Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
RE: Standardized Contract, Agreement, and/or Tariff for Community Solar (Docket No. E-00000A-22-0103) & (Docket No. E-01345A-21-0240)
Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders,
The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions.
At the working group meetings held on August 30 & 31, 2022, there was discussion of whether a contract, agreement, and/or tariff would exist between a community solar developer and the utility to which a community solar project is interconnected beyond a standard interconnection agreement. Further, there was discussion of whether such contract, agreement, and/or tariff would be subject to negotiation for each project or standardized.
At the working group meetings, representatives of the signatories to this letter stated that there would be a contract, agreement, and/or tariff to govern the interactions between the community solar developer and the utility to which a community solar project is interconnected. The representatives of the signatories also stated that the contract, agreement, and/or tariff would be standardized such that it would not be subject to negotiation for each project, thus eliminating any concerns about taking up time and resources to execute.
The signatories committed to filing standardized examples from programs in other states that could be used as a template for the community solar program in Arizona. Attached to this letter as Appendix A is the Solar Rewards Community Producer Agreement that is used by Xcel Energy in Colorado. Attached to this letter as Appendix B is the Standard Contract for Solar Rewards Community that is used by Xcel Energy in Minnesota. The signatories have previously referenced certain components of the community solar programs in Colorado and Minnesota because each state has a mature community solar program. The Colorado example in Appendix A is a standardized contract which exists outside of the utilities tariff as a program document. The Minnesota example in Appendix B is also a standardized contract, however it exists within the utilities electric tariff. The standardized examples attached to this letter will need to be edited to reflect Arizona-specific program requirements
We appreciate the opportunity to address these important issues. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona.
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