AriSEIA Submits Comments on APS' Interconnection Manual

Arizona Public Service
400 N 5th Street
Phoenix, AZ 85004
 
RE: AriSEIA Comments on the APS Interconnection Manual Draft Rev. 9.1 
 
Dear APS Interconnection Team,
 
The Arizona Solar Energy Industries Association (AriSEIA) appreciates the opportunity to provide comments on Arizona Public Service Company’s Interconnection Requirements Manual, Revision 9.1. These comments are intended to support clarity, consistency, and compliance with the Arizona Corporation Commission’s interconnection rules, particularly as they relate to Maximum Capacity, screening criteria, and the treatment of Active Power Limiting systems.
 
AriSEIA’s overarching concerns fall into several categories. First, multiple sections of the Manual reference Nameplate Capacity where Maximum Capacity is required under Arizona Administrative Code R14-2-2615. Consistent and accurate use of the defined regulatory terms is essential to ensure uniform application of the screening process and to prevent inadvertent misclassification of generating facilities.
 
Second, several provisions governing Active Power Limiting systems do not fully align with Arizona Corporation Commission requirements or with best practices used in other jurisdictions. These include scope limitations, terminology inconsistencies, and restrictions that would unnecessarily limit non-parallel operating modes that are widely expected to become more common as solar and storage penetration increases.
 
Third, certain protection and monitoring requirements would benefit from additional specificity to improve predictability for both developers and reviewers. In particular, clarification of Minimum Power Protection settings and the definition of the Relative Generating Facility Rating will help ensure consistent implementation across projects.
 
A detailed list of recommended revisions is attached. These recommendations include requested edits to sections 8.1, 8.3, 10.4, 12.2, and related protection and control provisions. Each recommended change is tied either to Arizona Corporation Commission rule requirements or to accepted technical standards used in other jurisdictions.
 
AriSEIA appreciates APS’s attention to these issues and remains committed to constructive engagement to support an interconnection process that is efficient, transparent, and compliant with state requirements. Please do not hesitate to contact us with any questions.
 
Sincerely,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

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