Sunridge Power Plant

Community reviewers identify omitted or minimized discussion of yellow-billed cuckoo, Bendire’s thrasher, cactus ferruginous pygmy-owl, bats, migratory birds, and other wildlife.

The concern is not that every reported species is proven to occupy the plant parcel. It is that the biological record must use an appropriate study area, seasonal timing, survey method, and source inventory before concluding that presence or impact potential is low.

The community submission points to reported yellow-billed cuckoo use near Los Robles Wash, a Bendire’s thrasher observed during project surveys, suitable cactus ferruginous pygmy-owl habitat near Ironwood Forest National Monument, nightly bat activity near the wash, and broader migratory-bird use. It asks for the underlying occurrence records, complete survey protocols and appendices, species-specific lighting and noise analysis, collision analysis, and any consultation with wildlife agencies.

These are community-raised observations and interpretations that should be tested against official records and qualified biological review. Before certification, the applicant should explain which species and habitats were evaluated, why any species were omitted, whether surveys covered the transmission corridor, and what enforceable protections would apply if protected or sensitive wildlife is found.

The proposed transmission line is a major project component, yet community reviewers say key studies use a plant-centered study area that does not fully cover the corridor.

A five-mile transmission connection can create impacts beyond the generating-site boundary. Community reviewers ask whether the full route and every alternative were surveyed for wildlife, washes, lighting, noise, collision risk, views, access, and nearby properties.

Particular questions concern migratory-bird collision risk near washes, bat activity near Los Robles Wash, the location of the proposed western substation, and whether biological surveys followed each potential route. The record should show route-specific methods, results, alternatives, and mitigation.

Before approval, the applicant should provide a corridor-wide analysis that uses consistent boundaries and explains how route selection will avoid, minimize, and monitor impacts.

Community reviewers dispute a broad characterization that no riparian habitat is nearby and request analysis of Los Robles Wash, the Santa Cruz River, local wells, and construction runoff.

Los Robles Wash and the Santa Cruz River are raised as nearby features used by wildlife and migratory birds. The public record should distinguish the plant parcel itself from adjacent riparian or xeroriparian functions and explain the geographic basis for any statement that habitat is absent or outside the project vicinity.

The same concern includes hydrology. Reviewers ask for cumulative groundwater analysis, effects on nearby wells and sensitive corridors, sediment and contamination controls at wash crossings, and reconciliation of differing statements that project water use would be either 30 percent or 16 percent less than historical agricultural use.

Those percentages are characterized here as community readings of the application and should be checked against the filed record. A useful response would cite the precise pages, baseline, demand assumptions, drought scenarios, and enforceable monitoring or contingency measures.

The monument boundary is approximately 0.5 miles from the Sunridge property and less than 6,000 feet from the Phase 1 facility itself, yet it is omitted from multiple application sections.

Ironwood Forest National Monument is relevant not simply as a named landmark but as nearby habitat, a recreation destination, a dark-sky resource, and part of the regional setting. Community reviewers ask the applicant to identify every section in which the monument was included or excluded and the boundary used for each analysis.

The submission notes nearby habitat potentially relevant to cactus ferruginous pygmy-owl, desert bighorn connectivity, xeroriparian migratory-bird habitat, recreation, and a pending dark-sky designation. The designation is described as pending, not complete.

The committee should require consistent treatment of the monument across biological, visual, lighting, recreation, access, and cumulative-impact analyses, supported by maps and source citations.

The application acknowledges the Ironwood–Picacho linkage, but community reviewers request movement studies or connectivity modeling addressing project-specific fragmentation risks.

This concern is separate from the page-538 bighorn inventory issue. The question is not whether the linkage exists; it is whether the project record adequately evaluates how the proposed facilities could change its function.

Community reviewers ask for analysis of fencing, nighttime lighting, construction and operational noise, transmission-line collision hazards, and expanded access roads. They also ask the applicant to identify wildlife-agency coordination, movement data, connectivity modeling, and design changes intended to preserve passage.

The committee should require a clear project-specific linkage analysis and enforceable measures tied to measurable outcomes, rather than relying only on a passing acknowledgment that the linkage is present.

Community reviewers say nearby habitat, the transmission corridor, the national monument, and riparian corridors receive inconsistent treatment depending on the section.

A conclusion can change substantially when the boundary changes. Community reviewers point to habitat approximately 0.8 miles away being treated as outside the project vicinity, transmission impacts being excluded from a plant-centered study area, the adjacent national monument being omitted, and nearby riparian corridors being dismissed.

The applicant should provide a glossary and map for every core geographic term, list the radius or polygon used in each discipline, and explain any difference. Where different study areas are scientifically justified, that justification should be explicit rather than inferred.

Consistent definitions are necessary for the committee and public to compare findings across wildlife, water, noise, lighting, views, recreation, and cumulative impacts.

The Species of Concern table on page 538 of the Sunridge CEC Application does not include desert bighorn sheep, even though documented photographs place them inside the table’s stated five-mile study radius.

Desert bighorn sheep are completely missing from the Species of Concern table on page 538 of the Sunridge CEC Application. The application itself places the proposed site in the Ironwood–Picacho linkage, so this concern does not need to re-establish the linkage. The immediate problem is whether a five-mile Species of Concern study that omits a documented large mammal present within that radius can be treated as serious or complete.

Kiley Hyatt states that three witnesses observed a desert bighorn sheep on September 7, 2019, approximately three miles from the proposed plant site. Hyatt is willing to sign a sworn affidavit concerning the authenticity and circumstances of the sighting. The downloadable original HEIC contains embedded camera metadata reporting an Apple iPhone 7, a device-recorded time of September 7, 2019 at 7:57:35 a.m., and GPS coordinates inside the study radius. The matching JPEG is shown without labels, with explanatory labels, and as a labeled crop. The original file and its checksum are provided for independent inspection.

John Davis also photographed desert bighorn sheep well within five miles of the proposed Sunridge plant on July 11, 2023. The original-capture timestamps embedded in all three supplied files report that date. Davis reports that the camera used does not record geolocation, and the files contain no usable GPS coordinates. Their precise location is intentionally withheld from filenames and public captions to help protect the herd.

Together, the 2019 geolocated file, witness account, and 2023 photographic record document desert bighorn presence within the area Sunridge says its table covers. Yet page 538 does not list or evaluate the species. Without consistent explanation for that omission, a complete disclosure of the records and methods used to compile the table, and a species-specific assessment responsive to this evidence, the application lacks sufficient information to support certification of environmental compatibility. A.R.S. § 40-360.06 requires consideration of effects on wildlife and the area’s total environment; that determination cannot rest on an incomplete Species of Concern inventory.

Community reviewers identify recurring qualifiers such as “when feasible,” “where possible,” and “to the extent practicable.”

Mitigation language does not provide reliable protection when it leaves performance optional, does not identify who must act, or supplies no measurable standard, deadline, monitoring method, reporting requirement, or consequence for failure.

The application should provide a mitigation table that connects each identified impact to a specific measure, responsible party, implementation date, verification method, public reporting mechanism, and enforcement authority. Any qualifier should be defined and supported by a documented decision process.

The committee can then distinguish enforceable certificate conditions from aspirations or best-effort statements and decide whether the remaining impacts are environmentally compatible.

Community reviewers say the application acknowledges cumulative effects but provides limited analysis of other existing and reasonably foreseeable development.

A project can meet an individual standard while still adding to a broader regional burden. The requested cumulative assessment should identify the geographic and time horizon, existing facilities, approved projects, reasonably foreseeable projects, shared transmission and water demands, and affected resources.

The analysis should address wildlife linkage function, groundwater draw, recreation and access, air pollution, noise, lighting, views, and construction overlap. It should explain which projects were included and excluded and avoid treating each resource with an inconsistent regional boundary.

This concern does not assume a cumulative violation. It asks for enough transparent analysis to let the committee judge the total environment and consider enforceable conditions based on combined effects.

The flood data used for Sunridge is not adequate for this siting decision. The official flood data is out of date for this site because it does not account for the site-specific effect of upstream mitigation built after 1983, which may force more floodwater downstream toward Red Rock, Missile Base, and the proposed plant. A new hydrologic and hydraulic study is necessary before approval.

The flood data used for Sunridge is not adequate for this siting decision. It does not demonstrate what happens at the proposed plant during a repeat of the approximately 65,000-cubic-feet-per-second October 1983 flood under today’s changed upstream conditions. That is the central danger: a model can follow an official map and still understate the flood that may actually reach this site.

In 1983, upstream mitigation projects that exist today had not yet been built. Part of the recorded upstream flood volume could spread or be retained before it reached Red Rock, reducing the flow that continued downstream. Those later projects now constrain or redirect water upstream. The current public record does not demonstrate that Sunridge’s flood model compensates for the possibility that more of the same 65,000 CFS volume would now be driven downstream toward the still-unmitigated Red Rock and Missile Base area.

The proposed property is close to the Santa Cruz River in both distance and elevation. Lifelong Red Rock residents identified the location reached by the 1983 flood, and that testimony-based high-water location is marked on the map with a blue X. The marked location has not been independently surveyed, but it is material evidence that must be tested—not dismissed—against current elevations and current upstream conditions.

The witnessed 1983 location may reflect only about 75 percent of the 65,000 CFS recorded immediately upstream if roughly 25 percent was dispersed or retained before reaching this area. Under present upstream conditions, a similar event could deliver that additional share downstream and produce a substantially higher water level than the witnessed mark. This is not presented as a completed engineering calculation. It is a specific, consequential scenario that the existing record has not resolved and that requires new site-specific hydrologic and hydraulic modeling.

Before any approval, the committee should require an independent study using the 1983 upstream flow, today’s upstream mitigation, current terrain, existing and finished site elevations, and failure scenarios above the modeled flood level. The study must show whether a raised plant pad or protective wall would redirect water toward Sasco Road, neighboring properties, Red Rock, Missile Base, or the Santa Cruz River. This work is necessary to protect lives, prevent the plant and electrical infrastructure from being overwhelmed, and avoid a potentially catastrophic release or environmental impact during the next extreme flood.

The record must also answer this basic question: If Pima County & the Federal Government require 20-foot-high walls with 10-foot-deep footings, then why wouldn’t properties immediately downstream be required to do the same?

The applicant’s CEC filing estimates annual emissions of particulate matter, nitrogen oxides, carbon monoxide, volatile organic compounds, sulfur dioxide, sulfuric acid mist, hazardous air pollutants, and more than 5.4 million tons of carbon-dioxide equivalent.

These are not abstract numbers. Fine particles can travel deep into the lungs and bloodstream. Nitrogen oxides contribute to ozone and particle pollution. Some volatile organic compounds and hazardous air pollutants are known or suspected to cause cancer or other serious effects. Children, older adults, people with asthma, and people with heart or lung disease can be especially vulnerable.

The application’s estimates do not by themselves prove that the plant would violate a legal standard or that any particular person would become ill. They do establish the scale of pollution that regulators and the public must evaluate. Before approval, the developer should show the modeled concentrations, assumptions, control efficiencies, startup and shutdown emissions, cumulative effects with nearby sources, monitoring plan, and enforceable limits in language the community can understand.

The final county air permit is where enforceable pollution limits, control equipment, monitoring, reporting, and consequences for violations must be established. The state siting process has a separate responsibility to decide whether this location is environmentally compatible. Meeting a numerical permit limit is a legal requirement, but it is not the same as proving that adding another major source beside an established community is the wisest or most health-protective choice.

Red Rock Elementary is an established PK–8 school near the proposed plant. Federal school data reports 420 students, making “about 400 children” a reasonable description.

Children are not simply another point on a map. Their lungs and bodies are still developing, they spend many hours at school, and the U.S. EPA identifies children as especially sensitive to several pollutants associated with combustion. Before approving this location, the developer and decision-makers should explain why it is acceptable to add a major emissions source roughly three miles from a school serving about 400 children and what enforceable protections would prevent harmful exposure.

A.R.S. § 40-360.06 gives the siting committee meaningful authority. It may approve or deny an application and may impose reasonable conditions. In judging whether the site is suitable, it must consider state and local plans for other developments at or near the site, the proposed plant’s effects on the area’s “total environment,” and any additional factors it considers relevant. The statute also requires every certificate to contain a condition mandating compliance with applicable air- and water-pollution standards.

The statute does not name schools as an automatic exclusion zone and does not establish a three-mile prohibition. But the school’s location, enrollment, daily occupancy, outdoor activity, emergency-planning needs, and children’s heightened susceptibility are relevant evidence about the total environment and the suitability of this particular site. The committee can demand evidence, impose health-protective conditions, or deny the application if the overall record does not support environmental compatibility.

The proposal would contribute to a future cluster of large industrial energy facilities around the established residential community of Red Rock and Missile Base.

Arizona’s established generation areas provide an important factual benchmark. Major facilities have been grouped in the Gila Bend area, the western Maricopa corridor around Arlington, Tonopah, and Harquahala—including Redhawk, Mesquite, Arlington Valley, and Harquahala—and the Springerville generation area. These projects commonly share remote industrial and transmission landscapes with substantial separation from established residential centers.

That history shows an administrative siting pattern, but this site has not identified a controlling Arizona court decision or statute that creates a categorical rule requiring every power-plant cluster to be far from communities. Prior CEC approvals are fact-specific, and older generating plants also exist in developed urban areas. The concern should therefore not depend on claiming a binding legal precedent that has not been established.

The forceful, supportable argument is that allowing a future cluster of large generating facilities to surround a pre-existing rural community departs from the pattern used for Arizona’s best-known generation clusters. Under A.R.S. § 40-360.06, the committee must examine nearby development plans and the area’s total environment. The applicant should identify every genuinely comparable Arizona case, explain the residential separation at each site, analyze the cumulative pollution and infrastructure burden here, and justify why Red Rock and Missile Base should receive less separation than communities near the state’s established remote generation areas.

Residents report using the wash and surrounding lands for recreation and ask when, where, and for how long access could be restricted.

The proposed transmission infrastructure would cross lands used for recreation. Community reviewers ask whether road closures or construction controls could interrupt access from Red Rock and Missile Base to nearby public lands, the wash, or Ironwood Forest National Monument.

A statement that access will resume after construction does not identify what access may be lost before or during construction. The applicant should map current routes, legal access status, closure areas, duration, detours, safety restrictions, restoration commitments, and any permanent change.

The committee should evaluate both formal access rights and the practical effect on established community recreation, while distinguishing State Trust Land requirements from access to federal monument land.

The proposed plant would convert land associated with agricultural use to long-term industrial energy infrastructure.

Arable land is finite. Converting agricultural land to a power plant, transmission facilities, roads, and related infrastructure can remove acreage from future food or forage production and make restoration difficult even after operations end.

The committee should require a clear accounting of the acreage currently farmed, fallowed, irrigable, or otherwise suitable for agriculture; soil classifications; water rights or irrigation history; the duration and reversibility of the conversion; and alternatives that would avoid higher-value agricultural land. The analysis should also distinguish current agricultural output from the land’s longer-term productive capacity.

This concern does not assume that every acre on the project parcel is presently productive or that agricultural use must always prevail. It asks decision-makers to treat loss of arable land as an environmental and land-use tradeoff, quantify it transparently, and compare it with practicable alternative sites and layouts.

Sunridge held three public meetings. The first drew three attendees after notice went only to immediate neighbors, the second was difficult to hear and see, and the third prevented attendees from seeing or communicating with one another online while leaving dozens of questions unanswered.

A Red Rock Village resident attended Sunridge Power’s three public meetings about this project. The first meeting was held after hours at the school in Red Rock Village, but Sunridge notified only its immediate neighbors. No notice went to the broader population of homeowners and residents in Red Rock Village, a community of thousands. Only three people attended. Sunridge later represented to Pinal County during the permitting process that public interest was low. The county approved the permit before the people of Red Rock Village knew about the project, even though Sunridge’s own documents said the plant would be located in Red Rock.

Red Rock Village residents were finally invited to the second meeting, but many community members could not attend because of conflicting schedules. The meeting was held in a very loud room. The HVAC overpowered the speakers’ voices, and Sunridge did not bring a public-address or other sound system that would allow the audience to hear. People repeatedly said they could not hear what was happening. Even people in the front row had difficulty hearing and asked some speakers to speak much louder. The front row was about 20 feet from a small screen, while the back row was likely 50 feet or more away. The slides were not bright or large enough for a packed room of about 30 people. Community members repeatedly said they could not see the slides. The presenters themselves sometimes could not hear what people were saying over the room noise and had to ask them to repeat themselves more loudly. The second meeting ended with more questions than answers.

The third meeting took place exclusively on Zoom. The meeting interface did not display the attendee count or other attendance statistics, and chat was disabled. Attendees could not see or communicate with one another. They had no option to use a microphone or camera and could not participate in the presentation. The Q&A portal showed each attendee only that person’s own submissions, so no one could see whether anyone else was present or what questions others had submitted. Dozens of questions went unanswered. Sunridge said there would be no further meeting and that the questions had come to an end, even though many questions had not been answered.

The screenshots below show the questions as they appeared to individual attendees and are presented as supplied, with participant names visible. They document the meeting interface and the questions that remained in the record; they do not by themselves establish whether every question was unanswered in full or in part. The applicant and committee should provide the complete question log, written responses, notice distribution record, meeting attendance records, and an explanation of why residents were not given a meaningful opportunity to hear, see, communicate, and receive answers.