Rep. Tom O’Halleran, Business Leaders, Clean Energy Advocates Discuss Benefits of Inflation Reduction Act for Arizonans
Arizona – Clean Air Task Force Action, a U.S. advocacy organization that advances climate and clean energy policies designed to achieve decarbonization, today hosted a virtual roundtable with Rep. Tom O’Halleran (AZ-01), business leaders across Arizona’s energy sector, and clean energy advocates to discuss the Inflation Reduction Act (IRA) and how its continued implementation will benefit Arizonans and the state’s economy.
“For far too long, we’ve failed to take meaningful action to mitigate the effects of climate change on the desert southwest—drought, fires, and flooding are directly impacting Arizonans every day, be it coming water restrictions for southern Arizona families and farmers, homes and businesses lost to deadly wildfires in overgrown northern forests, or flood after flood destroying the homes and businesses of folks in Flagstaff,” said Rep. Tom O’Halleran (AZ-01). “The Inflation Reduction Act makes historic, targeted investments that address climate change head-on, creating new incentives that will produce cleaner, more affordable energy and create good-paying jobs in the process.”
You can watch a full recording of the roundtable discussion here.
Signed into law in August 2022, the IRA will allocate nearly $370 billion to incentivize the private sector to build out America’s 21st-century clean energy infrastructure. The law will help spur the economic transformation needed to address climate change, make clean energy more accessible and affordable, and direct important investments to underserved communities.
"The Inflation Reduction Act provides much needed certainty to an industry that already employs nearly 10,000 people in Arizona," said John Mitman, Board President, Arizona Solar Energy Industries Association (AriSEIA). "That certainty will enable even greater investment in a state with immense solar potential and a flourishing electrification hub. This legislation puts Arizona in an ideal position to be a leader in the clean energy sector."
In Arizona alone, the IRA is expected to create more than 65,000 new, good paying, high-quality jobs in 2035. Additionally, the legislation will reduce energy expenditures each year across the desert southwest region, mitigate extreme heat, prevent wildfires, and provide emergency drought relief to tribes, improve canals, and supply water. In 2030, cost savings from reduced energy expenditures will translate to lower energy costs for Arizonans annually by an average of $360 per household relative to current policy.
“The passage of the IRA is an exciting time for the solar industry and our team at OMCO Solar,” said Eric Goodwin, Director of Business Development, OMCO Solar. “The bill will enable OMCO to leverage our Arizona Manufacturing footprint to bring value to our solar customers in our home state with our factory-direct single axis trackers and fixed tilt ground mount solutions.”
"Korsail Energy is honored to be engaging with Representative O’Halleran and CATF-Action. Today's discussion reaffirmed that the Inflation Reduction Act will be a powerful, pragmatic solution for Arizona as it transitions towards a clean energy future,” said Scott Meyers, Development Analyst, Korsail Energy. “As a utility-scale solar and storage developer, Korsail Energy remains committed to working with diverse groups of stakeholders to proliferate the adoption of zero-carbon energy."
The IRA will also substantially increase Arizona’s clean energy capacity by expanding solar and wind energy, investing in existing nuclear energy, increasing rural and tribal energy, and clean vehicle manufacturing. The IRA is projected to result in 47 gigawatts of new solar capacity and four gigawatts of new wind capacity, adding up to more than 50 gigawatts of new renewable energy. That is enough energy to power the equivalent of roughly 7.5 million homes.
“The Inflation Reduction Act is a once in a generation opportunity for the state to significantly improve our transportation and electric systems; making them cleaner, more equitable, reliable and affordable,” said Amanda Ormond, Director, Western Grid Group. “Arizona needs strong collaboration and coordination across energy sectors and jurisdictions to capitalize on these opportunities.”
“The passage of the Inflation Reduction Act is a crucial step toward securing energy equity and a clean future,” said Trevor Warren, Founder and President, Higherwire. “At Higherwire, our mission is to reduce burdens to renewable energy storage and production, and this legislation will help us achieve that goal. It will also spur investment and innovation to produce clean, cost-effective energy that will create local jobs and reduce energy costs for all Arizona families.”
“Ørsted is excited to be developing its first project in Arizona – Eleven Mile Solar in Pinal County,” said Brianna Berkson, Western Regional Development, Ørsted. “With the passage of the IRA, we look forward to working on more projects in Arizona, bringing jobs and tax dollars to rural areas, and offering low-cost energy to the grid.”
“The Inflation Reduction Act is a win for Arizona businesses and consumers, and the benefits will be far-reaching,” said Lindsey Baxter Griffith, Executive Director, Clean Air Task Force Action. “The law will create high-quality jobs in Arizona and across the country, support the transition to a clean energy economy, and keep American energy globally competitive and affordable for decades to come, all while helping the U.S. achieve our climate goals.”
Other panelists included Jim Mapstead from Accurate Signs; Stephen Lassiter from Sunrun; Adam Stafford from Western Resource Advocates; and Tyler Orcutt from the Coalition for Community Solar Access.
Clean Air Task Force Action is a 501(c)4 nonprofit organization and the counterpart of Clean Air Task Force. CATF Action works to advance U.S. political and advocacy objectives. Learn more at catfaction.org.
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Re: Exceptions to APS Interconnection Manual, Docket E-01345A-20-0152
Madam Chair and Commissioners,
The Arizona Solar Energy Industries Association (AriSEIA) hereby files its Exceptions to Staff’s Memorandum and Proposed Order filed on September 29th, 2022. AriSEIA appreciates Staff’s efforts in reviewing Arizona Public Service’s (APS) Draft Interconnection Manual (the “Manual”). AriSEIA believes that the Order should be amended to incorporate several outstanding changes that are important to simplifying the interconnection process and are justified based on established technology performance across the globe and in other leading U.S. markets. The following Exceptions detail what changes must be made so that APS customers can further benefit from distributed generation, which will play a critical role in modernization of the grid.
As further background, AriSEIA participated in extensive review and discussion of the Manual with Staff and APS personnel throughout 2022, and we have filed comments in this docket and 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 costs while adding unnecessary time and complexity to the process for interconnecting distributed generation systems in APS territory. The Exceptions detailed herein remain in the spirit of this prior notion.
I. Production Meters for Energy Storage Systems (Section 9.2(C) and (D) of the Manual)
Section 9.2.(C) of the Manual states that a customer must provide Production Metering for any Static Inverter based Energy Storage System (ESS) (i.e., battery backup system). In addition to requiring Production Metering, Section 9.2.(D) further requires that “[c]ustomer must provide a suitable visible open disconnecting means […] to electrically isolate any CT rated meter from all potential sources of power.”
AriSEIA strongly believes that Production Metering requirements and, by extension, additional disconnecting means, are unreasonable and unwarranted for any residential or commercial customer-owned ESS designed to provide value strictly “behind the meter.” A solar system Production Meter captures all of its production. When discharging, backup batteries do not create new energy production. Furthermore, Tucson Electric Power (TEP) already acknowledged these arguments and agreed to remove their requirement for ESS Production Metering in the latest version of their Interconnection Manual filed and approved earlier this year.
A proposed amendment making this modification is attached below as Attachment A, AriSEIA Proposed Amendment No. 1.
II. Production Meters for All Generating Facilities (Section 9 of the Manual)
In general, and as an extension of our comments above, AriSEIA contends that Production Meters for any customer-owned Generating Facility are unwarranted in the post-incentive era, which included Performance-Based Incentives (PBI) and Upfront Incentives in exchange for ownership of a customer’s Renewable Energy Credits (REC). The applicable requirements of Section 9 are costly and burdensome when considering that distributed generation industries are disproportionately impacted by supply chain and inflation conditions to the extent that project viability is seriously impacted. Meanwhile, it is entirely feasible for regulators and utility companies alike to estimate solar production based on the system details included in Interconnection Applications, and we contend that such estimates are sufficient in lieu of Production Metering.
A proposed amendment making this modification is attached below as Attachment B, AriSEIA Proposed Amendment No. 2.
III. Ground Fault Detection Requirements for Class III Systems (Section 10.2(B)(2)e. and (3)e. of the Manual)
Section 10.2(B)(2)e and (3)e. states that systems in the applicable size range may require the addition of ground fault detectors in cases where the Generating Facility parallels the utility through a transformer with ungrounded configurations (float wye or delta). Utility systems must already include ground fault detection and protection with or without the presence of customer-owned Generating Facilities. In addition, Screen B of Appendix B: Interconnection Application Screens validates whether a Generating Facility’s ground fault current contributions are low enough to be safe, and any system passing this Screen should, therefore, be accommodated through existing utility equipment. At a minimum, AriSEIA contends that a clear exemption from additional ground fault detection equipment must exist for any systems which pass Screen B, as well as Non-Exporting Systems and Inadvertent Export Systems of 20 kW or less.
A proposed amendment making this modification is attached below as Attachment C, AriSEIA Proposed Amendment No. 3.
IV. Study Feed (Appendix C of the Manual)
The Commission’s Rules for Interconnection established that fees are allowed for utility studies “if a tariff containing such a fee for the Utility has been approved by the Commission.” Both APS and TEP include written handbook provisions which require specific fee deposit payments and provide for refunds through subsequent adjustment to the actual study costs (though costs are not defined). AriSEIA members consistently experience disproportionately high utility study deposits relative to the actual charges that are attributable to the work involved. Refunds are issued after extended periods of time (often in excess of 12 months) and represent a consistent majority of the original deposits that were made. Considering the excessive study deposits that the industry continues to grapple with, AriSEIA contends that the deposit amounts, and philosophy on study deposits, be revised in accordance with the following comments, and should be submitted to the Commission for approval:
A proposed amendment making this modification is attached below as Attachment D, AriSEIA Proposed Amendment No. 4.
V. Rate Schedules Applicable to Distributed Generation, System Size Limiting Factors (Appendix D of the Manual)
Under System Size Limiting Factors in Appendix D of the Manual, item 1.b., the methodology for calculating the maximum system size for non-residential DG systems is presented as “125% of connected load for its meter, where connected load is defined as the maximum demand divided by 0.6.” Item 2.a. further defines that the “connected load is measured in AC.” Based on AriSEIA discussions with Staff and APS, and written redlines from APS, AriSEIA notes that the intent of the definition in 2.a. was to establish that the system size is measured in AC, rather than “connected load,” which would translate to the output of the methodology in 1.b. being a non-residential DG maximum system size measured in kW AC.
A proposed amendment making this modification is attached below as Attachment E, AriSEIA Proposed Amendment No. 5.
Because these manuals are iterative, the utilities should establish a stakeholder process to discuss developing issues with the manuals and technological change.
We respectfully request the Commission direct APS to file a revised Manual with the amendments attached below by November 15, 2022, to be effective immediately upon filing. Thank you for considering these comments meant to improve the compliance of the APS Manual with the spirit and letter of the Commission’s Interconnection Rules.
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
RE: Response to Arizona Public Service Community Solar Program Proposal - Docket No. E-00000A-22-0103 and Docket No. E-01345A-21-0240
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 nonprofit advocacy groups — appreciate the time that the Commission Staff, and stakeholders have dedicated to conducting five comprehensive working group meetings to date regarding the implementation of a community solar program in Arizona. With this letter, we provide a summary of necessary changes to the Arizona Public Service (APS) community solar program proposal, filed to the docket on September 26, 2022. While the signatories appreciate that APS has offered a program proposal as required by Commission Decision 78583, the signatories find several components of the APS proposal to be inconsistent with that Decision and generally not representative of how community solar programs operate in established markets across the country. The signatories believe that the APS proposal will not result in any competitive third-party development of community solar projects and, as such, restricts benefits that would be created for subscribers and ratepayers as a result of such development. In fact, APS’s proposal would let a single large-scale, utility-owned project interconnected on the transmission grid satisfy the entire community solar program requirement. The Commission should reject this program structure.
The signatories agree with the four core principles guiding APS’s program design:
The program proposal the signatories filed on August 26, 2022 is consistent with Decision 78583, the core principles listed above, and with community solar programs nationally. The signatories maintain that the program proposal we offered represents the best balance of benefits for all stakeholders. Should the Commission attempt to work within the framework proposed by APS, the signatories offer the following recommendations to be incorporated into the APS proposal. These recommendations are necessary for implementation of a successful competitive community solar program. Our recommendations incorporate certain elements of the signatories’ August 26, 2022 program proposal and were further supplemented by the bill credit rate proposal filed on September 9, 2022. The signatories request that Commission Staff adopt these necessary recommendations in its Recommended Opinion and Order (ROO).
Key changes and clarifications to the APS program proposal are required in the following thirteen (13) areas. Comprehensive rationale behind each of these changes is provided below.
To further supplement these recommendations, the signatories have provided Attachment A to this filing, which includes a table and graphs summarizing bill credit methodologies, values, and terms from nine programs across the country where the signatories have experience, which are also representative of successful, robust programs. We also provide Attachment B, which summarizes program size and LMI subscriber considerations in programs across the country. Finally, we provide Attachment C, which summarizes the key considerations of subscriber organizations and financiers when financing community solar projects.
Investing in infrastructure is an opportunity to imagine and build a better future for everyone. The influx of federal dollars from the recently-adopted Inflation Reduction Act and the Bipartisan Infrastructure Law is a once-in-a-generation chance to imagine what a better future for Arizona looks like and then to make it real.
New federal funds have enormous potential to save residents and businesses money on energy and transportation, create new jobs, and expand prosperity – while also improving our health and protecting our climate. However, how local governments choose to implement new policies will have a large effect on their overall impact. We, a coalition of 14 clean energy, energy efficiency, community health, and environmental justice groups, write to ask you to maximize the benefits of this unprecedented opportunity and to steer our region toward a better future.
Specifically, we urge you to identify, direct federal funding towards, and maximize public participation in projects and programs that will:
Opportunities to deliver these kinds of benefits to the region and state are plentiful within the Inflation Reduction Act and the Bipartisan Infrastructure Law. For example, states and local governments can:
Successfully implementing the Inflation Reduction Act and the Bipartisan Infrastructure Law will require coordination and cooperation across all levels of government. Our organizations stand ready to assist with the task at hand. We look forward to meeting with you and your staff to help identify opportunities to increase benefits, connect your staff with grant-writing assistance, support your funding applications, or discuss your investment or synergistic policy plans. Additionally, please take a look at the resources and assistance available through the Local Infrastructure Hub, including a grant application bootcamp for small- to medium-sized cities. (localinfrastructure.org)
We look forward to working with you to maximize the benefits of this unprecedented investment in the future of our region.
To Members of the Salt River Project Board and SRP Management,
Attached please find the People’s Energy Plan to provide clean energy alternatives to the proposed portfolios currently being considered by Salt River Project Agricultural Improvement and Power District (SRP) in your Integrated System Plan (ISP). The proposed portfolios we present are supported by various communities and stakeholders, including those who have signed this letter, who are concerned about a clean energy future for Arizona. Strategen, a consulting firm focused on decarbonizing energy systems, has done the modeling and analysis for the People’s Energy Plan.
The People’s Energy Plan presents a comprehensive and detailed resource plan that lays out a roadmap for how SRP can meet its clean energy obligations to SRP ratepayers and stakeholders, as well as the people of Arizona. SRP has the potential today to help Arizona address climate change. The People’s Energy Plan is a culmination of direct feedback from everyday hardworking people, community leaders and stakeholders who have strongly voiced what they would like to see from SRP as the Integrated System Plan moves forward.
Unfortunately, SRP has been doubling down on fossil fuels with its efforts to expand the Coolidge Generating Station with 16 additional gas units that would contribute to environmental injustice in the community of Randolph, a proposal to keep the Coronado Generating Station running longer, gas expansions at Agua Fria and Desert Basin, and most recently, proposed gas at Copper Crossing. SRP’s plans to spread out gas turbines to various locations in smaller configurations come at a higher cost for ratepayers and avoids oversight by the Arizona Power Plant and Line Siting Committee and the Arizona Corporation Commission. This is the wrong direction for a utility that indicates it is dedicated to sustainability.
The People’s Energy Plan provides a reliable alternative to more gas and continued reliance on coal and finds the following:
Recommendations in the People’s Energy Plan include minimizing investments in new gas, reassessing the retirement dates for coal-fired generating units at Four Corners and Coronado, continuing to support demand side resources, setting more meaningful carbon reduction targets, and exploring the incentives available through the Inflation Reduction Act.
We invite SRP leadership and Board members to thoroughly review the People’s Energy Plan and engage with the People’s Energy Plan coalition to ensure that the ISP represents a fair and transparent process that results in the cleanest and most equitable possible path forward for Arizonans. We expect the People’s Energy Plan will be a useful resource that SRP can implement to benefit ratepayers, Arizona communities, and the environment. SRP can and should be a leader among the state’s utilities in developing clean renewable energy, promoting energy efficiency, and integrating further adoption of distributed energy resources. The People’s Energy Plan demonstrates how SRP can achieve these goals and move away from reliance on coal and gas.
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