AriSEIA Sends Feedback to AZ Game and Fish on its Solar Development Guidelines

7/9/2026

Arizona Game and Fish Department
5000 W. Carefree Highway
Phoenix, AZ 85086

Re: AriSEIA Comments on the Guidelines for Solar Development in Arizona

Dear Arizona Game and Fish Department:

The Arizona Solar Energy Industries Association ("AriSEIA") appreciates the opportunity to provide comments on the Arizona Game and Fish Department's ("AZGFD") Guidelines for Solar Development in Arizona. AriSEIA is a statewide nonprofit organization that works on energy policy at every level of government. AriSEIA works with state agencies, utilities, local governments, industry stakeholders, and policymakers to advance practical energy policies that support Arizona's economy, electric grid, and clean energy future.

AriSEIA appreciates AZGFD's efforts to develop a comprehensive resource that promotes both wildlife conservation and responsible solar development. The draft appropriately recognizes that utility-scale solar is an important component of Arizona's energy future and acknowledges that thoughtful project siting and design can reduce impacts to wildlife while supporting continued deployment of renewable energy. AriSEIA strongly supports early coordination between developers and resource agencies and agrees that project-specific collaboration often produces better environmental and development outcomes.

While AriSEIA generally supports the objectives of the draft, several revisions would improve the document by maintaining flexibility, recognizing Arizona's significant energy needs, and ensuring that voluntary guidance is not inadvertently transformed into de facto regulatory standards.

I. The Guidelines Should More Clearly Emphasize Their Voluntary Nature

The Executive Summary appropriately describes this document as a “voluntary framework,” and AriSEIA commends that framing. However, we are concerned that this characterization is insufficiently reinforced throughout the body of the document. The guidelines explicitly encourage local governments to incorporate recommendations into zoning codes, conditional use permit criteria, and site plan review processes. As written, there is a substantial risk that recommendations developed as voluntary best management practices will instead become mandatory local development standards.

AriSEIA recommends strengthening the document’s repeated emphasis that these guidelines are advisory only, are intended to support project-specific decision making, and should not be interpreted as establishing minimum design requirements or default permit conditions applicable to every solar project. For example, the guidelines could expressly state that they are intended solely as voluntary best management practices and are not intended to establish regulatory requirements or mandatory permit conditions. Each section of AZGFD’s Guidelines could benefit from a brief reminder of this intent.

II. The Guidelines’ Framing Often Undermines the Solar Industry and the Wildlife Conservation Goals it is Trying to Advance

AriSEIA has a concern related to the structuring of the guidelines. Throughout the document, potential adverse impacts of solar development are described in detail, while the corresponding mitigations, advances in technology, or contradicting research are either presented as brief afterthoughts or omitted entirely. This imbalance does not reflect the current state of the science, and it risks discouraging the responsible solar development that both AZGFD and AriSEIA want to see done well.

A few examples:

The guidelines devote significant space to avian fatalities at solar facilities, citing studies documenting the “lake effect” phenomenon, while the counter research receives only a single sentence near the end of the section. Recent studies have found no evidence of bird collisions at modern facilities in the Southwest and suggests that previously reported fatalities may have been associated with older panel technologies no longer in use. This finding deserves equal emphasis, not a footnote.

Similarly, the section on hazardous materials implies that end-of-life solar panels pose a significant leaching risk. In practice, this risk is rare and highly regulated, and there are well-established industry best practices for responsible panel disposal and recycling. 1, 2 Presenting the risk without the context of how it is managed creates a misleading framing.

The vegetation management section raises concerns about herbicide overuse without noting that solar grazing (the use of livestock, commonly sheep, to manage vegetation within solar arrays) is well-documented and increasingly seen as an alternative.3 This strategy avoids herbicide use entirely while generating co-benefits for land managers and local agricultural operations.

The stormwater section similarly raises concerns without pointing to the body of knowledge on solar farm stormwater management best practices that do exist.4

AriSEIA recommends that AZGFD adopt a consistent framing practice throughout the document. When a potential impact is identified, any associated mitigation, newer technology, or counter research should be presented with equal weight in the same section and not buried or omitted. This would make the guidelines more accurate, more useful to developers and permitting agencies, and more in alignment with AZGFD’s stated goal of facilitating responsible solar development alongside wildlife considerations.

III. Additional Substantive Recommendations

Balancing Wildlife Conservation and Arizona’s Energy Needs
Arizona is experiencing unprecedented electric load growth driven by population growth, manufacturing, industrial development, data centers, and continued economic expansion. Meeting those needs will require substantial deployment of new generation resources, including utility-scale solar.

The draft appropriately recognizes that solar energy contributes to reducing greenhouse gas emissions and can be developed in a manner that minimizes impacts to wildlife. AriSEIA recommends expanding that discussion to acknowledge that facilitating the timely deployment of utility-scale solar is itself an important public policy objective that supports electric reliability, economic development, and Arizona's long-term energy security. Wildlife conservation and renewable energy development are complementary goals that should be advanced together.

Accordingly, AriSEIA recommends emphasizing throughout the guidelines that conservation measures should be implemented in a manner that is practical, proportional, and based on project-specific conditions. Recognizing the need to balance wildlife conservation with Arizona's growing energy needs will better reflect the important role these guidelines can play in supporting both objectives.

Soil Disturbance Should Be Centered Much Earlier in the Guidelines

The guidelines address soil disturbance and grading practices in Chapter 3’s vegetation management section which is located well into the document. Given how foundational soil health is to wildlife habitat, plant community recovery, pollinator contributions, and invasive species resistance, this topic warrants much earlier and more prominent treatment. Soil disturbance is not a vegetation management sub-issue but the primary driver of habitat impact and should be addressed as such.

Additionally, the guidelines do not note that complete site grading is increasingly unnecessary with modern solar installation designs and technologies. 5, 6 Tracker systems and racking designs can now be deployed with significantly reduced ground disturbance, preserving soil seed bank, mycorrhizal networks, and native root structures that the document correctly identifies as ecologically valuable. This is an important insight that the guidelines should highlight proactively rather than treating grading as a baseline assumption.

Pollinator Habitat Should Be Recognized for Its Broader Landscape Value

The guidelines’ discussion of pollinator habitat within solar facilities is welcome, but it stops short of acknowledging the broader co-benefits that well-designed solar pollinator habitat can deliver. Localized native plantings within and around solar arrays can function as corridors or stepping stones that support nearby rewilding efforts, wildland connectivity, and agricultural pollination services. This is critical for surrounding farms and ranches that are common in rural Arizona. These benefits should be articulated explicitly, as they represent a meaningful opportunity for solar facilities to contribute positively to the landscapes they occupy.

Recommendations That Significantly Reduce Developable Acreage Should Remain Flexible and Site-Specific

The draft contains numerous recommendations intended to improve wildlife movement and habitat connectivity, including wide wildlife corridors, rounded facility corners, avoidance of dead-end fencing, roadway setbacks, and preservation of unfenced areas. Collectively, these recommendations can substantially reduce the developable area of a project and materially affect project economics.

In particular, the recommendation for wildlife corridors approximately 1,300 feet wide, and potentially up to 2,000 feet under certain circumstances, represents a significant design recommendation with substantial land use implications. The draft also notes that AZGFD is continuing to study effective corridor widths for solar facilities. AriSEIA recommends emphasizing that corridor width, configuration, and wildlife accommodations should be determined through project-specific evaluation based on site conditions, target species, landscape context, and the best available science.

The Guidelines Should Recognize the Cumulative Effect of Multiple Recommendations

The draft appropriately identifies numerous best management practices addressing site selection, biological surveys, facility design, fencing, vegetation management, monitoring, and decommissioning. While many of these recommendations are reasonable individually, implementing numerous recommendations simultaneously can substantially increase project costs, extend development schedules, and reduce generating capacity.

AriSEIA recommends acknowledging that project proponents must balance environmental benefits with engineering feasibility, land availability, project economics, and Arizona's growing need for additional electric generation. Encouraging proportional, project-specific implementation of best management practices will better support both wildlife conservation and successful project development.

Cumulative Impact Analysis Should Be Project-Specific

The discussion of cumulative landscape-scale impacts provides useful context regarding statewide development trends. However, AriSEIA recommends clarifying that cumulative impacts should be evaluated using project-specific evidence rather than presumed solely because multiple solar facilities exist within a broader region.

Projects that incorporate appropriate avoidance, minimization, and mitigation measures should continue to be evaluated on their individual merits rather than being disadvantaged by generalized concerns regarding regional development patterns.

The Guidelines Should Distinguish Between Established Best Management Practices and Emerging Recommendations

AriSEIA appreciates that the draft reflects current scientific understanding regarding wildlife conservation and solar development. However, not all recommendations in the document are supported by the same degree of scientific consensus or practical experience. Some recommendations, such as early coordination, thoughtful site selection, and wildlife-compatible fencing, represent well-established best management practices. Other recommendations, including specific wildlife corridor widths, reflect areas where the draft acknowledges that research is ongoing.

AriSEIA recommends distinguishing between generally accepted best management practices and recommendations that represent emerging science or project-specific considerations. Doing so would improve transparency for developers, permitting agencies, and local governments while reducing the likelihood that recommendations based on evolving research are interpreted as universal design standards. This distinction would also reinforce the document's stated purpose as a voluntary, flexible framework that supports project-specific decision making.

Conclusion

AriSEIA appreciates AZGFD's work in developing these guidelines and recognizes the significant effort involved in producing a comprehensive resource addressing both wildlife conservation and renewable energy development. AriSEIA supports continued collaboration to identify practical, science-based approaches that conserve Arizona's wildlife while allowing the timely development of the renewable energy resources needed to support Arizona's continued economic growth.

As Arizona continues to experience growth in utility-scale solar and battery energy storage development, AriSEIA respectfully requests that AZGFD include the association in future stakeholder processes relating to renewable energy, battery energy storage systems, and associated wildlife guidance. AriSEIA values the opportunity to collaborate with state agencies and other stakeholders to develop practical, science-based approaches that support both wildlife conservation and responsible energy development.

Respectfully,
/s/ Autumn T. Johnson
Executive Director
AriSEIA
(520) 240-4757
[email protected]

cc Governor’s Office of Resiliency

[1] American Clean Power, 2024, Solar Panels are Safe for Your Community, https://cleanpower.org/wp-content/uploads/2024/10/ACP_Solar-Panels_are_Safe-for-Your-Community_FactSheet.pdf

[2] American Clean Power, 2024, Solar Panel Recycling and Disposal, https://cleanpower.org/wp-content/uploads/gateway/gateway/2024/10/SolarRecycling_241104.pdf

[3] American Solar Grazing Association, n.d., What Is Solar Grazing and How Does It Work?, https://solargrazing.org/wp-content/uploads/2019/06/Solar-Grazing-Brochure.pdf

[4] National Laboratory of the Rockies, last updated 2026, Photovoltaic Stormwater Management Research and Testing, https://www.nlr.gov/solar/market-research-analysis/pv-smart

[5] PV Magazine, 2026, Say goodbye to grading: New alternatives for solar on challenging topography, https://pv-magazine-usa.com/2026/01/13/say-goodbye-to-grading-new-alternatives-for-solar-on-challenging-topography/

[6] PV Tech, The end of mass grading for solar projects, 2023, https://www.pv-tech.org/the-end-of-mass-grading-for-solar-projects/