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AriSEIA filed joint comments today with Solar United Neighbors and Vote Solar in the various Demand Side Management (DSM) dockets and the docket containing APS' DDSR Aggregation Tariff. The comments highlighted that customer-sited energy storage systems can be a useful tool in reducing customers' electricity consumption. The comments were in response to a letter issued by Commission Kennedy in the DSM dockets.
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March 11, 2022
U.S. Economic Development Administration U.S. Department of Commerce 1401 Constitution Avenue, NW, Suite 71014 Washington, DC 20230 RE: Coal Communities – Build Back Better Regional Challenge Dear Economic Development Administration Representative, We submit this letter jointly on behalf of Arizona Solar Energy Industries Association (AriSEIA), Solar United Neighbors (SUN), and Vote Solar in support of the Hopi Tribe’s Economic Development Administration (EDA) grant application. The solar industry is an essential part of the U.S. and Arizona’s economy. As of Q3 2021, over 113.5 GW of solar has been installed nationwide, representing over 230,000 Americans working in the solar industry. To date, Arizona has 5.2 GW of installed solar capacity representing nearly $14 billion in total solar investment in the state. In addition, the solar industry provides 7,346 jobs within the state, ranking 5th in solar jobs throughout the country. Our organizations believe in Hopi’s vision to rebuild their economy. We have witnessed the impact of coal plant closures in Arizona and have had the opportunity to meet with tribal members and organizations. We also understand Hopi’s EDA grant application and believe in their vision to rewrite their energy story. It is our understanding that the Hopi Tribe is working to develop and construct a large-scale solar facility to transition the Hopi Tribe beyond the closure of the Navajo Generating Station (NGS) and Kayenta Mine. In addition, we understand that the Tribe will pursue local clean energy infrastructure projects to improve reliability on the reservation, as well as a workforce development program that leverages the construction projects to train Tribal Members for clean energy jobs. Our organizations are committed to supporting Hopi through our networks and members. Our networks include solar contractors, installers, manufacturers, distributors, consultants, engineers and designers, residential and commercial system owners, developers, universities, solar supporting businesses, nonprofits, and members of the public. We strongly encourage the EDA to award phase 2 funding to Hopi Utilities Corporation to support the Tribe to deliver these exciting infrastructure and economic development projects through the Build Back Better program. AriSEIA’s mission is to develop and support policies that create opportunities to advance Arizona’s economy through solar energy and storage. AriSEIA is Arizona’s largest trade association for the solar industry and is part of the national Solar Energy Industry Association (SEIA). We advocate for sustainable job creation in deployment of solar and complementary technologies and collaborate with stakeholders to encourage utilization of Arizona’s greatest natural resource, the sun. SUN is a national nonprofit composed of a community of people building a new energy system with rooftop solar at the cornerstone. It helps people go solar, join together, and fight for their energy rights. SUN envisions a clean, equitable energy system that directs control and benefits back to local communities, with solar on every roof and money in every pocket. Vote Solar’s mission is to make solar a mainstream energy resource across the U.S. Since 2002, Vote Solar has been working to lower solar costs and expand solar access. Vote Solar advocates for state policies and programs needed to repower the electric grid with clean energy. It works to remove regulatory barriers and implement key policies needed to bring solar to scale. Sincerely, Autumn T. Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) [email protected] 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) [email protected] 602-962-0240 Yaraneth Marin Interior West Regional Director Vote Solar [email protected] 602-492-6077 March 11, 2022
Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Re: Salt River Project (SRP) Certificate of Environmental Compatibility (CEC), Docket No. L-00000B-21-0393-00197 Madam Chair and Commissioners, Our organizations submit these joint comments to urge you to vote no on SRP’s CEC application. Not only did SRP not engage in a competitive bidding process and not comply with its own 2018 Integrated Resource Plan (IRP), but it did not adequately consider alternatives to the Coolidge Expansion Project (CEP). This leaves serious concerns about the estimated cost of the facilities and the potential increase in the cost of electric energy to customers. SRP’s 2017-2018 IRP Report states that, “Prior to making any financial commitments to major equipment or construction contracts for new-build generation, [SRP will] issue all-source RFPs [Request for Proposal] for the planned capacity. That capacity will explicitly include the opportunity for cost competitive and viable energy storage and demand response options.”[1] No all-source RFP was issued prior to the decision to expand Coolidge Generating Station by 820 MW. Shortly after the SRP Board voted to narrowly approve this project, SRP issued an all-source RFP for an additional 1000 MW to come online between 2024 and 2026.[2] It is unclear why SRP can issue an all-source RFP for these megawatts, but not the Coolidge megawatts given that both projects were announced within months of each other and are intended to come online within the same time frame. There was considerable testimony at the hearing that SRP did not adequately consider alternatives to this 820 MW expansion of Coolidge. Witness Mr. Robert Gramlich testified that not only did SRP not adequately consider alternatives, but that solar and storage would have been more economical.[3] Specifically, he testified that “SRP’s economic analysis overstated the need for clean resources by a factor of 3 or 4.”[4] “So the economic analysis was distorted by overstating the capacity needed for the renewables and storage.”[5] “A battery would have been more economic than CEP.”[6] Mr. Gramlich went on to testify that SRP did not adequately consider the analysis of its own consultant, E3, in assessing the alternatives to the Coolidge expansion. “E3 found that adding only 731 MW of battery capacity in 2026 provides the same capacity value as the 820 MW CEP.”[7] Arizona Revised Statute (ARS) 40-360.06(A)(8) states that the Committee shall consider “The estimated cost of the facilities and site as proposed by the applicant and the estimated cost of the facilities and site as recommended by the committee, recognizing that any significant increase in costs represents a potential increase in the cost of electric energy to the customers or the applicant.”[8] Further, ARS 30-360.07(B) states that the Commission shall “comply with the provisions of section 40-360.06 and shall balance, in the broad public interest, the need for an adequate, economical and reliable supply of electric power with the desire to minimize the effect thereof on the environment and ecology of this state.”[9] Therefore, the Commission must consider the cost of the project and the economics of supplying that electric power. Because SRP did not conduct an all-source RFP, the Commission does not have adequate information about the alternatives to this project and the potential for a less costly option, such as solar and storage, that would save customers money and better protect the environment and ecology of the state. Approval of the CEC application risks locking customers into significant new costs without evidence that the CEP is the right choice to meet the identified capacity need. We ask the Commission to vote no on this CEC application and direct SRP to proceed with an all-source RFP to consider the best available option for adding 820 MW between now and 2025. Respectfully, Autumn T. Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) [email protected] 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) [email protected] 602-962-0240 Yaraneth Marin Interior West Regional Director Vote Solar [email protected] 602-492-6077 [1] Salt River Project, Integrated Resource Plan Report, P.49, available here https://srpnet.com/about/stations/pdfx/2018irp.pdf. [2] Salt River Project, 2021 All-Source Request for Proposals, available here https://srpnet.com/energy/secure/all-resource-rfp.aspx. [3] February 15, 2022 Hearing Transcript, starting at P.1116, available here https://srpnet.com/electric/transmission/projects/Coolidge/pdfx/cec/07_02-15-2022_SRP_Coolidge_Expansion_Evidentiary_Hearing.pdf. [4] Id. at 1118, L.3-4. [5] Id. L. 6-8. [6] Id. L.9-10. [7] Id. at 1121, L.1-3. [8] ARS 40-360.06(A)(8) available here https://www.azleg.gov/ars/40/00360-06.htm. [9] ARS 40-360.07(B) available here https://www.azleg.gov/ars/40/00360-07.htm.  Speakers highlight the importance of solar investments to Southern Arizona’s growing clean energy industry
(Tucson, AZ) – Today, Arizona State Representatives Daniel Hernandez (D-2) and Morgan Abraham (D-10) joined solar power advocates gathered for a press conference to call on the U.S. Senate to pass significant investments in climate and clean energy to support the state’s growing clean energy industry. This event was sponsored by Solar United Neighbors Action. In late 2021, the U.S. House of Representatives delivered for the American people with its historic vote to approve $550 billion in climate investments. This included landmark investments in climate change, clean energy, justice, equity, families, and communities. The speakers thanked Senator Mark Kelly for leading on clean energy growth and solar power, and urged him to continue to fight for Arizonans by supporting critically needed investments to address the climate crisis, increase the adoption of solar power in Tucson, and drive growth in Arizona’s renewable energy sector. “When it comes to confronting the climate crisis, our leaders are responsible to do everything in our power to protect both the lives and livelihoods of our constituents,” said State Rep. Daniel Hernandez (D-2) “The results we’ve already achieved at the state level and in cities like Tucson illustrate that an economy that is more resilient to climate change can also be one that creates better-paying jobs and sets up Arizona’s cities for decades of high-tech economic growth. We know that climate change and economic growth are top of mind for Mark Kelly, and we need his help to secure the votes needed to pass this transformational climate funding through the Senate.” “Arizonans are already battling climate change in the form of worsening air quality, more extreme heat, and increasingly frequent potential droughts,” said State Rep. Morgan Abraham (D-10). “There’s broad awareness in this state that taking creative and committed action to move toward more clean energy is of critical importance, and the data is also clear that this transition has the potential to promote entrepreneurship and to create tens of thousands of high-quality long term jobs across Arizona in the process. Mark Kelly has proven time and again that he is a leader who puts science, pragmatic problem solving, and the safety of his constituents first, and we’re counting on him to fight for us to pass this critical climate funding.” Speakers stressed that time is running out to address the climate crisis. Climate change is making extreme weather events more frequent and severe with communities across the state paying the price. From 2010 to 2020, Arizona experienced 13 extreme weather events, costing the state up to $10 billion in damages. More than 40% of Americans experienced a climate change-fueled extreme weather event in 2021 alone. "Going solar helps families save money by taking control of where their electricity comes from," said Adrian Keller, Program Associate with Solar United Neighbors Action. "Congress has an opportunity to help more Arizonans benefit from solar energy. It should take it. In November, the House passed a bill with important investments that will ensure solar's benefits are shared by rural and underserved communities across the state. These investments will create good local jobs. Now, it is up to the Senate to come together to pass these needed measures." These investments in clean energy will not only help fight climate change but also will bring massive economic growth to Arizona. Prior to the COVID-19 pandemic, clean energy jobs were growing faster than the economy as a whole. As of 2021, there were more than 56,000 Arizona residents working in clean energy. Passing the $550 billion in climate investments will add nearly 83,000 jobs in Arizona over the next five years. “Arizona’s solar industries have already proven we can grow fast to meet ambitious capacity goals and create thousands of high-quality, long term jobs in this state,” said John Mitman, President of Arizona Solar Energy Industries Association. “Now, the country has a pivotal opportunity to expand on that progress on an unprecedented scale. This is not only critical funding for the climate fight, but also $550 billion of incentives and investments that will fuel cutting edge industries, foster entrepreneurship across this state, and create tens of thousands of family-sustaining jobs over the next five years. The House did their job – now we need the Senate to step up and pass this bill.” “The people of Arizona have been on the front lines of the climate crisis, and there is a clear popular will behind the measures that passed the House earlier this winter,” said Duane Etiger, of Sustainable Tucson. “This is long overdue funding that will fuel a revitalization and realignment of Arizona’s economy as we create thousands of jobs electrifying dangerously carbon-dependent transportation and broader energy use. These are investments in sustainability, but they are also investments in economic justice, in inidigineous communities and communities of color, and a more prosperous future for our state as a whole. We’re grateful for Mark Kelly’s past leadership on climate, and we’re counting on him to follow the science and champion this bill on behalf of Arizona.” A video of the in-person press conference can be found here. The event was held at The Historic Y in Tucson, Arizona. The Historic Y is the premier center for the arts, education, human rights, and social and environmental justice in Southern Arizona. In 2017, The Historic Y installed a 65.21 kW SunPower PV Solar System on the building’s rooftops that in 2018 accounted for approximately 45% of The Historic Y’s electric consumption. |
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The Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) non-profit trade association representing the solar, storage, and electrification industry, solar-friendly businesses, and others interested in advancing complementary technologies in Arizona. The group's focus is on education, professionalism and promotion of public policies that support deployment of solar, storage, and electrification technologies and renewable energy job growth and creation. |
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