03. 04.CPA250001 Z250001 Harquahala Flats PZ Staff Report

Maricopa County — Planning & Zoning (2025-06-26)

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CPA250001 and Z250001
Page 1 of 10
Report to the Planning and Zoning Commission
Prepared by the Maricopa County Planning and Development Department
Case:
CPA250001 & Z250001 – Harquahala Flats Energy Storage Project
Hearing Date:
June 26, 2025
Supervisor District:
4
Applicant:
Keith Nichter, Kimley-Horn
Owners:
Christopher, Katherine, Nicholas, Rebecca, Ronald, Theresa, and Timothy 
Peters
  
Requests:
1.
General Comprehensive Plan Amendment (CPA) to change the land use 
designation in the Tonopah Arlington Area Plan from ‘Rural Densities’ and 
‘Large Lot Residential’ to ‘Utilities’ 
2.
Zone Change with Overlay from Rural-43 to IND-2 IUPD for a photovoltaic 
solar energy generation and a battery energy storage (BESS) system
 
Site Location:
Generally located on both sides of I-10 at the 443rd Ave. alignment in the 
Harquahala Valley area
 
Site Size:
Approximately 321 acres
Density:
N/A
County Island: 
No
County Plan:
Tonopah Arlington Area Plan – Rural Densities and Large Lot Residential
Municipal Plan:
N/A
Municipal Comments:
None received to date 
Support/Opposition:
None known
Recommendations:
1.
CPA250001 - Approve 
2.
Z250001 – Approve with conditions

CPA250001 and Z250001
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Project Summary:
1.
The applicant is proposing a General CPA to the Tonopah Arlington Area Plan to change the land 
use designations from Rural Densities and Large Lot Residential to Utilities with a zone change 
with overlay from Rural-43 to IND-2 IUPD to allow for a photovoltaic solar energy generation and 
a battery energy storage (BESS) system with a 500kv step-up substation.  The site consists of 
321-acre parcel straddling both sides of I-10 at 443rd Ave. The initial development would consist 
of a BESS facility south of I-10’s eastbound ROW with later development of the land to the north 
past I-10 being dedicated to photovoltaic solar energy panels. Final kilowattage production of the 
solar energy generation facility is yet to be determined as of this report as it would be part of a 
later phase of development. The facility would tie from existing powerlines to the APS Delaney 
substation to the southwest.
2.
Much of this area has been developed for solar uses in the past several years as solar power has 
become a prominent part of Arizona’s energy grid. The facility would continuously operate and 
employ up to 400 employees during the phases of construction with 10 full-time maintenance 
employees upon buildout. Site screening would be limited to chain-link fencing with additional 
barbed wiring given the mostly vacant rural surroundings, with only a sparsely populated 
residential community to the site’s southeast at 443rd Ave. The nearest home in this area is 
approximately a quarter mile from the location of the BESS batteries. Several changes are 
requested as part of the IUPD overlay to accommodate the proposed BESS facility, as well as to 
relieve several regulations. The table below shows all requested changes to the underlying zoning 
district with modification to standards shown bolded.
REGULATION
IND-2 Base Zoning District 
Standard (IND-2 IUPD)
PROPOSED ZONING DISTRICT 
REGULATIONS (IND-2 IUPD)
Minimum Front Yard
10'
100’ for BESS, 10’ for PV panels
Minimum Side Yard
3’
100’ for BESS, 3’ for PV panels
Minimum Street-side Yard
10’
100’ for BESS, 10’ for PV panels
Minimum Rear Yard
25'
100’ for BESS, 25 for PV panels
Parking Spaces
See parking regulations
None Required
Screening
6' solid wall
Chain-link fencing and gates shall 
be allowed on the perimeter of the 
project. Barbed wire attached to 
fencing under 8’ will be allowed 
within the property boundaries
Paving Requirements
Article 1102.7.1
Parking/paving material allowed to 
be stabilized decomposed granite 
with an approved dust control plan 
by Maricopa County Air Quality 
Control.
Loading and Unloading
Article 1103.2
No loading or unloading space 
required
Landscaping
Article 901.4.1
No landscape strip required
Sight Visibility Triangles
Article 1111.5.5.3.
No SVT’s at project site, entry/exit 
points, section line, and mid-
section line intersecting 
alignments
Uses outside of an enclosed 
building
Article 902.9.1
All utility uses permitted outdoors
Max Electric Transmission Line 
Height
120’
150’

CPA250001 and Z250001
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3.
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 that the Harquahala Flats Energy Storage Project aligns with the Vision 2030 
Maricopa County Comprehensive Plan by supporting renewable energy development in response 
to changing market demands and infrastructure needs. They say the project is expected to 
generate hundreds of construction jobs and long-term maintenance roles, contributing to the 
local economy through tax revenue and use of regional contractors.  They say its proximity to 
existing utility infrastructure minimizes environmental impact and improves grid efficiency. By 
advancing renewable energy and battery storage capacity, the project supports Arizona's 
Renewable Portfolio Standard goals and Arizona Public Service Co.'s clean energy targets, 
fostering economic development, innovation, and energy independence within Maricopa County 
and beyond.
Whether the amendment will adversely impact all or a portion of the planning area by:
Altering acceptable land use patterns to the detriment of the plan.
The applicant states the proposed General Comprehensive Plan Amendment (CPA) will not 
negatively affect acceptable land use patterns in the area and is consistent with previously 
approved utility uses and zoning changes. The applicant argues that existing infrastructure 
investments make the site well-suited for future power generation and storage. The proposal 
aligns with the Plan’s Renewable Energy Strategy, which encourages the attraction of alternative 
energy development to Maricopa County. The applicant states that increasing the county’s 
support for solar power generation and storage will help lower long-term energy costs by boosting 
local supply and improving efficiency. This, in turn, supports integration of clean energy into 
sectors like housing, manufacturing, and transportation. The requested land use change from 
Rural Densities (0–1) to Utilities is said to conform with the Plan’s renewable energy policies and 
energy-related goals.
Requiring public expenditures for larger and more expensive infrastructure.
According to the application all associated infrastructure, access, and transmission costs will be 
borne by the developer.
Requiring public improvements to roads, sewer, or water systems that are needed to 
support the planned land uses.
The applicant expects limited impacts to roads, sewer, and water systems due to the nature of 
the project’s use.
Adversely impacting planned uses because of increased traffic.
According to the application the use will have limited impact on the transportation system beyond 
the construction phase of the project.
Affecting the livability of the area or health or safety of present and future residents.

CPA250001 and Z250001
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The applicant contends the facility will not result in undue or unmitigated social, visual, traffic, air 
quality, water quality, or other impacts which may have a disproportionate affecting the livability 
of the area.
Adversely impacting the natural environment or scenic quality of the area in contradiction 
to the plan.
The area is sparsely populated and there are other similar facilities nearby. The applicant has 
indicated that they will work with Arizona Game and Fish to protect local fauna from impacts and 
that  the facility will not adversely impact the scenic quality of the area. The applicant has also 
pledged to maintain compliance with applicable Maricopa County Air Quality Department 
permitting and operational standards, including conformance with U.S. Environmental Protection 
Agency (EPA), and Arizona Department of Environmental Quality.
Whether the amendment is consistent with overall intent of the comprehensive plan:
The applicant argues that the application supports Maricopa County’s mission statement and 
strategic priorities by supporting the future need in renewable energy, which has been identified 
as a strategic priority.
The extent to which the amendment is consistent with the specific goals and policies contained 
within the plan:
According to the applicant, the proposal meets the following plan elements of the Vision 2030 
Plan and Tonopah/Arlington Area Plan:
Land Use Element: Goal 3, Policy 7, Policy 20, Policy 22
Transportation Element: Goal 1, Goal 2, Goal 3, Policy 11, Policy 12
Environmental Element: Goal 1, Policy 2, Policy 3, Policy 4, Policy 5
Economic Growth Element: Goal 1, Policy 5, Policy 10
Growth Area: Goal 1, Policy 1
Water Resources Element: Goal 4, Policy 2, Policy 4, Policy 5, Policy 7
Energy Element: Goal 1, Goal 2, Policy 6
Cost of Development Element: Goal 1, Goal 2, Policy 1
Open Space Element: Goal 1

CPA250001 and Z250001
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Aerial photo of subject site and surrounding environs
 
Eagle view of subject site looking east into subject parcel (aerial image dated 10/1/21)

CPA250001 and Z250001
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Portion of site plan with north oriented to the left. BESS facility proposed south of Interstate 10 with PVs north of Interstate 10.
Existing On-Site and Adjacent Zoning / Land Use:
4.
On-site:
Rural-43 / Vacant
North:
Rural-43 / Vacant
South:
Rural-43 / Vacant
East:
Rural-43 / Vacant
West:
Rural-43 / Vacant
Zoning District map – the IND-2 zones are all similar solar facilities

CPA250001 and Z250001
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Utilities and Services:
5.
Water:
Well (portion of site south of I-10)
Wastewater:
On-site septic  (portion of site south of I-10)
Fire:
AZFMA
Police: 
MCSO 
Right-of-Way:
6.
The following table includes existing and proposed half-width right-of-way and the future 
classification based upon the Maricopa County Department of Transportation (MCDOT) Major 
Streets and Routes Plan.  
Street Name
Half-width Existing R/W
Half-width Proposed R/W
Future Classification
443rd Ave
65’
130’
Local
Adopted Plan:
7.
Tonopah/Arlington Area Plan (adopted September 6, 2000):
Rural Densities: The Rural category denotes areas where single family residential development is 
desirable but urban services (sewer, water, law enforcement, fire protection, schools, parks, etc.) 
are limited. Suitability is determined on the basis of location, access, existing land use patterns, 
and natural or man-made constraints. Densities greater than 1.0 du/acre may be permitted in a 
new development, but only if areas of lower densities offset the increase such that an average of 
no more than 1.0 du/acre is maintained. Uses in this category include agricultural and single 
family residential.
Large Lot Residential: The Large Lot Residential category denotes areas where single family 
residential development is desirable and urban services (sewer, water, law enforcement, fire 
protection, schools, parks, etc.) may only be partially available or be required as an improvement 
district. Suitability is determined on the basis of location, access, existing land use patterns and 
natural or man-made constraints. In a development, densities greater than 2.0 du/acre may be 
permitted, but only if areas of lower densities offset the increase such that an average of no more 
than 2.0 du/acre is maintained. A community sewer and water system will be required for 
developments above 1.0 du/acre and may be required for those below 1.0 du/acre depending on 
the underlying conditions.
Public Participation Summary:
8.
The applicant has complied with the Maricopa County public participation process with the 
required posting of the property and the notification to the adjacent property owners within 300’ 
of the subject site. The applicant did not receive a response from their public outreach efforts. 
Staff has not received any notice of opposition or support to the request.
Outstanding Concerns from Reviewing Agencies:
9.
N/A.
Staff Analysis:

CPA250001 and Z250001
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10.
Maricopa County recognizes the potential environmental and economic benefits that solar 
technology can provide. This facility will use photovoltaic technology that generates energy from 
sun absorption. Photovoltaic technology differs from other models of solar electric generation 
that require vast amounts of water to cool the units. In contrast, very little water is utilized for 
photovoltaic technology. As a result, this development would not pose a threat to the groundwater 
supply.
11.
Staff believes the proposed solar facility is well suited to this rural area, which requires large 
amounts of relatively flat land on both sides of I-10. 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 surrounding area is vastly undeveloped. Staff agrees with the 
applicant that the project will not detrimentally affect the visual quality of the area. Finally, the 
associated BESS facilities are compatible with rural areas where there is less danger from 
potential battery fires than there would be from other, more urban areas.
Recommendations:
12.
Staff recommends the Commission adopt a motion recommend that the Board of Supervisors 
approve CPA250001.
13.
Staff recommends the Commission adopt a motion recommending that the Board of Supervisors 
approve Z250001 subject to the following conditions ‘a’ – ‘h’:
a.
Development of the site shall be in substantial conformance with the Site Plan entitled 
“Harquahala Flats Energy Storage“, consisting of 1 full-size sheets, dated April 2, 2025 
except as modified by the following conditions. Staff may determine slight refinements to 
remain in substantial conformance with the approved site plan.  Minor and major 
amendments to the site plan will be determined in accordance with Chapter 3 of the 
Maricopa County Zoning Ordinance.
b.
Development of the site shall be in substantial conformance with the Narrative Report 
entitled Harquala Flats Energy Storage”, consisting of 23 pages and 12 pages respectively, 
both dated March 4, 2025, except as modified by the following conditions.
c.
The following Planning Engineering conditions shall apply: 
1.
Without the submittal of a precise plan of development, no development approval 
is inferred by this review, including, but not limited to number of proposed building 
lots/units, drainage design, access and roadway alignments. These items will be 
addressed as development plans progress and are submitted to the County for 
further review and/or entitlement.
2.
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. See 
https://www.maricopa.gov/DocumentCenter/View/74250/MCDOT-SolarLicense-
Application for more information.

CPA250001 and Z250001
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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.
d.
The following IND-2 IUPD standards shall apply: 
1.
Max Electrical Transmission Line Height: 150’
2.
Front Yard: 100’ for BESS, 10’ for PV panels
3.
Side Yard: 100’ for BESS, 3’ for PV panels
4.
Street-side Yard: 100’ for BESS, 10’ for PV panels
5.
Rear Yard: 100’ for BESS, 25’ for PV panels
6.
Screening: Chain-link fencing and gates shall be allowed on the perimeter of the 
project. Barbed wire attached to fencing under 8’ will be allowed within the property 
boundaries
7.
Paving Requirements: Parking/paving material allowed to be stabilized 
decomposed granite with an approved dust control plan by Maricopa County Air 
Quality Control.
8.
Loading and Unloading: No loading or unloading space required.
9.
Landscaping: No landscape strip required
10.
Sight Visibility Triangles: No SVT’s at project site, entry/exit points, section line, 
and mid-section line intersecting alignments.
11.
Uses outside of an enclosed building: All utility uses permitted outdoors.
e.
Noncompliance with any of the conditions assigned to the approval of this Zone Change 
by the Maricopa County Board of Supervisors may be grounds for revocation in 
accordance with the requirements and procedures as set forth in the Maricopa County 
Zoning Ordinance.
f.
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.
g.
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.
h.
The granting of this change in use of the property has been at the request of the applicant, 
with the consent of the landowner. The granting of this approval allows the property to 
enjoy uses in excess of those permitted by the zoning existing on the date of application, 
subject to conditions. In the event of the failure to comply with any condition, the property 
may be considered for reversion to the zoning that existed on the date of application in 
accordance with Maricopa County Zoning Ordinance requirements. It is, therefore, 
stipulated and agreed that reversion of the zoning 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 reversion of the zoning. This 
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:
Joel Landis, Planner
Reviewed by:
Rachel Applegate, Planning Supervisor

CPA250001 and Z250001
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Attachments:
Case Maps (2 pages)
CPA Narrative Report (23 pages)
Zoning Narrative Report (12 Pages)
Site Plan (1 page)
MC Engineering Comments (1 pages)
MCDOT TIS Approval (10 pages)

/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 320 approx.
Generated May 28, 2025 1:00 PM
CPA250001
Application Name:
Legal Description
HARQUAHALA FLATS ENERGY STORAGE PROJECT
Applicant
Case Address
2N 7W 18
Keith Nichter
Applicant Phone/Email
Parcel Primary:506-31-015
(602) 313-7206
keith.nichter@kimley-horn.com
Map scale 1:13,101
Supervisor District No.
Proposed General Comprehensive Plan Amendment (CPA) to change the land use designation from Rural
Densities (0-1) to Utilities.

/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 320 approx.
Generated May 28, 2025 1:06 PM
Z250001
Application Name:
Legal Description
HARQUAHALA FLATS ENERGY STORAGE PROJECT
Applicant
Case Address
2N 7W 18
Keith Nichter
5500 N 443RD AVE
Applicant Phone/Email
Parcel Primary:506-31-015
(602) 313-7206
keith.nichter@kimley-horn.com
TONOPAH, AZ 85354
Map scale 1:13,101
Supervisor District No.
Proposed Zone Change with Overlay to change the existing zoning from RU-43 (Rural) to IND-2 IUPD
district (Light Industrial)

kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
 
Exhibit A - Vicinity Map 
General Location: The proposed site is located roughly 4 miles west of Tonopah/15 miles west of 
Buckeye on a vacant +/-321-acre privately owned parcel, which straddles Interstate 10 in the northeast 
quarter of section 18, township 2 north, range 7 west in unincorporated Maricopa County, Arizona.   
 
HARQUAHALA FLATS ENERGY 
STORAGE PROJECT 
CASE #: CPA250001 & Z250001                                                                
REQUEST: General Comprehensive Plan Amendment from 
Rural Densities (0-1) to Utilities on Approximately 321.10 Acres
NARRATIVE REPORT FOR 
01-10-2025, Revised 03-04-2025

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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
 
 
 
 
 
 
 
 
TABLE OF CONTENTS 
A. EXECUTIVE SUMMARY ................................................................................................................ 3 
I. 
ON-SITE AND REGIONAL LOCATION .................................................................................... 3 
II. 
CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY ACREAGES ............................... 3 
III. 
ROADS/TRANSPORTATION SYSTEMS SERVING THE PROPOSED PROJECT ................ 4 
IV. 
SUITABILITY WITH SURROUNDING LAND USES ................................................................. 5 
TABLE 1 - EXISTING SURROUNDING SOLAR (UTILITY) LAND USE APPROVALS ..................... 6 
B. WHETHER THE AMENDMENT CONSTITUTES AN OVERALL IMPROVEMENT TO THE 
COMPREHENSIVE PLAN AND IS NOT SOLELY FOR THE GOOD OR BENEFIT OF A 
PARTICULAR LANDOWNER OR OWNERS AT A PARTICULAR POINT IN TIME. .......................... 6 
C. THE AMENDMENT WILL NOT ADVERSELY IMPACT ALL OR A PORTION OF THE 
PLANNING AREA BY: *EACH CRITERION IS ADDRESSED SEPARATELY WITH THE CRITERIA 
LISTED AND GENERAL RESPONSES TO THE CRITERIA CITED AS SUBHEADINGS IN THE 
PROCEEDING SUBSECTIONS BELOW: ............................................................................................. 8 
I. 
ALTERING ACCEPTABLE LAND USE PATTERNS TO THE DETRIMENT OF THE PLAN. .. 8 
II. 
REQUIRING PUBLIC EXPENDITURES FOR LARGER AND MORE EXPENSIVE 
INFRASTRUCTURE. .......................................................................................................................... 8 
III. 
REQUIRING PUBLIC IMPROVEMENTS TO ROADS, SEWER, OR WATER SYSTEMS 
THAT ARE NEEDED TO SUPPORT THE PLANNED LAND USES. ................................................. 9 
IV. 
ADVERSELY IMPACTING PLANNED USES BECAUSE OF INCREASED TRAFFIC. ........... 9 
V. 
AFFECTING THE LIVABILITY OF THE AREA OR HEALTH OR SAFETY OF PRESENT AND 
FUTURE RESIDENTS. ..................................................................................................................... 10 
VI. 
ADVERSELY IMPACTING THE NATURAL ENVIRONMENT OR SCENIC QUALITY OF THE 
AREA IN CONTRADICTION TO THE PLAN. ................................................................................... 10 
D. WHETHER THE AMENDMENT IS CONSISTENT WITH OVERALL INTENT OF THE 
COMPREHENSIVE PLAN: .................................................................................................................. 12 
E. THE EXTENT TO WHICH THE AMENDMENT IS CONSISTENT WITH THE SPECIFIC GOALS 
AND POLICIES CONTAINED WITHIN THE PLAN. ............................................................................ 13 
F. COMPREHENSIVE PLAN AMENDMENT MAP EXHIBIT ........................................................... 21 
G. COMPREHENSIVE PLAN AMENDMENT LEGAL DESCRIPTIONS EXHIBITS ........................ 22 
APPENDIX - A ‘SITE PARCELS’ ........................................................................................................ 23 
 
PROJECT TEAM 
 
PLANNING/ENTITLEMENTS/ APPLICANT/ 
DEVELOPER  
 
 
ENGINEERING  
 
REPRESENTATION 
HARQUAHALA FLATS ENERGY  
KIMLEY-HORN  
 
PEW & LAKE PLC 
STORAGE, LLC 
 
 
CONTACT: KEITH NICHTER  
CONTACT: RALPH PEW 
CONTACT: JAMES JACKSON  
(PLANNING), SHANE  
480.461.4670 
JAMES.JACKSON4@NEXTERAENERGY.COM   JOHANNSEN (ENGINEER) 
RALPH.PEW@PEWANDLAKE.COM  
 
 
 
 
 
602.313.7206 
KEITH.NICHTER@KIMLEY-HORN.COM 
 
 
 
 
 
SHANE.JOHANNSEN@KIMLEY-HORN.COM

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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
A. EXECUTIVE SUMMARY 
“Pew & Lake, PLC (the “Applicant”), on behalf of Harquahala Flats Energy Storage, LLC, a wholly-
owned, indirect subsidiary of NextEra Energy Resources (the “Developer”), with the permission of the 
Property Owners identified in a separate appendix, is requesting a General Comprehensive Plan 
Amendment (CPA) of the Vision 2030 Comprehensive Plan to change the land use designation for the 
±321-acre Harquahala Flats Energy Storage Project (“Project”) from Rural Densities (0-1) to Utilities. 
The General CPA request will be accompanied by a concurrent zone change request to rezone the 
underlying parcels from RU-43 to the IND-2 IUPD Zone. This General CPA will affect the land use 
designation of one (1) parcel (506-31-015) allowing for future photovoltaic solar energy generation and 
a battery energy storage (BESS) system, step-up substation and associated infrastructure. 
The BESS facility, which stores energy for later use, will improve reliability, availability, and efficiency 
of the power supply. Additionally, the 500 kV step-up substation will accommodate the future gen-tie 
connection that will link the site to the grid via overhead electrical structures, completing connection to 
the existing APS Delaney substation located +/-2 miles to the southwest. The site will also include one 
or more small buildings to house telecommunication equipment and allow for future BESS and/or solar 
generation on the northern portion of the property.  
Off-site supporting improvements, infrastructure, and/or uses include a gen-tie route corridor that 
extends through Arizona State Land Department (ASLD) to the APS Delaney substation.  
The proposed ±321-acre General CPA request, will not adversely impact the planning area and is 
consistent with other nearby Utility land use designations within and around the Harquahala Valley 
area. Approval of the proposed General CPA, concurrent rezone and associated development plans 
for the proposed project will not generate undue nor unmitigated impacts to the following areas of 
consideration identified in the Comprehensive Plan, which include, but are not specifically limited to: 
land use; public transportation system improvements; drainage and/or stormwater management; 
environmental considerations (air & water quality, potable water & wastewater treatment), areas of 
geologic concern, hazard, and/or significance; plant and wildlife habitat/migration environs and/or 
patterns; aviation and military installation operations and flight paths/patterns; economic growth; growth 
areas; open space, water resources; energy; and/or the cost of development. 
I. 
ON-SITE AND REGIONAL LOCATION 
The proposed Project is rectangular in shape and straddles Interstate 10, located north of 
Saddle Mountain, southeast of the Big Horn Mountains, at the northwest corner of the 
Camelback Road and 443rd Avenue alignments on Section 18 Township 2 North, Range 7 
West, 4 miles west of Tonopah Arizona in unincorporated Maricopa County. 
II. 
CPA SIZE AND DESCRIPTION OF LAND USE TYPES BY 
ACREAGES  
The General CPA is inclusive of one (1) parcel which is held under one (1) owner. The 
cumulative area of the property included in the General CPA request is ±321-acres. The subject 
property is generally vacant with the exception the Interstate 10 corridor which bisects the

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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
southern quarter of the site with the majority of the parcel located north of I10. The parcel 
considered under this General CPA is listed in Appendix A. 
The existing land use designation for the site is Rural Densities (0-1) which is intended to 
conserve and protect open land uses, foster orderly growth in rural and agricultural areas, to 
prevent urban and agricultural land use conflicts, and to encourage sustainable development. 
The current RU-43 zoning district is intended to have residential densities of one (1) dwelling 
unit per acre (du/ac). Principal permitted uses in the Rural zoning districts include both farming 
and non-farming related residential uses, farms, and recreational and institutional uses. The 
proposed Utilities land use and corresponding IND-2 IUPD (Light Industrial) zoning will be 
consistent with surrounding approvals necessary to develop the proposed BESS facility and 
potential future solar generation. 
 
 
III. 
ROADS/TRANSPORTATION SYSTEMS SERVING THE 
PROPOSED PROJECT 
The roadway network serving the proposed Project from the I-10 corridor includes the I-
10/411th Ave interchange (exit 94) that connects to Indian School Road and access to the site 
via 443rd Ave in accordance with access management policies and permitting requirements of 
Maricopa County. 
For the direct access Harquahala Flats Energy Storage Project will preserve necessary 
identified street right-of-way and, per Maricopa County Zoning Ordinance Section 1105, will 
Harquahala Flats Energy Storage Project –         Harquahala Flats Energy Storage Project – 
Existing Zoning RU-43    
 
 
    Proposed Zoning IND-2 IUPD

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kimley-horn.com
1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
provide the necessary setbacks starting from the future half street rights-of-way. Offsite 
improvements and any additional right-of-way needed will be determined by MCDOT Traffic 
Design and MCDOT Permits based on the submittal of a traffic statement. Final dedication, 
preservation, alignments, terminations, and vacations of unneeded ROW will be determined in 
negotiation with MCDOT. 
There would be no significant increase in traffic during the operational life of the Project that 
would require road improvements. There would be a relatively minor increase in the level of 
traffic during the phased construction. This increased traffic is expected to be minor during 
single peak morning and evening hours, primarily for the delivery of equipment and supplies 
and the commuting of the construction workforce. The TIS will be completed as part of the zone 
change process associated with the Project. The Developer has agreed to financial 
responsibility for repair of existing roads used during construction, including bonding for such 
work, so that there is not public expenditure for transportation infrastructure associated with 
the Project. 
IV. 
SUITABILITY WITH SURROUNDING LAND USES 
The surrounding area is characterized by active and passive agricultural land uses, natural 
gas-powered electric generation facilities, solar powered electric generation facilities, and 
native desert lands. The surrounding land uses include publicly owned and managed Local, 
State, and Federal Lands. These include lands controlled by the Arizona State Land Trust, and 
Bureau of Land Management. Other surrounding land uses include vacant lands, the Interstate 
10 transportation corridor and limited sparse distribution of privately owned parcels used for 
residential purposes to the southeast. Additionally, Luke Air Force Base (LAFB) is known to 
have military training routes out in this area. Under the Department of Defense (DOD) 
Clearinghouse process, energy projects greater than 199’ above ground level are required to 
go through a Formal Review. The routes in this area already fly over several existing 500kV 
lines and fly nearby several other solar and BESS projects. The proposed gen-tie pole heights 
will vary slightly, but no pole height is expected to exceed 199’. Although, the Project team will 
be proactive in addressing any potential concerns and will submit under the Informal Review 
DOD Clearinghouse process during the zoning process. 
Property owners and residents will be notified of the project and efforts will be made to identify 
concerns over visual impacts and incorporate effective mitigation and screening of the site 
against any residential boundaries.  
Considerations for buffering and screening of the Project and mitigation of visual impacts during 
construction and operational activities. Screening and mitigation of visual impacts will be 
addressed in greater detail at the rezone and plan of development submittals.  
The exterior of the BESS site will be enclosed by perimeter security fencing located on the 
portion of the parcel south of I-10. No fencing will impede or otherwise enclose existing roads 
within the project boundaries.

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The Project and the proposed Utilities land use is compatible with other similar approved and 
implemented solar and BESS projects within the general area. Associated facilities within this 
area include approved other CPA’s for Utility (solar) land uses, BESS, PV solar generation 
facilities, utility corridors, transmission lines and a utility substation. Other nearby projects are 
as follows: 
TABLE 1 - EXISTING SURROUNDING SOLAR (UTILITY) LAND USE APPROVALS 
Project 
Location (Township/Range) 
Maricopa Solar and Storage Project  
T1N R8W; T1N R9W; T2N R8W; T2N R9W
Harquahala Sun 
T1N R9W 
Harquahala Sun II and III 
T1N R9W 
Saddle Mountain Solar 
T1N R9W 
Eagletail Solar Farm 
T1S R9W 
Almeria Solar 
T2N R8W 
Sun Valley North  
T2N R8W 
Sun Valley South 
T2N R8W 
Areva Solar AZ II 
T2N R7W 
Papago Solar 
T2N R8W 
Tonopah Photovoltaic 
T2N R8W 
B. WHETHER THE AMENDMENT CONSTITUTES AN OVERALL 
IMPROVEMENT TO THE COMPREHENSIVE PLAN AND IS NOT 
SOLELY FOR THE GOOD OR BENEFIT OF A PARTICULAR 
LANDOWNER OR OWNERS AT A PARTICULAR POINT IN TIME. 
Per the Vision 2030 Maricopa County Comprehensive Plan (2016), Comprehensive Plan Amendments 
should improve the county’s overall condition and not undermine the plan’s core principles. The Plan 
recognizes the need to redesignate land uses in response to changing market conditions and to 
address the increasing demands of growth to the public infrastructure needs, specifically energy 
generation and consumption demands within the local economy.  
As stated, and reinforced in the Plan, the supply of energy is essential to the region’s transportation 
and manufacturing sectors. Energy resources significantly impact economic development by 
contributing to the region’s overall attractivity on basic and corresponding non-basic employment, 
primary and secondary employment sectors and markets, and research and development within 
existing and emerging markets and industries. Additionally, energy availability and even surplus 
opportunities function as an incubator for innovations within all segments of the local, regional, and 
state economy.

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The Project is anticipated to generate approximately 250-400 jobs in the construction, contracting, 
administrative, and project management fields during the construction phase. Routine maintenance 
activities will be performed by up to 10 full time employees based out of offsite regional facilities for 
equipment repair and replacement as needed per phase. In addition to providing in state construction 
jobs and long-term technical careers, local projects like The Harquahala Flats Energy Storage Project 
will help contribute to the regional economy by providing tax revenue and by using local engineering 
and development contractors in Maricopa County. 
The Harquahala Flats Energy Storage Project supports the county and greater region within the state 
by providing additional renewable energy resources and battery storage for local energy reliability and 
resiliency. The location and surrounding utility land uses minimize impacts to neighbors and lessen the 
impact to the environment based on proximity to the APS Delaney Substation by minimizing very long 
electrical interconnects. The electricity stored through these facilities would be distributed to the 
regional electrical grid, supplying the county and state while directly benefitting Arizona corporations 
seeking competitively priced renewable energy and looking to add new clean energy resources to 
power the record number of people and companies moving to the state. Specifically, consistent with 
their 2020 Clean Energy Commitment, Arizona Public Service Co. (APS) is looking to add additional 
clean energy resources to its diverse power supply and has issued a request for proposals (RFP) to 
supply renewable energy, which the Harquahala Flats Energy Storage Project supports. 
This Project is intended to promote and incentivize the production and delivery of renewable energy 
resources that meet and otherwise support consumption needs of existing and emerging markets which 
benefit the regional and state economies and tax bases. The availability of sustainable, renewable, and 
economically efficient energy and the resulting cost savings, both immediate and over time, creates 
opportunity for reinvestment of public and private capital back into the local and regional economy. 
The proposed Harquahala Flats Energy Storage Project is in direct support of this stated goal, the 
implementation of which is evidenced by the current approved CPA and rezoning of property within the 
current Project vicinity for solar and BESS projects. The need for this Project is established by growing 
demand for renewable energy as evidenced by the APS RFP and Arizona’s Renewable Portfolio 
Standard (RPS). RPS are policies designed to increase the use of renewable energy sources for 
electricity generation. These policies require or encourage electricity suppliers to provide their 
customers with a stated minimum share of electricity from eligible renewable resources. Most states, 
including Arizona, have enacted their own RPS programs to diversify their energy resources, promote 
domestic energy production and encourage economic development. Arizona has set their standards 
for investor-owned utilities at 45% by 2030 and 100% by 2050. 
Harquahala Flats Energy Storage Project, along with the many similar energy production and storage 
project approvals in the area, will strengthen the overall energy production output within Maricopa 
County. The increased local production and storage over time will create energy surplus within the 
market resulting in a reduction of cost and consumption by additional sectors of the local and regional 
economy. Project approval facilitates a larger regional share of renewable energy generation activities 
within the national production mix thereby promoting energy independence throughout related national 
industries and markets.

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C. THE AMENDMENT WILL NOT ADVERSELY IMPACT ALL OR A 
PORTION OF THE PLANNING AREA BY: *EACH CRITERION IS 
ADDRESSED SEPARATELY WITH THE CRITERIA LISTED AND 
GENERAL 
RESPONSES 
TO 
THE 
CRITERIA 
CITED 
AS 
SUBHEADINGS IN THE PROCEEDING SUBSECTIONS BELOW: 
I. 
ALTERING ACCEPTABLE LAND USE PATTERNS TO THE 
DETRIMENT OF THE PLAN. 
The proposed General CPA will not alter the acceptable land use patterns in the planning area 
in an adverse manner to the detriment of the plan. The proposed change in land use is 
consistent with existing approved utility land use patterns and subsequent zone change 
requests. Previous land use approvals should not be construed to imply future precedents, nor 
obligate future Board of Supervisor decisions. However, the infrastructure investment and 
development within this portion of the planning area make the Project site a more suitable and 
logical location for future development of power generation and storage. The single Renewable 
Energy Strategy in the Plan promotes/encourages the “[attraction] of solar and other alternative 
energy research and development to Maricopa County.” Approval of the General CPA is 
consistent with this strategy and the utility pattern that has been established in the Project area 
by recent BOS approvals in favor of large-scale solar powered generation and storage facilities 
within this remote area.  
Increasing the county’s investment (in terms of land use planning) in local solar powered 
generation and storage facilities has a long-term tangible impact of lowering costs of energy 
production, delivery, and consumption. This goal is achieved in part by increasing local/regional 
energy production/generation. The increased supply has a proportionate impact on the 
accessibility of the resource and encourages integration of applied uses and transitions away 
from reliance on outdated and inefficient modes of energy generation and transmission creating 
efficiencies in these areas. Increased supply and efficiencies will promote increased integration 
into the market for various sectors of the economy (housing, manufacturing, transportation, 
etc.).  
The General CPA to change the land use from Rural Densities (0-1) to Utilities to accommodate 
the proposed uses is in substantial conformance with renewable energy policies identified in 
the Plan, addressed in the Energy Goal and Policy Considerations in Section D of this report. 
II. 
REQUIRING PUBLIC EXPENDITURES FOR LARGER AND 
MORE EXPENSIVE INFRASTRUCTURE. 
Any and all expenditures for larger and more expensive infrastructure that are required as a 
result of the development shall be borne by the developer. Improvements for adjacent access 
roads will be borne solely at the expense of the developer proportionate to the impacts placed 
on the transportation network. Any public or private electric transmission infrastructure 
improvement costs needed in support of the Project will be borne solely by the developer.

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III. 
REQUIRING PUBLIC IMPROVEMENTS TO ROADS, 
SEWER, OR WATER SYSTEMS THAT ARE NEEDED TO 
SUPPORT THE PLANNED LAND USES. 
The amendment will not adversely impact the planning area by requiring public improvements 
to roads, sewer, or water system needed to support the planned land uses. The provision of 
these services will be the responsibility of the developer in a manner that does not detract or 
negatively impact the availability, delivery, and/or use of existing services within the planning 
area. All costs for public improvements or services necessary to support the planned 
development will be borne solely by the developer. 
Options for construction and operational water needs is currently under examination by the 
Developer, and none of these options would require improvements to public water systems.  
Each phase of the Project is anticipated to require approximately 80-100 acre-feet of water 
over the construction period. This water will be sourced from potential on-site wells or hauled 
in from outside sources. During the O&M phase, up to approximately 10 acre-feet of water 
would be required per year for module washing and maintenance. The Project will be consistent 
with Maricopa County’s water and wastewater treatment programs during all phases of the 
development. 
Underground wet/dry utility service or transmission lines within adjacent right-of-way will be 
solely at the developer’s expense. Required on-site water and wastewater service and/or 
treatment for construction, operations, and maintenance, activities will be the sole financial 
burden of the developer. Required services and the developer’s plan of provision will meet 
county and state requirements for water and on-site wastewater disposal criteria, permitting, 
and monitoring standards. 
IV. 
ADVERSELY IMPACTING PLANNED USES BECAUSE OF 
INCREASED TRAFFIC.  
Existing and planned uses surrounding the site which are dependent on the surrounding 
transportation system are not anticipated to be impacted due to increased traffic. Planned uses 
on-site will not be adversely impacted due to increased traffic. Increased traffic will be limited 
to construction and implementation activities associated with this Project and not from others. 
The Project will keep existing access points to nearby owners open and available during the 
construction phases. During the construction, minor increases are expected for each phase of 
Project construction; therefore, per the MCDOT Traffic Impact Manual, a traffic statement will 
be required in support of the necessary zone change application and review process. A traffic 
statement is a scaled down and simplified version of the traffic impact study and is intended for 
smaller Projects that will have lesser impacts on existing traffic as compared to the larger type 
of master plan developments. At that time, a clearer Projection of traffic impacts will be 
available which will consider construction and operational ADT, construction haul routes, 
necessary ROW dedications, and road improvements.

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V. 
AFFECTING THE LIVABILITY OF THE AREA OR HEALTH 
OR SAFETY OF PRESENT AND FUTURE RESIDENTS. 
The General CPA will not adversely affect the livability of the area or health or safety of present 
and future residents of the area. As previously discussed, there are relatively few residences 
in the area. Site preparation, construction, or operation will not include any hazardous activities, 
materials, processes, or outputs. Noise impacts would be limited construction activities during 
specified construction hours. Fugitive dust control will be achieved during construction and 
operational periods by implementation of proper grading, erosion control measures, and BMP’s 
to include appropriate dust control and mitigation of dust on unpaved roads. Standard 
operational activities conform to applicable noise ordinances. Fire hazard and wildfire 
mitigation will be addressed with the plan of development. The Harquahala Flats Energy 
Storage Project will comply with all applicable local and county fire laws and regulations. All 
reasonable measures will be taken to prevent fires on the site including the control or 
suppression of weeds. If necessary, all weed control would be in compliance with county 
regulations.  The General CPA will not result in undue or unmitigated social, visual, traffic, air 
quality, water quality, or other impacts which may have a disproportionate affecting the livability 
of the area. 
VI. 
ADVERSELY IMPACTING THE NATURAL ENVIRONMENT 
OR SCENIC QUALITY OF THE AREA IN CONTRADICTION 
TO THE PLAN.   
Given the Project site location, adjacent to the busy Interstate 10 thoroughfare, and the 
significant amount of similar BESS and solar project approvals in the surrounding area, is not 
anticipated that the proposed land use will generate adverse impacts to the natural 
environment or the scenic quality of the area.  
The Project team will conduct necessary onsite investigations and implement appropriate 
protective measures as needed for biological resources to either avoid or mitigate impacts to 
the natural environment, in coordination with the Arizona Game and Fish Department (AZGFD). 
The Project team recognizes that appropriate coordination, proper planning, and 
implementation of best management practices allow projects to be developed that avoid, 
minimize, or mitigate potential impacts to wildlife and recreational access during development 
and operation of the facilities. The Project team will coordinate with AZGFD through the review 
of the zone change and plan of development to minimize any potential impacts to the 
surrounding wildlife including proper treatment or preservation of drainage ways and wildlife 
corridors. Based on similar surrounding approvals, AZGFD will recommend surveys and 
monitoring to identify the species in the area and best management practices will be introduced 
to address potential impacts and safety.  
As discussed in the transportation sections, no major offsite road or transportation network 
improvements are required to support the Project. Dust control measures will be provided to 
protect air quality during construction activities. Ground disturbing activities may also require

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dust mitigation, erosion control BMPs, and select soils stabilization or enhancement where 
existing erosion is encountered to maintain compliance with local, state, and federal air and 
water quality standards. 
The site is predominately flat limiting the need for excessive grading for access, supporting 
accessory equipment or storage structures. Construction activities will implement accepted 
BMP’s for BESS facility development, which include minimum ground disturbance and non-
disturbance of existing low-lying vegetation and vegetation for erosion control purposes. 
Vegetation may require mowing to heights approved by the fire district or other environmental 
agencies to maintain appropriate levels of fire mitigation and erosion control.  
The site will have minor visual impacts to surrounding areas and properties. The site will be 
secured with a minimum 6-foot fence to provide separation and security. Details of proposed 
fencing will be provided with subsequent zone change and plan of development applications 
and finalized through coordination and input from residents and impacted property owners.  
The surrounding area has a few sparsely distributed residential land uses. The rest of the 
surrounding area is characterized by active and passive agricultural land uses, Bureau of Land 
Management (BLM) and Arizona State Land Department (ASLD) owned and managed lands, 
natural gas-powered electric generation facilities, solar powered electric generation facilities, 
and native desert lands. The predominant surrounding private land uses within the area is 
Utilities as designated by approved Comprehensive Plan Amendments which have changed 
the underlying future land uses from Rural Densities (0-1) to Utilities. 
No adverse or otherwise unmitigated impacts to the natural environment or scenic quality of 
the area are anticipated.  
The site will be surveyed prior to construction activities to identify plant/vegetation species 
which are protected by the Arizona Department of Agriculture under the Arizona Native Plant 
Law. Protected plant life and/or vegetation will be relocated or otherwise salvaged. All activities 
associated with the removal, relocation, or sale of protected plants/vegetation will comply with 
the notice requirements of Title 3, Chapter 3, Title II, of the Arizona Administrative Code. 
Additional detailed analysis of environmental impacts will occur with pending zone change and 
plan of development submittals. Any identified impacts will be evaluated together with Planning 
and other staff within affected local, state, federal regulatory agencies and corresponding 
county departments and agencies, and participating stakeholders to identify appropriate 
mitigation strategies and/or other acceptable offsetting measures. The Project will maintain 
compliance with applicable Maricopa County Air Quality Department permitting and operational 
standards, including conformance with U.S. Environmental Protection Agency (EPA), and 
Arizona Department of Environmental Quality.

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D. WHETHER THE AMENDMENT IS CONSISTENT WITH OVERALL 
INTENT OF THE COMPREHENSIVE PLAN: 
Maricopa County’s original Comprehensive Plan was adopted in 1997 as a sensible approach to 
addressing the regions fast paced growth and associated development issues. Additionally, the 
Tonopah/Arlington Area Plan, adopted in 2000 and updated to follow the direction of the 
Comprehensive Plan. A lot has changed since these adoptions, including a relevant update to introduce 
energy efficiency and renewable energy into the plan into the Comprehensive Plan in 2007, and the 
county looks to build on the past and lessons learned to experience continued smart growth and 
achieve a healthy, vibrant and prosperous future. This can be seen throughout the county’s current 
Vision 2030 Comprehensive Plan, which is a planning mechanism that looks to balance this future 
growth with a high quality of life. The Comprehensive Plan looks to achieve this balance by providing 
policies and recommendations on how to protect public health and safety, promote stable economic 
growth, maintain a healthy environment, provide adequate community services, and ensure that tax 
money is spent efficiently. These policies and recommendations also guide Maricopa County’s 
decisions regarding future development, and for when changes to this plan are justified.  
Applicant initiated changes to the comprehensive plan, like this change in land use designation, may 
occur with Board approval to account for changing conditions provided that such revisions benefit the 
county as a whole. This benefit can be weighed through the goals and policies of a series of plan 
elements, which each address a subject that affects the county’s quality of life. While each element is 
distinct, combined they reinforce the county’s strategic priorities and the core principles of Vision 2030, 
and promote consistent interpretation and implementation of its policies and recommendations.  
Consistent with the county’s core principles, this land use change helps support the implementation of 
Maricopa County’s mission statement and strategic priorities by providing fiscally responsible 
alternative energy services and effective and efficient infrastructure to implement delivery of services 
that help promote and contribute to a healthy community that residents can enjoy. The General CPA 
will maintain the county’s comprehensive plan approach to ensure that the land use request is 
understandable, measurable, consistent, practical and promotes efficiency.  
This narrative, and more specifically the goal and policy analysis below, lays out the expectations for 
future growth and development of the utilities designation, which promote an efficient use of land, 
energy and financial resources. Specifically, the renewable energy and solar uses are discussed 
throughout Vision 2030 responding to Maricopa County’s ability to be one of the most productive spots 
int the world for solar energy generation as discussed in the plan. These references provide measurable 
policies and strategies to further the Economic Growth, Water Resources and Energy elements, as 
described below, while complementing the growth and development related issues and goals of the 
remaining plan elements. Overall, this approach allows the Project to consider the county’s past 
decisions provided within Vision 2030 to provide practical and informed decisions to avoid future 
problems. 
The Project meets the overall intent of the Maricopa County Comprehensive Plan Vision 2030 by 
supporting the future need in renewable energy, which has been identified as a strategic priority, that 
benefits the region and county as a whole. Additionally, this Project will improve the quality of life as 
identified in the goals and policies of the Comprehensive Plan as discussed in the following section.

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E. THE EXTENT TO WHICH THE AMENDMENT IS CONSISTENT WITH 
THE SPECIFIC GOALS AND POLICIES CONTAINED WITHIN THE 
PLAN. 
Maricopa County’s Vision 2030 Comprehensive Plan considers growth-related topics that will affect the 
county’s future. The following nine (9) plan elements, which include the four (4) Tonopah/Arlington Area 
Plan elements (Land Use, Transportation, Environment, Economic Growth), examine key issues that 
shape the goals and policies that Maricopa County uses to implement its mission, vision, strategic 
priorities and make informed and effective decisions. 
 
Land Use 
 
Transportation 
 
Environment 
 
Economic Growth 
 
Growth Areas 
 
Open Space 
 
Water Resources 
 
Energy 
 
Cost of Development 
 
Harquahala Flats Energy Storage Project and the Utilities land use designation are affirmed by many 
of the goals, objectives, and policies identified within these identified plan elements. The relevant goals, 
objectives, and policies contained in the Comprehensive Plan are listed below with specific examples 
and guarantees of how each is relevant to the proposed use and why it is consistent. 
 
LAND USE GOALS AND POLICIES 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Land Use Goal #3: Protect 
public health, safety and well-
being  
Harquahala Flats Energy Storage Project is a low impact land 
use, consistently found in the area, that provides renewable 
energy storage to the region. The Project requires minimal water 
usage, minimal traffic, minimal operational employment or activity 
and no wastewater. Additionally, it improves air quality and will 
provide necessary ROW dedications, circulation, screening, and 
appropriate buffers. Altogether, this passive land use will help 
contribute to the public health, safety and well-being of the area. 
Land Use Policy #7:  Maricopa 
County supports coordinating 
land 
use 
and 
infrastructure 
planning with state agencies, 
counties, and municipalities.  
 
The process requires ongoing coordination with local, state, and 
federal agencies to ensure protections of public services, utilities, 
infrastructure, and natural resources. Coordination is either 
expected or has occurred directly with Maricopa County Planning 
and Zoning, Environmental Services, the Maricopa County 
Department of Transportation, and Arizona Game and Fish 
Department (AZGFD). Feedback from state agencies, other 
counties and municipalities located in close proximity to the 
Project will be received as well through Maricopa County’s 
enhanced notification process. Additional coordination will occur 
both on this site and with the associated gen-tie with these groups 
in addition to the State Historic Preservation Office (SHPO) and 
Arizona Department of Agriculture (AZDA). The coordination

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includes preparation of necessary reports and considerations for 
the provision as well as protection of natural resources and public 
services including, but not limited to, water resources 
(ground/surface water supplies), flora and fauna impacts, air and 
water quality, and stormwater impacts, open spaces, buffering 
and screening, and transportation facilities and rights-of-way. 
Land Use Policy #20: Maricopa 
County supports reducing the 
impacts 
of 
new 
urban 
development on existing rural 
land uses and agriculture. 
The Project is a land use that is already found in the surrounding 
area, reducing the impact on nearby agricultural and rural land 
uses.  
Land Use Policy #22: Maricopa 
County supports reducing the 
impacts of new development on 
environmentally sensitive areas, 
including native flora and fauna 
habitat and corridors.  
 
The Project does not include environmentally sensitive areas 
requiring avoidance or mitigation that we are aware of at this time. 
All development activities will remain compliant with applicable 
environmental regulations requiring flora/fauna habitat and/or 
environmental protection or relocation. Ongoing coordination with 
the appropriate agencies, including AZGFD, SHPO and AZDA, 
throughout the Project life cycle will ensure appropriate site 
treatments 
and 
regulatory 
compliance 
with 
applicable 
environmental policies, protocols, and regulations. 
 
 
TRANSPORTATION GOALS & 
POLICY CONSIDERATIONS 
CPA CONSISTENCY/JUSTIFICATION 
 
Transportation 
Goal 
#1: 
Promote and protect public 
health 
through 
a 
safe 
transportation system.  
 
One of Maricopa County’s strategic priorities is creating a safe, 
efficient and effective transportation system. Harquahala Flats 
Energy Storage Project will further this priority by addressing 
some of their related concerns specific to the preservation of road 
alignments and air pollution. The Project will be responsible for 
ROW preservation of the necessary roadway alignments, as 
indicated by MCDOT from its respective boundaries to comply 
with the Maricopa County Transportation Plan and road/ROW 
dedication standards of the county. Any exceptions will be 
negotiated with MCDOT and authorized by the MC BOS to 
memorialize terms of negotiated dedications, preservation, and/or 
and deferments or exemptions. Because no full-time employees 
are proposed on-site, outside of the limited construction traffic, 
Harquahala Flats Energy Storage Project provides a use that will 
limit automobile usage and reduce air pollution. 
Transportation 
Goal 
#2: 
Contribute to a safe, seamless 
and 
effective 
transportation 
system.  
The Project will support a safe, seamless, and effective 
transportation system by preserving required ROW in support of 
future road alignments as coordinated with MCDOT in a manner 
consistent with Departmental planning objectives and the 
Maricopa County Transportation Plan.

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

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Environmental Policy #3: 
To help protect water quality 
Maricopa 
County 
supports 
compliance with its Drinking 
Water program and its Water 
and 
Wastewater 
Treatment 
program.  
 
The Project as proposed is consistent with and will maintain 
compliance with Maricopa County Drinking and Wastewater 
Treatment program including water supply of the Maricopa 
County Environmental Health Code. As proposed, drinking water 
will be delivered by truck. If a local well is required for water use, 
such well will comply with local and state permitting, operations, 
monitoring, and recharge requirements. The Project, as 
proposed, will not have wastewater demands or discharge. A 
septic system will be used if an O&M building is required. 
Environmental 
Policy 
#4: 
Maricopa 
County 
supports 
innovative Project design and 
development techniques that 
protect and mitigate damage to 
important 
plant 
and 
animal 
habitat and migration corridors.  
 
The Project will be designed to minimize, avoid, and/or mitigate 
negative impacts to flora and fauna habitat and wildlife migration 
corridors during implementation and operational activities. 
Comments from the Arizona Game and Fish Department 
(AZGFD) will be addressed in a manner consistent with the intent 
of this policy, which may include preservation and/or relocation of 
impacted flora and/or fauna species. Best management practices 
will be employed to address flora/fauna impacts. 
Environmental Policy #5: As 
directed by SHPO and Arizona 
Game and Fish Department, 
Maricopa 
County 
supports 
cultural resource and biological 
surveys being completed – and 
needed 
mitigation 
measures 
established – prior to new 
development.   
Cultural and biological reporting and surveys associated with this 
Project, if required by the State Historic Preservation Office 
(SHPO) and AZGFD, will be submitted with the zone change and 
plan of development application to identify sensitive areas 
requiring protection, preservation, and/or mitigation of impacts to 
respective natural, biologic, and/or cultural resources. Mitigation 
identified by these or by the respective agency’s staff or other 
guidance documents will be adhered to during implementation, 
and operation of the use. 
 
ECONOMIC GROWTH GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Economic Growth Goal #1: 
Contribute 
to 
an 
effective 
regional economy. 
 
 
Economic Growth Policy #5:  
Maricopa 
County 
supports 
programs that attract a variety of 
Basic Sector industry clusters 
that 
have 
long-term, 
stable 
growth prospects. 
The physical development of the site will employ hundreds of 
specialized construction and skilled trade workers and laborers 
from unincorporated areas and incorporated municipalities within 
Maricopa 
County. 
Construction 
activities 
will 
generate 
employment 
opportunities 
for 
qualified 
workers 
over 
a 
construction period which is anticipated to occur from 
approximately late 2025 to mid-2028. Local businesses including, 
but not limited to retail, food service, gas station/convenience, and 
hospitality businesses will be supported by workers commuting to 
the site or lodging near the site for short/long terms during their 
respective periods of construction activities. No construction 
camps or on-site housing are proposed during the implementation 
(construction) phase of the Project. No on-site security or 
maintenance housing is proposed during the operational phase of 
this development.

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Economic Growth Policy #10: 
Maricopa 
County 
supports 
leveraging its solar resource 
potential to attract solar-related 
industries 
and 
alternative 
energy 
research 
and 
development. 
More accessible energy sources will attract energy dependent 
employment sectors to the region and allow existing basic sector 
industries to reinvest energy savings into expansions, research 
and 
development, 
and retrofitting activities to 
increase 
productivity in response to growing demands and competition in 
the regional and national share of their respective industries. 
Increasing the supply of locally generated renewable energy 
storage increases the attractiveness of the region on the demand 
for technological innovations to meet the demand for additional 
skilled and specialized workers. There will also be an increase in 
the demand for specialized workers to respond to changes and 
innovations in the solar powered generation industry and in the 
development of spin off applications in the manufacturing, 
transportation, and research/development industries.   
 
GROWTH AREA’S GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Growth 
Areas 
Goal 
#1: 
Achieve orderly urban growth 
that 
is 
fiscally 
and 
environmentally 
responsible, 
protects public health and safety 
and 
promotes 
sensible 
annexation patterns. 
The Project is located near existing and approved generation 
facilities and has convenient access to existing electrical 
infrastructure, major transmission corridors, and a major electrical 
substation. Proximity to existing transmission lines, corridors, and 
easements reduces the Developer’s expenditures to utilize 
existing infrastructure and to obtain necessary easements to 
interconnect to the electrical grid. Construction and operational 
activities will maintain compliance with applicable environmental 
criteria, regulations, and permitting to ensure protection of 
biologic and natural resources.  
Growth 
Areas 
Policy 
#1: 
Maricopa 
County 
supports 
consistent implementation of its 
urban growth area except in the 
noted instances.   
The proposed Project is considered an industrial land use that 
does not require a corresponding level of urban services and 
infrastructure and can be located in rural remote areas. As the 
plan recommends, this land use is acceptable outside the urban 
growth area. These uses could include electric generating 
facilities, proving grounds and test facilities, agriculturally oriented 
businesses, and other rural-type industrial uses on a case-by-
case basis.

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WATER RESOURCES GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Water Resources Goal #4:  
Increase water conservation. 
The switch in land use from allowed residential or agricultural 
uses to BESS will significantly increase water conservation in the 
county. The project team recognizes that the proposed site 
receives a high degree of solar radiation and that water supplies 
in the vicinity are limited. The Project will implement water 
conservation measures while utilizing water-efficient technology. 
Construction Peak Water Usage and Operations & Maintenance 
Water Usage would be significantly less than any allowed 
residential or agricultural use. 
Water Resources Policy #2: 
Maricopa County supports water 
conservation techniques in the 
planning and design of new 
development. 
The Project will include a comprehensive Water Conservation 
Plan with established BMPs for water conservation. The Project’s 
water-conscious design and implementation is consistent with the 
applicable water goals and policies of the Comprehensive Plan. 
Water Resources Policy #4: 
Maricopa 
County 
supports 
compliance with its Drinking 
Water 
and 
Water 
and 
Wastewater 
Treatment 
Programs. 
Drinking water will be delivered by truck. If a local well is required 
for water use, such well will comply with local and state permitting, 
operations, monitoring, and recharge requirements. 
The Project will maintain compliance with Maricopa County’s 
wastewater treatment programs during the construction activity 
period. The Project as proposed will not have wastewater 
demands or discharge. A septic system will be used if an O&M 
building is required. Alternatively, portable restroom facilities will 
be provided for employee use during the implementation and 
operational phases. 
Water Resources Policy #5: 
Maricopa County supports low 
water 
use 
solar 
electric 
generating technologies.   
Harquahala Flats Energy Storage Project will require very little 
water except for maintenance equipment support. This water will 
either be hauled to the site during construction and operation or 
obtained from wells permitted through the Arizona Department of 
Water Resources (ADWR), as needed. Water hauled to the site 
would be from permitted sources. 
Water Resources Policy #7: 
Maricopa County supports low 
water use and drought tolerant 
landscaping.   
If landscape treatments are required to provide visual buffering, 
they will be selected from drought tolerant xeric species which will 
require low water use to establish and maintain.

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ENERGY GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Energy Goal #1: 
Provide leadership to promote 
regional environmental quality.  
 
Harquahala Flats Energy Storage Project will have a long-term 
environmental impact of improving air quality by supporting solar 
energy production which reduces the emissions associated with 
conventional electric energy generation. The county has adopted 
environmental performance standards intended to preserve and 
sustain biologic, cultural, and environmental resources of the 
region which are evidence of the county’s regional leadership role 
in the promotion of environmental quality.  
Energy Goal #2: 
Make Maricopa County a leader 
in alternative energy research 
and development. 
 
Harquahala Flats Energy Storage 
Project provides the 
opportunity to implement, test, and evaluate the efficiencies of the 
most current battery energy storage systems. Evaluation of their 
operational performance is key to the research and development 
of more efficient equipment and related processes. An 
operational facility provides opportunities to implement advances 
in the associated technologies over the life of the Project. 
Approval of the facility provides opportunities to test storage 
systems in response to increasing demands for the use of stored 
energy.  
Energy Policy #6: 
Maricopa County supports being 
a 
responsible 
leader 
in 
alternative energy research and 
development. 
Harquahala Flats Energy Storage Project will be reflective of the 
Maricopa County Board of Supervisor’s regional and statewide 
leadership in the attraction, promotion, and delivery of renewable 
energy resources and infrastructure.  
 
COST OF DEVELOPMENT GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Cost of Development Goal #2: 
New 
development 
pays 
its 
proper and reasonable share of 
the costs of new infrastructure, 
services 
and 
other 
public 
improvements. 
All Project costs, including, but not limited to, on-site 
improvements, gen-tie line infrastructure and connections, 
collection lines, off-site road improvements, and water and 
wastewater treatment service, shall be borne solely by the 
Developer. 
Cost of Development Policy 
#2: Maricopa County supports 
recouping 
the costs 
of 
its 
products and services without 
unfairly burdening those most in 
need 
of 
its 
products 
and 
services. 
All development costs will be borne solely by the developer, 
including, but not limited to, applicable fees for service, impact 
fees, performance bonds and sureties, and property taxes.

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OPEN SPACE GOAL AND POLICY CONSIDERATIONS 
COMP PLAN ELEMENT 
(GOALS/POLICIES) 
CPA CONSISTENCY/JUSTIFICATION 
Open Space Goal #1:  Provide 
regional leadership to promote 
environmental quality, including 
the preservation of open, natural 
park and recreation lands. 
The Project is located away from, and will not impact, Maricopa 
County’s regional parks, trails, or other public recreation. 
Furthermore, this Project would enable the county to site utility-
scale solar generation and storage uses near existing electrical 
infrastructure and similar uses, in an area that development would 
result in limited impact to open space lands and would 
demonstrate efficient, orderly growth. In addition, the Project 
would be able to store renewable energy that would result in 
improved air quality through reduced emissions for electric 
generation, allowing Maricopa County to provide regional 
leadership in promoting environmental quality through improved 
air quality in the County. 
 
 
 
 
 
 
 
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F. COMPREHENSIVE PLAN AMENDMENT MAP EXHIBIT 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PROPOSED LAND USE: UTILITIES 
EXISTING LAND USE: RURAL DENSITIES (0-1)

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G. COMPREHENSIVE PLAN AMENDMENT LEGAL DESCRIPTIONS 
EXHIBITS 
(Legal descriptions for the parcel are available in a separate deed attachment.)

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APPENDIX - A ‘SITE PARCELS’  
One (1) parcel that constitute the +/-321.10-acre Site 
 
 
 
# 
Assessor 
Parcel No. 
(APN) 
Owner 
CPA Acreage 
(±AC) 
Township & 
Range 
Section 
Deed 
1 
506-31-015 
 
PETERS RONALD 
VINCENT/CHRISTOPH
ER DALE/REBECCA 
E/TIMOTHY/THERESA/
NICHOLAS/KATHERIN
E/GIFFORD MARINA C
321.10 
2N 7W 
18 
20080702007

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Exhibit A - Vicinity Map 
 
General Location: The proposed site is located roughly 4 miles west of Tonopah/15 miles west of 
Buckeye on a vacant +/-321-acre privately owned parcel, which straddles Interstate 10 in the northeast 
quarter of section 18, township 2 north, range 7 west in unincorporated Maricopa County, Arizona.   
 
 
HARQUAHALA FLATS ENERGY 
STORAGE PROJECT 
CASE #: Z250001 & CPA250001                                                      
REQUEST: Zone Change with Overlay from RU-43 to IND-2 
IUPD on Approximately 321.10 Acres 
NARRATIVE REPORT FOR 
01-10-2025, Revised 03-04-2025

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TABLE OF CONTENTS 
1. 
PURPOSE OF REQUEST .............................................................................................................. 3 
2. 
DESCRIPTION OF PROPOSAL .................................................................................................... 3 
2.1 Site Summary Information: .......................................................................................................... 3 
2.2 Proposed Uses (Summary): ......................................................................................................... 4 
Hours/Days of Operation: ................................................................................................................ 4 
Number of Employees: .................................................................................................................... 4 
Description/Location of Buildings: ................................................................................................... 4 
Color Palette: ................................................................................................................................... 4 
Sign Details: .................................................................................................................................... 4 
Screening Wall/Fence Details and Location: .................................................................................. 4 
3. 
RELATIONSHIP TO SURROUNDING PROPERTIES ................................................................... 5 
Existing Surrounding Solar (Utility) Land Use Approvals ................................................................ 6 
4. 
LOCATION AND ACCESSIBILITY ................................................................................................ 7 
Location: .......................................................................................................................................... 7 
Access: ............................................................................................................................................ 7 
5. 
CIRCULATION SYSTEM ................................................................................................................ 8 
Off-site Circulation (Access): ........................................................................................................... 8 
On-site Circulation ........................................................................................................................... 8 
Parking and Loading ....................................................................................................................... 8 
6. 
DEVELOPMENT SCHEDULE ........................................................................................................ 8 
7. 
COMMUNITY FACILITIES AND SERVICES ................................................................................. 9 
8. 
PUBLIC UTILITIES AND SERVICES ............................................................................................. 9 
TABLES 
1. Industrial Unit Plan of Development ……………………………………………………………...….12 
 
 
PROJECT TEAM 
 
PLANNING/ENTITLEMENTS/ APPLICANT/ 
DEVELOPER  
 
 
ENGINEERING  
 
REPRESENTATION 
HARQUAHALA FLATS ENERGY  
KIMLEY-HORN  
 
PEW & LAKE PLC 
STORAGE, LLC 
 
 
CONTACT: KEITH NICHTER  
CONTACT: RALPH PEW 
CONTACT: JAMES JACKSON  
(PLANNING), SHANE  
480.461.4670 
JAMES.JACKSON4@NEXTERAENERGY.COM   JOHANNSEN (ENGINEER) 
RALPH.PEW@PEWANDLAKE.COM  
 
 
 
 
 
602.313.7206 
KEITH.NICHTER@KIMLEY-HORN.COM 
 
 
 
 
 
SHANE.JOHANNSEN@KIMLEY-HORN.COM

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1. PURPOSE OF REQUEST 
“Pew & Lake, PLC (the “Applicant”), on behalf of Harquahala Flats Energy Storage, LLC, a wholly-
owned, indirect subsidiary of NextEra Energy Resources (the “Developer”), with the permission of the 
Property Owners identified in a separate appendix, request approval of a Zone Change with Overlay 
(rezone) from RU-43 (Rural) to IND-2 IUPD (Light Industrial) Zone for the Harquahala Flats Energy 
Storage Project (“Project”) on (1) parcel / approximately ±321 acres. The Project approval will allow for 
future photovoltaic solar energy generation and a battery energy storage (BESS) system, step-up 
substation and associated infrastructure. 
2. DESCRIPTION OF PROPOSAL 
2.1 Site Summary Information: 
The ±321 acres included are inclusive of the following one (1) underlying parcel:  
#
Assessor Parcel No. (APN)                     Owner 
Acreage 
Township & Range
Section
1
506-31-015 
PETERS RONALD VINCENT/ 
CHRISTOPHER DALE/REBECCA 
E/TIMOTHY/THERESA/NICHOLAS/KATHE
RINE/GIFFORD MARINA C 
321.10 
2N 7W 
18 
The Developer proposes to construct, operate, and maintain a battery energy storage system and 
associated infrastructure for the Project.  
The initial development will consist of a BESS facility, which stores energy for later use improving the 
reliability, availability, and efficiency of the power supply. Additionally, the 500 kV step-up substation 
will accommodate the future gen-tie connection that will link the site to the grid via overhead electrical 
structures, completing connection to the existing APS Delaney substation located +/-2 miles to the 
southwest. The site will also include one or more small buildings to house telecommunication 
equipment and allow for future BESS and/or solar generation on the northern portion of the property. 
The proposed rezone in support of the ±321-acre Project will not adversely impact the planning area in 
part nor portion. The sites solar and BESS elements will be developed in two phases with the first being 
the BESS facility in the parcel south of I-10 and the future second phase, being the solar/additional 
BESS element, developed in the parcel north of I-10 with details to be defined in a future Plan of 
Development (POD) application. In conjunction with this rezone request, a proposed General 
Comprehensive Plan Amendment (CPA) application will be submitted to modify the Projects current 
land use designation from ‘Rural Densities (0-1)’ to ‘Utilities’. Both applications will allow development 
of the Project. The Project will be consistent with the components of the Maricopa County 
Comprehensive Plan, which include, but are not specifically limited to: land use; public transportation 
system improvements; drainage and/or stormwater management; environmental considerations (air & 
water quality, potable water & wastewater treatment), areas of geologic concern, hazard, and/or 
significance; plant and wildlife habitat/migration environs and/or patterns; aviation and military

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installation operations and flight paths/patterns; economic growth; growth areas; open space, water 
resources; energy; and/or the cost of development. 
2.2 Proposed Uses (Summary): 
Hours/Days of Operation:  
The site will be in operation and/or production 24 hours a day, seven (7) days per week. Solar 
generation activities in the area would be limited to daytime (daylight) hours which vary seasonally but 
the energy storge activities and operations on this site will be continuous and energy transmission into 
the power grid will occur on demand as needed throughout both the daytime and nighttime hours. 
Number of Employees: 
Construction activities are anticipated to employ up to 250-400 in varying phases in the construction, 
contracting, administrative, and Project management fields during the construction and implementation 
phase. Operation of the site will not require full-time employees on site. Routine maintenance activities 
will be performed by up to 10 full time employees based out of offsite regional facilities for equipment 
repair and replacement as needed.  
Description/Location of Buildings: 
Smaller communication and electrical equipment could be located among future PV array fields. 
Electrical and telecommunication equipment may be contained within housing units or cabinets that are 
a manufactured protective outer covering for the internal equipment. Self-enclosed units include small 
telecommunications equipment cabinets and Battery Energy Storage System (BESS) equipment 
cabinets/shelters. BESS cabinets/shelters will be located near the BESS system components housed 
in prefabricated steel containers located. 
Operations & maintenance (O&M) building(s) will be provided for the Project located near the BESS 
area and substation. Site sewer for this building(s) will be septic and the water will be either hauled and 
provided via above ground tank or via well.  
Color Palette: 
All materials coatings, finishes, and colors, where practicable, will be selected to blend facility 
components to the natural setting. Selection of color palettes for electrical cabinets will be selected 
from factory specifications and options provided by the respective manufacturers. Color palette 
selection will conform to generally accepted and adopted industry standards for BESS equipment 
support structures. Final color selections will seek to minimize heat absorption and glare and blend with 
surrounding natural environment so far as is practicable. 
Sign Details:  
Signage will be limited to site identification signs, OSHA approved safety signage, and security signage 
in accordance with Chapter 14 of the Maricopa County Zoning Ordinance. 
Screening Wall/Fence Details and Location: 
As discussed below, the property is surrounded mostly by vacant and agricultural lands with some rural 
residential to the southeast and the site bisected by Interstate 10. To ensure proper site security, related

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to these surrounding uses, the site perimeter will be enclosed with chain link fence (6 feet in height with 
the addition of 1 foot’ of barb wire) with gates where needed along the perimeter of the Project.   
Security Lighting: 
Security lighting will be limited to motion activated lighting associated with the BESS yard(s) and other 
security sensitive areas such as entry gates, and parking areas, as shown on the Plan of Development. 
All lighting installed will be directed downward and into the site, in compliance with Maricopa County 
Zoning Ordinance Article 1112, to ensure lighting will not be cast onto neighboring properties. Lighting 
required for safety operations during nighttime operational or maintenance activities will be provided by 
the associated staff/employee personnel.  
3. RELATIONSHIP TO SURROUNDING PROPERTIES 
The Project is surrounded mostly by vacant Arizona State Land Department property to the west and 
south, Bureau of Land Management property to the north and east and private land to the east. West 
Phoenix Estates, a mostly vacant residential subdivision (1969), is located to the southeast. Adjacent 
property owners will be notified of the Project, and efforts will be made to identify and address any 
concerns. The Project has been designed with buffering in mind, with large BESS setbacks (minimum 
100’ per NFPA 855), and will be enclosed by perimeter security fencing along the property edges and 
adjacent rights of way. No fencing will impede Interstate 10 or otherwise enclose existing roads adjacent 
to the Project boundary.   
 
Exhibit B – Adjacent Properties

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Surrounding Adjacent General Land Descriptions 
Direction 
Zoning 
Land Use Designation 
Land Use  
North 
RU-43 
Rural Densities (0-1) (BLM) 
Agricultural/Vacant 
East 
RU-43 
Rural Densities (0-1) (BLM/Private) 
Agricultural/Vacant 
South 
RU-43 
Rural Densities (0-1) (ASLD) & Large Lot 
Residential (1-2) (Private) 
Agricultural/Vacant 
West 
RU-43 
Rural Densities (0-1) (ASLD) 
Agricultural/Vacant 
Existing Surrounding Solar (Utilities) Land Use Approvals 
The surrounding region is characterized by active and passive agricultural land uses, solar powered 
electric generation facilities, native desert lands and rural residential. The dominant private land use 
within the area surrounding the site is vacant desert, agriculture and solar generation facilities, which 
occurs on parcels or combinations of parcels totaling several hundred to thousands of acres in irregular 
configurations to the west and southwest. Other surrounding land uses include publicly owned and 
managed Local, State, and Federal Lands. These include lands controlled by the Maricopa Flood 
Control District, Arizona State Land Trust, and Bureau of Land Management. Other surrounding land 
uses include vacant and active agricultural uses with limited and sparse distribution of privately owned 
parcels used for residential purposes within the surrounding area. Additionally, Luke Air Force Base 
(LAFB) is known to have military training routes out in this area. Under the Department of Defense 
(DOD) Clearinghouse process, energy projects greater than 199’ above ground level are required to 
go through a Formal Review. The routes in this area already fly over several existing 500kV lines and 
fly nearby several large solar projects. Although, the Project team will be proactive in addressing any 
potential concerns and will submit under the Informal Review DOD Clearinghouse process during the 
zoning process. 
 
The Harquahala Flats Energy Storage Project looks to support nearby proposed solar voltaic sites by 
providing storage capacity for the energy produced by these other energy-based projects. As a result, 
the proposed use is compatible with other similar approved and implemented solar projects to the west, 
south-west and the region as a whole. Associated facilities within this area include approved CPA’s 
and rezones for Utility (solar) land uses, PV solar generation facilities, utility corridors, transmission 
lines and a utility substation. Many of the related parcels nearby the Project have been subject to 
previous CPA approvals. Some of the other nearby projects are as follows: 
Project: 
Location (Township/Range): 
Maricopa Solar and Storage Project  
T1N R8W; T1N R9W; T2N R8W; T2N R9W 
Harquahala Sun 
T1N R9W 
Harquahala Sun II and III-V 
T1N R8W; T1N R9W 
Saddle Mountain Solar 
T1N R9W 
Eagletail Solar Farm 
T1S R9W 
Almeria Solar 
T2N R8W 
Sun Valley North & South 
T2N R8W 
Areva Solar AZ II 
T2N R7W 
Papago Solar 
T2N R8W 
Tonopah Photovoltaic 
T2N R8W

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4. LOCATION AND ACCESSIBILITY 
Location: 
The Project is located in the northeast quarter of section 18, township 2 north, range 7 west in 
unincorporated Maricopa County, Arizona. The site is roughly 4 miles west of Tonopah and 15 miles 
west of Buckeye. The site is bounded by the W. Bethany Home Road alignment on the north, N. 443rd 
Avenue on the east, W. Camelback Road on the south and is bisected by the Interstate 10 (I-10) 
Highway. The portion of the site south of I-10 will be utilized for the substation and BESS uses with the 
portion to the north being reserved for future alternative energy development. 
Access: 
 
The Project straddles Interstate 10 (I-10), approximately 22 miles west of the State Route 85 (SR 
85) connection to I-10.  
 
Regional access to the site will be from the south via I-10 to the 411th Avenue exit, west on W Indian 
School Rd, then north on 443rd Ave to the southern portion of the site on the south side of I-10. 
 
Access to the site will be via the existing the sixty-five (65) half ROW from West Phoenix Estates 
Plat, no full ROW present and 130’ full ROW 443rd Ave and onsite access driveways shown in the 
site access illustration below (Exhibit C – Site Access).   
 
Exhibit C – Site Access

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5. CIRCULATION SYSTEM 
Off-site Circulation (Access): 
The site can be accessed most directly from the I-10/411th Avenue Highway interchange. The roadway 
network serving the proposed Project starts from the I-10/411th Avenue interchange, connects 411th 
Avenue south to W Indian School Road which extends west to the intersection with 443rd Avenue, 
turning north to the site. Access will be identified with the zone change and plan of development 
applications. Final access locations will be determined in accordance with access management policies 
and permitting requirements of Maricopa County. 
 
Residential properties adjacent to the Project area are located north of W Indian School Road, south 
of I-10 between 443rd Avenue on the west and 439th Avenue on the east. The Maricopa County 
Department of Transportation may request ROW dedications/preservations along the following 
alignments: 
There would be no significant increase in traffic during the operational life of the Project that would 
require road improvements. There would be a relatively minor increase in the level of traffic during the 
approximately 12 months required for construction. This increased traffic is expected to be fewer than 
250 trips during single peak morning and evening hours, primarily for the delivery of equipment and 
supplies and the commuting of the construction workforce. A traffic impact study has been completed 
as part of the zone change process associated with the Project. The Applicant has agreed to financial 
responsibility for repair of roads used during construction, including bonding for such work, so that there 
is not public expenditure for transportation infrastructure associated with the Project. 
On-site Circulation  
Internal circulation is planned via a network of private maintenance and service drive aisles to provide 
vehicular access to the BESS units and associated equipment. The typical 20’ internal drives are being 
compacted with decomposed granite (DG), or similar road base material to minimize imperviousness 
and stormwater runoff, as proposed with an approved dust control permit from Maricopa County Air 
Quality Control. Construction and maintenance of the drives will conform to applicable requirements of 
the Maricopa County Air Quality Control Department  
Parking and Loading 
With no occupied buildings or full-time employees on-site, there is no proposed formal parking spaces 
or ADA spaces. During operations maintenance parking, loading, and temporary maintenance staging 
will occur within designated area within the BESS yard area. Loading during maintenance activities in 
the BESS yard will occur on private 20-foot (typical) all weather surfaced roads. 
6. DEVELOPMENT SCHEDULE 
Construction of phase 1, south of Interstate 10, is anticipated in late 2025. 
Street name: 
Existing ½ Width ROW: 
Future ROW (Full): 
* Future Classification: 
443rd Avenue 
65’ (Varies) 
130’ 
Local

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7. COMMUNITY FACILITIES AND SERVICES 
The Project is located within the community service district boundaries: 
 
Western Maricopa Education Center (MEC) Technical School District (District Ward No. 4) 
 
Tonopah High School (Saddle Mountain Unified District) 
 
Saddle Mountain Unified District No. 90 
The Project is not anticipated to generate any adverse impacts to the listed school districts. 
8. PUBLIC UTILITIES AND SERVICES 
Utility service(s) to the site will be provided by the following providers. No water or wastewater service 
is planned. Water for construction purposes will be transported to the site. Drinking water for employees 
will be individually provided. No permanent restrooms will be provided. Temporary facilities will be 
provided for maintenance activities as needed.  
UTILITY/SERVICE 
AGENCY/PROVIDER 
Water 
(N/A) Hauled/well 
Sewer 
(N/A) Sanitary sewer provided via accessible 
portable 
restroom 
facility 
as 
needed 
for 
maintenance activities. In the event that a future 
O&M 
building 
is 
built 
and/or 
permanent 
employees are present on the site sewer to be 
septic. 
Electric Service  
Arizona Public Service 
Fire Protection (including EMS and Ambulatory 
Services) 
Arizona Fire & Medical Authority / South County 
Fire & Medical District 
Police Protection 
Maricopa County Sheriff Office 
Refuse (Waste Management) 
Republic Services 
Telephone 
American Telephone and Telegraph (AT&T) Co 
 
 
 
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HARQUAHALA FLATS ENERGY STORAGE PROJECT –  
IUPD MODIFICATIONS TO IND-2 DEVELOPMENT STANDARDS 
STANDARD 
CATAGORY 
IND-2 ZONING 
DISTRICT 
STANDARD 
PROPOSED IND-2 
IUPD ZONING 
DISTRICT STANDARD
JUSTIFICATION 
MAX. HEIGHT 
40' 
40' 
  
MIN. FRONT 
YARD
10'-25' 
10'-25', 100’ FOR 
BESS 
ADDITIONAL SETBACK PROVIDED FOR 
BESS. 
LANDSCAPING 
ARTICLE 901.4.1: ALL 
PROPERTIES 
ABUTTING A PUBLIC 
STREET SHALL 
HAVE AN OPEN 
SETBACK AREA 
WHICH SHALL BE 
LANDSCAPED 
EXTENDING FOR 
THE FULL WIDTH OF 
THE PROPERTY 
NO LANDSCAPE 
STRIP REQUIRED 
NO LANDSCAPING PROPOSED.  
MIN. SIDE YARD 3'-10' 
3'-10', 100’ FOR BESS ADDITIONAL SETBACK PROVIDED FOR 
BESS. 
MIN. REAR YARD 25' 
25', 100’ FOR BESS 
ADDITIONAL SETBACK PROVIDED FOR 
BESS. 
MIN. LOT AREA 6,000 SQ. FT. 
6,000 SQ. FT.  
  
MIN. LOT WIDTH 60' 
60' 
  
MAX. LOT 
COVERAGE
60% MAXIMUM 
60% MAXIMUM * 
 
PARKING 
REGULATIONS 
ARTICLE 1102.1.5: 
600 SQ.FT. OF 
FLOOR AREA; 5% OF 
PARKING SPACES 
SHALL BE 
HANDICAPPED 
PARKING SPACES 
NONE REQUIRED  
PARKING AREAS WILL BE AVAILABLE 
ON THE ALL WEATHER (PRIVATE) 
ACCESS ROADS OR AT THE 
DESIGNATED PARKING AREA AT THE 
BESS YARD. PARKING IS NOT 
REQUIRED DURING OPERATION. THE 
FACILITY WILL BE UNMANNED DURING 
OPERATIONS EXCEPT FOR 
OCCASIONAL TEMPORARY SYSTEM 
OR FACILITY MAINTENANCE.   
PAVING 
REQUIREMENTS ARTICLE 1102.7.1 
PARKING/PAVING 
MATERIAL ALLOWED 
TO BE STABILIZED 
DECOMPOSED 
GRANITE WITH AN 
APPROVED DUST 
CONTROL PLAN BY 
MARICOPA COUNTY 
AIR QUALITY 
CONTROL.
TRAFFIC WILL BE LIMITED WITHIN THE 
PROJECT. PRIVATE ACCESSWAYS 
WILL BE CONSTRUCTED OF 
COMPACTED AGGREGATE BASE WITH 
A STABILIZED DECOMPOSED GRANITE 
OVERLAY, PURSUANT TO THE MCDOT 
ROADWAY DESIGN MANUAL, TO LIMIT 
ANY ISSUES WITH DUST FOR AIR 
QUALITY PURPOSES. 
Table 1: Industrial Unit Plan of Development

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1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
LOADING & 
UNLOADING 
ARTICLE 1103.2 ONE 
LOADING AND 
UNLOADING SPACE 
FOR EACH 10,000 
SQ.FT. OF FLOOR 
AREA, OR FRACTION 
THEREOF, DEVOTED 
TO SUCH USE IN 
THE BUILDING 
NONE REQUIRED 
LOADING AND UNLOADING SPACES 
WILL NOT BE REQUIRED FOR THE 
SITE. THERE WOULD BE NO ROUTINE 
DELIVERIES OR SHIPMENTS. A 
STAGING AREA IS PROVIDED FOR 
RESPONDERS. 
SIGHT VISIBILITY 
TRIANGLES 
NO OBSTRUCTIONS 
OVER 2' IN HEIGHT 
WITHIN 25'X25' SVTS
NO SVT'S AT 
PROJECT SITE 
ENTRY/EXIT POINTS, 
SECTION LINE, AND 
MID-SECTION LINE 
INTERSECTING 
ALIGNMENTS 
FENCING AT INTERSECTIONS WILL BE 
OPEN CHAIN-LINKNED AND 
THEREFORE VISIBILITY WILL BE 
MAINTAINED. ADDITIONALLY, HAVING 
NO SVT REQUIREMENT WOULD BE 
THE MOST EFFICIENT USE OF SITE 
AREA AND MAXIMIZE ENERGY 
STORAGE AND GENERATION. 
ARTICLE 902.91 
ALL USES EXCEPT 
FOR PARKING, 
LOADING, 
UNLOADING OR 
STORAGE SHALL BE 
CONDUCTED 
WITHIN A 
COMPLETELY 
ENCLOSED 
BUILDING 
ALL UTILITY USES 
PERMITTED 
OUTDOORS 
THE OPERATING USES OF THE SITE 
INCLUDE ENERGY GENERATION AND 
STORAGE. SOLAR CANNOT BE 
UTILIZED WITHIN ENCLOSED 
STRUCTURES; THEREFORE, USES 
WILL BE LOCATED OUTSIDE OF 
ENCLOSED BUILDINGS. BESS UNITS 
ARE ENCLOSED WITHIN CABINETS. 
SITE 
ENCLOSURE 
AND SCREENING
6' CMU WALL 
ADJACENT TO 
RURAL AND 
RESIDENTIAL 
ZONING 
BOUNDARIES AND 
FOR OUTDOOR USE 
OF AN INDUTRIAL 
NATURE 
CHAIN-LINK FENCING 
AND GATES SHALL 
BE ALLOWED ON 
THE PERIMETER OF 
THE PROJECT  
AS REQUIRED TO ENSURE PUBLIC 
SAFETY REQUIRED BY APPLICABLE 
ELECTRICAL SAFETY REGULATIONS 
AND PROVIDE FOR THE SECURITY OF 
THIS INFRASTRUCTURE PROJECT, 
THE APPLICANT WILL INSTALL CHAIN-
LINK FENCING (WITH GATES WHERE 
NEEDED ALONG THE PERIMETER OF 
THE PROJECT). THE APPLICANT 
PROPOSES TO USE CHAIN LINK FOR 
THE GATES ALSO, WHICH WOULD BE 
CONSISTENT WITH OTHER NEARBY 
ENERGY GENERATION PROJECTS.  
BARBED WIRE 
FENCING 
BARBED WIRE 
ATTACHED TO 
FENCES IS 
PROHIBITED FOR 
FENCES UNDER 
8'. 
BARBED WIRE 
ATTACHED TO 
FENCING UNDER 8’ 
WILL BE 
ALLOWED WITHIN 
THE 
PROPERTY 
BOUNDARIES. 
A REDUCTION IN THE HEIGHT OF 
FENCING WILL IMPROVE THE 
AESTHETIC OF THE PROJECT, 
REDUCE ENVIRONMENTAL IMPACTS 
AND BE MORE COMPATIBLE WITH THE 
NEARBY SOLAR AND AGRICULTURAL 
USES.

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1001 West Southern Avenue Suite 131, Mesa, AZ 85210 
480 207 2666 
 
MAX ELECTRIC 
TRANSMISSION 
LINE HEIGHT 
120' 
150’ 
A NEW GEN-TIE ROUTE IS REQUIRED 
FOR THIS PROJECT AND WHILE THE 
MAJORITY OF IT IS OUTSIDE THIS 
ZONING BOUNDARY THERE IS STILL 
IMPACT TO THE PROJECT SITE WITH 
THE CONNECTION TO THE 
SUBSTATION(S). UTILITY POLE 
HEIGHTS UP TO 150 FEET ARE 
REQUESTED BECAUSE 
UTILITY STRUCTURES 120 FEET OR 
LESS IN HEIGHT MAY BE INFEASIBLE 
DUE TO FINAL ELECTRICAL DESIGN 
CONSIDERATIONS AND MAY IMPACT 
THE SUBJECT ROW/PROPERTIES 
MORE, REQUIRING LESS SPACING 
AND MORE POLES. THE APPLICANT’S 
CURRENT PRELIMINARY, 
CONCEPTUAL DESIGNS INDICATE 
THAT HIGHVOLTAGE DEAD-END 
STRUCTURES UP TO 150 FEET IN 
HEIGHT MAY BE REQUIRED AND 
COULD RESULT IN LESS IMPACT. THE 
APPLICANT REQUESTS THE 
FLEXIBILITY TO MAKE THE 
NECESSARY ADJUSTMENTS, AS 
NEEDED, FOR FUTURE FINAL 
DESIGNS. ADDITIONALLY, UNDER THE 
DOD CLEARINGHOUSE PROCESS, 
ENERGY PROJECTS GREATER THAN 
199’ ABOVE GROUND LEVEL ARE 
REQUIRED TO GO THROUGH A 
FORMAL REVIEW, WHICH THE 
PROJECT TEAM HAS PROACTIVELY 
SUBMITTED UNDER THE INFORMAL 
REVIEW DOD CLEARINGHOUSE 
PROCESS. 
 
*DETACHED PV SOLAR ARRAY DO NOT CONTRIBUTE TO THE OVERALL LOT COVERAGE AS 
PER ARTICLE 1206.3.2.A. OF THE MARICOPA COUNTY ZONING ORDINANCE. 
 
 
 
(The remainder of this page is left intentionally blank)

400'
DRAINAGE ESMT.
100'
DRAINAGE ESMT.
200'
ADOT ROW
200'
ADOT ROW
25'
200'
ADOT ROW
200'
ADOT ROW
731.9'
55' ROW
PRESERVATION
10'
51'
61'
28.1'
200' PROPOSED GEN-TIE ESMT.
443RD AVE
INTERSTATE 10
ACCESS ROAD
O&M SITE
(50' X 60')
SEPTIC SYSTEM
(20' X 20')
SECURITY FENCE
PROPOSED
GEN-TIE
SUBSTATION AREA
RETENTION BASIN S3-B
GATE
SITE ENTRANCE
BATTERY
ENCLOSURE (TYP.)
INVERTER SKID
(TYP.)
CONEX
BOX (TYP.)
LOW FLOW
CROSSING
RETENTION BASIN S3-A
FEMA ZONE A
SECURITY FENCE
BERM
RETENTION BASIN S2
RETENTION BASIN S1
LOW FLOW
CROSSING
ALTERNATIVE
SITE ACCESS
AREA OF FUTURE DEVELOPMENT
FOR PHOTOVOLTAIC
GENERATING PLANT AND BESS
FEMA ZONE A
FEMA ZONE AE
FEMA ZONE AE
FEMA ZONE AE FLOODWAY
25' SETBACK
5' SETBACK
65' ROW
PRESERVATION
65' ROW
PRESERVATION
EQUALIZER PIPE
DRAINAGE CHANNEL
5' SETBACK
350'
24'
(TYP.)
24'
(TYP.)
FIRE WATER TANK
RESPONDER STAGING AREA
RESPONDER STATION
WITH REPORTING PANEL
100' MIN. BATTERY
SETBACK - TYP.
100' MIN. BATTERY
SETBACK - TYP.
100' MIN. BATTERY
SETBACK - TYP.
100' MIN. BATTERY SETBACK - TYP.
VEGETATION AREA
SECURITY FENCE
40' MIN. FLOOD ZONE
SETBACK - TYP.
40' MIN. FLOOD ZONE
SETBACK - TYP.
HARQUAHALA
FLATS ENERGY
STORAGE
©
Contact Arizona 811 at least two full
working days before you begin excavation
Call 811 or click Arizona811.com
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62869
SHANE R.
JOHANNSEN
04
02
25
EX-1
ZONING
SITE PLAN
LEGEND
PROPERTY LINE
EASEMENT LINE
SECTION LINES
EXISTING GRADE CONTOUR
STANDARD CHAIN-LINK SECURITY
FENCE
AREA OF FUTURE DEVELOPMENT
(SOLAR & BESS)
FEMA ZONE A
FEMA ZONE AE
FEMA ZONE AE FLOODWAY
20' INTERIOR ACCESS ROAD
20' ALTERNATIVE ACCESS ROAD
GEN-TIE LINE
BERM CENTERLINE
DRAINAGE CHANNEL CENTERLINE
RETENTION BASIN
DRAINAGE AREA
NORTH
NORTH
VICINITY MAP
PROJECT BOUNDARY
INDIAN SCHOOL RD
443RD AVE
INTERSTATE 10
GEN-TIE ROUTE
DELANEY SUBSTATION
N.T.S
GENERAL NOTES
MARICOPA COUNTY CASE NUMBER: Z250001/CPA250001
PRELIMINARY
NOT FOR CONSTRUCTION

Page 1 of 1 
 
 
 
 
 
 
 
 
 
 
 
Larry Morden, PE 
Planning & Development 
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003 
Phone: (602) 372-0291 
www.maricopa.gov/planning 
Email address: 
Larry.morden@maricopa.gov  
Planning & Development 
 
Engineering Plan Review 
 Date:    
May 1, 2025 
 
Memo To: Darren Gerard, AICP, Planning Manager, Department of Planning & 
Development 
 
Attn: 
Joel Landis, Planner, Planning & Development Services 
 
 
From: 
Larry Morden, P.E., Engineering Supervisor, Planning & Development 
Services 
 
cc: 
Bob Fedorka, P.E., Engineering Manager, Planning & Development 
 
Subject:   
Z250001 - Zone Change (From RU-43 to IND-2 IUPD) for Harquahala 
Flatts BESS (E2 Memo) 
 
Job Site Address: I-10 and 443rd Avenue 
 
APN(s): 
506-31-015 
 
PND Engineering Plan Review (DPR, FCD and PND Transportation) has reviewed the 
2nd submittal of the Zone Change application and has no objections subject to the 
following conditions: 
1. Without the submittal of a precise plan of development, no development approval 
is inferred by this review, including, but not limited to number of proposed building 
lots/units, drainage design, access and roadway alignments. These items will be 
addressed as development plans progress and are submitted to the County for 
further review and/or entitlement. 
 
2. 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. See 
https://www.maricopa.gov/DocumentCenter/View/74250/MCDOT-Solar-
License-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. 
 
Please contact me if you have any questions or require any additional information.

Harquahala Flats BESS 
Traffic Statement 
 
  
 
 
 
 
 
 
APRIL 2025 
Prepared By: 
 
 
 
 
Traffic Impact Study - Approved
As per Attached Comments
05/28/2025 3:22:48 PM
MCDOT Traffic Engineering

2 
Harquahala Flats BESS │ Final Traffic Statement 
April 2025 │ Ver. 2  
 
Contents 
1 
Introduction ....................................................................................................................... 3 
 
Development Description .................................................................................................... 3 
 
Street Network Characteristics ........................................................................................... 5 
 
Existing Traffic Volumes ..................................................................................................... 5 
2 
Project Characteristics ...................................................................................................... 6 
 
Daily Operations Trip Generation ....................................................................................... 6 
 
TRIP DISTRIBUTION ...................................................................................................... 6 
 
AUXILARY LANES ........................................................................................................... 6 
3 
Heavy Vehicle Construction Traffic ................................................................................... 7 
4 
Conclusions and Recommendations ................................................................................. 8 
 
Figures 
Figure 1-1  Regional Vicinity Map ................................................................................................. 4 
Figure 1-2  Anticipated Site Driveway Locations .......................................................................... 4 
Appendices 
Appendix A  
Preliminary Site Plan 
Appendix B 
Development Plan

3 
Harquahala Flats BESS │ Final Traffic Statement 
April 2025 │ Ver. 2  
 
1 INTRODUCTION 
The following Traffic Statement (TS) has been prepared to identify the potential traffic effects associated 
with the operations of the Harquahala Flats BESS development (Project). 
 
DEVELOPMENT DESCRIPTION 
The Project consists of 32.8 acres of agricultural land on the western end of Maricopa County. It is located 
south of Interstate 10 (I-10), approximately 23 miles west of the State Route 85 (SR 85) connection to I-10, 
and one mile north of Indian School Road.  Figure 1-1 depicts the Project location with a regional context.  
The site is located entirely on private land and covers a portion of one parcel: 506-31-015. The parcel is 
321 acres as a whole, but the portion north of I-10 will not be developed as part of the Project.
The proposed site plan includes an approximately 450 megawatt, battery energy storage system (BESS). 
Appendix A contains the preliminary site plan. Appendix B contains the preliminary development plan. 
Access to the site will be established by the two full-access driveways shown in Figure 1-2. 
• 
Driveway A located on 443rd Avenue just south of I-10, and one mile north of Indian School Road 
o 
Driveway A will serve as the main entrance to the site 
• 
Driveway B located on 443rd Avenue approximately 0.2 miles south of Driveway A, and 
approximately 0.8 miles north of Indian School Road 
o 
Driveway B will serve as a secondary emergency access to the site 
Maricopa County Department of Transportation (MCDOT) requires that driveways be spaced a minimum 
of 250 feet from adjacent intersections on major collector roadways. As currently planned, all driveways will 
be located at least 250 feet from major or collector intersections. For purposes of this TS, it is anticipated 
that the facility will be constructed by the end of 2026.

4 
Harquahala Flats BESS │ Traffic Statement 
April 2025 │ Ver. 2 
 
 
Figure 1-1  Regional Vicinity Map 
 
Figure 1-2  Anticipated Site Driveway Locations

5 
Harquahala Flats BESS │ Traffic Statement 
April 2025 │ Ver. 2 
 
 
STREET NETWORK CHARACTERISTICS 
The proposed site will be accessed regionally from I-10. Local access to the site will be provided by, 443rd 
Avenue, Indian School Road, and 411th Avenue. Updated future functional classifications were received by 
MCDOT for many of these roadways. Indian School Road is the only MCDOT roadway that is located in 
the vicinity of the Project site. 
Interstate 10 is located less than 200 feet north of the proposed Project site and is generally aligned east-
west. Near to the site, I-10 is a four-lane divided freeway with a 150-foot dirt median with paved shoulders 
inside and outside the travel lanes in each direction. The posted speed limit is 75 mph in the vicinity of the 
site. Even with close proximity to I-10, the nearest regional access point to the site is at the interchange 
with 411th Avenue, which is located approximately four miles to the east of the Project site. 
Indian School Road has a functional classification of major collector by MCDOT and minor collector by 
ADOT and is an east-west aligned roadway with one lane in each direction and is currently unpaved. 
443rd Avenue is a north-south aligned roadway with one lane in each direction that provides local access 
to the site. It is currently unpaved and is not a classified roadway by either ADOT or MCDOT. 
The 443rd Avenue/Indian School Road intersection is currently stop-controlled with stop signs on 443rd 
Avenue. 
411th Avenue is a paved, north-south aligned roadway with one lane in each direction that provides regional 
access to the Community of Tonopah, and the site. It is a MCDOT roadway classified as minor arterial 
south of I-10 and has a traffic interchange with I-10. 
 
EXISTING TRAFFIC VOLUMES 
Daily traffic volumes for roadways in the vicinity of the site were obtained using the ADOT Transportation 
Data Management System (TDMS) database. 2023 traffic volumes on Indian School Road are summarized 
in Table 1-1. 
Table 1–1  Existing Daily Traffic Volumes 
Location ID 
Count Location 
2023 AADT 
MMA-3350 
Indian School Road, west of 411th Avenue 
1,288 vpd 
MMA-4717 
Indian School Road, east of Salome Highway 
5 vpd 
MMA-3351 
411th Avenue, between I-10 and Indian School Road 
511 vpd

6 
Harquahala Flats BESS │ Traffic Statement 
April 2025 │ Ver. 2 
 
2 PROJECT CHARACTERISTICS 
The following section describes anticipated traffic characteristics of the proposed project site. 
 
DAILY OPERATIONS TRIP GENERATION 
Institute of Transportation Engineers (ITE) Trip Generation 11th Edition does not contain land use 
information for BESS sites such as this one. Trip generation estimates were developed for the site based 
on information provided by the project applicant. 
The BESS facility will generally be unmanned during typical operations. However, it is anticipated that 
workers will access the site periodically for regular maintenance and related activities. For purposes of this 
TS, it is anticipated that the site would generate up to 2 visits to and from the site during a typical day. It is 
assumed that one of these visits would occur in the AM peak hour and the other in the PM peak hour. 
As previously described, the site only has one main entrance or access drive (Driveway A) that will typically 
be used to access the site. There is also a second emergency access driveway (Driveway B). This analysis 
only considers trips utilizing Driveway A. A single visit would result in 1 trip in and 1 trip out at Driveway A. 
The worst-case scenario would be 1 trip in and 1 trip out at Driveway A for each visit, or 4 total daily trips 
(2 occurring in the AM peak hour and 2 occurring in the PM peak hour). It is anticipated that of these trips 
to and from the facility will be completed in a pickup truck. A trip generation summary for the worst-case 
scenario is provided in Table 2-1. 
Table 2–1  Worst-Case Project and Driveway Trip Generation 
Trip Destination 
Daily 
Trips 
AM Trips 
PM Trips 
Inbound 
Outbound 
Inbound 
Outbound 
Driveway A Trips 
4 
1 
1 
1 
1 
Total Driveway Trips 
4 
1 
1 
1 
1 
 
     TRIP DISTRIBUTION 
Based on the existing roadway network, it is assumed that the Project traffic will come to/from I-10 utilizing 
411th Avenue, Indian School Road, and 443rd Avenue. Primary site access is expected to be provided by 
443rd Avenue. 
      AUXILARY LANES 
The MCDOT Roadway Design Manual provides criteria for when left and right turn auxiliary lanes are to be 
provided at site access driveways. 
MCDOT requires the installation of a right turn lane at a project access drive when either of the following is 
met:

7 
Harquahala Flats BESS │ Traffic Statement 
April 2025 │ Ver. 2 
 
• 
The outside lane has an expected volume of 250 vph or greater and the right turn volume is greater 
than 55 vph. 
• 
Any three of the below criteria are met:  
a. At least 5,000 vehicle per day are using or are expected to be using the adjacent street. 
b. The roadway’s posted speed limit is greater than 35 mph. 
c. At least 1,000 vehicles per day are using or are expected to use the driveway. 
d. At least 30 vehicles are expected to make right-turns into the driveway within a one-hour period. 
Based on the existing traffic volumes and the anticipated worst-case site traffic, right turn lanes are not 
warranted at either of the proposed access driveways. 
The MCDOT requirements for installation of a left turn lane are shown in Figure 2-1. 
 
Source: MCDOT Roadway Design Manual 
Figure 2-1  MCDOT Left Turn Volume Warrant Criteria 
The minimum required peak hour volume of left turning vehicles to warrant a left turn lane on a one-lane 
roadway is 8 vph. It is not anticipated that the site will have more than 4 total daily trips (2 inbound / 2 
outbound), which would only occur at Driveway A. As such, left turn lanes are not warranted at either of the 
proposed access driveways. 
 
3 HEAVY VEHICLE CONSTRUCTION TRAFFIC 
Based on similar BESS facility construction trip generation estimates, it is expected that the project site will 
generate approximately 2 heavy vehicle trips during each of the AM and PM peak hours (1 trips in and 1 
trips out) for a total of 4 daily trips (2 trips in and 2 trips out). It is expected that these trips will be primarily 
for deliveries.  
There are two classified roadways in the vicinity of the site that would experience construction traffic: Indian 
School Road as a major collector, and 411th Avenue as a minor arterial. Table 2.1 of the MCDOT Roadway 
Design Manual lists the maximum average daily traffic (ADT) volume for various classifications and 
configurations. 
Indian School Road, which is a rural, two-lane, undivided major collector, has a maximum ADT of 8,800 
vehicles per day (vpd). Table 1-1 of this TS shows the highest recorded existing daily volume on Indian 
School Road in the project vicinity is 1,288. The addition of construction traffic, particularly heavy vehicle

8 
Harquahala Flats BESS │ Traffic Statement 
April 2025 │ Ver. 2 
 
traffic, should more than accommodate this traffic with the remaining 8,792 vpd road capacity. 411th 
Avenue, which is a rural, two-lane, undivided minor arterial, has a maximum ADT of 9,500 vpd. Table 1-1 
of this TS shows the highest recorded existing daily volume on 411th Avenue in the project vicinity is 511 
vpd. The addition of construction traffic, particularly heavy vehicle traffic, should more than accommodate 
this traffic with the remaining 9,492 vpd road capacity. 
Based on the capacity and heavy vehicle results, it is not anticipated that the surrounding roadways will 
require mitigations to accommodate heavy vehicle site traffic during construction even if the number of daily 
heavy vehicle deliveries is increased. 
4 CONCLUSIONS AND RECOMMENDATIONS  
The Project is expected to generate a maximum of 2 daily visits to the site or 4 daily trips at Driveway A. 
This worst-case scenario would occur when maintenance activities are periodically required on the site and 
would not be a daily occurrence, as the facility is generally unmanned.  Based on the current roadway 
network conditions, existing traffic, and minimal traffic generated by the Project, all streets within the study 
area are anticipated to facilitate access to the site without traffic operations deficiencies.  Additionally, based 
on MCDOT standards, auxiliary turning lanes are not required at the Project access driveways. 
During construction, the site is expected to generate approximately 2 heavy vehicle trips during each of the 
AM and PM peak hours (1 trip in and 1 trip out) for a total of 4 daily trips (2 trips in and 2 trips out). It is 
expected that these trips will be primarily for deliveries. Additional construction traffic is expected to be 
accommodated by the surplus capacity available on the surrounding roadway network. Based on these 
capacity and heavy vehicle results, it is not anticipated that the surrounding roadways will require 
mitigations to accommodate heavy vehicle site traffic during construction even if the number of daily heavy 
vehicle trips is higher than what is reported in this TS.

Harquahala Flats BESS │ Traffic Statement 
April 2025 | Ver 2 
 
APPENDIX A: PRELIMINARY SITE PLAN

Harquahala Flats BESS │ Traffic Statement 
April 2025 | Ver 2 
 
APPENDIX B: DEVELOPMENT PLAN