AriSEIA Files Letter on TEP VPP Stakeholder Process

Read the Filing

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: TEP Rate Case, Customer Storage Program Stakeholder Meeting, Docket No. E-01933A-22-0107
 
Chairman and Commissioners,
 
AriSEIA submits these comments in response to the compliance filing that TEP filed on December 7, 2023, in response to the stakeholder process they were ordered to commence regarding a Bring Your Own Device (BYOD) program (also known as Virtual Power Plant (VPP)) and revisions to the R-TECH and LGST-SP tariffs.[1] These stakeholder processes are the result of Order 79065.[2]
 
Because some of the utilities have recently been using their compliance filings as evidence in other proceedings and have also asserted that stakeholder silence is agreement, AriSEIA makes this filing to detail our numerous concerns about how TEP has so far engaged on BYOD, R-TECH, and LGST-SP. AriSEIA put forth a robust proposal to implement a BYOD program, as well as specific modifications to the R-TECH and LGST-SP in the course of the last rate case. Those proposals are the reason this stakeholder process was ordered. Further, TEP stated multiple times in the course of the last rate case proceeding that they had not had time to review the proposals. January will be one year since AriSEIA filed those proposals and TEP still seems unfamiliar with them.
 
BYOD is a win/win for AZ ratepayers and the utilities. AriSEIA’s BYOD proposal leverages private investment in distributed battery storage to provide much needed capacity to the grid at a price that is less than the cost of utility-owned, utility scale battery storage.[3] Further, any costs associated with the program are pay for performance only. There is no upfront payment, no subsidy, no cost shift.
 
At the stakeholder meeting held by TEP on November 17, 2023, TEP had no substantive content prepared, had no response to the AriSEIA proposals, had no proposals of its own, did not have the correct people at the meeting to discuss policy, nor did they articulate any plan for how to manage this process going forward. Further, despite the fact that the Order is clear as to what these stakeholder processes are meant to do, TEP was not clear in its direction to participants as to what we were even there to discuss. TEP permitted the meeting to devolve into a tangent conversation about wholly unrelated technologies or whether or not storage should even be considered, despite the fact that storage is the very reason the stakeholder process was ordered.
 
AriSEIA makes the following recommendations to the Commission and TEP:
 
1.      TEP should have the correct personnel at the stakeholder meetings to discuss policy and regulatory issues;
2.    The AriSEIA proposals on BYOD, R-TECH, and LGST-SP should be the basis on which the process unfolds. TEP should come to the meetings prepared to suggest components of these programs they can or cannot support;
3.     R-TECH and LGST-SP are separate issues and while they are to be discussed concurrently with BYOD, need not be discussed simultaneously;
4.     TEP needs to provide a capable facilitator of the meetings and process, either internal or external;
5.    If TEP wishes to host additional stakeholder meetings on unrelated topics or technologies, it can do so, but these processes should remain consistent with and adherent to the Order and the issues discussed in the last rate case; and
6.   TEP needs to articulate a process and timeline for this work. We suggest monthly meetings of one hour, which should be scheduled in advance with a stakeholder list, like TEP does for its other “collaborative” meetings.
 
AriSEIA’s proposal on all three matters can be found in Kevin Lucas’ direct testimony, filed on January 27, 2023, starting at page 314.[4] An excerpt of that testimony is attached herein.
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] TEP, Notice of Filing-Tucson Electric Power Company’s Customer Storage Program Stakeholder Meeting Summary, Dec. 7, 2023, Docket. No. E-01933A-22-0107, available here https://docket.images.azcc.gov/E000032546.pdf.

[2] ACC, Opinion and Order No. 79065, Pg. 149, Lines 11-27, Aug. 25, 2023, Docket No. E-01933A-22-0107, available here https://docket.images.azcc.gov/0000209684.pdf?i=1701984045033.

[3] Kevin Lucas in APS rate case, hearing test., Sept. 1, 2023, Docket No. E-01345A-22-0144, 00:04:31 (this is also applicable in the TEP rate case).

[4] AriSEIA, Direct Testimony of Kevin Lucas, Jan. 27, 2023, Docket No. E-01933A-22-0107, available here https://docket.images.azcc.gov/E000023835.pdf?i=1701984045030.