08. 09. CPA2023005 Z2023026 PZ Report
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CPA2023005 & Z2023026
Page 1 of 12
Report to the Planning and Zoning Commission
Prepared by the Maricopa County Planning and Development Department
Case:
CPA2023005 & Z2023026 – Sun Pond III
Hearing Date:
October 5, 2023
Supervisor District:
4
Applicant:
Stephen Morgan, KP Environmental, Inc.
Owner:
LSH Land Holdings, LLC
Requests:
(1) Comprehensive Plan Amendment to the Tonopah/Arlington Area Plan
to change the land use designation from Rural Densities to Utilities
(2) Zone change with overlay from Rural-43 to IND-2 IUPD for a solar
photovoltaic electric generation facility
Site Location:
Generally located on the northeast corner of 351st Ave. and Baseline Rd.in
the Tonopah area
Site Size:
Approx. 80 acres
Density:
N/A
County Island:
No
County Plan:
Tonopah/Arlington Area Plan – Rural Densities
Municipal Plan:
N/A
Municipal Comments:
N/A
Support/Opposition:
None known
Recommendation:
Approve CPA2023005
Recommendation:
Approve Z2023026 with conditions
CPA2023005 & Z2023026
Page 2 of 12
Project Summary:
1.
The applicant is requesting a Comprehensive Plan Amendment (CPA) to change the land use
designation identified in the Tonopah/Arlington Area Plan from Rural Densities to Utilities on an
80-acre site to accommodate the development of a phased utility-scale photovoltaic solar panel
electric generating facility. Once complete, the facility will produce approximately ten megawatts
(MW) of electricity. Simultaneously, the applicant is requesting a zone change with an overlay
from Rural-43 to IND-2 IUPD which allows electric production facilities an opportunity to vary
certain development standards due to the unique design of these types of facilities. The site is
located between 351st Ave. and 349th Ave. and between Baseline Rd. and Vineyard Rd., 2½ miles
east of Palo Verde Nuclear Power Station.
2.
The terrain of the 80-acre site is relatively flat. Currently, the applicant is proposing to add an
estimated 2,200 photovoltaic panels (subject to change) which will cover approximately 66.3% of
the net area of the site. The site will be fenced with six-foot tall chain link fences topped with two
feet of barbed wire fencing for security. There will be security lighting that will be shielded and
comply with County standards and international dark sky requirements.
3.
Similar to many solar energy projects with large arrays of photovoltaic collectors to capture
natural solar rays. Once power is generated and converted it will be interconnected into the
regional power grid at the nearby Hassayampa Switchyard via overhead or underground electric
transmission lines. The flat terrain of the site allows for little or no additional grading for this site
maintaining the natural landscape.
4.
The applicant has included a precise site plan and is requesting legislative approval of a Plan of
Development (POD). It should be noted that the project may have future battery electric storage
which is anticipated to occupy up to ten acres of land. If there is a need for a battery electric
storage component, then a future request to amend the POD will be made at that time.
5.
The current development schedule will be in response to market demand. During construction,
the site will house temporary office trailers, laydown yards, containers, and warehouse buildings
which will be placed on the Sun Pond II site adjacent to Baseline Rd. Once the site is fully
constructed then all temporary structures and yards will be removed from the Sun Pond II site.
There will be around 400 or fewer construction workers in each phase of construction. When fully
operational there will be up to four full-time employees for security of the site and
maintenance/inspection of the photovoltaic arrays.
6.
The narrative report submitted for CPA2023005 asserts that this proposed development will meet
the goals and policies of the Tonopah / Arlington Area Plan according to the applicant in the
following ways:
•
This development will constitute an improvement to the area because the subject site has
the necessary characteristics that make it suitable for photovoltaic energy production
since the site is surrounded by existing electrical production infrastructure.
•
The operation of the facility will not create a significant increase in traffic and will not
necessitate the need for road infrastructure or improvement.
•
The proposed land use will not impact the health and safety of the individuals living in the
vicinity, since hazardous materials will not be stored on-site, no emissions will be
CPA2023005 & Z2023026
Page 3 of 12
generated from the facility, nor noise during operations due to the nature of photovoltaic
energy generation.
•
The project will not impact any significant or unique natural habitats by keeping most of
the land intact and avoiding natural drainage features.
•
The proposed use associated with this amendment will be consistent with the goals,
objectives, and policies set forth in the area plan.
•
The proposal will be compatible with the predominant energy production facilities and
adjacent rural residential land uses during operation.
•
Unlike traditional commercial or industrial land uses that tend to change the area’s rural
character, solar-generating facilities produce very little traffic and are land uses not
dominated by large buildings and parking areas.
•
The renewable energy generated by this facility will directly contribute to the efficiency
and cost-effectiveness of utilities, facilities, and services that support the population and
environment of the County.
•
The electricity generated will be cost-competitive by supporting Arizona’s renewable
energy goals and will contribute to a reduction of greenhouse gas emissions plus
lessening dependency on fossil fuel energy generation.
•
The project will follow MCDOT's advice and leave areas along section and mid-section
lines preserved for future roadways.
•
The proposal will not incorporate substantial landscaping, other than revegetation where
needed using only native drought tolerant vegetation.
•
The developer will conduct a Class I Cultural Resources Inventory Search to determine the
extent of known cultural resources in the project area. If known cultural resources are
located the developer will take measures to avoid and minimize impacts to these
resources.
•
The developer will consult with the State Historic Preservation Officer (SHPO) and a letter
from SHPO will be provided to the County before the development of the site.
•
The proposal is not expected to substantially alter the visual quality in the area due to
significant existing energy infrastructure.
7.
The subject zone change with an overlay to IND-2 IUPD will vary the development standards listed
below with varied standards in bold. [Chart on next page.]
CPA2023005 & Z2023026
Page 4 of 12
Regulation
Base IND-2 Zoning District
Standards
Proposed IND-2 IUPD Zoning
District Standards
Max. Height
40’
40’
Min. Front Yard
10’; 15’**; 20’*** & 25’****
None
Min. Side Yard
None & 5’*
None
Min. Rear Yard
None & 25’*
None
Min. Street Side Yard
None & 10’*
None
Average Perimeter Setback
N/A
20’
Parking
1 space per 600 sq. ft. of floor
area
None
Loading & Unloading
1 space for every 10,000 sq.
ft. of floor area
None
Max. Lot Coverage
60%
60% Photovoltaic solar panel
arrays are not calculated in
lot coverage calculations
Sight Visibility Triangles
No structure or obstruction
over 2’ in height within a Sight
Visibility Triangle
Chain link fences without
screening
materials
can
exceed a height of 2’ inside a
Sight Visibility Triangle but
shall not exceed the
maximum fence height of 8’
Additional Regulations
All
uses
except
parking,
loading, unloading, or storage
shall be contained within an
enclosed building
All utility uses permitted
outdoors
Paving
For other than one single-
family dwelling unit or one
mobile home on a lot, any
parking area or driveway must
be paved
Alternative surface materials
or methods approved by
MCAQ
to
minimize
dust
pollution may be used in any
driveway or parking area
Site Enclosure & Screening
Min. 6’ solid wall adjacent to
any rural or residential zoning
district
and
any
outdoor
storage
of
an
industrial
nature.
Min. 6’ tall chain link fences
and gates with no attached
screening materials adjacent
to a rural or residential zoning
district or outdoor storage
area
Including attached barbed
wire or concertina wire under
8’ in height
Note: * Adjacent to Rural/Residential zoning districts
Note: ** Along Collector/Mid-Section Line roadways
Note: ***Along Arterials/Section Line roadways
8.
The applicant justifies varying the above-listed development standards due to the general
isolation of the site in an area adjacent to a nuclear power plant and very little development. The
applicant is requesting to eliminate the required yards to allow for more room on the site for
CPA2023005 & Z2023026
Page 5 of 12
energy production; however, to accommodate this request the applicant is requesting to add 20-
foot-deep perimeter setbacks. The areas reserved along the north/south mid-section line and
east/west section lines for future right-of-way will act as an additional buffer. Additionally, the
applicant is requesting to allow for chain link fences without attached screening materials and
attached barbed wire to top the fences for security. Having transparent fencing instead of solid
fences will not impact the viewshed and keep an open feel for the area. Other RUPD variation
requests are a result of the isolated location of the site.
Aerial Photos of the Site
CPA2023005 & Z2023026
Page 6 of 12
Land Use of the Site and Environs
Zoning of the Site and Environs
CPA2023005 & Z2023026
Page 7 of 12
Portion of the Land Use Exhibit
Portion of the Site Plan
CPA2023005 & Z2023026
Page 8 of 12
9.
Existing On-Site and Adjacent Zoning/ Land Use:
On-site:
Rural-43 / Rural densities – Natural desert
North:
Rural-43 / Rural densities – Natural desert & one single-family residence
South:
Rural-43 / Small lot residences – Natural desert & two single-family
residences
East:
Rural-43 / Rural densities – Natural desert & five single-family residences
West:
Rural-43 / Rural densities – Natural desert
Utilities and Services:
10.
Water:
Private well
Wastewater:
Private septic system (if needed)
School Districts:
Arlington Elementary School District
Buckeye Union High School
Fire:
Arizona Fire & Medical Authority
Police:
MCSO
Right-of-Way:
11.
The following table shown below includes existing and proposed half-width right-of-way and the
future classification based on 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
351st Ave.
0-feet
55-feet (Reserved)
Arterial Roadway
Baseline Rd.
0-feet
55-feet (Reserved)
Arterial Roadway
Vineyard Rd.
0-feet
0-feet
Collector Roadway
349th Ave.
0-feet
0-feet
Collector Roadway
Adopted Plan:
12.
Tonopah / Arlington Area Plan (adopted September 6, 2000): The site is designated Rural
Residential (0-1 du/ac). This land use category denotes areas where single-family residential
development or agricultural uses are desirable but urban services (sewer, water, law enforcement,
fire protection, schools, parks, etc.) are limited. This request to change the land use designation
to Utilities would be appropriate for this area since photovoltaic solar generation facilities
generally use little or no need for urban services and would be compatible with the area's existing
power generation and utility infrastructure.
Public Participation Summary:
13.
The applicant has complied with the requirements stated in Maricopa County’s citizen review
process with the required posting of the site and notification to adjacent property owners within
300 feet of the subject parcel and interested parties via first-class mail. The applicant has
submitted a Public Participation Results Report and according to the report, the applicant did not
receive any comments from the public concerning these requests.
14.
During the review period for these cases staff have received several comments from the Arizona
Game and Fish Department (AZGFD) related to the protection of local species to be addressed at
the time of building permitting. Staff will be adding a condition of approval that will have the
landowner or developer work with AZGFD in each phase of development of this project.
CPA2023005 & Z2023026
Page 9 of 12
Outstanding Concerns from Reviewing Agencies:
15.
N/A
Staff Analysis:
16.
Staff supports this comprehensive plan amendment and zone change as the site is appropriate
for the development of clean alternative energy production such as solar collection does not
produce greenhouse gas emissions or negatively affect air quality. Additionally, the economic
benefits of both the initial development and the long-term would be beneficial to this portion of
the County. The trading of electricity that will be produced from the site will also be a sustainable
economic benefit for the western region of the United States. Sun Pond III will utilize photovoltaic
technology panels that will follow the sun throughout the day constantly absorbing solar energy
as a direct current and converting it to alternating current for electricity distribution onto the
electric grid. Unlike other energy production that requires large amounts of water and fossil fuels,
photovoltaic solar generation needs only a small amount of water to occasionally clean the solar
panels and no need for fossil fuels during the day-to-day operation of the facility.
17.
Staff believes that photovoltaic solar generation facilities are compatible with rural areas. These
types of facilities generally require flat terrain and access to electric transmission lines with
adjacent electrical substations which makes this site a perfect location due to these attributes.
Since this site is located 2½ miles east of Palo Verde Nuclear Power Station and 2½ miles from
electrical substations staff believe this facility will have a minimal impact in the immediate area.
Staff believe that the requested development standards are reasonable and are consistent with
recently approved photovoltaic solar generation facilities in this part of the County. Adding a 20-
foot-deep perimeter buffer and transparent fencing will be a supportable accommodation for a
large amount of requested varied development standards.
18.
The applicant has demonstrated in their CPA narrative report that changing the designated land
use to Utilities of this site will meet the goals and policies of both the Tonopah/Arlington Area
Plan and the County’s Vision 2030 Comprehensive Plan.
Recommendations (two motions – CPA2023005 & Z2023026):
19.
Staff recommends the Commission adopt a motion recommending that the Board of Supervisors
approve CPA2023005.
20.
Staff recommends the Commission adopt a motion recommending that the Board of Supervisors
approve Z2023026, subject to conditions ‘a’ – ‘q‘:
a.
Development of the site shall be in substantial conformance with the site plan entitled
“Sun Pond 3 Solar Project”, consisting of eight full-size sheets, dated July 2023, and
stamped received July 19, 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 “Sun Pond III Solar Project”, consisting of 18 pages, dated July 2023, and stamped
received July 19, 2023, except as modified by the following conditions.
CPA2023005 & Z2023026
Page 10 of 12
c.
A Plan of Development is approved subject to a site plan entitled “Sun Pond 3 Solar
Project” consisting of eight full-size sheets, dated July 2023, and stamped received July
19, 2023. The Plan of Development may be amended administratively under a separate
application as long as the amendment complies with the established IUPD development
standards as approved by the Board of Supervisors and Maricopa County Zoning
Ordinance requirements. 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.
d.
Prior to the submission of building permits the developer must conduct a Class I Cultural
Resources Inventory of the site to determine the extent of any known cultural resources.
The developer shall take measures to avoid and minimize the impact of any known or
found cultural resource during the construction of any phase of the development.
e.
Prior to the submission of building permits the developer shall provide a letter from the
State Historic Preservation Office (SHPO) stating if or if not, the site is located in an area
of historical or cultural significance.
f.
The landowner or developer shall coordinate with the Arizona Game & Fish Department in
each phase of development to determine best management practices to minimize
impacts on the area’s wildlife. The landowner or developer shall coordinate with the
Arizona Game & Fish Department to determine the appropriate wildlife and habitat surveys
that will need to be conducted during the development of the site.
g.
Prior to the submission of building permits the landowner or developer shall abandon the
existing recorded ingress/egress easements within the site.
h.
Prior to the submission of building permits the landowner or developer shall combine all
lots that make up the site into one single parcel with one assessor’s parcel number.
i.
The following Planning Engineering comments shall apply:
1.
Detailed Grading and Drainage Plans must be submitted with the application for
Building Permit(s) indicating that runoff from each solar field area will be directed
to a retention basin.
2.
Building permit submittals shall include analysis to determine stabilization
requirements for perimeter channels to meet County requirements.
3.
Any retention and spreader basins shall drain within 36 hours.
6.
Prior to the issuance of building permits, the Traffic Statement must be approved
by MCDOT’s Traffic Branch.
7.
A Solar License is required from MCDOT for any private utility company that will
occupy the County right-of-way (i.e. transmission facilities).
8.
Engineering review of planning and/or zoning cases is for conceptual design only.
All development and engineering design shall be in conformance with Section
1205 of the Maricopa County Zoning Ordinance; Drainage Policies and Standards;
CPA2023005 & Z2023026
Page 11 of 12
Floodplain Regulations for Maricopa County; MCDOT Roadway Design Manual;
and current engineering policies, standards, and best practices at the time of
application for construction.
9.
Based on the conceptual design nature of the information submitted, changes to
the site layout and/or a reduction in the number of solar arrays may be
necessitated by the final engineering design of the site’s drainage infrastructure.
j.
The following MCDOT Planning comments shall apply:
1.
The landowner or developer shall provide a reserved minimum right-of-way of 55
feet relative to the roadway’s centerline along the site’s west and south frontage.
k.
The following IND-2 IUPD zoning district development standards shall apply:
1.
There shall be no required yards.
2.
There shall be an average perimeter setback along reserved right-of-way and along
boundaries without reserved right-of-way of 20 feet.
3.
There shall be no parking requirements.
4.
There shall be no required loading/unloading spaces.
5.
Photovoltaic solar panel arrays shall not contribute to lot coverage calculations.
6.
Chain link fences without screening materials shall exceed two feet in height but
shall not exceed the maximum fence height of eight feet inside a 25-foot by 25-
foot sight-visibility triangle.
7.
Photovoltaic solar panel arrays shall not be enclosed in a building.
8.
Alternative surfacing materials or other methods approved by Maricopa County Air
Quality to minimize dust pollution shall be allowed in driveways and parking areas.
9.
A minimum of six-foot tall chain link fences and gates without screening materials
shall be allowed adjacent to any zoning district.
10.
Attached barbed wire or concertina wire shall be permitted under a height of eight
feet for fences and gates.
11.
The landowner or developer shall coordinate with the Arizona Game & Fish
Department to determine fencing design and layout to provide appropriate wildlife
access and maintain wildlife connectivity across the project area.
l.
The IUPD overlay instrument is applied to restrict the use of the site and this IND-2 IUPD
shall limit the use of the site to a photovoltaic electric generation facility including any
ancillary uses of the facility. Any other uses on the site shall require a zone change major
amendment.
CPA2023005 & Z2023026
Page 12 of 12
m.
All outdoor lighting shall be in compliance with Section 1112 of the Maricopa County
Zoning Ordinance. Any outdoor lighting shall be placed so as to reflect light away from
any adjoining rural or residential zoning district.
n.
Prior to the issuance of a building permit, written confirmation shall 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.
o.
Amendment to the zone change shall be processed as a revised application in accordance
with Maricopa County Zoning Ordinance requirements.
p.
Noncompliance with any Maricopa County regulation shall be grounds for initiating a
revocation of this Zone Change as set forth in the Maricopa County Zoning Ordinance.
q.
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:
Martin Martell, Planner
Reviewed by:
Matthew Holm, AICP, Planning Supervisor
Attachments:
Case Map (1 page)
Land Use Exhibit (1 page)
Site Plan (reduced 8.5”x11”, 9 pages)
CPA Narrative Report (11 pages)
Zone Change Narrative Report (18 pages)
MCDOT comments (4 pages)
DPR comments (2 page)
Arizona Game & Fish Department comments (16 pages)
/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 80 approx.
Generated September 22, 2023 9:13 AM
CPA2023005
Application Name:
Legal Description
Sun Pond III Solar Project EDR
Applicant
Case Address
,
Stephen J Morgan for LSH Land Holdings
Applicant Phone/Email
Parcel Primary:
603.557.8974
SMorgan@kpenvironmental.com
Map scale 1:6,489
Supervisor District No.
COMPREHENSIVE PLAN AMENDMENT (CPA) FOR 80 ACRES OF STATE TRUST LAND IN
UNINCORPORATED MARICOPA COUNTY TO ALLOW FOR THE DEVELOPMENT OF A SOLAR ENERGY
/
Maricopa County Planning & Development - Phoenix, AZ
4
Gross Acres: 521 approx.
Generated September 22, 2023 9:30 AM
Z2023026
Application Name:
Legal Description
Sun Pond III Solar Project EDR
Applicant
Case Address
,
Stephen J Morgan for LSH Land Holdings
Applicant Phone/Email
Parcel Primary:
603.557.8974
SMorgan@kpenvironmental.com
Map scale 1:6,489
Supervisor District No.
REZONE OF APPROXIMATELY 80 ACRES OF STATE TRUST LAND FROM RURAL ZONING (RU-43) TO
INDUSTRIAL (IND-2), WITH AN INDUSTRIAL UNIT PLAN OF DEVELOPMENT (IUPD), TO ALLOW THE
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U.P.R.R.
Chukar
Substation
07
Sun
Pond III -
CPA2023005
")
Mesquite Power
Generating Station
Palo Verde
Nuclear Gen.
Station
S 355th Ave
Tonopah/Arlington Area
Old US Hwy. 80 Area
CPA2011008
CPA2019001
CPA2020001
CPA2020001
CPA2010013
CPA2011004
CPA2010012
S 351st Ave
Hassayampa
Switchyard
Salome Hwy
S 355th Ave
W Elliot Rd
S 331st Ave
S 351st Ave
W Lower Buckeye Rd
S 339th Ave
S 343rd Ave
W Broadway Rd
W Dobbins Rd
S 371st Ave
S 349th Ave
Southern Ave
S 353rd Ave
W Baseline Rd
S 363rd Ave
367th Ave
Euclid Ave
367th Ave
S 348th Ave
W Sunrise Dr
Broadway Rd
S 365th Ave
S 347th Ave
S 341st Ave
S 336th Ave
W McNeil St
W Olney Ave
W Elwood St
S 375th Ave
S 330th Ave
Mobile Ln
Sunland Ave
W Western Star Blvd
367th Ave
379th Ave
S 335th Ave
W Roeser Rd
S 333rd Ave
S 360th Ave
S 350th Ave
342nd
W Piedmont Rd
Unpaved Rd
Caldwell St
W Paseo Way
W Siesta Way
S 361st Ave
W Illini St
S 358th Ave
W Steinway Dr
N 339th Ave
W Pioneer St
375th Ave
W Wood St
W Bowker St
S 377th Ave
W Broadway St
W Alta Vista Rd
S Mountain Ave
S 337th Ave
W Superior
S 349th Dr
S 359th Ave
S 357th Ave
W Pecan Dr
W la Mirada Dr
S Elliot Rd
S 352nd Ln
Huntington Dr
W Elliot Rd
W Elwood St
W Wier Ave
S 363rd Ave
S 347th Ave
S 335th Ave
S 348th Ave
S 360th Ave
S 339th Ave
W Sunrise Dr
W Baseline Rd
S 349th Ave
S 349th Ave
S 363rd Ave
W Southern Ave
S 347th Ave
W Dobbins Rd
Arlington
Wintersburg
Buckeye
Legend
Map
Extent
ARIZONA
Phoenix
Maricopa County
Author: sjw
Date: 07.11.23
SUN POND III SOLAR PROJECT
Map Extent: Maricopa County, Arizona
Figure 1: CPA2023005 Land Use Exhibit
0
1,000
2,000
3,000
4,000
Feet
°
State Plane Coordinate System
North American Datum 1983
Arizona Central
Linear Unit: Foot US
Existing Generating Station
")
Existing Substation
")
Hassayampa Switchyard
#*
!
!
!
Existing 500 kV Transmission Line
!
!
!
Existing 69 kV Transmission Line
Pipeline
Road
Railroad
Planning Area Boundary
Existing Land Use Designations
Sun Pond III - CPA2023005
Municipal Boundary
Master Planned Community
Rural
Palo Verde Nuclear Generating
Station
Rural Densities
Industrial
Large Lot Residential
Small Lot Residential
Utility
Commercial Retail Center
Open Space
RECEIVED 19. JUL 23
P: 602.490.0535 / F: 602.368.2436
www.hilgartwilson.com
2141 E. HIGHLAND AVE., STE. 250
PHOENIX, AZ 85016
HAS JOINED COLLIERS ENGINEERING & DESIGN
31
RECEIVED 19.JUL 23
Z2023026
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E
E
E
TX
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NO.
APN NUMBER
OWNER
ZONING
PROPERTY USE
33
504-34-003
JUE KENNETH/LAI KOON TR
RU-43
VACANT
34
401-42-015Z
HICE FAMILY TRUST
RU-43
VACANT
35
401-42-991A
CMH HOMES INC
RU-43
VACANT
36
401-42-016C
CMH HOMES INC
RU-43
VACANT
37
401-42-709
CASTRO FRANCISCA
RU-43
VACANT
38
401-42-710
CASTRO FRANCISCA
RU-43
VACANT
39
401-94-011
IBARRA ZOYLA
RU-43
SINGLE FAMILY RESIDENCE
40
401-42-644
ARELLANO JOSE G
RU-43
VACANT
41
504-34-006U
PANICKER PHILIP/SHIRLEY
RU-43
VACANT
42
504-34-078
PICASSO FLAVIO
RU-43
SINGLE FAMILY RESIDENCE
43
504-34-077
PICASSO FLAVIO
RU-43
VACANT
44
504-34-076
PICASSO FLAVIO
RU-43
VACANT
45
504-34-006R
RABICKE LAWRENCE & DIANE
RU-43
VACANT
46
504-34-042
CARRASCO NOEL GUEARA
RU-43
SINGLE FAMILY RESIDENCE
47
504-34-043
RIVERA JOEL/AGUILAR JOSE/MIRANDA ELSA
RU-43
SINGLE FAMILY RESIDENCE
48
504-34-006T
SUBHI KALLA TRUST B
RU-43
VACANT
49
504-34-006C
PADRON JESUS LOREDO
RU-43
VACANT
50
504-34-018
OROZCO AVELARDO
RU-43
VACANT
51
504-34-009A
ROMO GUILLERMO A
RU-43
VACANT
52
504-34-004A
SERNA MARIOM/BETTY J
RU-43
VACANT
53
504-34-045
SERNA BETTY/MARIO
RU-43
MOBILE HOME SITE
54
504-34-044
SERNA BETTY/MARIO
RU-43
VACANT
55
504-34-004X
GALVEZ RICARDO FIGUEROA
RU-43
VACANT
56
504-34-001Y
BURRUEL ISELA PARRA/AYON IVANNA
RU-43
MOBILE HOME SITE
75
76
77
78
79
80
81
82
83
10
504-34-002A
JNC BALD HILL LLC
RU-43
VACANT
504-34-001J
DUENAS LINDA S/MARTINEZ JOSE
RU-43
VACANT
504-34-004C
RAMIREZ ANA LILIA CONTRERAS
RU-43
VACANT
504-34-004W
GREGG RALPH C JR & BETTY J
RU-43
VACANT
504-34-047
SERNA BETTY/MARIO
RU-43
VACANT
504-34-046
SERNA BETTY/MARIO
RU-43
VACANT
504-34-070
SERNA BETTY/MARIO
RU-43
VACANT
504-34-009B
SIQUEIROS VICTOR
RU-43
VACANT
401-42-991E
CMH HOMES INC
RU-43
VACANT
401-42-994
SWEIS SAMIR S/RAMOS VICTOR/NGUYEN ED
RU-43
VACANT
E
E
E
TX
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working days before you begin excavation
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E
E
E
TX
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SALOME HWY
BASELINE RD
363RD AVE
361ST AVE
SOUTHERN AVE
367TH AVE
355TH AVE
351ST AVE
349TH AVE
SUN POND
SOLAR PROJECT
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The MaxWell
TM Plus Drainage System Detail And Specifications
Manufactured and Installed by
TORRENT RESOURCES
An evolution of McGuckin Drilling
www.torrentresources.com
ARIZONA 602/268-0785
NEVADA 702/366-1234
CALIFORNIA 661/947-9836
AZ Lic. ROC070465 A, ROC047067 B-4, ADWR 363
CA Lic. 528080, C-42, HAZ.
NV Lic. 0035350 A - NM Lic. 90504 GF04
U.S. Patent No. 4,923,330 - TM Trademark 1974, 1990, 2004
The MaxWell
TM IV Drainage System Detail And Specifications
Manufactured and Installed by
TORRENT RESOURCES
An evolution of McGuckin Drilling
www.torrentresources.com
ARIZONA 602/268-0785
NEVADA 702/366-1234
CALIFORNIA 661/947-9836
AZ Lic. ROC070465 A, ROC047067 B-4, ADWR 363
CA Lic. 528080, C-42, HAZ.
NV Lic. 0035350 A - NM Lic. 90504 GF04
U.S. Patent No. 4,923,330 - TM Trademark 1974, 1990, 2004
Contact Arizona 811 at least two full
working days before you begin excavation
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Sun Pond III Solar Project
Application for a General Comprehensive Plan
Amendment
Narrative Report
CPA2023005
NEC of 351th Ave. and Baseline in the Tonopah area
Submitted to:
Maricopa County
Planning and Development Department
July 2023
RECEIVED 19.JUL 23
1
Table of Contents
Table of Contents ....................................................................................................................................... 1
Executive Summary ................................................................................................................................... 2
Onsite and Regional Location .............................................................................................................. 2
CPA Size and Description of Land Use Types by Acreages ........................................................... 2
Roads and Transportation Systems Serving the Proposed Project ............................................... 2
Suitability with Surrounding Land Uses .............................................................................................. 2
Proposed Use ......................................................................................................................................... 3
Narrative Response ................................................................................................................................... 3
Whether the Amendment Constitutes an Overall Improvement to the Comprehensive Plan .... 3
Whether the Amendment Will Adversely Impact All or a Portion of the Planning Area By: ........ 3
Altering acceptable land use patterns ............................................................................................. 3
Requiring public expenditures for larger or more expensive infrastructure ............................... 3
Requiring public improvements to roads, sewer, or water systems that are needed to
support the planned land uses ......................................................................................................... 4
Adversely impacting planned uses because of increased traffic ................................................ 4
Affecting the livability of the area or health and safety ................................................................. 4
Adversely Impacting the natural environment or scenic quality of the area .............................. 4
Whether the Amendment is Consistent with the Overall Intent of the Comprehensive Plan ..... 5
The Extent to Which the Amendment is Consistent with the Specific Goals and Policies
Contained Within the Tonopah/Arlington Area Plan ......................................................................... 5
Land Use ............................................................................................................................................. 5
Transportation ..................................................................................................................................... 7
Environment ........................................................................................................................................ 7
Economic Development .................................................................................................................. 10
Other Pertinent Information As Requested by the Maricopa County Planning Department .... 10
2
Executive Summary
This narrative report provides the required information to support the request for a General
Comprehensive Plan Amendment (CPA) for the Sun Pond III Solar Project (Project) in
unincorporated, western Maricopa County in the vicinity of the Palo Verde Nuclear Generating
Station (PVNGS). The proposed use is the development of a photovoltaic (PV) solar energy
facility with battery storage to be located on approximately 80 acres of State Trust Land managed
by the Arizona State Land Department (ASLD), north of Baseline Road, east of South 351st
Avenue and west of West Fremont Road, about four miles northwest of the community of
Arlington. LSH Land Holdings, LLC (Applicant), a wholly owned subsidiary of Longroad Energy,
plans to submit applications for the following:
•
A General CPA to change the land use designation of the Tonopah/Arlington Area Plan
on approximately 80 acres from Rural Densities to Utilities.
•
Zone Change with Overlay request from Rural Zoning (RU-43) to Industrial with an
Industrial Unit Plan of Development (IND-2 IUPD) on approximately 80 acres.
Onsite and Regional Location
The Project is located on 80 acres of State Trust Land north of Baseline Road, east of South
351st Avenues and west of West Fremont Road, about four miles northwest of the community of
Arlington. The Project site is currently vacant land. The legal description of the lands included in
this application is: Section 31, Township 1 North, Range 5 West.
The Project is located in unincorporated, western Maricopa County, in the vicinity of the PVNGS.
The Project area is covered by the Tonopah/Arlington Area Plan, adopted in 2000. Most of the
Tonopah/Arlington Area Plan is unincorporated Maricopa County. The closest municipality to the
Project is the city of Buckeye, located approximately 13 miles to the east. Land ownership in the
immediate vicinity of the Project is a combination of private land and State Trust Land managed
by ASLD.
CPA Size and Description of Land Use Types by Acreages
The entire 80-acre Project site is located on State Trust Land designated as Rural Densities. This
application requests a CPA to change the land use designation for all 80 acres from Rural
Densities to Utilities, in order to develop a PV solar energy facility with battery storage.
Roads and Transportation Systems Serving the Proposed Project
The Project site will be accessed via existing roads. The Salome Highway to the north of the
Project will provide access to the arterial roads to the Project site. Regional traffic and access to
the arterial roads will be primarily via Interstate 10 (I-10). Additional details regarding the existing
roadway network, access, and traffic can be found in the Traffic Statement Technical
Memorandum attached to this CPA application.
Suitability with Surrounding Land Uses
The land use in the Project area is dominated by industrial and utility uses. These include several
existing high-voltage transmission lines; several existing generating stations (including PVNGS,
Arlington Valley Energy Facility, Red Hawk Power Station, and the Mesquite Power Generating
3
Station); several existing solar facilities (including Sun Streams I, Sun Streams II, Sun Streams
Expansion, Redhawk Solar Plant, and Mesquite Solar I Power Plant); the existing Hassayampa
Switchyard, the existing Chukar Substation, along with other transportation and industrial uses
such as the Union Pacific Railroad (UPRR). There are also low-density rural residential land uses
to the north and east of the Project.
Solar projects are typically low-impact developments that can be designed to blend into the
natural landscape. Designating the land for utility use allows for the efficient utilization of available
space while preserving the rural character of the surrounding rural residential areas. The Project
will be planned and executed in a manner that minimizes visual and environmental impacts,
ensuring compatibility with the rural residential setting. In addition, the proposed solar and battery
storage facility associated with this CPA will be compatible with surrounding land uses due to the
presence of substantial energy infrastructure in the area.
Proposed Use
The Applicant is proposing the development of a PV solar generation facility with energy storage.
Narrative Response
Whether
the
Amendment
Constitutes
an
Overall
Improvement
to
the
Comprehensive Plan
Amending the Tonopah/Arlington Area Plan to allow for the development of the proposed Project
will constitute an improvement to the Plan because the subject lands have the necessary
characteristics that make them very suitable for solar energy generation. The Project is located in
an area with:
•
excellent solar radiation suitable for utility-scale solar generation,
•
an absence of sensitive natural resources, and;
•
proximity to existing transmission infrastructure to allow for connection into the regional
electrical system without substantial upgrades.
In addition, the surrounding area contains substantial existing electrical infrastructure including
high-voltage transmission lines, several existing generating stations, several existing solar
facilities, the Hassayampa Switchyard, and the Chukar Substation.
Whether the Amendment Will Adversely Impact All or a Portion of the Planning
Area By:
Altering acceptable land use patterns
This amendment will not alter the acceptable land use patters because, the Project site is
surrounded by substantial existing electrical infrastructure including PVNGS and numerous power
generation facilities, including both natural gas and solar facilities. The land use associated with
the Project will be consistent with land use patterns in the surrounding area.
Requiring public expenditures for larger or more expensive infrastructure
4
This amendment will not require public expenditures because, the Project will utilize the
substantial existing electrical infrastructure in the Project vicinity.
Requiring public improvements to roads, sewer, or water systems that are needed to
support the planned land uses
The operation of the Project will not create a significant increase in traffic that necessitates the
need for road improvements. Construction traffic to the Project site will utilize existing roads, and
once constructed, the Project will require very few vehicle trips during operation. The Project will
not require the development of any new water or sewer systems. The need for water on the site
during operations will be minimal, necessary only for the needs of employees and intermittent
cleaning of the solar panels. The wastewater generated at the facility during operations is
anticipated to be treated with onsite wastewater treatment facilities, such as a conventional septic
tank system or similar alternative system as regulated by Arizona Department of Environmental
Quality and administered by Maricopa County Environmental Services Department.
Adversely impacting planned uses because of increased traffic
During the construction phase of the Project, traffic will temporarily increase due to the daily trips
for the construction workforce as well as deliveries of supplies and equipment. There will be
minimal vehicle trips during the operational life of the Project and no significant impacts on
local or regional traffic.
Affecting the livability of the area or health and safety
The proposed use of the subject lands will not impact the health and safety of the individuals
living in the vicinity of the Project. The Project will not utilize or store hazardous materials,
will not generate significant emissions or noise during operation, and will take measures to
reduce fugitive dust on the Project site.
All applicable local and county fire laws and regulations will be complied with, and all reasonable
measures will be taken to prevent fires on the site. Fire hazard risk may be reduced through
the control or suppression of weeds. All weed control will be conducted in compliance with
county regulations. Battery storage systems modules will be enclosed and designed with fire
suppression systems built to all applicable codes.
Adversely impacting the natural environment or scenic quality of the area
The Project will not impact any significant or unique natural habitats. The Project site is
previously disturbed vacant land that is not in pristine natural condition. The dominant vegetation
is creosote bush and other small, dispersed plants. There are several small drainages on the
Project site but no major washes. The Project will avoid development within drainage features
and floodplains. Drainage and flood patterns on the Project site will be incorporated into the final
design to reduce potential impacts to onsite and offsite flooding.
The solar field will introduce new structures to the visual landscape; however, it will not
adversely impact the scenic quality of the area due to the presence of substantial existing
infrastructure in the surrounding area.
5
Whether the Amendment is Consistent with the Overall Intent of the
Comprehensive Plan
The proposed use associated with this CPA will be consistent with the goals, objectives, and
policies set forth in the Tonopah/Arlington Area Plan. The relevant goals, objectives, and policies
are listed and discussed in the sections below.
The Extent to Which the Amendment is Consistent with the Specific Goals and
Policies Contained Within the Tonopah/Arlington Area Plan
Land Use
Land Use Element Goal: Promote efficient land development that is compatible with adjacent
land uses, is well integrated with the transportation system, and is sensitive to the natural
environment.
As discussed in previous sections, the surrounding land use is dominated by industrial and utility
uses that will be compatible with the proposed Project. These include several existing high-
voltage transmission lines; several existing generating stations (including PVNGS, Arlington
Valley Energy Facility, Red Hawk Power Station, and the Mesquite Power Generating Station);
several existing solar facilities (including Sun Streams I, Sun Streams II, Sun Streams Expansion,
Redhawk Solar Plant, and Mesquite Solar I Power Plant); the existing Hassayampa Switchyard,
the existing Chukar Substation, along with other transportation and industrial uses such as the
UPRR. The existing electric transmission infrastructure in the immediate vicinity allows this
Project to connect to the regional grid without the need for substantial upgrades or new
transmission lines.
The Project will have no long-term effects on the transportation system and will require very few
vehicle trips once constructed. The Project will not significantly impact the environment, as is
further discussed under the Environment Element, below.
Objective L1: Encourage orderly, efficient, and functional development patterns.
The Project is located in an area with substantial existing and planned energy development and
is compatible with the existing land use in the area. Siting this Project in an area with substantial
energy and utility infrastructure will further consolidate the land use in the Project vicinity, which
is an efficient and functional pattern of development.
Policy L1.3: Encourage land developers to cooperate with residents, and homeowner’s
associations during any development review process for construction near the property
holdings of those residents and homeowner’s associations.
The Applicant will coordinate with nearby residents during the review and public hearing
process of the Project. In addition, the Project will send mailers to residents within 300
feet of the Project as well as local stakeholders within 30 days of the submittal of this
application. Additional details regarding public notice and coordination can be found in the
attached Public Participation Plan.
Policy L1.5: Review development proposals along major streets and adjacent to existing
and approved land uses to determine compatibility with those uses.
6
Existing and planned land uses in the Project vicinity include extensive energy
infrastructure as well as low-density rural residential development. The Project will be
compatible with the predominant land use in the area due to the presence of existing
energy infrastructure, including the PVNGS located less than a mile west of the Project
site. The Project will be compatible with Rural Densities land use because it will produce
minimal noise and traffic once constructed.
Policy L1.6: Discourage the location of commercial or industrial developments in locations
specified for development with rural density land uses.
This CPA is compatible with the existing land uses as there are several existing generation
facilities including the PVNGS and industrial uses that cover a significant portion of the
areas adjacent to and near the Project site.
Policy L1.7: Encourage rural type, light industrial development near PVNGS and along
the railroad.
The Project will be a utility/light industrial use and will occur near PVNGS and the UPRR
corridor, as well as other power and transmission facilities in the area. Unlike traditional
commercial or industrial land uses that change the area’s rural character, solar-generating
facilities produce very little traffic and are land uses not dominated by large buildings or
large parking areas.
Objective L2: Provide for a functional, efficient and cost-effective system of utilities, facilities and
services to serve county population and employment centers.
The renewable energy generated by the proposed Project will directly contribute to the efficiency
and cost-effectiveness of utilities, facilities, and services that support the population and
employment in Maricopa County. The electricity generated by the Project will be cost-competitive,
will help support Arizona’s renewable energy goals and will reduce greenhouse gas emissions by
reducing the need for fossil fuel energy sources. The siting of this Project near existing generation
and transmission infrastructure supports a functional and efficient system because it consolidates
energy infrastructure and allows the Project to get solar energy to the grid without extensive new
transmission infrastructure.
Policy L2.2: Where possible and appropriate, in the design and construction of new
development, preserve natural drainage ways, including the Hassayampa River, major
washes, and open space corridors.
As was previously discussed, the Project will avoid development within drainage features
and floodplains. Drainage and flood patterns on the Project site will be incorporated into
the final design to reduce potential impacts to onsite and offsite flooding. If necessary, the
Applicant will apply for a Floodplain Use Permit from the Flood Control District of Maricopa
County (FCD) if future plans call for the construction of the limited number of project
components within the floodplain. The Applicant will also coordinate with the U.S. Army
Corps of Engineers if necessary for any limited construction within any jurisdictional
waterways determined to be located on site. In addition, any portion of a fence to be
constructed within the regulatory floodplain will be designed with adequate openings to
maintain historic flow patterns.
7
Transportation
Transportation Element Goal: Provide an efficient, cost-effective, integrated, accessible,
environmentally sensitive, and safe countywide multi-modal system that addresses existing and
future roadway networks, as well as promotes transit, bikeways, and pedestrian travel.
Objective T1: Establish a circulation system that provides for the safe, convenient and efficient
movement of goods and people throughout Maricopa County.
As was previously discussed, the operation of the Project will not create a significant increase in
traffic and will not necessitate the need for road improvements. Construction traffic to the Project
site will utilize existing roads, and once constructed, the Project will require very few vehicle trips
during operation. During construction, the Applicant will implement a traffic management plan to
efficiently and safely control the flow of traffic including worker trips and the delivery of
construction materials to the Project site.
Policy T1.4: Support efforts to provide all-weather travel over washes where justified.
Major drainages and washes will be avoided to the extent possible by the Project and
existing all-weather travel over washes will not be impacted.
Policy T1.6: Where appropriate, support efforts to obtain land dedication for roadways
during rezoning and subdivision processes.
As required by Maricopa County Department of Transportation (MCDOT), efforts to obtain
land preservation for roadways will be conducted during the rezoning process for the
Project.
Environment
Environment Element Goal 1: Promote development that mitigates adverse environmental
impacts on the natural and cultural environment, preserves highly valued open space, and
remediated areas contaminated with hazardous materials.
The Project will have minimal impacts on the natural and cultural environment and there is no
highly valued open space on the Project site. The Project will not expect to encounter any
historical and archaeological resources on the Project site during construction; however, if cultural
resources are encountered, the Project will comply with relevant policies and procedures to avoid
and minimize impacts.
The subject lands are not known to be contaminated with hazardous materials nor will hazardous
materials be stored or utilized on the Project site.
Environment Element Goal 2: Improve air quality and reduce noise impacts.
This CPA will be expected to result in improved air quality in regard to fugitive dust emissions
relative to the Project site in its current state. The Project will not generate significant emissions,
and there will be no significant noise emissions associated with the operation of the Project.
Objective E1: Encourage developments that are compatible with natural environmental features
and which do not lead to their destruction.
8
The Project site is a large and relatively flat property that is conducive to commercial solar
development. There are no significant terrain features on the Project site and only small drainages
on the site. The Project will avoid development within drainage features and floodplains. No
significant natural environmental features will be destroyed by the construction of the Project.
Policy E1.1: In order to minimize adverse impacts of hillside development, the submittal
of land development applications on lands with slopes of 15 percent or greater should be
discouraged.
The Project is not located on lands with slopes of 15 percent or greater.
Policy E1.2: Encourage land uses and development designs that are compatible with
environmentally sensitive areas such as parks, open space, floodplains, hillsides, wildlife
habitat, scenic areas, and unstable geologic and soil conditions.
Proposed development will not occur in sensitive areas. All lands targeted for development
are relatively flat, which will minimize necessary grading. Floodplains and drainage
features will be avoided and incorporated into the Project design. Unstable geologic/soil
conditions will be avoided to the extent possible and appropriate engineering
considerations will be incorporated into the Project design if needed.
Policy E1.3: Encourage compatible land use relationships with sources of excessive
noise.
There will be no significant noise emissions associated with the operation of the Project.
Policy E1.5: Encourage land uses and development designs that are compatible with soil
conditions which have severe development constraints such as within the Cherioni Rock
outcrop area located in the southwestern portion of the planning area, the Casa Grande
Harqua located in the southeast portion of the planning area, and the Carrizo-Brios and
Carrizo associates which are located along the eastern edge of the planning area.
The Project will be located on the Casa Grande-Harqua soil association, according to the
soils association mapping of the Tonopah/Arlington Area Plan. The Casa Grande-Harqua
soils do not pose substantial constraints to solar development. Soil compatibility will be
taken into consideration by the engineering team throughout the design process.
Objective E2: Protect and preserve existing water resources and minimize flood hazards.
Policy E2.1: Support Flood Control District policies, drainage regulations, and floodplain
regulations for all development within the County.
As noted above, there are no major washes on the Project site and the small drainages
will be avoided to the extent feasible. If development were to occur in a floodplain or
drainage, it will be conducted in accordance with the requirements of the Maricopa County
Flood Control District.
Policy E2.2: Encourage cooperation with the Flood Control District to minimize land
development conflicts and achieve compatibility with the development and implementation
of Area Drainage Master Plan Studies and other relevant investigations.
9
The Project will cooperate with the Flood Control District to minimize development conflicts
and achieve compatibility with any Area Drainage Master Plan Studies and other
investigations.
Policy E2.3: Discourage the location of structures that would alter current storm water
drainage patterns and which would increase water ponding and sheetflow in areas of
extremely flat land and areas currently susceptible to sheetflow.
Unlike a typical development, a PV project results in only a small portion of the site being
impervious. Any buildings, electrical equipment and paved driveways will create
impervious areas, but the solar field does not because the modules are elevated above
the ground. While the Project intends to cover much of the site with PV modules, the
supports on which the modules are mounted will cover considerably less than five percent
of the site. Precipitation on the modules themselves simply drains off their edges onto the
ground below. As a result, nearly full access to the ground surface will be retained.
Generally, the Applicant will be constructing channels, retention basins and berms
throughout the site to manage stormwater such that flows are not increased as a result of
development while also maintaining historical drainage patterns.
Policy E2.6: Encourage the use of drought tolerant and low water consumptive landscape
materials.
The Project will not incorporate substantial landscaping, other than revegetation where
necessary. Where revegetation is required, the Project will utilize native plants that are
drought tolerant and consume little water.
Objective E3: Preserve existing habitat areas of wildlife and/or desert plant species.
No high-quality habitats for sensitive wildlife are known to occur on the Project site. The Arizona
Game and Fish Department (AGFD) and U.S. Fish and Wildlife Service (USFWS) will be
consulted during development of the Project to determine what sensitive species have the
potential to occur in the Project area.
Policy E3.1: Encourage the protection of threatened and endangered species.
No sensitive species are known to occur on the Project site; however, AGFD and USFWS
will be consulted to determine what species have the potential to occur. Measures will be
taken during construction to avoid and minimize impacts to sensitive species.
Policy E3.5: Encourage the preservation and/or restoration of riparian habitats.
The Project will avoid development in the drainages and floodplains on the Project site.
Objective E4: Protect historical and archaeological resources.
Due to the location of the Project on State Trust Land, the Applicant will conduct a Class III
Cultural Resources Survey to support the leasing process with ASLD. If cultural resources are
located on the Project site, the Applicant will take measures to avoid and minimize impacts during
construction.
10
Policy E4.1: Prior to development, excavation, or grading, request that developers submit
a letter from the Arizona Historic Preservation Officer stating that the proposed land
development will have no effect on historical or cultural resources.
Due to the location of the Project on State Trust Land, the Applicant will complete a Class
III Cultural Resources Survey and consult with the State Historic Preservation Office
(SHPO). A letter from SHPO will be provided to the county prior to development of the
Project site.
Economic Development
Economic Development Element Goal: Promote a growing, balanced, efficient, and diversified
economy, consistent with available resources, that enhances quality employment opportunities,
improves quality of life, and is sensitive to the natural and cultural environment.
The Project will be sensitive to the natural and cultural environment, as discussed above, and will
promote an efficient economy due to the compatibility with existing land use in the area.
Policy ED1.7: Require that future industrial and commercial development be adequately
screened from public view.
The Project is not expected to substantially alter the visual quality in the area due to the
significant existing energy infrastructure. The solar panels will introduce new features into
the visual landscape; however, they are low profile and consistent with the existing solar
farms and infrastructure in the immediate vicinity including PVNGS. In addition, the solar
panels will not be visible for long distances due to the relatively flat nature of the Project
area.
Other Pertinent Information as Requested by the Maricopa County Planning
Department
At this time, no additional information has been requested by the Maricopa County Planning
Department.
Sun Pond III Solar Project
IND-2 (Industrial) Zone Change and
Industrial Unit Plan of Development (IND-2 IUPD)
Narrative Report
NEC of 351st Avenue and Baseline Road in the Tonopah area
Z2023026
Submitted to:
Maricopa County
Planning and Development Department
July 2023
RECEIVED 19.JUL 23
Z2023026
Z2023026
1
TABLE OF CONTENTS
1.0
Introduction ................................................................................................................................................... 3
1.1
Project Name .................................................................................................................................................... 3
1.2
Applicant ........................................................................................................................................................... 3
2.0
Purpose of Request ....................................................................................................................................... 3
2.1
Industrial Unit Plan of Development ................................................................................................................ 4
2.1.1 Justifications for Proposed Zoning District Standards ....................................................................................... 6
3.0
Description of Proposal ................................................................................................................................. 8
3.1
Overview ........................................................................................................................................................... 8
3.2
The Solar Field .................................................................................................................................................. 8
3.3
Electrical Collection System ................................................................................................................................ 9
3.4
Interconnection Facilities ................................................................................................................................... 9
3.5
Landscaping .................................................................................................................................................... 10
3.6
Operation and Maintenance .......................................................................................................................... 10
3.6.1
Site Security and Lighting ........................................................................................................................... 11
3.6.2
Weed Management .................................................................................................................................... 11
4.0
Relationship to Surrounding Properties ...................................................................................................... 12
5.0
Location and Accessibility............................................................................................................................ 12
6.0
Circulation System ....................................................................................................................................... 13
7.0
Development Schedule ............................................................................................................................... 13
7.1
Phasing Schedule ............................................................................................................................................ 13
8.0
Community Facilities and Services ............................................................................................................... 14
8.1
Emergency Response Plan ............................................................................................................................. 14
9.0
Public Utilities and Services ......................................................................................................................... 14
9.1
Fire Protection ................................................................................................................................................ 14
9.2
Police Protection ............................................................................................................................................ 15
9.3
Water and Wastewater Resources................................................................................................................. 15
9.4
Electric ............................................................................................................................................................ 15
10.0
Drainage and Grading .................................................................................................................................. 15
10.1
Drainage Design ............................................................................................................................................. 15
10.2
Grading Design ................................................................................................................................................ 16
11.0
Environmental Impacts ................................................................................................................................ 16
11.1
Noise ............................................................................................................................................................... 16
11.2
Air Quality ...................................................................................................................................................... 17
11.3
Visual Resources ............................................................................................................................................. 17
11.4
Biological Resources ....................................................................................................................................... 17
2
FIGURES
Figure 1: Project Location
3
1.0
Introduction
1.1
Project Name
The name of the project is the Sun Pond III Solar Project, hereafter referred to as Sun Pond III
or the Project in this narrative report.
1.2
Applicant
The Applicant is LSH Land Holdings, LLC, a wholly owned subsidiary of Longroad Energy,
LLC. Longroad Energy, LLC is a US-based developer, owner, and operator of renewable
energy projects, and is led by a team of industry veterans with a demonstrated track record of
success while working together for more than 15 years. Longroad owns and operates 20 solar
projects in the state of Arizona including large rooftop, canopy, and ground-mount systems.
In 2021, Longroad successfully completed construction of the 150-megawatt (MW) Sun
Streams 2 Solar Project in Maricopa County. In October 2022, Longroad began construction
on the 215-MW solar and storage Sun Streams 3 Project. Longroad has a development
pipeline in excess of 5,000 MW and, through a subsidiary, is contracted to operate and
manage a wind and solar operating portfolio of over 3,500 MW. During its time together, the
Longroad team has successfully developed over 60 utility-scale wind and solar projects
totaling roughly 6,300 MW. Longroad is owned and funded by the New Zealand
Superannuation Fund (“NZSF”), Infratil, Longroad’s Management Team, and MEAG, and
currently has over $35 billion in assets under management.
2.0
Purpose of Request
The Project is located on State Trust Land managed by ASLD in unincorporated, western
Maricopa County in the vicinity of the Palo Verde Nuclear Generating Station (PVNGS). The
Project site is located west of South 349th Avenue, south of Vineyard Road, between Baseline
Road and east of South 351st Avenue about four miles northwest of the community of
Arlington (Figure 1). This site is near significant existing power generation projects and energy
infrastructure in the vicinity of the PVNGS including several approved and existing solar
projects.
The Applicant requests to rezone approximately 80 acres of State Trust Land from rural zoning
(RU-43) to Industrial (IND-2), with an Industrial Unit Plan of Development (IUPD), to allow the
development of a photovoltaic (PV) solar energy generating facility.
Concurrently with the submittal of this zone change application, the Applicant is also filing a
General Comprehensive Plan Amendment (CPA) to redesignate the Sun Pond III site to a plan
designation suitable for solar development. This CPA will change the land use designation
under the Tonopah/Arlington Area Plan from Rural Densities to Utilities for the approximately
80-acre Project site.
The Project will consist of arrays of PV panels that absorb sunlight and directly produce
4
electricity. PV panels produce electricity without the use of heat transfer fluid or cooling water.
The Applicant’s goal is to produce up to 10 MW of clean solar power from Sun Pond III.
The Applicant’s plan for timing of the Project is to construct it immediately once the requisite
permits and approvals have been received from Maricopa County. This rezoning application
as well as the corresponding CPA are the first steps in preparing this Project site for
development. The Applicant will develop this Project in response to market demand and could
exceed the noted level of power generation output from this site if possible.
2.1
Industrial Unit Plan of Development
To develop the Project as planned, the Applicant will be seeking modifications from county
development standards using the overlay zoning district IUPD mechanism. According to the
Maricopa County Zoning Ordinance, the purpose of the IUPD is to allow variations to
development standards for industrial projects that require special design techniques or
flexibility due to topography, innovative or sustainable project design, or other considerations.
The majority of these modifications are related to the remote nature of this site and accommodating
solar arrays that maximize the efficiency of the site's solar power capacity while also providing for the
maintenance of natural drainage corridors. As a result, the Applicant is seeking to confirm that none of
the mile or half-mile street alignments will be developed through the site and, therefore, typical street
development standards including setbacks, improved landscaping, fencing and site visibility triangles
(SVTs) are necessary at the site. The Applicant is also requesting a deviation from the lot coverage
calculations to exclude solar arrays because they are mobile and have negligible ground disturbance
associated with them. The specific modifications of county development standards are set forth in Table
1 below and justifications for the modifications are discussed in Section 2.1.1.
5
Table 1 – Sun Pond III Solar Project IUPD Modifications to
Development Standards
Regulation*
BASE IND-2 Zoning District
Standards
Proposed
IND-2
IUPD
Zoning District Standards
Height
40’
40’
Front Yard
10’-15’**-20’***-25’*
0’
Side Yard
3-10’*
0’
Rear Yard
0-25’*
0’
Average
Perimeter
Setback
N/A
20’
Parking
Article 1102.1.5: 1 space per 600 sq.
ft. of floor area.
No required parking
Loading and Unloading
Article 1103.2 one loading and
unloading space for each 10,000
square feet of floor area, or fraction
thereof, devoted to such use in the
building.
None.
Maximum lot coverage
60%
60%
Solar panels not counted as
lot coverage.
Sight Visibility Triangles
(SVTs)
No obstructions over 2’ in height
within 25’ x 25’ SVTs.
Within
sight
visibility
triangles at any intersection
on site chain link fences
without screening materials
can exceed a height of 2’.
Additional Regulations
Article 902.9.1. All uses except for
parking,
loading,
unloading
or
storage shall be conducted within a
completely enclosed building.
A waiver is requested from
this regulation. Solar arrays
will not be located inside
enclosed buildings.
Paving
Article 1102.7.1. For other than one
single-family dwelling unit or one
mobile home on a lot of record, any
parking area must be paved or in the
alternative
surfaced
with
ABC
material.
Alternative
surfacing
materials
or
methods
approved
by
Maricopa
County
Air
Quality
to
minimize dust pollution may
be used in driveways and
parking areas.
Site
Enclosure
and
Screening
Minimum 6’ CMU wall adjacent to
rural
and
residential
zoning
boundaries and for outdoor use of an
industrial nature.
Minimum 6’ tall chain link
fences
adjacent
to
rural/residential
zoning
boundaries,
including
attached barbed wire or
concertina wire under 8’ in
height, and allow all gates to
have no attached screening.
* Adjacent to Rural/Residential zoned properties.
** Along Collector/Mid-Section Line roadways
***Along Arterials/Section Line roadways
6
2.1.1 Justifications for Proposed Zoning District Standards
The following standards for interior lot lines are requested to provide for the transition of uses
within the Project area, and in lieu of typical setbacks, an average perimeter setback of 20
feet is provided. In addition, future right-of-way reservations proposed by the Maricopa County
Department of Transportation (MCDOT) will serve as a setback. Preliminary coordination with
MCDOT has indicated that 55-foot preservation easements will be required along the northern
boundary along Southern Avenue; along the southern boundary along Baseline Road; and a
55-foot preservation easement along the western boundary along 351th Avenue. This
perimeter setback and right-of-way reservations will ensure compatibility and sufficient
distance from adjacent uses, outside of the Project area.
Front Yard
The Applicant requests a modification for all front yard setbacks to be zero feet. The inclusion
of yard setbacks will reduce the amount of energy production available from the Project site.
The removal of setbacks in the Project area is reasonable given the remote nature of the site
as well as the suitability of surrounding land uses. In addition, the solar equipment on the site
will be setback from the perimeter fence to accommodate a perimeter road on the site. The
Applicant requests the setback requirements be waived to allow fencing, vegetative buffers
(landscaping), driveways, signage, or other improvements, excluding buildings or solar
generation and energy storage equipment, within the yard setback areas. Fencing, vegetation,
landscaping, driveways, and signage are allowed in required yards.
Side Yard
The Applicant requests a modification for all side yard setbacks to be zero feet. The inclusion
of yard setbacks will reduce the amount of energy production available from the Project site.
The removal of setbacks in the Project area is reasonable given the remote nature of the site
as well as the suitability of surrounding land uses. In addition, the solar equipment on the site
will be setback from the perimeter fence to accommodate a perimeter road on the site. The
Applicant requests the setback requirements be waived to allow fencing, vegetative buffers
(landscaping), driveways, signage, or other improvements, excluding buildings or solar
generation and energy storage equipment, within the yard setback areas. Fencing, vegetation,
landscaping, driveways, and signage are allowed in required yards.
Rear Yard
The Applicant requests a modification for all rear yard setbacks to be zero feet. The inclusion
of yard setbacks will reduce the amount of energy production available from the Project site.
The removal of setbacks in the Project area is reasonable given the remote nature of the site
as well as the suitability of surrounding land uses. In addition, the solar equipment on the site
will be setback from the perimeter fence to accommodate a perimeter road on the site. The
Applicant requests the setback requirements be waived to allow fencing, vegetative buffers
(landscaping), driveways, signage, or other improvements, excluding buildings or solar
generation and energy storage equipment, within the yard setback areas. Fencing, vegetation,
landscaping, driveways, and signage are allowed in required yards.
Lot Coverage
7
The Applicant proposes that solar panel coverage is not included when calculating the IND-2
required 60% maximum lot coverage. Consistent with Article 1206.3.2, “lot coverage”, only
buildings and other permanent structures will count toward the coverage ratio. PV arrays are
not calculated into Lot Coverage.
Parking Regulations
The Applicant requests that no parking spaces be required for this site. No occupied structures
are anticipated at the facility and the Project will require few regular vehicle trips once
constructed. The Project may include unmanned structures to house components of the
energy storage system. Routine parking of vehicles on site is not anticipated, and no
permanent parking spaces are planned for this site.
Loading and Unloading
The Applicant requests that no loading and unloading spaces be required for the site as no
occupied structures are anticipated at the facility, no manned Project buildings will be located
on site or on public roads, and there will be no routine deliveries or shipments.
Sight Visibility Triangles
The Applicant is requesting to allow chain link fences over two feet in height inside a sight
visibility triangle because these types of fences do not obstruct vehicular visibility. Additionally,
allowing this will maximize the amount of usable space for solar generation.
Additional Regulations
The Applicant requests that the regulation requiring all uses except for parking, loading,
unloading, or storage to be conducted within an enclosed building be waived. The majority of
the site is planned for solar arrays which will not be located within enclosed buildings, as they
are required to be outdoors in order to generate energy.
Paving
The Applicant requests that alternative surfacing materials or methods approved by Maricopa
County Air Quality may be used in driveways and parking areas. The adjacent roadways providing
access to the Project site are unpaved dirt roads. Unpaved roads on the Project will be maintained
to reduce fugitive dust in accordance with the County air quality regulations.
Site Enclosure and Screening
The Applicant requests to install chain-link fencing (at least six feet in height) including
concertina or barbed wire topping (up to two feet) above the fence, where this is prohibited,
and gates along the perimeter of the Project. This fencing will not include any screening
material such as slats or privacy fabric. The proposed fencing will allow unimpeded surface
flows, be consistent with other industrial development in the area, and provide site security.
Screening material will only make the site more visible and should, therefore, be waived as a
requirement to compensate for the large amounts of perimeter fencing on the site. The
Applicant proposes to use chain link for the gates also which will be consistent with other
adjacent and nearby energy generation projects. Perimeter fencing will include small gaps at
the bottom (6”-8”) to allow for the movement of small wildlife. These gaps will be located in
8
areas where drainage features intersect with the Project perimeter to compensate for large
amounts of perimeter fencing on the site.
3.0
Description of Proposal
3.1
Overview
To allow the development of the Project, this zone change application includes the following:
•
Solar field of PV modules mounted on a single-axis tracking system, along with
supporting weather monitoring equipment;
•
Electrical collection systems, including PV combining switchgear, power conversion
stations, inverters, transformers, and collection lines;
•
A possible onsite substation, if needed;
•
An operation and maintenance (O&M) building, including a microwave tower (not
exceeding 120 feet above grade, in compliance with Section 1202.3.1.2 of the Maricopa
County Zoning Ordinance) for transmission of live Project data to remote monitoring
locations;
•
Multiple maintenance/laydown areas; and,
•
Associated civil infrastructure including fencing, access driveways and gates, driveways,
onsite parking, drainage channels, retention basins, signage, and possibly a septic tank
and leach field.
See the attached set of site plan drawings for details regarding the Project components.
3.2
The Solar Field
The solar field will consist of PV modules mounted on a single axis tracking rack system
supported by driven posts, driven concrete piles, ground screws and/or concrete ballasts. The
typical height of the PV modules, when mounted on the racks, will be approximately eight feet.
The maximum height at full rotation will be approximately 14 feet. The height will also vary
because the rack bases will be allowed to follow the natural contours of the ground to a limited
extent. This reduces the need for grading on the site while allowing a uniform presentation of
the panels to the sun.
To ensure optimal solar energy capture, the single-axis tracking system will rotate to follow
the sun throughout the day. The panel rows will be oriented north-to-south and rotate east-to-
west during the day. As the panels rotate, their height changes with the 14-foot height
measured from the maximum point of rotation. The rotation of the panels will be extremely
slow, and essentially noiseless.
Weather monitoring equipment will be installed in appropriately spaced locations to collect
critical data for solar plant operation. Stations include electronic instrumentation and
transmission antennas for remote reporting and will be about the size of a traffic signal box
with the antennas up to 25 feet tall.
9
The site plan depicts where the solar array field will be located on the Project site. The drainage
crossing the northeast corner of the Project site will be left undeveloped as part of the Project.
3.3
Electrical Collection System
The panels will be organized into approximately 1-5 MW groups referred to as Array Blocks.
The Array Block defines the system used to efficiently collect the electricity being generated
by each of the panels. A typical 1-5 MW Array Block can be up to 25 acres in size and include
more than 20,000 PV panels. The exact number of panels to be included in each Array Block
is not known at this time, as the specific PV panel to be utilized has not yet been selected.
Each panel, including its rack and rotational hardware, is referred to as a Row.
The varying sizes of the Array Blocks will allow for the site to be utilized in a manner that
optimizes the site’s power generation capability. Installing the PV panels at a consistent
height, the north-to-south orientation of all Rows on the site, and the application of consistent
perimeter setback standards will ensure that the appearance of all Array Blocks is generally
uniform and consistent from the site's perimeter.
Near the center of each Array Block will be a power conversion station (PCS) or its equivalent,
consisting of up to two static power inverters, one inverter step-up transformer, cabling
systems, and grounding systems. The PCS could be installed within prefabricated metal or
pre-cast concrete enclosures or have no enclosures. The electrical equipment within the PCS
prepares the solar power to be interconnected to the electrical grid. The inverters convert the
low-voltage direct current (DC) electricity generated by the panels to alternating current (AC)
electricity. The inverter step-up transformer then steps up the voltage of the AC electricity to
medium voltage (i.e., 34.5 kilovolts [kV]). The PCS locations will be less than nine feet tall and
generally not be visible from the site perimeters. If the Applicant decides to utilize shade
structures instead of enclosures for its PCS sites, the shade structures will be a maximum
height of 14 feet.
From each PCS, the electricity will be routed through underground or overhead cabling to a
collection substation where the voltage of the AC electricity will be further stepped up by a
power transformer for delivery to the electrical grid (see Section 3.5, below).
3.4
Interconnection Facilities
Once the power is generated and converted, it will need to interconnect into the regional power
grid. The Project is located in an area with extensive electrical infrastructure and expects to
interconnect into Hassayampa Switchyard. The Project will route electricity via either overhead
or underground medium-voltage (34.5 kV) lines to a collection substation located proximate to
the grid interconnection location (expected to be the Hassayampa Switchyard), where the
voltage will be stepped up again to match the regional power grid.
The medium-voltage lines will be outside the jurisdiction of the Arizona Corporation
10
Commission (ACC) as they regulate lines of 115 kV or more. Lines of lesser voltage may be
constructed by right up to a height of 120 feet per Maricopa County Zoning Ordinance Article
1111.7. Offsite transmission lines, unless constructed by an Arizona utility holding a Certificate
of Convenience and Necessity issued by the ACC, are not exempt from local jurisdiction
construction code authority.
3.5
Landscaping
The Project will maintain the natural desert vegetation along the site perimeter and fencing
will be chain link. The Project is extremely isolated and, therefore, mostly not visible to
passersby. In addition, because this area is so dry, non-natural landscaping will draw attention
and make the site more visible.
Solar panels will be set back from the property lines along the Project perimeter. The fences
themselves will be chain link topped with barbed wire making them as visually porous as
possible.
Therefore, any passersby will see natural desert and the low-height panels. The drainage
basins on site may be partially bermed on their downstream side to a height as much as four
feet also further screening visual impact.
See the attached site plans for the location of perimeter setbacks to be provided.
3.6
Operation and Maintenance
When operational, the Project will be remotely monitored and controlled by the Applicant.
There may be a small administrative/O&M facility in the Sun Pond II site. There will be up to
four full-time employees employed during the operational phase of the Project. These
employees will work normal shift hours (generally 8 a.m. to 5 p.m.).
PV solar energy generating facilities require a limited amount of maintenance. Maintenance
activities include but are not limited to the following:
•
Periodic inspections;
•
Cleaning PV Modules;
•
Dust control;
•
Weed control;
•
Maintaining electrical collection system components (inverters, switchgear,
transformers, and ESS); and,
•
Maintaining onsite infrastructure (driveways, drainage channels and retention basins),
as well as responding to issues detected by remote monitoring of the facility.
The only maintenance activities that could require regular water use are the potential cleaning
of PV modules and controlling dust. As noted above, to allow the modules to function
continuously through daylight hours, some maintenance, including some panel cleaning, if
11
needed, may be performed at night. When nighttime maintenance activities are needed,
directed lighting will be used. Water use for panel cleaning purposes will be minimal.
No major equipment is anticipated to be required for maintenance of the facility except as
necessary for periodic equipment replacement. Because the driveways providing access to
the site from local paved roads will also be paved, these surfaces will not require re-grading.
Interior roadways providing access to the solar array field will not be paved. The majority of
interior driveways will be native compacted soil and may require minor grading from time to
time. Interior roads will be maintained to reduce fugitive dust.
3.6.1 Site Security and Lighting
To provide a secure and safe environment, lands will be enclosed by an open chain-link fence
topped with barbed wire and all access points will be gated with swinging or rolling chain-link
gates topped with barbed wire for a total of eight feet. The fence and gates will include a
minimum of six feet of chain link topped with up to two feet of barbed wire, for a total of eight
feet after barbed wire. The Applicant plans to use open chain-link fencing to maintain a secure
but visually open appearance. Substations will be separately fenced as well with the same
type of fencing. The fence height may change if requested by county officials for drainage
purposes at the base of portions of the fence.
For nighttime security, the Project may use motion-activated lights or infrared (IR) illumination
with cameras mounted on 18-foot-tall poles. Because these security lights will be motion-
activated or IR illuminated only, the Applicant expects the site to be dark at night. The motion
detectors on the security lighting system will not react to animal movement. Furthermore, to
ensure that lighting will not be cast onto neighboring properties, all security lighting installed
will be directed downward and into the site. All onsite lighting will also comply with Maricopa
County Zoning Ordinance Article 1112.
Additional security measures that may be implemented include cameras to remotely monitor
the site and periodic patrols of the site's perimeter.
3.6.2 Weed Management
Following initial mowing of the site, vegetation will be allowed to reestablish to the extent it
does not interfere with equipment or facility O&M. The Applicant may need to use weed control
to ensure the equipment and retention areas continue to function. Herbicides will be used as
needed on a periodic basis and applied by licensed or certified applicators. Hand removal or
mechanical methods (i.e., small drivable weed mowers) of weed control could also be used to
where necessary and practical.
Because weeds can create a fire safety hazard, the presence of weeds (especially
tumbleweed) on the site will be regularly monitored and managed throughout the life of the
Project.
12
4.0
Relationship to Surrounding Properties
The development of a PV solar facility at this location is an appropriate and compatible land
use. The area is very rural with minimal nearby population in pockets of low-density rural
residential. The nearby existing and approved developed uses are primarily industrial and
specifically electrical infrastructure. The predominant land use in the area is energy production
and electrical transmission. As previously noted, the PVNGS, the largest nuclear power plant
in the United States, as well as several existing gas-fired and solar energy facilities are located
nearby.
Several of the existing and approved local power plants and associated high-voltage
transmission lines near the Project are labelled on Figure 1. The Hassayampa Switchyard is
a major energy transfer facility located just over two miles southwest of the site. The Applicant
already has connection agreements into the Hassayampa Switchyard through the existing
Applicant-owned Sun Streams complex.
Indicative of the appropriateness for the proposed use in this area, several rezonings, Special
Use Permits, and CPA applications have been previously approved by the Maricopa County
Board of Supervisors for solar energy generating facilities nearby. These solar energy facilities
include Sun Streams I, Sun Streams II, the Sun Streams Expansion, Mesquite Solar, Arlington
Valley Solar Energy (AVSE) II and III, Hassayampa I Solar and the AV Solar Project. The
addition of a solar power facility like this Project complements those existing land uses. The
proposed Project, when developed, will have a relatively low profile, will be noiseless and
odorless, and will have very little nighttime lighting or activity.
Arizona is the natural solar center of the United States. Factors critical to the siting of PV solar
energy generating facilities include large, contiguous areas of flat or nearly flat land; proximity
to existing electrical substations and transmission infrastructure; and compatibility with nearby
land uses. This site meets each of these criteria. Since the site is located in proximity to
existing electrical substations and transmission infrastructure, it has immediate access to the
Hassayampa Switchyard, limiting the need for extensive offsite overhead transmission
facilities.
Solar energy diversifies the energy supply, reduces the country's dependence on foreign oil,
improves air quality, offsets greenhouse gas emissions, and helps avoid the construction of
additional fossil-fuel-powered plants. In warm climates like Arizona, solar energy is also
beneficial for satisfying peak energy demands as solar energy is generated when the demand
for electricity is at its peak (during daylight hours). In addition to the environmental benefits,
construction of a facility of this magnitude stimulates the local economy by creating
construction jobs during installation and by generating fee and tax revenue for Maricopa
County.
5.0
Location and Accessibility
The Project is located on approximately 80 acres of State Trust Land managed by the ASLD,
13
west of 349th Avenue, south of Vineyard Road, between Baseline Road and east of South
351st Avenue about four miles northwest of the community of Arlington. Figure 1 depicts the
location and boundaries of the Project site.
Access to the Project will be via existing roads. Primary access is anticipated to be provided
via Baseline Road and regional access to the Project will be via Salome Highway and
Interstate 10 (I-10). The Project is not expected to require development or improvement of
roads in the Project vicinity.
Construction activity will generate trips for a limited duration. This traffic will be associated
with worker trips and the delivery of construction materials to the site, which will occur during
on-peak and off-peak hours. Project construction will require the delivery of materials from I-
10 and Salome Highway that will add approximately 20 semi-trucks per day to current traffic
levels. At its peak, Project construction is anticipated to require a workforce of up to 400. The
construction workforce may add approximately 300 vehicles per day to local roads. Due to
the distance workers may travel, this number anticipates some rate of carpooling by the
construction workforce. The mobilization and demobilization of equipment used for earthwork,
including scrapers, graders, water wagons, compactors, truck-mounted post drivers, skid
loaders, and forklifts, is anticipated to generate a minimal amount of traffic. The onsite parking
and staging yards for the Project will be located in the vicinity of the primary site access.
The Applicant will maintain its commitment to minimizing the impact of construction traffic
impacts on the Arlington Elementary School and the residences in the Project area. The
Applicant will meet with Arlington Elementary School District officials in advance of
construction to discuss traffic safety. Traffic trips generated during operations will be from up
to four full-time employees and the occasional delivery of materials and supplies.
6.0
Circulation System
Because of the nature of the proposed solar project development, no formal traffic circulation
or coordinated street system will be needed to support the Project. As stated above, access
to the site will be via a number of access driveways from the existing streets and roads that
abut the perimeter of the site. The proposed locations of these access points will be shown on
the Plan of Development site plan.
Inside the Project site, access to Project facilities will be provided via perimeter roads and
access ways between the solar arrays. These will be shown on the Plan of Development site
plan. These Project roads will be unpaved and maintained to reduce fugitive dust.
7.0
Development Schedule
7.1
Phasing Schedule
The Applicant will construct the Project in response to market demand. The timing of
construction of the Project or phases (if applicable) will ultimately depend on market conditions
and the timeline of Project approvals. Regardless of timing and phasing, all construction will
14
be subject to county oversight.
The Applicant is aware that county drainage regulations require that the drainage of the overall
site or any interim phase functions in an acceptable manner regardless of phasing. The
Applicant acknowledges that this may require the development of interim drainage facilities in
earlier construction phases. Each phase of development will be constructed with the requisite
drainage controls to manage the respective onsite and offsite stormwater runoff in accordance
with county design guidelines.
Temporary facilities, such as office trailers, laydown yards, containers, construction
warehousing buildings up to 40 feet in height, parking areas and equipment storage areas will
be required from move-on to completion of construction. The Applicant currently plans to
locate its temporary facilities along Southern Avenue near existing street access. Temporary
facilities will be removed upon the completion of construction.
Up to 400 construction workers will be employed during construction and this workforce will
vary with phases of construction. Once temporary construction uses are complete, the
Applicant may choose to develop additional solar panels on these lands. As previously
indicated, the Applicant will coordinate construction traffic management with the Arlington
Elementary School District.
8.0
Community Facilities and Services
During operations, the Project will have no impact on community facilities and services such
as schools and parks, as the Project is anticipated to only require a minimal number of full-
time employees.
8.1
Emergency Response Plan
The Applicant has prepared an Emergency Response plan for the existing Sun Streams
projects and will update that plan to cover this Project. The plan specifies notification,
assembly, accountability, and evacuation planning in the event of an emergency at the
PVNGS, as the site is located within the 10-mile Plume Exposure Pathway Emergency
Planning Zone (EPZ) for PVNGS.
9.0
Public Utilities and Services
9.1
Fire Protection
Fire response services for the area are provided by the Arizona Fire and Medical Authority
(AFMA). AFMA handles emergencies closer to Tonopah, located approximately nine miles
northwest of the site. Onsite driveways will provide egress for emergency and fire department
access. However, the anticipated level of fire protection needed for the site is very minimal,
as PV modules are constructed of non-combustible materials (glass and steel) and the
electricity generation process does not involve combustible fuel, high temperature, or high
15
pressure.
9.2
Police Protection
The Maricopa County Sheriff’s Office, operating out of one main station in Avondale and a
satellite station in Buckeye, provides protective services for the area. The Project site is
located within the District II patrol area and the nearest police substation is located at 920 E.
Van Buren Avenue in Avondale.
9.3
Water and Wastewater Resources
The Project will not impose any new water and wastewater requirements on the area. The site
is located within an Arizona Department of Water Resources (ADWR) regulated Active
Management Area (AMA). The need for water on the site during operations will be minimal,
necessary only for the needs of employees and intermittent cleaning of the solar panels. Water
for construction purposes will be delivered to the site. Portable toilets will be used during
construction.
As indicated above, during operations there could be up to four full-time employees on the
site. The potable water needs of four employees will be provided via bottled water or from
ADWR-exempt wells. The water needed to clean the panels is expected to be minimal as
cleaning occurs infrequently. This insignificant amount of water use does not require a Public
Water System.
The wastewater generated at the facility during operations is anticipated to be treated with
onsite wastewater treatment facilities, such as a conventional septic tank system or similar
alternative system as regulated by Arizona Department of Environmental Quality and
administered by Maricopa County Environmental Services Department. Alternatively, it is
possible that portable toilets could be used during operations.
9.4
Electric
Arizona Public Service (APS) is the electrical service provider for this area. The Applicant will
coordinate with electrical service providers in the area as needed throughout the construction
and operation of the Project.
10.0 Drainage and Grading
10.1 Drainage Design
A Preliminary Drainage Report was prepared to provide hydrologic analysis for the Project
and identify potential constraints as well as preliminary conveyance and retention design on
the Project site (Exhibit A). Storm water runoff generally flows from the northwest to southeast
across the site. Flow leaving the site exits as both shallow sheet flow and concentrated flow
through a series of small drainages. The entire Project site is located within Federal
Emergency Management Agency (FEMA) Zone X Flood Hazard Area.
16
No floodplains are present on the Project site, and the Applicant currently does not intend to
construct Array Blocks within any major drainages. This will allow wildlife movement through
the area and help maintain existing habitat and natural drainage. The Applicant will also
coordinate with the U.S. Army Corps of Engineers in the unlikely case that there is limited
construction within any jurisdictional waterways determined to be located on site. In addition,
any portion of a fence to be constructed within drainage areas will be designed with adequate
openings to maintain historic flow patterns.
Unlike a typical development, a PV project results in only a small portion of the site being
impervious. Any buildings, electrical equipment and paved driveways will create impervious
areas, but the solar field does not because the modules are elevated above the ground. While
the Project intends to cover much of the site with PV modules, the supports on which the
modules are mounted will cover considerably less than five percent of the site. Precipitation
on the modules themselves simply drains off their edges onto the ground below. As a result,
nearly full access to the ground surface will be retained.
Developed areas within Maricopa County are required to regulate stormwater discharge such
that net flow rates and flow volume exiting from the site are equal to or less than the pre-
development rate. This is often controlled through the construction of retention basins.
Generally, the Applicant will be constructing channels, retention basins and berms throughout
the site to manage stormwater such that flows are not increased as a result of development
while also maintaining historical drainage patterns.
10.2 Grading Design
Unlike a typical project, where a site is mass graded at the start of construction, the Applicant
plans to minimize the amount of earthwork required for this Project. The main areas that will
be graded are the retention basins and ancillary drainage controls for stormwater conveyance.
In order to minimize the amount of disturbance, most of the site will be cleared and/or mowed
only where needed. If required, select areas of the site may be disced and rolled. As shown
in the grading plan included in the attached site plan, grading will generally maintain the site's
existing topography. Grading activities will not involve significant dredging or filling within
major washes or any potential jurisdictional waterways determined to be located on site. As
detailed above, the Applicant is prepared to address appropriate permitting requirements of
both the FCD and U.S. Army Corps of Engineers, as necessary. The Grading and Drainage
Plan is attached as Exhibit B.
11.0 Environmental Impacts
11.1 Noise
When the Project is fully operational, it is not anticipated that there will be any regular activities
on the site that will result in discernable offsite noise. The use of equipment for performing
earthwork and installation of facilities could temporarily produce noise that is noticeable offsite
17
during construction. Due to the remote location of the Project and presence of existing energy
infrastructure in the area, the Project will have minimal impacts related to noise.
11.2 Air Quality
The Applicant will use construction dust control measures as required by Maricopa County to
limit fugitive dust emissions from the site. Details of the construction dust control plan will be
submitted and approved under a separate permit through the Maricopa County Environmental
Services Department. Dust control measures will be supported in part by minimizing the areas
requiring ground disturbance and applying water as necessary. The Project will not produce
any noticeable odors.
11.3 Visual Resources
The Project is not expected to significantly affect the visual quality of the area because it is
located in an area with considerable existing energy generation facilities present, is on
relatively flat desert land, will have a low profile on the landscape, is several miles from the
nearest population center, and is located in an area that does not provide recreational
opportunities or attract public attention. The visually dominant features of the area are the
existing PVNGS, the natural-gas-fired power plants, solar projects, and transmission lines. In
addition to the relatively low-height profile of the Project, the PV panels, which absorb sunlight,
will not cause substantial glare.
11.4 Biological Resources
Information was obtained from both the U.S. Fish and Wildlife Service and the Arizona Game
and Fish Department (AGFD) regarding the potential occurrence of special-status species
within the Project area. The Project is sited outside of areas designated for environmental
resource conservation, such as Areas of Critical Environmental Concern, Important Bird
Areas, National Wildlife Refuges, Wilderness Areas, important migratory pathways, or
stopover sites or other specially designated areas. The Project is co-located with existing
energy infrastructure in an industrial location, and does not contain designated critical habitats
for protected species or wetlands. There are sensitive species with the potential to occur in
the Project area; however, potential impacts to sensitive species will be minimized by
implementation of prevention, minimization and mitigation measures.
MCDOT -- TRAFFIC ENGINEERING
REVIEW COMMENT SHEET
1 of 1
Project Name: Sun Pond 3 - Solar Project
Location: NEC Baseline Rd. & 351st Ave.
MCDOT File No.: Z2023026
Date: 08/17/2023
Reviewer: Amber Cauble
Phone No.: (602) 319-9083
Consultant: HilgartWilson
Project No.: 2479
Plans Sealed By: Peter Gaido, PE
Consultant Code:
A = Will Comply
B = Deleted
C = Consultant to Evaluate
Item
Number
Page
Number
Comments
Consultant
Reply
= = =
1
= = =
General
3rd REVIEW (TS)
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 Sun Ponds 3 Solar Project is comprised of 1 parcel,
encompassing approximately 80 acres.
Per the TS, construction is anticipated to start third-quarter 2023 and continue
for approximately 2-years. During construction the site anticipates 20 semi-
trucks per day with an additional 300 vpd to support a workforce of
approximately 400 people. Upon build out, the development anticipates one
employee on site per day.
The development is proposing one (1) full-access on the north side of
Baseline Rd, approximately 600’ east of the intersection of 351st Ave and
Baseline Rd.
Review Comments:
The future classification of 351st Ave is Minor Arterial. The adjusted ROW
designation has been noted, as per MCDOT Planning provide minimum 55’
ROW relative to the roadway centerline along the site frontage.
MCDOT estimates after construction the proposed site will generate minimal
peak hour trips and have negligible impact on County roads.
The Traffic Statement is Approved.
Signature: _____________________________________ Date: ___________
Use CODE
"A", "B","C"
in this column
next to every
comment.
= = = =
MCDOT -- TRAFFIC ENGINEERING
REVIEW COMMENT SHEET
1 of 2
Project Name: Sun Ponds 3 Solar Project
Location: NEC Baseline Rd. & 351st Ave.
MCDOT File No.: Z2023025
Date: 06/29/2023
Reviewer: Amber Cauble
Phone No.: (602) 319-9083
Consultant: HilgartWilson
Project No.: 2479
Plans Sealed By: Peter Gaido, PE
Consultant Code:
A = Will Comply B = Deleted
C = Consultant to Evaluate
Item
Number
Page
Number
Comments
Consultant
Reply
= = =
1
2
3
= = =
General
General
General
2nd REVIEW (TS)
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 Sun Ponds 3 Solar Project is comprised of 1 parcel,
encompassing approximately 80 acres.
Per the TS, construction is anticipated to start third-quarter 2023 and continue
for approximately 2-years. During construction the site anticipates 20 semi-
trucks per day with an additional 300 vpd to support a workforce of
approximately 400 people. During the operation phase, site 1 anticipates one
employee on site per day.
The development is proposing one (1) full-access on the north side of
Baseline Rd, approximately 600’ east of the intersection of 351st Ave and
Baseline Rd.
General Comments:
REPEAT. The future functional classification of 351st Ave. is Minor Arterial.
Along the site frontage, provide minimum 65’ R/W relative to the roadway
centerline.
REPEAT. This review assumes no mixed-use land practice shall be allowed
on this site. Any mixed-use activities shall require a new traffic statement be
submitted for review and approval.
REPEAT. This review assumes Sun Ponds 3 is part of a three-phase project
including Sun Ponds 1, 2, and 3 and that the construction duration and trip
traffic mentioned in the report is for all three sites. Update the statement to
indicate the total number of phases and distribution of traffic to each
site during construction and operations.
Use CODE
"A", "B","C"
in this column
next to every
comment.
= = = =
TS addresses
only Sun Pond 3,
a single,
independent
development.
Should
construction
coincide with Sun
Pond 1 or Sun
Pond 2, the traffic
volumes would be
added
accordingly.
A - Acknowledged.
No mixed-use land
practices are
proposed.
B - Sun Pond 3 is
independent of Sun
Pond 1 and Sun
Pond 2. Construction
duration and trip
traffic described in
the TS is for Sun
Pond 3.
B - MCDOT has
approved 55' wide
R/W preservation.
Refer to attached
approval notice.
Engineering Division
2901 W. Durango Street
Phoenix, Arizona 85009
P: 602.506.4889
F: 602.506.5969
May 17, 2023
Sun Pond, LLC
330 Congress Street, 6th Floor
Boston, Massachusetts 02210
Delivered via email: contracts@longroadenergy.com
lindsey.kester@longroadenergy.com
bbrockman@hilgartwilson.com
Re: Recommendation of Future MCDOT Right-of-Way
Sun Pond 1-3 - Z2023024, Z2023025, and Z2023026
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 various mid-section and section lines, requiring the setback line be measured from a 40-
foot and a 55-foot future right-of-way, respectively.
Based on geographic constraints, it is recommended that the requirement for future half street rights-of-
way be reduced on specific alignments. The recommended setbacks are contained in the attached ROW
Preservation Exhibits for the Sun Pond 1 Solar Project, the Sun Pond 2 Solar Project, and the Sun Pond 3
Solar Project.
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) 506-4176 or
Angela.Macaluso@maricopa.gov.
Sincerely,
Angela Macaluso
Planning Project Manager
MCDOT Planning Branch
2141 E. HIGHLAND AVE., STE. 250
PHOENIX, AZ 85016
P: 602.490.0535 / F: 602.368.2436
©
Page 1 of 1
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:
August 8, 2023
Memo To: Darren Gerard, AICP, Planning Manager, Department of Planning &
Development
Attn:
Martin Martell. Planner, Planning & Development Services
cc:
Michael Norris P.E., Engineering Manager, Planning and Development
From:
Bob Fedorka, PE, Engineering Supervisor, Planning & Development
Subject:
Z2023026 – Sun Ponds 3 (Utility Scale Solar) – 3rd Submittal
APN(s):
State Land
Engineering Review has reviewed the third drainage plan and report routed for review
on 7/19/2023 and has no objections subject to the following conditions.
1. Detailed Grading and Drainage Plans must be submitted with the application
for Building Permit(s) indicating that runoff from each solar field area will be
directed to a retention basin.
2. Building permit submittals shall include analysis to determine stabilization
requirements for perimeter channels to meet County requirements.
3. Retention and spreader basins shall drain within 36 hours.
4. Prior to issuance of building permits, Owner/Applicant, the Traffic Statement
must be approved by MCDOT’s Traffic Branch.
5. A Solar License is required from MCDOT for any private Utility that will occupy
County R/W (i.e. transmission facilities).
6. Engineering review of planning and/or zoning cases is for conceptual design
only. 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.
7. Based on the conceptual design nature of the information submitted, changes
to the site layout and/or a reduction in the number of solar arrays may be
necessitated by the final engineering design of the site’s drainage
infrastructure.
Please contact me with any questions.
April 6, 2023
Mr. Martin Martell
Maricopa County
Planning and Development Department
301 W Jefferson Street, Suite 170
Phoenix, AZ 85003
Electronically submitted to Martin.Martell@maricopa.gov
RE:
Sun Pond I, II, III Solar Projects
Dear Mr. Martell:
The Arizona Game and Fish Department (Department) appreciates the opportunity to review and
provide comments on the General Comprehensive Plan Amendment (CPA) Applications for the
Sun Pond I, II, and III Solar Projects (Projects). The Department understands that these CPA
applications are to change the land use designation of the Tonopah/Arlington Area Plan from
Rural Residential to Utilities to allow for the proposed development of three installations of a
photovoltaic (PV) solar project on private and Arizona State Land Department (ASLD) land
within Maricopa County. Zone Change with Overlay will also be required for the three projects
in concurrence with the CPAs. The project sites are located within the vicinity of the Palo Verde
Nuclear Generating Station in western Maricopa County, cumulatively totaling approximately
800 acres of undeveloped Sonoran desertscrub 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 to develop renewable energy
locations that contribute to regional and state economic growth needs and would like to work
closely with Longroad Energy, KP Environmental, and Maricopa County during the planning
and development of this economically-important facility. The Department recognizes that
appropriate coordination, proper planning, and voluntary implementation of best management
practices allow projects to be developed that avoid, minimize, or offset potential impacts to
wildlife and recreational access during development and operation of the facilities. For your
AZGFD - Sun Pond Solar Farm
April 6, 2023
Page 2
consideration, the Department provides the following comments based on the agency's statutory
authorities, public trust responsibilities, and special expertise related to wildlife resources and
recreation.
Arizona has recently seen an increase in the number of proposed and in-development renewable
energy generation projects and associated infrastructure. A number of solar projects occur within
a 10-mile radius of the Sun Pond Solar Farm, and although each of these projects individually
may have a minimal impact on the broader landscape, these projects cumulatively could
potentially result in loss of habitat, impact wildlife movements, and affect wildlife-related
recreation. Additionally, long-term effects to wildlife can extend several kilometers beyond the
footprint of a solar project area (Sawyer et al. 2022 ). It is important to consider all potential
1
cumulative effects and to evaluate this project in association with other projects in the area.
Department staff are available to assist in identifying potential cumulative impacts to wildlife
and associated voluntary conservation measures that can be implemented for the project.
The Department recommends conducting surveys in the project area and adjacent lands to
determine species presence. These surveys should be of sufficient duration and intensity to
adequately assess all habitat types and potential species occurrence in and adjacent to the project
area. Department staff are available to assist Longroad Energy in determining survey methods,
appropriate design features, and best management practices that can help minimize potential
impacts. Based on the information provided, the Department offers the following general
recommendations to reduce impacts to wildlife and habitat; additional information can be found
in Guidelines for Solar Development in Arizona :
2
●
The Department recommends a qualified biologist survey for bird species within the
project area to better understand species presence and help identify potential impacts.
Point count surveys, conducted twice a year during the breeding season (mid-January
through June in this area) are the preferred method for surveys; McLaren et al. (2019)3
outlines protocols. The Department also recommends specific surveys for Bendire’s and
LeConte’s thrashers; protocols are outlined in DTWG (2018). Department staff remain
4
available to assist with identifying appropriate conservation measures based on species
presence at the site.
●
The Sonoran desert tortoise, which is an Arizona Species of Greatest Conservation Need,
could occur in the project area. The Department recommends conducting surveys, in
accordance with the Desert Tortoise Survey Guidelines for Environmental Consultants ,
5
to determine the presence of this species or its habitat. If tortoises are identified, please
refer to and implement the Recommended Standard Mitigation Measures for Projects in
5 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/2010SurveyguidelinesForConsultants.pdf
4 https://borderlandsbirds.org/wp-content/uploads/2017/08/Thrasher-Survey-Protocol-2018_DTWG.pdf
3 https://www.birdconservancy.org/wp-content/uploads/2021/03/2020-Field-Protocol-for-Spatially-Balanced-Sampling.pdf
2 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/
FinalSolarGuidelines03122010.pdf
1 https://esajournals.onlinelibrary.wiley.com/doi/10.1002/fee.2498
AZGFD - Sun Pond Solar Farm
April 6, 2023
Page 3
Sonoran Desert Tortoise Habitat and Guidelines for Handling Sonoran Desert Tortoises
6
Encountered on Development Projects .
7
●
The western burrowing owl, a special status species that is regulated under the MBTA,
could occur within the project area. The Department recommends conducting occupancy
surveys for western burrowing owls throughout the project area to determine if this
species occurs within the project footprint. Guidelines for conducting this survey are
found in Burrowing Owl Project Clearance Guidance for Landowners . Please note that
8
the surveys should be conducted by a surveyor who is certified by the Department or has
similar qualifications. If an active burrowing owl burrow is detected, please contact the
Department and the USFWS for direction, in accordance with the guidelines. The
Department recommends conducting surveys in advance of the design phase to
understand distribution of burrowing owls in the project site. The Department would like
the opportunity, based on results of this survey, to work with the developer on actions to
avoid, minimize, or offset potential impacts to existing burrowing owl populations.
●
Burrowing species such as kit foxes could occur within the project area and could be
influenced by loss of habitat and connectivity. Surveys for these species are recommended to
determine presence and to inform pre-construction activities. Department staff are available
to assist in identifying suitable conservation measures, such as one-way exclosures on kit fox
burrows that allow foxes to exit the burrows and disperse to adjacent lands.
●
A variety of other Arizona Species of Greatest Conservation Need have the potential to
occur within the project area. If wildlife are encountered during construction activities,
the Department recommends moving them outside of the construction area, no more than
0.25 mile outside the project boundary within similar habitat. Please note that the Arizona
State Wildlife Action Plan was recently updated, and the Department has an interactive
website, Arizona Wildlife Conservation Strategy , to help navigate and identify
9
conservation opportunities for the most recent list of Species of Greatest Conservation
Need.
Maintaining habitat connectivity is a priority for the Department, and wildlife movement
corridors are important to allow wildlife to respond to changing environmental conditions. It is
the Department’s understanding, based on the narrative report provided by the applicant, that
development will be avoided within the main drainages and ephemeral washes that flow through
the project sites. The Department supports the incorporation of this design feature while also
leaving those washes unfenced and with an appropriate setback from any development to allow
wildlife to utilize the washes as landscape-level movement corridors in the area. Additionally,
the Department recommends that the project site design facilitates wildlife movement through
the project, avoiding “dead end” or “cul-de-sac” features that could inadvertently confuse
animals and result in animals not moving through the project area. Department staff are available
to coordinate with the applicant and Maricopa County to assist in establishing these design
features and additional measures to reduce impacts to connectivity, including the following:
9 https://awcs.azgfd.com
8 https://www.azgfd.com/wildlife/speciesofgreatestconservneed/raptor-management/burrowing-owl-mangement/
7 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/2014%20Tortoise%20handling%20guidelines.pdf
6 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/MitigationMeasures.pdf
AZGFD - Sun Pond Solar Farm
April 6, 2023
Page 4
●
To the extent possible, the Department recommends retaining habitat features underneath
the panels, including vegetation and soils, rather than grading the entire site. The
topography in the majority of the site is flat and would require minimal trimming of
shrubs and existing vegetation to install the panels. Keeping the existing soil and root
structures intact would serve to minimize erosional run-off and help reduce biodiversity
loss within the site (Grodsky and Hernandez 2020 ).
10
●
The Department’s Wildlife Compatible Fencing Guidelines
provide information on how
11
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, such as leaving a 6–8-inch gap
between the ground surface and bottom of the fence to allow for smaller wildlife species
to move freely through the area and make use of any habitat within the project boundary.
Finally, the Department offers the following general recommendations to reduce potential
impacts to wildlife and habitat during construction and operation of the facility:
●
For
the
construction
of
any
generation-tie
transmission
lines
and
associated
infrastructure, 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
12
Collisions with Power Lines: The State of the Art in 2012 . Birds of prey, such as raptors,
13
owls, 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.
●
If proposed ground disturbance (both temporary and permanent) will meet or exceed 0.25
acre in areas with native vegetation, please ensure the project complies with the Arizona
Native Plant Law
. A Native Plant Inventory may need to be conducted to identify,
14
record, and coordinate plant salvage efforts for species that are protected under the
Arizona Native Plant Law. In addition, the applicable land management agencies should
be consulted regarding guidelines for revegetation efforts.
●
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
15
noxious weeds and the Arizona Native Plant Society
for recommendations on how to
16
16 https://aznps.com/invas
15 https://agriculture.az.gov/pestspest-control/agriculture-pests/noxious-weeds
14 https://agriculture.az.gov/plantsproduce/native-plants
13 https://www.aplic.org/uploads/files/15518/Reducing_Avian_Collisions_2012watermarkLR.pdf
12 https://www.aplic.org/uploads/files/2643/SuggestedPractices2006(LR-2).pdf
11https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/110125_AGF
D_fencing_guidelines.pdf
10 https://www.nature.com/articles/s41893-020-0574-x
AZGFD - Sun Pond Solar Farm
April 6, 2023
Page 5
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
17
application for tracking and managing invasive species.
●
If trenching will occur for the proposed project, the Department recommends that
trenching and backfilling crews be close together to minimize the amount of open
trenches at any given time. Where trenches 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 that have
been left open overnight be inspected to remove animals prior to backfilling.
●
The Department recommends revegetating disturbed areas with native drought-tolerant
species that represent the natural surrounding landscape. Landscaping with native plants
can help support wildlife and pollinator species in the area while reducing dust and
erosion.
●
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
18
minimum amount of light needed for safety. If feasible, narrow spectrum lighting is
wildlife-friendly and should be used as often as possible to minimize the number of
species affected by lighting. It is also beneficial that all lighting is shielded, canted, or cut
to minimize the amount of upward shining light.
Thank you for the opportunity to provide input on the Sun Pond Solar Farm Projects. For further
coordination, please contact Tyler Williford at twilliford@azgfd.gov or (928) 341-0047.
Sincerely,
Michael Sumner
Regional Supervisor - Yuma
cc:
A. Tyler Williford, Habitat, Evaluation, and Lands Program Supervisor - Region IV
Teigan Williams, Habitat, Evaluation, and Lands Program Specialist - Region IV
Tiffany Sprague, Project Evaluation Program Renewable Energy Lead
AZGFD #M23-03155721
18 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3657119
17 https://imap.natureserve.org/imap/services/page/map.html
Arizona Environmental Online Review Tool Report
Arizona Game and Fish Department Mission
To conserve Arizona's diverse wildlife resources and manage for safe, compatible outdoor recreation
opportunities for current and future generations.
Project Name:
Sun Pond I, II, III Solar Projects
Project Description:
A proposed new solar project, Sun Pond Solar Farm, consisting of 3 phases on private and ASLD land
totaling approximately ~573 acres, located just east of the Palo Verde Nuclear Generating Station in Maricopa
County.
Project Type:
Energy Storage/Production/Transfer, Energy Production (generation), photovoltaic solar facility (new)
Contact Person:
Teigan Williams
Organization:
Arizona Game and Fish Department
On Behalf Of:
OTHER
Project ID:
HGIS-18714
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_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 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_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 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_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 AM
Page 4 of 11
Arizona Game and Fish Department
project_report_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 AM
Page 5 of 11
Arizona Game and Fish Department
project_report_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 AM
Page 6 of 11
Arizona Game and Fish Department
project_report_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 AM
Page 7 of 11
Arizona Game and Fish Department
project_report_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 AM
Special Status Species Documented within 5 Miles of Project Vicinity
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Cylindropuntia echinocarpa
Golden Cholla
SR
Toxostoma lecontei
LeConte's Thrasher
S
2
Note: Status code definitions can be found at https://www.azgfd.com/wildlife/planning/wildlifeguidelines/statusdefinitions/
.
No Special Areas Detected
No special areas were detected within the project vicinity.
Species of Greatest Conservation Need Predicted that Intersect with Project Footprint as Drawn, based on
Predicted Range Models
Scientific Name
Common Name
FWS
USFS
BLM
NPL
SGCN
Ammospermophilus harrisii
Harris' Antelope Squirrel
Anthus spragueii
Sprague's Pipit
SC
2
Artemisiospiza nevadensis
Sagebrush Sparrow
Asio otus
Long-eared Owl
2
Athene cunicularia hypugaea
Western Burrowing Owl
SC
S
S
2
Auriparus flaviceps
Verdin
2
Botaurus lentiginosus
American Bittern
2
Buteo regalis
Ferruginous Hawk
SC
S
2
Buteo swainsoni
Swainson's Hawk
2
Calcarius ornatus
Chestnut-collared Longspur
2
Calypte costae
Costa's Hummingbird
2
Campylorhynchus brunneicapillus
Cactus Wren
2
Chaetodipus baileyi
Bailey's Pocket Mouse
2
Charadrius montanus
Mountain Plover
SC
2
Chilomeniscus stramineus
Variable Sandsnake
2
Coccyzus americanus
Yellow-billed Cuckoo (Western DPS)
Colaptes chrysoides
Gilded Flicker
S
2
Columbina inca
Inca Dove
2
Corynorhinus townsendii pallescens Pale Townsend's Big-eared Bat
SC
S
S
1
Crotaphytus nebrius
Sonoran Collared Lizard
2
Empidonax wrightii
Gray Flycatcher
2
Eumops perotis californicus
Greater Western Bonneted Bat
Falco mexicanus
Prairie Falcon
2
Falco peregrinus anatum
American Peregrine Falcon
Falco sparverius
American Kestrel
2
Gopherus morafkai
Sonoran Desert Tortoise
CCA
S
S
1
Icterus bullockii
Bullock's Oriole
2
Incilius alvarius
Sonoran Desert Toad
2
Lanius ludovicianus
Loggerhead Shrike
SC
2
Page 8 of 11
Arizona Game and Fish Department
project_report_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 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
Lasiurus blossevillii
Western Red Bat
S
2
Lasiurus xanthinus
Western Yellow Bat
S
2
Lithobates yavapaiensis
Lowland Leopard Frog
SC
S
S
1
Macrotus californicus
California Leaf-nosed Bat
SC
S
2
Megascops kennicottii
Western Screech-owl
Melanerpes uropygialis
Gila Woodpecker
2
Melospiza lincolnii
Lincoln's Sparrow
2
Melozone aberti
Abert's Towhee
S
2
Micrathene whitneyi
Elf Owl
Myotis velifer
Cave Myotis
SC
S
2
Myotis yumanensis
Yuma Myotis
SC
2
Nyctinomops femorosaccus
Pocketed Free-tailed Bat
2
Parabuteo unicinctus
Harris's Hawk
2
Passerculus sandwichensis
Savannah Sparrow
2
Pooecetes gramineus
Vesper Sparrow
2
Spizella breweri
Brewer's Sparrow
2
Tadarida brasiliensis
Brazilian Free-tailed Bat
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
Pecari tajacu
Javelina
Puma concolor
Mountain Lion
Zenaida asiatica
White-winged Dove
Zenaida macroura
Mourning Dove
Project Type: Energy Storage/Production/Transfer, Energy Production (generation), photovoltaic solar facility
(new)
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/.
Page 9 of 11
Arizona Game and Fish Department
project_report_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 AM
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.
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.
For any powerlines built, proper design and construction of the transmission line is necessary to prevent or minimize risk
of electrocution of raptors, owls, vultures, and golden or bald eagles, which are protected under state and federal laws.
Limit project activities during the breeding season for birds, generally March through late August, depending on species
in the local area (raptors breed in early February through May). Conduct avian surveys to determine bird species that
may be utilizing the area and develop a plan to avoid disturbance during the nesting season. For underground
powerlines, 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. In
addition, indirect affects to wildlife due to construction (timing of activity, clearing of rights-of-way, associated bridges and
culverts, affects to wetlands, fences) should also be considered and mitigated.
Based on the project type entered, coordination with State Historic Preservation Office may be required
(https://azstateparks.com/).
Based on the project type entered, coordination with U.S. Fish and Wildlife Service (Migratory Bird Treaty Act) may be
required (https://www.fws.gov/office/arizona-ecological-services).
Page 10 of 11
Arizona Game and Fish Department
project_report_sun_pond_i_ii_iii_solar_pro_59357_61169.pdf
Project ID: HGIS-18714
Review Date: 3/21/2023 10:29:57 AM
Vegetation restoration projects (including treatments of invasive or exotic species) should have a completed site-
evaluation plan (identifying environmental conditions necessary to re-establish native vegetation), a revegetation plan
(species, density, method of establishment), a short and long-term monitoring plan, including adaptive management
guidelines to address needs for replacement vegetation.
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:
HDMS records indicate that one or more native plants listed on the Arizona Native Plant Law and Antiquities Act have
been documented within the vicinity of your project area. Please contact:
Arizona Department of Agriculture
1688 W Adams St.
Phoenix, AZ 85007
Phone: 602.542.4373
https://agriculture.az.gov/sites/default/files/Native%20Plant%20Rules%20-%20AZ%20Dept%20of%20Ag.pdf starts on
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