AriSEIA Files Comments to Save AZ Goes Solar Website

Read the Filing

​Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
RE: Comments on APS 2026 RES Implementation Plan, Docket No. E-01345A-25-0140
 
Chairman and Commissioners,
 
The Arizona Solar Energy Industries Association (AriSEIA) submits these comments in response to the Utilities Division Staff Memorandum and Proposed Order concerning Arizona Public Service Company’s (APS) 2026 Renewable Energy Standard Implementation Plan.
 
These comments address two discrete issues: (1) Staff’s recommendation to deny continued funding for the Arizona Goes Solar website, and (2) the proposed waiver allowing Renewable Energy Standard compliance without the use and retirement of Renewable Energy Credits (RECs).
 
I.                    Objection to Elimination of Arizona Goes Solar Website Funding
 
Staff recommends denial of $360 in annual funding for the Arizona Goes Solar website without articulating any factual or policy basis for doing so. This recommendation is not supported by the record and fails to account for the website’s unique and critical role in Arizona’s energy regulatory ecosystem.
 
The Arizona Goes Solar website is not a discretionary marketing tool. It is a statewide consumer protection, transparency, and grid-awareness resource. It is the only centralized, publicly accessible platform in Arizona that provides neutral information on solar adoption, interconnection, incentives, utility-specific program requirements, and Renewable Energy Standard compliance across every major electric utility operating in the state. No other Commission-sponsored or utility-sponsored resource performs this function.
 
The website serves multiple core public-interest purposes. It provides consumers with clear, comparable information needed to make informed decisions, reduces confusion that can lead to fraud or misinformation, supports proper interconnection by directing customers to accurate utility requirements, and improves grid reliability by promoting informed deployment of distributed energy resources. In practice, the website reduces downstream disputes, complaints, and administrative burdens by improving clarity at the front end.
 
The annual cost of maintaining this resource is $360. This amount is de minimis relative to the overall Renewable Energy Standard budget and has no meaningful rate impact. Eliminating funding would not advance affordability or efficiency. It would instead eliminate the only neutral, statewide informational resource of its kind in Arizona, directly weakening consumer protection and transparency for no discernible benefit.
 
Importantly, elimination of this funding is inconsistent with the Commission’s stated priorities. Chairman Myers has publicly stated that his number one commitment as Chairman is transparency, noting that “transparency is not just about access; it’s about clarity.” The Arizona Goes Solar website embodies that principle. It provides clarity, not merely access, by consolidating complex, utility-specific information into a single, understandable public resource. Defunding the website would move the Commission in the opposite direction.
 
Absent a specific finding that the website is duplicative, inaccurate, unnecessary, or inconsistent with Commission policy, denial of continued funding is arbitrary and unsupported. The Commission has long recognized the value of low-cost educational and transparency tools that support informed participation in Arizona’s energy markets. Continued funding for the Arizona Goes Solar website is squarely aligned with that history and with the Commission’s stated commitment to transparency.
 
For these reasons, the Commission should reject Staff’s recommendation and approve continued funding for the Arizona Goes Solar website.
 
II.                 Objection to Waiver of REC Use and Retirement
 
AriSEIA also objects to APS’ request for a waiver of Arizona Administrative Code R14-2-1804(A), which would allow Renewable Energy Standard compliance without the use and retirement of RECs.
 
Nationwide, a REC represents the environmental attributes of one megawatt-hour of electricity generated from a qualifying renewable resource.[1] In every established Renewable Portfolio Standard or Renewable Energy Standard program in the United States, the core compliance mechanism is the demonstration that qualifying RECs have been both owned and retired on behalf of customers. Retirement is the act that permanently removes a REC from the market and prevents it from being claimed more than once.
 
This structure is not unique to Arizona. It is the uniform accounting framework used by state regulators, utilities, system operators, and voluntary and compliance markets across the country. The use and retirement of RECs is what ensures environmental integrity, prevents double counting, and preserves the credibility of renewable energy claims. Without retirement, there is no verifiable proof that renewable attributes have been exclusively applied to compliance rather than sold, transferred, or claimed elsewhere. Arizona Administrative Code R14-2-1804(A) reflects this national norm. It is not a procedural preference. It is the substantive mechanism by which Renewable Energy Standard compliance is verified.
 
The waiver requested in this docket would fundamentally depart from this established framework by allowing compliance to be demonstrated without the retirement of RECs. Approval would represent a significant deviation from nationally accepted REC accounting practices and would introduce uncertainty into Arizona’s REC market regarding ownership, exclusivity, and environmental claims.
 
Such a deviation would have consequences extending well beyond this filing. It would affect market confidence, undermine the validity of REC transactions, and create ambiguity for third parties that rely on Arizona RECs for compliance, voluntary procurement, financing, and contractual claims. These impacts would not be limited to APS or the 2026 plan year.
 
Fundamental changes to REC mechanics should not be decided through a single utility’s Renewable Energy Standard Implementation Plan proceeding. The appropriate venue for reconsideration of REC use, retirement, and compliance accounting is a dedicated rulemaking or policy docket with full stakeholder participation and a comprehensive evaluation of market, regulatory, and legal impacts. Determining the basic mechanics of REC compliance in this docket risks unintended and irreversible consequences that extend beyond the scope of the 2026 plan and beyond APS.
 
For these reasons, the Commission should deny the requested waiver and maintain the existing requirement that Renewable Energy Standard compliance be demonstrated through the use and retirement of RECs, unless and until the Commission considers changes through a broader, deliberate, and transparent policy process.
 
III.              Conclusion
 
For the reasons stated above, AriSEIA respectfully requests that the Commission reject Staff’s recommendation to eliminate funding for the Arizona Goes Solar website and deny APS’ requested waiver of REC use and retirement requirements in this docket. Two amendments are attached for your convenience.
 
Respectfully,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] US Environmental Protection Agency, Renewable Energy Certificates, available here https://www.epa.gov/green-power-markets/renewable-energy-certificates-recs?utm_source=chatgpt.com.