AriSEIA Submits Comments in Support of APS' Interconnection Manual Update

FIND THE COMMENTS HERE

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
RE: Support for APS’ Revised Interconnection Manual, Docket No. E-01345A-20-0152
 
Dear Chairman and Commissioners,
 
On behalf of the Arizona Solar Energy Industries Association (AriSEIA), this letter provides comments on Arizona Public Service Company’s (“APS”) revised Distributed Generation Interconnection Requirements Manual.
 
AriSEIA appreciates the collaborative process between stakeholders and APS in developing the revised Manual. We met multiple times over the course of 2025. The current version reflects meaningful improvements, including reduced costs and simplified equipment requirements for customer-sited solar installations. These changes address prior stakeholder concerns and improve clarity, consistency, and administrability of the interconnection requirements.
 
AriSEIA supports the Utilities Division Staff’s Recommended Opinion and Order docketed on March 25th, which finds that the revised Manual complies with the Commission’s Interconnection Rules and Decision No. 78783 and recommends approval.
 
AriSEIA notes that certain issues remain under discussion, including the treatment of Non-Exporting and Inadvertent Export systems. Specifically, the use of nameplate ratings rather than Maximum Capacity for certain requirements raises concerns for systems that are designed not to export to the grid. AriSEIA and APS have engaged on this issue and will continue working toward a resolution in future revisions to the Manual.
 
While these issues remain, AriSEIA supports approval of the revised Manual at this time and appreciates APS’ continued commitment to stakeholder engagement and iterative improvement.
AriSEIA remains committed to working collaboratively with APS, Staff, and the Commission to further refine interconnection standards in future updates.
 
Respectfully,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]
​