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Change of Use / Change of Occupancy Permit in Unincorporated Graham County, Arizona

Required when the use of an existing structure changes in unincorporated Graham County. The Zoning Ordinance makes it unlawful to 'use' any structure without first obtaining a Building Permit or appropriate Land Use designation, and requires the Zoning Official to issue a Certificate of Occupancy establishing that the property's use conforms to the Ordinance before occupancy is permitted. Graham County publishes no dedicated change-of-use fee line.

Reviewed 2026-08-15 · Source

When you need this permit

  • Zoning Ordinance Section 5.6.2 (Permit Required): 'It shall be unlawful to erect, construct, reconstruct, alter, place, or use any structure within a Land Use District covered by the Ordinance without first obtaining a Building Permit or appropriate Land Use designation from the Planning and Zoning Department.' The Inspector shall issue the permit when it appears to fully conform to the Zoning Ordinance; in any other case a permit may be withheld.
  • Zoning Ordinance Section 5.6.2(1): 'The Zoning Official shall issue a Certificate of Occupancy, after inspection, establishing that the use of said property conforms with the provisions of this ordinance and to insure that all safety and health provisions are met prior to permitting the occupancy of any building or site for residential, commercial use or manufacturing purposes.'
  • Certificate of Occupancy gate 1 — fire access (Zoning Ordinance Section 5.13.7(4), whose preamble frames items 1-5 as 'an example of requirements that must be met' when applying for rezoning, building permits, or improvements of any kind): 'Prior to the issuance of a Certificate of Occupancy, the physical access (as indicated on the legal survey (if required) or as indicated on the approved site plan) must be completed, and must satisfy the requirements for fire apparatus access in accordance with the International Fire Code adopted by Graham County.'
  • Certificate of Occupancy gate 2 — drainage (Zoning Ordinance Section 5.13.7(5)): 'Before requesting the issuance of a Certificate of Occupancy, any required drainage improvement must be completed, inspected, and approved; and easements recorded, in accordance with the approved Drainage Plan.'
  • Where the new use is a conditional use in the district rather than a use permitted by right, a Conditional Use Permit is required (Zoning Ordinance Section 5.6.2(2): 'Some land use zones allow for a Conditional Use, which may under the circumstances of a specific case be permissible, but use in general may not be permitted')
  • Outdoor lighting must be brought into compliance: Zoning Ordinance Section 8.3.3 (Change of Use) provides that 'Whenever the use of any existing building, structure or premises is changed to a new use, all outdoor lighting shall be reviewed and brought into compliance with this Code before the new use commences'
  • Zoning Ordinance Section 5.14.2(6) adopts the International Existing Building Code, 2003 edition, as part of the Graham County Building Code — the technical standard for a change of occupancy
  • Apply through the County's iWorQ citizen portal or in person at Planning & Zoning, 921 Thatcher Boulevard, 2nd Floor, Safford

Required documents

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Fee schedule

Change of use — building permit fee for associated workGraham County Inspection Fees PDF, Section 5.18.1 Inspection and Plan Review Fees — read from a 200 dpi rendered image (text extraction of this table mis-stacks the valuation column against the fee column and is unusable). NO change-of-use or change-of-occupancy line item exists in the Graham County Fee Schedule (REV 08/02/2022).
Valuation-based per Zoning Ordinance Section 5.15 / Section 5.18.1: $1.00-$500.00 = $20; $501.00-$2,000.00 = $20.00 for the first $500.00 plus $1.00 for each additional $100.00; $2,001.00-$25,000.00 = $20.00 for the first $2,000.00 plus $4.00 for each additional $1,000.00; $25,001.00-$50,000.01 = $112.00 for the first $25,000.00 plus $3.00 for each additional $1,000.00; $50,000.00-$100,000.00 = $187.00 for the first $50,000.00 plus $2.00 for each additional $1,000.00; $100,001.00-$500,000.00 = $287.00 for the first $100,000.00 plus $1.50 for each additional $1,000.00; $500,001.00 and up = $887.00 for the first $500,000.00 plus $1.00 for each additional $1,000.00. Valuation is total square footage times $100.00/sq ft residential (livable), $125.00/sq ft commercial (usable), or $50.00/sq ft utility (garages, carports, sheds, awnings, porches).
Administrative fee (added to permit fee)Graham County Fees for Planning & Zoning Department, REV 08/02/2022 — read from a 200 dpi rendered image.
$100.00
Application for Conditional Use Permit (where the new use is a conditional use)Graham County Fees for Planning & Zoning Department, REV 08/02/2022 — read from a 200 dpi rendered image. EXTRACTION WARNING: pdftotext -layout on this page mis-paired this row and reported $200.00; the render shows $350.00. DISCLOSED: the Zoning Ordinance's own reference fee table at Section 3.8 (as of August 2020) shows the same $350 figure but also lists an 'Application for Rezoning $250' and 'Public Hearing by Board of Adjustment $300' that do not appear on the 2022 standalone schedule, which instead carries 'Public Hearing plat, Zoning, Use permit, etc. $200.00.'
$350.00
Public Hearing (plat, zoning, use permit, etc.)Graham County Fees for Planning & Zoning Department, REV 08/02/2022 — read from a 200 dpi rendered image.
$200.00

Review timeline

Plan review
Not published — contact the department

How long did your Change of Use / Change of Occupancy Permit permit actually take in Unincorporated Graham County?

Anonymous — one question, no email. Answers are combined and only shown once at least 5 people have reported.

Inspection process

  1. 1

    Zoning conformity inspection

    The Zoning Official inspects before issuing a Certificate of Occupancy, establishing that the use of the property conforms with the Zoning Ordinance and that all safety and health provisions are met (Section 5.6.2(1))

  2. 2

    Fire apparatus access verification

    Physical access as shown on the legal survey or approved site plan must be complete and satisfy the fire apparatus access requirements of the International Fire Code adopted by Graham County before a Certificate of Occupancy issues

  3. 3

    Drainage improvement inspection

    Required drainage improvements must be completed, inspected and approved and easements recorded, per the approved Drainage Plan, before a Certificate of Occupancy can be requested

See the full Unincorporated Graham County inspection guide — scheduling & re-inspection fees →

Tips

  • In Graham County the Certificate of Occupancy is the real instrument for a change of use — Section 5.6.2(1) requires the Zoning Official to inspect and certify that the property's use conforms to the Ordinance before occupancy is permitted at all.
  • Two hard gates sit in front of that CofO and both are physical, not paper: completed fire apparatus access satisfying the adopted 2003 International Fire Code, and completed, inspected and approved drainage improvements with easements recorded.
  • Check whether the new use is permitted by right or is a conditional use in the district FIRST. A Conditional Use Permit application is $350.00 and runs through the Planning and Zoning Commission and Board of Supervisors — that is a hearing calendar, not a counter transaction.
  • Don't forget the outdoor lighting trigger: Section 8.3.3 requires ALL outdoor lighting on the site to be reviewed and brought into compliance with the County's lighting code before the new use commences — a change of use, not a construction project, is what fires that obligation.
  • There is no dedicated change-of-use application in the iWorQ portal (its five types are Building/Addition/Remodel, Solar/Electrical/Gas Only, Temporary RV, Manufactured Home, and Outbuilding). Call Planning & Zoning at 928-428-0410 for the correct intake path.
  • The technical standard is the 2003 International Existing Building Code (Zoning Ordinance Section 5.14.2(6)), which is not published online — a copy is available for public inspection at Planning and Zoning, 921 Thatcher Blvd., 2nd floor, Safford.

Frequently asked questions

Yes. Zoning Ordinance Section 5.6.2 makes it unlawful to erect, construct, reconstruct, alter, place, or use any structure in a Land Use District without first obtaining a Building Permit or appropriate Land Use designation from the Planning and Zoning Department. Source: https://www.graham.az.gov/DocumentCenter/View/574/County-Zoning-Ordinance-PDF

There is no dedicated change-of-use fee. Associated construction is billed on the County's valuation-based building permit formula plus a $100.00 administrative fee; if the new use is a conditional use in the district, a Conditional Use Permit application is $350.00 and a public hearing on a plat, zoning or use permit is $200.00. Source: https://www.graham.az.gov/DocumentCenter/View/569/Fee-Schedule-PDF

Unincorporated Graham County does not publish a plan-review timeline for this permit. Contact Graham County Planning and Zoning Department at 928-428-0410 for current turnaround.

You'll need: Plot Plan Sketch. Depending on your project, Unincorporated Graham County may also ask for: Petition for a Use Permit; Approved Drainage Plan / drainage improvements evidence. See the required-documents checklist on this page for details on each.

Unincorporated Graham County requires 3 inspection(s) for a change of use / change of occupancy permit, in order: Zoning conformity inspection, Fire apparatus access verification, Drainage improvement inspection. Schedule each through Graham County Planning and Zoning Department (928-428-0410).

Apply through Graham County Planning and Zoning Department at 921 Thatcher Boulevard, 2nd Floor, Safford, AZ 85546. Phone: 928-428-0410. Office hours: Monday - Thursday, 7:00 a.m. - 6:00 p.m. (per the County's Department Directory listing for Planning & Zoning at 921 Thatcher Boulevard). No public-facing department email address was found published on the County's Planning & Zoning page, Permits & Hearing Forms page, or FAQ pages as of this review; contact by phone at 928-428-0410 or in person.. Official information: https://www.graham.az.gov/277/Planning-Zoning.

Unincorporated Graham County, Arizona has adopted: Arizona has NO statewide mandatory building code floor for general construction — code adoption is a per-city/county authority under state enabling statutes (A.R.S. Title 11 for counties). Graham County independently adopts and administers its own building code for the unincorporated areas of the County (areas outside the incorporated cities/towns of Safford, Thatcher, and Pima) through the Planning and Zoning Department, per Graham County Planning and Zoning Ordinance Section 5.14 (Building Codes). Source: Graham County Planning and Zoning Ordinance (County-Zoning-Ordinance-PDF), Section 5.14.2.; 2003 International Building Code (IBC), published by the International Code Council, Inc. Source: Graham County Planning and Zoning Ordinance Section 5.14.2(1); also independently listed on the County's 'Planning & Zoning' web page ('Codes Adopted by Graham County').; 1994 Uniform Plumbing Code (UPC), Twenty-First Edition, published by the International Association of Plumbing and Mechanical Officials, copyright 1996. Source: Graham County Planning and Zoning Ordinance Section 5.14.2(2) and Section 5.14.16-5.14.19.; International Mechanical Code (IMC), 2003 edition, published by the International Code Council, Inc. — cross-referenced in Section 5.14.12-5.14.13 of the Ordinance, which cites '1997 Uniform Mechanical Code, published by the International Conference of Building Officials' as the specific adopted mechanical code text (copyright 1994-1997); the County's own web page lists '2003 International Mechanical Code' as the current adopted mechanical code. Both citations are reproduced here since the Ordinance itself is internally inconsistent between its Section 5.14.2 codes-adopted list and its Section 5.14.12 detail section — call the Planning and Zoning Department at 928-428-0410 to confirm which mechanical code edition governs a specific project.; 2002 National Electrical Code (NEC), published by the National Fire Protection Association, Inc., copyright 1998 — per Ordinance Section 5.14.2(4). Section 5.14.8-5.14.9 of the same Ordinance separately cites 'The 1999 National Electrical Code' superseding all previous editions; this is a second internal inconsistency in the Ordinance's own text between its codes-adopted list (2002 NEC) and its detail section (1999 NEC). Confirm the specific edition in effect for a given project with the Planning and Zoning Department (928-428-0410).; International Residential Code (IRC), 2003 edition, published by the International Code Council, Inc. Source: Graham County Planning and Zoning Ordinance Section 5.14.2(5).; International Existing Building Code (IEBC), 2003 edition, published by the International Code Council, Inc. Source: Graham County Planning and Zoning Ordinance Section 5.14.2(6).; International Fire Code (IFC), 2003 edition, published by the International Code Council, Inc., administered as the County's fire code. Source: Graham County Planning and Zoning Ordinance Section 5.14.2(7); also referenced in Section 5.13.7(4) regarding fire apparatus access requirements before Certificate of Occupancy issuance.; 2003 ICC Electrical Code — Administrative Provisions. Source: Graham County Planning and Zoning Ordinance Section 5.14.2(8).; International Energy Conservation Code (IECC), 2003 edition, published by the International Code Council — adopted by the Graham County Board of Supervisors, Resolution No. 2004-16, September 7, 2004, for Graham County Government Buildings ONLY (not applicable to private construction). Source: Graham County Planning and Zoning Ordinance Section 5.14.2(9).; Swimming Pool Safety Code, A.R.S. § 36-1681 (Arizona state statute governing residential swimming pool/spa enclosures and barriers) — cross-referenced directly by Graham County rather than a separate local pool-barrier ordinance. Source: Graham County Planning and Zoning Ordinance Section 5.10 (Swimming Pool Regulations).; As of this review (July 2026), the County's own published Planning & Zoning Ordinance and web page still show the 2003 ICC family (IBC/IRC/IEBC/IMC/IFC) plus a 1994 UPC and a 2002 (or, per a separate Ordinance section, 1999) NEC as the adopted codes, with no newer edition-update ordinance found published on the County's website, Forms/Fees pages, or DocumentCenter as of this review. This is materially older than many incorporated Arizona cities (which have since moved to 2018/2021/2024 ICC cycles). A copy of the Graham County Building Codes is available for public inspection at the Planning and Zoning Department, 2nd floor, 921 Thatcher Blvd., Safford, AZ, during regular working hours. Source: Graham County Planning and Zoning Ordinance Sections 5.14.3, 5.14.10, 5.14.14, 5.14.18.. Local amendments apply — see the Unincorporated Graham County overview page for the full list.

Two published physical conditions plus the zoning inspection: the physical access shown on the legal survey or approved site plan must be complete and satisfy the fire apparatus access requirements of the International Fire Code adopted by Graham County, and any required drainage improvement must be completed, inspected and approved with easements recorded per the approved Drainage Plan. The Zoning Official then issues the Certificate of Occupancy after inspection, establishing that the use conforms with the Ordinance. Source: https://www.graham.az.gov/DocumentCenter/View/574/County-Zoning-Ordinance-PDF

Sources & verification

Key facts verified against official sources. Last reviewed 2026-08-15.

Fees, timelines, and adopted codes are researched from each jurisdiction's published records — see how we verify. Requirements change and vary by project, so always confirm the current details with the Unincorporated Graham County building department before you submit. PermitBase is an independent reference and is not affiliated with any government agency.

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Change of Use / Change of Occupancy Permit in other cities

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