CPA2023013 BOS REPORT.PDF

Maricopa County — Formal (2023-12-06)

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December 6, 2023 
CPA2023013 
Page 1 of 1 
 
 
 
 
Report to the Board of Supervisors 
Prepared by the Maricopa County Planning and Development Department 
 
Board Hearing Date: 
December 6, 2023 
 
Case #/Title:   
 
 
CPA2023013 - Desert Gem Solar and Storage Project 
 
Supervisor District: 
5 
 
Applicant/Owners:  
Curtis Karmazin, Origis Development / Multiple – See Parcel Exhibit 
in Attachments 
 
Request: 
Major Comprehensive Plan Amendment (CPA) to change the land 
use designation in the Old U.S. Hwy 80 Area Plan from Open Space, 
Mixed Use & Small Lot Residential to Utilities. CPA approval is by 
Resolution. 
 
Site Location: 
Generally located north & south of Old US Highway 80 & Patterson 
Rd in the Buckeye / Gila Bend area. 
 
Site Size: 
Approx. 4,267 acres 
 
County Island Status: 
No 
Additional 
Comments: 
This application had expanded routing and was sent to all counties 
and registered reviewing agencies. The applicant has worked 
closely with AZ Fish & Game & Luke AFB to mitigate potential 
project impacts. At this time, outside reviewing agencies have no 
outstanding concerns.  
 
Commission  
 
Recommendation: 
On 11/2/23, the Commission voted 4-0 to adopt a motion 
recommending the Board of Supervisors approve CPA2023013  
 
 
Presented by: 
 
Andrew Lorentzen, Planner 
Reviewed by: 
 
Darren Gérard, AICP, Planning Manager   
 
Attachments: 
 
11/2/23 P&Z Packet (58 pages) 
 
 
Resolution (2 pages)   
 
 
Note: 
11/2/23 Draft P&Z Minutes are not available as of the writing of this report, but can be 
provided upon request later when available.

CPA2023013 
Page 1 of 9 
 
 
Report to the Planning and Zoning Commission 
Prepared by the Maricopa County Planning and Development Department 
 
 
Case: 
CPA2023013 - Desert Gem Solar and Storage Project 
 
 
 
 
Hearing Date: 
November 2, 2023 
 
Supervisor District: 
5 
 
 
 
  
 
Applicant: 
Curtis Karmazin, Origis Development 
 
Owner: 
Multiple – See Parcel Exhibit in Attachments 
   
Request: 
Major Comprehensive Plan Amendment (CPA) to change the land use 
designation in the Old U.S. Hwy 80 Area Plan from Open Space, Mixed Use 
& Small Lot Residential to Utilities 
 
  
 
Site Location: 
Generally located north & south of Old US Highway 80 & Patterson Rd in 
the Buckeye / Gila Bend area. 
 
  
Site Size: 
Approx. 4,267 acres 
 
Density: 
N/A 
 
County Island:  
No 
 
 
County Plan: 
Old U.S. Highway 80 Area Plan – Open Space, Mixed Use & Small Lot 
Residential (2-5 du./ac.) 
 
Municipal Plans: 
City of Buckeye: 2040 General Plan – Agriculture, Rural, Neighborhoods & 
Open space  
 
 
Town of Gila Bend: General Plan 2026 – Rural Residential (0-1 du./ac.) & 
Low Density Residential (1-5 du./ac.) 
 
Municipal Comments: 
None received to date  
 
Support/Opposition: 
None known 
 
Recommendation: 
Approve

CPA2023013 
Page 2 of 9 
 
 
 
 
Project Summary: 
 
1. 
Origis Development is requesting a Major CPA to change the land use designation in the Old U.S. 
Highway 80 Area Plan from Open Space, Mixed Use & Small Lot Residential to Utilities to allow 
phased development of a utility-scale solar electric generating project with associated battery 
storage system and future hydrogen manufacturing facility. Due to the size of the project at 4,267 
acres, a major CPA is required. The applicant will subsequently be required to obtain a zone 
change with overlay (including a precise plan of development) to IND-2 IUPD as part of the 
entitlement process. The site is comprised of forty-one (41) private parcels under 6 ownership 
groups in two non-contiguous areas.  All of the parcels are privately owned. 
 
2. 
Nearly all land used for solar energy projects is developed for the large fields of solar collectors 
that capture the energy through photovoltaic technology. The majority of the topography is flat 
and allows for development of solar energy with little or no additional grading. Precise site 
planning matters will be addressed more thoroughly in a future zone change and plan of 
development application. A majority of the site is vacant, native desert land with some large 
agricultural parcels utilized for row crops.  The Gila River is located east and various washes are 
present throughout the site. The proposal is expected to include a connection to nearby Jojoba 
substation. 
 
3. 
Adjacent land uses include vacant, agricultural, a correctional facility, a landfill, two additional 
industrial scale solar generation facilities and very limited rural residential uses.   
 
4. 
The narrative asserts that the proposed development meets the Comprehensive Plan 
Amendment criteria in the following manner:  
 
Whether the amendment constitutes an overall improvement to the Comprehensive Plan and is 
not solely for the good or benefit of a particular landowner or owners at a particular point in time.  
 
The narrative states that the Desert Gem Project is an improvement to the comprehensive plan 
due to the benefits to the state, county, local and regional economy.  According to the narrative, 
a future solar, battery storage and hydrogen production facility will provide employment for 
approximately 1,000 construction employees during the construction project life, as well as 25 
estimated stable jobs over the project lifespan.  The narrative also states that the addition of 
solar, utility scale battery storage and hydrogen generation improves the goals of the 
comprehensive plan by diversifying utilities to allow for strategic and efficient development 
patterns. Additionally, there will be little transportation infrastructure or water resources required 
to serve the site. Therefore, the amendment constitutes an overall improvement to the Vision 
2030 Maricopa County Comprehensive Plan and is not solely for the good or benefit of a particular 
landowner/owners at a particular point in time. 
 
 
Whether the amendment will adversely impact all or a portion of the planning area. 
 
A. 
Altering acceptable land use patterns to the detriment of the plan – According to the 
narrative, the amendment will not alter any surrounding land uses or land use patterns.  
The land is currently vacant or agricultural.  While this land will be unavailable during the

CPA2023013 
Page 3 of 9 
life of the project, the land can return to its agricultural function when the project ceases.  
Moreover, this site is situated in the vicinity of other utility uses in Maricopa County and 
comprises a key use-sector of unincorporated Maricopa County including utilities (solar 
and electric generating stations), agriculture and rural-residential. 
 
B. 
Requiring public expenditures for larger or more expensive infrastructure - The narrative 
states that the project would not require public expenditures for larger or more expensive 
infrastructure.  The costs of the project’s infrastructure needs shall be borne by the 
developer. 
 
C. 
Requiring public improvements to roads, sewer, or water systems that are needed to 
support the planned land uses – The narrative states that the project would require 
improvements to roads, septic and a potable water system associated with the Hydrogen 
production facility using on-site wells.  Existing roads will serve the project and any 
additional project infrastructure needs shall be borne by the developer. 
 
D. 
Adversely impacting planned uses because of increased traffic – The narrative indicates 
there would be increased traffic during the construction phases (approximately 18-36 
months) for the delivery of equipment / supplies and the commuting of the construction 
work force, but there would be no significant increase in traffic during the operational life 
of the project following the construction phase.  Access to existing uses within and around 
the site area would remain open to owners. 
 
E. 
Affecting the livability of the area or health or safety of present and future residents - 
During the construction period, dust control measures shall be utilized to minimize fugitive 
dust generation.  Air emissions will occur from construction equipment; however, long-
term air-quality will improve because of the project. Additionally, the project will follow 
federal, state and local regulations regarding the production, use, storage, transport or 
disposal of any hazardous materials.  Wildlife prevention and mitigation measures will be 
incorporated into the specific plan of development.  Fire hazard risks will be controlled 
through weed control. Compressed hydrogen is planned to be stored in tanks at the 
hydrogen generation facility. The tanks are required per OSHA standards to release gas 
for safety or operational issues. The facility may install a flare stack to employ a pilot 
flame to fully combust the released hydrogen gas. Hydrogen burns cleanly, the only 
combustion product is water vapor. However, there will be some Nitrogen Oxide byproduct 
being emitted by the flaring events. The applicant states the Nitrogen Oxide released will 
be monitored and reported in emissions reporting as well as that the levels produced are 
not to be anticipated to be greater than what is produced in most industrial processes and 
will not result in an impact or nuisance to adjacent land uses. Therefore, the project will 
not affect the livability of the area or health or safety of present and future residents. 
 
F. 
Adversely impacting the natural environment or scenic quality of the area in 
contradiction to the plan – The applicant states that the project will not significantly 
impact the natural environment or overall scenic quality of the area.  There are key 
measures of responsibility that demonstrate an applicant’s commitment to avoiding 
adverse impacts to the natural environment and scenic quality of a site.  These measures 
are subjective in a sense, but may include animals, plants, historical resources, scenic 
views and hydrology/ground disturbance.  
 
Animals

CPA2023013 
Page 4 of 9 
The applicant performed a field-site investigation and conducted pre-construction wildlife 
surveys to identify habitats for creatures.  The Arizona Game and Fish Department 
(AZGFD) has commented on the proposed project regarding measures to protect wildlife 
encountered on the site and maintaining habitat in the project area. The agency has 
concerns for  Western Burrowing Owl habitat, animal migration corridors and the nearby 
Lower Salt and Gila River Ecosystem Important Bird Area. Satisfaction of those comments 
are only required at the Zone Change with Overlay stage (where a precise Plan of 
Development is required). The applicant has demonstrated active coordination with 
AZGFD on wildlife protection measures as evidenced by the letter by AZGFD and meeting 
on August 3, 2023.  
 
Plants 
The applicant will salvage or dispose of protected native plants in accordance with AAC 
Title 3, Chapter 3, Article 11. 
 
 
Historical Resources 
A Class 1 Cultural Resources Inventory and pedestrian surveys were completed and are 
available for state agency review. AZSHPO was notified though did not review or comment 
on the proposal. Satisfaction of SHPO any comments is only required at the time of 
construction permitting.  Development will avoid any known archeological sites and any 
discovery of human remains or funerary objects will be reported to the Director of the 
Arizona State Museum upon discovery per state law. Further, the applicant will implement 
a ‘Unanticipated Discoveries Plan’ during construction to further define steps to take when 
unintended cultural discoveries arise.  
 
Scenic Views 
The narrative indicates that the height of panels and any screening from residential will 
not obscure scenic views. The applicant noted that existing nearby residences will see a 
change in views, though it would be similar to the 2 already existing solar facilities located 
nearby.   
 
 
Hydrology/Ground Disturbance 
According to the narrative, hydrologic conditions will be preserved by avoiding the Gila 
River and any identified Waters of the United States and wetlands and in accordance with 
agency requirements.  AZGFD issued comments concerned about on-site ephemeral 
washes and maintaining those washes to protect the riparian habitat.  The applicant will 
address retention in accordance with Maricopa County agency requirements at the zone 
change stage of the project.  Grading will occur at appropriate slopes associated with the 
project and for other appropriate facilities.  The applicant does not anticipate a need for 
new roads. 
 
 
Whether the amendment is consistent with the overall intent of the Comprehensive Plan. 
 
The applicant’s narrative states that the request is consistent with the overall intent of the 
Comprehensive Plan by addressing the Strategic Priorities for Maricopa County such as strategic 
access to alternative fuels and other forms of alternative energy. Hydrogen production will 
provide state and local job opportunities, an alternative transportation fuel option as well as 
attract and support additional industry and business growth. The narrative maintains that project 
has taken steps to mitigate local impact and notes that the solar generation uses little to no water 
and the hydrogen production will use ‘substantially’ less water than the current agricultural 
operations maintaining consistency with the county’s vision plan to limit development impact.

CPA2023013 
Page 5 of 9 
 
The extent to which the amendment is consistent with the specific goals and policies contained 
within the plan. 
 
The applicant’s narrative contains a substantial list of Goals and Policies from the Vision 2030 
Maricopa County Comprehensive Plan and Old U.S. Highway 80 Area Plan. This staff report 
identifies which Goals and Policies the applicant’s narrative addressed. 
 
Vision 2030 Maricopa County Comprehensive Plan 
 
Land Use Element – Goal 1, Goal 2, Policy 1, Policy 7, Policy 11, Policy 13, Policy 20, Policy 22, 
Policy 27, Policy 31 & Policy 33.  
 
Transportation Element – Goal 1, Policy 1, Policy 2, Policy 9, Policy 11 & Policy 12 
 
Environment Element – Goal 1, Policy 3, Policy 4, Policy 5, Policy 7 
 
Economic Growth Element – Goal 1, Goal 2, Policy 3, Policy 5, & Policy 10 
 
Water Resources Element –Policy 2 & Policy 5 
 
Energy Element – Goal 1, Goal 2, Policy 1 & Policy 6 
 
Cost of Development Element – Goal 2 
 
Old U.S. Highway 80 Area Plan  
 
Land Use Element – Goal L1, Objective L1.1 & Objective L1.4  
 
Transportation – Goal T1, Objective T11.2 & Objective T1.4 
 
Environmental – Goal E1, Objective E1.1, Objective E1.2, Objective E1.3 & Objective E1.4/E1.3 
 
Economic Development – Goal ED1, Objective ED1.1 
 
Growth Area – Goal G.1, Objective G.1.1 & Objective G.1.2 / G1.3 
 
Open Space – Goal O1, Objective 01.1, Objective O1.2 & Objective O1.3 / OS1.4 
 
Water Resources – Goal W1, Objective W1.1, Goal 2, Objective W2.1 & Goal W2.1 
 
Cost of development – Goal C1

CPA2023013 
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2023 Aerial Map 
 
 
 
 
2023 Zoning Map

CPA2023013 
Page 7 of 9 
Land Use Exhibit Excerpt – Current & Proposed Land Use 
 
 
Existing On-Site and Adjacent Zoning / Land Use: 
 
5. 
On-site: 
 
Rural-190, Rural-43 / Vacant/Agricultural 
North: 
Rural-190, Rural-43 / Vacant/Agricultural 
South: 
Rural-190, Rural-43 / Vacant/Agricultural 
East: 
Rural-190, Rural-43 / Vacant/Agricultural 
West: 
Rural-190, Rural-43 / Vacant/Agricultural 
 
 
Utilities and Services: 
 
6. 
Water: 
Private Well or Hauled Water 
Wastewater: 
Septic 
School District: 
Arlington Elementary / Buckeye Union High School District  
Fire: 
Buckeye Valley Fire District  
Police:  
MCSO  
 
Right-of-Way: 
 
7. 
The following table includes existing and future right-of-way and the future classification based 
upon the Maricopa County Department of Transportation (MCDOT) Major Streets and Routes 
Plan.

CPA2023013 
Page 8 of 9 
 
Street Name 
Existing R/W 
Future R/W 
Future Classification 
Old U.S. Hwy 80 
100’ 
100’ 
Principal Arterial 
Patterson Road 
80’ 
80 
Principal Arterial 
 
Adopted Plans: 
 
8. 
Old U.S. Highway 80 Area Plan: Open Space – The plan utilizes 2 types of open space; dedicated 
and proposed. Mixed Use – The plan reserves areas that are compatible with existing uses as 
‘mixed use’ to act as a buffer or transitional zone between uses. Small Lot Residential – Allows 
for single family residential from 2 to 5 dwelling units per acre.  
 
Public Participation Summary: 
 
9. 
The applicant posted the subject site and staff notified all property owners within 300’ of the site.  
Pursuant to state law, Staff also issued enhanced notification letters to all adjacent and internal 
jurisdictions to Maricopa County, select state and regional agencies and Luke Air Force Base 
(LAFB). Staff received two (2) letters from adjacent/internal jurisdictions (Pima County, City of 
Goodyear) expressing no comments.  Comments received from Arizona Game & Fish Department 
(AZGFD) are included in the attachments section, and while considered important are not 
actionable from the County’s perspective until the zone change and plan of development stage.  
The Arizona State Historic Preservation Office (AZSHPO) received notice of the project, but have 
not provided written comments at this time.   
   
10. 
LAFB sent a comment letter to staff indicating the close proximity to flight operations and 
potential interference impacts the project may pose to flight operations. The letter indicated the 
Base’s willingness to work with the applicant to mitigate potential impacts and notes the project 
does not directly pose an immediate impact. LAFB reserves the opportunity to provide additional 
comments upon future formal site plan (POD) submissions.   
 
11. 
According to the Public Participation Results Report submitted by the applicant, the applicant 
created a project website and has completed an extensive local calling campaign to inform over 
5,700 individuals of the project. Of those informed approximately 250 requested more 
information.   
 
12. 
County Staff received no opposition or support correspondence for the request.   
 
Outstanding Concerns from Reviewing Agencies: 
 
13. 
N/A 
 
Staff Analysis: 
 
14. 
The state and Maricopa County recognize the potential environmental and economic benefits 
that solar and hydrogen technology can provide.  The Desert Gem Solar and Storage Project will 
use photovoltaic technology that generates energy from sun absorption.  Photovoltaic technology 
differs from other techniques that required vast amounts of water to cool the units.  In contrast, 
very little water is utilized for photovoltaic technology. The Hydrogen production will utilize 
groundwater in production, though this amount is slated to be far less than the current agriculture 
use utilizes. As a result, this development would not pose a threat to groundwater depletion.  The

CPA2023013 
Page 9 of 9 
battery storage component associated with this proposal assists with additional production and 
any concerns associated with fire will be resolved prior to any construction permit issuance. 
  
16. 
Staff believes the proposed solar facility is well suited to this rural area.  Solar facilities require 
large amounts of relatively flat land, and the vast majority of the subject site is flat.   Staff agrees 
with the applicant that the subject site is suitable due to relative proximity to electrical 
transmission lines, nearby stations and substations, and because the surrounding area is 
undeveloped.  Staff agrees with the applicant that the project will not detrimentally affect the 
visual quality of the area.  The applicant engaged in an adequate participation process.  
Additionally, the applicant consulted on several occasions with AZGFD on wildlife preservation 
which is important to Staff as it demonstrates the responsibility associated with development of 
large swaths of land within unincorporated Maricopa County.  Since the area is primarily 
undeveloped vacant land in near proximity to other existing utility-scale solar projects, staff 
believes there will be minimal impacts to the surrounding area. 
 
17. 
Promoting the development of solar energy over the past several years in Maricopa County 
reinforces the County’s interest in promoting the County as an economic leader for solar 
development. Staff believes the Desert Gem Solar & Storage Project would add to this effort in a 
positive way by providing the potential for 1,000 temporary construction jobs for up 18-36 months 
each.  There will also be up to 25 long-term employment opportunities for County residents.  
 
18. 
Staff believes the Desert Gem Solar & Storage Project is consistent with and meets the goals and 
policies of the Comprehensive Plan. Staff’s position is that this project, as proposed and as 
governed by the recommended conditions, represent proper long-term land use planning in the 
region and for Maricopa County as a whole.   
 
Recommendation: 
 
19. 
For the reasons outlined in this report, staff recommends the Commission motion for Approval 
 
 
Presented by: 
Andrew Lorentzen, Planner 
Reviewed by: 
Darren Gerard, AICP, Planning Manager 
 
Attachments: 
Case Map (1 page) 
 
Land Use Exhibit (2 pages) 
 
Narrative Report (34 pages) 
 
Parcel Exhibit (1 page) 
 
AZGFD Comments (7 pages) 
 
LAFB Comments (2 pages) 
 
Pima County Comments (1 page) 
 
City of Goodyear Comments (1page)

N
C:\Users\bgonzales2\Documents\ArcGIS\Desert Gem\Desert Gem CPA.aprx     5/24/2023
A R I Z O N A
PROJECT
LOCATION
PHOENIX
TUCSON
4S 5W
4S 4W
4S 5W
3S 5W
4S 4W
3S 4W
4S 4W
4S 3W
3S 4W
2S 4W
3S 4W
3S 5W
3S 4W
2S 5W
3S 4W
3S 3W
2S 4W
2S 5W
2S 4W
2S 3W
3S 5W
2S 5W
4S 3W
3S 3W
3S
3W
2S
3W
2
4
1
3
5
6
10
34
31
27
6
34
25
15
24
31
27
35
4
28
2
8
17
18
27
33
29
26
11
32
14
34
28
36
9
3
35
29
25
13
1
32
22
5
30
26
12
30
7
21
19
36
20
23
16
33
1
2
35
26
2
26
36
25
35
24
23
36
14
11
25
13
1
12
S Highw
a
y 85
S E
nterpris
e Rd
W
C
i
t
r
us
V
a
lley
R
d
S O
ld U
s Highway 80
Highway 85 A
c
c
W Patterson Rd
S 283Rd Ave
S Bruner Rd
W Gas Pipeline Rd
0
0.5
1
Miles
DESERT GEM SOLAR
MARICOPA COUNTY, ARIZONA
FIGURE 3 - CURRENT LAND USE
Permitting Boundary
PERMITTING BOUNDARY
JOJOBA SUBSTATION
Maricopa County Planning
Old US Highway 80 Area Plan
State Route 85 Area Plan
Maricopa County Landuse
Dedicated Open Space
Proposed Open Space
Small Lot Residential (2-5)
Rural Densities (0-1)
Mixed Use

N
C:\Users\bgonzales2\Documents\ArcGIS\Desert Gem\Desert Gem CPA.aprx     5/25/2023
A R I Z O N A
PROJECT
LOCATION
PHOENIX
TUCSON
4S 5W
4S 4W
4S 5W
3S 5W
4S 4W
3S 4W
4S 4W
4S 3W
3S 4W
2S 4W
3S 4W
3S 5W
3S 4W
2S 5W
3S 4W
3S 3W
2S 4W
2S 5W
2S 4W
2S 3W
3S 5W
2S 5W
4S 3W
3S 3W
3S
3W
2S
3W
2
4
1
3
5
6
10
34
31
27
6
34
25
15
24
31
27
35
4
28
2
8
17
18
27
33
29
26
11
32
14
34
28
36
9
3
35
29
25
13
1
32
22
5
30
26
12
30
7
21
19
36
20
23
16
33
1
2
35
26
2
26
36
25
35
24
23
36
14
11
25
13
1
12
S Highw
a
y 85
S E
nterpris
e Rd
W
C
i
t
r
us
V
a
lley
R
d
S O
ld U
s Highway 80
Highway 85 A
c
c
W Patterson Rd
S 283Rd Ave
S Bruner Rd
W Gas Pipeline Rd
0
0.5
1
Miles
MARICOPA COUNTY, ARIZONA
FIGURE 5 - PROPOSED LAND USE
Proposed Utility
JOJOBA SUBSTATION
Maricopa County Planning
Old US Highway 80 Area Plan
State Route 85 Area Plan
Maricopa County Landuse
Dedicated Open Space
Proposed Open Space
Small Lot Residential (2-5)
Rural Densities (0-1)
Mixed Use
DESERT GEM SOLAR

DESERT GEM SOLAR 
MAJOR COMPREHENSIVE 
PLAN AMENDMENT 
 
 
DESERT GEM SOLAR AND STORAGE PROJECT 
 
CASE #: CPA2023013 
REVISION 1 
SEPTEMBER 11, 2023

CONTENTS 
1.0 Part A - Executive Summary ........................................................................ 1 
1.1. 
On-Site and Regional Location ........................................................................... 2 
1.2. 
CPA Size and Description of Land Use Types by Acreage .................... 3 
1.3. 
Road/Transportation Systems Serving the Project ................................... 3 
1.4. Suitability with Surrounding Land Use ............................................................ 4 
2.0 Comprehensive Plan Benefits and Improvements 
(Application, Part B) ...................................................................................... 5 
3.0 Comprehensive Plan Compatibility (Application, Part C) .................. 7 
3.1  Land use patterns ........................................................................................................ 7 
3.2. Infrastructure................................................................................................................. 7 
3.3. Roads, sewers, and water systems  ..................................................................... 8 
3.4 Traffic ................................................................................................................................ 8 
3.5 Livability and health and safety ............................................................................. 8 
3.6 Natural environment and scenic quality ............................................................ 9 
4.0 Consistency with the Overall Intent of the Comprehensive 
Plan (Application, Part D)........................................................................... 10 
4.1 Comprehensive Plan .................................................................................................. 10 
4.2 Area Plans .......................................................................................................................11 
U.S. Highway 80 Area Plan .................................................................................. 11 
State Route 85 Corridor Area Plan ................................................................. 12 
5.0 Consistency with the Specific Goals and Policies 
Contained within the Plans (Application, Part E) ............................... 12 
6.0 Other Pertinent Information as Requested by the 
Maricopa County Planning Department Staff. (Application, 
Part F) .............................................................................................................. 24 
7.0 Land Use Exhibit........................................................................................... 24 
 
TABLES 
Table 1: APNs and Respective Property Owners within Project Area ..................... 3 
Table 2: Consistency with Comprehensive Plan Elements ..........................................13 
Table 3: Consistency with Area Plan Elements............................................................... 20

ATTACHMENTS 
Attachment 1. Parcel Information and Acreage

1 
 
1.0 
Part A - Executive Summary 
 
Desert Gem Solar and Storage, LLC. (Applicant), a wholly-owned subsidiary of Origis Energy, 
is proposing to construct the Desert Gem Solar and Storage Project (Project), inclusive of a 
solar photovoltaic (PV) facility, battery energy storage system (BESS), and green hydrogen 
production facility on approximately 4,267 acres (Project Area) in Maricopa County, Arizona 
(County). This narrative report addresses the required information to support the Applicant’s 
request for a Major Comprehensive Plan Amendment (CPA) for the entire Project Area.  
The purpose of this Major Comprehensive Plan Amendment (CPA) request is to amend the 
Vision 2030 Maricopa County Comprehensive Plan to allow the development of the proposed 
Project. The majority of the Project Area is located within the Old U.S. Highway 80 Area Plan. 
The portions of the Project Area in this Area Plan are designated as Mixed Use and Small-Lot 
Residential (2–5 dwelling units per acre [d.u./ac]). The northern portion of the Project Area is 
located within the State Route 85 Corridor Area Plan. The Project Area covered by this Area 
Plan is designated as Rural Densities (0-1 du/ac). There are some future proposed Open 
Space areas in both Area Plans associated with the Gila River and Rainbow Wash that will be 
avoided to the maximum extent practicable. This CPA request is to change the future Area 
Plan designations from their current land use designations (i.e., Mixed Use, Small-Lot 
Residential, Rural, and Proposed Open Space) to Utilities to accommodate the proposed 
Project.  
At a future date, the Applicant will request a Zone Change with Overlay from the current RU-
190 and RU- 43 to IND-2 IUPD. The Applicant may submit a single application for subsequent 
entitlements for the entire Project or may file separate applications for the solar/BESS and 
the green hydrogen components to be covered by this CPA.  
The proposed Project consists of the solar facility and BESS with associated infrastructure 
necessary to generate a total of approximately 540 megawatts (MW) of renewable electrical 
energy coupled with approximately 400 MW of energy storage as well as a green hydrogen 
facility intended to produce hydrogen for delivery to the marketplace.  
The solar array area will cover the majority of the developable footprint with panels located 
on approximately 4,000 acres and will produce approximately 1,122,000 megawatt-hours 
(MWh) to power 100,000 homes. The exact final Project output within the Project Area may 
be higher or lower, depending on the procured panel technology and any development 
constraints identified within the Project Area. The Project will use high-efficiency, 
commercially available solar PV panels to convert the sunlight into electrical energy. The 
panels will be arranged on site in series called “strings” which are combined in the solar field 
through collection lines and then combined together at inverters and ultimately stepped up 
to send energy to the grid. Solar panels may be tracking or fixed tilt, single-sided or bifacial 
and will be mounted on tracking systems that are supported by piles driven into the ground 
and racking that runs aboveground. The solar PV area will also contain multiple inverters 
distributed across the site with blocks of PV panels, supporting collection lines, and roads for 
access and maintenance. The solar facility will be enclosed by security fencing to maintain 
safety of the public, facilities, and construction and maintenance personnel. 
The proposed Project BESS will include 4-hour batteries for a total of 1,600 MWh of energy 
storage. The BESS will be located on approximately 24 acres of land within western side of

2 
 
the Project Area. The specific enclosure manufacturers are still to be determined; however, 
the BESS area will include the battery enclosures and associated infrastructure including 
heating, ventilation and air conditioning (HVAC) systems, inverters, collection lines, internal 
access/maintenance roads, and a central control system. 
The Point of Interconnection (POI) for the Project will be either the existing Salt River Project 
(SRP) Jojoba Substation or the adjacent Arizona Public Services (APS) Komatke Substation, 
via a 230-kilovolt (kV) or 500 kV generation interconnection (gen-tie) line. The proposed 
Project gen-tie would originate at a proposed 5.7-acre onsite substation and head north for 
approximately 7.5 miles across private and/or State Trust Lands managed by the Arizona 
State Land Department (ASLD) to transfer energy to the POI.  
The proposed Project will allow for an efficient, economic, reliable, and safe solar energy 
generating facility. 
The Project is also anticipated to include a green hydrogen generation and distribution facility 
located in the northeast part of the southern portion. This facility will generate hydrogen 
through electrolysis and provide liquified hydrogen to the market. The green hydrogen 
component of the Project will consist of a 120 tons per day electrolytic hydrogen production 
plant, which includes access to existing onsite wells, water purification, electrolyzer stacks, 
compression, and gas storage tanks. The facility will also include a liquefaction plant and 
cryogenic hydrogen storage facilities. The hydrogen site will encompass nearly 60 acres 
within the Project Area including the facilities, the Operations and Maintenance (O&M) 
building, the refueling infrastructure, and turnaround space for the offtake trucks. The green 
hydrogen facility will connect to an onsite substation, shared with the solar project site for 
electrical interconnection. The facility may also include ancillary battery backup devices to 
keep operating during a power outage. 
1.1. 
On-Site and Regional Location 
The proposed Project is located approximately 10.5 miles north, northeast of the town of Gila 
Bend and 10.5 miles south of Buckeye in unincorporated portions of Maricopa County, 
Arizona. The Project Area consists of approximately 4,267 acres of privately owned lands 
with multiple landowners. The gen-tie route will consist of a 200-foot-wide corridor located 
on private or ASLD-managed lands.  
The site is bounded by Old U.S. Highway 80 and the Gila Bend Canal that run on the western 
side of the northern portion and the eastern side of the southern portion of the Project Area. 
The Gila River borders the western edge of the entire Project. Rainbow Wash bisects the 
Project perpendicularly to the Gila Bend Canal and U.S. Highway 80 and separates the 
northern and southern portions of the Project. Rainbow Wash flows into the Gila River. 
Topographically, the Project Area gradually slopes down westward, toward the Gila River. 
The Applicant’s Project Area consists of multiple parcels of land within the following 
Township (T), Range (R), and Sections: 
• 
T2S/R4W; Portions of Sections 23, 24, 27, 28, 29, 31, 32, 33 
• 
T3S/R4W; Portions of Sections 6, 7, 8, 17, 18, 20, 21, 29, 32, 33

3 
 
1.2. 
CPA Size and Description of Land Use Types by Acreage  
This request is for a Major CPA to change the land use designations of the 4,267-acre Project 
Area from the current Area Plan land use designations of Mixed Use, Small-Lot Residential 
and Rural to the Utilities land use designation.  
The primary current land use within the Project Area is agriculture, specifically cultivated 
crops (e.g., irrigated row crops). Land cover within the Project boundary is similar to that in 
the surrounding landscape and consists of cultivated crops with some inclusions of native 
habitat around the perimeter of the Project Area. Native habitat will be excluded from the 
development footprint. Utility use is common near the Project, with various pipelines and 
transmission lines bordering the northern portion of the Project and the Jojoba Switchyard 
and Substation located northeast of the Project. There are two existing solar projects located 
between the southern part of the Project Area and Highway 85. There are also two landfills in 
the area. The existing landfill operated by the City of Phoenix includes a large, planned 
expansion area located adjacent to the eastern boundary of the proposed Project. 
The site is comprised of forty-one (41) private parcels under six (6) separate ownerships. The 
APNs and respective owners are listed in Table 1 below. Most properties in the immediate 
vicinity of the Project are privately owned except for the Arizona State Prison and 
Department of Corrections located immediately east of the proposed Project and the landfill 
areas owned by the City of Phoenix and City of Buckeye. There are also ASLD-managed lands 
to the north and northeast between the Project Area and POI. As of the preparation of this 
application, the final POI and gen-tie route have not been finalized. 
Table 1: APNs and Respective Property Owners within Project Area 
APNs 
Owner 
Project Development Area 
401-66-029H, 401-66-029G, 401-66-
017B, 401-66-018B, 401-66-015Q, 
401-66-034B, 401-66-034A, 401-66-
019A, 401-69-004, 401-69-006B, 
401-69-006A, 401-72-004B, 401-69-
007D 
Structure 
Investments, LLC 
1, 705.3 
401-69-035 
John Farms 
169.3 
401-69-020A, 401-69-038, 401-69-
041H, 401-69-041K 
DYM, Inc. 
1324.2 
401-66-013D, 401-66-013C 
Patterson 152, LLC 
151.3 
401-66-012N, P, Q, R (formerly 401-
66-012H, 401-66-012L, 401-66-012E), 
401-63-002, 401-63-003, 401-63-
021B, 401-63-020, 401-63-005, 401-
63-004, 401-63-006A, 401-63-007 
Vanderhart Farms 
435.8 
401-63-013A, 401-63-016, 401-63-015, 
401-63-001D, 401-63-014, 401-63-
017, 401-63-019B, 401-63-019A, 401-
63-018 
Ladera, LLC 
480.5 
1.3. 
Road/Transportation Systems Serving the Project 
Primary access to the Project Area will be via Old U.S. Highway 80. The highway approaches 
the Project from the northwest, adjacent to the Gila Bend Canal and bisects the Project at

4 
 
West Patterson Road before continuing along the eastern edge of the southern portion of the 
Project. Based on information from the County Assessor’s website, Old U.S. Highway 80 has a 
100-foot right-of-way (ROW) in this area. West Patterson Road consists of two lanes and 
approaches the Project Area from the east, ending where it reaches Old U.S. Highway 80 and 
bisects the northern and southern portions of the Project. Patterson Road has a designated 
80-foot ROW. 
Gas Pipeline Road, an unpaved dirt road that appears to be operated by El Paso Natural Gas 
Company, provides access to the Project on the north end. This road is unpaved and 
connects to Highway 85 (Phoenix Bypass Route) to the east but ends to the west at the Gila 
Bend Canal where other dirt roads continue north. Many unnamed unpaved roads are 
established within the vicinity of the Project that run between agricultural fields. These 
provide access throughout the Project Area and to adjacent lands.  
1.4. 
Suitability with Surrounding Land Use 
This site is in a relatively remote area within close proximity to the regional electric grid, 
making it ideal for solar development. The general area surrounding the Project Area includes 
a significant amount of local infrastructure development, including pipelines, transmission 
lines, and the Jojoba Switchyard and Substation. There are other land uses in the area that are 
suitable with the proposed Project, including existing solar developments and existing and 
planned municipal landfills owned by the City of Phoenix and City of Buckeye. The proposed 
Project is consistent with these surrounding land uses and is evidenced by the approval of 
prior solar projects adjacent to the Project Area, namely the RE Gillespie Solar Project which 
was approved by Maricopa County through a CPA and SUP process (CPA  2010016). 
The site is on generally flat agricultural land with small areas of native desert land mainly 
around the perimeter and is surrounded by agricultural land, native desert lands, and 
commercial/industrial uses. Given the existing site grade and land use, construction will not 
require intensive grading. It is likely the amount of dust currently generated by the 
agricultural lands will be reduced with the Project’s development, given the lands will no 
longer be routinely tilled or harvested; rather, the land will lay fallow beneath solar arrays with 
minimal ground disturbance or vehicular activity. The Project will not generate noise and will 
reduce current water usage, even with the green hydrogen component.  
The solar array and associated facilities will be noticeable mainly along roadways from up to a 
quarter or half-mile of the Project Area, depending on direction. It will blend into the 
landscape as distance increases. There are many parcels around the Project Area; however, 
there are very few residential properties with homes or structures based on aerial imagery 
from 2022, site visits, and Applicant information. Based on County information, there are 26 
unique property ownership entities within 300 feet of the Project; however, some of these 
entities have the same individual owners or contacts. The nearest residences are located 
approximately 0.1 mile to the east of the Project Area, across Old U.S. Highway 80 and the 
adjacent Gila Bend Canal. These properties are also across from a small local private airstrip 
(owned by DYM, Inc.) used for agricultural purposes that is entirely within the Project Area to 
the west of Old U.S. Highway 80. These properties will see a change in views; however, they 
are already within 0.5 mile and 1 mile of two existing solar facilities to the south and north 
respectively. The proposed Project will be at a similar grade and views will be offset by 
existing linear barriers. Another property is located approximately 0.1 mile from the Project 
Area at the northern end. This property appears to include multiple outbuildings that are

5 
 
possibly agriculturally related and will face the Project on multiple sides. The Applicant will 
install screening at an applicable opacity per zoning requirements and in coordination with 
the County to minimize visual impacts. Agricultural residences to the west are over 1.25 miles 
away and will be screened by existing habitat along the Gila River and along the perimeter of 
the Project Area. 
2.0 Comprehensive Plan Benefits and Improvements 
(Application, Part B) 
The County places demonstrable value on alternative energy development, as evidenced by 
the strategic priorities and core principles of the County’s Vison 2030 Comprehensive Plan. 
Maricopa County explicitly identifies encouraging solar energy development as an important 
goal, particularly in Economic Growth Policy 10, Energy Goal 2, Energy Policy 6, and Water 
Resources Policy 5. 
The proposed Project as both a renewable energy generation facility and an alternative fuel 
production facility is consistent with the County’s mission and goals for strategic priorities 
and development of a balanced regional economy. 
This amendment will also improve the overall Area Plans because it will provide additional 
economic opportunities in an efficient growth pattern with negligible environmental impacts 
as outlined in subsequent sections. Amending the Area Plans will allow the Project and 
County to use efficient renewable energy and zero-emissions facilities, land use designations, 
and existing infrastructure (e.g., transmission lines, substations, and road networks) to create 
economic opportunities for local communities consistent with Economic Development Goal 
(ED) 1 and Growth Areas Goal (G.1) in the Area Plans. 
The Project, as a utility-scale renewable energy generation and storage facility, is in direct 
alignment with the County’s mission and guiding principles for leadership and strategic 
priorities to leverage its resources to provide for a balanced regional economy. The Project 
will benefit the local, county, state, and regional economy by providing employment 
opportunities for hundreds of experienced professionals during construction of the 540 MW 
solar/storage facility and the green hydrogen facility, each of which will occur over a 2 to 3-
year construction window, as well as revenue opportunities for local businesses.  
The actual number of jobs will ultimately depend upon the selected technology, final size and 
layout of the Project components, and timing of construction. It is anticipated that a daily 
workforce of up to 1,000 construction workers representing typical construction specialties 
will be required for construction of the Project. The Project would also provide up to 25 long-
term jobs during operations.  
Furthermore, the electricity generated by the Project will be distributed to the regional 
electrical grid, supplying the county, state and wider west/southwest regions. The hydrogen 
will be produced for use in the region as an alternative fuel source, consistent with County 
goals. The generation of solar electricity and production of hydrogen could also result in 
improved air quality through reduced emissions for electric generation and alternative fuel 
use, providing a benefit to air quality in Maricopa County, aligning with the county’s 
Comprehensive Plan Environmental Goal 1 and Area Plans Environmental Goal E1.

6 
 
Site characteristics have been taken into consideration to ensure the Project will be 
consistent with and uphold the County’s Comprehensive Plan policies and goals, and will 
enable efficient, responsible development. Amending the Comprehensive Plan to allow for 
solar energy electric generation and green hydrogen production in this location represents 
compatible land use strategy and efficient development patterns near existing electric 
utilities.  
The county’s Land Use Goal 1, Land Use Policy 33, Energy Goal 3 and the Area Plans’ Land 
Use Goal L1 for efficient development patterns will be supported by the Project, given the 
location in an area that allows for efficient interconnection with existing electrical 
infrastructure (i.e., numerous high voltage transmission lines, the SRP Jojoba Substation and 
APS Komatke Substation) serving regional electrical load growth. The area has a developed 
road system, such that the need for additional infrastructure will be minimized and the Project 
will not place excess burden on existing infrastructure, and existing and future road 
alignments will be maintained, supporting the County’s Transportation Goal 2 and 
Transportation Policy 1 and Policy 2, as well as Goal T1 in the Area Plans. 
Development on the site will occur in areas of existing agriculture and/or prior development. 
Given the existing land uses, there is low potential for impacts to special status species within 
the proposed development footprint, which will avoid native habitat areas, floodplains, 
jurisdictional features, and known cultural and biological resources to the maximum extent 
practicable. Consistent with the County’s Environmental Policy 5, desktop studies and site 
surveys have been conducted for biological, cultural, and United States Army Corps of 
Engineers (USACE) jurisdictional features in the Project Area to further define sensitive areas 
and the potential for impacts. Surveys of the interconnection will be conducted in accordance 
with ASLD requirements pending route determination. The Applicant has sited the proposed 
Project to avoid sensitive resources and will implement best management practices to avoid 
and minimize impacts during construction and operation of the facility. Development will be 
consistent with the County’s Environmental Policy 8 and compatible with Land Use Policy 22 
and 27 and Environmental Policy 4. The Project is also compatible with the Environmental 
Goal E.1 in both Area Plans. 
As a low water-use facility the solar and BESS Project will not require water in the generation 
of electrical power. It may be noted that a minimal amount of water is necessary for panel 
and equipment maintenance, especially as the site is located in a dusty environment. Water is 
expected to be sourced locally from existing wells or other nearby water sources. Overall, 
operating solar PV systems is a relatively water-efficient way to generate electricity, making it 
an ideal way to generate electricity in an environment where water is a priority. This supports 
the County’s Water Resources Goal 4 and Water Resources Policy 3 and, 5 as well as the 
Water Resources Goals W1 and W2 in the Area Plans. 
The green hydrogen facility will use water to produce hydrogen though the process of 
electrolysis. The water will be sourced from an existing agricultural supply and will result in an 
overall reduction in water demand as compared to the existing agricultural uses operating 
today. The anticipated water use for the green hydrogen facility will depend on the ultimate 
facility size and water source. Based on current sizing and associated water demand, water 
use is anticipated to be between 1- to   2 acre-feet per day (up to approximately 730 acre-
feet per year), compared to the current average agricultural use of 1,100 acre-feet per month 
over 10 months or 11,000 acre-feet per year to support cultivated crops. The Project will result

7 
 
in an overall significant reduction in water demand and will monitor water use to remain 
compliant with the County’s water resources goals and policies. 
In summary, the requested amendment constitutes an improvement to the overall 
Comprehensive Plan and is not solely for the benefit of the Applicant because it will: 
• 
Increase tax revenue; 
• 
Create much needed jobs; 
• 
Allow for development of land that is well‐suited for solar generation and 
renewable energy development;  
• 
Maintain a compatible land use that is consistent with adjacent and nearby land 
uses; and 
• 
Minimize impacts to resources. 
 
The Project will enable environmentally responsible and efficient land development, electrical 
generation, and alternative fuel (hydrogen) production to support a decarbonized economy 
for county, state, and regional residents. 
3.0 
Comprehensive Plan Compatibility (Application, Part C) 
The CPA for the Project is expected to result in negligible adverse impacts on the Old U.S. 
Highway 80 Area Plan and State Roue 85 Area Plan, as outlined below. 
3.1 Land use patterns 
The proposed Project is consistent and compatible with adjacent land uses which include 
energy generation, solid waste management, transmission/distribution infrastructure, as well 
as agriculture, transportation, and undeveloped desert.  
The effect on land use within the Project Area will be temporary due to a loss of farming 
practices during the life of the Project; however, reclamation can restore the land to its 
previous agricultural use at the conclusion of the Project’s operational design life period, or 
could transition to alternate land uses per the Area Plans. Approximately 87% of the Project 
Area is used for cultivated crops, and the land use adjacent to the Project Area is similar with 
the exception of the wetland areas that border the western portion of the site in relation to 
the Gila River. To reduce impacts to waters, the Gila River, large washes, and natural 
waterways such as Rainbow Wash will be avoided, with potential minor impacts from 
interconnection crossings. This avoidance of these features is also consistent with the future 
proposed open space areas associated with the Gila River and Rainbow Wash identified in the 
respective Area Plans. The proposed amendment will not adversely impact surrounding land 
uses or patterns. 
3.2. Infrastructure  
The cost of the Project’s infrastructure such as the gen-tie line, on-site connection lines, 
roads, and access improvements are the responsibility of the owner/developer of the Project. 
Depending upon timing and off-taker requirements, the green hydrogen facility may require a 
power load supply from the utilities. If required, this infrastructure will be subject to 
applicable permits and approvals with the utility. The proposed amendment will not require 
public expenditures for larger or more expensive infrastructure.

8 
 
3.3. Roads, sewers, and water systems  
The Project may require improvements to roads such as acceleration and/or deceleration 
lanes for Project site access; however, the costs for any improvements will be borne by the 
Applicant. The Project intends to use existing buildings and structures that are part of the 
property during operations and maintenance of the Project and won’t require the installation 
of new water supply or septic/wastewater system. Water for construction or operations is 
expected to be drawn from on-site water wells associated with the Project and will be below 
current water demand for agricultural activities. The proposed amendment will not require 
public improvements to support the planned land uses. 
3.4 Traffic 
Increased traffic is expected during construction, but it will be temporary and concentrated 
during the delivery of materials to the site. Impacts to the transportation network are 
anticipated to last approximately 18 to 36 months depending on Project phasing. There will 
be no significant increase in traffic during the operational life of the Project following the 
construction phase. The Project will not impact planned land uses during construction. 
Potential impacts during construction and operations of the facility will be further addressed 
during subsequent entitlements approval processes. The Applicant also anticipates the 
preparation of a traffic management plan prior to construction to minimize impacts on 
existing land uses and access to the site. Overall, the proposed amendment will not adversely 
impact planned uses of the area due to increased traffic.  
3.5 Livability and health and safety 
The vicinity of the Project Area has other solar projects, energy infrastructure (including 
substations, transmission and distribution lines, and gas pipelines), solid waste landfills, and a 
prison. Preparation, construction, and operation of the Project will not be expected to impact 
any residential areas or the health and safety of present and future residents. The Project will 
be enclosed by security fencing to minimize access to the facilities per County and electrical 
generation facility standards. Given the distance to residences and other existing barriers, 
screening to minimize visual impacts is not anticipated for the Project; however, it may be 
included in the areas closest to adjacent residential parcels if required.  
Construction activities have the potential to generate emissions associated with heavy 
equipment operations; however, emissions will be relatively low and temporary. The 
Applicant will use modern equipment to minimize emissions during construction and will 
conduct routine inspection and maintenance activities to prevent and minimize impacts from 
leaks and spills. The Applicant will also implement dust control measures to manage fugitive 
dust emissions. Operation of the solar and BESS facilities is not expected to generate air 
emissions.  
Construction and operation of the solar and BESS facility is not expected to include the use of 
hazardous materials. Materials that will be used onsite include fuels, oils, and lubricants 
associated with vehicles and equipment, as well as oils associated with transformers and 
inverters during operation. Herbicides may also be used to control invasive plants onsite but 
are not expected to be stored onsite and will be managed in accordance with applicable 
County regulations. The Applicant will implement spill control measures to manage risks from 
leaks and spills onsite.

9 
 
The green hydrogen facility will contain compressed gas storage and refueling stations. The 
Project will implement Process Safety Management (PSM) requirements in accordance with 
U.S. Occupational Safety and Health Administration (OSHA) standards to minimize the risk of 
releases or safety issues associated with operation of the facility, including transport of 
materials. The facility may install a flare for emergency and maintenance releases of hydrogen 
for which the pilot light could be natural gas or propane that will be stored onsite in tanks or 
cylinders. Flare stacks typically employ a pilot flame, which will be an emission source. 
Hydrogen itself burns cleanly – the only combustion product is water vapor. However, during 
the infrequent flaring events, combustion of hydrogen at the flare stack tip will generate 
some Nitrogen Oxides (NOx), which will be included in emissions reporting. Emission rates 
from the pilot and flaring events will be very low compared to most industrial processes and 
is not anticipated to result in impacts or be a nuisance to adjacent land uses. 
Consistent with all rural areas, the Project could be subject to wildfires. The Project will 
attempt to reduce the potential for fire to spread through efforts such as vegetation 
management and weed control. 
The Project will be managed in accordance with local, state, and federal regulations to 
minimize risk and exposure to workers, the public, and the environment; therefore, the 
proposed amendment will not affect the livability of the area or the health and safety of 
present and future residents. 
3.6 Natural environment and scenic quality 
The Applicant has completed a threatened and endangered species habitat assessment, 
wetlands and waters delineation, cultural pedestrian survey, and baseline drainage study of 
the Project Area to document the existing conditions. Each of these reports will be provided 
to the County under separate cover.  
The potential for listed species within the Project Area is low. Although there is potential 
habitat in the native vegetation areas associated with the Gila River and Rainbow Wash 
adjacent to and generally along the perimeter of the Project, desktop reviews and field 
surveys to date have not identified any habitat for federally-listed species in the Project Area. 
Sonoran pronghorn and Sonoran desert tortoise are unlikely to be observed within the 
Project Area due to the absence of suitable habitat. Western burrowing owls were observed 
in the Project Area and will be managed in accordance with Arizona Game and Fish 
Department (AzGFD) requirements including relocation to a suitable mitigation area, if 
appropriate. Nesting bird surveys will be conducted prior to construction activities occurring 
during the nesting bird season to avoid and minimize the potential for impacts to birds 
protected under the Migratory Bird Treaty Act. 
The proposed Project Area consists of cultivated crops. Native plants are located in desert 
scrub and drainage areas predominantly around the periphery of the Project Area that are 
protected under the Arizona Native Plant Law administered by the Arizona Department of 
Agriculture. Native habitat and drainages will be avoided to the extent practicable; however, 
if protected native plants are identified onsite prior to construction that must be removed, 
they will be relocated or salvaged as required. Native plant removal, relocation, or sale will be 
noticed as required by Arizona Administrative Code Title 3, Chapter 3, Article II.

10 
 
A Class I Cultural Resources Inventory consisting of a literature review and site files review 
was completed for the Project Area. Based on the literature review, there are nine 
archaeological sites previously recorded within one-mile of the Project Area. Five of the nine 
sites are located within the Project Area; three sites are listed as eligible for listing in the 
National Register of Historic Places (NRHP), and two sites have not been evaluated. 
Pedestrian surveys have been completed to further define cultural resources potentially 
present on site and to define avoidance buffers for the Project. The results will be 
documented in a report and provided to the County and applicable regulatory agencies 
under separate cover. The Applicant will also implement an Unanticipated Discoveries Plan 
during construction to define the steps to take in case of potential inadvertent discoveries. 
The Project borders the Gila River on the western side, and subsequently contains 16 National 
Wetland Inventory wetlands that are at least partially within the boundary. Wetland 
delineation surveys have been completed to determine the exact locations of potentially 
jurisdictional wetlands and transition areas in the Project Area. A delineation report will be 
provided to the County under separate cover. Jurisdictional waters will be avoided to the 
maximum extent practicable. 
The Project is not anticipated to impact the scenic quality of the area. The site is relatively flat 
with minimal topographic relief. The adjacent areas are also relatively flat and consist of 
existing electrical infrastructure (e.g., distribution and transmission lines, substations, solar 
generating facilities), transportation networks, a prison and municipal solid waste landfills. 
Views toward the site are limited due to the flat terrain and will decrease with distance. There 
are also linear barriers such as the Gila River, road networks and canals between the Project 
Area and adjacent properties. The closest known residences are located approximately 0.1 
mile east of the Project Area. These properties are located across Old U.S. Highway 80 and 
the canal and are across from a small local agricultural airfield that is within the Project Area. 
These properties will see a change in views; however, they are already within 0.5 mile and 1 
mile of two existing solar facilities to the south and north respectively. The proposed Project 
will be at similar grade and views and will be offset by existing linear barriers. If required, the 
Applicant will install screening at an applicable opacity per zoning requirements and in 
coordination with the County to minimize visual impacts. 
The proposed Project is located near existing electrical infrastructure and solar generating 
facilities and the Applicant is committed to preventing long term adverse impacts to the local 
natural environment and scenic quality of the site; therefore, the proposed amendment will 
not significantly impact the natural environment or scenic quality of the area. 
4.0 Consistency with the Overall Intent of the Comprehensive 
Plan (Application, Part D) 
4.1 Comprehensive Plan 
This CPA request is consistent with the Comprehensive Plan itself as the Plan explicitly 
identifies the support for and encouragement of alternative energy development, including 
solar generation (Economic Growth Policy 10, Energy Goals 2 and 6, and Water Resources 
Policy 5). The Plan specifically identifies the county’s potential to be a “global leader in 
renewable energy research and development, especially with respect to solar energy.” This

11 
 
Project will include the generation of up to 540 MW and storage of up to 400 MW of new 
solar energy to meet the needs of a growing population in Maricopa County and the State of 
Arizona. The Project will also generate up to 120 tons per day of hydrogen for delivery to the 
marketplace and expansion of clean fuel technologies. 
Solar energy development is important for the attraction of future solar and other alternative 
energy research and development in Maricopa County, and solar provides many state, county, 
regional, and local benefits to residents. Additionally, per the stated transportation goals, the 
Applicant has chosen land that is particularly suitable for solar development, being close to 
other solar generation utility facilities, the Jojoba Substation, utility/transmission corridors, 
and existing transmission lines, as well as nearby existing transportation networks, to provide 
energy more efficiently to the electrical grid.  
The proposal for green hydrogen is also consistent with strategic principles of the 
Comprehensive Plan including Economic Growth Policy 10 regarding alternative energy 
research and development and future expansion for research, development, and access to 
alternative fuels and other forms of renewable energy. The hydrogen facility will also support 
Energy Policy 4 by providing fuel for an alternative transportation option. The green 
hydrogen component will provide state, county, regional and local benefits with job 
opportunities and production that will attract and support other business and industries and 
further promote economic growth and development in a sustainable manner. 
The Project is consistent with the County’s vision to reduce the impacts of new development 
on environmentally sensitive areas by maintaining a level of integrity that will avoid or 
mitigate impacts to sensitive local flora and fauna. The impacts to water availability will also 
be positive, as solar generation requires no water for electricity generation and the hydrogen 
facility will use substantially less water than the current agricultural operations.  
Maintaining each of these consistencies with the Maricopa County Comprehensive Plan 
displays leadership and expertise within the solar industry, which will attract future renewable 
energy development and the associated professional workers. As a result, local businesses 
will be economically bolstered by the opportunity for retail provided by personnel living and 
working in the area. The narrative displays consistency with the Comprehensive Plan in the 
implementation of the proposed Project. 
4.2 Area Plans 
The Project is also consistent with the overall intent of the Area Plans. Both Area Plans 
contain a series of goals, objectives and policies used to define development standards, guide 
public investment, and public and private decision-making. 
U.S. Highway 80 Area Plan 
The Old U.S. Highway 80 Area Plan “provides recommendations for various planning related 
issues. The plan provides urban densities in certain areas while providing a rural alternative 
for those who wish to enjoy the rural lifestyle. The plan promotes the compatibility of 
residential, commercial, industrial, and employment land uses. The plan seeks to minimize 
impacts to the natural environment, reduce demand on groundwater supplies, and encourage 
the protection of vital open space areas and wildlife habitat. Most importantly, the Old U.S. 
Highway 80 Area Plan accounts for stakeholder and resident comments, concerns, and 
recommendations. Because the Project adheres to the goals, objectives, and policies of the

12 
 
Old U.S. Highway 80 Area Plan (see section 5.0 Part E and Table 3), the proposed 
amendment is consistent with the overall intent of the State Route 85 Area Plan as well. 
State Route 85 Corridor Area Plan 
The State Route 85 Corridor Area Plan “was completed to reflect current conditions and to 
accommodate a portion of the anticipated growth in a manner that is consistent with 
protecting public health, safety, convenience, and general welfare. In addition to elements 
examining Land Use, Transportation, Environment, and Economic Development, this Area 
Plan includes Environmental Effects, Growth Areas, Open Space, Water Resources, and Cost 
of Development elements…” . Because the Project adheres to the goals, objectives, and 
policies of the State Route 85 Area Plan (see section 5.0 Part E and Table 3), the proposed 
amendment is consistent with the overall intent of the State Route 85 Area Plan as well. 
5.0 Consistency with the Specific Goals and Policies Contained 
within the Plans (Application, Part E) 
The Project will use PV solar and battery technology to generate and store renewable energy 
power consistent with the clean energy goals of Maricopa County and State of Arizona. The 
Project will also generate green hydrogen to further grow the alternative energy and fuel 
economy. The potential environmental and economic benefits of renewable energy 
development is a key element recognized in the Comprehensive Plan and is responsible 
economic development and growth in the Area Plans, as indicated in many of the goals and 
policies. 
The Applicant has sited the Project in an area that is well suited for solar development. The 
Project is sited within relatively flat lands and existing road networks that will not require 
substantial land grading and preparation. The Project will also have minimal impacts on native 
landscapes and resources, will substantially reduce overall water consumption from existing 
land uses, and will minimize impacts on existing infrastructure due to its proximity to existing 
transportation networks and the proposed POI at the Jojoba Substation or adjacent Komatke 
Substation. 
The surrounding lands include compatible land uses such as agriculture, existing electrical 
infrastructure, road networks, municipal landfills, and a prison. The area has a very low 
development density with few existing residences. The existing visual setting is defined by 
current land uses and associated infrastructure and development, including electrical 
infrastructure (e.g., transmission and distribution lines and substations); the transportation 
network (e.g., major and minor roads, local/regional airports, and other farm roads); the 
prison with fences and buildings; the landfills; and agricultural farms and their associated 
infrastructure (e.g., water pumps, canals, farm roads, distribution lines, barns and buildings; 
and open desert landscapes).    
The Project will add to the existing disturbed visual landscape; however, the flat terrain and 
relatively low-profile nature of the facility components will minimize impacts. The most 
prominent features will be associated with the green hydrogen facility and the gen-tie 
interconnect, both of which have been located further north in closer proximity to existing 
lines, the prison, and municipal landfills. The visual impacts are not expected to adversely 
impact existing views or the existing setting.

13 
 
This Project will assist the County in advancing its goals to encourage renewable energy 
development and the creation of jobs, both temporary and permanent, as associated with 
these types of development. The Applicant believes this proposed Project is consistent with 
the specific goals and policies contained in Maricopa County’s Comprehensive Plan as well as 
the relevant Area Plans. Table 2 below includes an accounting of the relevant specific goals 
and policies contained in the Comprehensive Plan and the Project’s consistency with each. 
Similarly, Table 3 reflects the Project’s consistency with the relevant specific goals and 
policies in the Area Plans. 
 
Table 2: Consistency with Comprehensive Plan Elements 
Land Use Element 
Comprehensive Plan Policies 
Consistency with Comprehensive Plan 
Land Use 
Land Use Goal #1 
Achieve balanced and efficient 
development patterns. 
The Project design and location allows 
efficient interconnection with the 
existing electrical infrastructure serving 
regional load growth.  
Land Use Goal #3 
Protect public health, safety, 
and well-being. 
The Project will be designed, 
constructed, and operated to minimize 
risks to workers and the public; the 
Project will provide renewable energy 
generation that will help improve air 
quality through reduced emissions 
from fossil fuel energy generation. 
Land Use Policy #1 
Maricopa County supports 
compliance with its capital 
improvement and other 
funding programs, except 
when reimbursement is made 
to the county for unplanned 
costs or when services and 
infrastructure are funded by 
private capital. 
The Project will be funded by private 
capital. All infrastructure improvements 
required for the Project shall be paid 
for by the Applicant. If load is required 
for green hydrogen; that will be 
processed through required approvals 
with the applicable utility. 
Land Use Policy #7 
Support for coordinating land 
use and infrastructure 
planning with state agencies, 
counties, and municipalities. 
The Applicant has proposed a Project 
that will use state and private land and 
has committed to coordination with all 
applicable local, county, and state 
agencies to ensure an efficient, safe, 
and conscientious completion.  
Land Use Policy #11 
Support for including State 
Trust land in the planning and 
design of large-scale urban 
development. 
The current Project plan proposes to 
cross State Trust land for the gen-tie 
line that will connect this Project with 
existing electrical infrastructure. 
Land Use Policy #13 
Support for wildfire 
prevention and mitigation 
measures in the design of 
development. 
Best management practices and 
mitigation measures will be 
implemented by the Applicant to 
prevent the potential for wildfires in 
the Project Area.

14 
 
Land Use Element 
Comprehensive Plan Policies 
Consistency with Comprehensive Plan 
Land Use Policy #20 
Support for reducing impacts 
of new urban development on 
existing rural land uses and 
agriculture. 
The temporary nature of the Project 
creates a non-permanent impact on 
agricultural practices and land within 
the Project Area. Soils will be 
preserved and left fallow under the 
panel areas. At the end of the Project 
operational life, the property could be 
returned to agricultural use. 
Land Use Policy #22 
Support for reducing the 
impacts of new development 
on environmentally sensitive 
areas, including native wildlife 
(flora and fauna) habitat and 
corridors. 
The Project area is primarily 
agricultural land and is not considered 
suitable habitat for most sensitive 
species in the area. Species and 
habitats that have been deemed 
present by habitat and species surveys 
(i.e., burrowing owl; nesting birds) will 
have appropriate measures 
implemented to  avoid and minimize 
impacts. Areas such as Layton Wash 
and Rainbow Wash will remain open 
across the Project, to allow wildlife 
movement across the site. 
Coordination with the appropriate 
agencies will be ongoing to ensure 
regulatory compliance with applicable 
environmental policies, protocols, and 
regulations.  
Land Use Policy #27 
Support for keeping 
development out of 
delineated floodways and, 
where necessary, 100-year 
floodplains. 
The Applicant has delineated wetlands 
and important waterways within the 
Project Area and is committed to 
implementing appropriate avoidance or 
mitigation measures with coordination 
from applicable agencies to minimize 
impacts to these resources.  
Land Use Policy #31 
To promote safe and active 
communities, Maricopa 
County supports public safety 
and security features included 
in the design of new and 
existing development. 
The Applicant will ensure the Project 
design, construction, and operation will 
comply with known technology and 
methods to protect public health and 
safety. As dust generation is also a 
significant public health factor in the 
county, best management practices 
will be followed to ensure fugitive dust 
levels are kept in compliance with local 
and county regulations. 
Land Use Policy #33 
Support for using land use 
buffers and compatible land 
use strategies near existing 
and future high voltage 
electric utility line corridors. 
The Project location has been situated 
efficiently to allow for connection with 
existing electrical infrastructure, 
including nearby high voltage 
transmission lines and the SRP Jojoba 
Substation or adjacent APS Komatke 
Substation.

15 
 
Land Use Element 
Comprehensive Plan Policies 
Consistency with Comprehensive Plan 
Transportation 
Transportation Goal 
#1 
Develop and maintain an 
integrated and efficient 
transportation system that 
supports the mobility needs of 
residents, businesses, and 
visitors. 
Roads already present within the 
vicinity of the Project will either remain 
unchanged or will be improved based 
on the needs of Project access. Current 
available roadways are mostly 
sufficient for Project needs, which 
means additional infrastructure will be 
minimal. This ensures there is no excess 
burden on the existing infrastructure. 
Transportation Policy 
#1 
As necessary, Maricopa 
County supports preserving 
future road alignments called 
for in county-recognized 
transportation plans, 
especially mid-section line; 
section line and arterial roads; 
parkways; freeways; and 
interchanges. 
The Project supports preserving the 
existing and future road alignments in 
the Project Area. The Project will 
comply with the Maricopa County 
Department of Transportation planning 
objectives. 
Transportation Policy 
#2 
Maricopa County supports 
compliance with its Major 
Streets and Routes Plan. 
The Project supports preserving the 
existing and future road alignments in 
the Project Area. The Project will 
comply with the Maricopa County 
Department of Transportation planning 
objectives. 
Transportation Policy 
#9 
Maricopa County supports 
balanced and efficient land 
use patterns that reduce the 
number and length of vehicle 
trips. 
Consistent with typical solar 
development, the Project will require 
minimal staff, resulting in few vehicle 
trips to and from the site. The green 
hydrogen facility will have a larger 
workforce, but is not anticipated to 
have a significant impact on workforce 
trips during operations. 
Transportation Policy 
#11 
Maricopa County supports 
National Ambient Air Quality 
Standards (NAAQS) 
compliance. 
The Project will adhere to National 
Ambient Air Quality Standards. 
Compared to the emissions through 
other electric generation methods, the 
Project will generate renewable energy 
that will result in improved air quality. 
The green hydrogen facility will also 
provide an alternative fuel source to 
facilitate zero-emissions growth. 
Transportation Policy 
#12 
Maricopa County supports 
improving low volume dirt 
roads as directed by its PM-10 
Dust Abatement Program. 
A Maricopa County Air Quality 
Department (MDAQD) Dust Abatement 
Permit will be required prior to 
construction and will be obtained. Use 
of dirt roads will include dust 
abatement techniques during 
construction, operation, and 
maintenance as needed.

16 
 
Land Use Element 
Comprehensive Plan Policies 
Consistency with Comprehensive Plan 
Environmental Element 
Environment Goal #1 
Provide regional leadership to 
promote all aspects of 
regional environmental 
quality. 
The Project will generate renewable 
energy that will result in improved air 
quality through reduced emissions for 
electric generation, providing a benefit 
to air quality in Maricopa County. 
Green hydrogen will also provide an 
alternative to fossil fuel generation 
processes, reducing associated 
emissions. Coordination with agencies 
as well as the appropriate protective 
measures for biological and cultural 
resources will be implemented to 
minimize or prevent impacts to these 
resources. Additionally, the change in 
land use associated with development 
of the Project will result in a substantial 
reduction in overall annual water use in 
a state where water is a resource of 
concern. Amending the Comprehensive 
Plan to enable this Project will 
demonstrate responsible leadership to 
promote regional environmental 
quality. 
Environmental Policy 
#3 
To help protect water quality, 
Maricopa County supports 
compliance with its Drinking 
Water Program and its Water 
and Wastewater Treatment 
Program. 
This Project will provide appropriate 
water management and treatment to 
maintain water quality standards as 
required. Water use for site activities 
will utilize existing sources and will not 
result in the generation of new water 
supply sources. 
Environmental Policy 
#4 
Maricopa County supports 
innovative Project design and 
development techniques that 
protect important plant and 
animal habitat and migration 
corridors. 
The Project will be designed to avoid 
and minimize impacts to native habitat. 
The Project does not contain critical 
habitats. AZGFD noted that the Project 
bisects the Gila Bend - Sierra Estrella 
Linkage Design (a modelled wildlife 
movement corridor) and is adjacent to 
the Gila River Maricopa County Wildlife 
Movement 
Riparian Area. The Gila River is located 
to the west, and Rainbow Wash and 
Layton Wash may provide local access 
for wildlife. These features will be 
maintained and avoided during 
construction, operation, and 
maintenance to allow for wildlife 
access across the site. The Applicant 
will continue to coordinate with AZGFD 
to identify habitats and corridors in 
need of avoidance or impact mitigation 
during the life of the Project.

17 
 
Land Use Element 
Comprehensive Plan Policies 
Consistency with Comprehensive Plan 
Environmental Policy 
#5 
As directed by the State 
Historic Preservation Office 
(SHPO) and Arizona Game 
and Fish Department, 
Maricopa County supports 
cultural resource and 
biological surveys being 
completed – and needed 
mitigation measures 
established – prior to new 
development. 
The Project has conducted biological 
and cultural surveys for the Project 
Area. Surveys for the gen-tie will be 
conducted pending routing and 
appropriate authorizations from ASLD. 
Habitat assessment, cultural survey, 
and waters delineation reports are 
under preparation for the Project Area 
private lands and will be provided to 
the County under separate cover.  
Environmental Policy 
#7 
Where necessary Maricopa 
County supports noise 
reductions. 
This Project will conform to the 
required noise mitigation during 
construction and will maintain regular 
hours of operation consistent with 
Maricopa County regulations. The 
production of electricity from the 
completed solar field would not 
generate audible noise. The green 
hydrogen facility is not anticipated to 
generate noise levels that would 
substantially impact existing land uses 
or exceed County standards. 
Economic Element 
Economic Growth 
Goal #1 
Contribute to an effective 
regional economy. 
Maricopa County is uniquely situated 
with land and a climate that are ideal 
for solar generation, an important 
power resource. The proposed 
Project’s hydrogen facility will also 
contribute to furthering zero-emissions 
transportation and energy supply and 
infrastructure. This is also consistent 
with recent proposals to the 
Department of Energy for green 
hydrogen hubs in the Phoenix area. 
Along with providing efficient and 
renewable power and clean energy to 
residents and businesses, the Project 
will employ numerous experienced 
professionals and vendors from the 
local community. Local personnel will 
also bolster the local economy by 
providing business to local retail 
locations. As onsite housing will not be 
provided during construction, local 
motels, hotels, and privately owned 
rentals will also experience an 
economic benefit.

18 
 
Land Use Element 
Comprehensive Plan Policies 
Consistency with Comprehensive Plan 
Economic Growth 
Goal #2 
Have a diverse and balanced 
economy to promote long-
term economic stability and 
economic resiliency. 
This Project will further expand the 
electric resources in the County by 
taking advantage of abundant and 
readily available solar irradiation. These 
resources will be available for the 40-
year operational lifetime of the Project, 
providing long-term stability and 
economic resiliency. The green 
hydrogen component will also support 
long-range opportunities for economic 
growth and diversity. 
Economic Growth 
Policy #3 
Support for increasing 
entrepreneurial activities and 
business formation. 
Hundreds of construction personnel 
will be necessary for the completion of 
the Project, along with additional 
professionals in the safety, engineering, 
and environmental fields. These 
workers will provide economic benefits 
since personnel will use local 
businesses for food, overnight stays, 
and other retail opportunities. 
Economic Growth 
Policy #5 
Support for programs that 
attract a variety of Basic 
Sector industry clusters that 
have long-term, stable growth 
prospects. 
Economic Growth 
Policy #10 
Maricopa County supports 
leveraging its solar resource 
potential to attract solar-
related industries and 
alternative energy research 
and development. 
Maricopa County is uniquely situated to 
demonstrate their leadership in the 
renewable and solar energy sector due 
to abundant solar resources and the 
abundance of suitable land for solar 
development. The success of this 
Project will demonstrate the capacity 
for Maricopa County to support solar 
development and attract solar-related 
industries and other renewable 
development. The green hydrogen 
facility is an example of alternative 
energy development opportunities in 
an emerging market with Maricopa 
County having an opportunity to be at 
the forefront of this industry. 
Growth Area Element 
As none of the activities proposed here pertain to urban development, the Growth Area Goals 
and Policies are not applicable. 
Open Space Element 
As none of the activities proposed here pertain to natural park and recreation lands, trail systems, 
or regional parks, the Open Space Element Goals and Policies are not applicable.

19 
 
Land Use Element 
Comprehensive Plan Policies 
Consistency with Comprehensive Plan 
Water Resources Element 
Water Resources 
Policy #2 
Maricopa County supports 
water conservation techniques 
in the planning and design of 
new development. 
Solar development historically uses a 
negligible amount of water for 
maintenance and does not require 
water for the generation of electrical 
power, making it a suitable energy 
resource for arid climates. By 
promoting solar electrical generation, 
the county provides leadership on 
responsible water use by enabling low 
water use infrastructure to provide the 
southwest and western electrical grid 
with a renewable source of energy.  
The green hydrogen facility will require 
water supply for electrolysis; however, 
the conversion of the Project Area from 
cultivated crops to solar generation 
and green hydrogen production will 
result in a substantial decrease in water 
use annually, from 11,000 ac-ft/yr to 
less than 760 ac-ft/year. 
Water Resources 
Policy #5 
Maricopa County supports low 
water use solar electric 
generating technologies. 
The solar facility for the Project does 
not require water in the generation of 
electrical power and requires minimal 
water for panel and equipment 
maintenance. Washing of the panels 
may be necessary if bi-annual rains are 
not sufficient or if dust accumulation is 
considerable enough to warrant further 
cleaning. 
Energy Element 
Energy Goal #1 
Provide leadership to promote 
regional environmental 
quality. 
Solar energy generation will result in 
improved air quality for the county 
through reduced emissions for electric 
generation. Additionally, the 
conversion of land use from cultivated 
crops to energy generation and 
production associated with Project 
development will substantially reduce 
current water demand and result in an 
overall benefit to the already scarce 
water resources available to the 
county. Biological and cultural 
resources will also be appropriately 
protected to prevent or minimize 
impact to these resources. The 
completion of the Project will provide 
an effective framework for future 
sustainable solar energy development 
as well as retain professionals and 
knowledgeable personnel in the area. 
The availability of knowledgeable 
professionals  will more efficiently 
provide leadership for future Projects 
and promote environmental quality for 
renewable resource development. 
Energy Goal #2 
Make Maricopa County a 
leader in alternative energy 
research and development.

20 
 
Land Use Element 
Comprehensive Plan Policies 
Consistency with Comprehensive Plan 
Energy Policy #1 
Maricopa County supports 
energy efficient design and 
construction of new 
development. 
The Project will use current 
technologies and best management 
practices in all stages and components 
to support energy efficient design and 
construction. 
Energy Policy #6 
Maricopa County supports 
being a responsible leader in 
alternative energy research 
and development. 
Approval of the Project will be 
reflective of Maricopa County’s 
leadership in the attraction, promotion, 
and delivery of renewable energy, 
zero-emission resources and 
infrastructure. 
Cost of Development Element 
Cost of Development 
Goal #2 
New development pays its 
proper and reasonable share 
of the costs of new 
infrastructure, services, and 
other public improvements. 
All development costs and fees will be 
borne solely by the Applicant. Should 
such improvements be unexpectedly 
triggered by the Project, the Applicant 
is committed to paying its proper and 
reasonable share of the costs. 
Table 3: Consistency with Area Plan Elements 
Land Use Element 
Area Plan Policies 
Consistency with Area Plans 
Land Use 
Land Use Goal #L1 
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. 
See Comprehensive Plan Land Use 
Goal #1 And Environmental Policy #5. 
There are no designated scenic trails 
within the Project Area. The Project will 
be compatible with existing land uses. 
Objective L1.1:  
Encourage orderly, efficient, 
and functional development 
patterns. 
Objective L1.4 (HWY 
80) 
Preserve the scenic and where 
appropriate, the rural 
character of the Old U.S. 
Highway 80 planning area. 
Transportation (HWY 80) 
Goal T1:  
Provide an efficient, cost-
effective, integrated, 
accessible, environmentally 
sensitive, and safe multi-
modal system that addresses 
existing and future roadway 
networks, and promotes 
transit, bikeways, and 
pedestrian travel. 
See Comprehensive Plan responses: 
Transportation Goal 1 
Transportation Policy 1 
Transportation Policy 2 
Transportation Policy 9 
Objective T1.1:  
Establish a safe, convenient, 
and efficient system for 
existing and future roadways 
while considering the need for 
equestrian and multi-use trails 
access in the Old U.S. Highway 
80 planning area. 
No new roads are proposed outside of 
the Project Area. There are no public 
trails within the Project Area.

21 
 
Land Use Element 
Area Plan Policies 
Consistency with Area Plans 
Transportation (SR 85) 
Goal T1:  
Improve the roadway network 
to meet future transportation 
needs, promote safety, and 
mitigate congestion. 
See Comprehensive Plan responses: 
Transportation Goal 1 
Transportation Policy 1 
Transportation Policy 2 
Transportation Policy 9 
 
The Applicant will coordinate with the 
ADOT and/or MCDOT as needed to 
ensure that any Project access 
improvements meet applicable design 
standards and that any oversize or 
overweight vehicle traffic is properly 
permitted. 
Objective T1.2:  
Minimize traffic congestion on 
regional routes, state 
highways, and urban arterial 
roads. 
Objective T1.4:  
Provide alternatives to 
mitigate conflicts between 
commercial trucking and the 
interests of planning area 
residents. 
Long-term traffic trips are not 
expected as a result of operation of the 
solar project. The Project will assess 
impacts from the green hydrogen 
component associated with 
commercial trucking; however, 
adjacent access to existing major and 
minor roads and the existing 
transportation networks is expected to 
minimize impacts to planning area 
residents. See responses to other 
Transportation goals and objectives 
above. 
Environmental/Environmental Effects 
Goal E1: 
Promote development that 
mitigates adverse 
environmental impacts on the 
natural and cultural 
environment. 
(SR 85) – preserves highly 
valued open space. 
(HWY 80 ) – preserves highly 
valued wildlife habitat, 
minimizes flooding and 
drainage problems, and 
protects historical and 
archaeological resources.  
See response to Comprehensive Plan 
Environmental Goal 1 and Policies 3, 4 
and 5; Land Use Policy 27. 
Objective E1.1: 
Encourage development that 
is compatible with natural 
environmental features. 
See response to Comprehensive Plan 
Environmental Goal 1 and Policies 4 
and 5. 
Objective E1.2: 
Preserve significant natural 
and cultural resources. 
See response to Comprehensive Plan 
Environmental Goal 1 and Policies 4 
and 5. 
Objective E1.3 (HWY 
80): 
Improve air quality, water 
quality, and reduce noise 
impacts. 
See response to the Comprehensive 
Plan Environmental Goal 1 and Policy 7 
as well as Transportation Policy 11 and 
Transportation Policy 12.

22 
 
Land Use Element 
Area Plan Policies 
Consistency with Area Plans 
Objective E1.4 (HWY 
80)/ E1.3 (SR 85): 
Preserve significant habitat 
areas for wildlife and native 
plant species. 
The Project will not impact habitat 
areas for wildlife and plant species. The 
development footprint is concentrated 
in areas of existing agricultural crops. 
Economic Development 
Goal ED1: 
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. 
See Comprehensive Plan response to 
Economic Growth Goals and Policies. 
Objective ED1.1:  
Encourage quality 
employment opportunities by 
supporting efforts that 
encourage business formation 
and expansion. 
See Comprehensive Plan response to 
Economic Growth Goals and Policies 
above. 
Growth Areas 
Goal G.1: 
Promote orderly, timely, and 
fiscally responsible growth in 
Maricopa County/Planning 
Area. 
See Comprehensive Plan response to 
Economic Growth Goals and Policies. 
Objective G.1.1: 
Encourage timely, orderly, and 
fiscally responsible growth 
within the planning area and 
within mixed use 
Development Master Plans.  
See Comprehensive Plan response to 
Economic Growth Goals and Policies. 
Objective G.1.2 (HWY 
80)/ G1.3 (SR 85): 
Ensure that future growth is 
coordinated in an efficient 
manner with stakeholder 
input. 
The Project will involve opportunities 
for public and stakeholder input 
consistent with the Major CPA process. 
Open Space 
Goal O1: 
Maintain and, where 
necessary, encourage 
expanding the open space 
system for Maricopa County 
to address public access, 
connectivity, education, 
preservation, buffering, 
quantity, quality, and diversity 
for regionally significant open 
spaces.  
The Project will avoid native habitat 
areas to the extent feasible and will 
retain washes (Rainbow Wash and 
Layton Wash) to retain access across 
the Project Area for wildlife. There are 
no public open spaces in the area with 
the exception of Bureau of Land 
Management managed lands along the 
Gila River. The Project will not create 
any new barriers to associated public 
access points. 
Objective O1.1: 
Promote physical and visual 
public access to natural open 
space resources.  
There are no existing public spaces in 
the Project Area; the Project will not 
result in loss of access to open space 
resources. 
Objective O1.2: 
Establish regional natural 
open space connectivity and 
linkages for both recreation 
and wildlife purposes. 
The Project will avoid native habitat 
areas to the extent feasible and will 
retain washes (Rainbow Wash and 
Layton Wash) to retain access across 
the Project Area for wildlife.

23 
 
Land Use Element 
Area Plan Policies 
Consistency with Area Plans 
Objective O1.3 (HWY 
80)/OS1.4 (SR 85): 
Protect and enhance 
environmentally sensitive 
areas, including existing 
natural washes; steep slopes; 
historical, cultural, and 
archaeological resources; view 
corridors; sensitive desert; and 
significant wildlife habitat and 
ecosystems. 
See responses above to 
Comprehensive Plan:  
Environment Goal 1 
Environmental Policy 3 
Environmental Policy 4 
Environmental Policy 5 
Water Resources 
Goal W1: 
Promote development that 
makes conservative use of 
renewable water supplies such 
as effluent, surface water, and 
Central Arizona Project water 
when feasible, as well as non-
renewable sources like 
groundwater.  
See Comprehensive Plan response to 
Water Resources Policy 2. 
Objective W1.1: 
Encourage protection and 
enhancement of renewable 
water and groundwater 
supplies within the framework 
of state and federal laws, 
regulations, and guidelines for 
existing and future needs. 
See Comprehensive Plan response to 
Water Resources Policy 2. 
Goal W2: 
Reduce the impacts of 
development on water quality.  
The Project will implement best 
management practices during 
construction to avoid and minimize 
impacts to water quality, See 
Comprehensive Plan response to Water 
Resources Policy 3. 
Objective W2.1 (HWY 
80): 
Encourage voluntary actions 
and support federal, state, and 
local regulations and 
guidelines that protect and 
preserve current and future 
groundwater quality in the 
planning area. 
The Project will utilize existing 
groundwater wells for water supply 
and substantially reduce water use 
from current agricultural demands. 
Goal W2.1 (SR 85) 
Promote the protection and 
preservation of riparian areas 
within the framework of state 
and federal laws, regulations, 
and guidelines. 
The Project will avoid natural open 
space areas to minimize impacts to the 
extent practicable. Impacts will be 
limited to crossings of washes, where 
required, which will be implemented in 
accordance with applicable regulatory 
requirements. 
Cost of Development 
Goal C1: 
Ensure that new development 
pays its fair and proportional 
share of the cost of additional 
public facility and service 
needs generated by new 
development. 
The Project will not require new 
infrastructure, services, and other 
public improvements. Should such 
improvements be unexpectedly 
triggered by the Project, the Applicant 
is committed to paying its proper and 
reasonable share of the costs. 
Notes: 
• 
HWY 80 refers to applicability under the Old U.S. Highway 80 Area Plan

24 
 
• 
SR 85 refers to applicability under the State Route Corridor 85 Area Plan 
6.0 
Other Pertinent Information as Requested by the Maricopa 
County Planning Department Staff. (Application, Part F) 
The Applicant and their consultant Burns & McDonnell are available to provide any additional 
information as requested by Maricopa County Planning Department or by the Technical 
Advisory Committee. 
7.0 Land Use Exhibit 
1. Site Location Map 
2. Land Jurisdiction Map 
3. Current Land Use 
4. Zoning Map 
5. Proposed Land Use 
6. Parcels by Landowner

ATTACHMENT 1 
Parcel Information

Unique 
Number
APN NUMBER
LEGAL 
DESCRIPTION
SURVEY LEVEL LEGAL DESCRIPTION
ZONING
LAND USE
AREA PLAN
MPA
S.F.
ACRES
OWNER
ADDRESS
Legal Description 
Buildable Areas
1 401‐69‐020A
T3S, R4W, Sec. 32
The East ½ of the Southwest ¼ and the East ½ (4) of Section 20, T3S, R4W.
AND
The Northeast ¼ of the Southeast ¼ of the Northeast ¼ (1) and
The West ½ of the Southeast ¼ and the North ½ of the Southeast ¼ of the Southeast 
¼ and the South ½ of the Southeast ¼ of the Southeast ¼ (5)
And
The East ½ of the Northwest ¼ (6)
And
The West ½ of the Northeast ¼ and the Southeast ¼ of the Southeast ¼ of the 
Northeast ¼ and the West ½ of the Southeast ¼ of the Northeast ¼ (7)
And
The Northeast ¼ of the Southeast ¼ (8)
And
The Northeast ¼ of the Northeast ¼ (9)
And
The Northwest ¼ of the Northwest ¼ (R2) And
The East ½ of the Southwest ¼ (R2)
All a part of Section 29, T3S, R4W.
AND
The Northeast ¼ (2) of Section 32, T3S, R4W.
Area = 1095.73 Acres.
The West ½ of the Northwest ¼ of Section 33, T3S, R4W.
RU‐43
Mixed Use & Proposed 
Open Space
Old US 80
Buckeye & Gila 
Bend
47962112
1101.058586 DYM INC
25910 W BASELINE 
RD BUCKEYE AZ USA 
85326
1095.73
2 401‐69‐038
T3S, R4W, Sec. 33
The West ½ of the Northwest ¼ of Section 33, T3S, R4W.
RU‐43
Mixed Use
Old US 80
Gila Bend
3484800
80 DYM INC
25910 W BASELINE 
RD BUCKEYE AZ USA 
85326
78.92
3 401‐69‐041H
T3S, R4W, Sec. 33
A portion of the East ½ of the Northwest ¼ of Section 33, T3S, R4W, said portion 
being more particularly described as follows:
Beginning at the Northwest corner of said East ½ of Northwest ¼, thence S 0° 38’ 32” 
W, along the West line of said East ½ of the Northwest ¼ a distance of 2583.24 feet 
to the Southwest corner of said East ½ of the Northwest ¼;
Thence S 89° 21’ 57” E, along the South line of said East ½ of the Northwest ¼, a 
distance of 167.00 feet;
Thence N 0° 33’ 22” W a distance of 2579.38 feet to the North line of said East ½ of 
the Northwest ¼;
Thence N 88° 05’ 57” W, along said North line, a distance of 171.00 feet to the Point 
of Beginning.
RU‐43
Mixed Use
Old US 80
Gila Bend
435600
10 DYM INC
25910 W BASELINE 
RD BUCKEYE AZ USA 
85326
10.01
4 401‐69‐041K
T3S, R4W, Sec. 33
That portion of the Northeast ¼ and the East ½ of the Northwest ¼ of Section 33, 
T3S, R4W, said portion being more particularly describe as follows:
Beginning at the North ¼ of said Section 33, thence N 87° 31’ 37” W, along the North 
section line of said Section 33, a distance of 1149.69 feet;
Thence S 0° 18’ 30” E a distance of 2571.50 feet to the South line of the North ½ of 
said Section 33;
Thence S 89° 09’ 45” E, along said South line, a distance of 2745.50 feet to the 
Westerly Right‐of‐Way of old U.S. Highway 80;
Thence S 14° 23’ 51” W, along said Westerly Right‐of‐Way line, a distance 146.48 feet 
to a point of curvature;
Thence Northwesterly along said Westerly Right‐of‐Way line, along a curve to the 
left, having a central angle of 2° 26’ 51” and a radius of 11966.82 feet, a distance of 
511.19 feet to the point of tangency;
Thence N 16° 50’ 42” W, along said Westerly Right‐of‐Way line, a distance of 2033.16 
feet to a point on the North section line of said Section 33;
Thence S 88° 46’ 38” W, along said North section line, a distance of 847.38 feet to 
the Point of Beginning.
EXCEPT the following described parcel:
From the North ¼ of said Section 33, thence N 87° 31’ 37” W, along the North section 
line of said Section 33, a distance of 671.58 feet;
Thence S 00° 18’ 30” E a distance of 226.03 feet to the TRUE POINT OF BEGINNING;
Thence continue S 00° 18’ 30” E a distance of 200.00 feet;
Thence N 89° 41’ 30” W a distance of 200.00 feet; Thence N 0° 18’ 30” W a distance 
of 200.00 feet;
Thence S 89° 41’ 30” E a distance of 200.00 feet to the TRUE POINT OF BEGINNING.
All parcels in the Gila and Salt River Meridian, Maricopa County, Arizona.
RU‐43
Mixed Use
Old US 80
Gila Bend
6057759
139.067011 DYM INC
25910 W BASELINE 
RD BUCKEYE AZ USA 
85326
139.56
5 401‐69‐035
T3S, R4W, Sec. 32
The Southeast ¼ of Section 32, T3S, R4W, Gila and Salt River Meridian, Maricopa 
County, Arizona.
RU‐43
Mixed Use
Old US 80
Gila Bend
6969600
160 JOHN FARMS
17850 W ATLANTA 
GOODYEAR AZ USA 
85338
169.25

Unique 
Number
APN NUMBER
LEGAL 
DESCRIPTION
SURVEY LEVEL LEGAL DESCRIPTION
ZONING
LAND USE
AREA PLAN
MPA
S.F.
ACRES
OWNER
ADDRESS
Legal Description 
Buildable Areas
6 401‐63‐001D
T2S, R4W, Sec. 28
The Southwest ¼ of the Southwest ¼, Section 28, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
1742400
40 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
40.03
7 401‐63‐013A
T2S, R4W, Sec. 28
The South ½ of the Southeast ¼, Section 28, T2S, R4W.
RU‐43
Rural Densities (0‐1) & 
Proposed Open Space
SR 85
Buckeye
3484800
80 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
80.05
8 401‐63‐014
T2S, R4W, Sec. 32
The Northeast ¼ of the Northeast ¼, Section 32, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
1742400
40 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
40.05
9 401‐63‐015
T2S, R4W, Sec. 33
The North ½ of the Northwest ¼ and the Northwest ¼ of the Northeast ¼, Section 33, 
T2S, R4W.
RU‐43
Rural Densities (0‐1) & 
Proposed Open Space
SR 85
Buckeye
3484800
80 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
80.09
10 401‐63‐016
T2S, R4W, Sec. 33
The North ½ of the Northwest ¼ and the Northwest ¼ of the Northeast ¼, Section 33, 
T2S, R4W.
RU‐43
Rural Densities (0‐1) & 
Proposed Open Space
SR 85
Buckeye
1742400
40 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
40.04
11 401‐63‐017
T2S, R4W, Sec. 29
The South ½ of the Southeast ¼, Section 29, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
3484800
80 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
80.12
12 401‐63‐018
T2S, R4W, Sec. 29
The Southeast ¼ of the Southwest ¼, Section 29, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
1742400
40 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
40.06
13 401‐63‐019A
T2S, R4W, Sec. 32
All that portion of the West ½ of Section 8, T3S, R4W, lying Southwesterly of the 
Southwesterly Right‐of‐Way line of Old U.S. Highway 80, the Southwesterly Right‐of‐
Way line being more described as follows:
Beginning at the Northwest corner of said Section 8, thence S 01° 21’ 16” E, along 
the West section line of said Section 8, a distance of 1436.03 feet to a point on the 
said Southwesterly Right‐of‐Way;
Thence S 59° 43’ 09” E, along said Southwesterly Right‐of‐Way line, a distance of 
1829.23 feet to a point of curvature;
Thence Southeasterly along said Southwesterly Right‐of‐Way line, along a curve to 
the right, having a central angle of 29° 16’ 27” and a radius of 1860.00 feet, a 
distance of 950.32 feet, to a point of tangency;
Thence S 30° 26’ 42” E, along said Southwesterly Right‐of‐Way line, a distance of 
1007.87 feet to the North‐South centerline of said Section 8;
Thence N 00° 58’ 38” W, along said North‐south centerline, 407.85 feet;
Thence N 30° 40’ 56” W, parallel to the said Southwesterly Right‐of‐Way line, a 
distance of 819.90 feet to a point of curvature; Thence Northwesterly along a curve 
to the left, parallel to said Southwesterly Right‐of‐Way line, having a central angle of 
12° 01’ 12” and a radius of 1407.00 feet, a distance of 295.17 feet to the East‐West 
centerline of said Section 8;
Thence N 88° 41’ 08” E, along said East‐West centerline, a distance of 578.29 feet to 
the Center ¼ of said Section 8;
Thence N 00° 58’ 38” W, along the North‐South centerline of said Section 8, a 
distance of 2653.97 feet to the North ¼ of Section 8;
Thence S 87° 21’ 44” W, along the North section line of said Section 8, a distance of 
2724.32 feet to the Point of Beginning.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
1742400
40 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
40.02

Unique 
Number
APN NUMBER
LEGAL 
DESCRIPTION
SURVEY LEVEL LEGAL DESCRIPTION
ZONING
LAND USE
AREA PLAN
MPA
S.F.
ACRES
OWNER
ADDRESS
Legal Description 
Buildable Areas
14 401‐63‐019B
T2S, R4W, Sec. 32
All that portion of the West ½ of Section 8, T3S, R4W, lying Southwesterly of the 
Southwesterly Right‐of‐Way line of Old U.S. Highway 80, the Southwesterly Right‐of‐
Way line being more described as follows:
Beginning at the Northwest corner of said Section 8, thence S 01° 21’ 16” E, along 
the West section line of said Section 8, a distance of 1436.03 feet to a point on the 
said Southwesterly Right‐of‐Way;
Thence S 59° 43’ 09” E, along said Southwesterly Right‐of‐Way line, a distance of 
1829.23 feet to a point of curvature;
Thence Southeasterly along said Southwesterly Right‐of‐Way line, along a curve to 
the right, having a central angle of 29° 16’ 27” and a radius of 1860.00 feet, a 
distance of 950.32 feet, to a point of tangency;
Thence S 30° 26’ 42” E, along said Southwesterly Right‐of‐Way line, a distance of 
1007.87 feet to the North‐South centerline of said Section 8;
Thence N 00° 58’ 38” W, along said North‐south centerline, 407.85 feet;
Thence N 30° 40’ 56” W, parallel to the said Southwesterly Right‐of‐Way line, a 
distance of 819.90 feet to a point of curvature; Thence Northwesterly along a curve 
to the left, parallel to said Southwesterly Right‐of‐Way line, having a central angle of 
12° 01’ 12” and a radius of 1407.00 feet, a distance of 295.17 feet to the East‐West 
centerline of said Section 8;
Thence N 88° 41’ 08” E, along said East‐West centerline, a distance of 578.29 feet to 
the Center ¼ of said Section 8;
Thence N 00° 58’ 38” W, along the North‐South centerline of said Section 8, a 
distance of 2653.97 feet to the North ¼ of Section 8;
Thence S 87° 21’ 44” W, along the North section line of said Section 8, a distance of 
2724.32 feet to the Point of Beginning.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
1742400
40 LADERA LLC
2221 W BASELINE 
RD 101 TEMPE AZ 
USA 85283
40.03
15 401‐66‐013C
T3S, R4W, Sec. 6
All of the Southeast ¼ of Section 6, T3S, R4W, Gila and Salt River Meridian, Maricopa 
County, Arizona, lying Northeasterly of the Northeasterly Right‐of‐Way line of Old 
U.S. Highway 80
RU‐43
Rural Densities (0‐1) & 
Proposed Open Space
Old US 80 & SR 
85
Buckeye
1997226
45.85 PATTERSON 152 LLC
5080 N 40TH ST STE 
205 PHOENIX AZ 
USA 85018
47.86
16 401‐66‐013D
T3S, R4W, Sec. 6
All of the Southeast ¼ of Section 6, T3S, R4W, Gila and Salt River Meridian, Maricopa 
County, Arizona, lying Northeasterly of the Northeasterly Right‐of‐Way line of Old 
U.S. Highway 80
RU‐43
Rural Densities (0‐1)
Old US 80
Buckeye
4645238
106.6399908 PATTERSON 152 LLC
5080 N 40TH ST STE 
205 PHOENIX AZ 
USA 85018
103.41
17 401‐66‐015Q
T3S, R4W, Sec. 7
That portion of the East ½ of Section 7, T3S, R4W, more particularly described as 
follows:
Beginning at the Southeast section corner of said Section 7, thence S 88° 57’ 02” W, 
along the South section line, a distance of 1537.00 feet;
Thence N 10° 15’ 11” W a distance of 20.23 feet;
Thence N 19° 25’ 23” W a distance of 182.96 feet;
Thence N 2° 06’ 19” E a distance of 54.71 feet;
That portion of the East ½ of Section 7, T3S, R4W, more particularly described as 
follows:
Beginning at the Southeast section corner of said Section 7, thence S 88° 57’ 02” W, 
along the South section line, a distance of 1537.00 feet
RU‐43
Mixed Use
Old US 80
Buckeye
5552455
127.4668274 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
129.51
18 401‐66‐017B
T3S, R4W, Sec. 8
All of that portion of the Southeast ¼ of Section 8, T3S, R4W, lying Southwestery 
Right‐of‐Way line of old U.S. Highway 80, said Westerly Right‐of‐Way line being more 
particularly described as follows:
From the South ¼ of said Section 8, thence N 1° 07’ 20” W along the North‐South 
centerline of said Section 8, a distance of 1238.64 feet to the said Southwesterly 
Right‐of‐Way line;
Thence S 30° 56’ 41” E, along said Southwesterly Right‐of‐Way line, a distance of 
1435.06 feet to the South section line of said Section 8, from which the South ¼ 
bears N 89°56’ 41” W a distance of 702.92 feet.
RU‐43
Mixed Use & Rural 
Densities (0‐1)
Old US 80
Buckeye
625768
14.36565657 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
9.99
19 401‐66‐018B
T3S, R4W, Sec. 8
All that portion of the West ½ of Section 8, T3S, R4W, lying Southwesterly of the 
Southwesterly Right‐of‐Way line of Old U.S. Highway 80, the Southwesterly Right‐of‐
Way line
RU‐43
Mixed Use & Rural 
Densities (0‐1)
Old US 80
Buckeye
6321384
145.1190083 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
141.63
20 401‐66‐019A
T3S, R4W, Sec. 8
All that portion of the West ½ of Section 8, T3S, R4W, lying Southwesterly of the 
Southwesterly Right‐of‐Way line of Old U.S. Highway 80, the Southwesterly Right‐of‐
Way line
RU‐43
Mixed Use
Old US 80
Buckeye
926481
21.26907713 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
24.69
21 401‐66‐029G
T3S, R4W, Sec. 8
All of that portion of the Southeast ¼ of Section 8, T3S, R4W, lying Southwestery 
Right‐of‐Way line of old U.S. Highway 80, said Westerly Right‐of‐Way line being more 
particularly described as follows:
From the South ¼ of said Section 8, thence N 1° 07’ 20” W along the North‐South 
centerline of said Section 8, a distance of 1238.64 feet to the said Southwesterly 
Right‐of‐Way line;
Thence S 30° 56’ 41” E, along said Southwesterly Right‐of‐Way line, a distance of 
1435.06 feet to the South section line of said Section 8, from which the South ¼ 
bears N 89°56’ 41” W a distance of 702.92 feet.
RU‐43
Mixed Use
Old US 80
Buckeye
452024
10.37704316 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
10.39

Unique 
Number
APN NUMBER
LEGAL 
DESCRIPTION
SURVEY LEVEL LEGAL DESCRIPTION
ZONING
LAND USE
AREA PLAN
MPA
S.F.
ACRES
OWNER
ADDRESS
Legal Description 
Buildable Areas
22 401‐66‐029H
T3S, R4W, Sec. 17
All that part of Section 17, T3S, R4W, lying Southwesterly of the Southwesterly Right‐
of‐Way line of old U.S. Highway 80, the Southwesterly Right‐of‐Way line being more 
particularly described as follows:
From the North ¼ of said Section 17, thence S 89° 56’ 41” E, along the North section 
line of said Section 17, a distance of 702.92 feet to the True Point of Beginning;
Thence S 30° 24’ 15” E, along said Southwesterly Right‐of‐Way line, a distance of 
3782.68 feet to the East section line of said Section 17, the End of said Southwesterly 
Right‐of‐Way line, from which the Southeast section corner of said Section 17 bears S 
2° 31’ 28” W a distance of 2040.99 feet.
RU‐43
Mixed Use
Old US 80
Buckeye
24549983
563.5900597 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
559.98
23 401‐66‐034A
T3S, R4W, Sec. 18
A portion of the East ½ of Section 18, T3S, R4W, said portion being more particularly 
described as follows:
Beginning at the Northeast section corner of said Section 18, thence Westerly along 
the North section line of said Section 18, a distance of 1537.00 feet;
Thence Southeasterly 5424.2 feet, more or less, to a point on the South section line 
of said Section 18;
Thence Easterly along the said South section line a distance of 428.3 feet to the 
Southeast section corner of said Section 18.
RU‐43
Mixed Use & Proposed 
Open Space
Old US 80
Buckeye
10690495
245.4199954 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
47.07
24 401‐66‐034B
T3S, R4W, Sec. 18
A portion of the East ½ of Section 18, T3S, R4W, said portion being more particularly 
described as follows:
Beginning at the Northeast section corner of said Section 18, thence Westerly along 
the North section line of said Section 18, a distance of 1537.00 feet;
Thence Southeasterly 5424.2 feet, more or less, to a point on the South section line 
of said Section 18;
Thence Easterly along the said South section line a distance of 428.3 feet to the 
Southeast section corner of said Section 18.
RU‐43
Mixed Use
Old US 80
Buckeye
3248705
74.58000459 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
71.16
25 401‐69‐004B
NA/NA/ Sec. 19
A portion of the Northeast ¼ of Section 19, said portion being more particularly 
described as follows:
Beginning at the Northeast section corner of said Section 19, thence Westerly along 
the North section line of said Section 19 a distance of 428.3 feet; Thence 
Southeasterly 1383.3 feet, more or less, to a point on the East section line of said 
Section 19;
Thence Northerly along said East section line, a distance of 1327.32 feet to the Point 
of Beginning.
RU‐43
Mixed Use & Proposed 
Open Space
Old US 80
Buckeye
12196800
280 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
6.52
26 401‐69‐006A
T3S, R4W, Sec. 20
The West ½ of the Southwest ¼ and the Northwest ¼ of Section 20. T3S, R4W.
RU‐43
Mixed Use & Proposed 
Open Space
Old US 80
Buckeye
4642189
106.5699954 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
108.24
27 401‐69‐006B
T3S, R4W, Sec. 20
The West ½ of the Southwest ¼ and the Northwest ¼ of Section 20. T3S, R4W.
RU‐43
Mixed Use
Old US 80
Buckeye
5812211
133.4300046 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
133.37
28 401‐69‐007D
T3S, R4W, Sec. 21
A portion of the West ½ of Section 21, T3S, R4W, lying West of the Westerly Right‐of‐
Way line of the old U.S. Highway 80, said Westerly Right‐of‐Way line being more 
particularly described as follows:
Beginning at the Northwest corner of said Section 21, thence N 89° 35’ 34” E, along 
the North line of said Section 21, a distance of 837.65 feet to the said Westerly Right‐
of‐Way line;
Thence S 17° 27’ 00” E, along said Westerly Right‐of‐Way line, a distance of 1956.12 
feet to a point of curvature;
Thence Southwesterly along said Westerly Right‐of‐Way line, along a curve to the 
right, having a central angle of 2° 45’ 15” and a radius of 11393.77 feet, a distance of 
547.69 feet to a point of tangency;
Thence S 14° 41’ 45” E, along said Westerly Right‐of‐Way line, a distance of 1612.35 
feet to a point of curvature;
Thence Southeasterly along said Westerly Right‐of‐Way line, along a curve to the 
right, having a central angle of 3° 08’ 19” and a radius of 11331.06 feet, a distance of 
620.70 feet to a point of tangency;
Thence S 11° 33’ 26” E a distance of 743.13 feet to a point on the South section line 
of said section 21; Thence S 89° 32’ 59” W, along said South section line, a distance 
of 1960.47 feet, from which the Southwest section corner of said Section 21, bears S 
89° 32’ 59” W a distance of 200.00 feet;
Thence N 1° 57’ 14” W a distance of 200.00 feet;
Thence S 89° 32’ 59” W a distance of 200.00 feet to the said West section line of said 
Section 21, from which the said Southwest section corner bears S 1° 57’ 14” E a 
distance of 200.00 feet;
Thence N 1° 57’ 14” W, along said West section line, a distance of 2453.56 feet to the 
West ¼ of said Section 21;
Thence N 0° 31’ 07” W, along said West section line, a distance of 2644.09 feet to the 
Point of Beginning.
EXCEPT THE South 33 feet of said Section 21.
RU‐43
Mixed Use
Old US 80
Buckeye
8286854
190.2399908 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
189.37

Unique 
Number
APN NUMBER
LEGAL 
DESCRIPTION
SURVEY LEVEL LEGAL DESCRIPTION
ZONING
LAND USE
AREA PLAN
MPA
S.F.
ACRES
OWNER
ADDRESS
Legal Description 
Buildable Areas
29 401‐72‐004B
T4S, R4W, Sec. 5
A portion of the East ½ of Section 5, T4S, R4W, said portion being more particularly 
described as follows:
Beginning at the North ¼ of said Section 5, thence N 89° 45’ 03” E, along the North 
section line of said Section 5, a distance of 229.43 feet;
Thence S 11° 41’ 24” E a distance of 321.93 feet;
Thence S 50° 52’ 34” E a distance of 593.46 feet;
Thence S 88° 56’ 05” E a distance of 461.86 feet;
Thence S 0° 49’ 42” W a distance of 580.89 feet;
Thence N 89° 46’ 05” E a distance of 1365.21 feet to a point on the East section line 
of said Section 5;
Thence S 1° 04’ 50” W, along the said East section line, a distance of 3983.76 feet to 
the Southeast Section corner; Thence N 89° 59’ 07” W, along the South section line 
of said Section 5, a distance of 2695.11 feet to the South ¼ of said Section 5;
Thence N 0° 34’ 24” E, along the North‐South centerline of said Section 5, a distance 
of 5298.25 feet to the Point of Beginning.
RU‐190
Small Lot Residential (2‐
5) & Proposed Open 
Space
Old US 80
Gila Bend
11898870
273.1604683 STRUCTURES 
INVESTMENT LLC
1635 N GREENFIELD 
RD STE 106 MESA 
AZ USA 85205
273.37
30 401‐63‐002
T2S, R4W, Sec. 31
The North 925 feet and the West 300 feet of the South ½ of Section 31, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85 & Old US 
80
Buckeye
7322872
168.1100092 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
PO BOX 1479 
BUCKEYE AZ USA 
85326
71.659
31 401‐63‐003
T2S, R4W, Sec. 32
The North 925 feet of the Southwest ¼ of Section 32, T2S, R4W.
RU‐43
Rural Densities (0‐1) & 
Proposed Open Space
SR 85
Buckeye
6969600
160 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
PO BOX 1479 
BUCKEYE AZ USA 
85326
56.03
32 401‐63‐004
T2S, R4W, Sec. 32
The South ½ of the Northeast ¼ of Section 32 and the Southeast ¼ of the Northwest 
¼ of Section 32, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
3484800
80 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
PO BOX 1479 
BUCKEYE AZ USA 
85326
80.1
33 401‐63‐005
T2S, R4W, Sec. 32
The South ½ of the Northeast ¼ of Section 32 and the Southeast ¼ of the Northwest 
¼ of Section 32, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
1742400
40 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
PO BOX 1479 
BUCKEYE AZ USA 
85326
40.04
34 401‐63‐006A
T2S, R4W, Sec 32
The Northwest ¼ of the Southeast ¼, Section 32, T2S, R4W.
RU‐43
Rural Densities (0‐1) & 
Proposed Open Space
SR 85
Buckeye
3530925
81.0588843 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
PO BOX 1479 
BUCKEYE AZ USA 
85326
39.99
35 401‐63‐007
T2S, R4W, Sec. 33
The Southwest ¼ of the Northwest ¼ of Section 33, T2S, R4W.
RU‐43
Rural Densities (0‐1) & 
Proposed Open Space
SR 85
Buckeye
1742400
40 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
PO BOX 1479 
BUCKEYE AZ USA 
85326
40.03
36 401‐63‐020
T2S, R4W, Sec. 32, 
Sec. 31
The Southwest ¼ of the Northwest ¼ of Section 32 and The East ½ of the Southeast ¼ 
of the Northeast ¼, Section 31, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
1742400
40 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
PO BOX 1479 
BUCKEYE AZ USA 
85326
40.03
37 401‐63‐021B
T2S, R4W, Sec. 32, 
Sec. 31
The Southwest ¼ of the Northwest ¼ of Section 32 and The East ½ of the Southeast ¼ 
of the Northeast ¼, Section 31, T2S, R4W.
RU‐43
Rural Densities (0‐1)
SR 85
Buckeye
1400409
32.14896694 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
PO BOX 1479 
BUCKEYE AZ USA 
85326
20.09
38 401‐66‐012E
T3S, R4W, Sec. 6
That portion of the West ½ of Section 6, T3S, R4W, Gila and Salt River Meridian, 
Maricopa County, Arizona, said portion being North and East of the Easterly Right‐of‐
Way line of the Gila Bend canal as shown on said map.
RU‐43
Rural Densities (0‐1)
Old US 80
Buckeye
1955970
44.90289256 VANDERHART TIMOTHY / 
BARRERAS MARIA 
TERESA CORRAL
47.84
39 401‐66‐012N
6/3S/4W
County Updated Data Pending Availability
RU‐43
Rural Densities (0‐1)
Old US 80
Buckeye
1280426
29.39453627
40 401‐66‐012Q
6/3S/4W
County Updated Data Pending Availability
RU‐43
Rural Densities (0‐1)
Old US 80
Buckeye
200992
4.614141414
41 401‐66‐012R
6/3S/4W
County Updated Data Pending Availability
RU‐43
Rural Densities (0‐1)
Old US 80
Buckeye
272435
6.254247016
TOTAL
5028.43315
4266.329

August 3, 2023
Mr. Andrew Lorentzen
Maricopa County, Planning and Development
301 W. Jefferson Street, Suite 170
Phoenix, Arizona 85003
Electronically submitted to Andrew.lorentzen@maricopa.gov
RE:
Desert Gem Solar and Storage (CPA2023013)
Dear Mr. Lorentzen:
The Arizona Game and Fish Department (Department) appreciates the opportunity to review the
proposed Desert Gem Solar and Storage project. The Department understands that Desert Gem
Solar and Storage, LLC, a subsidiary of
Origis Energy, proposes to construct a 540 MW
photovoltaic (PV) solar facility with a battery energy storage system (BESS) and associated
infrastructure, along with a green hydrogen production facility and infrastructure, on an
approximately 4,297-acre leased parcel in Maricopa County, Arizona. The facility would be
located along Old Highway 80, northeast of Gila Bend and south of Buckeye, in primarily
undeveloped agricultural lands. An approximately 7.5-mile 230-kilovolt (kV) or 500kV
generation interconnection (gen-tie) transmission line would connect the facility to either the
existing Salt River Project (SRP) Jojoba Substation or the adjacent Arizona Public Services
(APS) Komatke Substation.
Under Title 17 of the Arizona Revised Statutes, the Department, by and through the Arizona
Game and Fish 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 Origis Energy, Burns & McDonnell, and Maricopa County during the planning and
development of this 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

Desert Gem Solar and Storage (CPA2023013)
August 4, 2023
Page 2
during development and operation of the facilities. For your consideration, the Department
provides the following comments based on the agency's statutory authorities, public trust
responsibilities, and special expertise related to wildlife resources and recreation.
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 have been
built or proposed within the vicinity of this project. Although each of these projects individually
may have a minimal impact on the broader landscape, these projects cumulatively could 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 cumulative effects and to
1
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.
Maintaining habitat connectivity is a priority for the Department, and wildlife movement
corridors are important for wildlife to respond to changing environmental conditions. This
project bisects the Gila Bend - Sierra Estrella Linkage Design, a corridor designed to conserve
and enhance wildlife movement between large areas of BLM administered lands (Beier et. al.
2008 ). It also lies directly adjacent to the Gila River Maricopa County Wildlife Movement
2
Riparian Area and is in the vicinity of three identified important connectivity zones for wildlife
movement. The Department would like to meet with Origis, Burns & McDonnell, and Maricopa
County to discuss opportunities to incorporate wildlife connectivity into the project design,
including the following:
●
The Department appreciates the applicant’s commitment to avoiding development within
the Gila River, large washes, and natural waterways such as Rainbow and Layton washes,
and recommends including additional setbacks within upland habitats to help reduce
potential impacts to connectivity and to help conserve the multiple functions these
washes serve in the ecosystem. Not only do they provide for hydrologic flow, which is
especially important in areas that receive infrequent and isolated precipitation events, but
these washes also serve as important landscape-level conveyance corridors for wildlife
movement. The Department also recommends incorporating open, unfenced corridors
across the project area in alignment with existing crossings over the Gila Bend canal into
the project design to facilitate and maintain wildlife movement within the Gila Bend -
Sierra Estrella Linkage.
●
The Department recommends that Origis Energy conduct minimal grading in the project
area and, to the extent possible, retain habitat features underneath the panels, including
vegetation and soils. 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 ).
3
3 https://www.nature.com/articles/s41893-020-0574-x
2 https://conservationcorridor.org/cpb/Beier_et_al_2008-GilaBend-SierraEstrella.pdf
1 https://esajournals.onlinelibrary.wiley.com/doi/10.1002/fee.2498

Desert Gem Solar and Storage (CPA2023013)
August 4, 2023
Page 3
●
The Department’s Wildlife Compatible Fencing Guidelines provide information on how
4
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 on 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.
The proposed project occurs within 3.5 miles of the southwestern portion of the Lower Salt and
Gila River Ecosystem Important Bird Area (IBA), which is of state and regional significance
5
and serves as breeding ground for the Yuma ridgway's rail, which is listed as endangered under
the Endangered Species Act (ESA), and numerous other avian species, including several species
of concern. Additionally, endangered Southwestern willow flycatcher and Yuma ridgway’s rail
have been observed along the western edge of the project in pockets of wooded riparian areas
associated with the Gila River and Layton Wash. The Department has concerns regarding the
potential for bird fatalities or injuries (i.e., bird strikes) if avian species mistake the solar panels
for open water. Large-scale solar photovoltaic facilities can result in bird mortality due to habitat
loss, collision with panels, attraction due to an optical illusion of water, and unknown causes
(Kosciuch et al. 2020 ). The Department would welcome the opportunity to explore conservation
6
measures with Origis Energy that aim to reduce potential impacts to rails and other avian species,
such as:
●
Use of non-reflective coatings on the solar panels. Although some daytime reflectivity
would still be expected, non-reflective coatings on the solar panels can reduce the
appearance of the array as a body of water and reduce the attraction of birds to the site.
●
To the extent feasible, maximizing the spacing between solar panels to reduce the “lake
effect,” in which continuous or closely-spaced panel arrays create an optical illusion of
water.
●
The Department encourages Origis Energy to implement post-construction monitoring
for avian and other wildlife injuries and fatalities. Recommendations for monitoring
design and frequency can be found in the U.S. Geological Survey’s 2016 Mortality
Monitoring Design for Utility-Scale Solar Power Facilities . Any avian injuries or
7
fatalities should be reported both to the Department and by using the U.S. Fish and
Wildlife Service’s Injury and Mortality Reporting
website. Department staff are
8
available to assist in developing the monitoring protocol and to further refine the
monitoring and reporting recommendations in order to develop feasible and repeatable
protocols to be implemented during operations. The Department is also available to help
determine adaptive management measures based on results of the post-construction
monitoring. For example, the U.S. Geological Survey has been conducting research that
8 https://ecos.fws.gov/imr/welcome
7 https://pubs.usgs.gov/of/2016/1087/ofr20161087.pdf
6 https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0232034
5 https://aziba.org/?page_id=531
4 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/
110125_AGFD_fencing_guidelines.pdf

Desert Gem Solar and Storage (CPA2023013)
August 4, 2023
Page 4
indicates birds are most attracted to solar arrays around midday, and tilting of panels
during key times of strikes could reduce bird attraction.
●
If uncertain about potential effects of this project to Yuma ridgway’s rail or Southwestern
willow flycatcher, or if it is anticipated the project will not be in compliance with the
ESA, the Department recommends that Origis Energy contact the U.S. Fish and Wildlife
Service (USFWS) for technical assistance and options to comply with the ESA.
9
The Department recommends conducting surveys in the project area 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 Origis Energy and Burns & McDonnell in determining appropriate
surveys to conduct and design features and best management practices that can help minimize
potential impacts. Based on the information provided, the Department offers the following
recommendations to reduce potential impacts to wildlife and habitat; additional information can
be found in Guidelines for Solar Development in Arizona :
10
●
The project site falls within the 10(j) recovery area for Sonoran Pronghorn. While it is not
anticipated that pronghorn will occur in the area due to the lack of suitable habitat, if
pronghorn are detected during project activities, please notify the USFWS and the
Department’s Sonoran Pronghorn Program Lead (jbright@azgfd.gov) as soon as possible.
●
The Sonoran desert tortoise, which is a federal and state species of special concern, has
been documented within less than a mile of the project area. If tortoises are identified
during project activities, please refer to and implement the Recommended Standard
Mitigation Measures for Projects in Sonoran Desert Tortoise Habitat
and Guidelines for
11
Handling Sonoran Desert Tortoises Encountered on Development Projects .
12
●
As stated in the project narrative, the western burrowing owl, a special status species that
is regulated under the Migratory Bird Treaty Act (MBTA), has been documented within
the project area. The Department appreciates that the species will be managed in
accordance with its guidelines, which include conducting occupancy surveys in advance
of the design phase to understand distribution of burrowing owls in the project site;
avoidance of a large burrowing owl population may be advisable over removal or other
conservation measures. Guidelines for conducting this survey are found in Burrowing
Owl Project Clearance Guidance for Landowners . Please note that the survey should be
13
conducted by a surveyor who is certified by the Department or has similar training and
qualifications. If an active burrowing owl burrow is detected, please contact the
Department and the USFWS for direction, in accordance with the guidelines.
●
The Department recommends that the applicant conduct avian surveys during the
planning stage in order to better understand species presence and to inform potential
13 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/nongame/eagles/BurrowingOwl
ClearanceProtocol_2009.pdf
12 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/2014%20Tortoise%20handling%20guidelines.pdf
11 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/MitigationMeasures.pdf
10 https://s3.amazonaws.com/azgfd-portal-wordpress/PortalImages/files/wildlife/planningFor/wildlifeFriendlyGuidelines/
FinalSolarGuidelines03122010.pdf
9 https://www.fws.gov/office/arizona-ecological-services/contact-us

Desert Gem Solar and Storage (CPA2023013)
August 4, 2023
Page 5
conservation measures. Point counts are the preferred method for breeding bird surveys.
These surveys are conducted twice a year during the peak breeding season, which is
mid-January through June in this area; McLaren et al. (2019)
outline protocols.
14
Additional surveys for Bendire’s and LeConte’s thrashers, two bird species of
conservation concern, are recommended; a draft protocol
from the Desert Thrashers
15
Working Group
is available online.
16
●
The Department appreciates that surveys will be conducted for nesting birds prior to
vegetation removal and/or construction activities that occur during the breeding season.
The vegetation within the project area may provide nesting opportunities for avian
species that are regulated under the Migratory Bird Treaty Act (MBTA). Due to the
proximity to the Gila River and the Lower Salt and Gila River IBA, federally listed
species have the potential to nest in the project vicinity. If it is anticipated the project will
not be in compliance with MBTA, the Department recommends contacting the USFWS
for technical assistance.
●
The Department recommends following standards established by the Avian Power Line
Interaction Committee (APLIC) for new power lines, which can be found in Suggested
Practices for Avian Protection on Power Lines: The State of the Art in 2006
and
17
Reduced Avian Collisions with Power Lines: The State of the Art in 2012 . Tuk
18
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.
●
Burrowing species could occur within the project area and could be influenced by
construction activities and by loss of habitat. Surveys for these species are recommended
to determine their presence and to inform pre-construction activities. Department staff are
available to assist in identifying suitable conservation measures, such as one-way
exclosures on burrows that allow wildlife to exit the burrows and disperse to adjacent
lands in advance of construction.
●
A variety of other Arizona Species of Greatest Conservation Need (SGCN) have the
potential to occur within the project area. If wildlife are encountered during project
activities, the Department recommends moving them out of harm’s way, 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 , that includes the most recent list of
19
SGCN to help navigate and identify conservation opportunities.
Finally, the Department offers the following general recommendations to reduce potential
impacts to wildlife and habitat during construction and operation of the facility:
19 https://awcs.azgfd.com
18 https://www.aplic.org/uploads/files/15518/Reducing_Avian_Collisions_2012watermarkLR.pdf
17 https://www.aplic.org/uploads/files/2643/SuggestedPractices2006(LR-2).pdf
16 https://borderlandsbirds.org/projects/desert-thrasher/
15 https://drive.google.com/drive/folders/1d9L8Su0HPbBzo2oGSH4H2xqrwOqHpT1o?usp=sharing
14 https://www.birdconservancy.org/wp-content/uploads/2021/03/2020-Field-Protocol-for-Spatially-Balanced-Sampling.pdf

Desert Gem Solar and Storage (CPA2023013)
August 4, 2023
Page 6
●
The Department appreciates that native habitat and drainages will be avoided to the
extent practicable and the commitment to comply with Arizona Native Plant Law
regulations
if protected native plants are identified on site prior to construction that
20
must be removed.
●
To minimize the potential introduction or spread of exotic invasive species, including
aquatic and terrestrial plants, animals, insects, and pathogens, the Department encourages
Origis Energy to take precautions to wash and/or decontaminate equipment before
entering and leaving the site. See the Arizona Department of Agriculture website
for a
21
list of prohibited and restricted noxious weeds and the Arizona Native Plant Society
for
22
recommendations on how to control them. To view a list of documented invasive species
or to report invasive species in or near the project area, visit iMapInvasives , which is a
23
national cloud-based application for tracking and managing invasive species.
●
The Department places a high priority on conserving existing public access and modes of
access for hunting, fishing, trapping, shooting, wildlife watching, off-highway vehicle
use, dispersed camping, and other responsible forms of outdoor recreational use on public
lands. While a majority of the project is sited on private lands, the Department requests
that, if there are access roads currently open to the public within the project site that
allow passage
into adjacent public lands, that these remain open or rerouted if at all
feasible.
●
If trenching or digging of large holes necessary for anchoring project infrastructure will
occur for the proposed project, the Department recommends trenching/digging and
backfilling crews be close together to minimize the amount of open holes at any given
time. Where trenches or holes cannot be back-filled immediately, the Department
recommends escape ramps be constructed in each hole and at least every 90 meters in
trenches. Escape ramps can be short lateral trenches or wooden planks sloping to the
surface. The Department recommends that slopes be less than 45 degrees (1:1) and
trenches and holes that have been left open be inspected to remove animals prior to
backfilling.
●
The Department recommends that Origis Energy revegetate 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
24
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.
24 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3657119
23 https://imap.natureserve.org/imap/services/page/map.html
22 https://aznps.com/invas
21 https://agriculture.az.gov/pestspest-control/agriculture-pests/noxious-weeds
20 https://agriculture.az.gov/plantsproduce/native-plants

Desert Gem Solar and Storage (CPA2023013)
August 4, 2023
Page 7
Thank you for the opportunity to provide input on the Desert Gem Solar and Storage Project. For
further coordination, please contact Teigan Williams at tstruck@azgfd.gov or (928) 341-4069.
Sincerely,
Michael Sumner
Regional Supervisor, Region IV
cc:
Tyler Williford – Habitat, Evaluation, and Lands Program Manager, Region IV
Ginger Ritter – Project Evaluation Program Supervisor
Tiffany Sprague – Project Evaluation Program Specialist
Kelly Wolff – Habitat, Evaluation, and Lands Program Manager, Region VI
AZGFD #M23-07073759

1
Andrew Lorentzen (PND)
From:
RAHN, JENNIFER L CIV USAF AETC 56 FW/CVE <jennifer.rahn@us.af.mil>
Sent:
Thursday, July 13, 2023 11:39 AM
To:
Andrew Lorentzen (PND)
Cc:
56 FW/CIT Community Initiative; PADILLA, JOHN G CIV USAF AETC 56 FW/RMO; GILLIES, WILLIAM A 
JR CIV USAF AETC 56 RMO/ASM
Subject:
RE: CPA2023013 - Desert Gem Solar and Storage Project - Major CPA (Outside Routing)
Good afternoon Mr. Lorentzen, 
 
Thank you for the opportunity to provide comments on the Comprehensive Major Plan Amendment application 
for the proposed Desert Gem Solar and Storage Project. This application proposes the rezoning of 5,034.69 acres for the 
development of solar storage, BESS, and hydrogen facilities.  The proposed location runs predominantly west of Old 
Highway 85 and approximately 10.5 miles north, northeast of Gila Bend and 10.5 miles south of Buckeye in 
unincorporated Maricopa County, AZ.  The parcel is outside of the Luke AFB 1988 JLUS 65 Ldn “high noise or accident 
potential zone” as identified by A.R.S. § 28-8461 and is outside the “territory in the vicinity of a military airport” also 
defined by A.R.S. § 28-8461.  However, the area is located under several military training routes and possible low-level 
flying routes. 
 
            We continually appreciate the opportunity to provide comments, acknowledging that we are not the approval 
authority.  Given the location of this development project, we have identified actual and/or potential mission risks and 
hazards should the development encompass the following:   
 
a. Light interference – Buildings or structures that would produce light interference at night and or 
glint/glare during the day that would distract or interfere with pilot vision.   
b. Spectrum utilization and radio frequency interference – Buildings or structures that would cause a loss 
of RADAR coverage such that it interferes with spectrum utilization.  Additionally, to avoid radio 
frequency interference, developers and or end users should not use radio equipment that would interfere 
with Luke’s frequency or operate on a military frequency.   
c. Impairment of pilot’s visibility – Any production that would release substances into the air that would 
impair visibility or otherwise interfere with operating aircraft such as:  steam, dust or smoke.  These 
items create a negative impact and should be eliminated. 
d. Bird Strike Hazard – Cooling ponds or standing water on the property increase the potential for the 
congregation of fowl which are a hazard to flight safety and therefore the community. Mitigation 
measures to detract fowl from congregating on the property are highly encouraged. 
 
Luke AFB follows A.R.S. § 28-8481 when evaluating compatible land use within the “territory in the vicinity of a 
military airport”.  Subject to the results of an FAA Obstruction Evaluation/Airport Airspace Analysis and Spectrum 
Analysis (OE/AAA), this request will not negatively impact the flying and base operations at Luke AFB; however, we 
reserve the right to comment as the development matures and site plans become available.  The location of tall equipment, 
final tie-in’s, the construction of additional transmission lines, and the hydrogen facility would be the prominent areas for 
in-depth review.  
 
            Even though the development will be located outside the “territory in the vicinity of a military airport,” it will be 
subjected to approximately 170 over flights a day.  We recommend you review the sound attenuation requirements found 
in A.R.S. § 28-8482.  In addition, a strong notification program on the part of the applicant is essential to inform potential 
occupants about Luke AFB operations.  We also recommend that the developer and/or future occupant(s) be made aware 
that the proposed development is underneath the Luke AFB to Barry M. Goldwater flight traffic pattern, specifically low-

2
level flights; therefore, there is an increased risk of accidents in that area as well as fuel dumping or jettison of external 
aircraft tanks. 
 
Respectfully, 
 
Jenn Rahn 
Senior Planner, Community Initiatives Team 
56th Fighter Wing 
Luke AFB AZ 85309 
Office:  623‐856‐9981 
DSN:  896‐9981 
 
 
From: Andrew Lorentzen (PND) <Andrew.Lorentzen@maricopa.gov>  
Sent: Thursday, July 6, 2023 8:06 AM 
To: gramirez@azdot.gov; redletter@azdot.gov; bfenske@azdot.gov; jgarcia@azdot.gov; DougCNelson@cox.net; 
Jon.Lacy@bvfd.az.gov; Mark.burdick@bvfd.az.gov; admin@bvfd.az.gov; dhenning@westvalleyview.com; 
kgalica@buckeyeaz.gov; swilken@azmag.gov; kcotner@azmag.gov; agarza@azmag.gov; pe@azland.gov; 
Dkrantz@citytocitycre.com; Frank McWilliams (MCSO) <FrankMcWilliams@MCSO.maricopa.gov>; tsprague@azgfd.gov; 
pep@azfgd.gov; twilliford@azgfd.gov; tstruck@azgfd.gov; 56 FW/CIT Community Initiative 
<56FW.CIT.CommunityInitiative@us.af.mil>; Teresa Retterbush (PRK) <Teresa.Retterbush@Maricopa.Gov>; 
dmheisler1@aol.com; fbuss@gilabendaz.org; bespinoza@gilabendaz.org; curtis.karmazin@origisenergy.com; 
jlguigliano@burnsmcd.com 
Subject: [URL Verdict: Neutral][Non‐DoD Source] CPA2023013 ‐ Desert Gem Solar and Storage Project ‐ Major CPA 
(Outside Routing) 
 
Hello Registered Area of Interest Member,  
Please find attached a planning & development application routing for CPA2023013, a major comprehensive plan 
amendment.  
See attached document for instructions to download application materials.  
Thank you,  
 
 
 
Andrew Lorentzen 
Planner 
PLANNING & DEVELOPMENT 
301 W. Jefferson St. Suite 170  
Phoenix, AZ 85003 
O:   602-506-2364     
MARICOPA.GOV 
Andrew.lorentzen@maricopa.gov 
Facebook | Instagram | Twitter | YouTube | LinkedIn

August 10, 2023 
 
 
 
 
 
 
 
SENT VIA EMAIL 
 
Joseph Mueller, Planner 
Andrew Lorentzen, Planner 
Nick Schlimm, Planner 
Maricopa County Planning and Development Department  
301 W. Jefferson Street, Suite 170 
Phoenix, AZ  85003 
 
Subject: 
CPA2023011: Major Comprehensive Plan Amendment – Maricopa Energy Center 
CPA2023012: Major Comprehensive Plan Amendment – Belmont Mixed Use 
CPA2023013: Major Comprehensive Plan Amendment – Desert Gem Solar Project 
 
Dear Mr. Mueller, Mr. Lorentzen, and Mr. Schlimm: 
 
Thank you for the opportunity to review and comment on Maricopa County Major Comprehensive 
Plan Amendments CPA2023011, CPA2023012 and CPA2023013 for solar energy projects and 
a mixed use in the county, to change land use designations from Rural Residential to Utilities on 
± 2,000 acres and ± 9,300 acres, respectively, for large-scale solar farm and battery storage 
systems. 
 
The Maricopa Energy Center major comprehensive plan amendment area is located generally 
south of Interstate 10, about halfway between the City of Phoenix and the Arizona/California 
boundary.  
 
The Desert Gem Solar project is located about midway between I-8 and I-10 on the west side of 
State Highway 85, about 15 miles south of the Town of Buckeye and 20 miles north of Gila Bend. 
 
The proposed solar energy generation and storage projects are located in regions of high solar 
exposure, proximity to other existing solar energy farms and adequate energy transmission 
infrastructure. Projects should have minimal impact on surrounding properties and generation of 
renewable energy would be a benefit to the region. In addition, the project will be retiring 
agricultural land and reducing associated water use and increasing regional renewable energy. 
 
The Belmont Mixed Use major comprehensive plan amendment area is located generally north 
of Interstate 10, about 40 miles west of central Phoenix. This proposed amendment will contribute 
to the economic development and exposed tourism opportunity in the region. 
 
Pima County Development Services Department, Planning Division has no opposition to the 
proposed major comprehensive plan amendments. 
 
Sincerely, 
Aaron Reid 
Planning Intern 
Pima County Development Services Department, Planning Division

1
Andrew Lorentzen (PND)
From:
David Williams <David.Williams@goodyearaz.gov>
Sent:
Monday, July 17, 2023 4:15 PM
To:
Andrew Lorentzen (PND)
Subject:
CPA2023013 - Desert Gem Solar and Storage Project
Mr. Lorentzen,  
 
Thank you so much for the opportunity to review this project.  At this time, City of Goodyear has no 
comments. 
 
Respectfully,  
 
David Williams 
Contract Senior Planner 
City of Goodyear 
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