the proposed development meets the Comprehensive Plan Amendment criteria in the following manner: Whether the amendment constitutes an overall improvement to the Comprehensive Plan and is not solely for the good or benefit of a particular landowner or owners at a particular point in time. The applicant states the proposed amendment to utilities constitutes an overall improvement to the comprehensive plan because the subject lands have the necessary characteristics that make them suitable for a solar project. The narrative states that this will be an improvement as the site is currently vacant and the project will promote stable economic growth, maintaining a healthy environment, and providing adequate community services. Whether the Amendment Will Adversely Impact All or a Portion of the Planning Area by: A. Altering acceptable land use patterns – The applicant states the proposed project will not alter any surrounding land uses or land use patterns as the site is near existing electrical infrastructure, existing solar facilities and nearby agricultural uses, airports, and rural housing development. CPA240008 and Z240026 Page 6 of 11 B. Requiring public expenditures for larger or more expensive infrastructure – The applicant states the proposed project will not require public expenditures as the site is near existing substantial infrastructure. C. Requiring public improvements to roads, sewer, or water systems that are needed to support the planned land uses – The applicant states the proposed project will not contribute to an increase in traffic that necessitates road improvements, and the use would not require water or sewer systems improvements. Water hauled to and stored on-site would be from permitted sources and stored on lands administered by the BLM. D. Adversely impacting planned uses because of increased traffic – The applicant indicates that during the construction phase of the proposed project, traffic will temporarily increase for the construction workforce, but otherwise little to no traffic after development of the site. E. Affect the livability of the area or health and safety – The applicant states the project will have minimal impact on the surrounding communities as all local environmental laws and regulations will be complied with. F. Adversely impacting the natural environment or scenic quality of the area – The applicant indicates the proposed project will have minimal impacts to the natural environment and scenic quality of the area due to the location and the presence of existing energy and utility infrastructure. Whether the amendment is consistent with the overall intent of the Comprehensive Plan. The applicant’s narrative states that the request is consistent with the overall intent of the Comprehensive Plan by addressing the three core principals of the plan such as fostering sustainable development and increasing the economic base for local, county, and state economies. The Extent to which the amendment is consistent with the specific goals and policies contained within the Plan. The applicant’s narrative contains a substantial list of goals and policies from the Vision 2030 Maricopa County Comprehensive Plan. This staff report identifies which goals, objectives, and policies the applicant’s narrative addressed. Vision 2030 Comprehensive Plan Land Use: Goal 1: Achieve balanced and efficient development patterns. Policy 10: Coordinate planning efforts between local, state, and federal agencies. Policy 15: Evaluate comprehensive plan amendments and zoning district changes to determine the existence of the urban services and infrastructure identified in this element. Policy 22: Reduce the impacts of new development on environmentally sensitive areas, including native flora and fauna habitat and corridors. CPA240008 and Z240026 Page 7 of 11 Policy 33: Support land use buffers and compatible land use strategies near existing and future high voltage electric utility line corridors. Transportation: Policy 1: Preserve future road alignments, called for in county-recognized transportation plans, especially mid-section line, section line, and arterials roads; parkways; freeways; and interchanges. 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. Policy 3: To help protect water quality Maricopa County supports compliance with its Drinking Water program and its Water and Wastewater Treatment program. 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. 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. Policy 7: Where necessary Maricopa County supports noise reductions in new development design and in the construction of new buildings. Economic Growth: Goal 1: Contribute to an effective regional economy. Policy 10: Maricopa County supports leveraging its solar resource potential to attract solar- related industries and alternative energy research and development. Open Space: Goal 1: Provide regional leadership to promote environmental quality, including the preservation of open, natural park and recreation lands. Water Resources: Policy 6: Maricopa County supports low water use solar electric generating technologies. Energy: Goal 2: Make Maricopa County a leader in alternative energy research and development. Policy 6: Maricopa County supports being a responsible leader in alternative energy research and development. CPA240008 and Z240026 Page 8 of 11 Policy 7: Maricopa County supports efforts to assist businesses and individuals with renewable energy options and energy conservation. Cost of Development: Goal 2: New development pays its proper and reasonable share of the costs of new infrastructure, services and other public improvements. Existing On-Site and Adjacent Zoning / Land Use: 9. On-site: Rural-190 / Vacant North: City of Goodyear / Vacant South: Rural-190 / Vacant East: Rural-190 / Vacant West: Rural-190 / Vacant Utilities and Services: 10. Water: On-site Well Wastewater: On-site Septic Fire: Phoenix Fire District and/or City of Goodyear Fire District Police: Maricopa County Sheriff’s Office Right-of-Way: 11. Right of way dedications and improvements will be reviewed during the Plan of Development when a traffic impact study will be reviewed by the Maricopa County Department of Transportation (MCDOT). Adopted Plan: 12. Vision 2030 (adopted 2016): This are plan designates the site as Rural Development Area (RDA). This category identifies areas where low density single-family development is desirable because urban services are limited or non-existent. Case No. CPA240008 proposes to designate the site for Utilities land uses which is consistent with the regional land use patterns. Public Participation Summary: 13. The applicant complied with the minimum requirements of the Maricopa County Citizen Review Process - with the required posting of the site and notification by first class mail to adjacent property owners within 300’ of the subject parcel and interested parties. The applicant submitted a Public Participation Results Report. To date, no opposition has been received. CPA240008 and Z240026 Page 9 of 11 Outstanding Concerns from Reviewing Agencies: 14. N//A Staff Analysis: 15. Maricopa County recognizes the potential environmental and economic benefits that solar technology can provide, and the fact that this region of the county has superior solar resources. Pinyon will use photovoltaic technology that generates energy from sun absorption. Photovoltaic technology differs from other models of solar electric generation that require vast amounts of water to cool the units. In constrict, very little water is utilized for photovoltaic technology. As a result, this development would not pose a threat to the groundwater supply. 16. Staff believes the proposed IND-2 IUPD zoning district is appropriate within this rural area for the future development of a utility scale solar facility, which requires large amounts of relatively flat land. The majority of the land is flat. Staff agrees with the applicant that the subject site is suitable due to proximity to electrical transmission lines, nearby stations and substation, and because the site is remote and the surrounding area is vastly undeveloped. Staff agrees with the applicant that the project will not detrimentally affect the visual quality of the area. 17. The development of solar energy over the past several years in Maricopa County reinforces the County’s interest in promoting the County as an economic leader for solar development. Staff believes that Pinyon Solar Project would add to this effort in a positive way by providing the potential of various temporary construction and operation/maintenance jobs. The development of this site is consistent and compatible with area land uses and development patterns. It is likely given the existing solar development within this area that solar development of this parcel would present the highest and best usage of the land. 18. Staff is recommending approval of the CPA and zone change request for the reasons noted above with the conditions of approval that would make the site appropriate for the area. Recommendations: 19. Staff recommends the Commission adopt a motion recommend that the Board of Supervisors approve CPA240008. 20. Staff recommends the Commission adopt a motion recommending that the Board of Supervisors approve Z240026 subject to the following conditions ‘a’ – ‘k’: a. Development of the site shall be in substantial conformance with the Narrative Report entitled “Pinyon Solar Project”, consisting of 15 pages, dated July 18, 2025, except as modified by the following conditions. b. Development of the site shall be in substantial conformance with the Zoning Exhibit entitled “Pinyon Solar Case No. Z240026”, consisting of 2 full-size sheet, dated July 18, 2025, and stamped received July 19, 2025, except as modified by the following conditions. c. The following IND-2 IUPD development standards shall apply for development of solar power generation and BESS facilities: 1. Parking: None required CPA240008 and Z240026 Page 10 of 11 2. Max. Lot Coverage: 60% Solar panels not counted as lot coverage. 3. Paving: Alternative surfacing materials or methods approved by Maricopa County Air Quality to minimize dust pollution such as but not limited to, compacted native soil or aggregate base course, may be used in driveways and parking areas. 4. Site Enclosure and Screening: Minimum 8’ tall chain-link fences adjacent to rural/residential zoning boundaries, including attached barbed wire. 5. Article 902.9.1 – All utility uses shall be permitted to be conducted outdoor. 6. Permitted uses: limited to solar energy generation, battery energy storage systems and ancillary uses. d. The IND-2 zoning is subject to an Industrial Unit Planned Development (IUPD) Overlay that limits the entitled use to solar power generation facilities and ancillary uses, or other uses determined by both the Planning & Development Department and the Environmental Services Department as appropriate and that can accommodate wastewater disposal via on-site septic systems until such time as a sanitary sewer system is available serving the site. The IUPD may be deleted or amended to entitle additional uses via Modification of Condition application to the Planning & Development Department but will require legislative approval by the Board of Supervisors after recommendation of the Planning & Zoning Commission. e. The following Planning Engineering conditions shall apply: 1. Without the submittal of a precise plan of development, no development approval is inferred by this review, including, but not limited to number of proposed building lots/units, drainage design, access and roadway alignments. These items will be addressed as development plans progress and are submitted to the County for further review and/or entitlement. 2. Development in regulated floodplains must comply with the Floodplain Regulations for Maricopa County. 3. A traffic impact study must be submitted with future entitlement application(s). 4. Private utilities that will occupy County R/W require a license in addition to any construction related permits. Contact MCDOTsolarlicense@maricopa.gov. Seehttps://www.maricopa.gov/DocumentCenter/View/74250/MCDOT-SolarLicense- Application for more information. 5. Engineering review of re-zone cases is conceptual in nature. All development and engineering design shall be in conformance with Section 1205 of the Maricopa County Zoning Ordinance; Drainage Policies and Standards; Floodplain Regulations for Maricopa County; MCDOT Roadway Design Manual; and current engineering policies, standards and best practices at the time of application for construction. f. Associated development on BLM land is shown of informational purposes only. All entitlement and construction permitting of BLM land will be coordinated with and processed through BLM. CPA240008 and Z240026 Page 11 of 11 g. The applicant and/or developer shall submit a Plan of Development for administrative review and approval prior to construction permitting. h. Prior to issuance of a building permit, written confirmation will be required from the emergency fire protection jurisdiction that emergency fire protection service will be provided to the facility. Prior to issuance of the certificate of occupancy, local fire protection jurisdiction review and approval will be required. i. Noncompliance with any Maricopa County Regulation shall be grounds for initiating a revocation of this Zone Change as set forth in the Maricopa County Zoning Ordinance. j. The property owner/s and their successors waive claim for diminution in value if the County takes action to rescind approval due to noncompliance with conditions. k. The granting of this change in use of the property has been at the request of the applicant, with the consent of the landowner. The granting of this approval allows the property to enjoy uses in excess of those permitted by the zoning existing on the date of application, subject to conditions. In the event of the failure to comply with any condition, the property may be considered by the Board after recommendation by the Commission at a public hearing for reversion. It is, therefore, stipulated and agreed that either revocation due to the failure to comply with any conditions, does not reduce any rights that existed on the date of application to use, divide, sell or possess the property and that there would be no diminution in value of the property from the value it held on the date of application due to such revocation of the Zone Change. The Zone Change enhances the value of the property above its value as of the date the Zone Change is granted and reverting to the prior zoning results in the same value of the property as if the Zone Change had never been granted. Presented by: Paola Jaramillo, Planner Reviewed by: Rachel Applegate, Planning Supervisor Attachments: Case Maps (2 pages) Narrative Report (CPA) (27 pages) Narrative Report (Zone Change) (15 pages) Zoning Exhibit (2 pages) Engineering comments (2 pages) MCESD comments (1 page) City of Goodyear Zoning Verification Letter (1 page) BLM: Design Features, BMPs, and Other Environmental Protection Measures (21 pages) / Maricopa County Planning & Development - Phoenix, AZ 5 Gross Acres: 240 approx. Generated August 15, 2025 8:53 AM CPA240008 Application Name: Legal Description Pinyon Solar Project Applicant Case Address 5S 1E 9 Colin Mann Applicant Phone/Email Parcel Primary:300-29-018C (303) 817-1229 cmann@avantus.com Map scale 1:13,006 Supervisor District No. Pinyon Solar Project / Maricopa County Planning & Development - Phoenix, AZ 5 Gross Acres: 240 approx. Generated August 15, 2025 8:39 AM Z240026 Application Name: Legal Description Pinyon Solar Project Applicant Case Address 5S 1E 9 Colin Mann 48400 S 91ST AVE Applicant Phone/Email Parcel Primary:300-29-018C (303) 817-1229 cmann@avantus.com GILA BEND, AZ 85337 Map scale 1:13,006 Supervisor District No. Pinyon Solar Project Revised July 2025 COMPREHENSIVE PLAN AMENDMENT (CASE NO. CPA240008) PINYON SOLAR PROJECT NARRATIVE REPORT Original Submittal December 20, 2024 Second Submittal June 3, 2025 Third Submittal July 18, 2025 Prepared by SWCA Environmental Consultants 257 East 200 South, Suite 200 Salt Lake City, Utah 84111 (801) 322-4307 www.swca.com On Behalf of 265BH 8me LLC 4370 Town Center Boulevard, Suite 110 El Dorado Hills, CA 95762 (303) 817-1229 Project Vicinity Map Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 1 CONTENTS 1 Introduction .......................................................................................................................................... 3 1.1 On-Site and Regional Information Location ................................................................................ 6 1.2 CPA Size and Description of Land Use Type by Acreages ......................................................... 6 1.3 Roads/Transportation Systems Serving the Proposed Project ...................................................... 6 1.4 Suitability with Surrounding Land Uses ....................................................................................... 7 1.4.1 Proposed Use ...................................................................................................................... 7 2 Whether the Amendment Constitutes an Overall Improvement to the Comprehensive Plan ........................................................................................................................................................ 8 3 Whether the Amendment will Adversely Impact all OR A of a Portion of the Planning Area........................................................................................................................................................ 8 3.1 Altering Acceptable Land Use Patterns to the Detriment of the Plan .......................................... 8 3.2 Requiring Public Expenditures for Larger and More Expensive Infrastructure ........................... 9 3.3 Requiring Public Improvements to Roads, Sewers, or Water Systems that are Needed to Support the Planned Land Uses .................................................................................................... 9 3.4 Adversely Impacting Planned Uses Because of Increased Traffic ............................................... 9 3.5 Affecting the Livability of the Area or Health or Safety of Present and Future Residents .......... 9 3.6 Adversely Impacting the Natural Environment or Scenic Quality of the Area in Contradiction to the Plan ............................................................................................................ 10 4 Whether the Amendment (or Conditional Modification) is Consistent with the Overall Intent of the Comprehensive Plan ..................................................................................................... 10 5 The Extent to which the Amendment (or Conditional Modification) is Consistent with the Specific Goals and Policies Contained within the Plan ................................................................... 11 5.1 Vision 2030 Comprehensive Plan .............................................................................................. 11 5.1.1 Land Use ........................................................................................................................... 11 5.2 Transportation ............................................................................................................................. 14 5.3 Environment ............................................................................................................................... 14 5.4 Economic Growth ....................................................................................................................... 15 5.5 Open Space ................................................................................................................................. 15 5.6 Water Resources ......................................................................................................................... 16 5.7 Energy ......................................................................................................................................... 16 5.8 Cost of Development .................................................................................................................. 16 6 Resource Protection ........................................................................................................................... 17 6.1 Access and Traffic ...................................................................................................................... 17 6.2 Vegetation ................................................................................................................................... 17 6.3 Wildlife ....................................................................................................................................... 18 6.4 Cultural and Historic Resources ................................................................................................. 18 6.5 Water Resources ......................................................................................................................... 18 6.6 Sonoran Desert National Monument and Recreation ................................................................. 19 7 Agency Coordination and Mitigation Measures .............................................................................. 19 7.1 City of Goodyear ........................................................................................................................ 19 7.2 Pinal County ............................................................................................................................... 20 7.3 BLM ........................................................................................................................................... 20 Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 2 7.3.1 Additional Consultation and Coordination with Agencies and Tribal Governments ....... 20 7.4 SHPO and THPO Consultations ................................................................................................. 21 7.5 US Fish and Wildlife Coordination ............................................................................................ 21 7.6 US Army Corps of Engineers ..................................................................................................... 21 7.7 Mitigation Measures ................................................................................................................... 22 8 Literature Cited .................................................................................................................................. 22 Figures Figure 1. Pinyon Solar Project location. ....................................................................................................... 4 Figure 2. Pinyon Solar Project land ownership and jurisdiction. .................................................................. 5 Figure 3. Pinyon Solar Project existing infrastructure. ............................................................................... 12 Appendices APPENDIX A Design Features, BMPs, and Other Environmental Protection Measures APPENDIX B BLM Entitlement Documentation Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 3 1 INTRODUCTION 265BH 8me LLC (Applicant), a subsidiary of Avantus Clean Energy LLC, proposes to construct, operate, maintain, and eventually decommission the Pinyon Solar Project (Project), a solar and battery storage project on approximately 1,788 acres of public lands administered by the Bureau of Land Management (BLM), Lower Sonoran Field Office, and approximately 241 acres of private lands in Maricopa County, Arizona (Figure 1). The Applicant is requesting a comprehensive plan amendment (CPA) for a portion of the Project area (approximately 241 acres of privately owned lands) from “rural development area” to the “utilities” land use designation. The Project includes an up to 300-megawatt alternating current solar photovoltaic (PV) power-generating facility and battery energy storage system, associated access roads, an operation and maintenance facility, a project substation, and other ancillary components. The Project applicant would also construct, operate and maintain, and decommission a 345-kilovolt electrical generation interconnection transmission line (gen-tie) in Maricopa and Pinal Counties. The gen-tie would originate at the project substation and proceed eastward across private lands for approximately 2.8 miles to the existing Tucson Electric Power (TEP) 345-kV terminal at the Pinal West Substation. Within the Maricopa County private lands, the Project will consist of solar PV panels, 6-foot-high fencing, access gates, and stormwater controls. Project construction is expected to occur starting as soon as fall of 2026 with construction lasting approximately 18 months, concluding early 2028. Based on commercial agreements, the project may be required to be constructed in phases. The sizing and timing of these phases has not been finalized at this time. However, the project footprint and components within the private lands in Maricopa County are not anticipated to change with any potential project phasing. The Applicant anticipates up to 400 employees throughout the course of the Project during construction, and five permanent, full-time staff during operation. The Project would operate 24 hours a day, 365 days per year. Maricopa County Zoning Ordinance (MCZO) 304.8 states that applications for changes in zoning district boundaries must comply with the Comprehensive Plan. As such, the Applicant is requesting a comprehensive plan amendment (CPA) for a portion of the Project area (approximately 241 acres of privately owned lands) from “rural development area” to the “utilities” land use designation (see LAND- EXHI-1 in application). The Applicant is requesting this CPA as utility-scale solar projects are not permitted within the existing land use designations and the proposed Project area is an optimal project site with little conflict to no conflict with natural and cultural resources, as described in Section 6. The Project is actively coordinating with federal, state, and other local agencies as described in Section 7. Additional information design features, mitigation measures, and best management practices are included in Appendix A. This CPA is being requested in conjunction with a zoning change request through Maricopa County that was filed on December 20, 2024. This narrative report addresses the information required to support the request for a CPA for the Pinyon Solar Project. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 4 Figure 1. Pinyon Solar Project location. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 5 Figure 2. Pinyon Solar Project land ownership and jurisdiction. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 6 1.1 On-Site and Regional Information Location The Project within unincorporated Maricopa County is located within Township 5 South, Range 1 East, Section 9. The Project is situated south of State Highway 238, approximately 10 miles west of the city of Maricopa and 2 miles south of State Route 238. The Project rests under the jurisdiction of both the City of Goodyear and unincorporated Maricopa County, with the eastern most portions of the gen-tie crossing into Pinal County. 1.2 CPA Size and Description of Land Use Type by Acreages The Project area encompasses up to 241 acres of private land and 1,788 acres of federal land managed by the BLM Lower Sonoran Field Office (LSFO). The Project’s gen-tie line spans approximately 2.8 miles across private property in Maricopa County, connecting to the existing Tucson Electric Power (TEP) 345-kilovolt (kV) terminal at the Pinal West Substation in Pinal County to the east. The land immediately northwest and southeast of the Project is primarily privately owned, while the land to the southwest and northeast is BLM-administered. The land use in the area is predominantly undeveloped desert scrub habitat, with smaller areas of rural residential land and fallow/idle cropland. The Project area also borders the Sonoran Desert National Monument. Public access to the monument and surrounding public lands is expected to have minimal impact and is under review by the BLM as described in Section 6. Within the entire Project area, existing property uses include recreational off-highway vehicle use and target shooting. Additionally, there are several access and utility rights-of-way (ROWs), including a section of the 368 Corridor (see Figure 3) and the future I-11 Corridor. Additional lands associated with the project, but outside of the CPA review area, are zoned RU-190. These include BLM managed lands within unincorporated Maricopa County, federal lands within the mapped boundary of City of Goodyear, and lands within unincorporated Pinal County. The application has been in communication with these additional jurisdictions and is currently pursuing applicable permits. Additional discussion of these coordination and permitting efforts is provided in Section 7. This application focuses on the 241 acres of privately owned land within Maricopa County. The Applicant requests a Comprehensive Plan Amendment (CPA) to change the land use designation of the Vision 2030 Comprehensive Plan for the 241 acres of privately owned lands from ”rural development” to “utilities.” The proposed "Utilities" land use aligns with the Vision 2030 Comprehensive Plan by supporting sustainable infrastructure development and efficient land utilization. Given the existing land uses in the area, the proposed utility use is appropriate for the site and will not negatively impact adjacent properties or compromise public health, safety, or general welfare. 1.3 Roads/Transportation Systems Serving the Proposed Project Access to the Project would be provided via existing roads. The Project would be accessible via S 83rd Ave and W Schumacher Lane, which will remain open during construction and operation of the Project. Access to the southern portion of the project area may be provided via Fulcar Road and S 83rd Avenue. The Applicant is currently coordinating with the BLM on path forward to provide continued access to surrounding BLM and private lands, as discussed in Section 6 and 7. The applicant is committed to providing continued access to areas outside the Project to members of the public and surrounding landowners. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 7 1.4 Suitability with Surrounding Land Uses The lands in the immediate vicinity of the Project are a mix of private lands, ASLD-administered lands, and BLM-administered lands. The land use in the immediate area consists of undeveloped desert scrub, rural residential, and regional airport infrastructure. However, other related facilities (including oil and gas pipelines, electrical substations, and high-voltage transmission lines) in the immediate vicinity of the Project make the Project site suitable for solar generation. Additionally, there are other solar facilities that are being proposed within the Project vicinity. The Applicant has been in coordination with multiple federal, state, and local agencies to design the project to avoid, minimize, and/or mitigate impacts to the natural environmental resources and culturally significant resources. These discussions, design features, and mitigation measures are described in Section 6, 7, and Appendix A. The Applicant will comply with all federal and state laws, regulations, and guidelines regarding the protection and mitigation of biological, cultural, water, and other natural resources as required. Table 1 Surrounding Land Use Location Designated Land Use Existing Land Use On Site Single Family - Rural Undeveloped scrub habitat, small areas of rural residential, and fallow/idle cropland North City of Goodyear, zoned Agricultural Undeveloped scrub habitat, fallow/idle cropland South Single Family - Rural Undeveloped scrub habitat, regional airport West Single Family - Rural Undeveloped scrub habitat, regional airport East Single Family - Rural Undeveloped scrub habitat, utility corridor, electrical substation 1.4.1 Proposed Use The Applicant proposed the construction, operation and maintenance, and decommissioning of a PV solar generation facility with battery energy storage and associated facilities. The Applicant estimates that the Project would generate up to 300 megawatts, alternating current (MWac) of solar generation and associated up to 8-hour battery storage capacity of 300 MW output. The Project PV solar array has been designed to occur on all the property identified in Figure 1, avoiding floodways, channels, setbacks, and easements or other ROWs. The PV modules would be mounted on steel support structures or single-axis trackers that are anchored to or driven into the ground. The Project would connect to the TEP Pinal West Substation approximately 2.8 miles east of the Project (see Figure 1). Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 8 2 WHETHER THE AMENDMENT CONSTITUTES AN OVERALL IMPROVEMENT TO THE COMPREHENSIVE PLAN In general, the Project location was selected due to its lack of conflicts with surrounding resources and compatibility with existing land uses. The location is favorable due to its proximity to the Pinal West Substation, minimal topographic variation, and limited potential impacts on human, cultural, and environmental resources. This proposed amendment change would improve and align with the overall Vision 2030 Comprehensive Plan as it would provide additional economic opportunity in an efficient growth pattern in support of the three core principles (Maricopa County 2016). Ultimately, the Pinyon Solar Project will make efficient use of the Maricopa County administered lands by meeting the goals of promoting stable economic growth, maintaining a healthy environment, and providing adequate community services. Within the proposed Project area, sunlight availability is steady and direct across the relatively flat land. Multiple solar projects have been proposed in the area due to the ideal location. Several transmission lines, one substation, and oil and gas pipelines are already constructed within the vicinity of the Project so there will not be a need for large transmission infrastructure improvements. Proximity of the Pinyon Solar Project to these resources make it ideal for utility development within this area. The Vision 2030 Comprehensive Plan is committing to all nine plan elements as the Applicant has developed multiple health and safety, environmental, construction, operation, and decommissioning plans to minimize and reduce its footprint outside of the Project area. Amending the Vision 2030 Comprehensive Plan would allow the Project and Maricopa County to use favorable solar resources, land use designations, and transmission infrastructure to create economic opportunity. 3 WHETHER THE AMENDMENT WILL ADVERSELY IMPACT ALL OR A OF A PORTION OF THE PLANNING AREA The CPA for the Project is expected to result in negligible adverse impacts on the Vision 2030 Comprehensive Plan, as outlined below. 3.1 Altering Acceptable Land Use Patterns to the Detriment of the Plan The Project would not alter or interfere with any nearby existing land uses and would remain consistent with adjacent and nearby energy and utility uses, including existing generation sites, transmission lines, and solar projects. The Project would also be compatible with nearby agricultural uses, airports, and rural housing developments. While public access to the SDNM will have minimal impact, the Project may impact scenic views and generate temporary noise and dust during construction. Impacts related to these resources are being analyzed as part of the BLM’s National Environmental Policy Act (NEPA) process and further discuss in Sections 6 and 7. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 9 3.2 Requiring Public Expenditures for Larger and More Expensive Infrastructure The Project will not require public expenditures for infrastructure. It will utilize existing electrical infrastructure, including the Pinal West Substation, ensuring no additional burden on public resources. 3.3 Requiring Public Improvements to Roads, Sewers, or Water Systems that are Needed to Support the Planned Land Uses No public improvements to roads, sewers, or water systems on lands administered by Maricopa County would be needed as a result of the Project. Water hauled to and stored on-site would be from permitted sources and stored on lands administered by the BLM. Any proposed road construction needed to access the Project would be constructed and paid for by the Applicant, in coordination with applicable agencies and would not require public expenditures. 3.4 Adversely Impacting Planned Uses Because of Increased Traffic Traffic in the Project area would be minimally impacted. Traffic would mildly increase during the relatively short construction period due to the delivery of equipment/supplies and the commuting of the construction workforce. However, no notable increase in traffic during the operation and maintenance of the Project would occur. A traffic impact analysis was prepared for the proposed Project as part of the BLM’s NEPA process to assess the potential impact on roadway and intersection level of services during the Project’s construction and operation. Based on this analysis, all intersections are projected to operate with minimal to no delays during construction and operations. The analysis determined that no additional turn lanes would be necessary, and the existing transportation infrastructure would adequately support the anticipated traffic demand associated with the Project. 3.5 Affecting the Livability of the Area or Health or Safety of Present and Future Residents The Project would not create any adverse effects on the livability of the area or health and safety of present and future residents. The Project’s design, construction, operation, maintenance, and decommissioning would meet or exceed requirements of the National Electrical Safety Code and U.S. Department of labor Occupational Safety and Health Administration (OSHA) standards. The Project would not use or store hazardous materials on Maricopa County administered lands, generate substantial emissions, or have other potential negative effects on health and safety. Fugitive dust emissions would be reduced through water application to disturbed areas, in compliance with the Maricopa County Rule 310 for Fugitive Dust from Dust-Generation Operations and managed by a trained dust control coordinator. The Project contemplated by this amendment is located near other proposed solar facilities and already constructed substations and transmission lines, making the Project location and efficient development pattern since it is near an area already containing several transmission and distribution facilities. No current residential developments are planned for this area. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 10 3.6 Adversely Impacting the Natural Environment or Scenic Quality of the Area in Contradiction to the Plan The Project would have minimal impacts on the natural environment and scenic quality of the area due to its location and the presence of existing energy and utility infrastructure. Situated south of State Route 238, west of State Route 347, and north of Interstate 8, the Project will largely be obscured from view by travelers along these major routes. In instances where the facility is visible, such views will be brief and are anticipated to have a negligible effect on the overall scenic quality of the landscape. Potential scenic impacts could be experienced by travelers along local roads and to dispersed recreational users in the SDNM, as well as those exploring the surrounding Palo Verde Mountains, Estrella Mountains, Maricopa Mountains, Booth Hills, and Tabletop Wilderness area. While the Project may introduce utility elements into the natural landscape, it remains consistent with existing energy infrastructure in the area. Additionally, visual studies for the Project as part of the BLM’s NEPA process have determined the impact would be low due to surrounding vegetation and topography. Beyond visual impacts, the Project’s development could affect the surrounding natural environment by altering local habitats and contributing to temporary disturbances during construction. Land clearing for solar panels and infrastructure may result in vegetation loss and habitat fragmentation. Additionally, soil erosion and changes in drainage patterns could impact local hydrology. The applicant has conducted multiple surveys and studies to assess the project area and surrounding environment. These studies are described in more detail in Section 6. Additionally, through coordination with multiple agencies, the applicant has committed to numerous design features and mitigation measures to avoid, minimize, and mitigate potential impacts to the surrounding environment, as described in Appendix A. 4 WHETHER THE AMENDMENT (OR CONDITIONAL MODIFICATION) IS CONSISTENT WITH THE OVERALL INTENT OF THE COMPREHENSIVE PLAN The overall intent of the Vision 2030 Plan is based on three core principles. These principles also guide Maricopa County’s decisions regarding future development and detail when changes to this plan are justified: 1) Decisions should support implementation of Maricopa County’s mission statement and strategic priorities; 2) Maintain a disciplined approach where comprehensive plan policies and growth- related decisions are understandable, measurable, consistent, practical and promote efficiency (land use decisions are also based on these factors); and 3) Avoid future problems by carefully considering past decisions. The policies and recommendations in the Vision 2030 plan are based on these principles. Since the Project adheres to the overall elements, goals, and policies of the Vision 2030 plan (see Section 5). The Project aligns with the principles outlined in the Vision 2030 Plan for Maricopa County. First, the Project supports the county’s mission to foster sustainable development and improve the quality of life for residents. By introducing a 300-megawatt solar photovoltaic facility, the project contributes to Maricopa County’s energy needs through clean, renewable energy, directly supporting the county’s environmental goals and reducing dependence on non-renewable energy sources. This renewable energy initiative is consistent with the county’s commitment to long-term sustainability and the responsible use of resources. Additionally, the Project reflects the Vision 2030 Plan’s emphasis on a disciplined, efficient approach to land use and growth. The CPA for the 241 acres of private land ensures that the area is appropriately Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 11 designated for utility use, a necessary step to accommodate utility-scale solar development. The project’s design adheres to the county’s goal of ensuring that development is clear, consistent, and useful. The selected site minimizes potential conflicts with natural and cultural resources, which aligns with the county’s commitment to making growth related decisions that promote environmental protection and the well-being of residents. Finally, by coordinating with federal, state, and local agencies, the project ensures that it adheres to the best practices and avoids potential issues associated with previous developments. The Project also supports both economic development and sustainable growth by including 400 employees for the construction phase and five permanent staff members during operation. With this, the Project is fully consistent with the Vision 2030 Plan, which seeks to balance growth, sustainability, and the efficient use of resources for the long-term benefit of Maricopa County. 5 THE EXTENT TO WHICH THE AMENDMENT (OR CONDITIONAL MODIFICATION) IS CONSISTENT WITH THE SPECIFIC GOALS AND POLICIES CONTAINED WITHIN THE PLAN 5.1 Vision 2030 Comprehensive Plan The following sections detail the Vision 2030 Comprehensive Plan Elements’ goals and policies that align with the Pinyon Solar Project. 5.1.1 Land Use Goals: 1. Achieve balanced and efficient development patterns. The amendment will be consistent with this goal as it will be compatible with adjacent uses, will have no long-term effects on the efficiency of the transportation system, and would be a balanced land use decision as there are no sensitive natural environmental features, and minimal impacts to federal and state sensitive species (see Environmental Policy #5 under Section 5.3). Additionally, the Pinyon Solar Project is located near several other solar facilities, substations, transmission lines, gas pipelines, and the BLM-designated Section 368 corridor (see Figure 3), making the Project location and efficient development pattern since it is near an area already containing several electrical generation, transmission, and distribution facilities. The proposed Project (i.e., a solar facility) contemplated by the amendment requires a large amount of flat land with minimal topographic variation. The proposed Project site is compatible with this land use because the area is a large amount of flat land and in a rural, undeveloped setting and is surrounded by undeveloped or utility infrastructure. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 12 Figure 3. Pinyon Solar Project existing infrastructure. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 13 Land Use Policy: 10. Maricopa County supports coordinated planning efforts between local, state and federal agencies. The majority of the Pinyon Solar Project (1,788 acres) is located on lands managed by the BLM LSFO. Additionally, the portion of the Project in unincorporated Maricopa County (241 acres) contemplated by this amendment is located entirely on private lands. Coordination with other agencies is described in Section 7. 15. Maricopa County supports evaluating comprehensive plan amendments and zoning district changes to determine the existence of the urban services and infrastructure identified in this element. The Pinyon Solar Project is near several high-voltage transmission lines and is approximately 2.8 miles west of the substation that would serve as the point of interconnection, making the Project area an appropriate location for this type of facility, as existing infrastructure is compatible with this type of development. Other proposed solar facilities are near the Project, as well. The Project would include a single-story O&M facility (expected to be adjacent to the Project substation. The O&M facility would be equipped with heating, ventilation, and air conditioning systems. The facility would also be equipped with interior lighting and fire alarms and would comply with local fire codes. The Applicant anticipates water is expected be hauled to the site during construction and operation and stored on BLM-administered lands to support fire suppression systems. If a septic system is required for the O&M facility, the Applicant will obtain applicable permits. Fire ignitions within the Phoenix Fire District are routed through the Arizona Interagency Dispatch Center and would provide fire and emergency medical services to the Project area through subscription or district incorporation, and the Maricopa County Sheriff’s Department provides law enforcement service to the Project area. The Applicant will coordinate further with the Phoenix Fire District and/or Goodyear Fire District to determine how best to serve the site with fire and emergency medical services. Therefore, existing infrastructure and urban services can support this type of proposed development. 22. Maricopa County supports reducing the impacts of new development on environmentally sensitive areas, including native flora and fauna habitat and corridors. The Project area is mainly mapped as having native vegetation characteristic of the Sonoran/Mohave Desert Scrub biome. The Applicant will comply with applicable federal, state, and local laws, regulations, and guidelines as required to avoid, minimize, and mitigate the impacts to the wildlife habitat present in the Project area. The project will be constructed with open areas to avoid existing washes. These open areas will provide wildlife and habitat corridors through the Project area. Additional discussions regarding these resources, agency coordination, and mitigation measures are provided in Sections 6 and 7. 33. Maricopa County supports land use buffers and compatible land use strategies near existing and future high voltage electric utility line corridors. One of the reasons the Project location was identified was due to the close proximity to the Pinal West Substation, in which Pinyon Solar will interconnect, along with the existing transmission line, railroad, oil and gas, and solar facilities in the area. The Project is compatible with these existing electrical generation and transmission facilities and was sited in proximity to these facilities based on Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 14 this compatibility and as a strategy to limit the need for additional new transmission and/or substation infrastructure. 5.2 Transportation Transportation Policy: 1. As necessary, Maricopa County supports preserving future road alignments, called for in county- recognized transportation plans, especially mid-section line, section line and arterial roads; parkways; freeways; and interchanges. The Project will not impact any freeways or interchanges and both 83rd Ave and Schumacher Lane will continue to be publicly accessible throughout the life of the Project. The Applicant will continue to work with applicable agencies to maintain public access to the surrounding area. 5.3 Environment Environment 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. Air quality impacts resulting from fugitive dust emissions would be minimal throughout the construction process as a fugitive dust plan will be implemented and a monitor on-site. However, dust/dirt would affect the performance of the solar panels. Therefore, after development of the solar fields, areas not directly utilized for solar energy infrastructure would be revegetated with native salvaged plants to reduce erosion of topsoils and dirt. In addition to minimizing the effects this dust would have on the solar panels, this would also reduce the amount of fugitive dust from these lands that could affect local air quality. 3. To help protect water quality Maricopa County supports compliance with its Drinking Water program and its Water and Wastewater Treatment program. The Applicant anticipates no need for sewer facilities, and water is expected be hauled to the site during construction and operation and stored on BLM-administered lands. The Applicant will comply with the Drinking Water program and Water and Wastewater Treatment program, as necessary. 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 has been in discussion with multiple agencies on how to avoid and mitigate potential impacts to habitat and migration corridors, as described in Sections 6 and 7. The applicant will comply with all applicable federal and state laws, regulations, and guidelines regarding the protection of plant and animal species, habitat, and migration corridors. The Applicant has committed to preliminary mitigation measures to reduce, minimize, and eliminate impacts to wildlife, vegetation, and the surrounding environment as described in Appendix A. 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. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 15 The Applicant has completed desktop and field-based reviews of cultural, biological, and water resources for the Project, as described in Section 6. Additionally, the applicant has been in discussion and coordination with multiple agencies regarding these resources as described in Section 7. These discussions have resulted in multiple design features, mitigation measures, and best management practices as described in Appendix A. It is anticipated that these coordination and compliance efforts will ensure that the impacts to cultural, biological, and water resources on the Project site are sufficiently avoided, minimized, and mitigated. 7. Where necessary Maricopa County supports noise reductions in new development design and in the construction of new buildings. The Project would generate noise during construction; however, there are no sensitive noise receptors near the proposed facility, and the nearest residence is approximately 1 mile west of the Project and includes several scattered, rural residences. Construction activities are anticipated to produce short- term noise increases at the site over the existing ambient noise levels. Noise reduction devices, such as mufflers, shall be utilized to minimize impacts on wildlife and special status species populations. Where feasible, low-noise systems shall be incorporated into equipment, including ventilation systems, pumps, generators, compressors, and fans, with a preference for models that do not produce prominent discrete tones. The BLM NEPA process will inform all noise reduction efforts and will be documented in the Environmental Assessment that will be posted to the federal register. Once construction is completed, the project will have minimal noise disturbance. Solar PV projects have limited moving parts and therefore produce very little noise. 5.4 Economic Growth Goals: 1. Contribute to an effective regional economy. The Applicant estimates that up to approximately 500 construction employees are expected over the course of Project construction. The Applicant would operate the Project with up to approximately five permanent, full-time, remote staff. These construction and operational jobs as well as tax revenue from the Project would help contribute to the regional economy. Economic Growth Policy: 10. Maricopa County supports leveraging its solar resource potential to attract solar-related industries and alternative energy research and development. The proposed Project being contemplated by this amendment (i.e., a solar generation facility) directly supports this economic growth policy. 5.5 Open Space Goals: 1. Provide regional leadership to promote environmental quality, including the preservation of open, natural park and recreation lands. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 16 The Project area does not contain any formal parks, designated open space, recreational lands, or trails. While the Project is directly adjacent to SDNM, it does not encroach upon or alter the monument’s boundaries, ensuring no direct impact on its ecological integrity or recreational value. Additionally, no formal open space uses are known to occur on this land, and there have been no public proposals submitted to the BLM for its designation as protected or recreational space. Refer to Section 6 for additional details. 5.6 Water Resources 5. Maricopa County supports low water use solar electric generating technologies. This Project utilizes PV solar technology, which requires little water except for maintenance for cleaning the solar panels and equipment and for dust abatement during construction activities. Once operational, it is anticipated that the Project will not exceed 20 acre-feet of water per year for panel maintenance. Water for panel maintenance would be sourced from commercial suppliers and trucked to the site to a storage tank. No groundwater from the site would be used. 5.7 Energy Goals: 2. Make Maricopa County a leader in alternative energy research and development. The Pinyon Solar Project would help Maricopa County fulfill this goal because a solar generation facility is a form of renewable, alternative energy development. Energy Policy: 6. Maricopa County supports being a responsible leader in alternative energy research and development. The Pinyon Solar Project would help Maricopa County fulfill this Vision 2030 goal because a solar generation facility is a form of renewable, alternative energy development and would be sited at a compatible location that has minimal conflict with environmental resources on-site and is surrounded by similar land use types (i.e., electrical transmission and distribution) as the proposed Project. 7. Maricopa County supports efforts to assist businesses and individuals with renewable energy options and energy conservation. The Pinyon Solar Project would help Maricopa County fulfill this goal because a solar generation facility would provide businesses and individuals with additional opportunities to use renewable energy. 5.8 Cost of Development Goals: 2. New development pays its proper and reasonable share of the costs of new infrastructure, services and other public improvements. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 17 The Project will not require new infrastructure, services, and other public improvements. If any infrastructure improvements are required as a result of the Project, the Applicant is fully committed to covering the entire cost of those improvements. While no Project-related public expenditures are proposed or anticipated, the Applicant will develop short, internal access roads to portions of the site for internal maintenance and security activities. These internal roads will be constructed with aggregate material. Any proposed road construction or improvements needed to safely access the Project would be constructed and paid for by the Applicant, in coordination with ADOT and MCDOT as necessary, and would not require public expenditure. 6 RESOURCE PROTECTION 6.1 Access and Traffic Access to the Project area will be via the existing road network, primarily South 83rd Ave, Schumacher Lane, and Fulcar Road. Within the solar facility, new 20-foot-wide permanent aggregate-base roads would be constructed to provide vehicle access. Additionally, minor improvements to portions of the existing routes (such as vegetation removal and movement of rocks and boulders) would be required to accommodate the transport of Project equipment to the solar facility. After construction, the Project applicant would continue to use access roads during O&M and decommissioning. These routes could require repair on an infrequent basis, which would be conducted by the applicant. The applicant is currently working with the BLM to determine the finalized use and layout of BLM roads within the Project area. However, the applicant is committed to maintaining access for surrounding landowners and the public. As part of this approach, Schumacher Lane and 83rd Avenue would remain open and accessible to the public during construction and operation. The Project could result in an average increase of 900 vehicle trips (or 450 roundtrips) per day and a maximum of 1,100 vehicle trips (or 550 roundtrips) per day during construction. The length of construction period would be impacted by phasing, but it is anticipated to last between 12-18 months per phase. During operations, site visits would be on an infrequent and as-needed basis and would not consistently affect daily traffic patterns in the vicinity. A traffic impact analysis was prepared for the proposed Project to assess the potential impact on roadway and intersection level of services during the Project’s construction and operation. Based on this analysis, all intersections are projected to operate with minimal to no delays during construction and operations. The analysis determined that no additional turn lanes would be necessary, and the existing transportation infrastructure would adequately support the anticipated traffic demand associated with the Project. 6.2 Vegetation Vegetation surveys were conducted for the entire Project area in 2023 and were reassessed in 2024. The most dominant perennial species across all survey plots was the shrub creosote. No protected plant species were identified during survey, however, stinknet (Oncosiphon piluliferum) and Sahara mustard (Brassica tournefortii) are in the Project area, both of which are classified as Arizona Department of Agriculture-listed noxious weeds. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 18 During construction and operations, the applicant would use biological monitors to identify potential protected species and implement invasive weed management strategies, including those identified in the Appendix A. If protected species or noxious weeds are documented during any phase of the project, they will be managed based on direction from the BLM, Arizona Department of Agriculture, or applicable regulatory agency. Species protected under the Arizona Native Plant Law would be avoided in construction areas, where practicable. Salvage-restricted plants that construction cannot avoid would be made available for salvage in a manner consistent with the Arizona Native Plant Law and in coordination with the Arizona Department of Agriculture, as applicable. 6.3 Wildlife Wildlife surveys were conducted for the entire project area in 2023. No federally protected species were documented within the project area. One BLM Arizona special status species, Le Conte’s thrasher (Toxostoma lecontei) was documented during these surveys. Additionally, while their presence was not documented, suitable habitat was observed for multiple protected wildlife species and migratory birds. To avoid impacts during construction and operations, the applicant has committed to using trained biological monitors before, during, and after construction to identify and avoid potential protected wildlife species. If these species are observed, the response will be managed based on guidance from the BLM, AZGFD, USFWS, or other appropriate agency. Additional design features and mitigation measures to protect wildlife species are described in Appendix A. As part of the federal review process required for the BLM ROW grant, the Project is currently undergoing Section 7 consultation through the USFWS to review impacts to federally protected species and their habitat in the project area. This process is discussed in additional detail in Section 7.4. 6.4 Cultural and Historic Resources Cultural resource surveys were conducted for the Project area in 2022 and 2023. Additionally, in 2024, a cultural resources assessment was conducted for the entire area of potential effect, which includes areas that may be directly and indirectly impacted by the project. These studies identified nine cultural resource sites within the Project construction footprint. Of the nine sites within the construction footprint, five are attributed to prehistoric land use, three are attributed to historical land use, and one is a rock feature of unknown cultural affiliation that could not be relocated. Seven of the sites within the construction footprint were recommended as not eligible for inclusion on the National Register of Historic Places, based on previous studies. One of the two remaining sites, one is not eligible for inclusion based on additional review and the other site will be avoided by the project. In addition to avoiding the one potentially eligible site, the Project applicant will have cultural resource monitors during construction activities to identify and avoid any sites that may have been missed or exposed during construction activities. These mitigation measures are included in the mitigation measures provided in Appendix A. Additional discussion regarding consultation and coordination with the State SHPO and THPO are include in the Section 7.3. 6.5 Water Resources Aquatic resource surveys were conducted for the project area in 2022 and did not identify any potentially jurisdictional wetlands or waterbodies in the project area. However, several ephemeral washes are adjacent to or bisect the Project area from south to north. These include Waterman wash and multiple Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 19 unnamed washes. These ephemeral washes consist of narrow and shallow sand bottoms with spare vegetation along the overbanks. Additionally, FEMA floodplains bisect and are adjacent to the solar facility. These floodplains are designated as Zone A, meaning no depths or base flood elevations are defined. The applicant has designed the project to avoid locating any structures within the mapped floodplains. Mitigation measures to protect and minimize impacts to the ephemeral washes, floodplains, and surrounding environment are provided in Appendix A. 6.6 Sonoran Desert National Monument and Recreation The Project area is adjacent to the Booth Hills area of the Sonoran Desert National Monument (SDNM), managed by the BLM. The monument, and surrounding BLM lands, provides dispersed recreation and wildlife-based recreational opportunities through motorized and nonmotorized means. Recreational uses within the monument include camping, hiking, horseback riding, hunting, OHV riding, mountain biking, wildlife viewing, stargazing, and recreational target shooting. The primary recreational activities in and around the Project area include dispersed recreational target shooting and OHV riding on BLM-managed lands The project applicant, in coordination with the BLM, is committed to allowing public access in the area to allow continued use of the SDMN and surrounding public lands. Additionally, visual studies for the project have determined the impact would be low due to surrounding vegetation and topography. Impacts to the SDMN and recreation on surrounding public lands, are reviewed and assessed by the BLM during the NEPA process described in Section 7.2. If the BLM identifies additional design features or mitigation measures necessary to address potential impacts to these areas, they will be incorporated into the project and added to the mitigation measures provided in Appendix A. 7 AGENCY COORDINATION AND MITIGATION MEASURES The Pinyon Solar project crosses multiple jurisdictional areas which requires discussion, coordination, and permitting through numerous agencies. The section below describes these discussions that have occurred to date and are ongoing. These discussions have all included the entire project footprint and surrounding areas, including the private lands in Maricopa County. 7.1 City of Goodyear The Applicant has had multiple meetings with the City of Goodyear during designing and permitting the Project. On April 2, 2025 the applicant had a meeting with Katie Wilken, Development Services Director for the City of Goodyear. Ms. Wilken confirmed during that meeting and subsequent email correspondence that Goodyear would not be implementing land use permitting or zoning requirements on federal lands. Additionally, the project received a Zoning Verification Letter from the City of Goodyear on July 10, 2025, confirming no SUP would be required for the project as the property is entirely on BLM lands within the City boundary. A copy of this determination is included with this application package. The Applicant will continue to work with Goodyear on topics such as access, road maintenance, emergency services, and other applicable issues. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 20 7.2 Pinal County The Applicant attended a Concept Review meeting with Pinal County on September 10, 2024. The county confirmed that utility transmission lines are a use by right in any zoning area and, therefore, no additional land use or zoning permits would be required for the project as currently designed. The Applicant will continue to keep the county updated on the project as it moves forward. 7.3 BLM The project will require a ROW grant from the BLM for the federal lands associated with the project. The project is undergoing detailed review under the National Environmental Policy Act (NEPA) through the development of an Environmental Assessment (EA) document. The EA will be published for public review in the spring of 2025. As part of the NEPA process, the project went through a scoping process which provided an opportunity for members of the public and agencies to learn about a proposed project and share their concerns. The BLM initiated the public scoping process for the EA by sending letters to stakeholders and the interested public requesting public comments concerning identification of potential alternatives, information, and analyses relevant to the Project. Comment submissions were accepted during the 30-day scoping period, which was between January 30, 2024, and February 29, 2024, via US mail or through direct submission of comments to the ePlanning page. As part of the scoping process, the BLM hosted one in-person meeting in Maricopa, Arizona, on February 1, 2024 and one virtual public meeting on January 30, 2024. The BLM also held discussions with agencies and interested stakeholders following the formal scoping process to further refine the issues and alternatives for analysis in this EA. During this period, the BLM received nine comment letters from the public, including the Arizona Game and Fish Department (AZGFD) and Maricopa County. These comments and on-going discussions with agencies have been incorporated into the project design, review, and mitigation measures provided in Appendix A. The BLM confirmed with the Applicant on March 11, 2025 that they will not require entitlements and permits from the local permitting authorities for the project area within their jurisdiction. A copy of this correspondence with the BLM is provided with this application package. 7.3.1 Additional Consultation and Coordination with Agencies and Tribal Governments The BLM contacted agencies that have jurisdiction or special expertise, or both, in the Project area prior to scoping, at the start of scoping, and the duration of the NEPA process. This gives the agencies or tribal governments the opportunity to weigh in on the project throughout the entire review process. A list of agencies and governments that are involved in this process is provided below. Agency or Tribe Ak-Chin Indian Community Federal Aviation Administration Arizona Association of Conservation Districts Fort McDowell Yavapai Nation Arizona Department of Environmental Quality Fort Mojave Indian Tribe of Arizona ADOT Fort Yuma Quechan Indian Tribe Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 21 Agency or Tribe Arizona Department of Water Resources Gila River Indian Community Arizona Ecological Services, USFWS Hopi Tribe of Arizona AZGFD Region IV Maricopa County ASLD Pascua Yaqui Tribe Arizona State Senate, District 23 Pinal County Arizona State Historic Preservation Office Pueblo of Zuni Bureau of Reclamation Salt River Pima-Maricopa Indian Community Chemehuevi Indian Tribe Tohono O'odham Nation City of Buckeye US Army Corps of Engineers City of Goodyear EPA Region 9 City of Maricopa USFWS Cocopah Indian Tribe Yavapai-Apache Nation Colorado River Indian Tribes of the Colorado River Indian Reservation Yavapai-Prescott Indian Tribe 7.4 SHPO and THPO Consultations Section 106 (54 USC 306108) of the NHPA requires federal agencies to consider the effects of their undertakings. The regulations also specify the need for meaningful consultation with the Arizona State Historic Preservation Office (SHPO), Tribal Historic Preservation Offices (THPO), Native American tribes, and other interested parties during all phases of Section 106 compliance. The BLM initiated Section 106 consultation through a letter to the State Historic Preservation Office and Native American tribes on October 26, 2022, and will finalize consultation prior to issuance of a decision. Consultation with the SHPO, THPO, the applicant, and the applicant’s consultant have been continual throughout the project and the project has been designed to avoid areas of known or potential cultural resources. 7.5 US Fish and Wildlife Coordination The BLM has submitted a request to initiate consultation with the US Fish and Wildlife Service (USFWS) under the Endangered Species Act for potential effects on March 7, 2025. Consultation will be completed prior to the BLM’s issuance of a decision. Prior to this request, numerous discussions have occurred between the USFWs, the BLM, the applicant, and the applicant’s consultant to identify potential issues early in the review process and implement appropriate design modifications to avoid or lessen impacts, as provided in Appendix A. 7.6 US Army Corps of Engineers The US Army Corps of Engineers (USACE) reviews and manages impacts to wetlands and waterbodies considered waters of the US (WOTUS). As no potential WOTUS features were identified during field surveys, an Approved Jurisdictional Determination (AJD) request was prepared for the Project for and submitted to the USACE in June 2024. The AJD concluded that none of the onsite surface water features would be considered waters of the U.S. (WOTUS) under the current rule. Recent correspondence from the USACE has indicated that they have completed the review of the AJD and anticipate sending a No Permit Required letter for the Project. Pinyon Solar Project Application for a General Comprehensive Plan Amendment Narrative Report 22 7.7 Mitigation Measures As part of the agency coordination process described above, the applicant has compiled a list of design features, best management practices, and other environmental protection measures that will be applied to the project. These measures are currently in draft form and may be modified during ongoing discussion with applicable agencies. A list of these draft measures is provided in Appendix A. 8 LITERATURE CITED Maricopa County. 2016. Vision 2030 Comprehensive Plan. Available at: https://www.maricopa.gov/DocumentCenter/View/6756/Comprehensive-Plan---Vision-2030- Plan-PDF?bidId=. Accessed August 17, 2024. WestLand Engineering & Environmental Services. 2023. Pinyon Solar Project Approved Jurisdictional Determination Maricopa and Pinal Counties, Arizona. June 16, 2023. WestLand Project Number: 10495. WestLand. 2024. Pinyon Solar Project. 2024 Baseline Biological Resources Report. Prepared by Westland Engineering and Environmental Services. Tucson, Arizona July 29, 2024 2 APPENDIX BLM and City of Goodyear Entitlement Documentation From: Lindsey, Tyler J To: Colin Mann Cc: Eli Murrey; Elliott Casper; Ellison Etnier Subject: Re: [EXTERNAL] Pinyon Solar - Maricopa County entitlements Date: Monday, March 10, 2025 11:55:35 AM Attachments: image002.png Outlook-rukgmqwh.png Outlook-g42rrls1.png Outlook-qrcodeWith.png Hi Colin, Thank you for your question. BLM suggest that Avantus follow all County and local government laws and requirements as it relates to potential future project development. BLM is not requesting from Avantus any additional zoning or entitlement requirements on Federal Lands, just what the County deems necessary for development on private lands. If you need anything else, please let me know. I am always happy to have a short meeting to discuss if needed. Tyler Lindsey Project Manager Phoenix District Office Bureau of Land Management Phoenix District Office 480-259-7436 My Digital Business Card Connect with me From: Colin Mann <cmann@avantus.com> Sent: Monday, March 10, 2025 10:34 AM To: Lindsey, Tyler J <tlindsey@blm.gov> Cc: Eli Murrey <emurrey@avantus.com>; Elliott Casper <ecasper@avantus.com>; Ellison Etnier <eetnier@avantus.com> Subject: [EXTERNAL] Pinyon Solar - Maricopa County entitlements This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding. Tyler, As discussed, we are working with Maricopa County on their land use permitting requirements for our Pinyon Solar Project. They have requested we provide confirmation from the BLM that you are not anticipating or requiring county entitlements over lands managed by the BLM - only the private lands associated with the project. While I wasn’t on the project at the time, the correspondence I could find on this topic came during the public scoping period. The county was noticed as part of the process and provided the following response: “Please be advised that proper entitlements will need to be sought through Maricopa County Planning and Development Department for the 241 acres located within privately-owned property within unincorporated Maricopa County.” I have attached a copy of the Scoping Report with this comment. Based on this guidance, we have been moving forward with county entitlement permitting on the privately owned property only. However, I wanted to confirm with you. Is the BLM is requiring additional county entitlements across the BLM lands on the project? Let me know if you have any questions or would like to discuss further. Thanks, Tyler. Colin Colin Mann DIRECTOR, PERMITTING (303) 817-1229 MOBILE cmann@avantus.com avantus.com 8minute is now Avantus NOTICE: This message is intended only for the use of the individual(s) named above, and may be attorney/client privileged and confidential. If you are not the intended recipient, please notify the sender at the telephone number above and delete this e-mail. Any unauthorized use, distribution or reproduction of this message and any attachment is strictly prohibited and may be unlawful. City of Goodyear Development Services Department, Planning and Zoning Division 1900 North Civic Square goodyearaz.gov Goodyear, Arizona 85395 623-932-3004 July 10, 2025 Colin Mann Avantus 4370 Town Center Blvd, Suite 110 El Dorado Hills, CA, 95762 RE: Zoning Verification Letter Case No. P25-00162 Generally Located West of South 83rd Avenue and North of West Schumacher Lane Section 3, Township 5 South, Range 1 East Dear Colin Mann: This letter is in response to your request for a Zoning Verification Letter for the above referenced property. The current zoning of the property is AG (Agriculture). The AG (Agriculture) zoning was approved on March 26, 2007 with the adoption of Ordinance No. 2007-1063. The property is subject to the uses and development standards as established in the City of Goodyear AG (Agriculture) zoning district. The permitted uses and development standards for this zoning district can be found in the City’s Zoning Ordinance Articles 3-2-2, and 3-2-3: https://goodyear.municipal.codes/ZoningOrds/3-2-2, https://goodyear.municipal.codes/ZoningOrds/3-2-3. There are no variances applicable to the parcel. There are no open zoning or building code violations on the subject property at this time. A copy of Ordinance No. 2007-1063 is attached. The question submitted below with the zoning verification letter request has been answered below: Applicant Question 1: Subject property requesting Zoning Verification and confirmation of no SUP required? Staff Response 1: Zoning verification is provided above. Based on the property being entirely located on BLM property, there will be no Special Use Permit process required. For copies of code violation cases, and other records, please use the online Public Records Request form. If you need additional information, please contact me at 623-882-7067 or Kevin.Duran@goodyearaz.gov. Sincerely, THE CITY OF GOODYEAR Kevin Duran Assistant Planner Revised July 2025 ZONE CHANGE WITH OVERLAY (CASE NO. Z240026) PINYON SOLAR PROJECT NARRATIVE REPORT Original Submittal December 20, 2024 Second Submittal June 3, 2025 Third Submittal July 18, 2025 Prepared by SWCA Environmental Consultants 257 East 200 South, Suite 200 Salt Lake City, Utah 84111 (801) 322-4307 www.swca.com On Behalf of 265BH 8me LLC 4370 Town Center Boulevard, Suite 110 El Dorado Hills, CA 95762 (303) 817-1229 Attn: Colin Mann Project Vicinity Map Pinyon Solar Project Application for a Zone Change with Overlay Narrative Report i CONTENTS 1 Title Page ............................................................................................................................................... 1 2 Purpose of Request ............................................................................................................................... 1 3 Description of Proposal ........................................................................................................................ 1 3.1 Decommissioning ......................................................................................................................... 2 3.2 Mitigation Measures and BMP Plans ........................................................................................... 6 4 Relationship to Surrounding Properties............................................................................................. 6 5 Location and Accessibility ................................................................................................................... 6 6 Circulation System ............................................................................................................................... 7 7 Development Schedule ......................................................................................................................... 7 8 Community Facilities and Services ..................................................................................................... 8 9 Public Utilities and Services ................................................................................................................ 8 10 Compliance with County General Plan .............................................................................................. 8 11 Proposed Standards ........................................................................................................................... 12 11.1 Site Enclosure and Screening ..................................................................................................... 12 11.2 Paved Parking Areas ................................................................................................................... 12 11.3 Lot Coverage .............................................................................................................................. 13 Figures Figure 1. Pinyon Solar Project location. ....................................................................................................... 4 Figure 2. Pinyon Solar Project Land ownership and jurisdiction. ................................................................ 5 Figure 3. Pinyon Solar Project existing zoning districts. ............................................................................ 10 Figure 4. Pinyon Solar Project proposed zoning districts. .......................................................................... 11 Appendices APPENDIX A Site Photographs and Figures APPENDIX B Citizen Participation Plan APPENDIX C Copies of Application Materials APPENDIX D Design Features, BMPs, and Other Environmental Protection Measures APPENDIX E BLM Entitlement Documentation 1 TITLE PAGE This Narrative Report addresses the information required to support the request for a Zone Change with Overlay for the Pinyon Solar Project (Project). Project Name: Pinyon Solar Project General Location: Approximately 10 miles west of the City of Maricopa and 2 miles south of State Route 238 Case Number: Z240026 Vicinity Map: Figure 1 depicts the Project area, which consists of approximately 241 acres of private lands in unincorporated Maricopa County, Arizona, and up to 1,788 acres of public lands administered by the Bureau of Land Management (BLM) 2 PURPOSE OF REQUEST 265BH 8me LLC (Applicant), a subsidiary of Avantus Clean Energy LLC, is requesting a Zone Change with Overlay from zoning district Rural 190 (RU-190) to Light Industrial with Industrial Unit Plan of Development (IND-2 IUPD) for the 241-acre portion of the Project area subject to the jurisdiction of Maricopa County (Application area). The Project is not a permitted use within the RU-190 zoning designation. The IUPD overlay will limit uses to utility scale solar generation and ancillary buildings typical with construction of this type including solar photovoltaic (PV) panels, battery energy storage system (BESS), access roads, operation and maintenance (O&M) building, and a Project substation. Within the 241-acres of this application, only PV panels will be constructed. Other equipment will be in the project area on Bureau of Land Management (BLM) lands. A Plan of Development will be developed and submitted to Maricopa County and processed separately for a site plan review. Additionally, the Applicant has submitted a General Comprehensive Plan Amendment (GCPA), case number CPA240008, to Maricopa County Planning and Development Department with the intent to complete the GCPA and Zone Change with Overlay processes concurrently. 3 DESCRIPTION OF PROPOSAL The Applicant proposes to construct, operate, maintain, and eventually decommission (see Section 3.1 for additional details) a solar generation facility. The Project includes an up to 300-megawatt (MW) alternating current solar photovoltaic (PV) power-generating facility, BESS, access roads, O&M building, Project substation, and other ancillary components. The Applicant would also construct, operate, maintain, and decommission a 345-kilovolt (kV) electrical generation interconnection transmission line (gen-tie) in Maricopa and Pinal Counties (see Figures 1 and 2). The gen-tie would originate at the Project substation and proceed eastward across private lands for approximately 2.8 miles to the existing Tucson Electric Power (TEP) 345 kV terminal at the Pinal West Substation. The PV generating facility would include multiple solar arrays, comprised of parallel strings of PV solar modules installed on rows of rotating single-axis trackers, inverter stations, and enclosed or canopied transformers. The solar arrays would be repeated as necessary to provide up to 300 MW of power- generating capacity. Access roads secured by gates would be developed throughout the Project area to access the arrays. Collector lines would be installed underground to transfer energy from the solar modules to the on-site Project substation. At the on-site Project substation, electricity would be stepped up from 34.5 to 345 kV for delivery to the Pinal West Substation via the gen-tie. The Project substation would occupy approximately three acres in the southeast corner of the Project area. The BESS facility would occupy an area up to 24 acres near the Project substation and would consist of equipment housed in stackable metal structures, typically no more than 15 feet in height from grade. The O&M building would be a prefabricated structure sited near the Project substation. Security fencing would be installed around the Project perimeter at a height of 8 feet, including 7 feet of chain link and 1 foot of barbed wire. As practicable, fences would be constructed in accordance with AZGFD Wildlife Compatible Fencing Guidelines, raised 6 to 8 inches from the ground to allow for small wildlife permeability, and allow for natural hydrological processes including sheet flow to occur. Stormwater controls would be installed per engineering design within the Project area. Materials that would be utilized in construction of the Project structures include masonry block, cement, steel, aluminum, and glass. During construction, the on-site workforce would consist of laborers, craft workers, supervisory personnel, support personnel, and construction management personnel. Construction would require a monthly average of approximately 400 employees during each construction phase, with labor requirements peaking at approximately 500 workers. Construction would generally occur between 5:00 am and 5:00 pm, Monday through Friday, but additional hours and days could be required to complete critical construction activities. Following construction, Project operations would require up to five full-time remote workers, with no permanent staff on-site. Maintenance support staff would be on- site to conduct routine inspection and service activities scheduled monthly, quarterly, semi-annually, or annually. The Project would operate 24 hours a day, 365 days per year. The Applicant is coordinating with the US Fish and Wildlife (USFWS), AZ Department of Game and Fish (AGFD), the AZ State Historic Preservation office (SHPO), BLM, and other state and federal entities as needed to identify project design considerations that would avoid, minimize, and/or mitigate impacts to the natural environmental resources and culturally significant resources. The Applicant will comply with all applicable federal and state laws, regulations, and guidelines regarding the protection and mitigation of biological, cultural, water, and other natural resources as required. Additional details regarding studies and surveys that have been conducted for the project and coordination with agencies, is in included in the GCPA request submitted to the county. Additional design features and mitigation measures to protect environmental resources are described in Appendix D. 3.1 Decommissioning All decommissioning of transmission structures, electrical devices, equipment, and wiring/cabling would be in accordance with local, state, and federal laws. Any electrical decommissioning would include obtaining required permits and following applicable safety procedures before de-energizing, isolating, and disconnecting electrical devices, equipment, and cabling. Concrete foundations and footers would be removed to 3 feet below grade. All surface structures would be removed, and the structure sites would be cleared and graded only to the extent necessary. The method of restoration would typically consist of returning disturbed areas to their natural contour (to the extent practical), installing cross drains for erosion control, placing water bars in the road, and filling ditches using straw waddles and sediment traps. All such measures would remain in place at the conclusion of reclamation until such time that they can be removed with the agreement of the land manager or landowner and the Project applicant. Project access roads or trails would be blocked or fenced, if requested, to prevent future use by the public. Fences, gates, and cattleguards would be replaced if damaged or removed during decommissioning and restoration. All previously existing public or administrative roads would be left in a condition equal to or better than their condition prior to construction. In general, all decommissioning and subsequent maintenance activities would be conducted in a manner that would minimize disturbance of soil and vegetation. Methods of restoration when the Project is terminated would adhere to the generally accepted standard operating procedures at that time. In addition, restoration would be implemented to achieve results that will maximize reuse/recycling where possible. Figure 1. Pinyon Solar Project location. Figure 2. Pinyon Solar Project Land ownership and jurisdiction. 3.2 Mitigation Measures and BMP Plans The Project would incorporate design features and Best Management Practices (BMPs) to reduce or avoid adverse impacts on the sensitive resources. These measures are detailed in Appendix D. 4 RELATIONSHIP TO SURROUNDING PROPERTIES Lands in the Project area and surrounding areas are owned by a mix of private, state, and federal entities (see Figure 2). The majority of the Project area consists of BLM-managed lands (approximately 1,788 acres) with the far western portion of the Project located on privately owned lands (approximately 241 acres). The Applicant has submitted a Standard Form 299 and Plan of Development to the BLM Lower Sonoran Field Office to obtain a right-of-way (ROW) grant to construct the Project on BLM- managed lands. The Applicant has been coordinating with the BLM to complete the appropriate natural and cultural resources surveys to support the ROW grant applicant. In addition, the City of Goodyear and Pinal County have been consulted and are aware of the proposed use and potential impacts. The Applicant anticipates continued coordination with these jurisdictions, the BLM and other state, federal, and local agencies as needed for the successful implementation of the Project. The use of the Project area as a solar generating facility is compatible with existing electric transmission infrastructure on surrounding properties. BLM Section 368 Designated Energy Corridor 115-208 runs northwest-northeast along the northeast portion of the Project area, with high-voltage transmission lines located within this corridor. Additionally, the TEP Pinal West Substation is situated less than 2 miles east of the Project area. The location of the Project would optimize the use of existing infrastructure, creating a new source of renewable energy in the region without the need to construct new high-voltage transmission lines. The Project area and surrounding properties are characterized as rural and are predominantly undeveloped desert scrub habitat with smaller areas of rural residential land and fallow/idle cropland. The Project area also borders the Sonoran Desert National Monument (SDNM), which will be minimally affected by the Project, and public access to the monument will be minimally impacted. Additionally details about mitigation measures are detailed in Appendix D and will be more thoroughly detailed in the BLM National Environmental Policy Act (NEPA) Environmental Assessment that will be posted to the federal register. Within the entire Project area, existing property uses include recreational off-highway vehicle use and target shooting. Additional discussion regarding impacts to the SDNM and access to surrounding public lands are included in the GCPA request submitted to the county. The portions of the Project area on BLM-managed lands overlap with the Conley grazing allotment. Solar facilities can be compatible with grazing uses, and coordination with any applicable BLM grazing permittees would occur as part of the BLM ROW grant process, as required by BLM regulations and rangeland management policies. The Project would be generally compatible with the rural characteristics of surrounding properties. Once in operation, day-to-day noise and traffic would be minimal. The proposed PV technology has a high level of reliability, requires low levels of maintenance, and requires very little water for operations. 5 LOCATION AND ACCESSIBILITY The Project area is located approximately 10 miles west of the city of Maricopa and 2 miles south of State Route 238 in unincorporated Maricopa County, Arizona. The Application area is in Section 9, Township 5 South, Range 1 East, and the remaining portions of the Project area are on BLM-managed lands in Sections 2, 3, 10, and 11, Township 5 South, Range 1 East. Access to the Project would be provided via existing roads. The majority of the Project would be accessible via S 83rd Ave, W Schumacher Lane, and other local roads. Additionally, access to the southern portion of the project area will be provided via Fulcar Road and S 83rd Avenue. Access through BLM-administered lands will ultimately be limited, with continued access via W Schumacher Lane and S 83rd Avenue. Maintaining connection between W Schumacher Lane and S 83rd Avenue will require rerouting S 83rd Avenue around the Project area, pending approval and coordination with the BLM LSFO. The applicant is committed to providing continued access to areas outside the Project to members of the public and surrounding landowners. 6 CIRCULATION SYSTEM During the construction period, typical traffic would consist of trucks transporting construction materials to and from the site and construction employee vehicles. Construction traffic would adhere to a Traffic Management Plan prepared by the Applicant prior to construction start. Once in operation, the Project would not affect daily traffic patterns in the vicinity. Periodic site visits would be required for maintenance activities, but permanent on-site staff would not be required. 7 DEVELOPMENT SCHEDULE Construction of the Project and associated gen-tie is anticipated to commence in the third quarter of 2026 and last for approximately 18 months, including pre-construction, mobilization, construction and installation, commissioning and testing, and demobilization and reclamation activities. A general schedule is provided in Table 1 below. Table 1. Project Construction Process and Schedule Construction Phase Dates/Time Frames Notes Pre-construction, mobilization, and staging September to November 2026 N/A Site preparation November 2026 to March 2027 Includes constructing road improvements and parking and laydown areas, site grubbing and grading, and installation of sediment controls and basins Installation of foundations or pads for buildings, inverters, and substation January to March 2027 N/A Gen-tie access road construction February to May 2027 N/A Installation of foundations for gen-tie towers April to July 2027 N/A O&M building, collector lines, inverters, and Project substation construction March to July 2027 N/A Solar array construction April 2027 to February 2028 Includes installing posts, racking, modules, combiner boxes, and PV panels Gen-tie construction June 2027 to February 2028 Includes erecting towers and stringing conductor Control systems and fiber optic lines November 2027 to February 2028 N/A BESS construction April 2027 to February 2028 N/A Testing and commissioning January to February 2028 Includes electrical testing and energization Commercial operation date Winter 2029 N/A Demobilization and post-construction site reclamation January to March 2028 Actual end date of site reclamation to be determined in coordination with the BLM Note: The estimated schedule for completing construction and operation of Pinyon Solar is subject to change as necessary to accommodate regulatory milestones. 8 COMMUNITY FACILITIES AND SERVICES No public facilities or amenities, including formal parks, open space, recreational designated lands, or trails, are existing or proposed to be constructed within the Project area. The Project is adjacent to but does not directly impact access to or use of the Sonoran Desert National Monument. 9 PUBLIC UTILITIES AND SERVICES New urban services and infrastructure, including water and sewer connections and refuse collection, would not be required for development and operation of the Project. Operation of the facility may require infrequent cleanings to remove dirt and dust from PV panels, with water demand not expected to exceed 20 acre-feet per year. Water needs would be met by a single 10,000-gallon potable water tank installed at the O&M facility and water to fill the tank would be sourced by commercial suppliers. Portable toilets would be used for collection and disposal of sanitary waste during construction and maintenance activities. Small volumes of non-hazardous waste would be generated during construction and would be removed throughout each construction phase. Once the facility is operational, minimal waste would be generated. A fire suppression system would be installed and a Fire Protection Plan (FPP) outlining fire prevention and emergency response planning and procedures would be implemented as part of the Project. In the event of a fire incident, Project personnel would follow reporting procedures and initial fire suppression protocols identified in the FPP. Reported wildfire ignitions on BLM lands would be routed through the Arizona Interagency Dispatch Center. The Applicant will coordinate further with the Phoenix Fire District and/or Goodyear Fire District to determine how best to serve the site with fire and emergency medical services. The Maricopa County Sheriff’s Department provides law enforcement service to the Project area. Therefore, existing infrastructure and urban services can support this proposed development. 10 COMPLIANCE WITH COUNTY GENERAL PLAN The Project’s proposed use aligns with the IND-2 IUPD purpose statement in Article 902.1 of the Maricopa County Zoning Ordinance (MCZO) and will comply with its development regulations. Based on existing land uses in the area, the proposed use is suitable for the land and will not adversely impact adjacent properties or the public’s health, safety, and general welfare (see Figure 3. While the Applicant proposes removing the RU-190 zoning designation, the proposed use remains compatible with the RU- 190 purpose statement in MCZO, Article 501.1, as this zoning district is intended to discourage small-lot or residential subdivisions and developments that would significantly impact public infrastructure such as water, sewage, and the need for additional government services. The Maricopa County Vision 2030 Comprehensive Plan (Vision 2030 Plan) outlines Maricopa County’s policies and strategies for development of unincorporated areas, including the Application area (Maricopa County 2016). The overall intent of the Vision 2030 Plan is based on three core principles: 1) Decisions should support implementation of Maricopa County’s mission statement and strategic priorities; 2) Maintain a disciplined approach where comprehensive plan policies and growth-related decisions are understandable, measurable, consistent, practical and promote efficiency (land use decisions are also based on these factors); and 3) Avoid future problems by carefully considering past decisions. The Project adheres to the overall elements, goals, and policies and is consistent with the overall intent of the Vision 2030 Plan. The Application area is designated as rural use. The Vision 2030 Plan allows for the development of industrial land uses, including electric generating facilities, outside of urban growth areas, provided that the industrial use does not require urban services or infrastructure. The Vision 2030 Plan further states that Maricopa County supports low water use solar electric generating technologies. The Project meets these criteria, as discussed in previous sections. The Vision 2030 Plan acknowledges and is intended to support anticipated significant population growth in Maricopa County and considers nine growth-related topics that affect policy decisions, including the environment and energy. With rapid population growth in the region, energy demand is projected to increase significantly. The Project would contribute to meeting this rising energy need by providing a new source of renewable energy, reducing reliance on non-renewable sources. This directly supports the Vision 2030 Plan’s goals of planning for the future needs of the population while aligning with the plan’s environment and energy goals and policies. The Applicant is submitting a GCPA application to change the Application area’s land use designation in the Vision 2030 Plan from rural development to utilities, and further details of the Project’s compliance with the Vision 2030 Plan are detailed in the GCPA application report. Figure 3. Pinyon Solar Project existing zoning districts. Figure 4. Pinyon Solar Project proposed zoning districts. 11 PROPOSED STANDARDS This supplemental questionnaire section is provided in conjunction with the Applicant’s request for proposed standards that vary from the MCZO development standards listed in Table 2. Table 2. Proposed Standards Table Regulation Existing Base Zoning District Regulations (RU- 190) Base Zoning District Regulations (IND-2) Proposed Zoning District Regulations (IND-2 IUPD) Max Height 30’ 40’ 40’ Min. Front Yard Setback 60’ 10’-25’ * 10’-25’ * Min. Side Yard Setback 30’ 0’-10’ ** 0’-10’ ** Min. Rear Yard Setback 60’ 0’-25’ *** 0’-25’ *** Landscaping N/A N/A No landscaping required Min. Lot Area 190,000 SF 6,000 SF 6,000 SF Min. Lot Width 300’ 60’ 60’ Max. Lot Coverage 10% 60% 60%; solar panels not to be counted as lot coverage Parking Regulations Chapter 11, Section 1102 Chapter 11, Section 1102 None required. Paving Requirements Article 1102.7.1 Article 1102.7.1 Alternative parking/driveway surface material or method approved by Maricopa County Air Quality Department to minimize dust pollution. Site Enclosure and Screening N/A Article 902.9.3 Min 6’ wall adjacent to rural and residential zoning boundaries and for outdoor use of an industrial nature with no attached barb wire under a height of 8’ Chain link fencing and gates will be allowed at the Project perimeter. Fencing and gates will be comprised of 1 foot of barbed wire strands atop 7 feet of chain link. * 10’ abutting a local roadway; 15’ abutting a midsection roadway; 20’ abutting section line roadway; and 25’ at an intersection abutting a rural zone district. ** 5’ abutting a rural zoning district; 10’ for a corner lot abutting a rural zoning district; and 3’ if provided. *** 25’ abutting a rural zoning district 11.1 Site Enclosure and Screening The Project will be enclosed by 8-foot-high fencing and gates, comprised of 1 foot of barbed wire strands atop 7 feet of chain link. Chain link fencing is a standard for solar facilities and barbed wire is required for security purposes. Transparent fencing will not impact the viewshed and will maintain open visibility in the area. This variance in fencing standards is consistent with other approved solar facilities within Maricopa County. 11.2 Paved Parking Areas During the operational phase, vehicular access and parking at the site will be limited to periodic maintenance activities. In parking and driveway areas, the Applicant is proposing to utilize ¾ minus gravel to minimize dust pollution. This variance in paving standards is consistent with other approved solar facilities within Maricopa County. There are no planned paved parking areas proposed for the Project. 11.3 Lot Coverage The Project’s solar panels and associated infrastructure would cover more than 60% of the total area in the project area, including the 241 acres within Maricopa County. The Applicant is requesting to exclude the solar panel area from the calculation of lot coverage. Factors supporting the exclusion of solar panels from lot coverage calculations include: • Unlike typical industrial developments where large portion of project area soils are covered by concrete, asphalt, or other impervious surfaces cover a large portion of the project area, soils in the Project area would primarily remain in a natural state. The Project’s solar panels would be installed 8 to 10 feet above the ground, limiting impacts to soil permeability and hydrology by allowing soils below the panels to continue to absorb water. Therefore, the Project’s solar panels should not be considered a significant ground coverage. • The solar farm’s lot coverage would vary throughout the day as the single-axis solar tracking systems rotate the solar panels to move with the sun to provide an optimal angle for solar energy production. This variance in calculating lot coverage is consistent with other approved solar facilities within Maricopa County. 00 City of Goodyear Development Services Department, Planning and Zoning Division 1900 North Civic Square goodyearaz.gov Goodyear, Arizona 85395 623-932-3004 July 10, 2025 Colin Mann Avantus 4370 Town Center Blvd, Suite 110 El Dorado Hills, CA, 95762 RE: Zoning Verification Letter Case No. P25-00162 Generally Located West of South 83rd Avenue and North of West Schumacher Lane Section 3, Township 5 South, Range 1 East Dear Colin Mann: This letter is in response to your request for a Zoning Verification Letter for the above referenced property. The current zoning of the property is AG (Agriculture). The AG (Agriculture) zoning was approved on March 26, 2007 with the adoption of Ordinance No. 2007-1063. The property is subject to the uses and development standards as established in the City of Goodyear AG (Agriculture) zoning district. The permitted uses and development standards for this zoning district can be found in the City’s Zoning Ordinance Articles 3-2-2, and 3-2-3: https://goodyear.municipal.codes/ZoningOrds/3-2-2, https://goodyear.municipal.codes/ZoningOrds/3-2-3. There are no variances applicable to the parcel. There are no open zoning or building code violations on the subject property at this time. A copy of Ordinance No. 2007-1063 is attached. The question submitted below with the zoning verification letter request has been answered below: Applicant Question 1: Subject property requesting Zoning Verification and confirmation of no SUP required? Staff Response 1: Zoning verification is provided above. Based on the property being entirely located on BLM property, there will be no Special Use Permit process required. For copies of code violation cases, and other records, please use the online Public Records Request form. If you need additional information, please contact me at 623-882-7067 or Kevin.Duran@goodyearaz.gov. Sincerely, THE CITY OF GOODYEAR Kevin Duran Assistant Planner