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AriSEIA filed its opening brief in the TEP rate case on May 26th highlighting our recommendations on the revenue requirement (including return on equity (ROE) and common equity ratio), as well as rate design (including community solar, a bring your own device/virtual power plant proposal, tariff re-designs for R-TECH and LGST-SP, and ending the distributed generation (DG) meter fee).
0 Comments
Arizona Corporation Commission
1200 W Washington St. Phoenix, AZ 85007 RE: Proposed Changes to the Public Comment Process, Docket No. AU-00000A-16-0141 Chairman O’Connor and Commissioners: Please consider the following comments on the Arizona Corporation Commission’s (ACC) pursuit of modifying how it considers public comment and implements a version of Robert’s Rules of Order for Thursday’s Staff Open Meeting. We wish to express our concern about the Commission’s vote during the May 1st Staff Open Meeting to keep these proposed changes private and away from public viewing. While keeping sensitive information confidential is reasonable, shielding proposed rule changes or procedures that will determine how everyday Arizonans participate at the Commission is not. We recognize that the proposed changes are meant to guide the operations of the ACC. However, that operation has a compelling public interest, and the document should be widely available. The commissioners are elected, and the ACC is considered a public agency for purposes of the public records law, open meeting law, and other provisions intended to ensure transparency and accountability. The ACC must allow meaningful opportunities for public comment. Not doing so would run contrary to the ACC's mission and leave commissioners to hear overwhelmingly from those monopolies it is charged to regulate. Those monopolies have disproportionate resources to lobby the ACC, and public comment is a critical counterbalance. Considering these concerns, we offer feedback on the proposed rule changes released upon a public records request below: Rule 2. Requiring that people register in advance to provide public comment will severely limit participation by everyday Arizonans, everyday ratepayers, who are most affected by the ACC's decisions. It is challenging enough already for them to participate in these processes, but this would make it even more so. Sometimes people do not know if they can get time off work ahead of time. They may only understand how an item affects them once they hear more about it. Frequently, last-minute amendments can alter agenda items and significantly change a proposal; individuals may want to respond to that as well. Rule 3. As nonprofits, some of which have a significant membership base, we represent individual ratepayers, people who cannot otherwise be at the ACC, whose voices would not be heard if we did not speak up for them. Curtailing our participation and our opportunity to address important issues before the ACC will also silence their voices. It is inappropriate to require various stakeholders or individual entities, such as nonprofits, to designate a spokesperson. Different organizations cannot speak for each other and, even if they were, the ACC needs to hear various perspectives on the issues before it, even if the recommendations are consistent. Requiring the designation of a spokesperson devalues individual experiences and perspectives and further disadvantages those that disagree with the utilities, which have far more power and resources in these matters. Rule 4. Public commenters should be granted a minimum of three minutes to speak. Again, there should not be a deadline to sign up to speak as long as the item has not been concluded, and as the rule is drafted now, the public comment period could be shorter than three minutes. Time limits should only be utilized when necessary due to the significant length of an agenda item. Otherwise, this rule only serves to limit public voices. Rule 6. Further, no public comment should ever be limited to one minute. That is not a meaningful amount of time to convey important and often complex information. See our comments above on Rule 2, as well. Rule 7. As long as an individual wishes to comment and the item has not concluded (i.e., voted on or completed and the next item is called), those who wish to speak but have not been afforded their three minutes should be permitted to speak. Talking to ACC staff should also not be prohibited. Staff represent the ACC as stakeholders in various proceedings, and communication should be encouraged among stakeholders not limited. As has been discussed at several meetings, Staff also need more resources and capacity. Commissioners have mentioned the number of empty positions multiple times. Therefore, stakeholders should be able to engage with Staff should there be an inadvertent error or miscommunication. It is also imperative that stakeholders have the opportunity to reply to comments made by the utilities, Staff, or Commissioners during a proceeding. Limiting a stakeholder’s comments to three minutes with no opportunity to reply makes the conversation more likely to be one-sided with the utilities offered numerous opportunities to speak. The ACC’s processes and procedures already make it difficult for many average Arizonans and most of the ratepayers to participate. The rules you have before you now will not facilitate their participation but will only make it more difficult. We ask that you not vote on changes to the public comment process on the May contingency date and instead post these proposed changes to the docket so that all stakeholders and at least some of the larger public have the opportunity to review and file comments and any changes be addressed at an Open Meeting, not a Staff Meeting, so that they also have the opportunity to speak. We recommend a 30-day time period between posting the proposed changes and any vote. Support for Arizona Public Service (APS) and Tucson Electric Power (TEP)’s Request for an Extension of Integrated Resource Plan (IRP) Filing Deadline
The Joint Signatories, all members of APS and/or TEP’s IRP Advisory Council, write to support APS and TEP’s request to extend the deadline for filing their IRPs from August 1st, 2023, to November 1st, 2023, contingent on timely access to the modeling software and training. The APS and TEP Resource Planning Advisory Councils (RPAC) comprise a diverse group of stakeholders and community representatives the RPACs have been providing input to APS and TEP on their next IRP on behalf of residential and business customers, local governments, public schools, the limited-income community, and the solar and environmental community, among others. We have been meeting monthly since the spring of 2021 for APS, and the fall of 2022 for TEP, to share perspectives and provide input to help both utilities chart a long-term integrated resource plan that maintains reliable, affordable electric service through a balanced, flexible resource mix, which also advances sustainable outcomes. Meetings have addressed topics vital to developing a comprehensive, integrated resource plan, such as load forecasting, existing resource fleet and transmission systems, technology options and costs, and environmental impacts. During these meetings, stakeholders have been invited to listen, offer feedback, and pose questions. Participants have also been encouraged to present their own views. All meeting materials, agendas, and summaries are publicly available on APS and TEP’s RPAC websites. Also, pursuant to the Commission’s Decision 78499, APS and TEP are preparing to provide access to modeling licenses for RPAC members so that they will have the ability to conduct their own modeling analysis to better inform and provide feedback to the final IRP scenarios. However, APS and TEP have not yet provided RPAC members with the model licenses or data necessary to start the modeling efforts. Because the three months remaining before the August 1st deadline is not enough time to give this process the due diligence it deserves, a three-month extension to November 1st, 2023, is justified. This new engagement model provides value to the Commission, APS, TEP, and other stakeholders by:
Because this is the first time this kind of advisory structure with modeling access has been implemented, ensuring that all RPAC participants have a solid understanding of various complex energy issues is essential. As such, many of the RPAC’s initial meetings have focused on education and information sharing. While these educational sessions have been valuable and necessary, the RPAC members have yet to receive the modeling licenses or modeling data and have not begun reviewing and providing input on the dozens of modeled IRP portfolios that APS and TEP produce. Approving APS and TEP’s request to extend the deadline for the filing of their IRPs from August 1st, 2023, to November 1st, 2023, and providing RPAC members access to the modeling license no later than May 2023, would enable the completion of this vital work. This deadline extension should be contingent on the utilities timely providing license access and training. The extension should require APS and TEP to provide access to the model and the requisite training within 30 calendar days of the decision. Thank you for considering our comments, and we encourage the Commission to discuss this matter during the May Contingency Open Meeting date on May 11th. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Joint Exceptions to Tucson Electric Power Company’s PPFAC rate adjustment Recommended Opinion and Order, Docket No. E-01933A-19-0028 Dear Chairman O’Connor and Members of the Arizona Corporation Commission, On behalf of the Residential Utility Consumer Office (RUCO), Freeport McMoRan, Southwest Energy Efficiency Project (SWEEP), Arizona Solar Energy Industries Association (AriSEIA), Vote Solar, and Wildfire, we appreciate the opportunity to provide the attached proposed amendment to Commission Staff’s proposed Order regarding Tucson Electric Power’s (TEP) request to increase the Purchased Power and Fuel Adjustment Clause (PPFAC).[1] In response to the TEP continuing to have a sizable under-collected balance in recent years, we would like to offer a joint amendment to address forward-looking adjustments attached herein. Thank you for considering our amendment, and we look forward to discussing this matter during the May 2nd Open Meeting. [1] https://docket.images.azcc.gov/E000026030.pdf?i=1682711963707 Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007-2996 RE: Resource Planning and Procurement in 2021, 2022, and 2023 (Docket No. E-99999A-22-0046) and In the Matter of Resource Planning and Procurement in 2019, 2020, and 2021 (Docket No. E-00000V-19-0034) Chairman O’Connor and Commissioners, At the February 2022 Open Meeting, scheduled for February 8th and 9th, 2022, the Commission voted to acknowledge the 2020 Integrated Resource Plans (IRPs) of Tucson Electric Power (TEP) and Arizona Public Service (APS).[1] In addition to acknowledging the IRPs, the Commission placed numerous other requirements on the utilities, including a requirement to provide stakeholders and Commission Staff with the requisite tools to meaningfully participate in the subsequent modeling process. IT IS FURTHER ORDERED that Arizona Public Service Company, Tucson Electric Power Company, and UNS Electric, Inc. shall in future Integrated Resource Plans negotiate a project-based licensing fee that permits up to 12 Resource Planning Advisory Council members and Staff the ability to perform their own modeling runs in the same software package as these load serving entities, and to provide all necessary data and support to fully utilize the models. The load serving entities shall absorb the cost of the licensing fees.[2] To date, nearly 15 months after this vote, neither utility has complied with the Order. Stakeholders have been requesting access since Q4 2022. Stakeholders are still waiting on Nondisclosure Agreements (NDAs) from TEP and were told by APS that training on the software would occur in April 2023. Only the utilities have the ability to execute NDAs, provide the licenses and data, and conduct the requisite training. Without these tools, stakeholders are unable to meaningfully participate in the manner desired by Order 78499. We ask the Commission to direct both TEP and APS to provide all of the above mentioned tools no later than May 31, 2023. Additionally, because of this lengthy delay, we ask for the IRP filing deadline to be extended past August 1, 2023. That is simply not enough time to conduct modeling and provide meaningful feedback on the results. Finally, we ask that the Commission take this issue up as soon as possible, at either the May 2nd Open Meeting or the May 11th Contingency Meeting, because the June Open Meeting is too close to the IRP deadline to permit resolution of these issues with sufficient time to carry out the analysis envisioned in the Commission’s Order. Respectfully, Autumn T. Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) 520-240-4757 autumn@ariseia.org [1] Open Meeting Notice, Docketed February 3, 2022, Agenda Item 26, available here: https://docket.images.azcc.gov/0000205866.pdf?i=1682712327380. [2] Decision No. 78499, Docketed March 2, 2022, Page 14, Lines 9-14, available here: https://docket.images.azcc.gov/0000206081.pdf?i=1682710289643. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Joint Comments in the request of Tucson Electric Power Company for approval of the PPFAC rate adjustment, Docket No. E-01933A-19-0028 Dear Chairman O’Connor and Members of the Arizona Corporation Commission, Vote Solar, the Southwest Energy Efficiency Project (SWEEP), and the Arizona Solar Energy Industries Association (AriSEIA) appreciate the opportunity to provide these comments on Commission Staff’s Recommended Opinion and Order (ROO) regarding Tucson Electric Power’s (TEP) request to increase the Purchased Power and Fuel Adjustment Clause (PPFAC). If approved by the Commission, TEP’s proposal would increase the average residential bill by $13.11 (10.8%) on top of the previously approved PPFAC, which was $6.36 (5.1%). The Staff’s proposal would increase the average residential bill by $12.07, plus the existing $6.36, for a total impact of $18.43 per month. The volatile nature of natural gas costs is an important reminder that the Commission should consider all tools at its disposal to mitigate significant increases to customer utility bills via fuel adjustors. After all, TEP’s request equates to a $19.47 monthly charge for the average residential customer. Notably, greater investment in reliable, affordable energy efficiency and renewable energy are vital solutions to insulate customers from this price shock and volatility. At the Energy Reliability Summit and Summer 2023 Energy Preparedness special open meeting, several commissioners reinforced the importance of demand response in maintaining reliability. Tools like demand response can also save costs for individual customers and the grid. Further, energy efficiency is well documented to cost less than other alternatives, including gas resources. During times of upward utility bill pressure, TEP’s energy efficiency offerings are especially vital because they can help residents and businesses control their energy costs, drive down energy bills, and redirect savings to the local economy. Additionally, renewable energy, such as wind and solar, offers a price-stable alternative because it has no fuel costs. However, the current structure of fuel adjustors passes 100% of fuel costs on to customers, significantly reducing the utilities’ incentive to make every effort to mitigate increasing costs. Utilities must consider fuel and other operations and maintenance costs when making resource procurement decisions because customers pay for the totality of those costs, not just capital costs. A Bring Your Own Device (BYOD) program is another option to reduce customer exposure to volatile fuel prices. Dispatch of customer-sited batteries, when demand is high, reduces the need for utilities to purchase more expensive peak power. As a result, customer-sited solutions like a BYOD program benefit the grid while reducing reliance on fuel adjustors. In conclusion, the current structure of the PPFAC creates significant exposure to fuel price volatility that results in variable and unpredictable customer bills. Accordingly, the Commission should examine the structure of fuel adjustors like the PPFAC to determine if the reinstatement of a cost-sharing provision to protect ratepayers from skyrocketing fuel costs is warranted. We believe this examination should occur in the Company’s current pending rate case or through a separate proceeding before the following PPFAC rate period proposal is filed. We appreciate your consideration of these comments and ongoing efforts to protect Arizona ratepayers. Respectfully, Kate Bowman Interior West Regulatory Director Vote Solar kbowman@votesolar.org Caryn Potter Arizona Representative SWEEP cpotter@swenergy.org Autumn Johnson Executive Director AriSEIA autumn@ariseia.org Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: Support for Approval of Revisions to Rate Schedule E-32 L SP, Docket No. E-01345A-22-0281 Chairman O’Connor and Commissioners, Vote Solar and the Arizona Solar Energy Industries Association (AriSEIA) are supportive of the Arizona Public Service (APS) Company’s Application for the approval of revisions to rate schedule E-32 L SP and encourage the Commission to approve this rate. APS’ proposed revisions are pursuant to Decision No. 78317 (November 9, 2021), which directed APS to engage in a collaborative with interested stakeholders to explore possible improvements to E-32 L SP (Large General Service Storage Pilot).[1] Following a series of collaborative meetings that took place from February to October 2022, APS has proposed revenue-neutral design changes that improve upon the Large General Service Storage Pilot rate. The Large General Service Storage Pilot rate is a pilot rate available to large commercial customers who choose to adopt energy storage systems. The purpose of E-32 L SP is to promote the economic dispatch of customer-sited energy storage systems in a manner that aligns with high peak load. To date, no customers have chosen to take service on E-32 L SP. APS’ revisions to the rate include higher energy charges during all hours and months of the year, and significantly higher energy charges during summer on-peak periods between 4:00 and 9:00 PM. Demand charges have been reduced commensurately, resulting in a rate design that is overall revenue-neutral. APS’ revisions address a flaw in the current E-32 L SP by increasing the emphasis on volumetric energy rates. As a result, the revised Large General Service Storage Pilot will provide greater investment certainty for commercial customers. Demand charges present operational challenges for customers seeking to reduce their energy bills because they are calculated based on the customers’ highest 15-minute period of energy usage throughout the month. A customer who proactively dispatches their energy storage system during all but a single 15-minute period of the month will pay a demand charge equal to what they would have paid had they not adopted energy storage at all. Demand charges can penalize customers who adopt energy efficient technology, especially new and unfamiliar technology, because it is challenging to forecast savings and there is significant risk that small changes in operation of the energy storage system could threaten forecasted savings. In contrast, emphasis on volumetric rates gives customers the opportunity to save money on their utility bill in a manner that is proportional to the benefit they are providing through dispatch of energy storage during times of peak load. APS’ proposed revisions - particularly the increases in the summer on-peak energy rate from 6.5 cents per kilowatt-hour to 17.6 cents per kilowatt-hour - maintains a strong price differential that will encourage the dispatch of customer-sited storage during periods of high load in the summer. We recommend one additional change to the E-32 L SP tariff. While the current tariff defines the on-peak period as 4:00 to 7:00 PM on weekdays, the revised tariff re-defines the on-peak period as 4:00 to 9:00 PM every day. We recommend narrowing the on-peak window to weekdays, as this better aligns with the hours when APS is most likely to experience high customer load and normal hours of business operations. The Commission could direct APS to evaluate this change as part of their current rate case in Docket No. E-01345A-22-0144. We do not wish this evaluation to delay approval of the revised tariff at the May 2 Open Meeting. Arizona is poised to lead on the adoption of distributed battery storage through the development of rates that encourage economically efficient adoption of customer-sited batteries. Increased adoption of customer-sited batteries gives utilities an additional tool to flexibly and cost-effectively meet their customers’ energy needs and can provide significant cost and grid resilience benefits for all ratepayers. We appreciate APS’ efforts to work with stakeholders to improve the E-32 L SP tariff. We urge the Commission to approve APS’ Application today and consider whether changes to the on-peak hours are warranted through evaluation as part of APS’ rate case. Thank you for your consideration of this important matter. Respectfully, Kate Bowman Interior West Regulatory Director Vote Solar kbowman@votesolar.org 703-674-8637 Autumn Johnson Executive Director AriSEIA autumn@ariseia.org 520-240-4757 [1] Decision No. 78317, November 9, 2021, page 441 lines 15 - 21. AriSEIA filed a response to TEP's rebuttal testimony in the TEP rate case today. The testimony covered three main topics: the company's return on equity (ROE) proposal, community solar, and rate design for distributed solar and storage. TEP has attempted to have several of our issues removed from this rate case, but we have highlighted this is simply a delay tactic and should be denied. Read the full testimony above.
Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 RE: Community Solar Policy Statement, Docket No. E-00000A-22-0103, Exceptions to Staff’s Proposed Order filed February 24, 2023 Chairman and Commissioners, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and nonprofit advocacy groups — have been participating in the Commission’s effort to develop a community solar program since May 2022, nearly a year ago. Our coalition has worked together, and in consultation with other stakeholders, to submit numerous filings that detail national best practices for community solar programs and recommendations for tailoring a community solar program to Arizona. To inform development of an Arizona-specific program, we have also provided a study from Brattle Group regarding the value of distributed community solar projects in APS’ service territory and a study completed by ASU that highlights the quantitative economic benefits of a community solar program in Arizona. We are supportive of the Commission’s effort to make community solar available to Arizonans and appreciate the opportunity to provide information and recommendations to support this goal. The policy statement and proposed order filed by Commission Staff on February 24, 2023 is misaligned with the common understanding and implementation of community solar across the country. Staff’s memorandum and proposed order fails to address or incorporate any of the feedback and recommendations provided by our coalition throughout the seven month working group process or in our stakeholder comments filed January 27, 2023. Staff’s memorandum includes many shortcomings and, if implemented, would not result in a community solar program, would not spur development of any community solar projects in the state, and would not expand the benefits of solar to families and businesses that currently cannot access rooftop solar. The Commission should reject the Staff proposal. We recommend the Commission either adopt our attached amendment or direct that the five issues of location, structure, LMI carve out, use of an all-source RFP, and must-take requirements be resolved via an evidentiary hearing. If the will of the Commission is to do neither, we ask that you vote no on the Staff’s Recommended Opinion and Order. For reference, a list of our previous filings can be found below: - Response[1] to July 7 Staff Memorandum and July 20, 2022 letter filed by RUCO; - Draft Program Proposal;[2] - The Brattle Group study[3] on the value of DG resources in APS territory; - Response[4] to Commissioner Marquez Peterson’s August 23, 2022 Letter; - Bill Credit Rate Proposal;[5] - Response[6] to APS Program Proposal; - Economic Impact Study conducted by Arizona State University;[7] - Exceptions and Proposed Amendment[8] to Staff’s Recommended Opinion and Order; and - Response to Staff’s request for comment on the forthcoming policy statement filed on January 27, 2023.[9] Decision 78784[10] directed Utilities Division Staff to work with stakeholders to provide a recommendation to the Commission regarding five elements of community solar program design: “(1) Location of the community solar program; (2) Structure of the program; (3) The percentage of carve out for low to moderate income customers; (4) Whether the program should be included in an all-source Request for Proposal; (5) Must take provision.”[11] Despite clear Commission direction, Staff’s memorandum and proposed order does not address or incorporate feedback filed by stakeholders. Additionally, Staff’s memorandum and proposed order includes several provisions that stakeholders have repeatedly demonstrated are not characteristic of other community solar programs and would not lead to a successful or robust program in Arizona. It also includes, without explanation, recommendations that were not discussed or recommended during the duration of the working group process. As a result, Staff’s order leaves the Commission without workable guidance on how to proceed with a meaningful program that benefits Arizona communities. (1) Structure of the Program Staff recommends that participation in a community solar program be optional for regulated electric utility companies. This is not a recommendation that was raised or discussed during the course of the working group process. This recommendation deviates from all traditional, third-party, community solar programs across the country, and will not result in a successful program in Arizona. Decision 78784 tasks the Commission with “adopting a statewide policy” for community solar.[12] Per the language within the Decision itself, a statewide community solar program should apply to all Commission-regulated investor-owned utilities (IOUs) in the state: Arizona Public Service (APS), Tucson Electric Power (TEP), and UNS Electric (UNS). An opt-in program for regulated utilities would result in inconsistent access to community solar across the state, depending on a customer’s utility service territory. Furthermore, the state’s investor-owned utilities have already announced their opposition to such a program, no matter how much their customers may want or benefit from it. We recognize that circumstances may differ for cooperative utilities and recommend that they should be permitted to opt-in to the program. Additionally, Staff recommends that the bill credit for energy exported from community solar programs not exceed avoided cost. The bill credit rate was specifically identified in Decision No. 78784 as an item to be addressed in the evidentiary hearing,[13] not the policy statement. It is premature to determine the bill credit rate at this time, and in isolation from other important program details which have not yet been determined. Regardless, the proposed bill credit would be by far the lowest in the country and would not result in the development of any community solar projects. Finally, Staff recommends that “[a] participating regulated electric utility company may offer community solar itself or via partnership with a third party.” It is unclear whether Staff is recommending that the regulated electric utility will use a third-party to administer the program or whether this statement is related to community solar project ownership. Community solar projects should be owned by competitive third-party entities in order to benefit Arizona customers through the use of private capital to develop projects. There are several important components that define the “structure” of a community solar program and are not addressed in Staff’s memorandum and proposed order, including transaction and crediting structure, program size, permitted resources, procurement structure, project maturity requirements, ownership, bill credit term, guaranteed savings, eligible subscribers, the treatment of unsubscribed energy, and all elements of consumer protection other than how the program interfaces with the utility disconnect moratorium. These components were discussed at length in our last filing on January 27, 2023.[14] (2) Location of the Community Solar Program Staff recommends that “[c]ommunity solar energy should be generated within a participating regulated electric utility company's service territory.”[15] We agree, and further recommended that individual community solar projects be connected to that utility’s distribution system. (3) Percentage Carve-Out for Low-Income Customers The joint signatories have previously recommended a low- and moderate-income (LMI) carve out of 20%, based on the models we have seen created in other markets. However, we can support an LMI carve-out of thirty (30) percent, as recommended by Wildfire. This aligns with neighboring states, such as New Mexico, which have recently opened third-party community solar programs. Staff recommends that the remaining project capacity not reserved for low- and moderate-income customers be “limited to non-profit (including faith-based organizations), schools, municipalities, extra small commercial, and small commercial customer classes.” This definition excludes residential customers. Decision No. 78583 clearly states that participating customers should include residential and low-income customers.[16] A recommendation that non-LMI residential customers be excluded from the program was never raised during the course of the working group process. Even residential customers who are not low-income cannot access rooftop solar if they are renters, live in a condo, or face other technical barriers to installing solar. A statewide community solar program should include all residential customers. (4) Whether the Program Should be part of an RFP Staff recommends use of a request for proposal (RFP) model for a community solar program in Arizona, without providing any details about how such a process could work. As discussed in our prior filings, states that use an RFP process for selecting community solar projects do so in order to select projects based on the benefits they deliver to participants and communities, not cost alone. Community solar programs need not rely on a price-based RFP procurement format to control project and/or program costs because project compensation is wholly determined by the value of Commission-approved bill credits paid to subscribers. (5) Must-take provision Staff states that a “must take requirement is not appropriate for Arizona’s community solar and storage program,” implying that utilities should be able to curtail community solar projects for any reason. Consistent with the precedent set in programs around the country, the signatories recommend against routine curtailment of power produced by community solar projects. There should be, of course, permissible instances during which the utility can curtail community solar production for emergency safety or reliability purposes. Like rooftop solar, community solar project subscribers derive value from their subscription in the form of bill credits only when power is produced and exported to the grid. Decision No. 78583 states, “Direct bill offsets may be considered for subscribers to produce savings in a structure substantially similar to that offered to rooftop solar customers.”[17] If a utility curtails community solar projects on a routine basis, it would unreasonably deny bill credits and savings to subscribers who sign up for the program and substantially differ from the structure through which rooftop solar customers experience savings.[18] Additionally, without predictable certainty regarding if and when projects will be producing energy, it will be impossible to secure financing to develop and build community solar facilities. The signatories are not aware of any community solar program anywhere else in the country that currently allows for routine curtailment by the utility. Utilities have stated that curtailment of community solar projects is necessary because negatively priced power is available, at times, on the market. In such instances, it is economic for utilities to curtail the highest-cost marginal resource in exchange for cheaper or negatively priced power on the market. Customers benefit when utilities curtail resources with high fuel costs or significant pollution impacts in exchange for cleaner, more affordable resources like solar. IOUs in Arizona do not curtail rooftop solar production, and yet they are able to appropriately manage the totality of resources on their system in order to provide cost-effective and reliable power to customers. We have recommended that a community solar program include a specific annual capacity allotment, and that utilities account for community solar project capacity in their long-term resource planning processes. This will make it easy for utilities to predict the amount of community solar resources that will be available to them and plan their operations and future resource procurement accordingly. We have attached a proposed amendment below as Attachment A. [1] Response to Staff Memorandum, filed in Docket No. E-00000A-22-0103 on July 29, 2022. See: https://docket.images.azcc.gov/E000020412.pdf?i=1673898931456. [2] Draft Program Proposal, filed in Docket No. E-00000A-22-0103 on August 26, 2022. See: https://docket.images.azcc.gov/E000020811.pdf?i=1673359840801. [3] Study of Community Solar Value Stack in Arizona, conducted by The Brattle Group, filed in Docket No. E-00000A-22-0103 on August 26, 2022. See: https://docket.images.azcc.gov/E000020793.pdf?i=1674487120887. [4] Response to Chairwoman Marquez Peterson’s Letter, filed in Docket No. E-00000A-22-0103 on September 9, 2022. See: https://docket.images.azcc.gov/E000021024.pdf?i=1674487120887. [5] Resource Comparison Proxy for Community Solar, filed in Docket No. E-00000A-22-0103 on September 9, 2022. See: https://docket.images.azcc.gov/E000021023.pdf?i=1674487120887. [6] Response to APS Program Proposal, filed in Docket No. E-00000A-22-0103 on October 7, 2022. See: https://docket.images.azcc.gov/E000021583.pdf?i=1673359840801. [7] The Potential Economic and Fiscal Impacts of Community Solar in Arizona, filed in Docket No. E-00000A-22-0103 on November 2, 2022. See: https://docket.images.azcc.gov/E000022238.pdf?i=1674487120887. [8] The Solar Coalition’s Amendment and Proposed Exceptions to Staff’s Memorandum and Proposed Order, filed in Docket No. E-00000A-22-0103 on November 4, 2022. See: https://docket.images.azcc.gov/E000022223.pdf?i=1674662938969. [9] Response to Staff Request for Comment on the Community Solar Policy Statement, filed in Docket No. E-00000A-22-0103 on January 27, 2023. See: https://docket.images.azcc.gov/E000023855.pdf?i=1677286561482. [10] Decision 78784 filed in Docket No. E-00000A-22-0103 on November 21, 2022. See https://docket.images.azcc.gov/0000208038.pdf?i=1673898931456. [11] Decision 78784 at pg. 11. [12] Decision 78784 at pg. 11. [13] Decision 78784 at pg. 11, Line 23. [14] Response to Staff Request for Comment on the Community Solar Policy Statement, filed in Docket No. E-00000A-22-0103 on January 27, 2023. See: https://docket.images.azcc.gov/E000023855.pdf?i=1677286561482. [15] Staff Memorandum and Proposed Order, filed in Docket No. E-00000A-22-0103 on February 24, 2023, Attachment A. [16] Decision No. 78583 filed in Docket No. E-01345A-21-0240 on May 27, 2022 at Page 11. See https://docket.images.azcc.gov/0000206888.pdf?i=1677813967352. [17] Decision No. 78583, May 27, 2022, Page 11. [18] Response to APS Proposal, Item 7. AriSEIA and other Solar Stakeholders filed a response to ACC Staff's memorandum calling for comment on five areas of community solar to be resolved in a March policy statement by Commissioners. This is in addition to the various litigated proceedings. You can see the full filing at the link above.
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The Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) non-profit trade association representing the solar, storage, and electrification industry, solar-friendly businesses, and others interested in advancing complementary technologies in Arizona. The group's focus is on education, professionalism and promotion of public policies that support deployment of solar, storage, and electrification technologies and renewable energy job growth and creation. |
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