AriSEIA Sends Letter to Apache County on Renewable Energy Ordinance Subcommittee

Apache County Board of Supervisors
75 West Cleveland Street
St. Johns, AZ 85936

Re: Renewable Energy Ordinance Subcommittee 

Dear Supervisors, Commissioners, and Staff,

The Arizona Solar Energy Industries Association (AriSEIA) has been actively engaged in Apache County's Renewable Energy Ordinance since the winter of 2025. During that time, AriSEIA has submitted multiple formal comment letters, participated through eight successive drafts of the ordinance, and worked with County staff and other stakeholders to improve the ordinance. County staff have invested substantial time developing a thoughtful, comprehensive regulatory framework, and numerous stakeholders have participated in good faith throughout this more than one-year process.

For that reason, AriSEIA's recommendation is straightforward: please complete the ordinance. After more than a year of public meetings, stakeholder input, and eight iterations of the draft, the process should reach its conclusion rather than be delayed by another layer of review. While no ordinance is ever perfect, the Board has before it a balanced document that can continue to evolve through future amendments as necessary, and any party with an opinion on this ordinance has had ample opportunity to provide input.

If the Board nevertheless determines that a Renewable Energy Ordinance Subcommittee is necessary, it should be structured in a manner that gives it the greatest likelihood of success rather than simply extending the process.

The subcommittee should also be supported by a neutral, professional facilitator with experience managing complex stakeholder processes. A facilitator can help ensure meetings remain productive, focused on the issues before the committee, and provide all participants with an equal opportunity to be heard. This will allow County staff to participate as subject matter experts while helping the committee efficiently work through areas of disagreement.

AriSEIA would be remiss not to acknowledge that public participation in this ordinance process has at times crossed into territory that is difficult to describe as welcoming. No stakeholder should have to fear retaliation, including threats of violence, for participating in a local government process, and their presence in this process has understandably discouraged some qualified voices from participating. Conducting subcommittee meetings remotely and identifying members by organization rather than by name would go a meaningful way toward ensuring that the full range of expertise Apache County needs is actually at the table. 

The subcommittee should also be intentionally structured to ensure balanced, informed participation that will facilitate decision-making while allowing for a diversity of perspectives. Members should be selected based on relevant professional qualifications and expertise rather than simply prior participation or advocacy. And for the safety and security of those participating, the privacy of committee members should be maintained throughout the process. 

At a minimum, AriSEIA recommends representation from:

• Apache County development staff;
• Apache County economic development staff or a representative of a local chamber of commerce;
• Arizona Game and Fish Department;
• An individual with land use legal expertise;
• An individual with utility-scale renewable energy development experience;
• A representative from an Arizona university or a public health expert familiar with the scientific literature regarding commonly raised health-related claims associated with renewable energy facilities.

The questions before the subcommittee will be technical, legal, economic, environmental, and scientific. They should therefore be evaluated by individuals with demonstrated expertise in those disciplines. A committee that lacks relevant professional experience or is composed primarily of individuals selected because of their advocacy positions is unlikely to improve the ordinance or resolve the issues that remain before the Board.

Apache County has already invested significant time and effort into developing this ordinance. AriSEIA remains committed to serving as a constructive partner in that process. The Board should either complete the ordinance now or, if it chooses to establish a subcommittee, ensure that the committee is balanced, technically qualified, professionally facilitated, and structured in a manner that allows participants to contribute without fear of harassment or retaliation.

For the Board's convenience, AriSEIA's prior comment letters regarding the Renewable Energy Ordinance are available at: https://www.ariseia.org/news/category/apache-county.

Respectfully,
​/s/ Autumn T. Johnson 
Executive Director
AriSEIA  
(520) 240-4757
[email protected]