AriSEIA Joins in Group Filing to Extend the IRP Deadline

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Support for Arizona Public Service (APS) and Tucson Electric Power (TEP)’s Request for an Extension of Integrated Resource Plan (IRP) Filing Deadline

The Joint Signatories, all members of APS and/or TEP’s IRP Advisory Council, write to support APS and TEP’s request to extend the deadline for filing their IRPs from August 1st, 2023, to November 1st, 2023, contingent on timely access to the modeling software and training.

The APS and TEP Resource Planning Advisory Councils (RPAC) comprise a diverse group of stakeholders and community representatives the RPACs have been providing input to APS and TEP on their next IRP on behalf of residential and business customers, local governments, public schools, the limited-income community, and the solar and environmental community, among others.

We have been meeting monthly since the spring of 2021 for APS, and the fall of 2022 for TEP, to share perspectives and provide input to help both utilities chart a long-term integrated resource plan that maintains reliable, affordable electric service through a balanced, flexible resource mix, which also advances sustainable outcomes. Meetings have addressed topics vital to developing a comprehensive, integrated resource plan, such as load forecasting, existing resource fleet and transmission systems, technology options and costs, and environmental impacts. During these meetings, stakeholders have been invited to listen, offer feedback, and pose questions. Participants have also been encouraged to present their own views. All meeting materials, agendas, and summaries are publicly available on APS and TEP’s RPAC websites. 

Also, pursuant to the Commission’s Decision 78499, APS and TEP are preparing to provide access to modeling licenses for RPAC members so that they will have the ability to conduct their own modeling analysis to better inform and provide feedback to the final IRP scenarios. However, APS and TEP have not yet provided RPAC members with the model licenses or data necessary to start the modeling efforts. Because the three months remaining before the August 1st deadline is not enough time to give this process the due diligence it deserves, a three-month extension to November 1st, 2023, is justified.
This new engagement model provides value to the Commission, APS, TEP, and other stakeholders by:

1. Helping APS and TEP to craft a resource plan that is informed by and reflective of stakeholder and community input, and
   
   
2. Contributing to the publicly available information that others can use to conduct their review and evaluation of APS and TEP’s IRP filings, including dozens of modeled IRP portfolios.

We also hope that a new engagement model will support an IRP process before the Commission that is less contentious than prior IRPs and will ensure that community input and feedback are considered from the outset. To realize these outcomes, however, RPAC members engaging in the additional modeling process must be allowed to complete their analysis fully with enough time to bring results to the RPAC consistent with the Commission’s directive. Without additional time, these efforts may be for naught. 

Because this is the first time this kind of advisory structure with modeling access has been implemented, ensuring that all RPAC participants have a solid understanding of various complex energy issues is essential. As such, many of the RPAC’s initial meetings have focused on education and information sharing. While these educational sessions have been valuable and necessary, the RPAC members have yet to receive the modeling licenses or modeling data and have not begun reviewing and providing input on the dozens of modeled IRP portfolios that APS and TEP produce. Approving APS and TEP’s request to extend the deadline for the filing of their IRPs from August 1st, 2023, to November 1st, 2023, and providing RPAC members access to the modeling license no later than May 2023, would enable the completion of this vital work. This deadline extension should be contingent on the utilities timely providing license access and training. The extension should require APS and TEP to provide access to the model and the requisite training within 30 calendar days of the decision.
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Thank you for considering our comments, and we encourage the Commission to discuss this matter during the May Contingency Open Meeting date on May 11th.