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Review Status: Approved

Review Details: ENTITLEMENT REVIEW v.1

Plan Number - TP-ENT-0726-00013
Review Name: ENTITLEMENT REVIEW v.1
Review Status: Approved
Review Date Reviewer's Name Type of Review Description Status Comments
Real Estate NOT REQUIRED The Real Estate Division has no objections or comments regarding this application.
DTM Planning REVIEW COMPLETED
Entitlement Review Coordinator Express REVIEW COMPLETED
Entitlements REVIEW COMPLETED DATE: September 8, 2026
For September 24, 2026 Hearing


TO: Linus Kafka FROM: Koren Manning
Zoning Examiner Planning & Development Services Director


SUBJECT: SPECIAL EXCEPTION LAND USE
PLANNING & DEVELOPMENT SERVICES REPORT
TP-ENT-0726-00013 Sonoran South Solar – 10002 S Swan Rd,
RH Zoning (Ward 5)

Issue – This is a special exception land use request in the RH Rural Homestead zone by Lazarus & Silvyn, P.C. on behalf of the property owner, Tucson Airport Authority, for the development of a utility-scale solar energy facility on approximately 1,400 acres of property located south of E Old Vail Connection Road, on either side of Swan Road (See case location map).

Renewable Energy Generation in the RH zone is subject to section 4.9.11.B.2, .3, .4, & .5 and 4.9.13.I of the Unified Development Code (UDC) and requires approval through the Zoning Examiner Special Exception Procedure, Sec. 3.4.3.

Planning and Development Services Recommendation – The Planning & Development Services Department recommends approval of the requested special exception land use, subject to the attached preliminary conditions.

Background Information

Existing Land Use: The project site consists of largely open space, with some existing surface mining quarries. While these cover a large area, they are relatively shallow compared to quarry sites further north on Swan Road. An existing TEP Substation is located east of Swan Road in the southern half of the project area.

Existing Zoning Description: Rural Homestead (RH) – This zone is intended to preserve the character and encourage the orderly growth of rural areas. It is intended to encourage rural development in areas lacking facilities for urban development and to provide for agriculture, commercial and industrial development only where appropriate and necessary to serve the needs of the rural area. This zone is solely to provide comparable zoning for annexed areas and is not intended for rezoning.

Surrounding Zones and Land Uses:

North – City I-2, P-I, County CI-2; Surface Mining
East – City RH; Arizona State Prison Complex
South – County RH; Single-family residential
West – City RH; Vacant State Trust Land

Previous Cases on the Property: There are no previous Special Exception cases on property.

Related Cases: None

Applicant’s Request – The applicant request is for special exception approval for the Renewable Energy Generation land use on the site with associated site improvements.

The proposed use requires a Zoning Examiner Special Exception in the RH zone.

Planning Considerations – Land use policy direction for this area is provided by Plan Tucson and the Rincon/Southeast Subregional Plan.

Plan Tucson: This location is within the Industrial building block. The project is in proximity to the future Sonoran Spur interstate link between Interstate 10 and Interstate 19, and in an area long-range planned for a variety of industrial uses. Large-scale renewable energy generation at this location is aligned with these goals and Tucson climate and sustainability goals. This project is supported for improving the provision of utilities in a sustainable manner, in a way that’s sensitive to the surrounding environment.

Rincon/Southeast Subregional Plan: This development is not within a Special Area or Map Detail Area of the RSSP, and there are no specific policies in favor of or against the development. The Plan does encourage an Environmental Resource Report, which was included in the applicant’s materials.

Design Considerations

Land Use Compatibility – The subject site consists of primarily open space, with some shallow surface mining operations on the north half of the project area and a TEP substation on the south half. The only nearby residential area is a rural neighborhood in Pima County south of the project site. Swan Road, which bisects the project area, is the only road in and out of this neighborhood. No impacts to residents are expected to the west, north, or east, as that land is undeveloped, surface mining, or the Arizona State Prison Complex, respectively.

The proposal is for utility-scale solar arrays across the project area, which would tie into a collector substation adjacent to the existing TEP substation. A 6’ wall and landscaping will be required along the south edge of the project, where it is adjacent to the single-family residential neighborhood in the County.

Although adjacent to a residential neighborhood, the RSSP and Plan Tucson designate large amounts of land in this area for Industrial Use – renewable energy generation is a low-intensity use of land, and the facility would buffer the existing neighborhood from more intense industrial development in the area, as well as from the Sonoran Spur interstate connector planned north and west of the project area. A large band of riparian habitat crosses the south edge of the project area, which further buffers it from the existing neighborhood.

The project is also located within the Tucson International Airport noise land use overlay areas, which a land use that has very low staffing requirements is more compatible with this type of overlay.

Drainage/Grading – Grading plans will be required during Development Package review showing the extent of disturbed areas, and a drainage report will need to delineate existing floodplain limits and show compliance with development in proximity to Environmental Regulatory Zone washes which run through the site.

Grading will be required to accommodate development in the surface mining areas on the north half of the site. The applicant’s preliminary plans indicate grading will avoid major wash corridors for habitat preservation onsite. The project is designed to maintain the property’s overall drainage characteristics.

Road Improvements/Vehicular Access/Circulation – Vehicle access to the project is proposed at three locations on Swan Road for maintenance personnel only. Renewable Energy Generation generates minimal additional trips and the project would have little to no impact existing roadway capacity.

The northwest corner of the project area is deliberately left undeveloped in anticipation of the future alignment of the Sonoran Spur highway, and the preliminary development plan shows landscaping and screening are contemplated along the corridor when the highway is developed.
Use Specific Standards – Renewable Energy Generation is allowed as a Special Exception in the Rural Homestead zone providing it meets the criteria established in Section 4.9.11.B.2, .3, .4, & .5 of the Unified Development Code (UDC) with approval through a Zoning Examiner Special Exception Procedure, in accordance with UDC Section 3.4.3.

Staff find the proposal to be in compliance with all applicable UDC Use-Specific Standards.

Conclusion –The proposal is in compliance with the performance criteria for a Renewable Energy Generation. The request is consistent with policy direction in Plan Tucson and the Rincon/Southeast Subregional Plan. Subject to compliance with the attached preliminary conditions, approval of the requested special exception is appropriate.
External Reviewers - Arizona Department of Transportation (ADOT) REVIEW COMPLETED ADOT has no comments.

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
External Reviewers - AZ State Land REVIEW COMPLETED
External Reviewers - COT Environmental Services REVIEW COMPLETED ES has no objections to this special exceptions request, as it relates to solid waste storage, collection and disposal.

Andy Vera
(520) 837-3798
Andy.Vera@tucsonaz.gov
External Reviewers - COT Parks & Recreation REVIEW COMPLETED
External Reviewers - Davis Monthan AFB REVIEW COMPLETED DMAFB Planning Staff has reviewed the request for special exception to develop a solar array off Swan Road. This is not within the AEZ overlay zone for the base and shouldn’t negatively impact our flying mission.



Kacey



V/r

B. Kacey Carter, DAFC, USAF ≡✪≡

Installation Community Planner

355th Civil Engineer Squadron/CENPL

Davis-Monthan AFB AZ

☎DSN: 312-3291

☎Comm: 520-228-3291

bonnie.carter@us.af.mil
External Reviewers - PC RFCD REVIEW COMPLETED
External Reviewers - Pima Association of Governments REVIEW COMPLETED
External Reviewers - Pima County Addressing REVIEW COMPLETED Pima County Addressing does not have comments for case TP-ENT-0726-00013.
David Wilging

Planner I - Addressing Division

Pima County Development Services

201 N. Stone Avenue 1st Floor

Tucson, Arizona 85701

520-724-6381
External Reviewers - Pima County Assessor REVIEW COMPLETED
External Reviewers - Pima County Development Services REVIEW COMPLETED
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
External Reviewers - Tucson Electric Power (TEP) REVIEW COMPLETED
External Reviewers - Tucson Unified School District (TUSD) REVIEW COMPLETED
Fire New Construction REVIEW COMPLETED
Historic REVIEW COMPLETED On page II-6 of the Special Exception Land Use Permit Report, the following is written regarding cultural resources: "Preliminary cultural resource analysis indicates no critical issues pertaining to cultural resources on the Property were observed in both literature and records reviews".

Records at the Arizona State Museum indicate that while some portions of the Project Area have been previously surveyed, there are some portions that have not been surveyed. As such, it is unknown whether this project will have a negative impact to cultural resources.

The Historic Preservation Office requests that a qualified archaeological consultant conducts a full Class I research study of the Project Area, in addition to a Class III pedestrian survey of all areas that have not been inventoried in the past 10 years. If the Class I and Class III studies identify cultural resources, mitigation measures may be prescribed (e.g. avoidance, monitoring). Please contact PDSDHistoric@tucsonaz.gov for more information.
IPC - Entitlements REVIEW COMPLETED
IPC - Fire New Construction REVIEW COMPLETED
IPC - Site Engineering REVIEW COMPLETED 1. A grading plan will need to be part of the development package submittal that shows clearing/grading and area of disturbance.
2. A drainage report will be required to delineate existing floodplain limits and show compliance with development in close proximity to ERZ washes throughout the site.
3. 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 Engineering to assure compliance with the applicable City Codes and Standards.

Stephen Blood
(520) 837-4958
Stephen.blood@tucsonaz.gov
IPC - Site Zoning REVIEW COMPLETED
IPC - Traffic Engineering REVIEW COMPLETED No traffic concerns associated with this project.
ROW Engineering Review REVIEW COMPLETED
Signs REVIEW COMPLETED Any new signage must comply with current UDC Sign Code standards.
Site Engineering REVIEW COMPLETED 1. A grading plan will need to be part of the development package submittal that shows clearing/grading and area of disturbance.
2. A drainage report will be required to delineate existing floodplain limits and show compliance with development in close proximity to ERZ washes throughout the site.
3. 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 Engineering to assure compliance with the applicable City Codes and Standards.

Stephen Blood
(520) 837-4958
Stephen.blood@tucsonaz.gov
Site Landscape REVIEW COMPLETED PLANNING AND DEVELOPMENT SERVICES DEPARTMENT
REVIEWER: CHAD KELLER, PLA
SITE LANDSCAPE/NATIVE PLANT PRESERVATION SECTION

PROJECT: SPECIAL EXCEPTION LAND USE TO PERMIT UTILITY-SCALE SOLAR ENERGY PROJECT
ACTIVITY NO: TP-ENT-0726-00013
RELATED CASE NO: TP-PRE-0326-00070
ADDRESS: 10002 S SWAN RD
ZONING: RURAL HOMESTEAD ZONE (RH)
LAND USE: UTILITY SERVICE/UTILITY-SCALE SOLAR ENERGY
8.21.26

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.

SITE LANDSCAPE/NPPO COMMENTS:

The following comments are tied to the orignial review of this site under activity number TP-PRE-0326-00070.

1. This utility service project is subject to the Native Plant Preservation Ordinance, and UDC landscape and screening compliance. At development package submittal, provide all required compliance documentation. The site landscape review section has no other comments or concerns with this solar/utility service project.

Thank you.
Chad Keller, PLA
Landscape Architect
chad.keller@tucsonaz.gov
520.837.4923
Site Zoning REVIEW COMPLETED 1. COMMENT: The proposed development requires compliance with Administrative Manual 2-06 - DEVELOPMENT PACKAGE (SITE PLANS AND TENTATIVE PLATS). As the proposed development is intersected by S SWAN RD, two development packages will be required for the development west of the Swan and the development east of Swan.


Loran Shamis
loran.shamis@tucsonaz.gov
Streetcar Track Access Review REVIEW COMPLETED
Sun Tran Review REVIEW COMPLETED
Transportation Landscape Review REVIEW COMPLETED
Tucson Water New Area Development REVIEW COMPLETED Based on the information provided, Tucson Water has no objections to the proposed development. Tucson Water does not have water service to the planned parcels The parcels are located in the Tucson Water service area, but there are no existing or planned water mains connecting this area to the Tucson water distribution system. Our one water 2100 plan includes a proposed path to serve the zone, but it requires a new reservoir, booster and up to 10 miles of new transmission main. If construction water is needed, please contact Tucson Water’s New Services Section by calling 520-791-5164 or by sending an email to TW_Common@tucsonaz.gov. They can assist with locating the closest option for a construction meter. 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