Joint Statement from Solar United Neighbors, Vote Solar, and the Arizona Solar Energy Industries Association

Arizona Corporation Commission Disappoints Solar Advocates, Siding with Utility Profits
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Tucson, Arizona - The Arizona Corporation Commission (ACC) today approved Tucson Electric Power’s (TEP) and UniSource Electric’s (UNSE) proposal to decrease Resource Comparison Proxy (RCP) rates for 2025, further undermining the opportunity to use solar energy to save money on utility bills for customers across Arizona. The Resource Comparison Proxy (RCP) is Arizona’s solar export rate, which determines how much solar customers are paid for the electricity they send back to the energy grid. Commissioners have the option to limit reductions to the RCP in order to avoid negatively impacting solar adoption, and have previously exercised this option during times of economic turmoil such as the COVID-19 pandemic. With the reduction approved today, utilities will pay less for the energy rooftop solar provides, which will ultimately discourage new installations and force the construction of costly new power plants that all customers will pay for through higher energy bills. Solar installations among TEP’s customers fell nearly 40% in 2024, and the ACC-approved reduction to solar rates will only accelerate this trend.[1]

“Today’s vote is yet another gift to profit-driven utilities at the expense of communities,” said Kate Bowman, Senior Regulatory Director at Vote Solar. “By cutting the value of solar, the ACC is making it harder for Arizonans to invest in solar—just as these same households are facing rising costs of living and utility bills and a phase out of the federal solar tax credit.”

“This decision demonstrates a troubling pattern of behavior by this Commission," said Adrian Keller, Arizona Program Director at Solar United Neighbors. "The ACC consistently approves utility requests while neglecting the ratepayers they are supposed to protect. Following their approval of APS's identical proposal last month, today’s decision continues to penalize families who invest in solar.”

“The Commission likes to say it is for an ‘all of the above’ energy strategy, yet its decisions paired with federal policy changes continue to single out renewables punitively,” said Autumn Johnson, Executive Director of the Arizona Solar Energy Industries Association (AriSEIA). “This Commission has imposed solar only fees, continues to reduce the solar export rate, and is trying to eliminate our renewable standards (REST rule), all while the federal government has cut tax credits, imposed extreme tariffs, and enacted a de facto moratorium on all renewables development.”

Utilities earn a rate of return on every dollar they spend building power plants and transmission lines. When homeowners invest their own savings to install rooftop solar, they help avoid these expensive projects, saving money for all customers—which is exactly why utilities oppose technologies that threaten their bottom line. Shortly before requesting a 10% reduction to the rate paid to solar customers for exporting electricity, TEP filed a rate case asking Commissioners to increase the rates families pay to purchase electricity from the utility by 14%.

Reducing solar export rates will ultimately eliminate jobs, weaken our grid, and force utilities to build new energy generation—a cost that will be passed down directly to customers. On the other hand, increasing access to solar has proven to help families mitigate rising power bills and deliver critical power during record-breaking heat and peak demand.

At a time when energy bills are soaring, the Commission should be making solar more affordable, not less. Arizonans deserve the freedom to choose solar power to reduce their bills and protect against rate hikes. Instead, the ACC continues giving utilities tools to discourage renewable energy adoption and maintain their monopoly control.
 
About Solar United Neighbors
Solar United Neighbors is a national nonprofit organization that helps people go solar, join together, and fight for their energy rights. SUN's Arizona program advocates for policies that expand solar access and protect solar rights for all Arizonans.
 
About AriSEIA
AriSEIA is an Arizona nonprofit trade association working on renewables policies across the state. AriSEIA’s mission is to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification.
 
About Vote Solar
Vote Solar is a nonprofit advocacy organization working to advance state-level policies that make solar and clean energy solutions accessible to all. Since 2002, Vote Solar has worked to build a just and equitable energy future by leveraging deep policy expertise, strategic partnerships, and public engagement. In the face of powerful opposition, Vote Solar champions bold solutions that expand clean energy access, drive investment in frontline communities, and accelerate the transition to 100% clean energy.

[1] According to TEP’s most recent published solar installation data, comparing the first three quarters of 2023 with the first three quarters of 2024. Available at: https://arizonagoessolar.org/tucson-electric-power-tep/

AriSEIA filed nearly 1000 pages of exhibits in the Sulphur Springs rate case in which the utility seeks to undermine the contract rights of solar customers. AriSEIA also filed a response to SSVEC's attempt to strike our testimony on their underpayment to solar customers, an issue we have been raising for almost two years.

September 12, 2025
 
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
RE: Response to Staff IRP Software License Reimbursement Framework; IRP Docket No. E-99999A-25-0058
 
Chairman and Commissioners,
 
AriSEIA is a member of both the TEP/UNSE and APS Resource Planning Advisory Councils (RPAC). We have been engaged with the last two TEP and APS Integrated Resource Plans (IRPs). In addition to being on the RPACs, regularly attending the meetings, submitting detailed comments on the plans, presenting at the IRP workshop and IRP open meeting; we also participated in the modeling process last time.
 
AriSEIA filed comments on the original Staff recommendation on October 4, 2024[1] and then again on June 13, 2025.[2] AriSEIA continues to maintain that it is a mistake to require stakeholders to pay for their own modeling licenses. AriSEIA also filed comments refuting utility statements at the IRP workshop that stakeholders had not properly utilized their licenses on August 27, 2024.[3] AriSEIA filed comments on the 2023 IRPs on January 31, 2024 as required. That filing was 142 pages long.[4] AriSEIA also filed 263 pages of joint comments with Vote Solar and Advanced Energy United as to the 2023 IRPs on January 31, 2024.[5] That filing included 124 slides as to RMI’s analysis of TEP and APS’ IRPs, based on their use of the modeling licenses. RMI was our consultant in that matter. AriSEIA filed joint comments in the same docket supporting the need to move the IRP deadline due to modeling delays on May 2, 2023.[6] AriSEIA filed a letter to the docket expressing concerns that APS and TEP were violating the 2020 IRP Order in delaying the release of the modeling tools on April 28, 2023.[7] We note these filings now to draw attention to our robust participation in IRP dockets, but also to highlight that issues with the modeling licenses plagued all of 2023. AriSEIA does not recommend changing the process yet again, as we had just barely worked out the issues with the prior process.
 
Nevertheless, we highlight the following remaining concerns with the Utilities Division Staff  IRP Software License Reimbursement Framework filed on September 3, 2025.[8]
 
RECOMMENDATION 1: Require One Model
 
AriSEIA recommends the policy require a stakeholder to run the base case scenario or one (not two) distinct portfolio. Staff’s concerns about ability to hire consultants, Staff capacity as to time, and their lack of any modeling in the 2023 IRP process highlight how onerous this work is. There is no substantiation as to why stakeholder need to run three models. One should be the floor. If a stakeholder has the time or resources to run more, then there is nothing stopping them from doing that. Many stakeholders are on multiple RPACs. Three models per utility means that some of us would actually need to run 6-9 models. Additionally, the Commission should not further limit what constitutes a distinct model by prohibiting modification of retirement dates to be considered a distinct model.
 
RECOMMENDATION 2: Create a Scholarship Option
 
The Commission should consider a scholarship process for stakeholders that can demonstrate a financial hardship. The Commission should put parameters in place to make sure only qualified stakeholders qualify for the scholarship. If a stakeholder does qualify, they should be required to complete the requirements set out in this policy, but without paying for the license themselves. Suggested parameters may include: being a member of the RPAC, attending a certain percentage of RPAC meetings, demonstrated participation in the last IRP process, being a not for profit entity, and financial hardship either by 990 or other means. Penalty for obtaining a scholarship and not completing the requirements as set forth in this policy could be disqualification from any such similar program in the next IRP cycle.
 
RECOMMENDATION 3: Provide Data to RPAC Members That Do Not Obtain Licenses
 
The cost of the licenses and a consultant to perform the required portfolios will cost ~$175,000. This will make this process cost prohibitive for many stakeholders, thereby reducing participation and the number of eyes reviewing plans that cost >$30 billion dollars. The Commission should create an alternative option by which RPAC members can obtain more data than the filed IRP, but not data that can only be utilized with proprietary software. Additionally, the Commission could direct the LSEs to provide certain deliverables to RPAC members and/or require LSEs to run portfolios suggested by RPAC members. For example, RPAC members that do not obtain licenses should be permitted to put forward two portfolios for the LSE to run by the NOI date in the Staff Framework.
 
Because the Framework does not have line numbers or numbered bullets, we have provided a redline for Commission consideration as Exhibit 1, as opposed to amendments. This is the bare minimum changes we recommend, but also suggest inclusion of Recommendations 2 and 3, as well.
 
Thank you for your consideration.
 
Respectfully,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] AriSEIA Comments on the August 30, 2024 Utilities Division Memorandum and Amendments, Docket No. E-99999A-22-0046, filed October 4, 2024, available here https://docket.images.azcc.gov/E000039019.pdf?i=1749756384020.

[2] AriSEIA Comments on the Staff Proposed Framework for IRP License Reimbursement, Docket No. E-99999A-22-0046, filed June 13, 2025, available here https://docket.images.azcc.gov/E000044750.pdf?i=1757656787403. . 

[3] AriSEIA Response, Docket No. E-99999A-22-0046, filed August 27, 2024, available here https://docket.images.azcc.gov/E000037591.pdf?i=1749756384020.

[4] AriSEIA Comments on the APS and TEP 2023 IRPs, Docket No. E-99999A-22-0046, filed January 31, 2024, available here https://docket.images.azcc.gov/E000033415.pdf?i=1749756384020.

[5] Joint Comments of AriSEIA, Advanced Energy United, and Vote Solar on the 2023 IRPs, Docket No. E-99999A-22-0046, filed January 31, 2024, available at https://docket.images.azcc.gov/E000033451.pdf?i=1749756384020.

[6] Support for APS and TEP’s Request for an Extension of IRP Filing Deadline, Docket No. E-99999A-22-0046, filed May 2, 2023, available at https://docket.images.azcc.gov/E000026358.pdf?i=1749756384020.

[7] AriSEIA Letter on IRP Modeling Licenses, Docket No. E-99999A-22-0046, available at https://docket.images.azcc.gov/E000026311.pdf?i=1749756384020.

[8] Utilities Division Staff Proposed Framework for IRP License Reimbursement Memorandum, Docket No. E-99999A-25-0058, filed May 9, 2025, available here https://docket.images.azcc.gov/E000044023.pdf?i=1748461994048. 

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
RE: Opposition to Repeal of the Electric Energy Efficiency Standards Rules in Docket No. RE-00000A-24-0025
 
Dear Chairman and Commissioners:
 
The Arizona Solar Energy Industries Association (AriSEIA) respectfully submits these comments in opposition to the wholesale repeal of the electric energy efficiency standards rules in the above-referenced docket. At the very least, please preserve the sections of the rule that pertain to filing Demand Side Management (DSM) plans R14-2-2405 through R14-2-2410, as well as any other provisions that Hearing Division deems necessary to DSM plan submission and approval.
 
Arizona is experiencing significant load growth and has repeatedly set new system peak records.[1] In this environment, demand side management programs are more critical than ever. Energy efficiency and demand side management resources provide cost-effective capacity, reduce reliance on volatile wholesale markets, and enhance reliability during times of peak demand. Arizona Public Service (APS) alone meets 14% of demand from DSM program, that is equal to the share of coal in their portfolio and exceeds the amount of utility scale renewables on their system.[2] APS has more than 2 GW of DSM on their system.[3] Eliminating the framework that enables these programs would increase costs for ratepayers and threaten grid stability.
 
We are particularly concerned about the proposed repeal of R14-2-2405 and the immediately following sections. These provisions are where utilities currently house their demand side management plans, including their virtual power plant (VPP) programs. The Commission has already twice voted to uphold these programs as valuable and cost-effective resources. These programs deliver capacity for less than market purchases and help utilities manage peak load reliably.
 
The Commission itself ordered the APS VPP pilot program in Docket No. E-01345A-22-0144, following review in a contested rate case and a year-long dedicated stakeholder process. The second year of funding for that program is now included in APS’s pending DSM plan in Docket No. E-01345A-23-0088. Repealing the DSM rule sections that house these plans could undermine the ability of the Commission and stakeholders to continue building on programs that have already been vetted and approved.
 
Energy efficiency and demand side management programs are not abstract policy ideas. They are in operation today, they are working, and they are providing measurable value to Arizona utilities and ratepayers. They save money, improve reliability, and ensure that Arizona can meet the challenges of rapid growth.
 
For these reasons, AriSEIA urges the Commission to reject the wholesale proposed repeal of the electric energy efficiency standards rules. Preserving at least portions of these rules, especially the DSM provisions, is essential to maintaining affordable, reliable, and resilient power for Arizona families and businesses.
 
Thank you for your consideration.
  
Respectfully,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] Arizona Corporation Commission, Arizona Electric Utilities Set Record High Demand Again; Demand Soars Above Original Forecasts for 2025, August 8, 2025, available here https://azcc.gov/news/home/2025/08/09/arizona-electric-utilities-set-record-high-demand--again--demand-soars-above-original-forecasts-for-2025.

[2] Arizona Public Service, Form 10-K 2024, December 31, 2024, p.5,  available here https://s22.q4cdn.com/464697698/files/doc_financials/2024/ar/PNW-2024-12-31-10-K.pdf.

[3] Arizona Public Service, 2023 Integrated Resource Plan, November 2023, p.26, available here https://www.aps.com/-/media/APS/APSCOM-PDFs/About/Our-Company/Doing-business-with-us/Resource-Planning-and-Management/APS_IRP_2023_PUBLIC.pdf?la=en&hash=F601897086C6836F7FD33C5C2F295F47. 

AriSEIA filed testimony today opposing the settlement agreement entered into in the Sulphur Springs rate case with Arizona Corporation Commission (ACC) Staff and the IBEW union. The settlement agreement violates federal law by allowing the export rate for solar to fall below avoided cost. It eliminates grandfathering for customers that already have solar on their businesses with no warning. And it eliminates the 10-year lock in for new solar customers, even though every other utility provides it. The settlement agreement in not in the public interest.