AriSEIA Submits Comments on ACC IRP Model Framework

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September 12, 2025
 
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
RE: Response to Staff IRP Software License Reimbursement Framework; IRP Docket No. E-99999A-25-0058
 
Chairman and Commissioners,
 
AriSEIA is a member of both the TEP/UNSE and APS Resource Planning Advisory Councils (RPAC). We have been engaged with the last two TEP and APS Integrated Resource Plans (IRPs). In addition to being on the RPACs, regularly attending the meetings, submitting detailed comments on the plans, presenting at the IRP workshop and IRP open meeting; we also participated in the modeling process last time.
 
AriSEIA filed comments on the original Staff recommendation on October 4, 2024[1] and then again on June 13, 2025.[2] AriSEIA continues to maintain that it is a mistake to require stakeholders to pay for their own modeling licenses. AriSEIA also filed comments refuting utility statements at the IRP workshop that stakeholders had not properly utilized their licenses on August 27, 2024.[3] AriSEIA filed comments on the 2023 IRPs on January 31, 2024 as required. That filing was 142 pages long.[4] AriSEIA also filed 263 pages of joint comments with Vote Solar and Advanced Energy United as to the 2023 IRPs on January 31, 2024.[5] That filing included 124 slides as to RMI’s analysis of TEP and APS’ IRPs, based on their use of the modeling licenses. RMI was our consultant in that matter. AriSEIA filed joint comments in the same docket supporting the need to move the IRP deadline due to modeling delays on May 2, 2023.[6] AriSEIA filed a letter to the docket expressing concerns that APS and TEP were violating the 2020 IRP Order in delaying the release of the modeling tools on April 28, 2023.[7] We note these filings now to draw attention to our robust participation in IRP dockets, but also to highlight that issues with the modeling licenses plagued all of 2023. AriSEIA does not recommend changing the process yet again, as we had just barely worked out the issues with the prior process.
 
Nevertheless, we highlight the following remaining concerns with the Utilities Division Staff  IRP Software License Reimbursement Framework filed on September 3, 2025.[8]
 
RECOMMENDATION 1: Require One Model
 
AriSEIA recommends the policy require a stakeholder to run the base case scenario or one (not two) distinct portfolio. Staff’s concerns about ability to hire consultants, Staff capacity as to time, and their lack of any modeling in the 2023 IRP process highlight how onerous this work is. There is no substantiation as to why stakeholder need to run three models. One should be the floor. If a stakeholder has the time or resources to run more, then there is nothing stopping them from doing that. Many stakeholders are on multiple RPACs. Three models per utility means that some of us would actually need to run 6-9 models. Additionally, the Commission should not further limit what constitutes a distinct model by prohibiting modification of retirement dates to be considered a distinct model.
 
RECOMMENDATION 2: Create a Scholarship Option
 
The Commission should consider a scholarship process for stakeholders that can demonstrate a financial hardship. The Commission should put parameters in place to make sure only qualified stakeholders qualify for the scholarship. If a stakeholder does qualify, they should be required to complete the requirements set out in this policy, but without paying for the license themselves. Suggested parameters may include: being a member of the RPAC, attending a certain percentage of RPAC meetings, demonstrated participation in the last IRP process, being a not for profit entity, and financial hardship either by 990 or other means. Penalty for obtaining a scholarship and not completing the requirements as set forth in this policy could be disqualification from any such similar program in the next IRP cycle.
 
RECOMMENDATION 3: Provide Data to RPAC Members That Do Not Obtain Licenses
 
The cost of the licenses and a consultant to perform the required portfolios will cost ~$175,000. This will make this process cost prohibitive for many stakeholders, thereby reducing participation and the number of eyes reviewing plans that cost >$30 billion dollars. The Commission should create an alternative option by which RPAC members can obtain more data than the filed IRP, but not data that can only be utilized with proprietary software. Additionally, the Commission could direct the LSEs to provide certain deliverables to RPAC members and/or require LSEs to run portfolios suggested by RPAC members. For example, RPAC members that do not obtain licenses should be permitted to put forward two portfolios for the LSE to run by the NOI date in the Staff Framework.
 
Because the Framework does not have line numbers or numbered bullets, we have provided a redline for Commission consideration as Exhibit 1, as opposed to amendments. This is the bare minimum changes we recommend, but also suggest inclusion of Recommendations 2 and 3, as well.
 
Thank you for your consideration.
 
Respectfully,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] AriSEIA Comments on the August 30, 2024 Utilities Division Memorandum and Amendments, Docket No. E-99999A-22-0046, filed October 4, 2024, available here https://docket.images.azcc.gov/E000039019.pdf?i=1749756384020.

[2] AriSEIA Comments on the Staff Proposed Framework for IRP License Reimbursement, Docket No. E-99999A-22-0046, filed June 13, 2025, available here https://docket.images.azcc.gov/E000044750.pdf?i=1757656787403. . 

[3] AriSEIA Response, Docket No. E-99999A-22-0046, filed August 27, 2024, available here https://docket.images.azcc.gov/E000037591.pdf?i=1749756384020.

[4] AriSEIA Comments on the APS and TEP 2023 IRPs, Docket No. E-99999A-22-0046, filed January 31, 2024, available here https://docket.images.azcc.gov/E000033415.pdf?i=1749756384020.

[5] Joint Comments of AriSEIA, Advanced Energy United, and Vote Solar on the 2023 IRPs, Docket No. E-99999A-22-0046, filed January 31, 2024, available at https://docket.images.azcc.gov/E000033451.pdf?i=1749756384020.

[6] Support for APS and TEP’s Request for an Extension of IRP Filing Deadline, Docket No. E-99999A-22-0046, filed May 2, 2023, available at https://docket.images.azcc.gov/E000026358.pdf?i=1749756384020.

[7] AriSEIA Letter on IRP Modeling Licenses, Docket No. E-99999A-22-0046, available at https://docket.images.azcc.gov/E000026311.pdf?i=1749756384020.

[8] Utilities Division Staff Proposed Framework for IRP License Reimbursement Memorandum, Docket No. E-99999A-25-0058, filed May 9, 2025, available here https://docket.images.azcc.gov/E000044023.pdf?i=1748461994048.