Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Re: APS Interconnection Manual, Docket E-01345A-20-0152
Madam Chair and Commissioners,
This item is scheduled for the Staff Meeting on August 16, 2022, as number 11. The Arizona Solar Energy Industries Association (AriSEIA) has reviewed the Arizona Public Service (APS) Interconnection Requirements for Distributed Generation Rev. 9.0 dated May 6, 2022, and as amended in redlined versions from APS on July 20, 2022 and August 10, 2022 (the “Manual”). We have filed comments in this docket, met with APS and Commission Staff several times, and have submitted written feedback to both APS and Staff on outstanding issues.
During the deliberation on the Commission’s Interconnection Rulemaking, we expressed our concern that there are many utility requirements that unnecessarily inflate cost while adding time and complexity to the process for interconnecting distributed generation systems in APS territory. Unfortunately, the July 24, 2020, Rev. 8.5 Manual shown on the APS website is the Manual currently being utilized by APS, despite numerous elements that make interconnecting distributed generation needlessly costly for consumers. In fact, in some respects, APS ignores the Commission’s Interconnection Rules. The usage of this older version of the manual is very detrimental to our member companies. This stands in stark contrast to Tucson Electric Power (TEP) who adjusted their interconnection requirements with each revision of their handbook as issues were identified and eliminated during the stakeholder process. The APS Manual revisions to date make multiple changes as a result of stakeholder engagement that address issues that continue to impact the cost, size, and schedules of projects over two and a half years after the Commission’s Interconnection Rules became effective.
We respectfully request the Commission direct APS to file a revised Manual no later than August 31, 2022 and to utilize that version until a final vote by the Commission. Given the significant delay in the finalization of the Manual, we request this matter be noticed for a final vote on the October Open Meeting agenda.
Thank you for considering these comments meant to improve the compliance of the APS document with the spirit and letter of the Commission’s Interconnection Rules.
Board of Directors
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