Plan Review Detail
Review Status: Approved
Review Details: ENTITLEMENT REVIEW v.1
Plan Number - TP-ENT-0526-00010
Review Name: ENTITLEMENT REVIEW v.1
Review Status: Approved
| Review Date | Reviewer's Name | Type of Review | Description | Status | Comments |
|---|---|---|---|---|---|
| Transportation Landscape Review | APPROVED | ||||
| Real Estate | NOT REQUIRED | The Real Estate Division has no comments or objections to the proposed request. Please contact the Real Estate Division if any property rights need to be addressed. | |||
| DTM Planning | REVIEW COMPLETED | ||||
| Entitlement Review Coordinator Express | REVIEW COMPLETED | ||||
| Entitlements | REVIEW COMPLETED | DATE: July 28, 2026 For August 13, 2026 Hearing TO: Linus Kafka FROM: Koren Manning, Director Zoning Examiner Planning & Development Services SUBJECT: SPECIAL EXCEPTION LAND USE PLANNING & AND DEVELOPMENT SERVICES REPORT TP-ENT-0526-00010 Pandora WCF – S Harrison Rd (ZESE) PAD-40 (Ward 4) Issue – This is a request by Destree Development for approval of a wireless communication facility (WCF). The special exception site is located at 4200 S Harrison Road, approximately 1100 feet west of Harrison Road and 4,300 feet north of Irvington Road, inside the Tucson Inert Landfill facility (see Case Location Map). The preliminary development plan (PDP) proposes a 70-foot wireless communication tower with an antenna array at the top of the tower. The project is designed to improve service quality and coverage for safety and general communications needs. The proposed ground equipment, including the monopole, would be placed within an approximately 2,500 square-foot (50 by 50 feet) ground area surrounded by a 7-foot-4-inch-high chain-link fence topped by three strands of security wire. Service access is provided via a gate on the north face of the compound, with a proposed utility access easement extending east to Harrison Road. The development is within PAD-40, the Harrison Landfill Planned Area Development (PAD). This PAD has an underlying zone of P-I (Park Industrial), which allows Wireless Communications Facilities as a Special Exception Land Use subject to Section 4.9.13.Q, and 4.9.4.I.2, .3, and .7b of the Unified Development Code (UDC) and requires approval through a Zoning Examiner Special Exception Procedure, in accordance with UDC Sec. 3.4.3, for a new wireless communications facility. The applicant’s RF frequency analysis demonstrates the tower fills an existing gap in coverage and is located over a mile from any existing wireless communications facility. The Zoning Examiner Special Exception Procedure requires a public hearing before the Zoning Examiner, after which the Zoning Examiner renders a decision to grant the use with or without conditions, or to deny the use. Planning & Development Services Department Recommendation – The Planning & Development Services Department recommends approval of the special exception request, subject to the attached preliminary conditions. Background Information Existing Land Use: The parcel is currently vacant, with occasional food truck use on the area southwest of the proposed cell tower site. Zoning Description: PAD (Planned Area Development Zone): The purpose of the Planned Area Development zone is to enable and encourage comprehensively planned development in accordance with adopted plans and policies. The PAD is a zoning classification which provides for the establishment of zoning districts with distinct standards. Surrounding Zones and Land Uses: North: Zoned SR; Pantano Wash South: Zoned SR; Vacant capped landfill East: Zoned SR; Animal Production West: Zoned R-2; Vacant, residential subdivision development proposed Previous Cases on the Property: The Harrison Road Inert Materials Landfill PAD was adopted my Mayor & Council on September 9, 2020 through rezoning case C9-20-03. The PAD and landfill were designed to facilitate the remediation of the former Harrison-Escalante Sand and Gravel Mine, which was an open pit aggregates operation located in Pima County. The mine was no longer in operation, the PAD establishes the landfill as well as setting land use guidelines for interim and future uses of the landfill site. Related Cases: The Pantano East Area Plan was amended on June 4, 2019 through plan amendment case PA-18-02 to add Subarea 6 to the Plan area. It created policy guidelines for the creation of the Inert Materials Landfill PAD and setting long-term Park Industrial land-use goals for the site. Applicant’s Request – The applicant requests special exception approval for the placement of a 70-foot-high cellular communications monopole. The monopole’s purpose is to resolve coverage gaps in the area and increase the bandwidth available to nearby wireless customers. The 70-foot height of the tower would provide opportunities for co-location to limit unnecessary proliferation of towers in the future. The pole and ground equipment will be contained within a 50 by 50-foot ground equipment area and screened by a chain-link fence. Planning Considerations – Land use policy direction for this area is provided by Plan Tucson and the South Pantano Area Plan. Plan Tucson identifies this area in the Future Growth Scenario Map as "Existing Neighborhoods" and supports complementary development which maintains a neighborhood feel and encourages new services and amenities that contribute to neighborhood stability. Policy A.25 requires that, if possible, wireless communication facilities be located, installed and maintained to minimize visual impacts and preserve views. The proposed wireless communication facility will fulfill demonstrated gap in coverage and bandwidth, which in some areas in the RF study area are insufficient for in-vehicle coverage. The site is within South Pantano Area Plan Subarea 6, which encourages the use of a PAD district to support future development with Park Industrial uses per Plan policy guidance. The applicant estimates that the proposed development will not generate additional measurable vehicle trips per day. ADOT and DTM have provided no comments concerning this development. Design Considerations Land Use Compatibility – The proposed monopole will be designed to accommodate future wireless carriers. There are no existing cell towers within one mile of the special exception site, and no existing structures to mount antennas at this location. By providing space for future carriers on a 70-foot monopole, the opportunity for other carriers to improve their services will be available without the construction of further poles in the area. The proposed height ensures that antennas co-located on the monopole will offer coverage to a wider area without necessitating additional monopoles. The applicant submitted a set of photo-sims depicting the tower in both a rusted and sky-blue finish. The tower location is in the vicinity of Pantano Wash, and all surrounding views would be from a higher elevation than the tower base. The photo-sims illustrate that at a distance, most viewing angles show terrain behind the tower rather than sky, and the rusted finish is appropriate for this location. The tower was originally proposed much closer to Pantano Wash, but engineering comments during the intake review indicated the tower would need to be moved at least 360 feet south of the wash to stay clear of the erosion hazard setback area. The applicant updated their preliminary development plan to relocate the tower south to comply. The preliminary development plan depicts a 137.5-foot setback to the west property line. The tower must be twice the height of the tower from any residential zone, and so at the time of development the tower should be moved slightly east to ensure it is at least 140 feet east of the western property line. This modification would still generally conform to the preliminary development plan and can be addressed at the time of development package submittal. Cell tower location maps were provided showing limited service in structures and vehicles in the area surrounding the special exception site. The area to the west of the landfill is in the planning stages for a new residential subdivision, and this tower would fill coverage gaps and provide additional bandwidth for cellular devices in the area. Staff acknowledge that the proposed monopole will help improve telecom services to the area and acknowledge the placement of wireless broadband antennas will help fulfill a communications infrastructure need. The monopole and ground equipment will be placed within a 2,500 square foot ground equipment area. Ground equipment will be housed inside cabinets within an area secured by a 7-foot-4-inch chain-link fence preventing access to the site. The landfill itself is surrounded by an earthen berm which limits visibility into the site. As the ground equipment area would be behind the berm, a chain-link fence is an acceptable enclosure material. If any part of the proposed chain-link enclosure is visible from a position on the ground outside of the landfill perimeter berm, then the enclosure should be a rusticated CMU wall at least 6 feet in height. Road Improvements/Vehicular Access/Circulation – No road improvements are proposed with this project. Vehicular access to the wireless communications facility is by way of a proposed access easement to Harrison Rd. Federal Regulations – Because this Special Exception application involves a request for a wireless communication facility, the Zoning Examiner’s consideration of the application is impacted by the application of federal laws specific to wireless communications. While federal law does not entirely preempt local decision-making authority based on legitimate zoning requirements, such as community aesthetics and compliance with stealthing requirements, it does impose the following limitations: 1) The decision on the application must occur within the “shot clock” period as provided under federal law, which for this type of application is 150 days. In this case, the application was accepted on June 2, 2026 and the “shot clock” period will expire on October 30, 2026. If a decision is not rendered within the “shot clock” period, the review and consideration process is presumed to be unreasonable and affords the applicant the opportunity to file a lawsuit. If sued, the City would need to prove that it acted “reasonably” when it failed to act within the established “shot clock” period. 2) The evaluation of the request cannot include consideration of potential environmental or health effects of radio-frequency (RF) emissions where, as here, the facility will comply with FCC regulations and standard on such emissions. 3) The decision on the application cannot unreasonably discriminate among providers of functionally equivalent services. A denial may be deemed to be “unreasonable discrimination” if the facility is designed and situated similarly to other previously approved facilities and is no more intrusive than those previously facilities. 4) The decision may not have the effect of prohibiting the provision of wireless services, or of causing a significant gap in the applying provider’s coverage. In this context, the relevant issues are: (1) whether the applicant has shown a significant gap in service coverage; and (2) whether the proposal to fill this gap is the least intrusive means of doing so, or whether there are alternative sites that would fill the gap. 5) In the event of a denial, that decision and its reasons must be delivered to the applicant in writing, and must be supported by substantial evidence. Given these constraints, the Zoning Examiner’s recommendation on this application should focus on whether the applicant has demonstrated a significant coverage gap; whether that gap could be addressed through an installation at an alternative site; and whether the proposed concealment/stealthing measures are sufficient to meet the City’s requirements. The Zoning Examiner should also consider how this application compares to other prior applications for similar facilities. In the event of a recommendation for denial, the reasons must be stated so they can be incorporated into a written decision and captured in the meeting minutes. Use-Specific Standards – The applicant’s proposal requires approval as a Zoning Examiner Special Exception and must meet the Use-Specific Standards of UDC Sections 4.9.4.I.2, .3, and .7.b. The Zoning Examiner shall render a decision to grant the use with or without conditions, or to deny the use. Below is the analysis of the performance criteria. 4.9.4.I.7.b The following requires approval as a special exception in accordance with Section 3.4.3, Zoning Examiner Special Exception Procedure. b. Wireless communication antennas provided: (1) The antennas are mounted on a new tower, and the tower and antennas are concealed or disguised, or the antennas are collocated on an existing structure; The 70-foot monopole shall be painted in a rusted finish to blend with the surrounding terrain. (2) The tower and antennas are architecturally and/or environmentally compatible with the surrounding structure(s) and general area; The rusted finish of the monopole shall complement the rural character of nearby animal production land uses by avoiding bright, more modern-looking finishes. (3) A new tower is set back at least two times the height of the structure from the boundary of any property zoned residential or office; and, The 70-foot monopole shall be located at least 140 feet from the western property boundary. (4) The tower and antennas are 80 feet or less in height. The monopole is proposed to be 70 feet in height. Staff finds the proposal to be in compliance with the UDC’s Use-Specific Standards. Conclusion – The proposal is in compliance with the performance criteria for a wireless communication facility. The special exception request is consistent with policy direction in Plan Tucson, which supports development designed to be compatible with and sensitive to surrounding land uses. Staff acknowledge that the WCF will help improve telecom services in the area. Subject to compliance with the attached preliminary conditions, approval of the requested special exception is appropriate. PRELIMINARY CONDITIONS: PROCEDURAL 1. A site plan in substantial compliance with the preliminary development plan dated June 12, 2026 is to be submitted and approved in accordance with Administrative Manual, Section 2-06. 2. Any relocation, modification, etc., of existing utilities and/or public improvements necessitated by the proposed development shall be at no expense to the public. 3. Five years are allowed from the date of initial authorization to implement and effectuate all Code requirements and conditions of the special exception land use. 4. A copy of the Special Exception decision letter shall be included with the site plan at the time of permit application submittal. LAND USE COMPATABILITY / CONCEALMENT MEASURES 5. The wireless communication monopole shall not exceed seventy feet in height from grade elevation. 6. The monopole shall be a rusticated finish. Antennas and other visible ancillary equipment on the monopole shall be painted or finished to blend in with the monopole. 7. Ground equipment to be located within lease area as depicted on the preliminary development plan dated June 12, 2026. 8. The ground equipment area shall be screened by an at least 6-foot CMU wall, which may then be topped with up to three strands of security wire. |
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| External Reviewers - Arizona Department of Transportation (ADOT) | REVIEW COMPLETED | ADOT has no comments. Thanks, Rick Freije, M.S.C.E., P.E. Regional Traffic Engineer SOUTHERN REGION TRAFFIC 1221 S 2nd Ave. Tucson, AZ 85713 Office: 520.388.4203 Mobile: 520.576.8614 | azdot.gov |
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| External Reviewers - AZ State Land | REVIEW COMPLETED | ||||
| External Reviewers - COT Environmental Services | REVIEW COMPLETED | ||||
| External Reviewers - COT Parks & Recreation | REVIEW COMPLETED | ||||
| External Reviewers - Davis Monthan AFB | REVIEW COMPLETED | ||||
| External Reviewers - PC RFCD | REVIEW COMPLETED | ||||
| External Reviewers - Pima Association of Governments | REVIEW COMPLETED | ||||
| External Reviewers - Pima County Addressing | REVIEW COMPLETED | Good afternoon, Pima County Addressing does not have comments for TP-ENT-0526-00010. Thank you, David Wilging Planner I - Addressing Division Pima County Development Services 201 N. Stone Avenue 1st Floor Tucson, Arizona 85701 520-724-6381 |
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| External Reviewers - Pima County Assessor | REVIEW COMPLETED | ||||
| External Reviewers - Pima County Development Services | REVIEW COMPLETED | June 17, 2026 SENT VIA EMAIL Gabriel Sleighter Entitlements Section, Planning and Development Services Department City of Tucson Tucson, AZ 85701 Subject:TP-ENT-0426-00010 – S. Harrison Rd. Dear Gabriel: Thank you for the opportunity to review and comment on City of Tucson TP-ENT-0526-00010 – S. Harrison Rd, for a special exception for proposed wireless communications facility in the PAD4H zone, located on the west side of S. Harrison Rd., near the intersection of E. Millimar Rd and S. Harrison Rd. The request represents aa proposal to construct a new 70-foot-tall cell tower (wireless communication facility). The site is a former quarry and currently is used as a landfill. There are some residential uses to the east across Harrison Road, however there is a significant amount of land that is not being used for residential, commercial, or industrial uses in the other three cardinal directions. As the tower is being sited in the northwest corner of the property, there should be a limited impact on surrounding residential uses. Pima County Development Services Department, Planning Division supports the proposed rezoning request. Sincerely, Spencer Hickman Planner II Pima County Development Services Department, Planning Division |
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| External Reviewers - Pima County Natural Resources | REVIEW COMPLETED | ||||
| External Reviewers - Pima County Transportation | REVIEW COMPLETED | ||||
| External Reviewers - Pima County Wastewater (RWRD) | REVIEW COMPLETED | ||||
| External Reviewers - Tohono Oodham | REVIEW COMPLETED | ||||
| External Reviewers - Tucson Airport Authority | REVIEW COMPLETED | July 2, 2026 Gabriel Sleighter Public Works Building 1st Floor 201 N. Stone Avenue Tucson, AZ. 85701 RE: TP-ENT-0526-00010, Pandora WCF – S Harrison Rd, Ward 4, Received June 15, 2026 Dear Mr. Sleighter, Thank you for the opportunity to comment on TP-ENT-0526-00010 – S Harrison Road, a request for a special exception land use permit for a wireless communication tower on approximately 55.56 acres of land. This special exception land use permit is located 4,400 feet northwest of intersection of East Irvington Road and South Harrison Road. This site does lie within FAA Part 77 airspace. Below are the responses that the FAA Pre-Screening Tool provided on the applicant’s project. 1) Based on the information you provided, you are required to file notice with the FAA. You must submit notice at least 45 days before the start of the proposed construction or alteration or the date an application for a construction permit is filed, whichever is earliest. 2) Note: If you propose construction or alteration that is subject to the licensing requirements of the Federal Communications Commission (FCC), you must submit notice to the FAA on or before the date that an application is filed with the FCC. Visit FCC Licensing to learn more. The Tucson Airport Authority is requiring the below conditions of approval to be included within the approved special exception land use request. Conditions of approval: 1. “The applicant shall file FAA Form 7460 with the FAA at least 45 days before construction activities begin unless FAA staff, with the Obstruction Evaluation / Airport Airspace Analysis (OE/AAA), provides the project applicant with written communication that filing FAA Form 7460 is not required. It is highly recommended that the applicant file earlier than 45 days to provide the applicant with sufficient time to respond to any concerns which are identified by the FAA. Any cranes which are used must also be identified with Form 7460. Please file Form 7460 at https://oeaaa.faa.gov/oeaaa/external/portal.jsp” Please do not hesitate to contact me if you have any questions or concerns regarding this comment letter. I may be reached by email at srobidoux@flytucson.com or by telephone at 520- 573-4811. Respectfully, Scott Robidoux, C.M. Manager of Planning |
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| External Reviewers - Tucson Electric Power (TEP) | REVIEW COMPLETED | June 29, 2026 City of Tucson Gabriel Sleighter Entitlements Section RE: TP-ENT-0526-00010 – Pandora WCF – S Harrison Rd Dear Mr. Sleighter; On behalf of Tucson Electric Power (TEP), thank you for the opportunity to comment on this Special Exception Land Use Permit memorandum. TEP has no objections to this memo. This property is located within TEP’s service territory. Please email me with any questions or concerns. I can be reached at Jenna.Reilly@tep.com, or by phone at (520) 734-5488. Respectfully, Jenna Reilly Environmental & Land Use Planner II Tucson Electric Power Company A UNS Energy Corporation |
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| External Reviewers - Tucson Unified School District (TUSD) | REVIEW COMPLETED | ||||
| Fire New Construction | REVIEW COMPLETED | ||||
| Historic | REVIEW COMPLETED | The project area is not located within any Historic District. The project area, which is highly disturbed, is not located within an Archaeological Sensitivity Zone, and a review of records does not indicate that any archaeological site has been documented within or near the project footprint. | |||
| IPC - Entitlements | REVIEW COMPLETED | Applicant updated PDP for erosion hazard setback. Revised my analysis, the Zoning Examiner Special Exception is the route for approval of this request. | |||
| IPC - Fire New Construction | REVIEW COMPLETED | ||||
| IPC - Site Engineering | REVIEW COMPLETED | 1. Per city code section 26-7.1 the minimum erosion hazard setback for a straight section of the Pantano Wash is 360 feet measured from the top of bank. This line needs to be delineated on the plans and the tower would need to be located outside of this setback. Stephen Blood (520) 837-4958 Stephen.blood@tucsonaz.gov |
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| IPC - Site Zoning | REVIEW COMPLETED | ||||
| IPC - Traffic Engineering | REVIEW COMPLETED | No Comments | |||
| ROW Engineering Review | REVIEW COMPLETED | No comments - GS | |||
| Signs | REVIEW COMPLETED | All proposed signage to be per current sign code standards and applied for under separate sign application. | |||
| Site Engineering | REVIEW COMPLETED | 1. Per city code section 26-7.1 the minimum erosion hazard setback for a straight section of the Pantano Wash is 360 feet measured from the top of bank. This line needs to be delineated on the plans and the tower would need to be located outside of this setback. Stephen Blood (520) 837-4958 Stephen.blood@tucsonaz.gov |
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| Site Landscape | REVIEW COMPLETED | PLANNING AND DEVELOPMENT SERVICES DEPARTMENT REVIEWER: CHAD KELLER, PLA SITE LANDSCAPE/NATIVE PLANT PRESERVATION SECTION PROJECT: 70' RUSTICATED MULTI-CARRIER WIRELESS COMMUNICATIONS FACILITY WITH ASSOCIATED GROUND EQUIPMENT IN 50' X 50' COMPOUND ACTIVITY NO: TP-ENT-0526-00010 ADDRESS: 4200 S HARRISON RD ZONING: PAD-40 HARRISON LANDFILL PAD LAND USE: UTILITY SERVICE 7.1.2026 THE COMMENTS PROVIDED ARE PRELIMINARY AND ARE NOT TO BE ASSUMED AS A COMPLETE REVIEW OF THE PROPOSAL. DURING THE DEVELOPMENT PACKAGE REVIEW PROCESS, A FULL REVIEW WILL BE MADE BY THE SITE LANDSCAPE/NPPO REVIEW SECTION TO ENSURE COMPLIANCE WITH THE APPLICABLE CITY OF TUCSON UNIFIED DEVELOPMENT CODE, TECHNICAL STANDARDS MANUAL AND ADMINISTRATIVE MANUAL REQUIREMENTS FOR SITE LANDSCAPE, NATIVE PLANTS AND RAINWATER HARVESTING. PAD 40 - HARRISON LANDFILL DOCUMENT - SITE LANDSCAPE COMMENTS: 1. PAD 40 Document page 17 - F. Landscape and Screening • Standards for Permitted Uses and Special Exception Uses: Development of the property with Permitted Uses or Special Exception Uses, whether such development occurs during the interim phase or after the termination of the interim timeframe shall conform to the UDC requirements for Landscaping and Screening in UDC Section 7.6. This PAD does not preclude applicants from applying for a Design Development Option (DDO) per Section 3.11.1 of the UDC. 2. *PER UDC TABLE 7.6.4-1 UTILITY SERVICE LAND USE ADJACENT TO RESIDENTIAL ZONE REQUIRES A 6’ MASONRY WALL. LOOK AT CHANGING THE CHAIN-LINK PERIMETER FENCE TO A MASONRY WALL. 3. PAD 40 Document page 17 - F. Landscape and Screening - PROPERTY LINE SCREEING AND LANDSCAPE BORDERS East property line has an existing earth berm for screening and supplement plantings in the Harrison Road Greenway Landscaping (per below) • New plants used for perimeter landscape borders shall be drought-tolerant species. All new plant materials used must be selected from the Arizona Department of Water Resources’ Low Water Use/Drought Tolerant Plant List. 4. The landscape border planting requirements along the west property line shall be as follows: • Canopy trees, meeting the size requirements of TSM 5-01.5.0, shall be planted every 33 linear feet per UDC 7.6.4.C.1. • Drip irrigation for the canopy trees shall be installed per an approved landscape plan. • Passive water harvesting tree wells with a minimum containment depth of 6- inches shall be placed around each canopy tree. Where located on or adjacent a slope, the well shall be open on the up-gradient side to capture runoff from the slope area. • Ground cover and vegetative cover requirements within the landscape border shall be only to hydroseed the landscape border. Hydroseeding shall conform to the Native Seed List standards of TSM 5-02.6.0 Exhibit I. Supplemental plantings within the Harrison Road Greenway shall conform to the Greenway planting guidelines specified in the Pima Regional Trail System Mater Plan, as shown on Page 61 of that document which is included below with pertinent sections indicated by red arrows. The existing vegetation shall be supplemented to increase the canopy tree density to one per 33 linear feet of Greenway length. Where possible, supplemental trees shall be placed to alternate from one side of the paved multi-use path to the other with varying distances from the path edge. An approved landscape plan and right-of-way use permit shall be required. 5. PAD 40 Document page 43 - O. Vegetation and Wildlife Vegetation on the subject property is generally sparse with some areas with moderate to dense growth of weeds, shrubs and trees. It is not expected that any vegetation within the interior will be preserved due to the nature of the landfill activities. A native plant inventory and mitigation plan should be prepared. Typical desert wildlife is expected to be present onsite but there are no Protected Riparian Areas present due to the lack of floodplain areas. 6. *Note: If any plantings are proposed with this project, an irrigation plan will be required. Thank you. Chad Keller, PLA Landscape Architect chad.keller@tucsonaz.gov 520.837.4923 |
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| Site Zoning | REVIEW COMPLETED | 1. COMMENT: Correct the ZONING classification on the first sheet to state the ZONING is PAD-40. Currently the note says the ZONING is PAD-4H. 2. COMMENT: Include the applicable use specific standards adjacent to the USE note on the plan set. The applicable use specific standards are UDC 4.9.4.I.2, .3, & .8. |
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| Streetcar Track Access Review | REVIEW COMPLETED | ||||
| Sun Tran Review | REVIEW COMPLETED | ||||
| Tucson Water New Area Development | REVIEW COMPLETED | Based on the information provided, Tucson Water has no objections to the proposed development. If any new domestic water, irrigation water, or fire water services are needed to serve this proposed development, please contact Tucson Water’s New Services Section by calling 520-791-5164 or by sending an email to TW_Common@tucsonaz.gov. The above comments are based on the limited preliminary information provided by the applicant and should not be construed as a complete review of the proposal. Any questions, comments or concerns about these comments may be directed to Abdullah Salman (Project Manager) at Abdullah.Salman@tucsonaz.gov. |