AriSEIA Files Amendments in the SSVEC Rate Case

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AriSEIA submitted Exceptions to the Recommended Opinion and Order (ROO) to address several findings and conclusions that are not supported by the evidentiary record, are inconsistent with Commission practice, or undermine regulatory certainty. The ROO adopts Sulphur Springs Valley Electric Cooperative, Inc.’s (SSVEC’s) cost-of-service study despite its omission of recognized distributed generation benefits, eliminates commercial net metering without a fair transition period, removes the ten-year export rate lock even though the Commission recently confirmed that it should remain unchanged, and concludes that SSVEC did not underpay distributed generation members in 2023 despite the Cooperative paying below avoided cost and failing to update its export rate as required. It further approves interconnection fees that are unsupported by the record, declines to direct SSVEC to evaluate virtual power plant and critical peak pricing programs despite consistent support for such programs across multiple Arizona utilities, and dismisses the legitimate transparency concerns raised by the settlement process.

For these reasons, and for those set forth in detail in the filing, AriSEIA respectfully requested that the Commission modify the ROO. AriSEIA submitted proposed amendments addressing the phase-in period for commercial net metering, the ten-year export rate lock, reimbursement of the 2023 underpayment, the interconnection fee provisions, and the virtual power plant and critical peak pricing directive.