Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
RE: Community Solar, Docket No. E-00000A-22-0103
 
Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders,
 
The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions.
 
We were encouraged by the progress made during the Commission’s community solar working group held on August 4, 2022 and appreciate that the next meeting will be a two day working group session held on August 30 and 31. We understand that Staff is still developing the proposed agenda for the August meetings; therefore, we suggest the following topics: bill credit structure and value,  eligible subscribers and low- and moderate-income (LMI) subscriber participation, program and project size, project selection, storage, and hosting capacity maps. 
 
To the extent that it is helpful to the Staff and other stakeholders, below are potential questions that could be posed for each topic at the next meeting.
 
●     Bill credit structure and value
○     How should the bill credit be structured?
○     Would the resource comparison proxy (RCP) accurately represent the full value of community solar projects?
○     Given the bill credit structure, what is the projected value of the bill credit?
○     What should the term of the bill credit be?
 
●     Eligible subscribers and LMI participation
○     Which customer classes should be eligible for participation in the program?
○     Should there be percentage per-project subscription targets or requirements for certain customer classes?
○     Should there be a required percentage for LMI customer subscription?
○     Should there be a maximum project capacity that “anchor tenants” can subscribe to?
 
●     Program size and project size
○     Should there be a cap on program size?
○     If yes, how should it be constructed? (e.g., percentage of total retail sales vs. number of MW)
○     Should there be a maximum project size or only a requirement that projects connect to the distribution grid?
 
●     Project selection
○     How should projects be selected for participation in the program? (e.g., first-come first-served vs. RFP)
○     What type of project maturity milestones should be required for eligibility in the program, and should those milestones depend on the program size (capped versus uncapped)?
 
●     Storage
○     Should community renewables projects be limited to solar photovoltaic systems, potentially paired with storage?
 
●     Hosting capacity maps
○     Has Arizona Public Service (APS) completed a hosting capacity study and if so, how do the results compare to what would be needed for program implementation?
○     Does APS have hosting capacity maps and if so, how are they to be used by developers?
○     Are there recommended examples of hosting capacity maps in other states?
○     What types of data should be included in hosting capacity maps and how often should they be updated?
 
Further, as was requested at the August 4th working group meeting, we have provided as Attachment A an illustrative example of cash flows for a community solar program, sample or redacted bills as Attachment B from Minnesota and New York, and sample contracts from Nautilus and Arcadia as Attachment C.
 
We appreciate the opportunity to address these important concerns. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona.
 
Respectfully,
 
Autumn Johnson
Executive Director
Arizona Solar Energy Industries Association
(520) 240-4757
autumn@ariseia.org
 
Salar Naini
Executive Vice President, Business Development
Turning Point
(480) 330-1245
snaini@tpoint-e.com
 
Justin Biltz
Director, Policy & Strategy, Community-Scale Markets
Cypress Creek Renewables
(330) 515-1564
justin.biltz@ccrenew.com
 
Bret Fanshaw
Arizona Program Director | West Region Director
Solar United Neighbors
(602) 962-0240
bfanshaw@solarunitedneighbors.org
 
Angela Navarro
Head of State Regulatory Affairs
Arcadia
(352) 262-8201
angela.navarro@arcadia.com

Kevin Cray
Mountain West Regional Director
Coalition for Community Solar Access (CCSA)
(303) 819-3457
kevin@communitysolaraccess.org
 
Maria McCoy
Research Associate, Energy Democracy
Institute for Local Self-Reliance
(612) 808-0688
maria@ilsr.org
 
Sara Birmingham
Senior Director of State Affairs
Solar Energy Industries Association
(415) 385-7240
sbirmingham@seia.org
 
Joy Crossman
Director of Development
Soltage, LLC
(201) 559-6243
jcrossman@soltage.com
 
Kate Bowman
Interior West Regulatory Director
Vote Solar
(703) 674-8637
kbowman@votesolar.org
 
Landon Stevens
Director of Policy
Conservative Energy Network
(480) 338-9767
Lstevens@conservativeenergynetwork.org
  
Scott Risley
Executive Director of Public Policy
Nautilus Solar
(928) 925-5972
srisley@nautilussolar.com
 
Christopher Mejia
Founder
Consolidated Solar
(717) 884-2204
chris@consolidatedsolar.net

 

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: APS Interconnection Manual, Docket E-01345A-20-0152

Madam Chair and Commissioners,
​
This item is scheduled for the Staff Meeting on August 16, 2022, as number 11. The Arizona Solar Energy Industries Association (AriSEIA) has reviewed the Arizona Public Service (APS) Interconnection Requirements for Distributed Generation Rev. 9.0 dated May 6, 2022, and as amended in redlined versions from APS on July 20, 2022 and August 10, 2022 (the “Manual”). We have filed comments in this docket, met with APS and Commission Staff several times, and have submitted written feedback to both APS and Staff on outstanding issues.

During the deliberation on the Commission’s Interconnection Rulemaking, we expressed our concern that there are many utility requirements that unnecessarily inflate cost while adding time and complexity to the process for interconnecting distributed generation systems in APS territory. Unfortunately, the July 24, 2020, Rev. 8.5 Manual shown on the APS website is the Manual currently being utilized by APS, despite numerous elements that make interconnecting distributed generation needlessly costly for consumers. In fact, in some respects, APS ignores the Commission’s Interconnection Rules. The usage of this older version of the manual is very detrimental to our member companies. This stands in stark contrast to Tucson Electric Power (TEP) who adjusted their interconnection requirements with each revision of their handbook as issues were identified and eliminated during the stakeholder process. The APS Manual revisions to date make multiple changes as a result of stakeholder engagement that address issues that continue to impact the cost, size, and schedules of projects over two and a half years after the Commission’s Interconnection Rules became effective.

We respectfully request the Commission direct APS to file a revised Manual no later than August 31, 2022 and to utilize that version until a final vote by the Commission. Given the significant delay in the finalization of the Manual, we request this matter be noticed for a final vote on the October Open Meeting agenda.

Thank you for considering these comments meant to improve the compliance of the APS document with the spirit and letter of the Commission’s Interconnection Rules.

Respectfully,

Autumn Johnson
Executive Director
AriSEIA
520-240-4757
autumn@ariseia.org
​
Mark Holohan
Board of Directors
AriSEIA
602-339-8274
markdholohan@gmail.com

For Immediate Release: August 12, 2022
Contacts:

• Yara Marin, Vote Solar, yaraneth@votesolar.org, 602.492.6077
• Bret Fanshaw, SUN Action, bfanshaw@solarunitedneighbors.org, 602.962.0240 
• Autumn Johnson, AriSEIA, autumn@ariseia.org, 520.240.4757

Arizona’s solar community applauds passage of Inflation Reduction Act
 
Phoenix, AZ – Arizona’s solar community, including the Arizona Solar Energy Industries Association (AriSEIA), Solar United Neighbors Action, and Vote Solar, celebrated the passage of the Inflation Reduction Act on Friday. Among many provisions, the landmark legislation will extend and expand tax credits over the next decade for homeowners and businesses installing solar panels, as well as large-scale clean energy development. The bill earned support from a majority of Arizona’s Congressional Delegation, including Senators Kyrsten Sinema and Mark Kelly, and Representatives Gallego, Grijalva, Kirkpatrick, O’Halleran, and Stanton. It now goes to President Biden for his signature.
 
“The Inflation Reduction Act is a huge win for anyone that wants to use solar power in Arizona,” said Bret Fanshaw, Arizona Program Director with Solar United Neighbors Action. “By making solar more affordable for Arizona families, households will directly reap the benefits with lower electric bills for decades to come. We applaud Arizona’s leaders who supported the bill, especially Senators Sinema and Kelly.”
 
The legislation increases the Federal Solar Investment Tax Credit for residential solar installations from 26% to 30%, beginning this year and extending through 2032. This will lower the cost of an average home solar installation in Arizona by around $6,000. It also makes battery storage technology eligible for tax credits as a standalone resource. 
 
“More solar and storage investment in Arizona will mean tens of thousands more jobs in the renewable energy sector,” said Autumn Johnson, Executive Director with AriSEIA. “With the passage of this bill, Arizona is poised to use our ideal climate and existing solar industry to continue to lead the country on the deployment of solar power.”
 
In addition to expanding and extending residential tax credits, the bill also provides direct cash payments to tax-exempt organizations installing solar. Traditionally, tax-exempt entities like nonprofits, schools and local governments have not had direct access to federal solar incentives. Rural small businesses and agricultural producers installing solar will also benefit from an expansion of the Rural Energy for America Program (REAP). REAP provides grants that can cover up to half the cost of an eligible rural solar project. The Inflation Reduction Act also includes a $7 billion EPA grant program to enable deployment of zero-emission technologies in lower-income and environmental justice communities.
 
“We are energized by the solar components within the Inflation Reduction Act. The direct pay and REAP provisions help to reduce barriers to solar for communities and marginalized groups,” said Yara Marin, Regional Director for the Interior West at Vote Solar. “However, we recognize that this bill does not remove every barrier to solar access. Vote Solar will continue to work at the state level to ensure solar for all.” 
 
At the same time the bill is poised to make transformational investments in solar and other clean energy resources, it also has significant shortcomings, such as potential for new fossil fuel development which has an outsized negative  impact on historically marginalized communities. Advocates recognized the need for federal, state, and local government agencies to ensure the bill delivers meaningful results to all Arizonans. As the sunniest state in the country and a burgeoning hub for clean energy technologies from solar panels to battery storage and electric vehicles, Arizona is poised to reap the benefits of this historic $370 billion investment in clean energy and a healthy climate.
 
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Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) trade organization and the state chapter of the Solar Energy Industries Association (SEIA). AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy and storage. We advocate for sustainable job creation and encourage utilization of Arizona’s greatest natural resource, the sun.
 
Solar United Neighbors Action is a national 501(c)4 nonprofit. SUN Action represents solar homeowners and everyone who wants to benefit from solar energy. We are fighting for a clean, resilient, and equitable energy system. We do this by putting rooftop solar at the cornerstone. Our grassroots network of solar supporters communicates with lawmakers to implement the policies that will make this vision a reality.
 
Vote Solar is a 501(c)3 non-profit organization. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar works to remove regulatory barriers and implement key policies needed to bring solar to scale. Vote Solar works to realize a 100% clean energy future through a solutions-driven, people-first approach. 

Senator Kyrsten Sinema
333 E. Camelback Road, Suite 200
Phoenix, AZ 85018
 
RE: Support for the Inflation Reduction Act of 2022
 
Dear Senator Sinema,
​
The Arizona Solar Energy Industries Association’s (AriSEIA) mission is to develop and support policies that create opportunities to advance Arizona’s economy through solar energy and storage. AriSEIA advocates for sustainable job creation in deployment of solar and complementary technologies and collaborates with stakeholders to encourage utilization of Arizona’s greatest natural resource: the sun.

We write to encourage you to vote “yes” on the Inflation Reduction Act (IRA). This legislation will provide much needed funding and incentives to advance our transition to a clean energy economy. Renewables are a critical component in that energy transition. In addition to supporting a robust solar supply chain, the IRA will bring new jobs to Arizona, as well as the potential for significant dollars of additional economic development and investment in our state. Princeton’s REPEAT Project estimates that the IRA will create 65,000 new jobs in Arizona in the renewables sector by 2035. It will also save Arizona consumers approximately $360 per household on energy expenses by 2030.

AriSEIA represents approximately sixty companies already doing business in Arizona that are ready and willing to ramp up their operations and increase their investment. Solar already provides more than 8,000 jobs in Arizona and we look forward to that continuing to grow. Our members engage in every aspect of the solar supply chain, and they are eager to get to work doing even more to promote our economy, our environment, and our residents with the passage of this historic legislation. Additional renewables deployment also means Arizona’s electric system will use less water, which is critical as we face unprecedented water shortages, because solar uses considerably less water than thermal electricity generation.

Voting “yes” on the IRA is a vote for the clean energy transition and the companies and workers in Arizona that make it happen. Please support the Inflation Reduction Act.

Sincerely,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org

Salt River Project
1500 N. Mill Avenue
Tempe, AZ 85288
 
RE: Integrated System Plan and Stakeholder Engagement
 
Salt River Project and Board,

The Arizona Solar Energy Industries Association (AriSEIA) requests inclusion in Salt River Project’s (SRP) Integrated System Plan (ISP) Advisory Group. AriSEIA has previously requested inclusion in the ISP Advisory Group on more than one occasion beginning in January of 2022. We have been told that we cannot participate in the Advisory Group because SRP seeks to “have focused engagement from a diverse, but small group of SRP customers and community stakeholders.” However, as you can see from the list of stakeholders [above], there are zero participants that represent the renewables sector; no companies or nonprofit organizations.[1] Further, the Advisory Group size is not unwieldy or even on the larger size of stakeholder groups run by other utilities. AriSEIA has been included in the Arizona Public Service (APS) and Tucson Electric Power (TEP) resource planning processes. And other utilities, such as Idaho Power, keep their meetings open to anyone interested and have not found it to be burdensome. Many of the entities on the current Advisory Group are not actively engaged, thereby further reducing the burden the inclusion of AriSEIA may hypothetically pose.

AriSEIA has also not been included in the Sustainability 2035 Advisory Council. Renewables play a key role in the clean energy transition and the lack of inclusion of any renewables stakeholders is inadequate. We request inclusion in the ISP Advisory Group, as well as the Sustainability Advisory Council. Participation in the very infrequent, public meetings is insufficient, as it does not provide ample opportunity to participate in any of the modeling discussions, where key decisions are made.

Sincerely,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org

[1] SRP Meeting 3 Presentation, 1.19.2022, available here https://www.srpnet.com/assets/srpnet/pdf/grid-water-management/grid-management/isp/ISP-Advisory-Group-Meeting-3-Presentation.pdf.