AriSEIA filed direct testimony today with the Arizona Corporation Commission in the Tucson Electric Power rate case. We discuss TEP’s current time of use (“TOU”) rates for both residential and non-residential customers.  We also conducted analyses related to the Company’s system-level and class-level load profiles to inform a redesign of these TOU rates.  Finally, we discuss the Company’s Customer Energy Management (“CEM”) Framework that is designed to replace TEP’s current demand-side management programs. 

Cochise County Board of Supervisors
1415 Melody Lane
Bisbee, AZ 85603
 
RE: Utility Scale Solar Work Study Sessions
 
Dear Supervisors and Staff,
 
The Arizona Solar Energy Industries Association (AriSEIA) appreciates the opportunity to provide information regarding the economic and water resource benefits associated with utility-scale solar development. While AriSEIA does not currently have a standalone economic impact study for Cochise County, extensive analysis conducted across southern Arizona counties demonstrates consistent and measurable benefits for rural communities with similar land use patterns and economic conditions.
 
About AriSEIA
AriSEIA is Arizona’s statewide trade association representing the solar and energy storage industry. Our members work across both rural and urban communities throughout Arizona. AriSEIA works with counties, utilities, state agencies, and local stakeholders to support responsible energy development that strengthens local economies, protects ratepayers, and respects community priorities. Our role is to provide accurate information and technical expertise so that local decision-makers can evaluate projects based on objective data.
 
Economic Development and Local Investment
Solar energy development represents one of the largest forms of private infrastructure investment currently occurring in rural Arizona. Independent economic analyses prepared by Elliott D. Pollack & Company show that a typical 200-megawatt solar facility with battery storage represents approximately $528 million in capital investment, generating substantial local economic activity and tax revenue over decades of operation.
 
• A representative project in Yuma County generated approximately 299 construction-related jobs, more than $213 million in total economic activity, and an estimated $25.8 million in tax revenues over the life of the project benefiting counties, special districts, and local schools.
 
• A similar project analyzed in Pinal County created approximately 265 construction jobs, produced nearly $199 million in lifetime economic output, and generated about $27.3 million in total tax revenue.
 
These impacts are particularly meaningful for rural counties because solar facilities:
• Provide significant temporary construction employment and local spending during development;
• Generate long-term property tax revenue without creating service demands comparable to residential growth;
• Provide stable revenue streams supporting fire districts, libraries, flood control districts, and school districts; and
• Create ongoing annual economic activity through operations, maintenance, and worker spending.
 
Solar projects are centrally assessed under Arizona law and pay personal property taxes on equipment over multi-decade operating lives, providing predictable revenue for local jurisdictions.
 
Water Conservation Benefits
Water use is often a central concern in land-use decisions across southern Arizona. Independent analysis comparing water consumption across land uses shows that solar energy is among the lowest water-consuming forms of development available.
 
Solar facilities use approximately 0.03 acre-feet of water per acre annually, compared to an average of approximately 3.4 acre-feet per acre across other evaluated land uses. Irrigated agriculture averages about 4.1 acre-feet per acre, while data centers average approximately 6.3 acre-feet per acre. In practical terms, solar uses roughly 100 times less water than typical alternative land uses considered for rural development.
 
Because solar generation requires minimal ongoing water consumption, it allows productive economic use of land while preserving scarce groundwater resources. Unlike residential or agricultural expansion, solar development does not create permanent long-term water demand growth.
 
Power Supply for Future Data Center Development
Across Arizona and other western states, large-load facilities such as data centers are increasingly being paired with “bring your own power” energy strategies, where new electricity demand is matched with new generation resources rather than relying solely on existing grid capacity. Utility-scale solar and battery storage projects are uniquely suited to support this model because they can be developed quickly, located near load growth, and provide predictable long-term energy pricing.
 
In several regions, local governments and utilities have encouraged pairing large industrial or data center development with dedicated renewable generation to reduce strain on existing infrastructure, limit cost impacts to existing customers, and improve grid reliability. This approach allows economic development to proceed while ensuring that new electricity demand does not require costly transmission upgrades or shift system costs onto residents and small businesses.
 
For rural counties such as Cochise County, locally sited solar generation can position the region competitively for future economic development opportunities while maintaining local control over land use and resource planning. When paired thoughtfully, solar development can serve as enabling infrastructure that attracts investment while protecting water resources and maintaining grid stability.
 
Long-Term Community Stability
In addition to direct fiscal benefits, solar development provides broader community advantages:
• Stable long-term lease income for landowners;
• Energy price stability supported by fuel-free generation;
• Diversification of local economies traditionally dependent on agriculture or resource extraction; and
• Infrastructure investment without population growth pressures on housing, roads, or schools.
 
For rural counties balancing economic development with water conservation and fiscal responsibility, solar projects uniquely align these priorities.
 
Conclusion
Experience across southern Arizona demonstrates that utility-scale solar development delivers measurable economic investment, reliable long-term tax revenues, and substantial water savings compared to alternative land uses. These benefits make solar an effective tool for supporting Cochise County’s economic development goals while protecting limited water resources.
 
On a personal note, this letter carries special meaning for me. My father is from Bisbee, and my great-grandfather, Jack Howard, served as Sheriff of Cochise County in the 1950s. Cochise County is part of my family’s history, and I deeply respect the community’s strong traditions of independence, stewardship of land, and thoughtful local decision-making. AriSEIA’s goal is to ensure that energy development contributes positively to that legacy.
 
AriSEIA appreciates the County’s consideration and welcomes continued collaboration to ensure that future energy development reflects local priorities and community values.
 
Respectfully,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]