AriSEIA Files Comments in Support of APS VPP Funding

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Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: AriSEIA Support for the 2024 Arizona Public Service Company Demand Side Management Implementation Plan, Docket No. E-01345A-23-0088
 
Chairman and Commissioners,
 
The Arizona Solar Energy Industries Association (AriSEIA) respectfully urges the Arizona Corporation Commission (Commission) to approve the Arizona Public Service Company (“APS”) Second Amended 2024 Demand Side Management (DSM) Implementation Plan as filed, along with the Utilities Division Staff Recommended Opinion and Order.
 
AriSEIA supports approval of the APS Second Amended 2024 DSM Implementation Plan[1] because the record demonstrates that the proposed measures comply with the Arizona Administrative Code requirements for cost-effective DSM programs and because the Utilities Division Staff Recommended Opinion and Order concludes that the updated portfolio meets applicable evaluation criteria.[2] AriSEIA’s interest is ensuring a stable, predictable regulatory landscape for distributed energy resources and demand-side programs. Approval of the plan, along with the Staff recommendation, provides needed clarity for market participants, customers, and project developers.
 
AriSEIA also strongly urges the Commission to preserve the Bring Your Own Device (BYOD) Virtual Power Plant Battery Pilot Program even if other changes to the DSM portfolio are considered. The BYOD program has been approved twice by vote of the Commission and resulted from a fully litigated rate case. It is a pay-for-performance-only program designed to compensate customers strictly for verified grid services. The Commission approved BYOD for a five-year term, and the program has not yet operated through even a single summer season. Premature modification or suspension would undermine the purpose of the pilot, create regulatory uncertainty, and diminish the value of distributed demand response resources that the Commission has repeatedly endorsed.
 
The BYOD pilot is also an essential contributor to APS’s projected portfolio-wide capacity savings. APS estimates that BYOD could enroll up to five thousand customers and contribute approximately 17 MW of dispatchable capacity during the pilot period.[3] These distributed, flexible resources play a significant role in meeting peak demand, reducing system costs, and increasing grid resilience for all APS customers.
 
For these reasons, AriSEIA supports approval of the Second Amended 2024 DSM Implementation Plan and the Utilities Division Staff Recommended Opinion and Order. If the Commission elects to modify the plan, AriSEIA respectfully asks that the Commission preserve the BYOD pilot in its entirety, including all funding allocated to the program in this plan, consistent with the Commission’s prior decisions and the purpose of the pilot itself.
 
Thank you for your consideration.
 
Respectfully,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] Application of Arizona Public Service Company for Approval of Its Second Amended 2024 Demand Side Management Implementation Plan, Docket No. E-01345A-23-0088 (filed June 20, 2025).

[2] Utilities Division Staff, Recommended Opinion and Order, Docket No. E-01345A-23-0088 (Nov. 19, 2025).

[3] Application of Arizona Public Service Company for Approval of Its Second Amended 2024 Demand Side Management Implementation Plan, Docket No. E-01345A-23-0088 (filed June 20, 2025) at page 3.