03. 04. CPA2023009 Z2023059 PZ Report

Maricopa County — Planning & Zoning (2023-10-19)

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CPA2023009 and Z2023059 
Page 1 of 12 
 
 
Report to the Planning and Zoning Commission 
Prepared by the Maricopa County Planning and Development Department 
 
 
Cases: 
CPA2023009 & Z2023059 – Gila Hydrogen Facility  
 
 
 
 
Hearing Date: 
October 19, 2023 
 
Supervisor District: 
5 
 
 
  
 
Applicant: 
Stephen Anderson, Gammage & Burnham  
 
Owners: 
Jae Koo Huh and Miriam Huh Family Trust 
   
Requests: 
General Comprehensive Plan Amendment to change the land use 
designation in the Vision 2030 Comprehensive Plan from Rural 
Development Area (0-1 d.u./ac) to Heavy Industrial,  and zone change with 
overlay from Rural 43 to IND3 IUPD 
 
  
 
Site Location: 
Generally located 1,000’ north and 3,200’ west of the NWC of Interstate 10 
and Salome Highway in the Tonopah area 
 
  
Site Size: 
172.49 acres 
 
Density: 
N/A 
 
County Island:  
No 
 
 
County Plan: 
Rural Development Area (0-1 d.u./ac)  
 
Municipal Plan: 
N/A 
 
Municipal Comments: 
None received to date  
 
Support/Opposition: 
One email in opposition  
 
Recommendation: 
Approve (CPA2023009) 
 
Recommendation: 
Approve with conditions (Z2023059)

CPA2023009 and Z2023059 
Page 2 of 12 
Project Summary: 
 
1. 
The applicant is requesting a general comprehensive plan amendment (CPA) to change the land 
use designation in the Vision 2030 Maricopa County Comprehensive Plan from Rural 
Development Area to Heavy Industrial.  Additionally, the applicant is requesting a subsequent 
zone change with overlay from Rural-43 to IND-3 IUPD.  Both requests are on the same subject 
parcel covering about 172.49 acres in the far western stretches of the county.  The purpose of 
the requests is to facilitate the future development of a hydrogen production facility that will 
produce hydrogen from water via electrolysis, which is a process that will convert water into 
hydrogen and oxygen gases using electricity.  The plant will capture the hydrogen gas and convert 
it to liquid via a process involving cryogenic fluids and compressors.  The hydrogen will be stored 
and shipped off site as a liquid in tanker trucks.    Per the applicant’s narrative the industrial 
equipment will occupy about a third on the site and the rest of the site will be dedicated to large 
evaporation ponds, engineered drainage features, and open space. Staff notes that no Plan of 
Development (POD) was included with the zoning case, and a POD will be required prior to 
approval of construction permits. 
 
2. 
The site is comprised of a single property covering all 172.49 acres.  The property is in a very 
remote part of the county, being over seven miles west of the western most boundary of the 
Tonopah/Arlington Area Plan.  Somewhat unusual for such a remote site, it is also located very 
close to the junction of Salome Hwy and Interstate 10, allowing for prime interstate access for 
distribution tankers.  The applicant’s narrative states the remote location was ideal given the 
industrial nature of the proposed hydrogen production.  The narrative also states that interstate 
access will provide a large opportunity for site users as it will allow the produced hydrogen to be 
easily shipped to markets both in the Phoenix area as well as Los Angeles and Southern 
California.  
 
3. 
Adjacent land use of the site is almost exclusively vacant.  Much of the land to the north is publicly 
owned State Trust Land and appears to be relatively undisturbed.  Parcels to the west are vacant 
but appear to have been used for grazing either by livestock or wild animals as vegetation is much 
less sparse than similar land in the general area.  There are some major infrastructure corridors 
near the parcel.  A canal owned by the federal government runs along the eastern boundary of the 
site.  Salome Hwy. boarders the southern boundary of the site and Interstate 10 is only about a 
1,000’ south.  The closest permanent land users appear to be some farms south of the interstate, 
about half a mile south of the subject site.  The applicant states in the narrative that the nearest 
residence is over a mile from the subject site boundaries, which is especially noteworthy given 
the sheer size of the site itself.  
 
4. 
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 narrative states that the Gila Hydrogen Facility is an improvement to the Comprehensive Plan 
due to the benefits to the state, county, local and regional economy.  The narrative states that 
initial investments on the site will be in the $1 billion range, making this a significant financial 
investment in the county.  Additionally, construction of the facility will create approximately 300 
construction jobs, with a construction period of approximately 30 months.  While the construction 
jobs will mostly only last during the initial construction phase of the site, the applicant states there 
will be about 30 highly skilled, well-paying permanent jobs on site in addition to about 60 truck

CPA2023009 and Z2023059 
Page 3 of 12 
positions for truck drivers distributing the hydrogen to market. The narrative also points that the 
facility will help diversify the regions energy sources as the applicant posits hydrogen will become 
a major fuel source for trucks, fleet vehicles, forklifts, and eventually consumer vehicles in the 
coming decades. Therefore, the amendment constitutes an overall improvement to the Vision 
2030 Maricopa County Comprehensive Plan and is not solely for the good or benefit of a particular 
landowner/owner at a particular point in time. 
 
Whether the amendment will adversely impact all or a portion of the planning area.  
 
A. 
Altering acceptable land use patterns to the detriment of the plan – According to the 
narrative, the amendment will not alter any surrounding land uses or land use patterns.  
Most of the adjacent land is vacant and largely unused currently.  Given the remoteness 
of the area it is unlikely that and significant development on surrounding properties would 
occur in the foreseeable future. The narrative states the specific site is appropriate for the 
proposed land use designation as it is near a major interstate interchange. 
 
B. 
Requiring public expenditures for larger or more expensive infrastructure - The narrative 
states that the project would not require public expenditures for larger or more expensive 
infrastructure.  The costs of the project’s infrastructure, notably infrastructure for water 
and wastewater, needs shall be borne by the developer. 
 
C. 
Requiring public improvements to roads, sewer, or water systems that are needed to 
support the planned land uses – The narrative states that the project would not require 
improvements to roads as traffic due to the proposed use will be minimal. The applicant 
will need to make significant improvements from water and wastewater, but costs will be 
borne by the developer and all such infrastructure will be on site. Existing roads will serve 
the project and any additional project infrastructure needs shall be borne by the developer. 
 
D. 
Adversely impacting planned uses because of increased traffic – The narrative indicates 
there will be a negligible increase in traffic that will be easily handled by the existing 
highway, interstate, and interchange infrastructure near the site.  The narrative states the 
increase in traffic on the interstate due to this site will be unnoticeable. 
 
E. 
Affecting the livability of the area or health or safety of present and future residents – 
The narrative asserts that there are no present residents within a mile radius of the site – 
a fact that the applicant claims will remain unchanged for the foreseeable future.  The 
applicant states that the remoteness of the site is a primary reason why this location was 
selected as to not negatively impact anyone’s health or welfare by locating a large 
industrial site near their residence.  Additionally, the project will follow federal, state and 
local regulations regarding the production, use, storage, and transport of hydrogen gas 
and liquid.  The applicant has secured a will-serve letter for fire protection and has actively 
been working with applicable fire protection agencies to establish a best practice fire-
mitigation plan. 
 
F. 
Adversely impacting the natural environment or scenic quality of the area in 
contradiction to the plan – The applicant states that the project will not significantly 
impact the natural environment or overall scenic quality of the area.  The applicant states 
that the site is relatively flat and lacks significant drainage features.  The narrative states 
that the area is not one of significant scenic distinction.

CPA2023009 and Z2023059 
Page 4 of 12 
 
Animals 
The applicant performed a preliminary field-site investigation, which per the applicant 
yielded little evidence of any significant wildlife habitation on the site. The Arizona Game 
and Fish Department (AZGFD) has commented on the proposed project regarding 
measures to protect wildlife encountered on the site. The Sonoran Desert Tortoise and 
the Western Burrowing Owl were identified as the two species of most concern in this 
area.  Satisfaction of those comments are part of required conditions of the companion 
Zone Change with Overlay case.  
 
Plants 
The applicant will salvage or dispose of protected native plants in accordance with AAC 
Title 3, Chapter 3, Article 11. 
 
Scenic Views 
The narrative describes the proposed hydrogen facility as having an “industrial 
appearance” as there will be several tall towers, exposed pipes, and large tanks on site.    
However, the narrative states that the size of the parcel will allow the facility to be setback 
as far as possible from the highway and freeway, measures that the applicant claims will 
mitigate any detriment to scenic views of the area. 
 
Whether the amendment is consistent with the overall intent of the Comprehensive Plan. 
 
The applicant’s narrative states that the request is consistent with the overall intent of the 
Comprehensive Plan by addressing the Strategic Priorities for Maricopa County such as creating 
a benefit and asset to the county and by not introducing uses that would be detrimental to the 
surrounding environment, neighbors, existing infrastructure, or create a financial burden for the 
general public. The applicant argues that this is demonstrated through the economic benefits 
provided in consumption and export of the product (liquid hydrogen), the hiring of workers and 
government revenue gained through the proposal.  In addition, the narrative asserts that the 
project contributes to an effective and efficient infrastructure and diversifies the energy portfolio 
of the county. 
 
The extent to which the amendment is consistent with the specific goals and policies contained 
within the plan. 
 
The applicant’s narrative contains a substantial list of Goals and Policies from the Vision 2030 
Maricopa County Comprehensive Plan. This staff report identifies which Goals and Policies the 
applicant’s narrative addressed. 
 
Vision 2030 Maricopa County Comprehensive Plan 
 
Land Use Element – Goal 3, Policy 20, Policy 21, Policy 22, Policy 27 
 
Transportation Element – Goal 2, Policy 11 
 
Environment Element – Goal 1, Policy 5 
 
Economic Growth Element –Goal 2, Policy 6, Policy 10 
 
Energy Element –Goal 2, Policy 2

CPA2023009 and Z2023059 
Page 5 of 12 
 
 
Other pertinent information as requested by the Maricopa County Planning Department Staff. 
 
The applicant was responsive and provided quality information as requested by Maricopa County 
Planning Department Staff. 
 
 
5. 
The subject property did not have any significant history prior to the current pursuit of change in 
land use designation and zoning entitlement.  There was a temporary use permit for a 
meteorological monitoring station, TU2022018, administratively approved on May 13, 2022, over 
400 sq feet of the far northwestern corner of the subject site.  The initial pre-application meeting 
on the proposal was held on November 8, 2022.  The formal submittal of both CPA2023009 and 
Z2023059 occurred on May 5, 2023 and the technical advisory committee meeting was held on 
June 6, 2023. 
 
REGULATION 
BASE ZONING 
DISTRICT 
REGULATIONS (IND-3) 
PROPOSED ZONING REGULATIONS 
(IND-3 IUPD) 
Height  
40’ 
150’ 
Min. Front Yard 
20’(abutting any major 
street, section line 
road, state or federal 
highway) 
20’ (abutting any major street, section 
line road, state or federal highway) 
Min. Side Yard 
5’ 
5’ 
Min. Rear Yard 
25’ (abutting rural or 
residential) 
25’ (abutting rural or residential) 
Min. Lot Area 
6,000 sq. ft. 
6,000 sq. ft. 
Min. Lot Width 
60’ 
60’ 
Max. Lot Coverage 
60% 
60% 
Uses Permitted 
All uses permitted in 
the IND-3 zoning 
district 
Hydrogen production and ancillary 
uses including electrical sub station 
only 
Load and Unloading 
Regulations 
For all wholesale, 
manufacturing and 
industrial buildings 
there shall be one 
loading and unloading 
space for each 10,000 
sq ft of floor area 
For all wholesale, manufacturing and 
industrial buildings there shall be 
one loading and unloading space for 
each 100,000 sq ft of floor area

CPA2023009 and Z2023059 
Page 6 of 12 
Site Screening 
Solid masonry wall not 
less than 6’ in height 
Minimum 6’ chain-link fence topped 
with barbed wire along all property 
lines 
Parking 
Minimum One stall per 
600 square feet of 
floor area 
Minimum One stall per 10,000 
square feet of floor area 
Carpool stalls 
15% of required 
parking shall be 
designated carpool 
stalls 
Minimum of 10 carpool stalls 
 
 
2023 aerial

CPA2023009 and Z2023059 
Page 7 of 12 
Zoning Map 
 
 
Existing On-Site and Adjacent Zoning / Land Use: 
 
6. 
On-site: 
 
Rural - 43 / vacant 
North: 
Rural - 43 / vacant 
South: 
Rural - 43 / Salome Hwy then ROW for Interstate 10 
East: 
Rural - 43 / vacant 
West: 
Rural - 43 / vacant 
 
 
Utilities and Services: 
 
7. 
Water: 
 
On-site wells to Harquahala aquifer via water transfer rights 
Wastewater: 
On-site septic 
School District: 
Arlington Elementary School District and Buckeye Union High School 
District 
Fire: 
Harquahala Fire District 
Police:  
Maricopa County Sherriff’s Office 
 
Right-of-Way:

CPA2023009 and Z2023059 
Page 8 of 12 
 
8. 
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 
Salome Hwy 
60’ 
65’ 
Minor Arterial 
 
Adopted Plan: 
 
9. 
Vision 2030 Maricopa County Comprehensive Plan: The entire site (approx. 172.49 acres) is 
designated as Rural Development Area (0-1 d.u./ac.).  The Rural Development Area land use 
designation encourages low-density rural residential and agricultural uses. 
 
Public Participation Summary: 
 
10. 
The applicant performed satisfactory public participation that met and exceeded minimum 
requirements and expectations.  The applicant sent notice of the proposals to all property owners 
within half a mile of the subject site, well beyond the required 300’ notification buffer, as well as 
all identified areas of interest.  In addition the site was posted with signage according to all 
requirements laid forth in the ordinance.  The applicant reported one response via email 
requesting information on hearing date and location.  The applicant stated that follow-up 
information was provided to the inquire, but no continued communication commenced. This is 
consistent with the level of response received from staff, with only one email in opposition.   The 
lone email in opposition posed some general concerns over altering historic drainage patterns.  
Staff notes that a grading and drainage plan for the site will need to be approved by the county 
engineering staff prior to any construction approvals for the facility.  Staff has received 
communication from several state and federal agencies, including Arizona Game & Fish, Arizona 
State Land Department and Luke Air Force Base.  In general staff received responses of interest 
but no concern.  Arizona Game and Fish included some requested conditions of approval which 
are discussed below.  
 
Outstanding Concerns from Reviewing Agencies: 
 
11. 
N/A 
 
Staff Analysis: 
 
12. 
The applicant has made a poignant argument for the proposed heavy industrial land use 
designation in order to allow for a large-scale hydrogen production facility.  Staff recognizes the 
benefits of the county becoming a front runner in hydrogen production as hydrogen is becoming 
an alternative fuel source with rapidly expanding potential.  The change in land use designation 
will bring clear economic benefits from large-scale financial investment, temporary construction 
jobs and permanent high skilled employment opportunities.  Staff notes that while 30 permanent 
jobs in a large metropolitan area may not seem significant, they represent a much larger benefit 
in a remote area where job sites are scarce and far apart.  Staff concurs with the applicant’s 
assessment that the remote area is suitable for such a use as it will ensure the least amount of 
impact to human habitation.  Staff notes that the site is over seven miles west of the western 
boundary of the Tonopah/Arlington Area Plan and is outside of the Phoenix Active Management 
Area.

CPA2023009 and Z2023059 
Page 9 of 12 
Proximity to Tonopah / Arlington Area Plan 
 
 
 
13. 
Staff had some initial concerns over water usage for the proposed site as water is essentially 
used as a raw material to produce the desired product.  The applicant has provided ample 
documentation that they have a secure water source that will serve the site for the projected 
lifespan of the facility, which the applicant states is estimated to be 30 years.  The site is not 
within the Phoenix Active Management Area but rather located within the Harquahala Irrigation 
non-expansion Area.  The applicant provided documentation of rights to use water stored in the 
VIDLER Underground Storage Facility, which is in La Paz County.  Since the subject site is within 
the same aquifer as the underground storage, the applicant may draw their allotted supply from 
on site wells.  As such, staff have no concerns over water usage on site. 
 
14. 
Along with the zone change with overlay request, the applicant has also requested several 
standards to be altered in order to best serve the proposed facility.  Perhaps the most visually 
impactful is the request to allow structures up to 150’, which is well above the base zoning height 
maximum of 40’.  The applicant made a strong argument justifying the height as necessary for 
the type of equipment that will be a part of the facility. The applicant states that the tallest 
structures on site will be vent stacks but other components to the site will include electrolyzes, 
liquefaction equipment, hydrogen storage structures, truck loading equipment, and associated 
infrastructure including an electrical sub station to process electricity coming onto the site (the 
site will not generate electricity).  Additionally, the narrative points to the fact that the site was 
specifically selected so that the height and size of the facility would provide as minimal visual 
impacts as possible.  The applicant made a similar argument in conjunction with the request for 
reduced site screening, which is requested to be a 6’ chain link fence topped with barbed wire.  
Staff notes that with the increased height of 150’, and the sheer size of the site in general, a solid 
screen wall of 6’ in height would do little to obscure much of the site.  As such staff has no 
objections to the requested reduction in screening requirements.  The remaining requests are all 
related to parking and loading/unloading spaces.  Staff is of the general opinion that with the 
remote location of the site, parking and loading stalls mostly only be utilized by employees of the 
facility.  As such staff feels that the applicant should know best what the parking needs of the 
site are, and has no concern of reducing the parking standards to fit their needs.  Additionally, it 
should be noted that the use of the site is limited to only hydrogen production and ancillary uses.  
As such, any new use would require a modification to the IUPD overlay, at which time the parking 
may be re-evaluated to ensure it is still appropriate.

CPA2023009 and Z2023059 
Page 10 of 12 
 
 
 
 
 
 
 
Conceptual Rendering Provided By Applicant  
 
 
 
15. 
Arizona Game and Fish submitted a comprehensive review complete with several recommended 
conditions to ensure minimal impact to the wildlife that inhabit the subject area.  These include 
additional surveys to ensure with certainty the presence, or lack thereof, of the Sonoran Desert 
Tortoise and the western burrowing owl.  If either species is identified AGFD requests 
coordination with their department to ensure best practices are employed in clearing and 
relocating the species prior to development of the site.  It is also recommended that no animal is 
relocated more than a quarter mile from the subject site.  The department also detailed several 
recommended design and use guidelines to minimize wildlife impacts during both construction 
and the life of the facility.  These include back filling trenches or providing escape ramps, 
employing deterrent methods to discourage avian use of the evaporation pond, minimizing site 
lighting, among others.  Staff concurs with their recommendations. 
 
16. 
Staff supports both of the applicant’s proposals. The applicant provided ample evidence to 
support the change in land use designation as being in line with county goals and policies.  A 
strong case has been made that the change will be very beneficial for the county and the state as 
a whole.  Additionally, staff has no concerns over the requested zone change with overlay.  Any 
such, concerns that may be accompanied with such a large scale industrial development have 
been quelled by the applicant’s diligence in selecting a remote area that shall prove to provide 
minimal disturbance once the use is up and running.  Further, the IUPD overlay will limit the site 
to just hydrogen production, and ancillary uses, so staff is not concerned with the potential for 
another, unrelated use to occur onsite without additional entitlement. 
 
 
Recommendation:

CPA2023009 and Z2023059 
Page 11 of 12 
 
17. 
Staff recommends the Commission adopt a motion recommend that the Board of Supervisors 
approve CPA2023009 
 
18. 
Staff recommends the Commission adopt a motion recommending that the Board of Supervisors 
approve Z2023059 subject to the following conditions ‘a’ – ‘g’: 
 
a. 
Development of the site shall be in substantial conformance with the Zoning Exhibit 
entitled “Gila Hydrogen“, consisting of 2 full-size sheets, dated August 17, 2023, and 
stamped received August 17, 2023, 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 “Gila Hydrogen Facility”, consisting of 41 pages, dated August 17, 2023 and 
stamped received August 17, 2023, except as modified by the following conditions. 
 
c. 
 The following conditions as per Arizona Game and Fish recommendations shall apply: 
 
1. The applicant shall coordinate with Arizona Game and Fish to come up with an 
acceptable plan of removal if any evidence of Sonoran Desert Tortoise or the Western 
Burrowing Owl are found on site. 
2. Deterrent measures shall be in place to prevent birds and other wildlife gathering at 
the evaporation pond. 
3. All other recommendations provided by Arizona Game and Fish shall be adhered to, 
whenever possible, as per the letter dated June 2, 2023. 
 
d. 
The following Planning Engineering Conditions shall apply: 
 
1. Without submittal of a precise plan of development, no development approval is 
inferred by this review, including, but not limited to number of proposed buildings, 
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. Dedication of right-of-way across the Salome highway site frontage (both parcels) is 
required to provide 65’ half-width from center.  Dedication shall occur prior to the 
issuance of building permits. 
3. Right-of-way preservation along the east side of 523rd ave shall be 25’ 
4. 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; MDOT Roadway Design Manual; and current engineering 
policies standards, and best practices at the time of application for construction. 
 
e. 
The following IND-3 IUPD standards shall apply to the site: 
 
1. Maximum Height: 150’ 
2. Parking: one stall per 10,000 sq ft floor area 
3. Carpool Parking Stalls: Minimum 10 dedicated carpool stalls 
4. Site Screening: minimum 6’ chain link fence topped with barbed wire

CPA2023009 and Z2023059 
Page 12 of 12 
5. Loading and Unloading spaces: one loading/unloading space per 100,000 sq feet of 
floor area 
6. Use: use of site shall be limited to production of hydrogen and ancillary uses  
 
f. 
Administrative approval of a Plan of Development will be required prior to approval and 
issuance of construction permits to develop and establish use of the site. Prior to 
issuance of a building permit, written confirmation will be required from the emergency 
fire protection jurisdiction having authority that the facility has been designed in 
accordance with their regulations and requirements, and that emergency fire protection 
service will be provided to the facility. Prior to issuance of the certificate of occupancy, 
local fire protection jurisdiction review and approval will be required. 
 
g. 
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 
shall revert to the zoning that existed on the date of application.  It is, therefore, stipulated 
and agreed that either revocation due to the failure to comply with any conditions, does 
not reduce any rights that existed on the date of application to use, divide, sell or possess 
the property and that there would be no diminution in value of the property from the value 
it held on the date of application due to such revocation of the Zone Change.  The Zone 
Change enhances the value of the property above its value as of the date the Zone Change 
is granted and reverting to the prior zoning results in the same value of the property as if 
the Zone Change had never been granted. 
 
 
 
Presented by: 
Joseph Mueller, Planner 
Reviewed by: 
Matthew Holm, AICP, Planning Supervisor 
 
Attachments: 
Case Maps (2 pages) 
 
Land Use Exhibit (reduced 8.5”x11”, 1page) 
 
Zoning Exhibit (reduced 8.5”x11”, 1 Page) 
 
Narrative Report (CPA2023009) (11 pages) 
 
Narrative Exhibits (CPA2023009) (9 pages) 
 
Narrative Report (Z2023059) (20 pages) 
 
Narrative Exhibits (CPA2023009) (21 pages) 
 
MCDOT Future Right-of-way Memo (2 pages) 
 
MCESD comments (4 pages) 
 
DPR comments (3 pages) 
 
AZGF Comments (15 pages) 
 
ASLD Response (1 page) 
 
LAFB Response (2 pages) 
 
opposition (1 page)

/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 173 approx.
Generated October 10, 2023 3:00 PM
CPA2023009
Application Name:
Legal Description
Gila Hydrogen Facility
Applicant
Case Address
,
STEPHEN ANDERSON for GAMMAGE & BURNHAM
Applicant Phone/Email
Parcel Primary:
602.256.4422
SANDERSON@GBLAW.COM
Map scale 1:8,158
Supervisor District No.
GILA HYDROGEN FACILITY

/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 173 approx.
Generated October 10, 2023 3:12 PM
Z2023059
Application Name:
Legal Description
GILA HYDROGEN FACILITY
Applicant
Case Address
,
STEPHEN ANDERSON for GAMMAGE & BURNHAM
7653 N 523RD Ave
Applicant Phone/Email
Parcel Primary:506-18-038A
602.256.4422
SANDERSON@GBLAW.COM
TONOPAH AZ 85354
Map scale 1:8,158
Supervisor District No.
ZONE CHANGE WITH OVERLAY RURAL - 43 TO I-3 IUPD

100'
100'
SALOME HASSAYAMPA ROAD
100'-0" EXISTING PUBLIC R/W
HARQUAHALA VALLEY DISTRIBUTION SYSTEM
U.S.B.R. TRACT No. HV-L-5
125'-0" R/W
OWNER:  WIS PARTNERS IV LLC
APN:  506-18-004G RU-43
OWNER:  WIS PARTNERS IV LLC
APN:  506-18-001A RU-43
OWNER:  BUREAU OF LAND MANAGEMENT (BLM)
APN:  N/A RU-43
OWNER:  VERMA MD2 515 / SALOME HWY 128 LLC
APN:  506-18-037F RU-43
OWNER:  VERMA MD2 515 / SALOME HWY 128 LLC
APN:  506-18-037E RU-43
OWNER:  STATE TRUST LAND
APN:  N/A
OWNER:  STATE TRUST LAND
APN:  N/A
APN 506-18-038C
172.199 ACRES (SURVEYED)
25' REAR YARD SETBACK LINE
5' SIDE YARD SETBACK LINE
5' SIDE YARD SETBACK LINE
25' REAR YARD SETBACK LINE
1836.29'
3147.79'
3422.03'
411.21'
2347.02'
20' FRONT YARD SETBACK LINE
5' SIDE YARD SETBACK LINE
5' SIDE YARD SETBACK LINE
15' ANTICIPATED DEDICATION
20' ROW RESERVATION
5' SIDE YARD SETBACK LINE
20' ROW RESERVATION
20'
5'
15'
20'
15'
20'
20'
5'
25
25'
20' FRONT YARD SETBACK LINE
15' ANTICIPATED DEDICATION
EXISTING ASPHALT ROADWAY (2 x 12' LANES)
50' FENCE SETBACK FROM PROPERTY LINE
TO AVOID EXISTING RUNOFF DIVERSION
DITCH ALONG WEST SIDE OF WATER CANAL
APN 506-18-038B
0.291 ACRES (SURVEYED)
A
ISSUED FOR PERMIT
OPEN
D. LEWIS
T. SHIN
DRAWING NUMBER
PROJ MGR
ENG MGR
LEAD ENG
ENGINEER/DESIGN
ORIGINATOR
D. LEWIS
DATE
REV
CHECKED BY
DESIGN BY
T. JOHNSTON
M. SMITH
G. ROUSH
1
2
3
4
5
6
7
8
9
F
E
D
C
B
A
20043365-CS-102
- PRELIMINARY -
NOT FOR CONSTRUCTION
10
11
H
G
GILA HYDROGEN, LLC
GILA H2 FACILITY
SCALE: 1" = 100'-0"
S C A L E   I N   F E E T
100
0
100
200
ZONING STATISTICS
CURRENT ZONING:  RURAL-43
PLANNED ZONING:  IND-3 IUPD HEAVY INDUSTRIAL UNIT PLAN
OF DEVELOPMENT
PARCELS:  APN 506-18-038A,  APN 506-18-038B
TOTAL PROPERTY AREA:  172.49 ACRES
MAXIMUM LOT COVERAGE = 60% OF LOT AREA
NOTES
1. THE HORIZONTAL PROJECT DATUM IS BASED UPON THE STATE PLANE COORDINATE SYSTEM;
NAD83 ARIZONA STATE PLANE, CENTRAL ZONE.
2. BASED ON THE NATIONAL FLOOD INSURANCE PROGRAM FIRM MAP NO. 04013C1525M, MAP REVISED SEPTEMBER 18,
2020, THE SUBJECT PROPERTY LIES WITHIN FLOOD ZONE X AND IS IDENTIFIED AS FOLLOWS:  0.2% ANNUAL CHANCE
FLOOD HAZARD, AREAS OF 1% ANNUAL CHANCE FLOOD WITH AVERAGE DEPTH LESS THAN ONE FOOT OR WITH
DRAINAGE AREAS OF LESS THAN ONE SQUARE MILE.
3. SEWAGE/GRAY WATER GENERATED AT THE SITE WILL BE HANDLED WITH AN ON-SITE SEPTIC TANK AND LEACH FIELD
SYSTEM.
4. FIRE COVERAGE IS PROVIDED BY HARQUAHALA FIRE DISTRICT STATION 371 WHICH IS LOCATED APPROX. 9 MILES SOUTH
OF THE SUBJECT PROPERTY.  FIRE SERVICE IS DISPATCHED BY THE PHOENIX FIRE REGIONAL DISPATCH CENTER.
GILA HYDROGEN, LLC
ZONING  EXHIBIT
B
ISSUED FOR PERMIT
OPEN
D. LEWIS
M. SMITH
VICINITY MAP
PROJECT
LOCATION

A
ISSUED FOR PERMIT
OPEN
D. LEWIS
T. SHIN
DRAWING NUMBER
PROJ MGR
ENG MGR
LEAD ENG
ENGINEER/DESIGN
ORIGINATOR
D. LEWIS
DATE
REV
CHECKED BY
DESIGN BY
T. JOHNSTON
M. SMITH
G. ROUSH
1
2
3
4
5
6
7
8
9
F
E
D
C
B
A
20043365-CS-103
- PRELIMINARY -
NOT FOR CONSTRUCTION
10
11
H
G
GILA HYDROGEN, LLC
GILA H2 FACILITY
GILA HYDROGEN, LLC
ZONING EXHIBIT
B
ISSUED FOR PERMIT
OPEN
D. LEWIS
M. SMITH
PROPERTY DESCRIPTION
DESCRIPTION FROM TITLE COMMITMENT:
THE LAND REFERRED TO HEREIN BELOW IS SITUATED, IN THE COUNTY OF MARICOPA, STATE OF ARIZONA, AND IS DESCRIBED AS FOLLOWS:
PARCEL NO. 1: INTENTIONALLY DELETED.
PARCEL NO. 2:
LOTS 3 AND 4: THE WEST HALF OF LOT 2 AND THAT PORTION OF THE SOUTH HALF OF THE NORTHWEST QUARTER; WEST HALF OF THE SOUTHWEST QUARTER OF THE
NORTHEAST QUARTER; NORTHWEST QUARTER OF THE NORTHWEST QUARTER OF THE SOUTHEAST QUARTER OF SECTION 3, TOWNSHIP 2 NORTH, RANGE 9 WEST, OF THE
GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, LYING NORTH OF THE RIGHT OF WAY (100 FEET WIDE) OF THE HASSAYAMPA-SALOME ROAD WHICH ROAD IS
DESCRIBED IN STATE OF ARIZONA PATENT NO. 5718 AS FOLLOWS:
BEGINNING AT A POINT OF THE EAST LINE OF SAID SECTION 3, WHICH POINT BEARS SOUTH 0 DEGREES 10 MINUTES 33 SECONDS WEST 619.56 FEET FROM THE EAST
QUARTER CORNER THEREOF;
THENCE SOUTH 0 DEGREES 10 MINUTES 33 SECONDS WEST ALONG SAID EAST SECTION LINE, A DISTANCE OF 103.52 FEET;
THENCE NORTH 74 DEGREES 50 MINUTES 42 SECONDS WEST 5098.91 FEET TO A BEARING EQUATION POINT, AT WHICH POINT NORTH 74 DEGREES 50 MINUTES 42 SECONDS
WEST = NORTH 74 DEGREES 53 MINUTES 31 SECONDS WEST;
THENCE NORTH 74 DEGREES 53 MINUTES 31 SECONDS WEST 336.12 FEET;
THENCE ALONG THE ARC OF A CURVE TO THE RIGHT HAVING A RADIUS OF 1482.39 FEET. A DISTANCE OF 36.73 FEET TO A POINT ON THE WEST LINE OF SAID SECTION 3,
WHICH POINT BEARS SOUTH 0 DEGREES 09 MINUTES 31 SECONDS WEST 1941.44 FEET FROM THE NORTHWEST CORNER THEREOF;
THENCE  NORTH 0 DEGREES 09 MINUTES 31 SECONDS EAST ALONG SAID WEST SECTION LINE, A DISTANCE OF 104.55 FEET;
THENCE FROM A LOCAL TANGENT BEARING OF SOUTH 72 DEGREES 15 MINUTES 03 SECONDS EAST ALONG THE ARC OF A CURVE TO THE  LEFT HAVING A RADIUS OF 1382.39
FEET, A DISTANCE OF 63.72 FEET;
THENCE SOUTH 74 DEGREES 53 MINUTES 31 SECONDS EAST 336.12 FEET TO A BEARING EQUATION POINT, AT WHICH POINT SOUTH 74 DEGREES 53 MINUTES 31 SECONDS
EAST = SOUTH 74 DEGREES 50 MINUTES 42 SECONDS EAST;
THENCE SOUTH 74 DEGREES 50 MINUTES 42 SECONDS EAST 5072.15 FEET TO THE POINT OF BEGINNING;
EXCEPT ALL OIL, GASES, AND OTHER HYDROCARBON SUBSTANCES, HELIUM OR OTHER SUBSTANCES OF A GASEOUS NATURE, GEOTHERMAL RESOURCES, COAL, STONE,
METALS, MINERALS, FOSSILS AND FERTILIZER OF EVERY NAME AND DESCRIPTION AND EXCEPT ALL URANIUM, THORIUM, OR ANY OTHER MATERIAL WHICH IS OR MAY BE
DETERMINED BY THE LAWS OF THE STATE OF ARIZONA, THE UNITED STATES OF AMERICA, OR DECISIONS OF COURTS TO BE PECULIARLY ESSENTIAL TO THE PRODUCTION OF
FISSIONABLE MATERIALS, WHETHER OR NOT OF COMMERCIAL VALUE, AS RESERVED IN SECTION 37-231 ARIZONA REVISED STATUTES; AND
EXCEPT THE FOLLOWING DESCRIBED PROPERTY:
THIS PAGE IS ONLY A PART OF A 2016 ALTA COMMITMENT FOR TITLE INSURANCE ISSUED BY COMMONWEALTH LAND TITLE INSURANCE COMPANY. THIS COMMITMENT IS
NOT VALID WITHOUT THE NOTICE; THE COMMITMENT TO ISSUE POLICY; THE COMMITMENT CONDITIONS; SCHEDULE A; SCHEDULE B, PART I- REQUIREMENTS; AND
SCHEDULE B, PART II-EXCEPTIONS; AND A COUNTER-SIGNATURE BY THE COMPANY OR ITS ISSUING AGENT THAT MAY BE IN ELECTRONIC FORM.
81C165 COMMITMENT FOR TITLE INSURANCE (ADOPTED 6-17-06 REVISED 08-01-2016)
A PARCEL OF LAND IN THE NORTHEAST QUARTER OF SECTION 3, TOWNSHIP 2 NORTH, RANGE 9 WEST , GILA AND SALT RIVER BASE AND MERIDIAN, SAID PARCEL BEING A
PORTION OF PARCEL 37, AS SHOWN ON ASSESSOR'S MAP IN BOOK 506, MAP 18, RECORDS OF MARICOPA COUNTY, SAID PARCEL CONTAINS AN AREA OF 8.19 ACRES, MORE
OR LESS, AND IS MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT IN THE NORTH LINE OF THE NORTHEAST QUARTER OF SAID SECTION 3 THAT BEARS SOUTH 89 DEGREES 20 MINUTES 17 SECONDS EAST 3147.79 FEET
FROM THE NORTHWEST CORNER OF THE SAID SECTION 3;
THENCE SOUTH 89 DEGREES 20 MINUTES 17 SECONDS EAST 134.89 FEET ALONG SAID NORTH LINE;
THENCE LEAVING SAID NORTH LINE SOUTH 21 DEGREES 25 MINUTES 11 SECONDS EAST 2853.49 FEET TO A POINT ON THE EAST-WEST MIDSECTION LINE OF SAID SECTION 3;
THENCE NORTH 88 DEGREES 59 MINUTES 45 SECONDS WEST ALONG THE SAID EAST-WEST MIDSECTION LINE 135.22 FEET;
THENCE LEAVING SAID MIDSECTION LINE NORTH 21 DEGREES 25 MINUTES 11 SECONDS WEST 2852.62 TO SAID POINT OF BEGINNING.
PARCEL NO. 3:
THAT PART OF SECTION 3, TOWNSHIP 2 NORTH, RANGE 9 WEST, OF THE GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, DESCRIBED AS FOLLOWS:
EXACT LEGAL TO BE PROVIDED BY SURVEYOR
APN: 506-18-038A, 506-18-038B
PROPERTY DESCRIPTION
AS SURVEYED DESCRIPTION:
PARCEL NO. 2:
LOTS 3 AND 4; THE WEST HALF OF LOT 2 AND THAT PORTION OF THE SOUTH HALF OF THE NORTHWEST QUARTER; WEST HALF OF THE SOUTHWEST QUARTER OF THE
NORTHEAST QUARTER; NORTHWEST QUARTER OF THE NORTHWEST QUARTER OF THE SOUTHEAST QUARTER OF SECTION 3, TOWNSHIP 2 NORTH, RANGE 9 WEST, OF THE
GILA AND SALT RIVER BASE AND MERIDIAN, MARICOPA COUNTY, LYING NORTH OF THE RIGHT OF WAY (100 FEET WIDE) OF THE HASSAYAMPA-SALOME ROAD WHICH ROAD IS
DESCRIBED IN STATE OF ARIZONA PATENT NO. 5718
EXCEPTING THEREFROM THE FOLLOWING DESCRIBED PROPERTY:
U.S.B.R. TRACT NO. HV-L-5, AS SHOWN ON THE DECLARATION OF TAKING, PARCEL 3 OF DOCUMENT NO. 84 182029, KNOWN AS THE HARAQUAHALA VALLEY DISTRIBUTION
SYSTEM 125 FOOT RIGHT OF WAY.

LAND USE EXHIBIT
Rural Development Area
Rural Development Area
Current Land Use Designation: Rural Development Area
Proposed Land Use Designation: Heavy Industrial
Subject Area Legal Description:
Heavy Industrial

11834.6.3578297.2 
 
 
 
 
 
 
MINOR COMPREHENSIVE PLAN AMENDMENT 
 
 
GILA HYDROGEN FACILITY NARRATIVE 
 
 
Located at NEC of Salome Highway and 523rd Avenue, approximately 10 miles west of Tonopah 
 
Requests: Minor Comprehensive Plan Amendment to change land use designation from Rural 
Development Area to Heavy Industrial 
 
Case No. 
CPA2023009  
 
Original Submittal: May 5, 2023 
2nd Submittal: August 17, 2023 
 
Gammage & Burnham PLC / Stephen W. Anderson 
(602) 256-4422 | sanderson@gblaw.com

11834.6.3578297.2 
i 
TABLE OF CONTENTS 
OVERVIEW OF PROPOSAL ............................................................................................................... 1 
PURPOSE OF REQUEST .................................................................................................................... 3 
RELATIONSHIP TO SURROUNDING PROPERTIES............................................................................. 3 
LOCATION AND ACCESSIBILITY ....................................................................................................... 4 
COMPREHENSIVE PLAN ANALYSIS .................................................................................................. 4 
CONCLUSION ................................................................................................................................... 8

11834.6.3578297.2 
Page 2 of 11 
 
TABLE OF EXHIBITS  
 
EXHIBIT 1 – Aerial Map 
 
EXHIBIT 2 – Vicinity Map 
 
EXHIBIT 3 – Existing Comprehensive Plan Amendment Map 
 
EXHIBIT 4 - Proposed Comprehensive Plan Amendment Map 
 
EXHIBIT 5 – Legal Description of Site 
 
EXHIBIT 6 – Harquahala Fire District Will Serve Letter 
 
EXHIBIT 7 – Site Renderings

11834.6.3578297.2 
Page 1 of 11 
OVERVIEW OF PROPOSAL 
A. 
Hydrogen as an Alternative Energy Source 
 
Arizona already plays a key role in the nation’s drive for energy independence and the 
transition away from fossil fuels.  Palo Verde Nuclear Generating Station is the country’s largest 
nuclear power plant, producing no greenhouse gases.  Thousands upon thousands of acres of 
previously vacant Arizona desert now produce hundreds of megawatts of solar energy, using 
clean, quiet, carbon-free, photovoltaic cells.  Arizona is at the industry forefront of the electric 
vehicle (EV) sector, whether it be Lucid’s 2022 Motor Trend Car of the Year or Nikola’s new trucks 
coming off the assembly line in Coolidge.   
 
 
Gila Hydrogen, LLC (the “Applicant”), a wholly-owned, indirect subsidiary of NextEra 
Energy Resources, LLC, the world’s largest producer of solar and wind energy, is collaborating 
with Linde, the world’s leading industrial gases company with over 150 hydrogen plants in 
operation, to develop the Gila Hydrogen Facility (the “Facility”).  The Applicant now seeks 
Maricopa County’s permission to develop this Facility.  When done, the Gila Hydrogen Facility is 
expected to produce up to 120 metric tonnes of liquid hydrogen each day.  The hydrogen this 
Facility produces will provide a significant alternative energy option for virtually any purpose.  
One example would be corporate fleets.  The hydrogen from this Facility could power as many as 
3,000 trucks, eliminating both their reliance on diesel – in excess of 60 million gallons per year – 
and their production of carbon emissions and other pollutants, all while reducing America’s 
dependence on imported oil.  The only emission from these vehicles will be water vapor, reducing 
carbon emissions by 850,000 metric tonnes per year.  The Applicant has already initiated 
discussions with major fleet operators who are excited about this new opportunity to advance 
their decarbonization goals.     
 
 
The Applicant expects to invest up to $1 billion developing the Gila Hydrogen Facility.  Like 
other energy plants in the County, the Applicant also expects to pay significant taxes, about $40 
million in state income and local property taxes over the first twenty years of operation.  That 
figure does not include sales taxes from construction, or income tax impacts from either 
construction or permanent payroll.  The Applicant projects that the Facility will generate 
approximately 300 constructions jobs.  Once operational, the Facility will create approximately 
30 highly skilled, on-site jobs and approximately 60 positions for truck drivers to distribute the 
hydrogen from the Facility to customers.   
 
      B. Proposed Comprehensive Plan Amendment 
 
 
The Gila Hydrogen Facility will be an industrial facility producing clean liquid hydrogen.  
Specifically, the Facility will be located on Maricopa County Assessor Parcel Numbers 506-18-
038B and -038C (the “Site”), located 10 miles west of Tonopah, approximately 0.2 miles north of 
the Interstate 10 and immediately adjacent to W. Salome Highway. The Site identified for this 
project is ideal for the needs of such a facility.  See Exhibit 1, Aerial Map of Site.

11834.6.3578297.2 
Page 2 of 11 
 
 
 
The Site is appropriately sized.  It is 173 acres, which will be sufficient for the Applicant to 
construct and operate all of the hydrogen generation facilities, while also providing ample 
vehicular maneuvering spaces and a generous setback for its primary equipment areas.     
 
 
The Site is ideally located.  It is both remote from any settled areas while being proximate 
to Interstate 10.  To reiterate, the Site is 10 miles west of Tonopah.  The nearest structures are 
on a farm at the north end of the Harquahala Valley, more than a mile away on the other side of 
the Interstate.  Despite its isolation from any actual settlement, the Facility is just a few thousand 
feet away from the Salome Road interchange to and from I-10.  This gives the Facility the ability 
to transport hydrogen via truck east to Phoenix or west to California, giving it access to an 
enormous market of potential customers.  See Exhibit 2, Vicinity Map.   
 
The Site is not located within any Planning Area identified in the Maricopa County Vision 
2030 Comprehensive Plan.  As a result, it is designated as Rural Development Area.  The Applicant 
has selected the Site precisely because of this isolation.  This proposed industrial use will not be 
near any existing residences or businesses, and also lies completely outside the path of any 
proposed residences or businesses, indeed, of any planned area at all.  In addition, the Site is 
relatively flat and has no major drainage features.  Likewise, it is not occupied by any sensitive 
plant or animal species, so it is an environmentally suitable parcel for remote, industrial use.  
Finally, although the Site is isolated, it is also proximate to an existing interchange along 
Interstate 10, so it has ready, and uncongested, freeway access.  For these reasons, the County 
should approve the proposed Comprehensive Plan Amendment designating this Site for 
Industrial use.

11834.6.3578297.2 
Page 3 of 11 
 
PURPOSE OF REQUEST 
A. 
Statement of Specific Applications 
To facilitate the development of the Gila Hydrogen Facility, the Applicant respectfully requests 
the following:   
1. Minor Amendment to County Comprehensive Plan to change designation of property 
from Rural Development Area to Heavy Industrial; and 
 
2. Rezone from Rural-43 One Acre Per Dwelling Unit (RU-43) to Heavy Industrial (IND-3) 
Industrial Plan of Development (IUPD).   
See Exhibits 3 and 4, Existing Comprehensive Plan Map and Proposed Comprehensive Plan 
Amendment Map.  See also Exhibit 5, Legal Description.  The rezoning request is the subject of 
a separate narrative document.   
B. 
Description of Proposal 
The Gila Hydrogen Facility will produce up to 120 metric tonnes of hydrogen each day.   
The hydrogen this Facility produces will provide a significant alternative energy option for 
virtually any purpose.  As detailed above, one example would be corporate fleets.  The hydrogen 
from this Facility has the potential to save 60 million gallons of diesel fuel use each year and 
reduce carbon emissions by 850,000 metric tons per year.  Forklifts would be another clear 
opportunity for the use of hydrogen in a corporate fleet setting. 
RELATIONSHIP TO SURROUNDING PROPERTIES 
 
As has been thoroughly detailed above, the Applicant has carefully and thoughtfully 
selected this Site because of its remote location near an isolated I-10 interchange.  There are 
essentially no neighbors.  Thus, the Facility will have no adverse impact in terms of visibility, 
noise, or odor.  There is sufficient space for the necessary transmission corridor to and from a 
nearby APS substation.  The adjacent freeway interchange that serves little other traffic will allow 
for easy on and off access for the limited number of trucks and employee vehicles that will be 
making regular use of the Site.

11834.6.3578297.2 
Page 4 of 11 
 
The surrounding properties, uses and zoning are as follows.  Note that every single 
surrounding parcel is vacant.   
Location 
Use 
Current Zoning 
Onsite 
Vacant 
RU-43 
North 
Vacant 
RU-43 
East 
Vacant 
RU-43 
South 
Vacant, Salome Highway 
RU-43 
West 
Vacant, 523rd Avenue 
RU-43 
Northwest 
Vacant 
RU-190 
 
LOCATION AND ACCESSIBILITY 
 
The Site is located ten miles west of Tonopah.  There are no nearby residences and 
adjacent properties have rural zoning.  The nearest structures are on a farm at the north end of 
the Harquahala Valley, more than a mile away on the other side of the Interstate.  
 
The Site is located right off the Salome Road interchange with I-10.  This interchange does 
not see significant use today, nor is significant use planned for the foreseeable future.  The Gila 
Hydrogen Facility will have an insignificant volume of traffic that will make fair use of this existing 
infrastructure.   
COMPREHENSIVE PLAN ANALYSIS  
According to the Maricopa County Vision 2030 Comprehensive Plan’s Land Use Guide, 
Unincorporated areas outside of county area plans are designated Rural Development Area.  
Below is an analysis of how the amendment meets the intent of the overall Comprehensive Plan.  
1. 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 proposed amendment appropriately allows for the development of a significant 
industrial facility in a remote location that is close to a freeway interchange.  The 
proposed industrial facility will make a significant contribution to the transition to 
renewable energy sources, allowing for significant gains in air quality.  It also represents 
a huge investment in the County.  The amendment allows for these various community 
benefits in a location that will not adversely impact any County residents, any sensitive 
lands or species, or any public infrastructure.

11834.6.3578297.2 
Page 5 of 11 
 
2. 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 area plan? 
The Site is outside any planning area, so the proposal does not impact any area plan.  The 
proposed industrial use is appropriate for a location in close proximity to an existing 
freeway interchange.   
Requiring public expenditures for larger and more expensive infrastructure 
improvements to roads, sewer, or water systems than are needed to support the 
planned uses.  
The amendment will not require any public infrastructure expenditures at all.  The 
Applicant will be financially responsible for all of its water and wastewater needs.  The 
Site is served by an existing freeway interchange and adjacent road.  The Applicant will 
be providing additional right of way, but its traffic report indicates that it creates no need 
for any additional road improvements at this time.  The Applicant has already secured a 
will serve letter from the local fire district.  See Exhibit 6.   
Adversely impacting planned uses because of increased traffic? 
The amendment will not cause adverse impacts to the area due to increased traffic.  The 
applicant’s traffic generation will be minimal, and can use the existing road and 
interchange.  There are no other planned uses in the area at this time.   
Affecting the livability of area or the health or safety of present and future residents? 
There are no present residents anywhere within a mile of this site, and Tonopah is ten 
miles to the east.  The area cannot sustain future residents without the development of 
significant infrastructure, none of which is anywhere nearby.  The Applicant selected this 
site precisely because of its isolation, so that it would not impact anyone’s health or 
safety.  Having said that, as already noted, the Applicant already has a will serve letter 
from the local Fire District.  Hydrogen production’s general safety record and the 
extensive safety steps involved in this federally regulated Facility are detailed in the 
separate rezoning narrative.   
Adversely impacting the natural environment or scenic quality of the area in 
contradiction to the plan.   
To reiterate, the Site is relatively flat and lacks significant drainage features.  The 
Applicant has already completed a Biological Survey of the Site, and determined that 
there are no significant plant or animal species on the Site.  The Applicant is including that 
Survey along with this submittal.  The immediate area is not noted for any unique scenic 
qualities.  The Facility is not expected to be significantly visible to passersby on the 
Interstate.  A rendering of the Facility from I-10 is included as Exhibit 7.

11834.6.3578297.2 
Page 6 of 11 
 
3. Consistent with overall intent of CP 
The proposed amendment is consistent with the overall intent of the Comprehensive 
Plan.  The Amendment will place a heavy industrial land use in an area isolated from any 
existing or planned future development, and will not impact any County residents or 
businesses.  At the same time, the Amendment utilizes a Site that has no environmentally 
sensitive issues.  In addition, the Site is adequately served by the adjacent road and 
nearby freeway interchange, and the Applicant intends to provide the rest of its needed 
infrastructure at its own expense.  Thus, the Amendment has no adverse financial impact 
on the County or its residents.   
4. Consistent with specific goals and policies 
The proposed amendment supports specific goals and policies set forth for the 
Comprehensive Plan as follows: 
Land Use 
 Land Use Policy #20: Maricopa County supports reducing the impacts of new 
urban development on existing rural land uses and agriculture.  
Response: The isolation of this Facility will have no impact on existing rural 
land uses or agriculture, which are located at least a half mile away on the 
other side of the Interstate.   
 Land Use Policy #21: Maricopa County supports reducing the impacts of new rural 
development and agriculture on existing urban land uses.  
Response:  The isolation of this Facility will have no impact on any existing 
urban land uses, which are many miles away.   
 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.   
Response:  The Applicant’s Biological Survey indicates that the Site is not 
an environmentally sensitive area, and lacks significant native flora or 
fauna habitat or corridors.   
 Land Use Policy #27: Maricopa County supports keeping development out of 
delineated floodways and, where necessary, 100-year floodplains. 
Response: The Site has no significant drainage features.   
Transportation 
 Transportation Policy #11: Maricopa County supports National Ambient Air 
Quality Standards (NAAQS) compliance.  
Response: The proposed Amendment is for a hydrogen facility that will very 
likely provide fuel allowing corporate trucking fleets to convert from fossil fuels 
to clean-burning hydrogen which produces only water vapor as a by-product, 
eliminating hundreds of tonnes of exhaust.

11834.6.3578297.2 
Page 7 of 11 
 
Environment 
 Environment Goal #1: Provide regional leadership to promote all aspects of 
regional environmental quality. 
Response: The County has already been a leader in the development of nuclear 
and solar energy resources to replace fossil fuel use.  This opportunity to 
embrace hydrogen as yet another renewable energy source is consistent with 
that history.   
 Environment Policy #1: Maricopa County supports its Compliance Assurance 
model approach to meet federal air quality standards.  
Response: The proposed Amendment is for a hydrogen facility that will very 
likely provide fuel allowing corporate trucking fleets to convert from fossil fuels 
to clean-burning hydrogen which produces only water vapor as a by-product, 
eliminating hundreds of tonnes of exhaust.   
 Environment Policy #5: As directed by SHPO and Arizona Game and Fish 
Department, Maricopa County supports cultural resource and biological surveys 
being completed – and needed mitigation measures established – prior to new 
development.  
Response: The Applicant has completed a Biological Survey and included it with 
this application.  It indicates that no mitigation is required.     
Economic Growth 
 Economic Growth Goal #2: Have a diverse and balanced economy to promote 
long-term economic stability and economic resiliency.  
Response: The County has nuclear and solar energy, but there is no significant 
hydrogen facility currently proposed in unincorporated Maricopa County.  This 
Facility is expected to have a development budget of approximately $2 billion.  
It represents an extraordinarily significant investment in a part of the County 
which otherwise would likely not see any development.   
 Economic Growth Policy #6: Maricopa County supports efforts to recruit 
prospective businesses and industries to the county, and efforts to retain existing 
businesses and industries. 
Response: The business proposal here represents a generational, 
transformative investment that has little precedent.   
 Economic Growth Policy #10: Maricopa County supports leveraging its solar 
resource potential to attract solar-related industries and alternative energy 
research and development. 
Response:  Alternative energy development is the purpose of this proposed 
Amendment.

11834.6.3578297.2 
Page 8 of 11 
 
Energy 
 Energy Goal #2: Make Maricopa County a leader in alternative energy research 
and development. -AND- 
 Energy Policy #6: Maricopa County supports being a responsible leader in 
alternative energy research and development. 
Response: The proposed Amendment will make Maricopa County a leader 
in the hydrogen field.    
CONCLUSION 
 
The Gila Hydrogen Facility will be a game changer for the County, the State and the nation.  
It will address our country’s critical need to identify new fuel sources for our vital transportation 
logistics and overall economy.  At the same time, it will safely and dramatically reduce air 
pollution and carbon emissions.  This massive investment is a significant step toward our better 
collective future. 
This Comprehensive Plan Amendment designating the Site for Industrial land use allows 
this substantial and innovative project to proceed.  It does so at a Site that is appropriately 
isolated, environmentally benign, and well-served by existing transportation infrastructure.  The 
County should approve the proposed Comprehensive Plan Amendment.

EXHIBIT 1

Subject Property
+/- 176 acres
AERIAL MAP OF SITE
523RD AVE

EXHIBIT 2

Subject
Property
MARICOPA COUNTY LINE
VICINITY MAP*
*2019 Aerial Photo

EXHIBIT 3

EXISTING COMPREHENSIVE PLAN LAND USE DESIGNATION
Rural Development Area
Rural Development Area
RURAL DEVELOPMENT
AREA

EXHIBIT 4

PROPOSED COMPREHENSIVE PLAN LAND USE DESIGNATION
Rural Development Area
Rural Development Area
Industrial

EXHIBIT 5

20180001423 
EXHIBIT "A" 
Lots 3 and 4; the West half of Lot 2 and that portion of the South half of the Northwest 
quarter; West half of the Southwest quarter of the Northeast quarter; Northwest quarter of 
the Northwest quarter of the Southeast quarter of Section 3,Township 2 North, Range 9 
West, of the Gila and Salt River Base and Meridian, Maricopa County, lying North of the 
right of way (100 feet wide) of the Hassayampa-Salome Road which road is described in 
State of Arizona Patent No. 5718 as follows: 
BEGINNING at a point of the East line of said Section 3, which point bears South 0 
degrees 10 minutes 33 seconds West 619.56 feet from the East quarter comer thereof; 
Thence South 0 degrees 10 minutes 33 seconds West along said East section line, a 
distance of 103.52 feet; 
Thence North 74 degrees 50 minutes 42 seconds West 5098.91 feet to a Bearing Equation 
Point, at which point North 74 degrees 50 minutes 42 seconds West / North 74 degrees 
53 minutes 31 seconds West; 
Thence North 74 degrees 53 minutes 31 seconds West 336.12 feet; 
Thence along the arc of a curve to the right having a radius of 1482.39 feet, a distance of 
36.73 feet to a point on the West line of said Section 3, which point bears South 0 degrees 
09 minutes 31 seconds West 1941.44.,..•Acn,-7,,7, 'he Northwest comer thereof; 
Thence North 0 degrees 09 minutes 31 seconds East along said West Section line, a 
distance of 104.55 feet; 
Thence from a Local Tangent Bearing of South 72 degrees 15 minutes 03 seconds East 
along the arc of a curve to the left having a radius of 1382.39 feet, a distance of 63.72 
feet; 
Thence South 74 degrees 53 minutes 31 seconds East 336.12 feet to a Bearing Equation 
Point, at which point South 74 degrees 53 minutes 31 seconds East / South 74 degrees 50 
minutes 42 seconds East; 
Thence South 74 degrees 50 minutes 42 seconds East 5072.15 feet to the POINT OF 
BEGINNING; 
EXCEPT all oil, gases, and other hydrocarbon substances, helium or other substances of 
a gaseous nature, geothermal resources, coal, stone, metals, minerals, fossils and fertilizer 
of every name and description and except all uranium, thorium, or any other material 
which is or may be determined by the laws of the State of Arizona, the United States of 
America, or decisions of courts to be peculiarly essential to the production of fissionable

20180001423 
materials, whether or not of commercial value, as reserved in Section 37-231 Arizona 
Revised Statutes; and 
EXCEPT the following described property lying within Parcel 1: 
A parcel of land in the Northeast quarter of Section 3, Township 2 North, Range 9 West, 
Gila and Salt River Meridian, said parcel being a portion of parcel 37, as shown on 
Assessor's Map in Book 506, Map 18, records of Maricopa County, said Parcel contains 
an area of 8.19 acres, more or less, and is more particularly described as follows: 
BEGINNING at a point in the North line of the Northeast quarter of said Section 3 that 
bears South 89 degrees 20 minutes 17 seconds East 3147.79 feet from the Northwest 
comer of the said Section 3; 
Thence South 89 degrees 20 minutes 17 seconds East 134.89 feet along said North line; 
Thence leaving said North line South 21 degrees 25 minutes 11 seconds East 2853.49 
feet to a point on the East-West midsection line of said Section 3; 
Thence North 88 degrees 59 minutes 45 seconds West along the said East-West 
midsection line 135.22 feet; 
Thence leaving said midsection line North 21 degrees 25 minutes 11 seconds West 
2852.62 feet to said POINT OF BEGINNING. 
Unofficial Document

EXHIBIT 6

Harquahala Valley Fire District 
Susan Corbin – Chair, Larry Deneen – Clerk,  
Charlie Kooistra – Member, Chip Main – Member, Chester Daffern – Member 
Jeff McMenemy – Fire Chief 
 
 
Harquahala Valley Fire District 
51510 W Tonto Street, Tonopah AZ. 85354 
Office 928-372-2249 
Cell- 602-882-0434 
Jmcmenemy@hfdaz.org 
 
 
 
 
 
DATE:  6/22/2022 
 
TO:  
Jonathan Hichborn, PE 
 
 
NextEra Energy Resources 
 
APN: 
506-18-038A       
 
RE:  
Will Serve Letter  
 
 
 
ADDRESS:_7653 N 523rd Avenue,  Tonopah AZ. 85354               
        
  
 
Thank you for inquiring about fire and rescue services that are provided by the Harquahala Valley Fire District.  The above referenced 
property falls within the boundaries of the District.  Accordingly, we will provide fire and emergency medical services for the structures 
and occupants.  The ISO rating for the above referenced parcel is 8B. 
 
 
If you have any questions, please feel free to contact me. 
 
 
 
 
Sincerely,  
 
 
 
 
 
Jeff McMenemy 
Fire Chief

EXHIBIT 7

Conceptual Site Renderings

Conceptual Site Renderings

Conceptual Site Renderings

11834.6.3577914.1 
Page 1 of 20 
 
 
 
 
 
 
ZONE CHANGE WITH OVERLAY 
 
GILA HYDROGEN FACILITY NARRATIVE 
 
 
Located at NEC of Salome Highway and 523rd Avenue, approximately 10 miles west of Tonopah 
 
Request: Rezone from RU-43 to IND-3 IUPD 
 
Case No. 
Z2023059 
 
Original Submittal: May 5, 2023 
2ND Submittal: August 17, 2023 
 
Gammage & Burnham PLC / Stephen W. Anderson 
(602) 256-4422 | sanderson@gblaw.com

11834.6.3577914.1 
Page 2 of 20 
 
 
TABLE OF CONTENTS 
 
OVERVIEW OF PROPOSAL...................................................................................................................4 
PURPOSE OF REQUEST ................................................................................................................................. 6 
RELATIONSHIP TO SURROUNDING PROPERTIES ....................................................................................... 11 
LOCATION AND ACCESSIBILITY .................................................................................................................. 12 
CIRCULATION SYSTEM ................................................................................................................................ 13 
DEVELOPMENT SCHEDULE (PHASING) ...................................................................................................... 14 
COMMUNITY FACILITIES AND SERVICES .................................................................................................... 15 
PUBLIC UTILITIES AND SERVICES ................................................................................................................ 16 
INDUSTRIAL UNIT PLAN OF DEVELOPMENT – DISTRICT REGULATIONS ................................................... 17 
JUSTIFICATION FOR THE INDUSTRIAL UNIT PLAN OF DEVELOPMENT ..................................................... 19 
CONCLUSION .............................................................................................................................................. 20

11834.6.3577914.1 
Page 3 of 20 
 
 
TABLE OF EXHIBITS 
 
EXHIBIT 1 – Aerial Map 
 
EXHIBIT 2 – Vicinity Map 
 
EXHIBIT 3 – Proposed Comprehensive Plan Amendment Map 
 
EXHIBIT 4 – Proposed Rezoning Map 
 
EXHIBIT 5 – Conceptual Site Plan 
 
EXHIBIT 6 – Site Renderings 
 
EXHIBIT 7 – Harquahala Fire District Will Serve Letter 
 
EXHIBIT 8 – Arizona Department of Water Resources Account Summary 
 
EXHIBIT 9 – Water Rights Maps

11834.6.3577914.1 
Page 4 of 20 
 
 
OVERVIEW OF PROPOSAL 
 
     A. Hydrogen as an Alternative Energy Source 
 
Arizona already plays a key role in the nation’s drive for energy independence and the 
transition away from fossil fuels.  Palo Verde Nuclear Generating Station is the country’s largest 
nuclear power plant, producing no greenhouse gases.  Thousands upon thousands of acres of 
previously vacant Arizona desert now produce hundreds of megawatts of solar energy, using 
clean, quiet, carbon-free, photovoltaic cells.  Arizona is at the industry forefront of the electric 
vehicle (EV) sector, whether it be Lucid’s 2022 Motor Trend Car of the Year or Nikola’s new trucks 
coming off the assembly line in Coolidge.   
 
 
Gila Hydrogen, LLC (the “Applicant”), a wholly-owned, indirect subsidiary of NextEra 
Energy Resources, LLC, the world’s largest producer of solar and wind energy, is collaborating 
with Linde, the world’s leading industrial gases company with over 150 hydrogen plants in 
operation, to develop the Gila Hydrogen Facility (the “Facility”).  The Applicant now seeks 
Maricopa County’s permission to develop this Facility.  When done, the Gila Hydrogen Facility is 
expected to produce up to 120 metric tonnes of liquid hydrogen each day.  The hydrogen this 
Facility produces will provide a significant alternative energy option for virtually any purpose.  
One example would be corporate fleets.  The hydrogen from this Facility could power as many as 
3,000 trucks, eliminating both their reliance on diesel – in excess of 60 million gallons per year – 
and their production of carbon emissions and other pollutants, all while reducing America’s 
dependence on imported oil.  The only emission from these vehicles will be water vapor, reducing 
carbon emissions by 850,000 metric tonnes per year.  The Applicant has already initiated 
discussions with major fleet operators who are excited about this new opportunity to advance 
their decarbonization goals.     
 
 
The Applicant expects to invest up to $1 billion developing the Gila Hydrogen Facility.  Like 
other energy plants in the County, the Applicant also expects to pay significant taxes, about $40 
million in state income and local property taxes over the first twenty years of operation.  That 
figure does not include sales taxes from construction, or income tax impacts from either 
construction or permanent payroll.  The Applicant projects that the Facility will generate 
approximately 300 constructions jobs.  Once operational, the Facility will create approximately 
30 highly skilled, on-site jobs and approximately 60 positions for truck drivers to distribute the 
hydrogen from the Facility to customers.   
 
      B. Proposed Rezoning 
 
 
The Gila Hydrogen Facility will be an industrial facility producing clean liquid hydrogen.  
Specifically, the Facility will be located on Maricopa County Assessor Parcel Numbers 506-18-
038A and -038B (the “Site”), located 10 miles west of Tonopah, approximately 0.2 miles north of 
the Interstate 10 and immediately adjacent to W. Salome Highway. The Site identified for this 
project is ideal for the needs of such a facility.  See Exhibit 1, Aerial Map of Site.

11834.6.3577914.1 
Page 5 of 20 
 
 
 
The Site is appropriately sized.  It is 173 acres, which will be sufficient for the Applicant to 
construct and operate all of the hydrogen generation facilities, while also providing ample 
vehicular maneuvering spaces and a generous setback for its primary equipment areas.     
 
 
The Site is ideally located.  It is both remote from any settled areas while being proximate 
to Interstate 10.  To reiterate, the Site is 10 miles west of Tonopah.  The nearest structures are 
on a farm at the north end of the Harquahala Valley, more than a mile away on the other side of 
the Interstate.  Despite its isolation from any actual settlement, the Facility is just a few thousand 
feet away from the Salome Road interchange to and from I-10.  This gives the Facility the ability 
to transport hydrogen via truck east to Phoenix or west to California, giving it access to an 
enormous market of potential customers.  See Exhibit 2, Vicinity Map.   
 
Because of its isolation from any established land uses, the Site will have no impact on 
the surrounding area.  Because of its proximity to an isolated stretch of the Interstate, the Facility 
will have minimal impact on traffic.  As noted in the traffic report provided with this application, 
the limited volume of increased traffic is not expected to adversely impact traffic flows in the 
vicinity.  For these reasons, the County should approve the proposed rezoning of this remote Site.

11834.6.3577914.1 
Page 6 of 20 
 
 
PURPOSE OF REQUEST 
 
Statement of Specific Applications 
 
To facilitate the development of the Gila Hydrogen Facility, the Applicant respectfully requests 
the following:   
 
1. Minor Amendment to County Comprehensive Plan to change designation of property 
from Rural Development Area to Heavy Industrial; and 
 
2. Rezone from Rural-43 One Acre Per Dwelling Unit (RU-43) to Heavy Industrial (IND-3) 
Industrial Plan of Development (IUPD).   
 
See Exhibits 3 and 4, Proposed Comprehensive Plan Amendment Map and Proposed Rezoning 
Map.  The Comprehensive Plan Amendment has been addressed in a separate narrative 
document.   
 
 
Description of Proposal 
 
The Gila Hydrogen Facility will produce up to 120 metric tonnes of hydrogen each day.   
The hydrogen this Facility produces will provide a significant alternative energy option for 
virtually any purpose.  As detailed above, one example would be corporate fleets.  The hydrogen 
from this Facility has the potential to save 60 million gallons of diesel fuel use each year and 
reduce carbon emissions by 850,000 metric tons per year.  Forklifts would be another clear 
opportunity for the use of hydrogen in a corporate fleet setting.

11834.6.3577914.1 
Page 7 of 20 
 
 
DESCRIPTION OF ZONING EXHIBIT AND OPERATIONS 
 
The Site is 173 acres.  It is located ten miles west of Tonopah, in an appropriately remote 
location with excellent access to Interstate 10.  As a result of its isolation, it will not have an 
adverse impact on adjacent land uses.  See Exhibit 5, Conceptual Site Plan.   
 
A. Creating Hydrogen  
 
The Facility has been located and designed to have a minimal impact on the surrounding area.  
To reiterate, the Site is close to no existing land uses.  The Facility as proposed will include 
hydrogen generation equipment (electrolyzers), liquefaction equipment to convert hydrogen gas 
to a liquid for economic storage and distribution, hydrogen storage, a truck loading facility and 
associated infrastructure including electrical equipment, water treatment systems, air and/or 
cooling water systems, and safety/control systems.  
 
The hydrogen generation equipment will consist of electrolyzers that use electricity to split 
water into oxygen and hydrogen gas.  The hydrogen gas will be processed through a liquefaction 
system that uses cryogenic fluids and compressors to cool the hydrogen to -423 degrees 
Fahrenheit where it converts to a liquid.  At this temperature, the hydrogen can be economically 
stored and transported by truck.   
 
As suggested by the extreme temperatures and chemical processes involved, the main part 
of the Facility will have an industrial appearance, with piping, process and electrical equipment, 
tanks, cooling towers, etc.  The tallest components of the Facility will be vent stacks (piping), 
which will rise to height up to 150 feet above grade.   The attached bird’s eye view rendering 
gives an idea of the Facility layout.  See Exhibit 6, Site Renderings.   
 
The Applicant has designed the Facility to further isolate the main mass of industrial 
operations within the Site.  The industrial component of the Facility utilizes a limited portion of 
the Site, the bulk of which is set aside for evaporation ponds, stormwater management features, 
and open space.  The industrial equipment actually takes up about a third of the Site.  The 
Applicant has taken advantage of this configuration by pushing the vertically developed part of 
the project into the northern portion of the Site, the more remote part of the Site.  This further 
reduces any visibility of the Facility from I-10.   
 
The Applicants have developed a rendering indicating the expected level of visibility of the 
Facility from I-10.  See again Exhibit 6, Site Renderings.  As the I-10 rendering indicates, the 
Facility will be a relatively small, industrial landmark on the horizon.  In that regard, the Facility 
will be a footnote to passersby, much like Palo Verde Nuclear Generating Station or the Hickman 
Egg Farm (although the Egg Farm is closer to the Interstate and therefore more visible than this 
Facility).   In this regard, the proposed rezoning will have no significant impact on County 
residents.

11834.6.3577914.1 
Page 8 of 20 
 
 
B. Safe Handling of Hydrogen 
 
The production, storage and use of hydrogen is a well-proven practice.  According to the U.S. 
Department of Energy, approximately 10 million metric tonnes of hydrogen are already being 
produced annually in the U.S.  In fact, the Applicant and its team have many facilities that already 
store and use hydrogen for power generation purposes. 
 
Ensuring the safety of employees and the community is the highest priority. The Facility will 
be designed, built and operated in accordance with all federal, state and local regulations. That 
starts with performing process hazard analyses, designing robust safety systems, setting rigorous 
operating standards and developing emergency response plans in coordination with local first 
responders.  The Applicant has already met and had detailed discussions with leadership at the 
Harquahala Fire District.   
 
Numerous protection features will be implemented to ensure the safe operation of the 
Facility. The Facility design will incorporate gas detection devices, continuous monitoring of 
processes, and automatic emergency shutdown features. Additionally, physical setbacks to 
property boundaries, particularly Salome Road, will be designed into the Facility to ensure safe 
operation.   
 
Hydrogen production is subject to significant regulatory oversight.  The primary safety 
oversight in this case is expected to be the federal government, through both the Environmental 
Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA). These 
agencies will require the Applicant to draft and implement a Risk Management Program and 
Process Safety Management System (RMP/PSMS), pursuant to applicable federal regulations. 
The RMP/PSMS document will identify on-site procedures and the personnel responsible for 
them on both a daily operational basis and in the event of an emergency.  Linde brings an 
outstanding record of safe, reliable facilities, as the result of more than 70 years of production 
experience, and highly skilled system design, engineering, and execution teams.  Linde takes 
pride in some of the most stringent safety practices in the industry, practices which will either 
meet or exceed all applicable federal regulations.   
 
The Applicant has already met with the Harquahala Fire District, which is the local first 
responder agency for this remote Site.  This is the first step in an ongoing relationship during the 
design, construction and initial operation of the Facility to ensure safe operation.  The District 
has issued us a will-serve letter, which is included here as Exhibit 7, Harquahala Fire District Will 
Serve Letter.   
 
C. The Role of Water at the Facility 
 
Water is the foundational element in the production of hydrogen.  The Applicant estimates 
the Facility’s maximum daily water use could be up to 1.12 million gallons per day (“GPD”), or 
about 3.44 acre feet per day.  The projected life span of the Facility is about 30 years.

11834.6.3577914.1 
Page 9 of 20 
 
 
To ensure an adequate water supply for the Facility, the Applicant has acquired 55,000 acre-
feet (“AF”) of water, in the form of Long Term Storage Credits (“LTSCs”) within the Harquahala 
Irrigation Non-Expansion Area (the “INA”).  This water supply easily meets and exceeds the 
expected lifespan of the Facility.  A copy of the Applicant’s Water Account with the Arizona 
Department of Water Resources evidencing this water right is attached as Exhibit 8.  In order to 
utilize its rights, the Applicant will have to file annual reports with ADWR regarding its actual 
water use.  If the Facility’s production capacity expands in the future, Applicant is prepared to 
purchase additional LTSCs. 
 
The Applicant’s water supply has unique geographic features that make it particularly 
appropriate for the proposed Facility.  As Exhibit 8 indicates, the Applicant acquired these rights 
from the Vidler Water Company.  The Vidler Water Company developed these rights within the 
INA.  Maps illustrating the location of the Vidler site, the subject property, the INA, and the 
Phoenix Active Management Area are attached as Exhibit 9.  As a general matter, water rights 
within the INA cannot practically be relocated outside the INA at this time – in other words, the 
Applicant’s water cannot be used in the broader Phoenix AMA.  Furthermore, because both 
Vidler and the Facility are located within the INA, the Applicant may extract its water rights 
directly on the Site.  The Applicant does not need to pipe water from the Vidler location.   
 
There is currently only one well at the site. The Applicant can, and expects to, develop 
additional, new recovery wells on the Site to access its water rights.  This will include water 
storage tanks to provide redundancy and reliability.  Applicant is still evaluating the specifications 
and precise locations of the additional recovery wells that it intends to operate. To secure final 
approval to operate the recovery wells, Applicant will comply with all ADWR regulations 
necessary for the recovery well permits.  The recovery well permit process will include a well 
impact analysis regarding nearby wells, but at this time, ADWR records do not indicate the 
presence of any nearby wells.  As these details indicate, the water rights and their use at the 
Facility are both environmentally responsible and consistent with Arizona’s vitally important 
Groundwater Code. 
 
The Applicant will use its well water for fire protection, process makeup water for electrolysis, 
and cooling water.  The Applicant might also use the well water for potable service, and, if it does 
so, will comply with the Public Water System application process and the New Source Approval 
process with MCESD.  (The Applicant might otherwise choose to import potable water via truck.)  
Evaporation ponds and/or other methods will be utilized for treatment and disposal of process 
wastewater, water treatment system reject, and cooling water system blowdown.   
 
D. Distributing the Hydrogen 
 
Once the Facility has produced the hydrogen, it will be shipped by tanker trucks to its final 
destination.  It is anticipated that about sixty (60) tanker trucks a day will visit the Facility, load, 
and leave.  The Facility is anticipated to have thirty (30) or fewer full-time employees at any given 
time, therefore employee traffic should not be an issue either.  No significant traffic impacts at 
this remote interchange or along the Interstate are expected as a result of transporting the

11834.6.3577914.1 
Page 10 of 20 
 
 
hydrogen or employees traveling to and from the Facility.  Out at this remote interchange, that 
will not create any traffic issues, and on the Interstate, it will be a drop in an ocean.  A traffic 
impact statement is being submitted along with this application.   
 
E. Powering the Production of Hydrogen 
 
Both the electrolysis process and the liquefication process for producing hydrogen require a 
significant amount of energy.  Scientists have created a color spectrum to refer to the method of 
production used to separate and capture the hydrogen (which is and remains colorless 
throughout the production process).  Hydrogen can be produced using renewable energy such 
as solar and wind, and hydrogen produced using this energy source is called “green” hydrogen.  
As another example, hydrogen can be produced using nuclear power like that from the Palo 
Verde Nuclear Generating Station, and hydrogen produced using this energy source is called 
“pink” hydrogen.   
 
The Applicant for the Gila Hydrogen Facility has not made a final determination regarding its 
energy source, and thus what color designation its hydrogen will bear.  However, the Applicant 
is primarily focused on producing green hydrogen.  Solar energy is already abundant in Arizona 
in general, and in western Maricopa County in particular, and can be readily purchased off the 
Western power grid from the APS Delaney substation, a couple miles to the southeast.  In 
addition, the surrounding miles of vacant lands could host new solar farms to directly serve the 
Facility.   
 
Regardless of what power source the Applicant chooses, the hydrogen produced at this 
Facility will have the same end result: the diversification of our nation’s power supplies and the 
reduction of carbon emissions, most likely from the vital transportation sector.

11834.6.3577914.1 
Page 11 of 20 
 
 
RELATIONSHIP TO SURROUNDING PROPERTIES 
 
 
As has been thoroughly detailed above, the Applicant has carefully and thoughtfully 
selected this Site because of its remote location near an isolated I-10 interchange.  There are 
essentially no neighbors.  Thus, the Facility will have no adverse impact in terms of visibility, 
noise, or odor.  There is sufficient space for the necessary transmission corridor to and from a 
nearby APS substation.  The adjacent freeway interchange that serves little other traffic will allow 
for easy on and off access for the limited number of trucks and employee vehicles that will be 
making regular use of the Site.   
 
The surrounding properties, uses and zoning are as follows.  Note that every single 
surrounding parcel is vacant.   
Location 
Use 
Current Zoning 
Onsite 
Vacant 
RU-43 
North 
Vacant 
RU-43 
East 
Vacant 
RU-43 
South 
Vacant, Salome Highway 
RU-43 
West 
Vacant, 523rd Avenue 
RU-43 
Northwest 
Vacant 
RU-190

11834.6.3577914.1 
Page 12 of 20 
 
 
LOCATION AND ACCESSIBILITY 
 
 
The Site is located ten miles west of Tonopah.  There are no nearby residences, and 
adjacent properties have rural zoning.  The nearest structures are on a farm at the north end of 
the Harquahala Valley, more than a mile away on the other side of the Interstate.  
 
 
The Site is located right off the Salome Road interchange with I-10.  This interchange does 
not see significant use today, nor is significant use planned for the foreseeable future.  The Gila 
Hydrogen Facility will have an insignificant volume of traffic that will make fair use of this existing 
infrastructure.

11834.6.3577914.1 
Page 13 of 20 
 
 
CIRCULATION SYSTEM 
 
 
At 173 acres, the Site has ample room to accommodate all truck maneuvering 
requirements and employee parking needs.   
 
There are no conflicting activities between the Site and the I-10 interchange that would 
hamper truck turning movements.

11834.6.3577914.1 
Page 14 of 20 
 
 
DEVELOPMENT SCHEDULE (PHASING) 
 
 
The Applicant anticipates developing the Gila Hydrogen Facility in a single phase.  The 
Applicant aims to start construction in 2024 and estimates that actual construction and 
commissioning will take approximately 30 months.  Because the Facility can come on line 
sequentially, it could commence initial operations as early as 2025, with full operations underway 
around mid-2026.

11834.6.3577914.1 
Page 15 of 20 
 
 
COMMUNITY FACILITIES AND SERVICES 
 
Community Facilities and Services Table
Facility
Distance from Site
Provider
Burnt Well Rest Area Westbound
+/- 6 miles
Arizona Department of Transportation
Tonopah Valley High School
+/- 17 miles
Saddle Mountain Unified School District
Ruth Fisher Elementary School
+/- 17 miles
Saddle Mountain Unified School District
Robbins Butte Game Preserve
+/- 34 miles
Arizona Game & Fish Department

11834.6.3577914.1 
Page 16 of 20 
 
 
PUBLIC UTILITIES AND SERVICES 
 
Public Utilities and Services Table
Utility
Provider
Water
Private, onsite Harquahala aquifer
Sewer
Onsite septic
Gas
N/A
Communications
TBD
Refuse
TBD
Law Enforcement
Maricopa County Sheriff
Fire and Emergency Medical Services
Harquahala Fire District
Electric
APS
Telephone
TBD

11834.6.3577914.1 
Page 17 of 20 
 
 
INDUSTRIAL UNIT PLAN OF DEVELOPMENT – DISTRICT REGULATIONS 
IND-3 IUPD DISTRICT REGULATIONS
IND-3 DISTRICT REGULATIONS
PROPOSED IND-3 IUPD DISTRICT 
REGULATIONS 
Permitted Uses
-
Hydrogen Production Facility, 
including accessory electrical 
substation and other power 
equipment, and distribution 
facilities 
Maximum Building Height
40 feet
150 feet.  Along the east, 
south, and west property lines 
a 2:1 setback will be provided 
for every foot of height over 40 
feet.  
Minimum Front Yard (south
side) 
Abutting any major street, 
section line road, State or 
Federal highway not less than 
20 feet 
Abutting any major street, 
section line road, State or 
Federal highway not less than 
20 feet 
Minimum Perimeter Side Yard 
(east and west sides) 
Where a lot is adjacent to a 
rural or residential zoning 
district, there shall be a side 
yard on the side of the lot 
adjacent to such rural or 
residential zoning district having 
a width of not less than five 
feet. 
Where a lot is adjacent to a 
rural or residential zoning 
district, there shall be a side 
yard on the side of the lot 
adjacent to such rural or 
residential zoning district having 
a width of not less than five 
feet. 
Minimum Rear Yard (north side)
None required (see Chapter 9, 
Section 902., Article 902.3. - 
Height Regulations) except that 
where a lot abuts a rural or 
residential zoning district 
whether or not separated by an 
alley, there shall be a rear yard 
having a depth of not less than 
25 feet. 
Where a lot abuts a rural or 
residential zoning district 
whether or not separated by an 
alley, there shall be a rear yard 
having a depth of not less than 
25 feet. 
Minimum Lot Area
6,000 square-feet
6,000 square-feet
Minimum Lot Width
60-feet
60-feet
Maximum Lot Coverage
60%
60%
Loading and Unloading 
Regulations 
For all wholesale, 
manufacturing and industrial 
buildings hereafter erected, or 
for any building converted to 
such use or occupancy, there 
shall be provided one loading 
and unloading space for each 
10,000 square feet of floor area, 
For all wholesale, 
manufacturing and industrial 
buildings hereafter erected, or 
for any building converted to 
such use or occupancy, there 
shall be provided one loading 
and unloading space for each 
100,000 square feet of floor

11834.6.3577914.1 
Page 18 of 20 
 
 
or fraction thereof, devoted to 
such use in the building. 
area, or fraction thereof, 
devoted to such use on the site. 
Additional Regulations:
Site Enclosure and Screening 
Requirements 
Industrial sites and/or uses shall 
be enclosed to provide effective 
site screening from adjoining 
properties, uses or streets as 
follows: a. Adjacent to any rural 
or residential zone, automobile 
parking shall be screened from 
view. b. A solid masonry wall 
not less than six feet in height 
shall be required along and 
adjacent to any side or rear 
property line abutting any rural 
or residential zone boundary, or 
any alley abutting such zone 
boundary. Further, any access 
gates shall be constructed of 
view-obscuring material to 
provide effective site screening. 
c. The perimeter of any portion 
of a site not adjacent to a rural 
or residential zone boundary 
upon which any outdoor use of 
an industrial nature is permitted 
shall be enclosed to a height of 
not less than six feet by building 
walls, walls or fences of any 
view-obscuring material. No 
outdoor industrial use or 
enclosure thereof shall 
encroach into any required 
setback area adjacent to any 
street, nor shall any storage 
products or materials exceed 
the height of any such 
enclosure. 
A chain link fence not less than 
six feet in height topped with 
barbed wire.  Barbed wire / 
concertina shall be a minimum 
of eight feet above natural 
grade.  Security fencing shall be 
required along and adjacent to 
any and all property lines. 
Parking
One per 600 square feet of floor
area, per MCZO Section 
1102.1.5 
One per 600 feet of regularly 
occupied floor space (excluding 
equipment areas). 
Lighting
MCZO Section 1112
MCZO Section 1112
Sign Regulations
MCZO Section 1404
MCZO Section 1404

11834.6.3577914.1 
Page 19 of 20 
 
 
JUSTIFICATION FOR THE INDUSTRIAL UNIT PLAN OF DEVELOPMENT 
 
The purpose of the Industrial Unit Plan of Development is to allow variations in the 
development standards in industrial projects that require special design techniques or flexibility 
due to topography, innovative or sustainable project design, or other considerations.  Given the 
size and nature of the proposed facility, minimal and modest modifications are being requested.  
These modifications are not being made to allow the applicant to “overuse” the Property or in a 
manner that is excessive of reasonable and substantial property rights.  
This application requests modifications to the following: 
Maximum Building Height.  The maximum height allowed within the IND-3 zoning district 
is 40’.  This proposal is requesting an extended height allowance of up to 150’ in order to 
accommodate proposed vent stacks, cold box equipment structures, and hydrogen 
storage spheres.  Water storage tanks, and other equipment enclosures may also exceed 
the 40’ height.  All these vertical elements of the facility are strategically located further 
to the north, in the more remote area of the Property, further reducing visibility from the 
I-10.  To further reduce any potential impact, along the east, south, and west property 
lines a 2:1 setback will be provided for every foot of height over 40 feet.  The remainder 
of the development will be in compliance with the standard 40-foot maximum height.   
 
Loading.  This Facility will be producing hydrogen that will then be transferred off site by 
tanker trucks.  A significant amount of the industrial space of this site will be devoted to 
processing equipment that does not trigger a need for loading for each such structural 
space.  Therefore, it would be appropriate to significantly reduce the standard loading 
requirement to avoid constructing a large number of unnecessary loading spaces at each 
structure that would waste resources and generate unwarranted heat.  Instead, 
centralized truck loading and unloading, including truck storage, is a primary use of the 
site.  Therefore, the site plan will provide a large truck loading area of approximately 
17,000 square feet in size, almost half an acre.  This will allow for both loading operations 
themselves, as well as ample truck maneuvering and storage areas.   
 
Site Enclosure and Screening.  Due to the very remote location and immense size of this 
Property a solid screen wall is not necessary.  There is no development of any kind on the 
adjacent, vacant desert land.   There are no pedestrian paths or amenities in the area.  A 
chain link fence a minimum of 6-feet in height is requested along all property lines.  
Furthermore, due to the nature of the proposed use, the chain link fence will be topped 
with barbed wire in order to provide safety and security.   
 
Parking.  As previously indicated, the vast majority of floor space within the Facility will 
be occupied by processing equipment which generates no need for parking spaces for 
employees.  The proposed standard follows the County’s regular parking requirement, 
while making this important clarification.

11834.6.3577914.1 
Page 20 of 20 
 
 
CONCLUSION 
 
 
The Gila Hydrogen Facility will be a game changer for the County, the State and the nation.  
It will address our country’s critical need to identify new fuel sources for our vital transportation 
logistics and overall economy.  At the same time, it will safely and dramatically reduce air 
pollution and carbon emissions.  This massive investment is a significant step toward our better 
collective future.   
 
The rezoning sought here to secure this advance is completely appropriate.  The Site is 
extremely isolated, with no existing uses anywhere nearby.  No County residents will be impacted 
by the Facility.  The traffic generated by this Facility is minimal, and will have no impact at the 
nearby, remote interchange along I-10.  Because of the ideal location, the County should approve 
this rezoning request.

EXHIBIT 1

Subject Property
+/- 176 acres
AERIAL MAP OF SITE
523RD AVE

EXHIBIT 2

Subject
Property
MARICOPA COUNTY LINE
VICINITY MAP*
*2019 Aerial Photo

EXHIBIT 3

PROPOSED COMPREHENSIVE PLAN LAND USE DESIGNATION
Rural Development Area
Rural Development Area
Industrial

EXHIBIT 4

PROPOSED ZONING
Heavy Industrial
IND-3 IUPD

EXHIBIT 5

R=60'
R=60'
OWNER:  WIS PARTNERS IV LLC
APN:  506-18-004G
OWNER:  WIS PARTNERS IV LLC
APN:  506-18-001A
APN 506-18-038A
172.199 ACRES (SURVEYED)
8' CHAIN-LINK SECURITY
FENCE W/ BARBED WIRE
8' CHAIN-LINK SECURITY
FENCE W/ BARBED WIRE
8' CHAIN-LINK SECURITY
FENCE W/ BARBED WIRE
8' CHAIN-LINK SECURITY
FENCE W/ BARBED WIRE
8' CHAIN-LINK SECURITY
FENCE W/ BARBED WIRE
GROUNDWATER WELL
8' CHAIN-LINK SECURITY
FENCE W/ BARBED WIRE
EXISTING ASPHALT ROADWAY (2 x 12' LANES)
PROCESS EQUIPMENT AREA
(14.5 ACRES)
ELECTRICAL SWITCHYARD
(6.7 ACRES)
PROCESS
EQUIPMENT AREA
(9.3 ACRES)
PROCESS EQUIPMENT
AREA
(2.3 ACRES)
8' CHAIN-LINK SECURITY
FENCE W/ BARBED WIRE
EVAPORATION POND
(50.0 ACRES)
GROUNDWATER WELL
SECURITY GATE
OPERATIONS BLDG.
(75'-0" x 75'-0")
OPERATIONS BLDG.
(70'-0" x 50'-0")
OPERATIONS BUILDING
(185'-0" x 85'-0")
PROCESS
EQUIPMENT
AREA
PROCESS
EQUIPMENT
AREA
LEACH
BED
R=75'
R=75'
DOUBLE SWING GATE
DOUBLE SWING GATE
R=75'
R=60'
PROCESS
EQUIPMENT
AREA
PROCESS
EQUIPMENT
AREA
R=75'
R=75'
R=45'
R=45'
R=45'
R=60'
R=75'
R=35'
R=35'
SECURITY GATE
8' CHAIN-LINK SECURITY
FENCE W/ BARBED WIRE
OPERATIONS BLDG.
(60'-0" x 50'-0")
SOUTH
PARKING LOT
5:1 PAVEMENT TAPER
STORMWATER MANAGEMENT
INFILTRATION BASIN
(BOTTOM AREA = 6.5 AC)
39.82'
20.00'
14.60'
100.00'
R=75'
OPERATIONS
BUILDING
(25'-0" x 20'-0")
R=75'
R=75'
PROCESS
EQUIPMENT
AREA
25.00'
R=75'
R=75'
25.00'
OPERATIONS BLDG.
(100'-0" x 80'-0")
R=75'
PROCESS EQUIPMENT AREA
(8.5 ACRES)
R=75'
575.00'
525.00'
144.50'
515.00'
148.24'
600.00'
1050.00'
25.00'
25.00'
25.00'
25.00'
820.00'
DOUBLE SWING GATE
DOUBLE SWING GATE
360.00'
350.00'
265.00'
370.00'
1100.00'
GROUNDWATER WELL
50' FENCE SETBACK FROM PROPERTY LINE
TO AVOID EXISTING RUNOFF DIVERSION
DITCH ALONG WEST SIDE OF WATER CANAL
PROCESS
EQUIPMENT
AREA
(4.5 ACRES)
APN 506-18-038B
0.291 ACRES (SURVEYED)
NORTH
PARKING LOT
376.72'
373.27'
318.00'
R=45'
615.00'
GROUNDWATER WELL
LEGEND
PROPERTY LINE
SETBACK LINE
8 FT. CHAIN-LINK FENCE W/ BARBED WIRE
BUILDING OUTLINE
PROCESS/EQUIPMENT ZONE BOUNDARY
CONCRETE/ASPHALT PAVEMENT
OPEN GRADED AGGREGATE SURFACING (PERVIOUS)
NATIVE SEED MIX
EVAPORATION POND W/ HDPE LINER
CONSTRUCTION LAYDOWN AREA
A
ISSUED FOR PERMIT
OPEN
T. JOHNSTON
---
DRAWING NUMBER
PROJ MGR
ENG MGR
LEAD ENG
T. JOHNSTON
DATE
REV
CHECKED BY
DESIGN BY
T. JOHNSTON
B. VANLONG
G. ROUSH
1
2
3
4
5
6
7
8
9
F
E
D
C
B
A
SITE PLAN
- PRELIMINARY -
NOT FOR CONSTRUCTION
10
11
H
G
GILA HYDROGEN, LLC
GILA H2 FACILITY
SCALE: 1" = 100'-0"
S C A L E   I N   F E E T
100
0
100
200
ZONING STATISTICS
CURRENT ZONING:  RURAL-43
PLANNED ZONING:  IND-2 LIGHT INDUSTRIAL
PARCELS:  APN 506-18-038A,  APN 506-18-038B
MAXIMUM HEIGHT ON SITE IS PROPOSED TO BE  150 FEET
TOTAL PROPERTY AREA:  172.49 ACRES
MAXIMUM LOT COVERAGE = 60% OF LOT AREA
PROVIDED LOT COVERAGE = 13.8% (BASED ON TOTAL BUILDING AREA & PROCESS
EQUIPMENT AREAS;  SEE ZONING STATISTICS BELOW)
NOTES
1. THE HORIZONTAL PROJECT DATUM IS BASED UPON THE STATE PLANE COORDINATE SYSTEM;
NAD83 ARIZONA STATE PLANE, CENTRAL ZONE.
2. BASED ON THE NATIONAL FLOOD INSURANCE PROGRAM FIRM MAP NO. 04013C1525M, MAP REVISED SEPTEMBER 18, 2020, THE SUBJECT PROPERTY LIES
WITHIN FLOOD ZONE X AND IS IDENTIFIED AS FOLLOWS:  0.2% ANNUAL CHANCE FLOOD HAZARD, AREAS OF 1% ANNUAL CHANCE FLOOD WITH AVERAGE
DEPTH LESS THAN ONE FOOT OR WITH DRAINAGE AREAS OF LESS THAN ONE SQUARE MILE.
3. SEWAGE/GRAY WATER GENERATED AT THE SITE WILL BE HANDLED WITH AN ON-SITE SEPTIC TANK AND LEACH FIELD SYSTEM.
4. WATER SOURCED FROM FOUR (4) ON-SITE GROUNDWATER WELLS;  ONE EXISTING WELL AND THREE NEW WELLS.  WATER UTILIZED FOR PRODUCTION
PROCESSES, FIRE PROTECTION AND DOMESTIC USE WILL BE TREATED AND STORED ON-SITE WITHIN THE PROCESS EQUIPMENT AREAS DESIGNATED ON
THE SITE PLAN.
5. FIRE COVERAGE IS PROVIDED BY HARQUAHALA FIRE DISTRICT STATION 371 WHICH IS LOCATED APPROX. 9 MILES SOUTH OF THE SUBJECT PROPERTY.
FIRE SERVICE IS DISPATCHED BY THE PHOENIX FIRE REGIONAL DISPATCH CENTER.
B
ISSUED FOR PERMIT
OPEN
D. LEWIS
---
C
ISSUED FOR PERMIT
OPEN
D. LEWIS
---
D
ISSUED FOR PERMIT
OPEN
D. LEWIS
---

EXHIBIT 6

Conceptual Site Renderings

Conceptual Site Renderings

Conceptual Site Renderings

EXHIBIT 7

Harquahala Valley Fire District 
Susan Corbin – Chair, Larry Deneen – Clerk,  
Charlie Kooistra – Member, Chip Main – Member, Chester Daffern – Member 
Jeff McMenemy – Fire Chief 
 
 
Harquahala Valley Fire District 
51510 W Tonto Street, Tonopah AZ. 85354 
Office 928-372-2249 
Cell- 602-882-0434 
Jmcmenemy@hfdaz.org 
 
 
 
 
 
DATE:  6/22/2022 
 
TO:  
Jonathan Hichborn, PE 
 
 
NextEra Energy Resources 
 
APN: 
506-18-038A       
 
RE:  
Will Serve Letter  
 
 
 
ADDRESS:_7653 N 523rd Avenue,  Tonopah AZ. 85354               
        
  
 
Thank you for inquiring about fire and rescue services that are provided by the Harquahala Valley Fire District.  The above referenced 
property falls within the boundaries of the District.  Accordingly, we will provide fire and emergency medical services for the structures 
and occupants.  The ISO rating for the above referenced parcel is 8B. 
 
 
If you have any questions, please feel free to contact me. 
 
 
 
 
Sincerely,  
 
 
 
 
 
Jeff McMenemy 
Fire Chief

EXHIBIT 8

All volumes expressed in acre-feet (AF)
55,000.00
ACCOUNT BALANCE
70-461005.0000
ACCOUNT NAME
ACCOUNT NUMBER
HARQUAHALA FLATS SOLAR LLC LTSA
2021 LONG-TERM STORAGE ACCOUNT SUMMARY
6/27/2023
ARIZONA DEPARTMENT OF WATER RESOURCES
LTSA CREDITS CERTIFIED on 09/14/2022
TYPE OF WATER
LTSA RECEIVED FROM
VOLUME
CREDITS TRANSFERRED ACTIVITY
WSP NUMBER
70-461000.0000
73-564970.0000
CAP
BEGINNING BALANCE
0.00
TRANSFER IN, ON 11/03/2021, CREDIT YEAR = 1998
450.23
TRANSFER IN, ON 11/03/2021, CREDIT YEAR = 1999
799.77
TRANSFER IN, ON 12/21/2021, CREDIT YEAR = 1999
217.30
TRANSFER IN, ON 12/21/2021, CREDIT YEAR = 2000
757.40
CUMULATIVE WSP CREDIT BALANCE
2,224.70
VIDLER WATER COMPANY -
70-461000.0000
73-576699.0100
CAP
BEGINNING BALANCE
0.00
TRANSFER IN, ON 12/21/2021, CREDIT YEAR = 2001
2,178.51
TRANSFER IN, ON 12/21/2021, CREDIT YEAR = 2002
9,682.90
TRANSFER IN, ON 12/21/2021, CREDIT YEAR = 2003
22,292.27
TRANSFER IN, ON 12/21/2021, CREDIT YEAR = 2004
18,621.62
CUMULATIVE WSP CREDIT BALANCE
52,775.30
VIDLER WATER COMPANY -
TOTAL CREDIT BALANCE FROM TRANSFER ACTIVITY
55,000.00
Page 1 of 1

EXHIBIT 9

VIDLER Underground 
Storage Facility (USF)
Gila Hydrogen Site
Harquahala Irrigation 
Non-expansion Area (INA) 
Harquahala Irrigation 
Non-expansion Area (INA) 
GILA HYDROGEN
Illustration of Vidler Water Rights

Harquahala Irrigation 
Non-expansion 
Area (INA) 
VIDLER Underground 
Storage Facility (USF)
Gila Hydrogen Site
Maricopa County
La Paz County
Yuma County
Pinal County
Gila County
Pima County
Yavapai County
GILA HYDROGEN
Illustration of Vidler Water Rights
Phoenix Active Management Area (AMA)
Pinal Active Management 
Area (AMA)

Engineering Division 
2901 W. Durango Street 
Phoenix, Arizona 85009 
P: 602.506.4889 
F: 602.506.5969 
 
 
February 21, 2023 
 
Jae Koo Huh and Miriam Huh Family Trust 
C/O: Gammage & Burnham 
40 North Central Avenue, 20th Floor 
Phoenix, Arizona 85004 
 
Delivered via email: sanderson@gblaw.com  
 
Re:   Recommendation of Future MCDOT Right-of-Way – APN 506-18-038A and -038B – PA2022187 
 
Dear Applicant: 
 
Maricopa County Department of Transportation (MCDOT) has reviewed the request to waive the 
requirement that the setback lines on the referenced properties be measured from the future half street 
right-of-way as required by Section 1105 of the Maricopa County Zoning Ordinance. The subject properties 
are located along two Section Line alignments (523rd Avenue and Northern Avenue), requiring the setback 
lines be measured from a future half street right-of-way of 55-feet respectively.  
 
Based on future traffic demand, it is recommended that the requirement for future half street right-of-way 
be measured as follows: 
• 
25-feet for 523rd Avenue 
• 
0-feet for Northern Avenue 
 
This recommendation pertains only to future right-of-way needs for a public roadway on the 
identified alignments and does not consider legal access requirements, easements, drainage, 
utilities, etc. which still apply to the subject property. 
 
If you have any questions on this decision, I can be contacted at (602) 506-6172 or 
Denise.Lacey@maricopa.gov.  
 
Sincerely, 
 
 
Denise Lacey 
Planning Branch Manager 
MCDOT Planning Branch 
 
Cc:  
Toral Patel, Planning and Development 
 
Nicole Nelson, Planning and Development

Engineering Division 
2901 W. Durango Street 
Phoenix, Arizona 85009 
P: 602.506.4889 
F: 602.506.5969 
Page 2 
 
 
 
Bob Fedorka, Planning and Development  
Michael Norris, Planning and Development 
Joshua Sutter, Office of Enterprise Technology - GIS 
Chris Turner, Office of Enterprise Technology – GIS 
 
Elizabeth Valenzuela, MCDOT Permits

Page | 1  
 
 
Subdivision 
Infrastructure  
& Planning Program 
301 W. Jefferson St. 
Phoenix, AZ 85003 
 
S u b d i vi s io n @ m a ri co p a .go v  
e s d .m a r i c o pa .g o v 
 
 
 
 
 
The Maricopa County Environmental Services Department (MCESD) has completed review 
for the  GILA HYDROGEN FACILITY planning case(s). Please note the following MCESD 
requirements for site development: 
Drinking Water –  
Per the Safe Drinking Water Act, any water system that supplies more than 25 people or 15 
service connections per day for at least 60 days per year is classified as a Public Water 
System (PWS).  
• 
A Public Water System application and a New Source Approval application are 
required and must be submitted to the MCESD’s Drinking Water Program. A water 
quality analysis report will be required with submittal and is good within one-year of 
testing. 
 
An Approval to Construct application is required to be submitted to the MCESD’s 
Subdivision & Infrastructure Program for all water system infrastructure. 
• 
For questions, please contact the Subdivision and Infrastructure Program at (602) 
506-1058 or email subdivision@maricopa.gov 
 
For additional Drinking Water related questions, please contact the Drinking Water program 
at (602) 506-6935 or by email at sdwquestions@maricopa.gov. 
Onsite Wastewater –  
A Notice of Intent to Discharge application for an onsite wastewater treatment (septic) 
system is required for any construction. Application must be submitted to the MCESD 
Onsite Wastewater Program. 
• 
Wastewater is not permitted to discharge to an adjacent parcel’s septic system. 
 
For Onsite Wastewater related questions, please contact the Onsite Program at (602) 506-
6666 or by email at septicquestions@maricopa.gov. 
Project Name:  GILA HYDROGEN FACILITY Primary Contact Name:  STEPHEN 
ANDERSON 
Planning Application Type: Other (General 
Comprehensive Plan Amendment) 
APN(s): 506-18038A & 038B 
Reviewer: Souren Naradikian, P.E. 
Email: Souren.Naradikian@maricopa.gov 
Phone: 602-372-2907 
Planner Name:  Joseph Mueller 
Planning Case #:  CPA2023009  
Date: May 16, 2023 
 
Water and Waste Management Division

Page | 2  
 
 
Additional Notes –  
Environmental Services does not require these items for condition of approval of  CPA2023009 , 
however these items must be addressed with the development of the site. Environmental Services 
does not require additional review of this case. 
 
*It should be noted that this document does not approve the referenced project. Comments are provided 
for the benefit of the applicant for MCESD permit requirements and as an advisory to Maricopa County 
Planning and Development Department. Other Maricopa County agencies may have additional 
requirements. Final review and approval will be made through Planning and Development Department 
procedures. Applicant may need to submit separate applications to the Maricopa County Environmental 
Services Department for approval of proposed facilities regulated by the Department. Review of any such 
application will be based on current regulations at the time of application.

Page | 1  
 
 
Subdivision 
Infrastructure  
& Planning Program 
301 W. Jefferson St. 
Phoenix, AZ 85003 
 
S u b d i vi s io n @ m a ri co p a .go v  
e s d .m a r i c o pa .g o v 
 
 
 
 
 
The Maricopa County Environmental Services Department (MCESD) has completed review 
for the ZONE CHANGE WITH OVERLAY RURAL - 43 TO I-3 IUPD planning case(s). Please note 
the following MCESD requirements for site development: 
Drinking Water –  
Per the Safe Drinking Water Act, any water system that supplies more than 25 people or 15 
service connections per day for at least 60 days per year is classified as a Public Water 
System (PWS).  
• 
A Public Water System application and a New Source Approval application are 
required and must be submitted to the MCESD’s Drinking Water Program. A water 
quality analysis report will be required with submittal and is good within one-year of 
testing. 
 
An Approval to Construct application is required to be submitted to the MCESD’s 
Subdivision & Infrastructure Program for all water system infrastructure. 
• 
For questions, please contact the Subdivision and Infrastructure Program at (602) 
506-1058 or email subdivision@maricopa.gov 
 
For additional Drinking Water related questions, please contact the Drinking Water program 
at (602) 506-6935 or by email at sdwquestions@maricopa.gov. 
Onsite Wastewater –  
A Notice of Intent to Discharge application for an onsite wastewater treatment (septic) 
system is required for any construction. Application must be submitted to the MCESD 
Onsite Wastewater Program. 
• 
Wastewater is not permitted to discharge to an adjacent parcel’s septic system. 
 
For Onsite Wastewater related questions, please contact the Onsite Program at (602) 506-
6666 or by email at septicquestions@maricopa.gov. 
Project Name: ZONE CHANGE WITH 
OVERLAY RURAL - 43 TO I-3 IUPD 
Primary Contact Name: STEPHEN 
ANDERSON 
Planning Application Type: Zone Change 
with Overlay 
APN(s): 506-18038A & 038B 
Reviewer: Souren Naradikian, P.E. 
Email: Souren.Naradikian@maricopa.gov 
Phone: 602-372-2907 
Planner Name: Joseph Mueller 
Planning Case #: Z2023059  
Date: May 16, 2023 
 
Water and Waste Management Division

Page | 2  
 
 
Additional Notes –  
Environmental Services does not require these items for condition of approval of Z2023059 , however 
these items must be addressed with the development of the site. Environmental Services does not 
require additional review of this case. 
 
*It should be noted that this document does not approve the referenced project. Comments are provided 
for the benefit of the applicant for MCESD permit requirements and as an advisory to Maricopa County 
Planning and Development Department. Other Maricopa County agencies may have additional 
requirements. Final review and approval will be made through Planning and Development Department 
procedures. Applicant may need to submit separate applications to the Maricopa County Environmental 
Services Department for approval of proposed facilities regulated by the Department. Review of any such 
application will be based on current regulations at the time of application.

Page 1 of 2 
 
 
 
 
 
 
 
 
 
 
 
Bob Fedorka, PE 
Planning & Development 
301 W. Jefferson St., Suite 170 
Phoenix, Arizona 85003 
Phone: (602) 506-7151 
www.maricopa.gov/planning 
Email address: 
bob.fedorka@maricopa.gov 
Planning & Development 
 
Engineering Plan Review 
Date:    
June 2, 2023 (Revised 6/5/23) 
 
Memo To: Darren Gerard, AICP, Planning Manager, Department of Planning & 
Development 
 
Attn: 
Joseph Mueller, Planner, Planning & Development Services 
 
cc: 
Michael Norris P.E., Engineering Manager, Planning and Development 
 
From: 
Bob Fedorka, PE, Plans Examiner Engineer, Planning & Development 
 
Subject:   
Z2023059 – Zone Change without POD for Gila Hydrogen Facility 
APN(s): 
506-18-038A & 038B 
This application is to specify zoning for future development and does not include a 
Plan of Development. 
Engineering Review has reviewed the first plan and report routed for review on 
5/16/2023, for the subject 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 buildings, 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 (i.e. POD). 
 
2. Dedication of right-of-way across the Salome Highway site frontage (both 
parcels) is required to provide 65’ half-width from center. 
 
Dedication shall occur prior to the issuance of building permit(s). See 
https://www.mcdot.maricopa.gov/744/Right-of-Way-Dedications 
for 
more 
information on the dedication process. 
 
3. 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.

Page 2 of 2 
 
 
 
 
 
 
 
 
 
 
 
PND TRANSPORTATION PLAN REVIEW R/W INFORMATION  
 
1. Salome Highway (MCDOT Jurisdiction) 
a. Current Classification:  
Minor Arterial 
b. Future Classification:  
Principal Arterial 
c. Existing R/W:  
50 Feet 
d. Ultimate R/W:  
65 Feet 
 
 
MCDOT TIS REVIEW 
 
1. MCDOT’s review of the TIS is attached hereto. 
 
 
Please contact me with any questions.

MCDOT -- TRAFFIC ENGINEERING 
REVIEW COMMENT SHEET 
1 of 1 
Project Name: Gila Hydrogen Facility 
Location:  I-10 West of Salome Rd 
MCDOT File No.: Z2023059 
Date: 5/23/2023 
Reviewer: Bonnie Perotti, PE 
Phone No.: (602) 506-4618 
Consultant: Dibble  
Project No.:  1022085 
Plans Sealed By: Seth Chalmers, PE 
Consultant Code: 
A = Will Comply        B = Deleted 
C = Consultant to Evaluate 
Item 
Number 
Page 
Number 
 
Comments 
Consultant 
Reply 
 
 
 
 
 
 
 
 
=  =  = 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1 
 
 
 
2 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
=  =  = 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Site Plan 
 
 
 
Site Plan 
 
 
 
 
 
 
 
 
 
 
 
1st REVIEW (TIS) 
 
Consultant:  Please use the code and respond to each comment in the 
Consultant Reply Column.  This sheet is for our record, please answer every 
question and sign and date your acknowledgement or the plans will be 
sent back to complete the process.  Send back the marked-up plans and a 
new set of plans along with this comment sheet.  Thank you for your 
cooperation. 
=  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  =  = 
General Project Summary: 
 
The proposed 173 acre site improvement is planned to include hydrogen 
process equipment areas, evaporation pond, operations buildings, and 
parking.  The site consists of a 6.7 acre electrical switchyard, total of 20,000 
SF office space/ operation buildings and 50 acre evaporation pond and 
includes 52 parking spaces.   
 
Per the TIS, the proposed development is not fully designed and does not 
have the building square footage defined.  The type of facility also does not 
have an ITE trip code that works for this type of business. It is anticipated to 
generate approximately 95 daily trips.  Truck access and site operation will be 
available 24 hours/day therefore, the truck trips will be distributed throughout 
the day and night and are not expected to have concentrated peaking 
characteristics. 
 
Speed in this area is assumed at 50 mph. Development is proposing 2 full-
access driveway a minimum of 360’ apart.  
 
Review Comments: 
 
Salome Rd. future functional classification is minor arterial. Along the site 
frontage, maintain/provide minimum 65 ft. R/W and any additional R/W 
required by the MCDOT Planning Department during the permit process. 
 
Proposed driveway shall be in accordance with MCDOT Roadway Design 
Manual (August 2021), Section 7.6. 
 
Based on future traffic demand, the requirement for future half street right-of-
way be measured as follows:  
• 
25-feet for 523rd Avenue (western boundary of the property) 
• 
0-feet for Northern Avenue (northern boundary of the property) 
This recommendation pertains only to future right-of-way needs for a public 
roadway on the identified alignments. 
 
The Traffic Impact Statement is Approved for the development as 
proposed.  If site changes or access changes a new TIA will be required. 
Use CODE 
"A", "B","C" 
in this column 
next to every 
comment. 
 
 
 
=  =  =  =

June 2, 2023
Mr. Joseph Mueller
Planning and Development
Maricopa County
301 E Jefferson Street
Phoenix, AZ 85003
Electronically submitted to Joseph.Mueller@maricopa.gov
RE:
CPA2023009 and Z2023059 - Gila Hydrogen Facility
Dear Mr. Mueller:
The Arizona Game and Fish Department (Department) appreciates the opportunity to review and
provide comments on the Comprehensive Plan Amendment (CPA) and Zone Change with
Overlay applications for the Gila Hydrogen Project (Project). The Department understands that
CPA2023009 is to change the land use designation from Rural Densities to Heavy Industrial, and
Z2023059 is a zone change with overlay request from Rural - 43 to I-3 IUPD to allow for the
development of a hydrogen production facility. The project site is approximately 173 acres in
size, located 10 miles west of Tonopah, Arizona, and is previously disturbed, recovering desert
scrub habitat.
Under Title 17 of the Arizona Revised Statutes, the Department, by and through the Arizona
Game and Fish Commission (Commission), has jurisdictional authority and public trust
responsibilities to conserve and protect the state fish and wildlife resources. In addition, the
Department manages threatened and endangered species through authorities of Section 6 of the
Endangered Species Act and the Department’s Section 10(a)(1)(A) permit. It is the mission of
the Department to conserve and protect Arizona's diverse fish and wildlife resources and manage
for safe, compatible outdoor recreation opportunities for current and future generations.
The Department recognizes the importance of planning efforts that contribute to the county and
the state’s economic growth needs and opportunities to develop renewable energy locations. The
Department
recognizes
that
appropriate
coordination,
proper
planning,
and
voluntary
implementation of best management practices allow projects to be developed that avoid,
minimize, or offset potential impacts to wildlife habitat and populations. For your consideration,
the Department provides the following comments based on the agency's statutory authorities,
public trust responsibilities, and special expertise related to wildlife resources and recreation:
●
The Sonoran desert tortoise, which is covered under a Candidate Conservation
Agreement (CCA), has been documented within three miles of the project area. The

AZGFD – Gila Hydrogen Facility
June 2, 2023
Page 2
Department recommends conducting surveys, in accordance with the Desert Tortoise
Survey Guidelines for Environmental Consultants , to determine the presence of this
1
species or its habitat. If tortoises are identified, please refer to and implement the
Recommended Standard Mitigation Measures for Projects in Sonoran Desert Tortoise
Habitat
and Guidelines for Handling Sonoran Desert Tortoises Encountered on
2
Development Projects .
3
●
The western burrowing owl, a special status species that is regulated under the Migratory
Bird Treaty Act, may be present within the project area. If suitable habitat for this species
is present (i.e. burrows in the ground), the Department recommends conducting an
occupancy survey for western burrowing owls to determine if this species occurs within
your project footprint. Guidelines for conducting this survey are found in Burrowing Owl
Project Clearance Guidance for Landowners . Please note that the survey should be
4
conducted by a surveyor who is certified by the Department or has similar training and
qualifications. If an active burrowing owl burrow is detected, please contact the
Department and the U.S. Fish and Wildlife Service for direction, in accordance with the
5
Burrowing Owl Project Clearance Guidance for Landowners.
●
A variety of Arizona Species of Greatest Conservation Need (SGCN) could occur in the
project area. If any wildlife are observed during construction or operation activities, the
Department recommends moving them no more than 0.25 mile outside the project
boundary into similar habitat.
●
It is the Department’s understanding based on the project description that the facility will
include a 52.6-acre evaporation pond to be used for treatment and disposal of processed
wastewater, water treatment system reject, and cooling water system blowdown. If the
water that will be held within this pond could be harmful to birds and other wildlife that
may be attracted to the site, the Department recommends that active and/or passive
deterrent methods (i.e. human patrols, netting, fencing, etc.) be incorporated into the
facility’s operational plan to discourage access to the pond.
●
If trenching or digging of large holes will occur for the proposed project, the Department
recommends trenching/digging and backfilling crews be close together to minimize the
amount of open holes at any given time. Where trenches or holes cannot be back-filled
immediately, the Department recommends escape ramps be constructed at least every 90
meters. Escape ramps can be short lateral trenches or wooden planks sloping to the
surface. The Department recommends that slopes be less than 45 degrees (1:1) and
trenches and holes that have been left open be inspected to remove animals prior to
backfilling.
5 https://www.fws.gov/office/arizona-ecological-services/contact-us
4 https://www.azgfd.com/wildlife/speciesofgreatestconservneed/raptor-management/burrowing-owl-mangement/
3 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/2014%20Tortoise%20handling%20guidelines.pdf
2 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/MitigationMeasures.pdf
1 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/2010SurveyguidelinesForConsultants.pdf

AZGFD – Gila Hydrogen Facility
June 2, 2023
Page 3
●
If a new powerline will be required to transmit energy to and from the facility, the
Department recommends following standards established by the Avian Power Line
Interaction Committee (APLIC), which can be found in Suggested Practices for Avian
Protection on Power Lines: The State of the Art in 2006 and Reduced Avian Collisions
6
with Power Lines: The State of the Art in 2012 . Birds of prey, such as raptors, owls,
7
vultures, and eagles, are vulnerable to powerline strikes and electrocution during
construction and operation of transmission lines; power poles can also serve as perches
for birds of prey. Tuk Jacobson, the Department’s Raptor Coordinator, can provide further
information on specific design features and best management practices; he can be
contacted at raptors@azgfd.gov or 623-236-7575.
●
To minimize the potential introduction or spread of exotic invasive species, including
aquatic and terrestrial plants, animals, insects, and pathogens, precautions should be
taken to wash and/or decontaminate equipment before entering and leaving the site. See
the Arizona Department of Agriculture website for a list of prohibited and restricted
8
noxious weeds and the Arizona Native Plant Society for recommendations on how to
9
control them. To view a list of documented invasive species or to report invasive species
in or near your project area, visit iMapInvasives , which is a national cloud-based
10
application for tracking and managing invasive species.
●
Artificial lighting could impair the ability of nocturnal animals to navigate (e.g., owls,
migratory birds, bats, and other nocturnal mammals) and may affect wildlife behavior
and populations (Davies et. al. 2013 ). The Department recommends using only the
11
minimum amount of light needed for safety. The Department encourages the use of
motion sensing lighting and narrow spectrum lighting wherever possible to lower the
range of species affected by lighting. All lighting should be shielded, canted, or cut to
ensure that light reaches only areas needing illumination.
●
If any portions of the project area will be fenced, the Department recommends adhering
to guidance found in the Wildlife Compatible Fencing Guidelines , which provide
12
information on how fencing impacts wildlife, ways to design fencing to prevent wildlife
entanglement and impalement, and to ensure wildlife movement is not restricted.
Department personnel are available as resources to help determine appropriate fencing
design and layout that will achieve its objective while reducing impact to wildlife.
12 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/
110125_AGFD_fencing_guidelines.pdf
11 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3657119
10 https://imap.natureserve.org/imap/services/page/map.html
9 https://aznps.com/invas
8 https://agriculture.az.gov/pestspest-control/agriculture-pests/noxious-weeds
7 https://www.aplic.org/uploads/files/15518/Reducing_Avian_Collisions_2012watermarkLR.pdf
6 https://www.aplic.org/uploads/files/2643/SuggestedPractices2006(LR-2).pdf

AZGFD – Gila Hydrogen Facility
June 2, 2023
Page 4
Thank you for the opportunity to provide input on the Gila Hydrogen Facility. For further
coordination, please contact Teigan Williams at tstruck@azgfd.gov or (928) 341-4069.
Sincerely,
Michael Sumner
Regional Supervisor - Region IV
cc:
Ginger Ritter - Project Evaluation Program Supervisor
Tyler Williford - Habitat, Evaluation, and Lands Program Supervisor - Region IV
AZGFD #M23-05171423
SIGN

Arizona Environmental Online Review Tool Report
Arizona Game and Fish Department Mission
To conserve Arizona's diverse wildlife resources and manage for safe, compatible outdoor recreation
opportunities for current and future generations.
Project Name:
Gila Hydrogen Facility
Project Description:
A 173 acre site used for the production of clean liquid hydrogen.
Project Type:
Development Outside Municipalities (Rural Development), Commercial/industrial (mall) and associated
infrastructure, New construction
Contact Person:
Teigan Williams
Organization:
Arizona Game and Fish Department
On Behalf Of:
OTHER
Project ID:
HGIS-19292
Please review the entire report for project type and/or species recommendations for the location
information entered. Please retain a copy for future reference.
Page 1 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Disclaimer:
1. This Environmental Review is based on the project study area that was entered. The report must be
updated if the project study area, location, or the type of project changes.
2. This is a preliminary environmental screening tool. It is not a substitute for the potential knowledge
gained by having a biologist conduct a field survey of the project area. This review is also not intended to
replace environmental consultation (including federal consultation under the Endangered Species Act),
land use permitting, or the Departments review of site-specific projects.
3. The Departments Heritage Data Management System (HDMS) data is not intended to include potential
distribution of special status species. Arizona is large and diverse with plants, animals, and
environmental conditions that are ever changing. Consequently, many areas may contain species that
biologists do not know about or species previously noted in a particular area may no longer occur there.
HDMS data contains information about species occurrences that have actually been reported to the
Department. Not all of Arizona has been surveyed for special status species, and surveys that have been
conducted have varied greatly in scope and intensity. Such surveys may reveal previously
undocumented population of species of special concern.
4. Arizona Wildlife Conservation Strategy (AWCS), specifically Species of Greatest Conservation Need
(SGCN), represent potential species distribution models for the State of Arizona which are subject to
ongoing change, modification and refinement. The status of a wildlife resource can change quickly, and
the availability of new data will necessitate a refined assessment. 
Locations Accuracy Disclaimer:
Project locations are assumed to be both precise and accurate for the purposes of environmental review. The
creator/owner of the Project Review Report is solely responsible for the project location and thus the correctness
of the Project Review Report content.
Page 2 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Recommendations Disclaimer:
1. The Department is interested in the conservation of all fish and wildlife resources, including those
species listed in this report and those that may have not been documented within the project vicinity as
well as other game and nongame wildlife.
2. Recommendations have been made by the Department, under authority of Arizona Revised Statutes
Title 5 (Amusements and Sports), 17 (Game and Fish), and 28 (Transportation).
3. Potential impacts to fish and wildlife resources may be minimized or avoided by the recommendations
generated from information submitted for your proposed project. These recommendations are preliminary
in scope, designed to provide early considerations on all species of wildlife.
4. Making this information directly available does not substitute for the Department's review of project
proposals, and should not decrease our opportunity to review and evaluate additional project information
and/or new project proposals.
5. Further coordination with the Department requires the submittal of this Environmental Review Report with
a cover letter and project plans or documentation that includes project narrative, acreage to be impacted,
how construction or project activity(s) are to be accomplished, and project locality information (including
site map). Once AGFD had received the information, please allow 30 days for completion of project
reviews. Send requests to:
Project Evaluation Program, Habitat Branch
Arizona Game and Fish Department
5000 West Carefree Highway
Phoenix, Arizona 85086-5000
Phone Number: (623) 236-7600
Fax Number: (623) 236-7366
Or
PEP@azgfd.gov
6. Coordination may also be necessary under the National Environmental Policy Act (NEPA) and/or
Endangered Species Act (ESA). Site specific recommendations may be proposed during further
NEPA/ESA analysis or through coordination with affected agencies
Page 3 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Page 4 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Page 5 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Page 6 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Page 7 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Special Status Species Documented within 3 Miles of Project Vicinity
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Antilocapra americana sonoriensis
Sonoran Pronghorn
LE,XN
S
1
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1
Note: Status code definitions can be found at https://www.azgfd.com/wildlife/planning/wildlifeguidelines/statusdefinitions/
. 
Special Areas Documented that Intersect with Project Footprint as Drawn
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Big Horn Mtns - Eagletail Mtns
Maricopa County Wildlife Movement
Area - Landscape
Harquahala Plain
Conservation Opportunity Area
Note: Status code definitions can be found at https://www.azgfd.com/wildlife/planning/wildlifeguidelines/statusdefinitions/
. 
Species of Greatest Conservation Need Predicted that Intersect with Project Footprint as Drawn, based on
Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Anthus spragueii
Sprague's Pipit
SC
2
Antilocapra americana sonoriensis
Sonoran Pronghorn
LE,XN
S
1
Artemisiospiza nevadensis
Sagebrush Sparrow
Asio otus
Long-eared Owl
2
Athene cunicularia hypugaea
Western Burrowing Owl
SC
S
S
2
Auriparus flaviceps
Verdin
2
Calypte costae
Costa's Hummingbird
2
Charadrius montanus
Mountain Plover
SC
2
Chilomeniscus stramineus
Variable Sandsnake
2
Colaptes chrysoides
Gilded Flicker
S
2
Eumops perotis californicus
Greater Western Bonneted Bat
Falco mexicanus
Prairie Falcon
2
Falco sparverius
American Kestrel
2
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1
Incilius alvarius
Sonoran Desert Toad
2
Lanius ludovicianus
Loggerhead Shrike
SC
2
Lasiurus cinereus
Hoary Bat
2
Lasiurus xanthinus
Western Yellow Bat
S
2
Macrotus californicus
California Leaf-nosed Bat
SC
S
2
Megascops kennicottii
Western Screech-owl
Melanerpes uropygialis
Gila Woodpecker
2
Myotis velifer
Cave Myotis
SC
S
2
Myotis yumanensis
Yuma Myotis
SC
2
Page 8 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Species of Greatest Conservation Need Predicted that Intersect with Project Footprint as Drawn, based on
Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Nyctinomops femorosaccus
Pocketed Free-tailed Bat
2
Passerculus sandwichensis
Savannah Sparrow
2
Pooecetes gramineus
Vesper Sparrow
2
Spizella breweri
Brewer's Sparrow
2
Tadarida brasiliensis
Brazilian Free-tailed Bat
Thomomys bottae subsimilis
Harquahala Southern Pocket Gopher
SC
2
Toxostoma bendirei
Bendire's Thrasher
2
Toxostoma lecontei
LeConte's Thrasher
S
2
Species of Economic and Recreation Importance Predicted that Intersect with Project Footprint as Drawn
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Callipepla gambelii
Gambel's Quail
Odocoileus hemionus
Mule Deer
Pecari tajacu
Javelina
Puma concolor
Mountain Lion
Zenaida asiatica
White-winged Dove
Zenaida macroura
Mourning Dove
Project Type: Development Outside Municipalities (Rural Development), Commercial/industrial (mall) and
associated infrastructure, New construction
Project Type Recommendations:
During the planning stages of your project, please consider the local or regional needs of wildlife in regards to movement,
connectivity, and access to habitat needs. Loss of this permeability prevents wildlife from accessing resources, finding
mates, reduces gene flow, prevents wildlife from re-colonizing areas where local extirpations may have occurred, and
ultimately prevents wildlife from contributing to ecosystem functions, such as pollination, seed dispersal, control of prey
numbers, and resistance to invasive species. In many cases, streams and washes provide natural movement corridors
for wildlife and should be maintained in their natural state. Uplands also support a large diversity of species, and should
be contained within important wildlife movement corridors. In addition, maintaining biodiversity and ecosystem functions
can be facilitated through improving designs of structures, fences, roadways, and culverts to promote passage for a
variety of wildlife. Guidelines for many of these can be found
at: https://www.azgfd.com/wildlife/planning/wildlifeguidelines/.
Consider impacts of outdoor lighting on wildlife and develop measures or alternatives that can be taken to increase
human safety while minimizing potential impacts to wildlife. Conduct wildlife surveys to determine species within project
area, and evaluate proposed activities based on species biology and natural history to determine if artificial lighting may
disrupt behavior patterns or habitat use. Use only the minimum amount of light needed for safety. Narrow spectrum bulbs
should be used as often as possible to lower the range of species affected by lighting. All lighting should be shielded,
canted, or cut to ensure that light reaches only areas needing illumination.
Page 9 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Minimize the potential introduction or spread of exotic invasive species, including aquatic and terrestrial plants, animals,
insects and pathogens. Precautions should be taken to wash and/or decontaminate all equipment utilized in the project
activities before entering and leaving the site. See the Arizona Department of Agriculture website for a list of prohibited
and restricted noxious weeds at https://www.invasivespeciesinfo.gov/unitedstates/az.shtml and the Arizona Native Plant
Society https://aznps.com/invas for recommendations on how to control. To view a list of documented invasive species or
to report invasive species in or near your project area visit iMapInvasives - a national cloud-based application for tracking
and managing invasive species at https://imap.natureserve.org/imap/services/page/map.html. 
To build a list: zoom to your area of interest, use the identify/measure tool to draw a polygon around your area of
interest, and select “See What’s Here” for a list of reported species. To export the list, you must have an
account and be logged in. You can then use the export tool to draw a boundary and export the records in a csv
file. 
 
Minimization and mitigation of impacts to wildlife and fish species due to changes in water quality, quantity, chemistry,
temperature, and alteration to flow regimes (timing, magnitude, duration, and frequency of floods) should be evaluated.
Minimize impacts to springs, in-stream flow, and consider irrigation improvements to decrease water use. If dredging is a
project component, consider timing of the project in order to minimize impacts to spawning fish and other aquatic species
(include spawning seasons), and to reduce spread of exotic invasive species. We recommend early direct coordination
with Project Evaluation Program for projects that could impact water resources, wetlands, streams, springs, and/or
riparian habitats.
The Department recommends that wildlife surveys are conducted to determine if noise-sensitive species occur within the
project area. Avoidance or minimization measures could include conducting project activities outside of breeding
seasons.
Based on the project type entered, coordination with State Historic Preservation Office may be required
(https://azstateparks.com/).
Trenches should be covered or back-filled as soon as possible. Incorporate escape ramps in ditches or fencing along the
perimeter to deter small mammals and herpetofauna (snakes, lizards, tortoise) from entering ditches.
Communities can actively support the sustainability and mobility of wildlife by incorporating wildlife planning into their
regional/comprehensive plans, their regional transportation plans, and their open space/conservation land system
programs. An effective approach to wildlife planning begins with the identification of the wildlife resources in need of
protection, an assessment of important habitat blocks and connective corridors, and the incorporation of these critical
wildlife components into the community plans and programs. Community planners should identify open spaces and
habitat blocks that can be maintained in their area, and the necessary connections between those blocks to be preserved
or protected. Community planners should also work with State and local transportation planning entities, and planners
from other communities, to foster coordination and cooperation in developing compatible development plans to ensure
wildlife habitat connectivity. The Department's guidelines for incorporating wildlife considerations into community
planning and developments can be found on the Wildlife Friendly Guidelines portion of the Wildlife Planning page at 
https://www.azgfd.com/wildlife/planning/wildlifeguidelines/.
Based on the project type entered, coordination with Arizona Department of Environmental Quality may be required
(http://www.azdeq.gov/).
Based on the project type entered, coordination with Arizona Department of Water Resources may be required
(https://new.azwater.gov/).
Based on the project type entered, coordination with U.S. Army Corps of Engineers may be required
(http://www.usace.army.mil/)
Page 10 of 11

Arizona Game and Fish Department
project_report_gila_hydrogen_facility_62599_64473.pdf
Project ID: HGIS-19292
Review Date: 5/22/2023 09:32:11 AM
Based on the project type entered, coordination with County Flood Control district(s) may be required.
Development plans should provide for open natural space for wildlife movement, while also minimizing the potential for
wildlife-human interactions through design features. Please contact Project Evaluation Program for more information on
living with urban wildlife at PEP@azgfd.gov or
at https://www.azgfd.com/wildlife/planning/wildlifeguidelines/ and https://www.azgfd.com/Wildlife/LivingWith.
The Department requests further coordination to provide project/species specific recommendations, please
contact Project Evaluation Program directly at PEP@azgfd.gov. 
Project Location and/or Species Recommendations:
Analysis indicates that your project is located in the vicinity of an identified Conservation Opportunity Area (COA). While
there are many areas in Arizona that present abundant conservation opportunities, COAs are specific areas on the
landscape that the Department identified as having the greatest potential for conservation efforts. COAs were identified
using species and habitat data, the presence of unique landscape features, and Departmental expertise. COAs range in
size, scope, and focal species and/or habitats and are strictly a non-regulatory conservation tool for the public and our
conservation partners to consider. For more information regarding this particular COA near your project area and the
Department's suggestions for potential conservation efforts, please visit the COA profile at 
https://awcs.azgfd.com/conservation-opportunity-areas.
Analysis indicates that your project is located in the vicinity of an identified wildlife habitat connectivity feature. The 
County-level Stakeholder Assessments contain five categories of data (Barrier/Development, Wildlife Crossing Area,
Wildlife Movement Area- Diffuse, Wildlife movement Area- Landscape, Wildlife Movement Area- Riparian/Washes) that
provide a context of select anthropogenic barriers, and potential connectivity. The reports provide recommendations for
opportunities to preserve or enhance permeability. Project planning and implementation efforts should focus on
maintaining and improving opportunities for wildlife permeability. For information pertaining to the linkage assessment
and wildlife species that may be affected, please refer
to: https://www.azgfd.com/wildlife/planning/habitatconnectivity/identifying-corridors/.
Please contact the Project Evaluation Program (pep@azgfd.gov) for specific project recommendations.
Powered by TCPDF (www.tcpdf.org)
Page 11 of 11

1
Joseph Mueller (PND)
From:
Rhonda Buss <rbuss@azland.gov>
Sent:
Thursday, June 8, 2023 2:56 PM
To:
Joseph Mueller (PND)
Cc:
Karen Dada
Subject:
Case No. CPA2023009 and Z2023059
Dear Joseph Muller, 
Thank you for the notice on Case No. CPA2023009 and Z2023059 for the proposed Gila Hydrogen Facility. There are 
State Trust Land parcels that run the length of the entire eastern and southern site boundaries. 
ASLD’s mission is to manage State Trust Land (STL), on behalf of the beneficiaries. While STL in the area is currently 
vacant, the parcels will likely develop in the future, and it is essential that STL be protected from the views/operations of
the proposed hydrogen facilities operation. As such, ASLD requests that the screening development standards 
referenced in the County’s approved Zoning Code be upheld with no modifications adjacent to STL. 
Should you have any questions, please feel free to contact me. 
 
 
Thank you,  
 
Rhonda Buss, AICP | Planner III 
Arizona State Land Department 
1110 West Washington Street | Phoenix, AZ 85007 
O: 602-542-3126 | rbuss@azland.gov 
Funding Arizona Public Schools and Institutions since 1915 
 
To help 
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download of 
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Inquiry #: 50715
Status: Assigned
Resolution/Action
Assign To / Completed By:
Schedule For:
Notes / Comments:
Assign Request
 
Finalize Request
 
Save Comments
Invalid Request
Request Date: 7/16/2023 8:30:31 AM
Inquiry Type: Land Use Planning and Zoning Applications
Customer: Marguerite Cambeis
Address: 76800 58th St, 1710, Salome, AZ, 85348
Contact Via: Phone
Email: mouse0921@gmail.com
Phone: +1 (602) 615-0912
Description: When is the hearing. We highly object to this
zoning change.
Loc. Address: 173 Acres
Loc. X-Streets: NEC 523RD AVE & Salome Highway
Board of Supervisors:
Related By:
Permit Number: Case # CPA 2023009 and Z2023059
Parcel Number:
Edit Customer
Entered By: Web Inquiry - 7/16/2023 8:30:31 AM
Division: Planning
Assigned To: Joseph Mueller - 7/17/2023 7:57:26 AM
Subject: Land Use Planning and Zoning Applications
Attach Files:
Choose Files No file chosen
 Upload
Notes/Comments:
Department:
Planning and Developmen
Division:
Planning
Subject:
Land Use Planning and Zo
Person:
-------