AriSEIA filed its final brief in the APS rate case today. The brief addresses false and misleading statements in APS' opening brief related to VPP, microgrids, community solar, E-32L SP, and its solar cost of service study. You can read the brief at the link above. A decision is expected in Q1.

AriSEIA filed its opening brief today in the ongoing APS rate case. ​AriSEIA and SEIA's primary objectives in this rate case are to establish a Bring Your Own Device ("BYOD") program to leverage private investment in behind the meter batteries to lower costs for all ratepayers, stop APS' expansion into customer-sited microgrids, revise the battery-supporting E-32 and R-TECH tariffs, establish new and recalculate existing EV tariffs and demand charges, reject APS' solar cost of service study, and reconsider the Commission's community solar policy statement.

There is a common misconception that solar projects do not contribute to the economy nor generate tax revenues for local governments. The report showed that in the first year during construction an estimated $1.1 million in tax revenues and 302 jobs would be created in the local economy from one sample project. In addition, over the life of the project, more than $28.1 million in tax revenue would be generated by personal property tax on equipment. These taxes would directly benefit the county, fire districts, school districts, and other special districts such as flood control, library, and education districts. All totaled, the example solar project would create over $442.5 million in economic activity within Mohave County during construction and 40 years of operations. Again, this is all from just one single project. Additional projects would result in proportional, additional revenue.

​If you currently have solar on your home or you hope to someday have solar on your home, ACC Commissioners need to hear from you and soon. This is docket number 14-0023 and you can attend the meeting in person at 10 a.m. on Oct. 11 at 1200 W. Washington St. in Phoenix and/or you can call or email Commissioners to tell them not to re-open the decision they already made on solar and renege on their commitment to 270,000 people in the State of Arizona. The contact information for every Commissioner can be found at azcc.gov/contact. In Arizona, Commissioners are also elected statewide and choices they make that impact your pocketbook ought to be remembered on election day. 

FOR IMMEDIATE RELEASE

Arizona Corporation Commission Decision Creates Economic Uncertainty for Rooftop Solar 
Solar advocates criticize ACC's decision.

​WATCH Our Press Conference Here

Phoenix, Arizona — Yesterday, the Arizona Corporation Commission (ACC) held a meeting to discuss the value of solar. The agenda included a vote on reopening the Value of Solar proceeding, whether to change the 10-year buyback rate lock-in period for solar customers and the rule limiting the reduction in buyback rates to no more than 10% per year, and reversing course on the grandfathering of legacy net metering customers. Thousands of people wrote to the Commission, and dozens provided oral testimony during the meeting, overwhelmingly opposed to the ACC reopening the value of solar proceeding or increasing the step-down rate. Those in opposition included solar homeowners, solar workers, clean energy advocates, ratepayer advocates, and every regulated utility in the state.

The Commission decided not to re-open the Value of Solar case, which dictates how solar owners who installed in 2017 or later are credited for the surplus energy they contribute to the grid. However, the Commission did vote to open a new docket to re-evaluate the 10% step-down limitation and lock-in period for future solar customers. 

The original 2017 Value of Solar decision, reached after a lengthy evidentiary hearing and extensive deliberation and compromise, was designed to ensure predictable compensation for solar owners while providing stability to Arizona's rooftop solar market. Current solar customers will maintain their rates. 

Autumn Johnson, Arizona Solar Energy Industries Association (AriSEIA), said, "We are very disappointed in the decision to open a new proceeding on the value of solar. Even opening the docket plunges the market into uncertainty. The new hearing to design a rate case for future customers could have a lasting and detrimental impact on both the solar industry and consumers. Solar is not just a source of clean energy; it's a driver of economic growth, job creation, and energy independence. It's essential to remember that the solar industry has been a significant contributor to Arizona's economy, providing thousands of jobs and attracting investments that benefit local communities."

While the ACC did not re-open the export rate proceeding today, the potential changes could still substantially reduce compensation for solar energy and erode critical protections for homeowners investing in solar power. The step-down limit and lock-in period give homeowners predictability about the compensation they will receive for energy exported to the grid, which is critical when deciding to invest in solar. Changing these rules would directly impact the Arizona solar industry during a period of heavy federal investment in clean energy. 

“We're deeply concerned that any changes to how solar owners are credited for their extra power will jeopardize the future of rooftop solar in Arizona. Without the assurance of stable and predictable savings, many Arizonans will lack the confidence to go solar. Low-income and historically disadvantaged communities, especially, will be unable to access solar savings. The decline in rooftop solar growth would harm all ratepayers since rooftop solar creates a more affordable, efficient, and reliable power grid for everyone. It's crucial that we continue to work together to ensure a fair and equitable energy future with rooftop solar at the cornerstone,” said Adrian Keller of Solar United Neighbors.

Prior to the meeting, stakeholders hosted a webinar and press conference to shed light on the need to maintain the established rates solar customers are paid by their utility for the extra power they provide to the grid. Experts from Vote Solar, AriSEIA, and Solar United Neighbors provided comments during the ACC meeting. 

"It's disheartening to witness some Commissioners actively seeking to undermine the value of distributed generation and disrupt the stability that consumers have come to rely on. We firmly believe in the value of distributed generation, like rooftop solar, as a crucial component of a clean and resilient energy future. We'll remain steadfast in our commitment to advocate for policies that prioritize the interests of consumers, the growth of renewable energy, and the protection of energy independence. We are proud of the thousands of people who sent in comments and the dozens who testified against these harmful decisions. We will work together in the new hearing to ensure equitable access to clean energy solutions.” said Kate Bowman, Vote Solar. 

Commissioners Nick Myers, Jim O'Connor, and Kevin Thompson all voted in favor of the new proceeding. Commissioners Lea Márquez Peterson and Anna Tovar voted against reassessing the stepdown and lock-in rates. The dates for the new hearing are forthcoming, with the six-month proceeding to take place next year. 

###

For media inquiries, interviews, or further information, please contact:
Autumn Johnson
autumn@ariseia.org
520-240-4757

Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) trade organization and the state affiliate of the Solar Energy Industries Association (SEIA). AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. We advocate for sustainable job creation and encourage utilization of Arizona’s greatest natural resource, the sun.

Solar United Neighbors is a 501(c)3 nonprofit organization that works in Arizona and nationwide to represent the needs and interests of solar owners and supporters. Solar co-ops are part of the organization’s mission to create a new energy system with rooftop solar at the cornerstone. Solar United Neighbors holds events and education programs to help people become informed solar consumers, maximize the value of their solar investment, and advocate for fair solar policies.

Vote Solar is a 501(c)3 non-profit organization. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar works to remove regulatory barriers and implement key policies needed to bring solar to scale. Vote Solar works to realize a 100% clean energy future through a solutions-driven, people-first approach. ​

Mohave County Supervisors
700 W. Beale Street
Kingman, AZ 96401
 
RE: Opposition to the Resolution Implementing the Moratorium on the Designation of the E (Energy Overlay) Zone

Dear Chairman and Supervisors,

The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We urge you to vote NO on the moratorium on renewable energy projects in Mohave County at the Board of Supervisors meeting on October 16, 2023.

Economic Benefits. This moratorium will affect the county’s opportunity to benefit from the tax revenues of these projects which could address some of the county’s potential budget deficit issues. In August 2023, the Board voted for a hiring freeze until plans could be made to address the County’s potential $18.5 million deficit.[1] The County is considering an 18% budget cut that would affect, “one-in-five county employees” according to the County’s Chief Financial Officer.[2] Utility scale solar projects could help the County avoid the economic difficulties from the necessary austerity measures it will need to take to address this budget deficit.

For example, constructing a 100 MW utility scale project, depending on equipment costs, labor costs, financing costs, and other federal incentives, could cost between $100 - $200 million. The tax revenue from this project using the standard formula of Property Tax Revenue = Assessed Property Value × Property Tax Rate, could be between $1.25 – 2.5 million a year. If we then assume that the following projects: White Hills (450 MW), Mineral Park Solar (275 MW), and Leo Solar (300 MW), all projects proposed on public lands in Mohave County, being considered by the BLM, were on private property, the county could easily collect between $12.8 to $25.6 million per year in tax revenues. This would essentially solve the County’s budget deficit issues.

AriSEIA did commission a study by Elliott D. Pollack & Company to assess the benefit to the County of a sample solar + storage project. The study is attached and found that the total economic impact of a single project was $442.5 million in economic impact countywide. The fiscal or tax impact of a single project to the County would be nearly $31 million.

Low Water Usage. The draft of the resolution implementing the moratorium, incorrectly cites the study by Kahled Hasan, et al, Effects of Different Environmental and Operational Factors on the Solar Performance: A Comprehensive Review,[3] to justify the statement, “WHEREAS a significant amount of water and other resources are necessary to maintain solar panels in desert and arid environments.” In the Kahled et al. study, the researchers attempt to understand the environmental conditions that may affect the performance of solar systems during their operational lifecycle by conducting a review of the academic literature on the topic. While their study shows that dust and  humidity do affect the performance of solar systems, they show that the use of hydrophobic (water repelling) and hydrophilic (water dispersing) coating materials for the panels help clean them by sweeping away all the dirt during a rain. While the study suggests that sprinkling water on the solar modules helps reduce their temperature thereby improving performance, it does not discuss how much water is needed to perform this. In fact, the study suggests that properly tilted solar modules with the necessary cooling and self-cleaning material would require as little water as possible during their lifecycle. In fact, operators of solar farms do not wash the panels, as it costs more to do than the benefit obtained.

A study from researchers at the Brookhaven National Laboratory, shows that when compared to conventional power generation technologies such as coal and natural gas, solar actually uses far less water during its lifecycle. That study looked at the lifecycle uses of water of  different generation technologies across the United States and concluded that solar and wind are the best options for conserving water supply, when compared to coal, nuclear, oil/gas, and biomass technologies.[4]

Another study by researchers at the National Renewable Energy laboratory (NREL), estimated both the water withdrawal and consumption of electricity generating technologies. Again, they found that solar and wind technologies use less water than their counterpart energy technologies. This study looked at the use of water through the entire lifecycle of the technology from component manufacturing to fuel acquisition to power plant operation and decommissioning, and concluded that the water used by thermoelectric plants, such as coal, oil/gas, and nuclear for water cooling still dominate the entire water value chain in electricity production.[5]

Panel Safety. The draft resolution states that the “impact of these renewable energy projects on the local population and environment over a long period of time is unknown.” This is not the case. The long-term impacts of some renewable energy technologies such as solar and wind, on host and surrounding communities have been extensively studied in the United States and other parts of the world. One such study on the environmental impacts during the installation and operation of large-scale solar power plants studied these effects with respect to land use, climate, geohydrological resources, and human health in comparison to traditional power systems.[6] They found that solar causes less exposure to hazards like mercury, cadmium, and particulate matter.

Further, risks of site contamination are much less than for most other industrial uses because solar technologies employ few toxic chemicals and those used are present in very small quantities.[7] Testing shows that silicon and cadmium telluride (CdTe) panels are both safe to dispose of in landfills and are also safe in worst case conditions of abandonment or damage in a disaster.[8] Multiple sources report that most modern solar panels (both crystalline silicon and cadmium telluride) pass the Toxic Characteristic Leaching Procedure (TCLP), which is a test method used to determine whether a waste is a toxic hazardous waste.[9]

Interconnected Grid. During the public hearing meetings on August 7, 2023, and September 5, 2023, some residents and other stakeholders raised the issue of the location of these large utility scale solar projects in Mohave County. They were specifically concerned about the fact that the power generated from the solar farms may not be used by residents of Mohave County. This is a misunderstanding of how the U.S. electric power grid operates and how electricity is regulated at the Federal and State levels. Utility scale solar projects can only be located in areas where land is plentiful and the solar resource – the sun – is abundant. This makes Arizona a good location for these projects. In addition, once a generation asset is connected to the transmission system, there is no way of determining which electrons go to a specific consumer. This is because electricity takes the path of least resistance. Hence there is no way of knowing if the electricity used by residents in Mohave County was generated in Mohave County. The important issue is that there should always be enough capacity on the grid to meet the demand in real time, which is consistently changing.  If this is not the case, the reliability of the grid could be called into question.

For example, UNS Energy Inc. (UNSE) owns a total of 291 MW of installed thermal capacity from three natural gas generation plants. Only Black Mountain is in Mohave County, with Valencia and Gila River projects located in Nogales and Maricopa respectively. UNSE also purchases about 36% firm capacity through wholesale market power purchase agreements (PPA) to address summer peaks, and also purchases over 89.4% of its renewable energy resources through PPAs with third parties.[10] This is similar to Mohave Electric Cooperative (MEC), which is a member of the Arizona Electric Power Cooperative (AEPCO). AEPCO is the generation and transmission (G&T) co-op utility for Mohave and six other distribution co-ops in Arizona, New Mexico, and California. While MEC owns two solar farms in southeast Fort Mohave, AEPCO, from which it purchases most of its electricity, owns generation assets throughout Arizona and California. This means that Mohave County residents are consuming electricity generated in other counties in Arizona and even in California. The interconnected nature of the US electric power grid is a strength. If a major generation plant in Mohave County fails, its residents can be rest assured that they have access to power from Nevada, California, New Mexico, and other states in the west.

Environmental Impact Statements. The draft of the resolution stated that “additional information and research are needed to determine the allowable groundwater usage and suitable areas for large projects such as solar, wind, and geothermal. The location of a facility that uses water, while on the surface may fit the area and general plan, may overuse water and other resources in the groundwater basin.” The draft went on to refer to the environmental impact statement on the Desert Sunlight Solar Farm, one of the largest solar farms in the country located on the California Desert Conservation Area, to justify that claim. This is incorrect.

The California Desert Conservation Area is a vast ecosystem located in Southern California managed by the BLM. Based on the environmental impact statement, the BLM amended the “California Desert Conservation Area Plan (CDCA Plan) to allow for solar energy and of a right-of-way (ROW) grant to lease” the land to the developers of the project, which was commissioned in 2015. In fact, according the BLM, many of the adverse impacts of the projects “to biological resources, cultural resources, land use, visual resources, hydrology, water quality, and water use,” were adequately “avoided or substantially reduced based on compliance with applicable laws, ordinances, regulations and standards, and compliance with measures provided” in the impact statement.[11] Hence by conducting the environmental impact study, the effects of the project on wildlife, groundwater, and other resources were adequately known and appropriately mitigated. In fact, a 230 MW Battery Energy Storage System (BESS) was added to the Desert Sunlight Solar farm in August 2022.[12] Conducting an environmental impact study is standard procedure for utility scale solar projects.

For the reasons articulated above, please vote no on the draft resolution and reject a renewables moratorium in Mohave County.
​
Respectfully,
 
Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org


[1] River City Newspapers, County to Consider Exceptions to Hiring Freeze, Aug 30, 2023, available here https://www.havasunews.com/news/county-to-consider-exceptions-to-hiring-freeze/article_8cbda648-45fa-11ee-bf3b-1b533a671250.html.

[2] Today’s News Herald, As County Faces $18.5 Million Deficit, Departments Present Bleak View of Possible Cuts, September 20, 2023, available here https://www.havasunews.com/news/as-county-faces-18-5-million-decit-departments-present-bleak-view-ofpossible-cuts/article_fdd35ab2-581f-11ee-8a65-e36102c35e70.html.

[3] Kahled Hasan, et al, Effects of Different Environmental and Operational Factors on the Solar Performance: A Comprehensive Review, 10 ENERGY SCI. ENG. 656, 664-65.

[4] Vasilis Fthenakis, Hyung Chul Kim, Life-cycle uses of water in U.S. electricity generation, Renewable and Sustainable Energy Reviews, Volume 14, Issue 7, 2010, Pages 2039-2048, ISSN 1364-0321, available here https://doi.org/10.1016/j.rser.2010.03.008.

[5] J Meldrum et al 2013 Environ. Res. Lett. 8 015031, available here https://iopscience.iop.org/article/10.1088/1748-9326/8/1/015031/pdf.

[6] Damon Turney, Vasilis Fthenakis, Environmental impacts from the installation and operation of large-scale solar power plants, Renewable and Sustainable Energy Reviews, Volume 15, Issue 6, 2011, Pages 3261-3270, ISSN 1364-0321, available here https://doi.org/10.1016/j.rser.2011.04.023.

[7] Parikhit Sinha, Potential Environmental Hazards of Photovoltaic Panel Disposal: Discussion of Tammaro et al. (2015), available here https://doi.org/10.1016/j.jhazmat.2016.04.021.

[8] Human Health Risk Assessment Methods for PV Part 3: Module Disposal Risks, 2020, Report IEA-PVPS T12-16: 2020, ISBN 978-3-906042-96-1.

[9] Health and Safety Impacts of Solar Photovoltaics, NC Clean Energy Technology Center, North Carolina State University, May 2017.

[10] UNS Electric Inc, 2020 Integrated Resources Plan (IRP), available here https://docs.uesaz.com/wp-content/uploads/UNSE-2020-Integrated-Resource-Plan.pdf.

[11] US DOE, Office of NEPA Policy and Compliance, EIS-0048, June 24, 2011.

[12] Energy Storage News, 230MW BESS Comes Online at Bureau of Land Management Site in California, August 17, 2022, available here https://www.energy-storage.news/230mw-bess-comes-online-at-bureau-of-land-management-site-in-california/. 

United States Environmental Protection Agency,
Office of the Greenhouse Gas Reduction Fund, Solar for All,
Funding Opportunity Number EPA-R-HQ-SFA-23-01

RE: Letter of Support for Arizona’s Solar for All Application

To Whom it May Concern:

The Arizona Solar Energy Industries Association (AriSEIA) submits this letter in support of the Arizona Governor’s Office of Resiliency’s Solar for All Arizonans application for the maximum amount of $250 million. We were heavily involved in crafting this proposal. It reflects significant stakeholder engagement and the balancing of a myriad of needs within the State. Arizona currently faces numerous political and policy barriers to the implementation of clean energy, including solar, and federal support, such as through this grant, is critically needed. Solar is unique in that it is a zero carbon technology, but is also a tool that anyone can use to help reduce and control their electric bills in a time of what seems like endless rate increases. The programs in this proposal will help advance the clean energy transition in Arizona, while also reducing the energy burden for low income residents.

AriSEIA is a 501(c)(6) organization. We operate statewide to advance policies that support solar, storage, and electrification in Arizona. Our work spans all scales of solar and every level of government. We also regularly engage with our state’s major utilities and strive to promote professionalism in our industry with a commitment to consumer protection.

Importantly for AriSEIA, this proposal will also help stabilize the health of our solar industry, a vital industry to Arizona’s economy. Arizona has more than 350 solar companies that employ more than 8,000 people statewide. Given policy setbacks at the legislature and utility commission, paired with sky high interest rates, our residential solar installations are down nearly 30% and many companies are worried about laying off their employees and closing their doors. This grant will be a much needed lifeline to a sector that is essential for decarbonization.

Through this Solar for All proposal, the Arizona Governor’s Office of Resiliency seeks to bring a wide variety of stakeholders to the table to deliver on the promises of solar. The proposal is guided by the goal and vision of increased access to solar energy and increased energy affordability for Arizona families. We are committed to supporting and collaborating on this proposal to deliver the benefits of solar to all Arizonans.

Sincerely,
​
/s/ Autumn T. Johnson
Executive Director, AriSEIA
(520) 240-4757
autumn@ariseia.org

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: Value of Solar, Docket No. E-00000J-14-0023
 
Chairman and Commissioners,
 
The Arizona Solar Energy Industries Association (AriSEIA) is a party to the Value of Solar proceeding. That matter took three years to conclude, had approximately 35 parties, and resulted in a compromise. That compromise was adopted by an entirely republican Commission by a 4-1 vote. It is not a decision the solar industry is excited about. But it put in place a predictable framework by which homeowners, solar companies, and the utilities understood the regulatory landscape. As such, AriSEIA strongly opposes reopening the Value of Solar decision.
 
This Commission has stated multiple times that it supports “regulatory certainty.” Regulatory certainty should apply to all matters before the Commission, not only select matters. It is impossible to do business when the rules under which you operate can change on a whim. While reasonable minds can differ on policy, the institution has a responsibility to ratepayers, utilities, and the other stakeholders that appear before it, including the solar industry, to uphold its own rules, regulations, and orders. Decision 75859 states,
 
There were also concerns raised in regard to the possibility of dramatic changes in the export rate and resulting uncertainty. However, to allow the export rate developed using this methodology to change gradually, it will be updated annually after it is initially set in a rate case proceeding or separate rate design phase. At the time that the initial DG export rate is set, a Plan of Administration that provides the mechanism for annual modifications to that initial rate also will be adopted. The annual updates accomplished between rate cases should be formulaic exercises where the Resource Comparison Proxy Methodology and the Avoided Cost Methodology established in the rate case is updated; however the reduction to the compensation rate under the RCP methodology shall not exceed ten percent per year.[1]
 
Gradualism is referred to eighteen (18) times in the order. Multiple parties asserted the importance of making any changes gradually. “RUCO assert[ed] that the process of applying step-down schedules to the initially-established rate, and predictably and gradually lowering the rate, as market uptake increases and the cost of solar declines, will allow solar to ‘become a net benefit to all ratepayers - DG and non-DG customers alike.’”[2] “Staff assert[ed] that it is critical that the Commission's move away from the current framework be accomplished in a gradual manner.”[3] Further, the Commission’s order determined that the proposed methodologies “provide[d] a path for a gradual transition away from the current net metering model.”[4] The Commission stated, “[w]e believe that this will reduce the risk of dramatic changes to customers and the solar industry and is consistent with our interest in rate gradualism.”[5] Again, this adherence to gradual changes in rates or regulations is an essential component to regulatory certainty. Increasing the stepdown percentage would run counter to the positions of RUCO, Staff, and the Commission, as well as the stated goals in every rate case in recent memory.
 
Decision 75859 also locked in the export rate for a period of ten (10) years.[6] This period provides regulatory certainty for the homeowner. Homeowners make significant investments with private capital, into a generating resource that provides predictable power to the grid. Those investments can be tens of thousands of dollars. Those investment decisions take into account the export rate. It would be impossible to evaluate such a significant investment decision without certainty as to the Commission’s regulations for a period of time directly after the investment. Given the cost of the investment and the longevity of the system, ten (10) years is a very reasonable lock-in period.
 
There are more than 350 solar companies operating in Arizona. These companies employ approximately 8,337 people in Arizona alone and have contributed $16.8 billion dollars to the state’s economy, with $1.5 billion invested just last year.[7] Residential rooftop solar installations are down almost 30% year over year since 2022. This decline is due in part to the declining export rate, in combination with very high interest rates for anyone taking out a loan to install solar. Any homeowner looking to finance rooftop solar will find interest rates as high as 11.99%. Further declines in installations are likely to result in workforce reductions. Individual installers are considering job cuts of dozens of jobs with an average, annual pay of $62,500 a year. A decline in solar will also result in declines in the roofing industry and other energy efficiency contractors, such as HVAC, windows, and insulation. Reopening this docket will plunge an already struggling industry into uncertainty. It is hard to imagine why anyone would install solar when they have no way to predict what the Commission will do or if it will continue to honor any decision it does reach longer than an election cycle. High interest rates paired with a declining export rate and significant regulatory uncertainty will result in a substantial negative impact to the state’s economy.

Companies looking to do business in Arizona investigate the regulatory environment prior to investing in the state. The rate riders for the Resource Comparison Proxy (RCP) are notably forward looking. For example, APS’ rate rider explicitly states, “[t]he RCP rate may not be reduced by more than 10% each year” and “[e]ach Customer’s initial RCP rate will be applicable for 10 years from the time of their interconnection.”[8] Similarly, TEP’s website on RCP specifically states, “the RCP will not be allowed to fall more than 10 percent annually.”[9] Companies do not make business decisions in two-year election cycles. Changing the rules that impact major investments for homeowners or businesses is not good for the economy or the State.

Lastly, the Commission spends considerable time discussing staffing shortages, high workloads, and trouble juggling competing deadlines. A redo of a matter that took three years is simply not a good use of Commission or Staff time and resources. AriSEIA urges you to vote no on reopening the Value of Solar docket for the reasons stated above.

Respectfully,

/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org

[1] Arizona Corporation Commission, Order 75859, Page 151, Line 24 through Page 152, Line 4 (emphasis added), Filed January 3, 2017, available here https://docket.images.azcc.gov/0000176114.pdf?i=1692725715837.

[2] Id. at 96, Line 20-23.

[3] Id. at 137, Line 11-12.

[4] Id. at 148, Line 7-8.

[5] Id. at 154, Line 2-4.

[6] Id. at 156, Line 22-24.

[7] Solar Energy Industries Association (SEIA), Arizona Solar Census, Q2 2023, available here https://www.seia.org/sites/default/files/2023-09/Arizona.pdf.

[8] APS Rate Rider RCP, Page 1 (a) and (c).

[9] TEP, Resource Comparison Proxy Export Rate, available here https://www.tep.com/rcp/. 

​FOR IMMEDIATE RELEASE
 
Arizona Residents Stand United to Protect Rooftop Solar
Stakeholders Meet Ahead of ACC meeting on the fate of rooftop solar in Arizona.
 
Phoenix, Arizona — Yesterday, six years after the original solar export rate decision, energy justice and solar advocates held a virtual stakeholder briefing ahead of the Arizona Corporation Commission (ACC) meeting that could alter the future of rooftop solar in Arizona. The briefing, hosted by Solar United Neighbors in collaboration with Vote Solar and the Arizona Solar Energy Industries Association (AriSEIA), shed light on the need to maintain the established rates solar customers are paid by their utility for the extra power they provide to the grid.
 
WATCH: Stop the Attack on Solar in Arizona Stakeholder Briefing
 
“Arizonans were promised a certain amount for their excess solar production. They made economic investments based on the ACC’s previous decision. Any changes to the value of solar the Commission makes now r could undermine the private investments made by more than 200,000 Arizonans in an effort to lower their monthly energy bills. Ratepayers rely on their utility’s regulator to make decisions on their behalf that maintain stability and certainty. Reopening the value of solar docket does neither,” said Adrian Keller of Solar United Neighbors.
 
At the upcoming ACC meeting on October 11th, Commissioners will decide whether to re-examine the solar export rate, which dictates how solar owners are credited for surplus energy they contribute to the grid. The original 2017 decision, reached after a lengthy evidentiary hearing as well as extensive deliberation and compromise, was designed to ensure predictable compensation for solar owners while providing stability to Arizona's rooftop solar market. Re-opening this case would initiate a new proceeding and could lead to significant changes, which could undermine the value of investments Arizona families have already made in solar. If the ACC were to re-open this case, it also sends families and businesses in the state a signal that the ACC could reverse course on other important policy decisions at any time, undermining the value of long-term investments.
 
Autumn Johnson, Arizona Solar Energy Industries Association (AriSEIA), said, “Any changes to the solar export rate would not only affect homeowners but could also jeopardize our state's economic development. Solar employs more than 8,000 people in Arizona and contributed $1.5 billion to the state’s economy last year, with a total market of $16.8 billion. Paired with high interest rates, total market uncertainty could devastate this important industry in one of the sunniest states in the country.”
 
The potential changes to export rates could include a substantial reduction in compensation for solar energy and the erosion of critical protections for homeowners investing in solar power. A reduction in the export rate would impact the Arizona solar industry during a period of heavy federal investment in clean energy.
 
“Rooftop solar is an essential tool to help meet Arizona’s rapidly growing energy needs affordably while also improving the resilience of our communities. When families invest their own money in locally-produced solar power, it helps to reduce the need to build expensive new power plants and transmission lines, keeping electricity costs low for everybody. Thanks to new federal programs, tax credits, and financing options, rooftop solar is about to become more affordable and attainable than ever. But changes to the value of solar will slam the door shut on low-income communities, first-time homebuyers, and others who are only now getting access to clean energy solutions for the first time” said Kate Bowman, Vote Solar.
 
Stakeholders will hold a press conference at the ACC on the morning of their October 11th meeting at 9:30 a.m. After the press conference, advocates and the public will provide public comment.
 
To review a recording of this briefing, please click here.
 
###
 
For media inquiries, interviews, or further information, please contact:
Autumn Johnson
autumn@ariseia.org
520-240-4757
 
Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) trade organization and the state affiliate of the Solar Energy Industries Association (SEIA). AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. We advocate for sustainable job creation and encourage utilization of Arizona’s greatest natural resource, the sun.
 
Solar United Neighbors is a 501(c)3 nonprofit organization that works in Arizona and nationwide to represent the needs and interests of solar owners and supporters. Solar co-ops are part of the organization’s mission to create a new energy system with rooftop solar at the cornerstone. Solar United Neighbors holds events and education programs to help people become informed solar consumers, maximize the value of their solar investment, and advocate for fair solar policies.
 
Vote Solar is a 501(c)3 non-profit organization. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar works to remove regulatory barriers and implement key policies needed to bring solar to scale. Vote Solar works to realize a 100% clean energy future through a solutions-driven, people-first approach. 

Salt River Project
1500 N. Mill Avenue
Tempe, AZ 85288
 
RE: Integrated System Plan and Stakeholder Engagement
 
Salt River Project and Board,

The Arizona Solar Energy Industries Association (AriSEIA) requested to be a part of the Integrated System Plan (ISP) stakeholder group in 2022. That request was denied. AriSEIA also requested to be included in the Sustainability Advisory Council and, to date, that has also not been granted. It is unclear why AriSEIA continues to be excluded from all formal SRP stakeholder processes. Therefore, AriSEIA submits the following comments on Item 4 of the October 2nd Board Meeting:

SRP should be required to issue All Source Requests for Proposals (ASRFPs) for all major procurements of generating resources. Those ASRFPs should be vetted through the ISP stakeholder process, as Arizona Public Service (APS) has started to do. The ISP stakeholder process should not exclude stakeholders that request inclusion, especially if they are well established organizations that participate in the resource planning processes of every other major utility in the state. Additionally, no stakeholder process should purposely exclude an entire stakeholder segment, such as renewable energy organizations. Such a stance needlessly excludes valuable expertise from what should be a technically robust process. Meetings should also be virtual or hybrid. In person meetings, such as has been the case for the last two, exclude many stakeholders. Stakeholders that are out of the Phoenix metro area, have small children, or cannot devote multiple hours to commuting to and from SRP are excluded. The other major utilities all have remote options for stakeholder participation.

Further, the ISP stakeholder process should be meaningful. There should be an exchange of information in both directions and the utility should be willing to make modifications based on stakeholder feedback, run requested portfolios, and provide the modeling inputs and results to stakeholders. Board members should familiarize themselves with the Arizona Corporation Commission (ACC) Integrated Resource Plan (IRP) process and should hold SRP to a similar standard, as you all serve as the regulator of SRP.

SRP has been holding meetings on the ISP for more than two years. The board should be voting on a resource plan, not three vague slides called “strategies.” That is not adequate oversight of an unregulated monopoly. The “strategies” provide no meaningful information as to what the utility plans to do regarding RFPs, procurement, or implementation of their sustainability goals. The 2017-2019 resource plan was much more detailed and it completely neglected major procurements, such as the Coolidge expansion.
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SRP is the only major utility in the state that does not have an exit date for all coal; does not have a mass based carbon emissions goal; and has pursued major gas plant expansions that were never in a resource plan or RFP. The board should demand that the company do better. You are the only oversight on the second largest utility in the state.
Sincerely,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org