Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007-2996
 
RE:      Salt River Project (SRP) Coolidge Expansion Project Certificate of Environmental Compatibility (CEC), Docket No. L-00000B-21-0393-00197
 
Chairman O’Connor and Commissioners,
​
The Arizona Solar Energy Industries Association (AriSEIA) filed joint comments opposing the SRP CEC on March 11, 2022. That filing is attached, as is a filing from the Solar Energy Industries Association (SEIA) on March 14, 2022. None of the underlying reasons for our opposition have been resolved and we remain opposed to SRP’s Application to Amend Decision 78545, filed on June 14, 2023.
 
First, we are concerned with how quickly this application was filed and then docketed for an open meeting. We received notice of this filing at 4:30 pm on June 14th. We received notice of it being on the revised June open meeting agenda at 10:06 am on June 15th, which is only six (6) calendar days before the open meeting and three (3) business days before the open meeting. This is an inadequate amount of time for interested parties to respond and a vote should not be taken at the June 21st open meeting. Further, SRP has clearly known about this arrangement much longer than other interested stakeholders, which is reflected in the fact that their supporters had ample warning to file supportive comments in the docket. This is not the case and a significant disadvantage for those in opposition. Finally on this topic, it is worth noting that almost all of their letters in support are the same organizations that supported granting the CEC before any proposed settlement. Therefore, their support is not contingent on the settlement or anything that has happened since the CEC was filed in 2021.
 
Second, none of the underlying reasons why AriSEIA opposed the CEC in the first place have been addressed. SRP first proposed the Coolidge Expansion Project two years ago in the summer of 2021. One of our largest complaints was that SRP made the decision to invest nearly $1 billion dollars in almost 1 GW of new gas at the Coolidge Generating Station with no competitive bidding process in violation of their own Integrated Resource Plan (IRP). It has been two years and SRP has issued multiple all-source requests for proposals (ASRFPs) since and they have still not solicited or made public any bids to substantiate this project or its massive cost. There is simply no legitimate reason why SRP could not have done so in the last two years. It is highly unlikely that this Commission would allow Arizona Public Service (APS) or Tucson Electric Power (TEP) to do similarly with no competitive bidding process.
 
Third, the statutes that permit the CEC review clearly state that the Commission shall consider the cost of the facilities when determining to grant the CEC. SRP has never provided a rate impact analysis regarding this project. We simply do not know how much it will cost ratepayers. Further, SRP has not docketed any data that reflects the total cost of the project nearly two years later. If the project was $1 billion in 2021, how much does it cost now with 1) significantly increased interest rates, 2) millions of dollars in negotiated concessions, and 3) the dramatic increase in fuel prices we have seen in both TEP and APS fuel adjustor dockets, as well as the increase SRP’s board also voted to pass recently for their own fuel adjustor? It is not prudent to only include capital costs. Any resource acquisition should also include the operations and maintenance (O&M) costs for that plant/resource, as ratepayers pay the total cost.
 
It is simply imprudent to grant this CEC now. SRP should complete its currently pending IRP (called Integrated System Plan or ISP by SRP) process to determine what resources are needed and when and then should issue an ASRFP like every other utility in the state to determine the best project at the lowest cost. If the winning proposal is for a thermal resource, SRP should apply for a CEC, as required. There is no reason for the Commission to deviate from a process it would require of TEP and APS for SRP, certainly not for a CEC that has already been denied twice by this Commission and lost in court, as well.
 
Attached are two letters filed in opposition in March of 2022. As the Commission makeup has changed since, please review them. Please do not vote on the SRP’s CEC application to amend at the June open meeting and when you do vote, please vote no.
 
Respectfully,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org

AriSEIA coauthored an article today in PinalCentral on a pending anti-solar ordinance currently being considered in Eloy, AZ. Local renewables opposition is a huge impediment to the clean energy transition and means we will continue to rely on fossil fuels for electricity. Read the full article above and contact Eloy's city council in opposition.

AriSEIA filed direct testimony on rate design today in the APS rate case. The testimony covered a BYOD/VPP program proposal, a recommendation to disallow cost recovery for APS' uncompetitive microgrid program, rate design changes to several commercial storage rates, a change to how demand charges work for commercial customers installing EV chargers, a robust critique of APS' solar cost of service study, and community solar. 

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007

Re: In the Matter of the Five-Year Review of the Rules of Practice and Procedure before the Power Plant and Transmission Line Siting Committee, Arizona Administrative Code Title 14, Chapter 3, Article 2, Docket No. ALS-00000A-23-0063

Chairman and Commissioners,

We appreciate the opportunity to weigh in on changes to the Line Siting rules. Below you can find our joint recommendations regarding changes to R14-3-201 through 220.

We Recommend Changes to All Requirements to File Written Copies of Documents and/or Mail Documents.

Numerous provisions of the rules require filing hard copies of documents and/or mailing documents. We recommended that all of these sections be updated to permit electronic filing and to remove all requirements to file any print copies. If for some reason a print copy is required, such as an exhibit that may not lend itself well to a print version, only one print copy should be required. Further, service should be permissible via electronic means and should not require mailing.

R14-3-217 may be entirely unnecessary given this change.

We Recommend Updating Outdated Language.  

There is no reason that the presiding officer should be presumed to be male. The language should be updated to remove personal pronouns. If this is not possible, alternating pronouns or using something like “s/he” or another generic term would be suitable.
 
Recordings of the Proceedings Should Also be Available on the Arizona Corporation Commission’s “Live” Page for Streaming and for Archived Recordings. 

All Line Siting proceedings, including meetings and hearings, should be available to watch from the Commission’s “Live” page and a recording of all meetings and proceedings should also be available as an archived video on the same page. We recommend creating a tab for “Line Siting” on the archive portion of the webpage.
 
The Rules Should Allow That Hearings  Be Held at State Buildings Other Than the Capitol and That Notice Should Be Provided Electronically. 

R14-3-208(B)(2) says hearings can be held at the State Capitol in Phoenix. We recommend an option to hold the hearing in Phoenix, but think the Commission and other state buildings should also be an option for hearings. Further, public notice should be provided by means other than filing in the newspaper. Direct outreach to residents within a specific vicinity should be provided, as well as electronic notice via social media, email, radio, etc. should be utilized.
 
The Rule Should Expressly Allow Intervenors to Issue Data Requests. 

R14-3-211 should be updated to expressly indicate that intervening parties may issue data requests, along with the response time for responses.
 
We Recommend Requiring That a Free Read-Only Version of the Transcript Be Provided to all Intervenors and the Public. 

Procedural orders for Line Siting already require applicants to provide a read only copy of the hearing transcript to be publicly available on the applicant’s website. R14-3-212 should be updated to reflect this and the transcript should also be available on the Commission’s website, not just the applicant’s website.
 
We Recommend “Days” be Clarified as Calendar or Business Days. 

R14-3-215 should clearly specify if the Committee is using business days or calendar days to calculate deadlines or time periods provided under the rules, as well as what happens if the final day falls on a non-business day.
 
We Recommend Ex Parte Communications Be Treated More Seriously. 
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R14-3-220(D) should be updated to require disclosure of any ex parte communications received by a member of the Committee, as well as a requirement to recuse oneself, should the Member have initiated or responded to the ex parte communication with anything other than a notice that such communication was prohibited.
 
Thank you for considering our recommendations to this important update to the Line Siting rules.
 
Respectfully,
 
Patrick Woolsey
Sierra Club Environmental Law Program
patrick.woolsey@sierraclub.org
 
Autumn Johnson
Arizona Solar Energy Industries Association (AriSEIA)
autumn@ariseia.org

BLM Yuma Field Office
Attn: Erica Stewart
7341 E. 30th Street, Suite A
Yuma, AZ 85365
 
RE: Solar Variances

Dear BLM Staff,

The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We are active at all levels of government in the state and represent organizations throughout the clean energy economy. I am writing to encourage BLM to continue moving forward with the solar variance process for the proposed solar projects located in Mohave County.

Solar and storage systems benefit surrounding communities in several ways. First, Arizona continues to struggle with water quantity challenges. Solar development and operation of solar facilities does not require large amounts of water compared to other land uses. Using these lands for solar development can help alleviate some of Arizona’s water quantity challenges. Second, the use of clean energy reduces emissions and can improve air quality. Third, the proposed projects should not adversely impact local ecosystems. All three of the proposed projects plan to protect and preserve the natural habitat. Local wildlife and vegetation will still be protected on these lands and can also be used for solar facilities. Along with positive local impacts, the use of solar and storage benefits the entire nation, making public lands a particularly suitable place to develop these facilities. Air quality is a national and global issue; therefore, the emissions reductions achieved from transitioning to the use of more clean energy resources has widespread benefits. The deployment of solar energy also increases energy security throughout the United States. Overall, solar development on public lands will have long term benefits for both surrounding communities and the nation.

Please continue to consider and analyze the three solar projects for future development on BLM lands. These include White Hills Solar, Mineral Park Solar, and Leo Solar. AriSEIA supports renewable energy development on public lands. BLM and the solar companies involved should continue to be diligent in their analyses and take the steps necessary to evaluate the suitability of these projects. I have also attached some information on the water usage of solar (operations and lifecycle), the lifecycle emissions of different electricity generating resources, and solar development rates in Arizona and accompanying economic benefits.
Sincerely,
 
Autumn Johnson, Executive Director
AriSEIA
520-240-4757
autumn@ariseia.org
 
Figure 1 Life cycle water use for electricity generation: a review and harmonization of literature estimates. J Meldrum et al 2013 Environ. Res. Lett. 8 015031

Figure 2 Water Impacts of High Solar PV Electricity Penetration, NREL/TP-6A20-63011, September 2015 (operational water usage)

Figure 3 Life Cycle Greenhouse Gas Emissions from Electricity Generation: Update, NREL, 2021

AriSEIA filed a reply brief today in the Tucson Electric Power (TEP) rate case focusing on mechanisms to improve the use of storage for residential and commercial customers to benefit the grid widely. TEP has ignored and attempted to delay any such programs throughout the proceeding and for several years prior to the case.

AriSEIA filed its opening brief in the TEP rate case on May 26th highlighting our recommendations on the revenue requirement (including return on equity (ROE) and common equity ratio), as well as rate design (including community solar, a bring your own device/virtual power plant proposal, tariff re-designs for R-TECH and LGST-SP, and ending the distributed generation (DG) meter fee).