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Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 RE: RLS-00000A-23-0251; Line Siting Rules Chairman and Commissioners, AriSEIA files these comments in response to the Memo filed to this docket by Hearing Division on August 20, 2025.[1] As a macro issue, AriSEIA is not aware of any statutory or administrative code basis for “recertification.” Projects should not be “recertified” for decades, especially with no formal process for doing so. This issue must be taken up in this rulemaking. All projects granted a CEC should be done so on a limited basis in which to actually build the project. The factors under ARS 40-360.06 will change over time. None of these factors are static. The total environment of the area, noise levels, wildlife habitat, etc. could all very likely be different decades later than they were when the CEC was granted. If a project is not built in a timely manner, those issues should be reevaluated by the Committee before any extensions are granted. That time limit should be included in this rules update. R14-3-201 The definitions of party and potential party should be modified. If someone has filed a timely notice to intervene, they should have the rights of a party until their intervention is denied with good cause. The definition of “legal representative” is also confusing as a representative under Rule 31.3(c)(5) is not necessarily a “legal” representative and is simply a representative. All defined terms should be capitalized through the rules. R14-3-204 More than 24 hours’ notice should be provided of Line Siting Committee meetings. The Committee should strive for the utmost notice, but not less than 3 business days. R14-3-207 There is no mention of a disclaimer of jurisdiction in Article 6.2 of Title 40 (the Line Siting statutes). Where does the authority to disclaim jurisdiction derive? If there is no statutory basis for it, it should not be in the Code. Further, the burden should not be on an intervenor to provide an affidavit as to the facts supporting the objection. It is an unfortunate reality that utilities (and other applicants) have an information asymmetry over other intervenors, including the public and nonprofit organizations. Additionally, ARS 40-360.05 grants intervention as a matter of right to the applicant, local governments, and domestic nonprofits. The Commission cannot circumvent statute via its own rules. The second sentence of (D) and all of (E) should be eliminated. Further, this section does not afford enough due process by which to grant a disclaimer. Objecting parties should be able to issue data requests to the would be applicant, question its witnesses, and offer testimony and other exhibits in opposition. Disclaimer should only be granted via hearing when there are objecting parties, contrary to (F)-(H). R14-3-210 Under A(5), it is not clear what documentation one would need to demonstrate compliance with Rule 38, as you would have a bar number with the Arizona State Bar. That bar number should be sufficient and you should not need to provide additional documentation like you would under Rule 39. It is also unclear why Rule 42 is mentioned here. The timeline for intervention under (E) should not be different than the timeline for intervenors under (A). It should just be 10 days for everyone. Also, the procedural order that sets the hearing should state the intervention deadline. Under (F), the Committee should still be required to provide due process, which should require an explanation as to why intervention was denied and a means to either appeal or be heard. As written, the rules specifically discriminate against national or regional nonprofit organizations. It is unclear how (G) is supposed to work. Do the rules permit adding parties after a hearing? Or the Committee is making legal determinations before a hearing? Everyone should have the same deadline to be a party and such determinations should be made only after the hearing. There should not be multiple rounds of hearings because local jurisdictions did not become a party at the appropriate time. This will just cause delay of what is already a lengthy process. If a city or county is impacted, they should get notice at the outset by the applicant and should apply for intervention 10 days before the hearing. The applicant should be required to notify all jurisdictions within a specified radius of any aspect of the project in advance of the hearing so they can participate from the outset. It is unclear why (H) is there when there is a separate section on disclaimers. R14-3-211 In (A), it is unclear to us who may be subpoenaed by the Commission. Is it all parties or only the applicant? In (B), why would anyone who is not a party be able to issue subpoenas and to whom? In (H), do the objections need to be in writing? (K)(2)(c) may be unreasonable. Requiring someone in Navajo or Mohave Counties, for example, to travel to Phoenix or Tucson for a deposition is unduly burdensome. R14-3-213 All transcripts should be made publicly available on the applicant’s webpage and electronically via the Commission’s website. R14-3-215 All Line Siting hearings should be recorded like other Commission proceedings and the recordings should be made available on the Commission’s website. Parties and public comment should be able to appear in person or remotely, at their discretion, and those arrangements should be made by the Commission or applicant. Regarding (F), the procedural order should also include any deadlines such as this or others. Exhibits should not need to be printed. All documents should be able to be filed and exchanged electronically. The Commission should also codify a discovery process for Line Siting cases here. R14-3-216 In (B), is there any requirement that both the chair and the hearing officer will be an attorney and have the relevant energy experience? (C) should specify when public comment will be taken, otherwise it is hard for the public to know when they need to attend or how long they will need to be present, which will drive down participation. We recommend holding it the first day of the hearing. In (D)(4), the witnesses should not appear as a panel. The Commission does not do that in rate cases and should not do that in Line Siting cases. It reduces accountability. (D)(6) is ambiguous. What is “material, relevant, nonrepetitive evidence”? If a party moves to admit an exhibit and an objection is not offered and sustained, the exhibit must be admitted. (F) should be revised as it is not clear that this includes representatives under the Rules of the Arizona Supreme Court 31.3(c)(5) and (6)). R14-3-218 Only parties should be able to request a continuance, not “potential parties.” The definitions should be modified, as suggested above. Similarly, only parties and the Committee should be permitted to take the tour. R14-3-219 (D) grants too much discretion to the presiding officer to exclude evidence. As mentioned before, if it is offered and no objection is sustained, it should be admitted. In (F), once an objection is ruled upon, the party should not be able to continue to raise it seeking a different result. Similarly, the Presiding Officer should not be able to waffle on an objection already ruled upon. Parties need to be able to rely on decisions made in the docket or in the hearing. R14-3-220 Transcripts should be made available, free of charge to the parties and the public in every Commission proceeding. The Commission should continue to make them available in Line Siting matters as they have done for years. (B) should state the “Presiding Office shall require” instead of “may.” Transcripts should be covered by the applicant in Line Siting and rate cases. If someone wants printed pages of a transcript in person the page number needs to be dramatically increased. R14-3-222 Does this mean that CECs will not be reviewed and voted on by the Commission unless requested by a party? R14-3-226 The Committee should also require the applicant to provide water impacts as water is part of the “total environment.” Thank you for consideration of these comments. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] [1] Hearing Division Memo, August 20, 2025, Docket No. RLS-00000A-23-0251, available here https://docket.images.azcc.gov/0000215068.pdf?i=1760395720620. 
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Joint Statement from Solar United Neighbors, Vote Solar, and the Arizona Solar Energy Industries Association
Arizona Corporation Commission Disappoints Solar Advocates, Siding with Utility Profits Tucson, Arizona - The Arizona Corporation Commission (ACC) today approved Tucson Electric Power’s (TEP) and UniSource Electric’s (UNSE) proposal to decrease Resource Comparison Proxy (RCP) rates for 2025, further undermining the opportunity to use solar energy to save money on utility bills for customers across Arizona. The Resource Comparison Proxy (RCP) is Arizona’s solar export rate, which determines how much solar customers are paid for the electricity they send back to the energy grid. Commissioners have the option to limit reductions to the RCP in order to avoid negatively impacting solar adoption, and have previously exercised this option during times of economic turmoil such as the COVID-19 pandemic. With the reduction approved today, utilities will pay less for the energy rooftop solar provides, which will ultimately discourage new installations and force the construction of costly new power plants that all customers will pay for through higher energy bills. Solar installations among TEP’s customers fell nearly 40% in 2024, and the ACC-approved reduction to solar rates will only accelerate this trend.[1] “Today’s vote is yet another gift to profit-driven utilities at the expense of communities,” said Kate Bowman, Senior Regulatory Director at Vote Solar. “By cutting the value of solar, the ACC is making it harder for Arizonans to invest in solar—just as these same households are facing rising costs of living and utility bills and a phase out of the federal solar tax credit.” “This decision demonstrates a troubling pattern of behavior by this Commission," said Adrian Keller, Arizona Program Director at Solar United Neighbors. "The ACC consistently approves utility requests while neglecting the ratepayers they are supposed to protect. Following their approval of APS's identical proposal last month, today’s decision continues to penalize families who invest in solar.” “The Commission likes to say it is for an ‘all of the above’ energy strategy, yet its decisions paired with federal policy changes continue to single out renewables punitively,” said Autumn Johnson, Executive Director of the Arizona Solar Energy Industries Association (AriSEIA). “This Commission has imposed solar only fees, continues to reduce the solar export rate, and is trying to eliminate our renewable standards (REST rule), all while the federal government has cut tax credits, imposed extreme tariffs, and enacted a de facto moratorium on all renewables development.” Utilities earn a rate of return on every dollar they spend building power plants and transmission lines. When homeowners invest their own savings to install rooftop solar, they help avoid these expensive projects, saving money for all customers—which is exactly why utilities oppose technologies that threaten their bottom line. Shortly before requesting a 10% reduction to the rate paid to solar customers for exporting electricity, TEP filed a rate case asking Commissioners to increase the rates families pay to purchase electricity from the utility by 14%. Reducing solar export rates will ultimately eliminate jobs, weaken our grid, and force utilities to build new energy generation—a cost that will be passed down directly to customers. On the other hand, increasing access to solar has proven to help families mitigate rising power bills and deliver critical power during record-breaking heat and peak demand. At a time when energy bills are soaring, the Commission should be making solar more affordable, not less. Arizonans deserve the freedom to choose solar power to reduce their bills and protect against rate hikes. Instead, the ACC continues giving utilities tools to discourage renewable energy adoption and maintain their monopoly control. About Solar United Neighbors Solar United Neighbors is a national nonprofit organization that helps people go solar, join together, and fight for their energy rights. SUN's Arizona program advocates for policies that expand solar access and protect solar rights for all Arizonans. About AriSEIA AriSEIA is an Arizona nonprofit trade association working on renewables policies across the state. AriSEIA’s mission is to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. About Vote Solar Vote Solar is a nonprofit advocacy organization working to advance state-level policies that make solar and clean energy solutions accessible to all. Since 2002, Vote Solar has worked to build a just and equitable energy future by leveraging deep policy expertise, strategic partnerships, and public engagement. In the face of powerful opposition, Vote Solar champions bold solutions that expand clean energy access, drive investment in frontline communities, and accelerate the transition to 100% clean energy. [1] According to TEP’s most recent published solar installation data, comparing the first three quarters of 2023 with the first three quarters of 2024. Available at: https://arizonagoessolar.org/tucson-electric-power-tep/ AriSEIA filed nearly 1000 pages of exhibits in the Sulphur Springs rate case in which the utility seeks to undermine the contract rights of solar customers. AriSEIA also filed a response to SSVEC's attempt to strike our testimony on their underpayment to solar customers, an issue we have been raising for almost two years.
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. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Opposition to Repeal of the Electric Energy Efficiency Standards Rules in Docket No. RE-00000A-24-0025 Dear Chairman and Commissioners: The Arizona Solar Energy Industries Association (AriSEIA) respectfully submits these comments in opposition to the wholesale repeal of the electric energy efficiency standards rules in the above-referenced docket. At the very least, please preserve the sections of the rule that pertain to filing Demand Side Management (DSM) plans R14-2-2405 through R14-2-2410, as well as any other provisions that Hearing Division deems necessary to DSM plan submission and approval. Arizona is experiencing significant load growth and has repeatedly set new system peak records.[1] In this environment, demand side management programs are more critical than ever. Energy efficiency and demand side management resources provide cost-effective capacity, reduce reliance on volatile wholesale markets, and enhance reliability during times of peak demand. Arizona Public Service (APS) alone meets 14% of demand from DSM program, that is equal to the share of coal in their portfolio and exceeds the amount of utility scale renewables on their system.[2] APS has more than 2 GW of DSM on their system.[3] Eliminating the framework that enables these programs would increase costs for ratepayers and threaten grid stability. We are particularly concerned about the proposed repeal of R14-2-2405 and the immediately following sections. These provisions are where utilities currently house their demand side management plans, including their virtual power plant (VPP) programs. The Commission has already twice voted to uphold these programs as valuable and cost-effective resources. These programs deliver capacity for less than market purchases and help utilities manage peak load reliably. The Commission itself ordered the APS VPP pilot program in Docket No. E-01345A-22-0144, following review in a contested rate case and a year-long dedicated stakeholder process. The second year of funding for that program is now included in APS’s pending DSM plan in Docket No. E-01345A-23-0088. Repealing the DSM rule sections that house these plans could undermine the ability of the Commission and stakeholders to continue building on programs that have already been vetted and approved. Energy efficiency and demand side management programs are not abstract policy ideas. They are in operation today, they are working, and they are providing measurable value to Arizona utilities and ratepayers. They save money, improve reliability, and ensure that Arizona can meet the challenges of rapid growth. For these reasons, AriSEIA urges the Commission to reject the wholesale proposed repeal of the electric energy efficiency standards rules. Preserving at least portions of these rules, especially the DSM provisions, is essential to maintaining affordable, reliable, and resilient power for Arizona families and businesses. Thank you for your consideration. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] [1] Arizona Corporation Commission, Arizona Electric Utilities Set Record High Demand Again; Demand Soars Above Original Forecasts for 2025, August 8, 2025, available here https://azcc.gov/news/home/2025/08/09/arizona-electric-utilities-set-record-high-demand--again--demand-soars-above-original-forecasts-for-2025. [2] Arizona Public Service, Form 10-K 2024, December 31, 2024, p.5, available here https://s22.q4cdn.com/464697698/files/doc_financials/2024/ar/PNW-2024-12-31-10-K.pdf. [3] Arizona Public Service, 2023 Integrated Resource Plan, November 2023, p.26, available here https://www.aps.com/-/media/APS/APSCOM-PDFs/About/Our-Company/Doing-business-with-us/Resource-Planning-and-Management/APS_IRP_2023_PUBLIC.pdf?la=en&hash=F601897086C6836F7FD33C5C2F295F47. AriSEIA Files Testimony Opposing SSVEC's Attempt to End Grandfathering for C&I DG Customers9/8/2025 AriSEIA filed testimony today opposing the settlement agreement entered into in the Sulphur Springs rate case with Arizona Corporation Commission (ACC) Staff and the IBEW union. The settlement agreement violates federal law by allowing the export rate for solar to fall below avoided cost. It eliminates grandfathering for customers that already have solar on their businesses with no warning. And it eliminates the 10-year lock in for new solar customers, even though every other utility provides it. The settlement agreement in not in the public interest.
AriSEIA filed a neutral response to the Trico settlement agreement. AriSEIA is neutral on the settlement because:
AriSEIA filed surrebuttal testimony in the Sulphur Springs (SSVEC) rate case, We oppose the settlement agreement entered into between the Arizona Corporation Commission (ACC) and SSVEC and continue to make the following recommendations:
If the Commission adopts the proposed settlement, The Commission should make the following modifications:
The Arizona Corporation Commission is updating their practice and procedure rules that govern how the Commission conducts itself in rulemakings and adjudicated cases. These rules cover everything from transcripts to public comments to ex parte to how to ask for a rehearing or file a complaint against a utility. You can read AriSEIA's detailed comments at the link above.
Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Rulemaking (RE-00000A-24-0026) — Proposed Modifications to the Renewable Energy Standard and Tariff (REST) Rules Chairman and Commissioners, Vote Solar, the Arizona Solar Energy Industries Association (“AriSEIA”), and Solar United Neighbors appreciate the opportunity to provide comments regarding modifications to Arizona Administrative Code (“A.A.C.”) Title 14, Chapter 2, Article 18 (the “REST Rules”). The REST Rules have provided a framework for investment in Arizona’s energy economy for nearly 20 years. Any changes to the REST rules will have broad and profound implications for affordability, economic development, and clean energy investments in Arizona. Background The REST has long served as the foundational policy framework guiding clean energy development and investment in Arizona. Implemented by a majority republican Commission in 2006, the REST established a target for utilities to source 15% of their electricity from renewables by 2025. Bipartisan support for the clear and incremental goals established in the REST rules supported a stable, pro-business environment that has attracted billions in investment, created jobs, and positioned Arizona as a leader in the solar economy. Arizona now ranks 4th in the nation for total solar capacity and 6th in the nation for solar employment, with over 9,700 jobs in the sector.[1] State energy goals have evolved in the years since the REST was created. Today, 36 states have established clean and renewable standards or goals and 21 states have set target dates for reaching 100% clean energy.[2] As the technology supporting an affordable and reliable transition to clean energy has advanced, state goals have adapted: 12 states now have established energy storage targets.[3] Given Arizona’s considerable progress towards a clean electric grid, it is worthwhile to revisit the REST Rules and evaluate whether changes are warranted to ensure it addresses the challenges that Arizona’s residents, businesses, and utilities face today and remains relevant and useful into the future. However, a wholesale repeal of the REST Rules, as proposed in Staff’s July 31, 2025 Memorandum, will destabilize Arizona’s energy economy and have profound impacts on consumers and businesses across the state. We urge the Commission not to abdicate its responsibility for charting a course towards an affordable, reliable, and clean energy future for Arizona by repealing the REST Rules. Cost and Affordability Renewable energy is now the cheapest generation resource available. Solar and wind generation are less expensive than building new fossil fuel plants, but Arizona utilities plan to continue investing in gas plants and running outdated coal plants that lock customers into higher costs for decades. Even when solar is unsubsidized it is the most cost competitive for of electricity generation. Solar is the least cost AND fastest to deploy resource.[4] The levelized cost of a solar plant in Arizona is less than the cost of a new gas plant, in part because solar energy generation has no fuel costs and minimal ongoing operations and maintenance costs. The investments made to meet the REST goals benefit consumers by protecting them from the volatile cost of fossil fuels, especially in recent years, and stabilizing energy prices. Ratepayers have reaped the benefits: according to a 2024 Strategen study, the REST delivered over $1.5 billion in net benefits to the public and more than $469 million in savings to APS and TEP customers.[5] Press releases and public statements issued by the Commission, such as vote explanations at the February 6, 2024 Open Meeting, include inaccurate or unsubstantiated claims about ratepayer costs from the REST.[6] When evaluating the costs and benefits to ratepayers, it is important to consider not only the capital cost of energy resources built to achieve the REST standards, but also the alternative cost of non-renewable resources that would have been built absent the REST Rules and the long-term savings to ratepayers from the development of renewable energy resources that have no ongoing fuel costs. A fair and balanced analysis must also consider the benefits associated with the lessened health and environmental impacts of renewable resources, which produce no pollution. Without this context, statements about the cost of the REST are meaningless. State Economic Impacts The REST Rules created a stable, pro-business environment that has made Arizona a destination for clean energy investment, yielding decades of economic benefits across the state. Renewable energy projects generate substantial lease income, tax revenue and job creation, often in rural communities. For example, a single 200 MW solar + 200 MW storage project in Maricopa County is estimated to yield $26.2 million in tax revenue and $349.7 million in economic activity. A similar project in Yuma County is projected to generate $25.8 million in taxes and $213.4 million in economic benefits, including hundreds of local jobs.[7] The REST Rules have also provided ancillary economic benefits as businesses that invest in and rely on the clean energy technologies of the future chose to locate in Arizona. According to an analysis by the Western Way, 11 manufacturing and facility expansion projects in the clean energy sector brought $6.1 billion in labor income to the state economy.[8] Over the last year, new or expanded facilities for manufacturing clean energy technologies contributed 2.7% of state GDP.[9] Many of the largest and most successful U.S. companies have 100% renewable energy goals[10] and are actively seeking to do business in states that will facilitate seamless access to clean energy. Large employers such as Meta, Google, Intel, PayPal, and Apple have operations in Arizona that rely on clean energy to meet corporate sustainability goals. LG Energy Solutions and others have cited solar potential as a reason for major investments. Weakening or eliminating the REST undermines Arizona’s competitive advantage in attracting these companies and the jobs they bring. Disinvestment in Arizona’s Energy Future Without the guiding goals set by the REST, Arizona’s utilities may not make investments in the renewable energy resources needed to support a clean, affordable, and reliable grid in years to come. Having largely achieved the modest 15% renewable energy goal set by the REST, Arizona’s utilities are not committing to scale development of renewable energy resources to continue meeting or exceeding this goal as load growth accelerates. Recent integrated resource plans outline a continued reliance on fossil fuel resources, including the conversion of coal plants to gas and the extension of coal plant operations, and APS recently abandoned its near-term clean energy targets and delayed retirement of coal plants it previously determined are no longer economic for customers.[11] APS currently reports only 19% of its energy mix from renewables,[12] and TEP stands at 22%.[13] These figures fall short of the 15% threshold when considering growth expectations and cast doubt on assertions that the standard is no longer necessary. The repeal of the REST Rule also sends a destabilizing signal to investors, developers, and corporate buyers who are considering energy development projects in the state. It suggests Arizona may no longer be a reliable place to conduct business in clean energy, especially as neighboring states pursue more ambitious goals. The impact is already visible: counties such as Yavapai[14] and Mohave[15] are considering or enacting de facto moratoriums or extreme caps on solar development, often citing the repeal of the REST as justification. In a state with just 15 counties, this trend introduces barriers and red tape that slow progress towards the grid of the future, posing serious risks to grid affordability, reliability, and energy independence. Certainty in the Market for Renewable Energy Credit (RECs) The REST Rules are the only policy framework clearly defining RECs in Arizona, and the regulatory claim to renewable energy usage that RECs represent. RECs are the fundamental tool that entities with clean energy goals use to track compliance with clean energy targets and ensure they have secured a valid claim to clean energy. Put simply, RECs protect entities looking to access clean energy from misleading claims, greenwashing, and fraud. Without a clear, enforceable definition of RECs in A.A.C there is no reliable mechanism to ensure renewable generation is properly accounted for or that it can be uniquely attributed. This opens the door to double counting, where RECs generated in Arizona are counted towards multiple purposes because there is no clear definition. As a result, states, federal entities, or companies with clean energy goals may choose to avoid purchase of RECs from Arizona (and third-party certification providers may be unwilling to recognize them), which will further disincentivize investment in new clean energy resources across the state. Deficiencies Identified in Staff’s July 31, 2025 Memorandum Staff’s July 31, 2025 Memorandum recommends repealing the REST Rules without providing any substantive information about how this change would impact consumers and the economy, the costs and benefits, or why a repeal of the REST is necessary or even desirable. Most concerning, Staff’s Memorandum includes only a passing reference to the comments filed by nearly 30,000 members of the public. The overwhelming majority of the public’s comments are supportive of maintaining the REST in its current form or expanding state renewable energy goals. While we respect Elliott Pollack & Co., whose work we also rely upon, the economic memorandum filed by Staff on August 21, 2024, contains no quantitative analysis. It also fails to identify industry stakeholders or their employees as affected parties, despite the clear implications for both. Conclusion We strongly urge the Commission to reject Staff’s Memorandum. Instead, we suggest that the Commission revisit previous efforts to modernize the REST Rules to reflect Arizona’s current opportunities, technological advancements, and economic goals, as reflected in Docket RU-00000A-18-0284. This is a pivotal moment for Arizona’s clean energy leadership. Eliminating the state’s only enforceable renewable energy standard, without a clear replacement, introduces uncertainty, undermines accountability, and jeopardizes both voluntary and regulatory progress. Further, repealing a rule without substantive support in the record is arbitrary and capricious. We urge the Commission to retain the REST and use it as a foundation for building Arizona’s energy future. Thank you for your consideration. Respectfully, Autumn T. Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) [email protected] 520-240-4757 Adrian Keller Arizona Program Director Solar United Neighbors (SUN) [email protected] 602-610-9055 Kate Bowman Interior West Regulatory Director Vote Solar [email protected] 703-674-8637 [1] Solar Energy Industries Association (SEIA), Arizona Solar State Spotlight, June 2025, available here https://seia.org/wp-content/uploads/2025/06/Arizona.pdf. [2] Database of State Incentives for Renewables and Efficiency (DSIRE), Renewable and Clean Energy Standards, April 2025, available here https://ncsolarcen-prod.s3.amazonaws.com/wp-content/uploads/2025/04/RPS-CES-April2025.pdf [3] Database of State Incentives for Renewables and Efficiency (DSIRE), Energy Storage Targets, September 2024, available here https://ncsolarcen-prod.s3.amazonaws.com/wp-content/uploads/2024/09/DSIRE_Storage_Targets_September_2024.pdf [4] Lazard LCOE, June 2025, available here https://www.lazard.com/news-announcements/lazard-releases-2025-levelized-cost-of-energyplus-report-pr/. [5] Strategen, Arizona REST 2020 Progress Report, Mar. 3, 2020, available here https://www.ceres.org/resources/reports/arizona-renewable-energy-standard-and-tariff-2020-progress-report. [6] Arizona Corporation Commission, ACC Directs Staff to Draft Rules to Repeal Renewable and Energy Efficiency Mandates, February 2024 available here https://www.azcc.gov/news/home/2024/02/07/acc-directs-staff-to-draft-rules-to-repeal-renewable-and-energy-efficiency-mandates Arizona Corporation Commission, Chairman O’Connor and Commissioner Thompson Act to Sunset Energy Surcharges that Have Cost Arizona Ratepayers Nearly $3.4 Billion Dollars, February 2024, available here https://www.azcc.gov/news/home/2024/02/08/chairman-o-connor-and-commissioner-thompson-act-to-sunset-energy-surcharges-that-have-cost-arizona-ratepayers-nearly-3.4-billion-dollars. [7] AriSEIA submitted over 450 pages of studies supporting the economics of renewables in Arizona. All such studies, including our county economic impact studies can be found with our October 1, 2024 comments filed in this docket, available here https://docket.images.azcc.gov/E000038867.pdf?i=1754888599487. [8] The Western Way: Arizona’s Pro-Business Climate Drives New Jobs and Workforce Needs, available here https://www.thewesternway.org/tww-blog/2023/11/2/report-release-arizonas-pro-business-climate-drives-new-jobs-and-workforce-needs. [9] Rhodium Group & MIT CEEPR, Clean Investment Monitor Database. Available at: https://www.cleaninvestmentmonitor.org/database. [10] See Re100 members, Available at: https://www.there100.org/re100-members. [11] AZ Central, APS to walk back clean energy goals, drawing criticism from environmentalists, available here https://www.azcentral.com/story/money/business/energy/2025/08/07/arizona-utility-will-walk-back-its-clean-energy-goals/85534895007/. [12] APS SEC Form 10-K, December 31, 2024, P.5, available here https://d18rn0p25nwr6d.cloudfront.net/CIK-0000764622/4703b2d6-ddea-44b3-85bf-ef9814d7d691.pdf. [13] TEP 2024 Energy Mix, available here https://www.tep.com/our-energy-mix/. [14] Yavapai County Planning & Zoning Ordinance, Section 608. [15] Mohave County Ordinance No. 2024-10. |
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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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