AriSEIA Files its Final Brief in the APS Rate Case

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The Arizona Solar Energy Industries Association (AriSEIA) filed its Responsive Brief in Arizona Public Service Company's (APS) pending rate case, urging the Arizona Corporation Commission to eliminate the Grid Access Charge (GAC) and Legacy Solar Rate Increase (LSRI). AriSEIA argues that APS still has not identified costs uniquely caused by residential solar customers that would justify imposing additional charges on them. APS's own witness acknowledged that the Company did not attempt to identify specific costs attributable to residential distributed generation customers, while Commission Staff described the GAC as a mechanism intended to recover lost fixed-cost revenues. AriSEIA argues that lost revenue is not a cost caused by solar customers and cannot provide the cost-causation basis necessary to support a solar-specific charge. AriSEIA therefore asks the Commission to resolve the issue in this rate case and eliminate both charges rather than defer the question to another proceeding.

AriSEIA also continues to oppose proposals that would undermine customer investment in distributed energy resources. The brief asks the Commission to reject Kroger's proposed changes to APS's E-32 M and E-32 L commercial rates, which would shift additional revenue recovery from volumetric energy charges to demand charges. AriSEIA argues that such a change would reduce customers' ability to lower their bills through energy efficiency, solar, and storage while working against distributed energy programs the Commission is considering in the same case. AriSEIA also urges the Commission to retain and redesign the E-32 L Storage Pilot rather than eliminate it simply because it has attracted no participants. Zero participation demonstrates that the existing tariff has not worked, not that a properly designed commercial storage tariff cannot work.
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Finally, AriSEIA asks the Commission to improve APS's virtual power plant programs by expanding Storage Rewards to non-residential customers and allowing third-party-owned systems to participate. AriSEIA argues that APS's delay in launching the program should not become a reason to postpone improvements that could expand participation and increase the value distributed batteries provide to the grid. The brief also opposes the Arizona Free Enterprise Club's proposed disallowance related to the Agave Battery Energy Storage System, noting that Agave was selected through a competitive all-source request for proposals overseen by an independent monitor and that no evidence identified an actual competing project capable of meeting similar needs at a lower cost. Together, AriSEIA's recommendations seek a rate design that fairly reflects the costs customers actually impose on the APS system while expanding opportunities for solar, storage, and other distributed energy resources.