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By Don McDowell

Arizona Deer Association

Comments on the proposed Vulcan Solar project


September 1, 2023

To whom it may concern,

The Arizona Deer Association is a 501 C3 Non Profit conservation organization, founded in 1996, dedicated to protecting, improving wildlife habitat and expanding Arizona's deer herds, as well as other wildlife species on private and public lands.

This Vulcan Solar Project will require extensive construction damaging an already delicate Lower Sonoran Desert environment and eco system by means of heavy grading, leveling, shrub and vegetation removal and sterilizing thus creating erosion damage to adjacent parcel and runoff problems including silt and sediment buildup and increasing the cost of Aqua Caliente Road maintenance by MCDOT. Desert washes adjacent to the project site including Centennial Wash will be affected by the additional soil distribution by means of uncontrolled erosion due the vegetation removal. The Centennial Wash drainage into the Gila River which already suffers from substantial amounts of soil and sediment build up thus rerouting the flow towards the Painted Rock Dam Reservoir. Another consequence would be the unknown negative impacts upon the Hassayampa River on the Aqua Fria Drainage including negative effects on the Arlington Game Refuse.

This project is taking mutli-use land converting to single purpose use for commercial purposes, removing the acreage from recreational, grazing, hiking and other outdoor activities for good. At the sunset of the project, estimated to be 25-30 years, we would inherit scorched, unusable, flat, sterilized acres that would take generations to recover, if ever. And of course there's the concern of contamination of our precious aquifer system with heavy metals sterilizing chemicals. The ground water contamination would reach far beyond the limits of the project boundaries, with no know methods to decontaminate, flowing to human consumption wells site creating severe health hazards if consumed.

This project is removing Arizona State asset land albeit some deemed Federal Land Managed by the BLM and a portion managed by the AZ State Land Department. The power generated is slated to go to California, leaving Arizonans the devastated once delicate flora landscape contained within the Lower Sonoran Desert Eco system, and lost Wildilfe, wildlife habitat, grazing allotments and recreational and access opportunities.

The Lower Sonoran Desert contains an eco-system containing multiple and varying species of wildlife including Desert Bighorn Sheep, Mule Deer, Javelina, endangered Sonoran Pronghorn Antelope and the seldom seen Sonoran White Tail Deer. This also includes several species of endangered plants and reptiles i.e. Desert Tortoise, Gila Monsters, Bat and seasonal raptors. The ungulate species are utilizing the proposed acreage as migratory routes between the Signal Mountain Wilderness area, Woolsey Peak Wilderness area and the major sections of the Centennial Wash. Solar panel projects have a proven history of negative impact on avian populations and the "lake effect" on migratory water fowl. This project area is on the eastern edge of the migratory water fowl Pacific Flyway.

Another issue of concern is the treatment and preservation of Native American sites, artifacts and over 200 petroglyphs and the original area historic travel roads and trails by their and our ancestors.

In closing, the proposed project should be shelved and the BLM search their land inventory 245 million acres for a suitable expanse to house such a projects that shall not have a negative impact on wildlife, wildlife habitat, eco-system, grazing or grazing allotments, hunting and other outdoor activities and that doesn't place historical Native American sites, cultural heritage at risk.


Don R. McDowell

Past President,

Board Member - AZ Deer Association

Readers Comments

To Whom it may concern: I am a Native Arizonan, my family has worked, lived and enjoyed the out doors in the far west valley for going on 5 generations now. This consideration has been made by someone who has never spent any time in this area and is made completely on ease of connectivity to the grid without regard for wildlife, RARE AND ENDANGERED PLANT LIFE, and CULTURAL, both ARTIFACTS and DWELLING SITES, which are there all through the path of the projected site. My concern is for the LESS THAN INTENSIVE EFFORT to search for the RARE and ENDANGERED PLANT SPECIES, the PROTECTED and ENDANGERED REPTILES and ANIMALS. SEASONAL Migratory corridors and dormancy periods of ALL PLANTS, REPTILES AND ANIMALS. For instance now is the breeding time for the protected GILA MONSTER. They are most active now, they are there. Due to the high heat most people will never venture out until it cools off, by that time they have gone under ground for the COOLER MONTHS. DESERT TORTOISE are also there, they have already gone through there breeding season and gone into their sub terranean homes for the summer. You won't see them unless you are in the right place at the right time, nevertheless, they are there. There are different species of Horned lizards there also. Burrowing owls, screech owls, different types of birds of prey. MY point is, to make a less than intensive effort, (ie; looking at a website for information on what lives and grows in an area) without putting boots on the ground would be a major travesty and a dereliction of duty on ALL our parts. I am willing to spend my time and energy to assist in anyway I can, Please contact me for any assistance.

Best Regards,

David L. Lanford


The proposed central and main portion of the project is on both sides of Agua Caliente Rd a well used recreation and scenic road in relatively undisturbed Lower Sonoran Desert environment.

Note - Go to for more on Agua Caliente Rd

Both Arizona Highways magazine and Sunset magazine publish articles promoting the use and scenic value of the area and road.

Agua Caliente is an all vehicle county road regularly maintained by Maricopa County Department of Transportation.

Proposed, substantial, grading and natural vegetation removal will lead to increased runoff and sediment in washes.

Many originating from Signal Mountain Wilderness area thru an already sensitive environment.

This increased runoff will adversely affect Centennial Wash as well as leased State Trust Land, existing downstream roads , including Old Highway 80, and potentially AZGF Arlington Wildlife area South portion under rehabilitation.

Substantial increased cost for leveling terrain for developer to install solar panels.

Solar project has a stated 30 year life cycle when land is to be restored to previous habitat.

Lower Sonoran Desert habitat would almost be impossible to repair.

I have had professional experience with required "Bonds" to guarantee repair.

It will not go well.

Access to proposed solar project is on and along Agua Caliente road which is frequently impassable due to flooding from Summer rains as well as prolonged Winter storms.

Check with MCDOT, as they frequently barricade and close the road.

There are Wildlife and Flora concerns.

Proposed area is a seasonal migration route of Mule Deer between Signal Mountain Wilderness and Centennial Wash.

Desert Bighorn Sheep as well are in the area.

There are many Burrowing Owl nests as well as other raptors in the area.

Potential endangered Flora.

Many Night Blooming Ceres, Saguaro and other rare cacti in area.

The Eastern proposed parcel has remnants of Native (First) American use as well as historical road and travel use.

Solar project will affect historical grazing permit land as well as increased runoff will damage Arizona State Trust Land grazing permitted areas.

This BLM managed land is rare in that it is on and along a county maintained road thru relatively untouched Lower Sonoran Desert next to two Federally protected Wilderness areas very near our country's fastest growing city.

Heavily used by many different, responsible, outdoor enthusiasts.

Quite frankly Maricopa County should designate Agua Caliente Road and area as a preserved scenic road and area as everything North of Centennial Wash has already been master planned by Maricopa County for development.

Bottom line is BLM has far better land available for solar development both from an economic development cost as well as minimal loss for recreation and historical grazing.

For example, in La Paz County near the Cielo Azul Switching Project currently in development along Interstate 10.

Feel free to contact me to answer questions or for further information.



Subject: Greenlee County Cattle Growers meeting

Good morning Representatives and Senator,

What a good meeting on Saturday. I'm always appreciative of the ranchers, their attendance and participation.

I was very pleased to meet you all and had an opportunity to hear firsthand what you are doing for the State constituency, especially the ranching community. We have so many challenges, it's nice to know that you are working hard on such key issues in common causes. So many times I feel like the Don Quixote out on the landscape fighting windmills, real or imagined.

Last evening, I did forward you my initial comments to BLM on the Vulcan Solar Project as a matter of information.

It appears the fix may be already in on this project, however, we do have a glimmer of hope. And that hope comes for the discovery of endanger plant, animal and reptiles species. The down side is that apparently the BLM had given a green light to the owners of the project, Candela Renewables to hire an unknown entity to conduct some sort of EA or EIA/EIS and seek out wildlife and suspected endangered plants i.e. the Tumamoc globeberry, animals and reptiles. I was told Candela Renewables sent a report to AZ Game and Fish that stated no wildlife found was in the area. That in itself is an incorrect statement. The area is home to Mule Deer, Sonoran Pronghorn Antelope which some are collared, Desert Bighorn Sheep move in an out of the area and there is a little known and seen Sonoran Whitetail Deer, Javelina and small game species, Cottontail and Jack Rabbits, a vast variety of avian life including Morning Dove, migratory White Winged Dove during certain parts of the year for breeding purposes and large populations of the Gambel's Quail. The area has a certain population of the Sonoran Desert Tortoises, Burrowing owls and a vast number of various reptiles. And the population of Apex predators, Mountain Lion, Coyotes, Bob Cat, Foxes, Badgers, skunk etc. In short this area abounds with an abundance of wildlife and plant species.

The point here is that the EIA has to be performed by a qualified third party, independent of the owner or BLM (BLM says they don’t have the staff) must do the EIA in a competent manner to discover the variety of common place animals, birds, reptiles, plant, and those of endangered or threatened status. This effort cannot be left to the devices of ownership.

We appreciate the hard work that you do and look forward to working with you on this and other critical matters we face as a community and State.

And please accept my invitation to join us on the radio show to publicize any issue you may want to get to the public. We do have several developed websites and social media venues at your disposal.

I look forward to hearing from you.


Don McDowell



Don McDowell Outdoor Radio

ACGA Wildlife Chairman

AZ Deer Association - Past President & Board Member,

Division Vice Commander

US Coast Guard Aux 114-10-11


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