AriSEIA Opposes Continued Decline in Solar Export Rate

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Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
RE: APS 2024 RCP, Docket No. E-01345A-24-0095; TEP 2024 RCP, Docket No. E-01933A-24-0094  
 
Dear Chairman and Commissioners,
 
Both Arizona Public Service (APS) and Tucson Electric Power (TEP) have filed in the above noted dockets to request the maximum annual reduction in the Resource Comparison Proxy (RCP).While it is AriSEIA’s position that the underlying Value of Solar decision from Docket No. E-00000J-14-0023 should not be modified in the new export rate Docket No. AHD-00000J-23-0273, we would like to highlight concerning developments in the residential solar sector in Arizona.
 
Recently, Arizona has seen several major residential solar companies leave the Arizona market. Very large residential solar installers based in Arizona have closed entirely. And just in the last week, several AriSEIA members have declared bankruptcy, including companies local to Arizona. Overall, residential solar installations in Arizona are down 31% year over year. Installations in the state are at their lowest level since 2020, a year in which the Commission decreased the RCP by less than the maximum.
  
The decline in residential solar installations, bankruptcies, and company closures are not due solely to the RCP. But a decrease in the RCP will continue to exasperate this alarming situation. Solar represents a significant amount of jobs and economic development in Arizona. Such a significant downturn in this sector in the sunniest state in the country should be cause for concern.
 
Further, distributed generation, including rooftop solar and battery storage, is a critical tool in the toolbox for peak demand reduction and grid reliability. With solar alone, it is possible for rooftop solar customers to completely eliminate or dramatically reduce their peak usage. With a battery, it is possible for them to provide that capacity back to the grid. With well designed policies, these resources can benefit all ratepayers.
 
Respectfully,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]