FOR IMMEDIATE RELEASE
Phoenix, AZ - Yesterday, the Arizona Corporation Commission (ACC) voted 4-1 to impose a new and discriminatory fee on rooftop solar customers in APS service territory. The new fee imposes a 15% greater increase on solar customers, over and above the rate increase that all customers will see starting on March 8th. The fee will show up on most customers' bills as a "grid access charge" and will be approximately $2-3 a month in addition the the rate increase everyone will get of approximately $10-12 a month, per APS. AriSEIA opposed the fee and offered an amendment to eliminate it from the rate case, which was not adopted.
AriSEIA championed a Virtual Power Plant (VPP) program that was adopted 5-0 as a pilot program to commence next year. This program will save all ratepayers money, by allowing customers with batteries to opt in and share their battery capacity with APS when there is high demand on the grid, thereby limiting the need to build new, replacement resources.
The ACC also voted 5-0 to prohibit APS from competing with private industry in the microgrid space and voted 5-0 to correct on-peak hours for a commercial storage tariff called E-32 L SP, both upon AriSEIA's request. AriSEIA's request to stop disproportionately negative impacts from increased demand rates over energy rates on the E-32 M and E-32 L rate plans was not adopted.
"Yesterday was a challenging day for solar in Arizona. In a state with more than 300 days of sunshine, almost 400 solar companies that employ more than 8.250 people and contribute more than $1.5 billion to the state annually, we should be looking at ways to foster the sector, not penalize it. An unsubstantiated and discriminatory fee on solar customers is a step in the wrong direction," said Autumn Johnson, Executive Director of AriSEIA.
AriSEIA plans to file a Motion for Reconsideration on the solar charge and will engage with APS on the VPP program implementation.
AriSEIA is the state's solar, storage, and electrification trade association. It is the only trade association in the state that focuses on all scales of solar at every level of government, doing both regulatory and legislative work, and has boots on the ground.
Arizona Corporation Commission is making a big bet against solar energy
Last week, the Arizona Corporation Commission (ACC), which regulates most of the state’s utilities, voted to start the process to roll back Arizona’s energy efficiency and renewable energy standards. This is remarkably negative: to my knowledge, this would make us the first state to completely do away with these standards. As executive director of the Arizona Solar Energy Industries Association (AriSEIA), I am deeply concerned about what this signals to our industry in the sunniest state in the country.
Climate is one of the state’s “Five Cs,” and the sun is Arizona’s greatest natural resource. To date, our state has done commendable work harnessing its power for the benefit of all Arizonans. We rank fifth in the nation for total installed solar capacity, and sixth for total solar jobs, with more than 8,000 workers employed in Arizona’s solar economy.
Our state has installed enough solar panels to power more than 1 million homes, and our solar market is valued at $17.3 billion. Solar power provides 10% of Arizona’s electricity. Despite antagonism from our legislature and the ACC, Arizona Public Service (APS) is targeting 100% clean energy by 2050 and 65% clean energy by 2030. Tucson Electric Power (TEP) has a goal of net zero by 2050, with an interim goal to reduce carbon emissions by 80% by 2035.
Arizona’s current renewable energy target of 15% by 2025 is a far cry from Nevada’s and New Mexico’s goals of 50% by 2030. If the ACC is successful in repealing even this comparatively modest target, clean energy companies may stop doing business in the state, or companies that have made commitments to only use clean energy might think twice about setting up shop here. Rolling back our energy efficiency and renewable energy standards would send a clear message to these companies: take your business and your jobs elsewhere.
To make matters worse, the ACC is poised to vote next week on a new fee for residential rooftop solar customers in APS territory. The new fee applies a 15% increase on rooftop solar customers in addition to the increase all customers will endure after next week’s vote on the APS rate case. This will result in approximately an additional $3- to $4-charge just to solar customers. APS did not ask for this increase; it was unilaterally proposed by the ACC.
We are facing an inflection point. We can continue to welcome investment from solar power and renewable energy more broadly, bringing jobs, cost savings, and environmental benefits across the state. Or we can follow the path the ACC is laying out for us and shun the economic benefits of the clean energy transition.
If we go down that path, our neighboring states will out-compete us for clean energy investment. Nevada just made headlines for hosting the Super Bowl at Allegiant Stadium, the first NFL stadium to be powered by 100% renewable energy. We should be making headlines for innovation like this, instead of regressing.
The ACC is playing political games they think will help them in November. However, if they were listening to the people of the state, they would know that three-fourths (74%) of Arizonans are supportive of more solar power.
Unlike oil and gas, the sun and wind are unlimited natural resources. Not only are they the least costly form of energy; they’re also going to get cheaper over time. In fact, the costs of solar and wind power in the state are projected to drop by 22% and 34%, respectively, over the next 30 years. Under the Inflation Reduction Act, Arizonans can get tax credits to cover 30% of the cost of installing solar panels.
Investing in renewable energy means energy independence and freedom from volatile oil and gas prices. It means cost savings on utility bills. Investing in clean energy also means new good-paying jobs for Arizonans—with more than 13,000 jobs and $10 billion in investment announced in our state since 2022.
This is what we stand to lose if we turn our backs on clean energy. After the ACC releases its new draft rules, there will be a public comment period. Before that comment period begins, the public can also share their feelings on the new solar charge in the APS rate case by calling (602) 542-4251 or contacting the commissioners via email. Tell them to vote no on the new solar charge in Docket No. E-01345A-22-0144. Its passage will mean a dimmer future for all Arizonans.
Thursday, Feb. 22 press conference:
Arizona Solar Advocates Call on the ACC to Vote NO on a New Discriminatory Solar Charge
Phoenix, Arizona – On Thursday, February 22 at 8:30 a.m, Arizona Corporation Commission (ACC) stakeholders and solar advocates will hold a press conference to call on the ACC to vote no on a brand new charge being targeted only at APS customers with solar.
APS has proposed to increase rates for all of its customers by 13%. This significant increase comes on the heels of a 2023 rate hike caused by APS’s overreliance on natural gas that increased the average residential customer’s bill by $145 annually. The ACC has now proposed that solar customers rates be increased by 15% more than everyone else. This will result in an additional fee of $3-4 a month per solar customer in addition to the 13% overall rate hike. This discriminatory fee was proposed in the final stage of a multi-year rate case proceeding, and there has been no testimony or briefing addressing the fee or opportunity for the public to comment on it. Multiple parties have called on the ACC to eliminate the solar-specific fee when they vote on the rate case on February 22nd.
At the press conference, speakers will describe how local rooftop solar helps to reduce grid costs and protect ratepayers from skyrocketing gas prices, the solar fee the ACC has proposed, and the impact such a discriminatory fee will have on ratepayers and the solar industry in Arizona.
Thursday, February 22, 2024
8:30 AM MST
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Speakers will be available for questions following the press conference.
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
RE: APS Rate Case, Docket No. E-01345A-22-0144
Chairman and Commissioners,
In advance of the vote on this matter on February 22nd, the Arizona Solar Energy Industries Association (AriSEIA) submits these additional comments regarding:
1. Chairman O’Connor’s Proposed Amendment No. 3 and Commissioner Myers Revised Proposed Amendment No. 3
2. Hearing Division Proposed Amendment No. 2
3. ROO Resolution on E-32 M and E-32 L
I. Chairman O’Connor Proposed Amendment No. 3 and Commissioner Myers Revised Proposed Amendment No. 3
We appreciate the Chairman’s thoughtful consideration of our BYOD proposal. As we mentioned in our briefs, BYOD (or Virtual Power Plants (VPP)) are an innovative way to deploy the capacity already available with distributed batteries, paid for by individuals’ private capital, in an aggregated way, at a rate lower than the utility would pay to build new utility scale resources. The batteries are aggregated together to create a capacity resource that the utility controls and only pays for when it uses it. There are no subsidies or incentives. Ratepayers pay for their own batteries and APS pays to use them only when needed. The evidence was uncontested that the cost to ratepayers of the proposed BYOD program is significantly less than the cost to ratepayers of utility-owned batteries. In fact, APS agreed that when it owns a battery, it costs ratepayers $208/kW every year for 20 years while the cost of the BYOD program is only $150/kW for 5 years. Every single kW of batteries deployed via BYOD with private investment saves all ratepayers money. These savings can begin as soon as this program commences.
VPPs are being deployed all over the country and have been found to save billions in capital investments over the next decade. Our proposal is modeled off of a successful program already in operation and carefully modified to be useful to APS.
Our proposal was uncontroverted in the record. Indeed, no stakeholders filed amendments to the ROO regarding the BYOD program. And the ROO cautiously adopts the proposal with a few changes as a modest, pilot program. The ROO specifically acknowledges APS expects significant load growth and the proposal’s value as a capacity resource. Capacity resources like a VPP are critical tools for reliability. The ROO orders APS to file a POA as a compliance item in this docket within 90 days of the decision. A stakeholder process to develop the POA is to commence within 30 days of the decision. Staff already has the opportunity to review the POA within 60 days after it is filed and then is to file a Staff Report and Proposed Order. We have already spent more than a year on the APS rate case. We spent the entirety of 2023 writing testimony, in hearing, and briefing. It is unnecessary and not in the best interests of ratepayers, the utility, or the grid to delay a resource that is currently being squandered for another six months. APS has not filed exceptions asking for more time for the stakeholder process or to file a POA.
Similarly, doubling the time frame for Staff to review the POA that is the result of a year of rate case litigation and an additional three-month stakeholder process is unnecessary. Staff also did not file exceptions on this matter. The additional six months of delay included in the Chairman’s amendment was not requested by anyone and will result in ratepayers paying more for equivalent resources, as the utility has an obligation to keep the lights on and will do so with more expensive resources in the interim. It is uncontroverted that the BYOD program costs less than building the same new utility scale resources.
Further, the merits of our proposal were already vetted at length in the hearing and rehashing whether the pricing should be based on kWh or kW, whether there should be differences in on-peak vs. off-peak pricing, and whether any on-peak or off-peak times used for pricing should be different than those established for TOU customers would utilize extensive Staff time and resources unnecessarily.
Therefore, we respectfully oppose the Chairman’s Proposed Amendment No. 3 and Commissioner Myers Revised Proposed Amendment No. 3. Ratepayers and the grid will benefit and save money from thoughtful deployment of a VPP and the program as proposed is already only a pilot. A year of delay is not in the public interest and will cost ratepayers money. If the program needs tweaks, the Commission can revisit the issue at the conclusion of the pilot. If the Commission does vote to move forward with the Chairman’s Proposed Amendment No. 3, please modify the time frame to be consistent with that outlined in the ROO. An additional six (6) months of delay is unwarranted and costly.
II. Hearing Division Proposed Amendment No. 2
The ROO’s conclusion in this rate case is completely inconsistent with precedent and a prior Commission decision on this very same matter in the last rate case. As our exceptions outline in detail, the ROO makes a 180 degree turn on this issue. The same judge found that there was “no evidence of any specific and unique costs that DG solar customers impose on APS’s system.” That decision literally eliminated a charge unique to solar customers that this rate case then reimposes with the only justification being that somehow residential solar customers are equivalent to AG-X customers and not other residential customers and should have to pay for resource adequacy (RA) via some means other than through their base rates, which was never an issue addressed in the case. Indeed, the ROO says, “[t]he evidence in the record in this matter now makes it clear that APS does not truly provide additional services and does not use additional equipment to serve DG customers.”
Additionally, all of this is predicated on accepting a flawed site Cost of Service Study (COSS), which was thoroughly litigated in the last rate case. Assuming the Commission prioritizes regulatory certainty and having no notice of the issue, we did not resubmit all of that testimony in this case, because it was resolved in the last case. Had we known this rate case was a do over for all issues settled in prior rate cases—even those that no party raised—we would have resubmitted all the testimony again. We posit that is not an effective way to process what are already lengthy, time consuming, and complex proceedings with dozens of intervenors.
Furthermore, the proposed amendment suggests via a footnote that a broad provision in the Public Notice should serve as sufficient legal notice to the public that, apparently, anything can happen in the rate case including approving a solar-specific charge, even though the issue was never once mentioned during the hearing. AriSEIA is confident that courts will not agree that a catchall in a public notice is sufficient to put the public on notice that literally all possible outcomes are open for adjudication in a rate case proceeding even if no parties so much as mention an issue during the pendency of an action. Such an interpretation undermines the entire purpose of public notice in the first place and is a clear deprivation of due process.
The Hearing Division Amendment incorrectly states that there is a “sizable disparity” between residential solar customers and non-solar customers that results in a subsidy to rooftop solar customers. We have extensive testimony in the 2019 rate case and this rate case refuting that characterization, which the Commission agreed with in just the last decision. Indeed, the “resolution” section in the ROO orders APS to conduct additional analyses as to the solar COSS. It is illogical to both order APS to do additional analysis in the next rate case, but also rely on the apparently incomplete analysis in this case to impose a fee the Commission just eliminated only a couple of years before. This yo-yoing of policy is not in the public interest.
Further, APS provides RA to all customers, and all customers pay for that RA through their base rates. That is its fundamental job as a utility. Solar customers should not be the only residential customers having to essentially pay an extra fee solely for that. Singling out solar customers is what the same judge labeled as discriminatory in the last APS rate case.
Not only does Hearing Division Proposed Amendment No. 2 include the forgoing deficiencies, but the Commission should also be concerned with the proposed amendment’s endorsing of COSSs introduced by commercial interests that suggest residential rates as a whole should be nearly 45% higher than they are today. In this sense, the proposed amendment appears to argue that solar customers should not complain because, in reality, residential rates should be much higher anyway.
AriSEIA respectfully opposes Hearing Division Proposed Amendment No. 2 and is prepared to appeal the rate case decision if the solar charge is not eliminated. AriSEIA continues to recommend adoption of AriSEIA Proposed Amendment No. 1.
III. ROO Resolution on E-32 M and E-32 L
AriSEIA agrees with APS that Kroger’s proposal on E-32 M and E-32 L is not consistent with the public interest. It disproportionately and negatively impacts lower load factor customers and uniquely benefits Kroger and only Kroger and similarly situated companies. An increase in demand charges over volumetric charges is extremely punitive to customers with distributed generation whose investments in such systems rely on financial returns predicated on the original rate design. Any rate increase applied to specific customer classes should be evenly spread across the existing rate components in accordance with their relative magnitude, not distributed in a manner that dramatically increases demand charges over energy charges. Please find AriSEIA Proposed Amendment No. 4 attached.
/s/ Autumn T. Johnson
 Kevin Lucas in hearing test., September 1, 2023, at 00:04:31.
 See id. at 00:15:28; See also Direct Testimony of Kevin Lucas, Docket No. E-01345A-22-0144, January 15, 2023, at 36:5–6, available here https://docket.images.azcc.gov/E000027777.pdf?i=1708454244009 [hereinafter Lucas Direct Testimony].
 Ryan Hledik, Virtual Power Plants (VPPs) Could Save US Utilities $15-35 Billion in Capacity Investment Over 10 Years, Brattle (May 2, 2023), available here https://www.brattle.com/insights-events/publications/real-reliability-the-value-of-virtual-power/.
 See Lucas Direct Testimony at 34:13.
 See Recommended Opinion & Order from the Hearing Division, Docket No. E-01345A-22-0144, January 25, 2024, at 363-64, available here https://docket.images.azcc.gov/E000033297.pdf?i=1707275118683 [hereinafter APS ROO].
 Order No. 78317, Docket No. E-01345A-19-0236, November 9, 2021 at 358:5-10, available here https://docket.images.azcc.gov/0000205236.pdf?i=1707254089396 [hereinafter 2019 APS Rate Case].
 APS ROO at 272:27-273:1 (emphasis added).
While AriSEIA was successful in adding a Virtual Power Plant (VPP) pilot program in the course of the rate case, other aspects of the Recommended Opinion and Order (ROO) warrant changes. AriSEIA requested three changes. The most significant of which eliminates a brand new charge on solar customers that was not requested by APS or any other party in the case. You can read the comments at the link above. The vote is February 22nd.
AriSEIA worked with the Registrar of Contractors (ROC), SEIA, and Sunsolar Solutions to offer this joint training to contractors in Arizona on consumer protection issues in residential solar.
AriSEIA hired Rocky Mountain Institute (RMI) jointly with Vote Solar and Advanced Energy United as a consultant during the 2023 IRP process. RMI advised stakeholders and the utilities on integrated resource plan (IRP) best practices, made recommendations about analysis of distributed energy resources and the Inflation Reduction Act (IRA), and also to review the filed plans by Arizona Public Service (APS) and Tucson Electric Power (TEP). Read the comments above.
Arizona Corporation Commission
1300 W. Washington Street
Phoenix, AZ 85007
RE: Comments on the APS and TEP 2023 IRPs, Docket No. E-99999A-22-0046
Chairman, Commissioners, and Staff,
AriSEIA is an active member of the Resource Plan Advisory Council (RPAC) for both Arizona Public Service (APS) and Tucson Electric Power (TEP). AriSEIA also jointly hired Rocky Mountain Institute (RMI) to engage in the RPAC process. Their findings are filed separately from these jointly with Vote Solar and Advanced Energy United.
AriSEIA submits the following comments on APS and TEP’s Integrated Resource Plans (IRPs) filed on November 1, 2023. Our comments include four sections. First, we include documentation on the affordability and reliability of solar resources. Second, we make recommendations as to the forthcoming Order. Third, we include an analysis of APS’ plan. Fourth, we include a review of TEP’s plan.
/s/ Autumn T. Johnson
 APS, 2023 IRP, Filed Nov. 1, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000031965.pdf?i=1704923236078 [hereinafter APS IRP].
 TEP, 2023 IRP, Filed Nov. 1, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000031960.pdf?i=1704923236078 [hereinafter TEP IRP].
Sierra Club, the Arizona Solar Energy Industries Association, Western Grid Group, Arizona Public Interest Research Group Education Fund, Southwest Energy Efficiency Project, and Western Resource Advocates (collectively, the “Joint Signatories”) provide the following comments regarding Staff’s memorandum, five-year report, and proposed order in Docket No. AUD-00000A-23-0142.
On May 26, 2023, the Utilities Division issued a memorandum opening this docket to review the following Commission rules as part of the Commission’s 5-year review procedure:
On November 30, 2023, Staff issued a memorandum, five-year report, and proposed order recommending that the Commission open a new rulemaking docket to consider amendments to the above-listed rules, with the exception of Article 7 (resource planning and procurement), which already has an existing rulemaking docket (Docket No. RE-00000A-22-0029). Staff’s attached five-year report reviews the objectives, effectiveness, clarity, and probable costs and benefits of each section of Articles 7, 9, 18, 24, and 25, and recommends that portions of each article be amended.
II. CONSIDERATION OF POTENTIAL CHANGES TO RESOURCE PLANNING RULES
If the Commission decides to consider potential changes to the integrated resource planning (“IRP”) rules in Article 7, the Joint Signatories agree with Staff that such consideration should occur in the existing IRP rulemaking docket (Docket No. RE-00000A-22-0029).
A. The Commission Should Consider the Existing Record in the IRP Rulemaking Docket.
In considering any proposed changes to the IRP rules, the Commission should refer to the existing record in Docket No. RE-00000A-22-0029. In that docket, proposed rules were developed by Staff via a collaborative process with extensive stakeholder input, which included multiple rounds of comment and several day-long in-person meetings over more than a year.
On March 10, 2022, Commission Staff filed a memorandum and proposed order containing the text of proposed rules governing All-Source Requests for Proposals (“ASRFPs”) and the IRP process, which would have been contained in a new Article 28 of the Commission rules. While it appears the current 5-year review rulemaking docket is intended to be narrower in scope, parts of Staff’s 2022 proposal remain relevant and could be adopted via amendments to Article 7.
On March 11, 2022, Sierra Club, Western Grid Group, Tierra Strategy, and Western Resource Advocates filed joint comments on Staff’s proposed IRP rules. Those comments are incorporated herein by reference. The 2022 joint comments expressed support for most aspects of Staff’s March 2022 proposal, concluding that the proposed rules would modernize and strengthen Arizona’s IRP process, promoting transparent and accountable resource planning.
The 2022 joint comments supported Staff’s proposal to require that a competitive ASRFP procurement process be fuel-neutral and technology-neutral. The comments also supported a robust stakeholder input process via Resource Planning Advisory Councils, and supported requiring utilities to provide stakeholders and Staff with access to modelling software as a permanent feature of the IRP process.
However, the 2022 joint comments expressed concerns about a few aspects of Staff’s March 2022 proposal, opposing the inclusion of biomass in the definition of renewable energy resources, and called for IRPs to prioritize development of renewable and clean energy resources in impacted communities affected by fossil fuel power plant closures. Sierra Club filed further comments regarding the Commissioners’ proposed amendments in the IRP rulemaking docket on April 13, 2022, which are incorporated herein by reference.
B. The Commission Should Consider Updating Definitions in the IRP Rules.
With regard to Staff’s proposed order and 5-year review report in Docket No. AUD-00000A-23-0142, the Joint Signatories agree with Staff that Section R14-2-701 should be amended to clarify the definition of “renewable energy resource” and to define the terms “Resource Planning Advisory Council” and “All-Source Request for Proposals.” The Joint Signatories intend to provide further substantive comments on potential changes to this and other sections of Article 7 if the Commission proceeds with the IRP rulemaking process.
C. The Commission Should Include Robust Stakeholder Input In the IRP Rulemaking.
The Article 7 IRP rules proposed for review encompass a number of important statewide policy issues related to utility resource planning. Potential amendment of these rules could have far-reaching consequences. These important issues require thorough consideration and robust input from interested parties. The rulemaking process must be transparent and provide ample time for all interested stakeholders to fully participate.
In considering any proposed changes to the IRP rules, the Commission should provide extensive opportunities for meaningful stakeholder input. This should include (1) stakeholder workshops, (2) development and issuance of an initial proposal by Staff, including the text of proposed changes to the rules, (3) adequate time for stakeholders to review that proposal and provide feedback, including recommended changes to the text of the rules, (4) issuance of a final proposal by Staff, and (5) adequate time for stakeholders to provide written comments on the final Staff proposal and any proposed amendments prior to the Commission vote.
In considering any proposed changes to the IRP rules, the Commission should refer to the existing record in Docket No. RE-00000A-22-0029, and should provide ample opportunities for further stakeholder input.
If the Commission decides to consider potential changes to the IRP rules via a rulemaking process as proposed by Staff, the Joint Signatories intend to participate fully in that process, and will provide more detailed comments at the appropriate time.
 Utilities Division Memorandum and Proposed Order, No. RE-00000A-22-0029 (Mar. 10, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/295540.
 Sierra Club, Western Grid Group, Tierra Strategy, and Western Resource Advocates, Stakeholder Comments on Possible Rulemaking for the Adoption of All-Source Requests for Proposals and Integrated Resource Planning Rules, No. RE-00000A-22-0029 (Mar. 11, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/295575.
 Sierra Club, Comments on Amendments to Rulemaking for the Adoption of All-Source Requests for Proposals and Integrated Resource Planning Rules, Docket No. RE-00000A-22-0029 (Apr. 13, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/296682.
 See Utilities Division Memorandum and Proposed Order, No. RE-00000A-22-0029 (Mar. 10, 2022), Exhibit A at 1.
 The Joint Signatories’ silence as to any aspect of Staff’s memorandum, five-year report, and proposed order not addressed in these comments should not be interpreted as agreement with or endorsement of those aspects.
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Re: TEP Rate Case, Customer Storage Program Stakeholder Meeting, Docket No. E-01933A-22-0107
Chairman and Commissioners,
AriSEIA submits these comments in response to the compliance filing that TEP filed on December 7, 2023, in response to the stakeholder process they were ordered to commence regarding a Bring Your Own Device (BYOD) program (also known as Virtual Power Plant (VPP)) and revisions to the R-TECH and LGST-SP tariffs. These stakeholder processes are the result of Order 79065.
Because some of the utilities have recently been using their compliance filings as evidence in other proceedings and have also asserted that stakeholder silence is agreement, AriSEIA makes this filing to detail our numerous concerns about how TEP has so far engaged on BYOD, R-TECH, and LGST-SP. AriSEIA put forth a robust proposal to implement a BYOD program, as well as specific modifications to the R-TECH and LGST-SP in the course of the last rate case. Those proposals are the reason this stakeholder process was ordered. Further, TEP stated multiple times in the course of the last rate case proceeding that they had not had time to review the proposals. January will be one year since AriSEIA filed those proposals and TEP still seems unfamiliar with them.
BYOD is a win/win for AZ ratepayers and the utilities. AriSEIA’s BYOD proposal leverages private investment in distributed battery storage to provide much needed capacity to the grid at a price that is less than the cost of utility-owned, utility scale battery storage. Further, any costs associated with the program are pay for performance only. There is no upfront payment, no subsidy, no cost shift.
At the stakeholder meeting held by TEP on November 17, 2023, TEP had no substantive content prepared, had no response to the AriSEIA proposals, had no proposals of its own, did not have the correct people at the meeting to discuss policy, nor did they articulate any plan for how to manage this process going forward. Further, despite the fact that the Order is clear as to what these stakeholder processes are meant to do, TEP was not clear in its direction to participants as to what we were even there to discuss. TEP permitted the meeting to devolve into a tangent conversation about wholly unrelated technologies or whether or not storage should even be considered, despite the fact that storage is the very reason the stakeholder process was ordered.
AriSEIA makes the following recommendations to the Commission and TEP:
1. TEP should have the correct personnel at the stakeholder meetings to discuss policy and regulatory issues;
2. The AriSEIA proposals on BYOD, R-TECH, and LGST-SP should be the basis on which the process unfolds. TEP should come to the meetings prepared to suggest components of these programs they can or cannot support;
3. R-TECH and LGST-SP are separate issues and while they are to be discussed concurrently with BYOD, need not be discussed simultaneously;
4. TEP needs to provide a capable facilitator of the meetings and process, either internal or external;
5. If TEP wishes to host additional stakeholder meetings on unrelated topics or technologies, it can do so, but these processes should remain consistent with and adherent to the Order and the issues discussed in the last rate case; and
6. TEP needs to articulate a process and timeline for this work. We suggest monthly meetings of one hour, which should be scheduled in advance with a stakeholder list, like TEP does for its other “collaborative” meetings.
AriSEIA’s proposal on all three matters can be found in Kevin Lucas’ direct testimony, filed on January 27, 2023, starting at page 314. An excerpt of that testimony is attached herein.
/s/ Autumn T. Johnson
 TEP, Notice of Filing-Tucson Electric Power Company’s Customer Storage Program Stakeholder Meeting Summary, Dec. 7, 2023, Docket. No. E-01933A-22-0107, available here https://docket.images.azcc.gov/E000032546.pdf.
 ACC, Opinion and Order No. 79065, Pg. 149, Lines 11-27, Aug. 25, 2023, Docket No. E-01933A-22-0107, available here https://docket.images.azcc.gov/0000209684.pdf?i=1701984045033.
 Kevin Lucas in APS rate case, hearing test., Sept. 1, 2023, Docket No. E-01345A-22-0144, 00:04:31 (this is also applicable in the TEP rate case).
 AriSEIA, Direct Testimony of Kevin Lucas, Jan. 27, 2023, Docket No. E-01933A-22-0107, available here https://docket.images.azcc.gov/E000023835.pdf?i=1701984045030.
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