Mohave County Planning and Zoning Commission
Development Services Department
P.O. Box 7000
Kingman, AZ 86402
 
RE: April 10th  Planning and Zoning Meeting, Agenda Item 17, Evaluation of a Request to Amend the Mohave County Zoning Ordinance Section 12.2, Energy Overlay (E) Zone; Section 37.4, Special Uses, and Section 37.U, Energy Projects.
 
Supervisors, Commissioners, and Staff,
 
AriSEIA is the State’s nonprofit solar, storage, and electrification trade association. We are active at all levels of government in Arizona, working to advance renewables policy. We worked heavily on Eloy’s 2023 ordinance and are currently working with Yavapai County and Pinal County on similar processes. We spoke to the Mohave County Board of Supervisors when the Moratorium was passed last fall. We also presented an economic impact analysis completed by Elliott Pollack and have included that here as Attachment B for your convenience.
 
We have also attached redlines of the proposed Ordinance here as Attachment A. We encourage you to make a few small modifications before submitting this to the Board of Supervisors for a vote. However, when the final version is voted on, we encourage you to replace the existing Moratorium with the new ordinance as soon as possible.
 
Our two biggest concerns with the proposed Mohave Ordinance are the one mile buffer zone and the amount of time (12 months) that triggers decommissioning. We suggest a quarter mile buffer zone and a force majeure clause for decommissioning, as there are reasons why there may be a 12+ month delay that are not the result of abandonment.
 
We would be happy to participate in any stakeholder process the County implements to finalize this Ordinance. Thank you for your time and consideration.
 
Respectfully,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]
 

Mohave County Supervisors
700 W. Beale Street
Kingman, AZ 96401
 
RE: Opposition to the Resolution Implementing the Moratorium on the Designation of the E (Energy Overlay) Zone

Dear Chairman and Supervisors,

The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We urge you to vote NO on the moratorium on renewable energy projects in Mohave County at the Board of Supervisors meeting on October 16, 2023.

Economic Benefits. This moratorium will affect the county’s opportunity to benefit from the tax revenues of these projects which could address some of the county’s potential budget deficit issues. In August 2023, the Board voted for a hiring freeze until plans could be made to address the County’s potential $18.5 million deficit.[1] The County is considering an 18% budget cut that would affect, “one-in-five county employees” according to the County’s Chief Financial Officer.[2] Utility scale solar projects could help the County avoid the economic difficulties from the necessary austerity measures it will need to take to address this budget deficit.

For example, constructing a 100 MW utility scale project, depending on equipment costs, labor costs, financing costs, and other federal incentives, could cost between $100 - $200 million. The tax revenue from this project using the standard formula of Property Tax Revenue = Assessed Property Value × Property Tax Rate, could be between $1.25 – 2.5 million a year. If we then assume that the following projects: White Hills (450 MW), Mineral Park Solar (275 MW), and Leo Solar (300 MW), all projects proposed on public lands in Mohave County, being considered by the BLM, were on private property, the county could easily collect between $12.8 to $25.6 million per year in tax revenues. This would essentially solve the County’s budget deficit issues.

AriSEIA did commission a study by Elliott D. Pollack & Company to assess the benefit to the County of a sample solar + storage project. The study is attached and found that the total economic impact of a single project was $442.5 million in economic impact countywide. The fiscal or tax impact of a single project to the County would be nearly $31 million.

Low Water Usage. The draft of the resolution implementing the moratorium, incorrectly cites the study by Kahled Hasan, et al, Effects of Different Environmental and Operational Factors on the Solar Performance: A Comprehensive Review,[3] to justify the statement, “WHEREAS a significant amount of water and other resources are necessary to maintain solar panels in desert and arid environments.” In the Kahled et al. study, the researchers attempt to understand the environmental conditions that may affect the performance of solar systems during their operational lifecycle by conducting a review of the academic literature on the topic. While their study shows that dust and  humidity do affect the performance of solar systems, they show that the use of hydrophobic (water repelling) and hydrophilic (water dispersing) coating materials for the panels help clean them by sweeping away all the dirt during a rain. While the study suggests that sprinkling water on the solar modules helps reduce their temperature thereby improving performance, it does not discuss how much water is needed to perform this. In fact, the study suggests that properly tilted solar modules with the necessary cooling and self-cleaning material would require as little water as possible during their lifecycle. In fact, operators of solar farms do not wash the panels, as it costs more to do than the benefit obtained.

A study from researchers at the Brookhaven National Laboratory, shows that when compared to conventional power generation technologies such as coal and natural gas, solar actually uses far less water during its lifecycle. That study looked at the lifecycle uses of water of  different generation technologies across the United States and concluded that solar and wind are the best options for conserving water supply, when compared to coal, nuclear, oil/gas, and biomass technologies.[4]

Another study by researchers at the National Renewable Energy laboratory (NREL), estimated both the water withdrawal and consumption of electricity generating technologies. Again, they found that solar and wind technologies use less water than their counterpart energy technologies. This study looked at the use of water through the entire lifecycle of the technology from component manufacturing to fuel acquisition to power plant operation and decommissioning, and concluded that the water used by thermoelectric plants, such as coal, oil/gas, and nuclear for water cooling still dominate the entire water value chain in electricity production.[5]

Panel Safety. The draft resolution states that the “impact of these renewable energy projects on the local population and environment over a long period of time is unknown.” This is not the case. The long-term impacts of some renewable energy technologies such as solar and wind, on host and surrounding communities have been extensively studied in the United States and other parts of the world. One such study on the environmental impacts during the installation and operation of large-scale solar power plants studied these effects with respect to land use, climate, geohydrological resources, and human health in comparison to traditional power systems.[6] They found that solar causes less exposure to hazards like mercury, cadmium, and particulate matter.

Further, risks of site contamination are much less than for most other industrial uses because solar technologies employ few toxic chemicals and those used are present in very small quantities.[7] Testing shows that silicon and cadmium telluride (CdTe) panels are both safe to dispose of in landfills and are also safe in worst case conditions of abandonment or damage in a disaster.[8] Multiple sources report that most modern solar panels (both crystalline silicon and cadmium telluride) pass the Toxic Characteristic Leaching Procedure (TCLP), which is a test method used to determine whether a waste is a toxic hazardous waste.[9]

Interconnected Grid. During the public hearing meetings on August 7, 2023, and September 5, 2023, some residents and other stakeholders raised the issue of the location of these large utility scale solar projects in Mohave County. They were specifically concerned about the fact that the power generated from the solar farms may not be used by residents of Mohave County. This is a misunderstanding of how the U.S. electric power grid operates and how electricity is regulated at the Federal and State levels. Utility scale solar projects can only be located in areas where land is plentiful and the solar resource – the sun – is abundant. This makes Arizona a good location for these projects. In addition, once a generation asset is connected to the transmission system, there is no way of determining which electrons go to a specific consumer. This is because electricity takes the path of least resistance. Hence there is no way of knowing if the electricity used by residents in Mohave County was generated in Mohave County. The important issue is that there should always be enough capacity on the grid to meet the demand in real time, which is consistently changing.  If this is not the case, the reliability of the grid could be called into question.

For example, UNS Energy Inc. (UNSE) owns a total of 291 MW of installed thermal capacity from three natural gas generation plants. Only Black Mountain is in Mohave County, with Valencia and Gila River projects located in Nogales and Maricopa respectively. UNSE also purchases about 36% firm capacity through wholesale market power purchase agreements (PPA) to address summer peaks, and also purchases over 89.4% of its renewable energy resources through PPAs with third parties.[10] This is similar to Mohave Electric Cooperative (MEC), which is a member of the Arizona Electric Power Cooperative (AEPCO). AEPCO is the generation and transmission (G&T) co-op utility for Mohave and six other distribution co-ops in Arizona, New Mexico, and California. While MEC owns two solar farms in southeast Fort Mohave, AEPCO, from which it purchases most of its electricity, owns generation assets throughout Arizona and California. This means that Mohave County residents are consuming electricity generated in other counties in Arizona and even in California. The interconnected nature of the US electric power grid is a strength. If a major generation plant in Mohave County fails, its residents can be rest assured that they have access to power from Nevada, California, New Mexico, and other states in the west.

Environmental Impact Statements. The draft of the resolution stated that “additional information and research are needed to determine the allowable groundwater usage and suitable areas for large projects such as solar, wind, and geothermal. The location of a facility that uses water, while on the surface may fit the area and general plan, may overuse water and other resources in the groundwater basin.” The draft went on to refer to the environmental impact statement on the Desert Sunlight Solar Farm, one of the largest solar farms in the country located on the California Desert Conservation Area, to justify that claim. This is incorrect.

The California Desert Conservation Area is a vast ecosystem located in Southern California managed by the BLM. Based on the environmental impact statement, the BLM amended the “California Desert Conservation Area Plan (CDCA Plan) to allow for solar energy and of a right-of-way (ROW) grant to lease” the land to the developers of the project, which was commissioned in 2015. In fact, according the BLM, many of the adverse impacts of the projects “to biological resources, cultural resources, land use, visual resources, hydrology, water quality, and water use,” were adequately “avoided or substantially reduced based on compliance with applicable laws, ordinances, regulations and standards, and compliance with measures provided” in the impact statement.[11] Hence by conducting the environmental impact study, the effects of the project on wildlife, groundwater, and other resources were adequately known and appropriately mitigated. In fact, a 230 MW Battery Energy Storage System (BESS) was added to the Desert Sunlight Solar farm in August 2022.[12] Conducting an environmental impact study is standard procedure for utility scale solar projects.

For the reasons articulated above, please vote no on the draft resolution and reject a renewables moratorium in Mohave County.
​
Respectfully,
 
Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]


[1] River City Newspapers, County to Consider Exceptions to Hiring Freeze, Aug 30, 2023, available here https://www.havasunews.com/news/county-to-consider-exceptions-to-hiring-freeze/article_8cbda648-45fa-11ee-bf3b-1b533a671250.html.

[2] Today’s News Herald, As County Faces $18.5 Million Deficit, Departments Present Bleak View of Possible Cuts, September 20, 2023, available here https://www.havasunews.com/news/as-county-faces-18-5-million-decit-departments-present-bleak-view-ofpossible-cuts/article_fdd35ab2-581f-11ee-8a65-e36102c35e70.html.

[3] Kahled Hasan, et al, Effects of Different Environmental and Operational Factors on the Solar Performance: A Comprehensive Review, 10 ENERGY SCI. ENG. 656, 664-65.

[4] Vasilis Fthenakis, Hyung Chul Kim, Life-cycle uses of water in U.S. electricity generation, Renewable and Sustainable Energy Reviews, Volume 14, Issue 7, 2010, Pages 2039-2048, ISSN 1364-0321, available here https://doi.org/10.1016/j.rser.2010.03.008.

[5] J Meldrum et al 2013 Environ. Res. Lett. 8 015031, available here https://iopscience.iop.org/article/10.1088/1748-9326/8/1/015031/pdf.

[6] Damon Turney, Vasilis Fthenakis, Environmental impacts from the installation and operation of large-scale solar power plants, Renewable and Sustainable Energy Reviews, Volume 15, Issue 6, 2011, Pages 3261-3270, ISSN 1364-0321, available here https://doi.org/10.1016/j.rser.2011.04.023.

[7] Parikhit Sinha, Potential Environmental Hazards of Photovoltaic Panel Disposal: Discussion of Tammaro et al. (2015), available here https://doi.org/10.1016/j.jhazmat.2016.04.021.

[8] Human Health Risk Assessment Methods for PV Part 3: Module Disposal Risks, 2020, Report IEA-PVPS T12-16: 2020, ISBN 978-3-906042-96-1.

[9] Health and Safety Impacts of Solar Photovoltaics, NC Clean Energy Technology Center, North Carolina State University, May 2017.

[10] UNS Electric Inc, 2020 Integrated Resources Plan (IRP), available here https://docs.uesaz.com/wp-content/uploads/UNSE-2020-Integrated-Resource-Plan.pdf.

[11] US DOE, Office of NEPA Policy and Compliance, EIS-0048, June 24, 2011.

[12] Energy Storage News, 230MW BESS Comes Online at Bureau of Land Management Site in California, August 17, 2022, available here https://www.energy-storage.news/230mw-bess-comes-online-at-bureau-of-land-management-site-in-california/. 

Eloy City Council
595 N. C Street
Eloy, AZ 85131
 
RE: Opposition to Sections B and F(2) of the Revision of the City’s Zoning of Solar Generating and Storage Facilities
​
Dear Mayor and Council Members,

The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We are active at all levels of government in the state and represent organizations throughout the clean energy economy. I am writing to urge you to modify or eliminate Sections B and F(2) from updates to 21-3-1.39.

We previously submitted a letter to this body in February 2023 and have attended three meetings of the Council or Planning and Zoning Committee. We are encouraged by the City’s willingness to make modifications throughout this process. However, there are still two major areas of concern.

First, the City should not arbitrarily limit expansion of solar to 16% of City acreage. This number is not based on the public interest or any quantitative or qualitative assessment of appropriate solar development in Eloy. It is a duplication of a Coolidge requirement. This kind of restriction limits private property rights of landowners in Eloy, unnecessarily restricts economic development in the area, and risks grid reliability. With the peak records we are seeing broken this summer,[1] massive load growth in the state,[2] and increasingly hot weather,[3] Arizona’s utilities will need to build significant new infrastructure to keep the lights on in Eloy and around the state. Limiting that development on the front end is unnecessary. The City already has a process by which to approve projects and, if so desired, could keep the second half of Section B, without the 16% cap.

Second, while we recommend no cap on the amount of storage per project, any cap should be based on capacity not lot size. Further, that cap should be closer to 10-20% of capacity, not 5% of lot size. This is also arbitrary, needlessly limits reliability, and impedes a growing technology prematurely. We recommend modifying Table 3-1-1 to remove the “Lot Coverage, Maximum” or modifying it to “Capacity Maximum” and 10-20%.

Finally, we would like to address some of the statements made over the course of this process that may be based on misunderstanding. Throughout the western interconnect, the grid is interconnected all over the western US. Power is produced and utilized all over the west. Power in Eloy comes from New Mexico and California, for example. Limiting renewables development in Eloy because the power is not used on site is counter to how the grid operates. We are seeing increasing local opposition to renewables development. Coolidge[4] set a limit previously and Mohave County[5] is considering a one-year moratorium. Columbia Law School has found more than 200 local restrictions specifically against renewables.[6] These projects can only be located in some geographic locations. Increased limitation impedes our ability to transition the grid, save water, reduce air pollution, and keep the lights on.

It has also been said that renewables projects do not “benefit residents” because the bulk of the tax revenue benefits the County and schools more than the City. However, the schools and County services do benefit residents. Residents work in the schools and send their kids to those same facilities. Personally, where I send my children for 1/3 of the day matters a lot to me as a resident. More funding correlates with better facilities and outcomes. Each of these projects contribute tens of millions of dollars to the local economy, several million of which does go directly to the City.

Eloy and Pinal County have very serious air quality and water quantity challenges. It is important to look at economic development opportunities wholistically. These challenges will limit the types of businesses and industries that choose to locate in Eloy. There are only so many industries that do not need water, for example. Renewables, including solar, are an ideal economic opportunity given the constraints of the local area. I have re-included data regarding the water usage and emissions of renewables for your convenience. Solar has no point source emissions and lower lifecycle emissions than fossil fuels. It also uses less water in operations and in its lifecycle than most other electricity generating technologies. Lastly, new companies are relocating to Arizona every day and many of them are doing so to help meet their clean energy goals. The national Solar Energy Industries Association (SEIA) tracks clean energy procurement on behalf of businesses in their Solar Means Business Report and the numbers are staggering. We encourage Eloy to not indicate to those businesses that they are closed for business.

Please reject Sections B and F(2) of the staff proposal. Thank you for your consideration to this important matter.

Sincerely,

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

[1] Daily Energy Insider, Arizona Public Service Breaks Own Peak Demand Record Seven Days Running, July 26, 2023, available here https://dailyenergyinsider.com/news/40515-arizona-public-service-breaks-own-peak-demand-record-seven-days-running/.

[2] APS stated in its currently pending rate case that they are looking at a 40% increase in peak and a 60% increase in demand by 2031.

[3] Arizona Republic, July Earned Phoenix Hottest Month on Record for a US City, August 1, 2023, available here https://www.azcentral.com/story/news/local/phoenix-weather/2023/08/01/july-earned-phoenix-hottest-month-on-record-for-a-us-city/70505349007/.

[4] Coolidge Council Restricts New Solar, May 14, 2022, available here https://azbex.com/local-news/coolidge-council-restricts-new-solar/#:~:text=After%20nearly%20a%20year%20of,the%20list%20of%20approved%20uses..

[5] Mohave County Board Materials for August 7, 2023, available here https://lfportal.mohavecounty.us/bos/DocView.aspx?dbid=0&id=2038857&page=1&cr=1.

[6] Columbia Law School, Report Finds 228 Local Restrictions Against Siting, Wind, Solar, and Other Renewables, May 31, 2023, available here https://blogs.law.columbia.edu/climatechange/2023/05/31/report-finds-228-local-restrictions-against-siting-wind-solar-and-other-renewables-as-well-as-293-contested-projects/. 

Mohave County Supervisors
700 W. Beale Street
Kingman, AZ 96401
 
RE: Moratorium on Renewable Energy Projects

Dear Chairman and Supervisors,

The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We are active at all levels of government in the state and represent organizations throughout the clean energy economy. I am writing to urge you to not to halt all renewable energy projects for the next year within the county.

Much of Arizona has very serious air quality and water quantity challenges. Increased deployment of renewable energy can help alleviate both problems. Solar has no point source emissions and lower lifecycle emissions than fossil fuels. It also uses less water in operations and in its lifecycle than most other electricity generating technologies. Further, solar and storage have the opportunity to greatly benefit Mohave County economically. A 25-year fiscal impact summary for an average project reflects the potential to bring in more than $2 million to the City, $12.5 million to the County, and nearly $17 million to the local school districts. That’s a total positive fiscal impact of nearly $32 million from a single project. Further, new companies are relocating to Arizona every day and many of them are doing so to help meet their clean energy goals. The national Solar Energy Industries Association (SEIA) tracks clean energy procurement on behalf of businesses in their Solar Means Business Report and the numbers are staggering.

Please affirm the Mohave County Planning and Zoning Commission decision. Certainly, do not institute a moratorium on all solar development in the county. I have attached some information on the number of jobs attributable to solar in Arizona, the water usage of solar (operations and lifecycle), and the lifecycle emissions of different electricity generating resources.
​
Sincerely,
 
Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

AriSEIA coauthored an article today in PinalCentral on a pending anti-solar ordinance currently being considered in Eloy, AZ. Local renewables opposition is a huge impediment to the clean energy transition and means we will continue to rely on fossil fuels for electricity. Read the full article above and contact Eloy's city council in opposition.

BLM Yuma Field Office
Attn: Erica Stewart
7341 E. 30th Street, Suite A
Yuma, AZ 85365
 
RE: Solar Variances

Dear BLM Staff,

The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We are active at all levels of government in the state and represent organizations throughout the clean energy economy. I am writing to encourage BLM to continue moving forward with the solar variance process for the proposed solar projects located in Mohave County.

Solar and storage systems benefit surrounding communities in several ways. First, Arizona continues to struggle with water quantity challenges. Solar development and operation of solar facilities does not require large amounts of water compared to other land uses. Using these lands for solar development can help alleviate some of Arizona’s water quantity challenges. Second, the use of clean energy reduces emissions and can improve air quality. Third, the proposed projects should not adversely impact local ecosystems. All three of the proposed projects plan to protect and preserve the natural habitat. Local wildlife and vegetation will still be protected on these lands and can also be used for solar facilities. Along with positive local impacts, the use of solar and storage benefits the entire nation, making public lands a particularly suitable place to develop these facilities. Air quality is a national and global issue; therefore, the emissions reductions achieved from transitioning to the use of more clean energy resources has widespread benefits. The deployment of solar energy also increases energy security throughout the United States. Overall, solar development on public lands will have long term benefits for both surrounding communities and the nation.

Please continue to consider and analyze the three solar projects for future development on BLM lands. These include White Hills Solar, Mineral Park Solar, and Leo Solar. AriSEIA supports renewable energy development on public lands. BLM and the solar companies involved should continue to be diligent in their analyses and take the steps necessary to evaluate the suitability of these projects. I have also attached some information on the water usage of solar (operations and lifecycle), the lifecycle emissions of different electricity generating resources, and solar development rates in Arizona and accompanying economic benefits.
Sincerely,
 
Autumn Johnson, Executive Director
AriSEIA
520-240-4757
[email protected]
 
Figure 1 Life cycle water use for electricity generation: a review and harmonization of literature estimates. J Meldrum et al 2013 Environ. Res. Lett. 8 015031

Figure 2 Water Impacts of High Solar PV Electricity Penetration, NREL/TP-6A20-63011, September 2015 (operational water usage)

Figure 3 Life Cycle Greenhouse Gas Emissions from Electricity Generation: Update, NREL, 2021

Eloy City Council
595 N. C Street
Eloy, AZ 85131
 
RE: Opposition to Revision of the City’s Zoning of Solar Generating and Storage Facilities

Dear Mayor and Council Members,

The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We are active at all levels of government in the state and represent organizations throughout the clean energy economy. I am writing to urge you to not revise the City’s Adopted Zoning Map to restrict solar and storage development.

Pinal County has very serious air quality and water quantity challenges. Increased deployment of renewable energy can help alleviate both problems. Solar has no point source emissions and lower lifecycle emissions than fossil fuels. It also uses less water in operations and in its lifecycle than most other electricity generating technologies. Further, solar and storage have the opportunity to greatly benefit Eloy and Pinal County economically. A 25-year fiscal impact summary for a single project reflects the potential to bring in more than $2 million to the City, $12.5 million to the County, and nearly $17 million to the local school districts. That’s a total positive fiscal impact of nearly $32 million from a single project. Further, new companies are relocating to Arizona everyday and many of them are doing so to help meet their clean energy goals. The national Solar Energy Industries Association (SEIA) tracks clean energy procurement on behalf of businesses in their Solar Means Business Report and the numbers are staggering.

Please reject the staff proposal. Certainly, do not exclude ongoing projects that have been engaging with the City in good faith from any potential “solar zone.” Any changes should only apply to prospective projects. Instead of blanket restrictions, please review each project on its own merits. Also, please reject the separation requirement as it will needlessly prevent important clean energy development.

I have attached some information on the number of jobs attributable to solar in Arizona, the water usage of solar (operations and lifecycle), and the lifecycle emissions of different electricity generating resources.
Sincerely,
 
Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

Figure 1 Life cycle water use for electricity generation: a review and harmonization of literature estimates. J Meldrum et al 2013 Environ. Res. Lett. 8 015031

Figure 2 Water Impacts of High Solar PV Electricity Penetration, NREL/TP-6A20-63011, September 2015 (operational water usage)

Figure 3 Life Cycle Greenhouse Gas Emissions from Electricity Generation: Update, NREL, 2021