AriSEIA filed its reply brief in the Sulphur Springs rate case today. AriSEIA is the only intervenor in that case to provide any meaningful push back on the utility and its wildly anti-solar rate design. Our recommendations are as follows:
1.  Reject or modify the proposed settlement to the extent it establishes a Distributed Generation Exported Energy (DGEE) rate of $0.0307 per kilowatt hour for three years without demonstrating compliance with the avoided cost floor applicable and without showing substantial evidence supporting the value.
2. Reject the settlement provision that freezes net metering and limits grandfathering of existing customers to the earlier of twenty years from installation or November 17, 2035, because Decision No. 76465 stated that to deviate from that framework required a showing of good cause supported by evidence. (AriSEIA-22 at 12).
3. Preserve the ten year export rate lock in applicable to distributed generation customers because the Value of Solar decision requires a ten year lock in period (AriSEIA-22 at 10) and the Commission just reaffirmed that framework in the RCP Docket No. 23-0273.
4.  A six-month implementation buffer must precede elimination of NEM or adoption of new tariffs,
5. Direct SSVEC to perform the required annual update consistent with the Plan of Administration and demonstrate that export compensation is not less than avoided cost.
6. Require SSVEC to credit customers for the year in which they were paid below avoided cost for their exported solar (2023).
7. Reject imposition of interconnection fees that were not supported by record evidence, were first provided after the hearing, and were never subject to cross examination. (Joint Opening Brief at 12–13).

AriSEIA filed a reply brief with the Arizona Court of Appeals today in the ongoing appeal from Arizona Public Service's last rate case, in which they imposed a discriminatory fee on rooftop solar customers. This is expected to be the last round of briefing and oral argument should be held in early 2026.

UNSE has been operating Black Mountain Generating Station illegally for almost two decades. It never obtained a Certificate of Environmental Compatibility or a disclaimer of jurisdiction, despite the plant exceeding 100 MW. They now argue the Arizona Corporation Commission should let them continue to violate the law as long as they pursue baseless appeals.

AriSEIA filed a complaint against UNSE after its disclaimer of jurisdiction for the Black Mountain Expansion Project was denied by the Arizona Power Plant and Line Siting Committee in 2024. However, because the ACC overrode that decision and then it was appealed, the complaint has been on hold. Today the Superior Court ruled against UNSE. It must obtain a Certificate of Environmental Compatibility (CEC) for the expansion and because it never obtained a CEC for the underlying plant, it has been violating the law daily since at least 2008.

AriSEIA filed its brief today in opposition to the settlement agreement between Arizona Corporation Commission (ACC) Staff and Sulphur Springs (SSVEC), which eliminates net metering for commercial and industrial solar customers, eliminates grandfathering for solar customers, violates federal law by allowing the export rate to drop below avoided cost, eliminates the 10-year export rate clock for residential solar customers, and imposes punitive interconnection fees on solar customers. 

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
RE: RLS-00000A-23-0251; Line Siting Rules
 
Chairman and Commissioners,
 
AriSEIA files these comments in response to the Memo filed to this docket by Hearing Division on August 20, 2025.[1] As a macro issue, AriSEIA is not aware of any statutory or administrative code basis for “recertification.” Projects should not be “recertified” for decades, especially with no formal process for doing so. This issue must be taken up in this rulemaking. All projects granted a CEC should be done so on a limited basis in which to actually build the project. The factors under ARS 40-360.06 will change over time. None of these factors are static. The total environment of the area, noise levels, wildlife habitat, etc. could all very likely be different decades later than they were when the CEC was granted. If a project is not built in a timely manner, those issues should be reevaluated by the Committee before any extensions are granted. That time limit should be included in this rules update.
 
R14-3-201
The definitions of party and potential party should be modified. If someone has filed a timely notice to intervene, they should have the rights of a party until their intervention is denied with good cause. The definition of “legal representative” is also confusing as a representative under Rule 31.3(c)(5) is not necessarily a “legal” representative and is simply a representative. All defined terms should be capitalized through the rules.
 
R14-3-204
More than 24 hours’ notice should be provided of Line Siting Committee meetings. The Committee should strive for the utmost notice, but not less than 3 business days.
 
R14-3-207
There is no mention of a disclaimer of jurisdiction in Article 6.2 of Title 40 (the Line Siting statutes). Where does the authority to disclaim jurisdiction derive? If there is no statutory basis for it, it should not be in the Code. Further, the burden should not be on an intervenor to provide an affidavit as to the facts supporting the objection. It is an unfortunate reality that utilities (and other applicants) have an information asymmetry over other intervenors, including the public and nonprofit organizations. Additionally, ARS 40-360.05 grants intervention as a matter of right to the applicant, local governments, and domestic nonprofits. The Commission cannot circumvent statute via its own rules. The second sentence of (D) and all of (E) should be eliminated. Further, this section does not afford enough due process by which to grant a disclaimer. Objecting parties should be able to issue data requests to the would be applicant, question its witnesses, and offer testimony and other exhibits in opposition. Disclaimer should only be granted via hearing when there are objecting parties, contrary to (F)-(H).
 
R14-3-210
Under A(5), it is not clear what documentation one would need to demonstrate compliance with Rule 38, as you would have a bar number with the Arizona State Bar. That bar number should be sufficient and you should not need to provide additional documentation like you would under Rule 39. It is also unclear why Rule 42 is mentioned here.
 
The timeline for intervention under (E) should not be different than the timeline for intervenors under (A). It should just be 10 days for everyone. Also, the procedural order that sets the hearing should state the intervention deadline.
 
Under (F), the Committee should still be required to provide due process, which should require an explanation as to why intervention was denied and a means to either appeal or be heard. As written, the rules specifically discriminate against national or regional nonprofit organizations.
 
It is unclear how (G) is supposed to work. Do the rules permit adding parties after a hearing? Or the Committee is making legal determinations before a hearing? Everyone should have the same deadline to be a party and such determinations should be made only after the hearing. There should not be multiple rounds of hearings because local jurisdictions did not become a party at the appropriate time. This will just cause delay of what is already a lengthy process. If a city or county is impacted, they should get notice at the outset by the applicant and should apply for intervention 10 days before the hearing. The applicant should be required to notify all jurisdictions within a specified radius of any aspect of the project in advance of the hearing so they can participate from the outset.
 
It is unclear why (H) is there when there is a separate section on disclaimers.
 
R14-3-211
In (A), it is unclear to us who may be subpoenaed by the Commission. Is it all parties or only the applicant? In (B), why would anyone who is not a party be able to issue subpoenas and to whom? In (H), do the objections need to be in writing? (K)(2)(c) may be unreasonable. Requiring someone in Navajo or Mohave Counties, for example, to travel to Phoenix or Tucson for a deposition is unduly burdensome.
 
R14-3-213
All transcripts should be made publicly available on the applicant’s webpage and electronically via the Commission’s website.
 
R14-3-215
All Line Siting hearings should be recorded like other Commission proceedings and the recordings should be made available on the Commission’s website. Parties and public comment should be able to appear in person or remotely, at their discretion, and those arrangements should be made by the Commission or applicant. Regarding (F), the procedural order should also include any deadlines such as this or others. Exhibits should not need to be printed. All documents should be able to be filed and exchanged electronically. The Commission should also codify a discovery process for Line Siting cases here.
 
R14-3-216
In (B), is there any requirement that both the chair and the hearing officer will be an attorney and have the relevant energy experience? (C) should specify when public comment will be taken, otherwise it is hard for the public to know when they need to attend or how long they will need to be present, which will drive down participation. We recommend holding it the first day of the hearing. In (D)(4), the witnesses should not appear as a panel. The Commission does not do that in rate cases and should not do that in Line Siting cases. It reduces accountability. (D)(6) is ambiguous. What is “material, relevant, nonrepetitive evidence”? If a party moves to admit an exhibit and an objection is not offered and sustained, the exhibit must be admitted. (F) should be revised as it is not clear that this includes representatives under the Rules of the Arizona Supreme Court 31.3(c)(5) and (6)).  
 
R14-3-218
Only parties should be able to request a continuance, not “potential parties.” The definitions should be modified, as suggested above. Similarly, only parties and the Committee should be permitted to take the tour.
 
R14-3-219
(D) grants too much discretion to the presiding officer to exclude evidence. As mentioned before, if it is offered and no objection is sustained, it should be admitted. In (F), once an objection is ruled upon, the party should not be able to continue to raise it seeking a different result. Similarly, the Presiding Officer should not be able to waffle on an objection already ruled upon. Parties need to be able to rely on decisions made in the docket or in the hearing.
 
R14-3-220
Transcripts should be made available, free of charge to the parties and the public in every Commission proceeding. The Commission should continue to make them available in Line Siting matters as they have done for years. (B) should state the “Presiding Office shall require” instead of “may.” Transcripts should be covered by the applicant in Line Siting and rate cases. If someone wants printed pages of a transcript in person the page number needs to be dramatically increased.
 
R14-3-222
Does this mean that CECs will not be reviewed and voted on by the Commission unless requested by a party?
 
R14-3-226
The Committee should also require the applicant to provide water impacts as water is part of the “total environment.”
 
Thank you for consideration of these comments.
 
Respectfully,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]
 
[1] Hearing Division Memo, August 20, 2025, Docket No. RLS-00000A-23-0251, available here https://docket.images.azcc.gov/0000215068.pdf?i=1760395720620. 

Maricopa County
Planning and Development Department
301 W. Jefferson Street, Suite 170
Phoenix, AZ 85003
 
RE: MZCO Update Draft #1 comments as to renewable energy and battery storage
 
Dear Supervisors, Commissioners, and Staff,
 
The Arizona Solar Energy Industries Association (AriSEIA) is the State’s solar, storage, and electrification trade association. We are active on energy policy issues at every level of government in Arizona. We have previously engaged on the City of Eloy, Mohave County, City of Mesa, City of Buckeye, Town of Chino Valley, Navajo County, Apache County, Town of Gila Bend, City of Surprise, and Yavapai County solar/storage ordinances. While we made comments into the online draft document, please find our consolidated comments on the draft below:
 
Article 305.4.2 – Plan of Development (Site Plan) Expiration
The current two-year expiration period, with only a single one-year extension, is insufficient for solar projects, which often experience extended development timelines due to utility coordination and other regulatory processes. The expiration period should be lengthened—or eliminated entirely—for solar projects, and applicants should be permitted to obtain an unlimited number of extensions as needed.
 
Article 506 – Landscaping and Buffering
The landscaping and buffering requirements for industrial districts are not appropriate for solar projects and impose unnecessary costs given the large land area such projects typically cover. Solar projects should be exempt from these industrial landscaping and buffering standards.
If a full exemption is not adopted, there should at least be a mechanism allowing staff to administratively approve alternative approaches for remote projects, similar to the process proposed by the City of Buckeye. Additionally, any irrigation requirements would undermine one of the key environmental benefits of solar facilities—their inherently low water use.
 
Article 601 – Setbacks
Tying the ordinance to the most recent versions of UL 9540 and National Fire Protection Agency (NFPA) 855 is recommended. The American Planning Association found the national setback average for BESS-specific setbacks was 50-150 feet from property lines.[1] While the NFPA recommends 100’, we recommend no more than 150’ from the structures (not the property line) based on the Phoenix Regional Standard Operating Procedures Battery Energy Storage Systems policy.[2] Also, the setbacks should be measured from the BESS equipment, not the BESS property line. This would align Maricopa County’s ordinance with national standards, improve regulatory defensibility, and ensure that safety requirements scale appropriately with actual risk rather than imposing arbitrary limits that could either under- or over-regulate BESS facilities.
 
Additionally, modern BESS projects are subject to new and updated safety standards and codes that have addressed and corrected issues found in earlier system design.  The American Clean Power Association (ACP) provides a helpful FAQ that covers questions about battery safety and air emissions.[3] ACP also has a Claims v. Facts one-pager on battery safety, included again as Attachment A. “It should also be noted that the average emissions rates of equivalent masses of plastics exceed those of batteries.”[4] Additionally, sampling was done by the Environmental Health Division and the U.S. Environmental Protection Agency (EPA) after the Moss Landing incident and “no threat to human health or the surrounding environment” was found.[5] All electricity generation and energy storage creates some amount of risk. However, battery incidents represent only 2% of battery installations.[6] Setbacks for batteries should not be more onerous than setbacks for other energy infrastructure, such as substations. ACP’s model BESS ordinance is included as Attachment B.
 
Applicability
Your current battery energy storage system (BESS) definition does not exempt distributed projects. If the ordinance is intended to only apply to utility scale projects, we suggest you make that explicit. A sample definition is below:
 
Battery Energy Storage System (BESS):
A facility that stores electrical energy in battery cells or modules for later use in providing electricity to the grid or enhancing the reliability and efficiency of the electric system. A BESS includes all associated structures, equipment, and controls necessary for safe and effective operation.
 
For purposes of this ordinance, a BESS shall be considered utility-scale when designed for wholesale energy market participation or grid services and when not primarily intended to serve on-site end-use load. Residential, commercial, and industrial systems installed behind the customer meter or serving on-site consumption shall be considered distributed generation and are exempt from this definition.
Similarly, you have three different definitions of solar. These should also be revised and the ordinance should make it clear that the ordinance is intended to only apply to utility scale projects. A sample definition is below:
 
Solar Energy Facility (Utility-Scale):
A facility that converts sunlight into electrical energy using photovoltaic or concentrated solar technologies and delivers that energy to the electric transmission or distribution grid for wholesale market participation or sale to a utility. A solar energy facility includes all associated equipment, such as panels, inverters, racking systems, transformers, access roads, and maintenance buildings.
 
This definition applies only to utility-scale solar installations. It excludes solar energy systems installed for on-site use or self-consumption, such as residential, commercial, or industrial distributed generation located behind the meter or designed to offset the energy use of the property on which it is installed.
 
Waiver Provision
The ordinance should include a waiver provision in the event a project proposal conflicts with some component of the ordinance, but is otherwise an ideal site. The City of Eloy Solar and BESS Ordinance includes such a provision.[7] We recommend adding language such as that included in 21-3-1.39(B) of Eloy’s ordinance. A waiver provision gives the city the flexibility when special circumstances and safety demand.

Other
​As discussed above, the NFPA 855 provides recognized industry best practices for BESS. Incorporating NFPA 855 by reference into this ordinance will provide Maricopa County with clear, nationally recognized metrics on maximum system capacity, hazard mitigation, emergency response, and decommissioning. 
 
Thank you for your time and consideration and we look forward to continuing to engage with the
County on this ordinance as the stakeholder process progresses.
 
Respectfully,
Autumn Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] American Planning Association, Zoning Practice, P.10 (Mar. 2024), available here https://planning-org-uploaded-
media.s3.amazonaws.com/publication/download_pdf/Zoning-Practice-2024-03.pdf

[2] City of Phoenix, Battery Energy Storage Systems, April 2023, available here https://www.phoenix.gov/firesite/Documents/205.20A%20Battery%20Energy%20Storage%20Systems.pdf.

[3] American Clean Power Association, Energy Storage: Safety FAQ, available here https://cleanpower.org/wp-content/uploads/gateway/2023/07/ACP-ES-Product-4-BESS-Safety-FAQs-230724.pdf.

[4] Consolidated Edison and NYSERDA, Considerations for ESS Fire Safety, Feb. 9, 2017, at iii, available here https://www.nyserda.ny.gov/-/media/Project/Nyserda/files/Publications/Research/Energy-Storage/20170118-ConEd-NYSERDA-Battery-Testing-Report.pdf.

[5] County of Monterey, Air Quality Testing Information and Process During Moss Landing Fire Incident, Sept. 30, 2022, available here https://www.countyofmonterey.gov/Home/Components/News/News/9345/1336.

[6] California Public Utility Commission, Energy Storage Procurement Study: Safety Best Practices, 2023, available here https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/energy-storage/2023-05-31_lumen_energy-storage-procurement-study-report-attf.pdf.

[7] Eloy Ordinance, 21-3-1.39, available here https://codelibrary.amlegal.com/codes/eloyaz/latest/eloy_az/0-0-0-9381.

City of Mesa
Development Services
55 N. Center Street
Mesa, AZ 85201
 
RE: City of Mesa Draft BESS Ordinance (Section 11-31-37)
 
Council Members, Planning and Zoning Board Members, and Staff,
 
The Arizona Solar Energy Industries Association (AriSEIA) is the State’s solar, storage, and electrification trade association. We are active on energy policy issues at every level of government in Arizona. We have previously engaged on the City of Eloy, Mohave County, City of Buckeye, Town of Chino Valley, Navajo County, Apache County, Town of Gila Bend, City of Surprise, and Yavapai County solar/storage ordinances.
 
Applicability
AriSEIA recommend that Mesa look at the pending Buckeye BESS ordinance as an example. We further recommend significant changes to B(1)(a) and B(2)(b). As written, this ordinance will potentially apply to many commercial and industrial distributed generation projects. 1 MW is much too small, if the ordinance is meant to only apply to utility scale projects. We recommend you not have any size threshold and instead just state that the ordinance applies only to utility-scale BESS projects, such as is seen in Buckeye’s ordinance (Section 3.2.2(1)): “The requirements of this Section shall apply to all utility-scale BESS facilities permitted, installed, or modified after the effective date, excluding general maintenance and repair. Utility-scale BESS facilities constructed or installed prior to the effective date are not required to meet the requirements of this Chapter.” Alternatively, you could state that the ordinance does not apply to distributed generation projects with on-site battery energy storage. If the City feels it is imperative to include a size threshold, we recommend only doing it in B(1) and not B(2). And it should be 5 MW, not 1 MW.
 
Further, the limitation in B(2)(b)(ii) is problematic because it would preclude commercial and industrial customers from participating in any forthcoming virtual power plant programs offered by the utilities to their business customers. Instead of “exclusively,” it should say “primarily.”
 
Additionally, restrictions in B(1)(a) and C(1) to general and heavy industrial are too limited and may actually create a de facto moratorium on BESS within the City of Mesa. Engineers from Arizona utilities, including Salt River Project (SRP), have publicly spoken about the importance BESS technologies play in ensuring continued electrical service in the Valley amid growing demand. SRP expects electricity demands will grow 6% per year for the next decade, compared against the 2% yearly growth seen from 2015-2025.[1] To keep pace with this demand, SRP will have to double—and possibly triple—its capacity. Given those electricity demand needs, it is absolutely critical to leverage a variety of technologies, including BESS. We recommend all industrial, including light industrial, be eligible for BESS.
 
Setbacks
Tying the ordinance to the most recent versions of UL 9540 and National Fire Protection Agency (NFPA) 855 is recommended. Currently, Mesa has a drafted setback of 400 feet in Section F(2)(a).[2] The American Planning Association found the national setback average for BESS-specific setbacks was 50-150 feet from property lines.[3] While the NFPA recommends 100’, we recommend no more than 150’ from the structures (not the property line) based on the Phoenix Regional Standard Operating Procedures Battery Energy Storage Systems policy.[4] Also, the setbacks should be measured from the BESS equipment, not the BESS property line. This would align Mesa’s ordinance with national standards, improve regulatory defensibility, and ensure that safety requirements scale appropriately with actual risk rather than imposing arbitrary limits that could either under- or over-regulate BESS facilities.
 
Additionally, modern BESS projects are subject to new and updated safety standards and codes that have addressed and corrected issues found in earlier system design.  The American Clean Power Association (ACP) provides a helpful FAQ that covers questions about battery safety and air emissions.[5] ACP also has a Claims v. Facts one-pager on battery safety, included again as Attachment A. “It should also be noted that the average emissions rates of equivalent masses of plastics exceed those of batteries.”[6] Additionally, sampling was done by the Environmental Health Division and the U.S. Environmental Protection Agency (EPA) after the Moss Landing incident and “no threat to human health or the surrounding environment” was found.[7] All electricity generation and energy storage creates some amount of risk. However, battery incidents represent only 2% of battery installations.[8] Setbacks for batteries should not be more onerous than setbacks for other energy infrastructure, such as substations. ACP’s model BESS ordinance is included as Attachment B.
 
Noise
Sound restrictions for BESS should not be different than those for other land uses. E(4) requires an initial sound study before the project is developed and G requires a mitigation plan should the noise level exceed the level when there was no development. Alternatively, at the applicant’s election, we recommend capping the decibel level of the project from the nearest residence. In a residence you would have normal conversation at 60 dB, a vacuum at 70-85 dB, an AC unit or TV at 70 dB. AriSEIA recommends the City not require a noise level less than 65 dB from the nearest residence if the ambient noise is below that.
 
BESS Spacing
Any BESS spacing in F(3) should only be 3 ft. The NFPA 855 sets its threshold at 3 feet between individual BESS units. NFPA 855 allows for adjustment upward or downward based on site-specific hazard data, including through written agreements with adjacent property owners, provided that such agreements are reviewed and accepted by the City and supported by the site’s hazard mitigation analysis (HMA). This mechanism allows jurisdictions to maintain safety standards while accommodating site-specific conditions and product design innovations.
 
Mesa’s suggestion to increase cabinet spacing over and above the requirements of the fire code are not without consequences. Projects that require more internal spacing will require more land for development. Consequently, these projects will become bigger in area and be costlier to develop. This will come back to Mesa citizens in the rates they pay for electricity.  
 
(F)(4) requires that all fire access drives and drive aisles within the BESS facility be paved and (F)(6) requires full site screening with opaque walls or fences extending one foot or greater from the top of the equipment. By exceeding NFPA’s safety recommendations, these proposed requirements impose significant costs and potentially jeopardize project feasibility without a commensurate increase in safety. Instead, the ordinance should align these standards with NFPA 855 and (1) allow drive aisles to be made of aggregate all-weather surfacing and (2) only require partitions to be one foot higher than BESS units.
 
Undergrounding
In F(8), the City appears to require undergrounding of distribution and transmission lines. AriSEIA recommends that whether lines are undergrounded or not be left to the BESS Facility, the utility, and the Arizona Corporation Commission’s (ACC) Power Plant and Line Siting Committee (if applicable), as the ACC has a policy on undergrounding that disfavors it, as it can be excessively costly.[9]
 
Waiver Provision
The ordinance should include a waiver provision in the event a project proposal conflicts with some component of the ordinance, but is otherwise an ideal site. The City of Eloy Solar and BESS Ordinance includes such a provision.[10] We recommend adding language such as that included in 21-3-1.39(B) of Eloy’s ordinance. A waiver provision gives the city the flexibility when special circumstances and safety demand.
  
Other
 
Additionally, there is an error in the nameplate capacity definition. We recommend an updated definition such as, “NAMEPLATE CAPACITY: The maximum rated power output that a battery energy storage system (BESS) or facility can discharge or receive under specific conditions designated by the manufacturer. It is also referred to as rated capacity or peak capacity, and is expressed in megawatts (MW) or kilowatts (kW) for power. The associated energy capacity, sometimes referred to as nameplate energy capacity, represents the total amount of energy the system can store or deliver over time, expressed in megawatt-hours (MWh) or kilowatt-hours (kWh).”
 
As discussed above, the NFPA 855 provides recognized industry best practices for BESS. Incorporating NFPA 855 by reference into this ordinance will provide Mesa with clear, nationally recognized metrics on maximum system capacity, hazard mitigation, emergency response, and decommissioning.
NFPA 855 requires the following submittals and by incorporating NFPA 855, Mesa will be requiring each of these:

• Hazard Mitigation Analysis (HMA);
• Emergency Response Plan;
• Details of all safety systems, including;
  • UL 1973 – for battery modules and components;
  • UL 9540 – for integrated BESS systems;
  • UL 9540A – for fire propagation testing to evaluate thermal runaway risk; and
    • Results of UL 9540A or equivalent testing

Thank you for your time and consideration and we look forward to continuing to engage with the
City on this ordinance as the stakeholder process progresses.
 
Respectfully,
Autumn Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] Pinal County, Board of Supervisors meeting, Sept. 10, 2025, available here https://pinalcountyaz.new.swagit.com/videos/355087?ts=230.

[2] This setback is in addition to further setbacks between the BESS installation and its own project boundary.

[3] American Planning Association, Zoning Practice, P.10 (Mar. 2024), available here https://planning-org-uploaded-
media.s3.amazonaws.com/publication/download_pdf/Zoning-Practice-2024-03.pdf

[4] City of Phoenix, Battery Energy Storage Systems, April 2023, available here https://www.phoenix.gov/firesite/Documents/205.20A%20Battery%20Energy%20Storage%20Systems.pdf.

[5] American Clean Power Association, Energy Storage: Safety FAQ, available here https://cleanpower.org/wp-content/uploads/gateway/2023/07/ACP-ES-Product-4-BESS-Safety-FAQs-230724.pdf.

[6] Consolidated Edison and NYSERDA, Considerations for ESS Fire Safety, Feb. 9, 2017, at iii, available here https://www.nyserda.ny.gov/-/media/Project/Nyserda/files/Publications/Research/Energy-Storage/20170118-ConEd-NYSERDA-Battery-Testing-Report.pdf.

[7] County of Monterey, Air Quality Testing Information and Process During Moss Landing Fire Incident, Sept. 30, 2022, available here https://www.countyofmonterey.gov/Home/Components/News/News/9345/1336.

[8] California Public Utility Commission, Energy Storage Procurement Study: Safety Best Practices, 2023, available here https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/energy-storage/2023-05-31_lumen_energy-storage-procurement-study-report-attf.pdf.

[9] Arizona Corporation Commission, Decision No. 79140, P.3, L.2-6, Oct. 4, 2023, available here https://docket.images.azcc.gov/0000209995.pdf?i=1760388397879.

[10] Eloy Ordinance, 21-3-1.39, available here https://codelibrary.amlegal.com/codes/eloyaz/latest/eloy_az/0-0-0-9381.