AriSEIA Joins Response to ACC Chairwoman's Community Solar Letter

Read the Full Text Here

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007

RE: Response to Chairwoman Marquez Peterson’s Letter Dated August 23, 2022 - 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.

The signatories are filing this letter in response to Chairwoman Marquez Peterson’s letter dated August 23, 2022 which posed questions about thirteen models she requested be compared to community solar.  As requested in the Chairwoman’s letter, attached as Appendix A is a matrix that provides an analysis of the models referenced.  As explained more fully below, most models described in the letter are not community solar and are not models the signatories are recommending for Arizona. Some of the models describe existing tariffs or programs and others describe hypothetical models that, as far as we know, have not been implemented elsewhere, making direct comparison challenging.  While the signatories do not recommend adoption of the models referenced in the matrix, the signatories desire to assist Staff and other stakeholders in their review of the models.  

It is important to note that 22 other states have already implemented community solar programs, and there is substantial precedent for how community solar programs work and experience with the models they follow. The underlying structure of community solar programs across the country is largely the same, and is consistent with the signatories’ program proposal filed on August 26, 2022 (henceforth referred to as “Signatories’ Proposal”). There are, of course, variations among existing programs which were achieved via policy making and/or regulatory decisions. The Signatories’ Proposal relies on common components of community solar programs around the country and has been tailored to Arizona and can be implemented within the existing regulatory framework.

Because there is substantial precedent for how community solar programs work across the country, we do not believe it is necessary to complete an exhaustive review of each of the thirteen models referenced in the Chairwoman’s letter beyond what is provided in Appendix A.  Below, the signatories have answered, in greater detail, the seventeen questions posed in the Chairwoman’ letter relative to the Signatories’ Proposal. 

As requested in the Chairwoman’s letter, the signatories seek to narrow the focus of the Commission’s research of how a community solar program fits within the existing regulatory and ratemaking framework in Arizona by reiterating the signatories’ preferred community solar model, filed on August 26, 2022 (henceforth referred to as “Signatories’ Proposal” and noted as item 4 below).  The signatories have made four filings to provide the Commission with detailed information on community solar program implementation in Arizona and how the preferred model would work.  These filings include:

1. Letter dated July 29, 2022 responding to Staff's July 7, 2022 memorandum and the July 19, 2022 letter filed by RUCO.  This letter contains details regarding the definition of community solar, structure of community solar, consumer protections, key programmatic elements, and sample disclosure forms.
2. Letter dated August 12, 2022 containing an illustrative example of community solar cash flows, sample bills, and sample contracts.
3. Letter dated August 26, 2022 containing the study of the community solar value stack in Arizona as prepared by The Brattle Group.
4. Letter dated August 26, 2022 containing a detailed community solar program proposal for additional discussion and implementation consideration.

The signatories will be filing additional information to further supplement the Signatories’ Proposal to address topics discussed at the working group meetings held on August 30 & 31, including a bill credit rate proposal.  The Signatories’ Proposal will provide substantial benefits and consumer protections for customers.  

Please see below for answers to the questions posed by the Chairwoman relative to the Signatories’ Proposal...