AriSEIA Files Direct Testimony in the APS Rate Case

READ THE TESTIMONY

AriSEIA filed direct testimony in the Arizona Public Service rate case. We make the following recommendations:

​Site Load COSS

• Discontinue the use of the Site Load COSS and instead direct APS to use a Delivered Load COSS going forward.
• In the alternative, direct APS to make the following modifications to the Site Load COSS
  • Use AriSEIA’s recommended methodology to determine demand reductions associated with Residential DG solar.
  • Use the same transmission cost allocation in the Solar Credit as APS does in its FERC tariff filings.
  • Do not “charge” solar customers for revenue shortfalls associated with transmission rates or EPR-6 or RCP purchases.
  • Utilize a marginal avoided energy cost rate instead of the average fuel and purchased price rate to value energy generation.
• Recognizing that the cost shift in the Site Load COSS disappears after fixing the methodological errors above, cancel the GAC and LSRI and direct APS to recalculate its rates without these adjustments.

DG Study

• Find that the Company did not follow the Commission’s directive to provide sufficient information in its application for intervenors to “scrutinize” the DG Study.
• Reject the results of the DG Study based on the myriad methodological flaws identified in my testimony.
• Do not direct the Company to perform the DG Study going forward.

SP Tariff

• Shorten the on peak window from 4 PM to 9 PM to 5 PM to 8 PM.
• Expand the SP Tariff to the E32-S and E-32M rates.
• Adjust variable cost recovery to 80% energy / 20% demand.
• Adopt AriSEIA’s “3:2:1’ variable energy rate design.
• Update its marketing materials to highlight the availability and benefits of this rate.

VPPs

• Expand the VPP program to non-residential customers.
• Update its marketing materials to highlight the availability and benefits of this rate.