Yavapai County Development Services
1120 Commerce Drive Prescott, AZ 86305 RE: Redlines of the May 13, 2024 Solar Facilities Ordinance Draft Supervisors, Commissioners, and Staff, AriSEIA is the State’s nonprofit solar, storage, and electrification trade association. We are active at all levels of government in Arizona, working to advance renewables policy. We worked heavily on Eloy’s 2023 ordinance and are currently working with Mohave County and Pinal County on similar processes. We have been in touch with Matthew Blake and Jeremy Dye regarding the Yavapai County solar ordinance. We attached our redlines as Attachment A to this letter and plan to attend the June 19, 2024 meeting. While we are in the process of completing an economic impact analysis with Elliott Pollack for Yavapai County, it is not yet complete. Therefore, we have attached our equivalent study for Mohave County as Attachment B for your reference. You will note, Attachment A has numerous edits. The Yavapai ordinance is the first we have seen that would include distributed generation (i.e. residential and commercial solar). We would encourage you to reconsider its inclusion in an ordinance that appears to be targeted at utility scale development. Our largest concern for the utility scale portion of the ordinance is that it appears to unfairly single out and target solar development with restrictions that are not applicable to any other land uses. Our overall feedback is that solar should not be subject to restrictions that are not applicable to other types of development. There are also provisions we believe violate Arizona law, namely regarding the Arizona Power Plant and Line Siting Committee of the Arizona Corporation Commission. Our two other largest concerns have to do with the caps on the acreage of projects and the cap on solar development in the County in F(1), as well as the setbacks for solar projects in F(2). We also have concerns about the technical feasibility of some of the storage (BESS) components of the ordinance. We encourage you to hold a stakeholder meeting and invite residential and commercial installers, as well as utility scale developers to discuss the feasibility of the provisions of this ordinance before moving further. Thank you for your time and consideration. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected]
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