Salt River Project
1500 N. Mill Avenue
Tempe, AZ 85288
RE: Integrated System Plan and Stakeholder Engagement
Salt River Project and Board,
The Arizona Solar Energy Industries Association (AriSEIA) requested to be a part of the Integrated System Plan (ISP) stakeholder group in 2022. That request was denied. AriSEIA also requested to be included in the Sustainability Advisory Council and, to date, that has also not been granted. It is unclear why AriSEIA continues to be excluded from all formal SRP stakeholder processes. Therefore, AriSEIA submits the following comments on Item 4 of the October 2nd Board Meeting:
SRP should be required to issue All Source Requests for Proposals (ASRFPs) for all major procurements of generating resources. Those ASRFPs should be vetted through the ISP stakeholder process, as Arizona Public Service (APS) has started to do. The ISP stakeholder process should not exclude stakeholders that request inclusion, especially if they are well established organizations that participate in the resource planning processes of every other major utility in the state. Additionally, no stakeholder process should purposely exclude an entire stakeholder segment, such as renewable energy organizations. Such a stance needlessly excludes valuable expertise from what should be a technically robust process. Meetings should also be virtual or hybrid. In person meetings, such as has been the case for the last two, exclude many stakeholders. Stakeholders that are out of the Phoenix metro area, have small children, or cannot devote multiple hours to commuting to and from SRP are excluded. The other major utilities all have remote options for stakeholder participation.
Further, the ISP stakeholder process should be meaningful. There should be an exchange of information in both directions and the utility should be willing to make modifications based on stakeholder feedback, run requested portfolios, and provide the modeling inputs and results to stakeholders. Board members should familiarize themselves with the Arizona Corporation Commission (ACC) Integrated Resource Plan (IRP) process and should hold SRP to a similar standard, as you all serve as the regulator of SRP.
SRP has been holding meetings on the ISP for more than two years. The board should be voting on a resource plan, not three vague slides called “strategies.” That is not adequate oversight of an unregulated monopoly. The “strategies” provide no meaningful information as to what the utility plans to do regarding RFPs, procurement, or implementation of their sustainability goals. The 2017-2019 resource plan was much more detailed and it completely neglected major procurements, such as the Coolidge expansion.
SRP is the only major utility in the state that does not have an exit date for all coal; does not have a mass based carbon emissions goal; and has pursued major gas plant expansions that were never in a resource plan or RFP. The board should demand that the company do better. You are the only oversight on the second largest utility in the state.
/s/ Autumn T. Johnson
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