AriSEIA Joins Letter in Support of Transportation Electrification Implementation Plan at ACC9/21/2022 RE: In the Matter of Electric Vehicles, EV Infrastructure and Electrification of the Transportation Sector in Arizona (Docket No. E-00000A-21-0104)
Madam Chair and Commissioners, On behalf of Arizona Solar Energy Industries Association (“AriSEIA”), Solar United Neighbors (“SUN”), and Vote Solar, we would like to commend Tucson Electric Power (“TEP”) for bringing forward a comprehensive Transportation Electrification Implementation Plan (“TEIP”). We want to make our support known and urge the Commission to act swiftly to approve the TEIP. Our organizations have been thoroughly engaged in developing electrification policy as we believe transportation electrification is key to building a cleaner, more flexible, and more affordable grid. The growth of transportation electrification is also an opportunity to make Arizona a leader in the clean energy transition. TEP’s TEIP provides a comprehensive framework for reaching this ambitious goal. Building out electric vehicle (EV) infrastructure has numerous economic and environmental benefits. Implementation of the TEIP will make it more convenient, affordable, and reliable for Arizonans to adopt EVs, while also reducing air pollution. We would like to highlight and applaud some key objectives TEP laid out in the TEIP. First, we appreciate TEP’s willingness to invest in educational campaigns and outreach. Many customers remain unfamiliar with EVs, so it is important to give customers opportunities to learn more and especially to get hands-on experience driving an EV, as TEP has proposed through their “EV Showcase.” We hope that TEP’s proposal to develop multiple marketing campaigns based on segmented customer data will result in educational campaigns that appeal to a wide variety of TEP customers and are equally accessible in English and in Spanish. This will ensure consumers, especially in disadvantaged communities, better understand the benefits of EVs and how to optimize charging, thereby saving money and reducing peak demand. The plan correctly recognizes that although investments in EV charging will positively lead to a reduction in fuel costs, high peak loads on our grid systems need to be proactively minimized through education and awareness of rate structures. Second, we are pleased that the TEIP includes a variety of incentive options to help residential and commercial customers adopt EV charging infrastructure at their homes and businesses. Incentivizing customers to adopt smart charging equipment that contributes to grid flexibility will save all customers money. Above and beyond the upfront cost of purchasing EV charging equipment, many EV adopters will find that they need to upgrade the wiring in their home or business. This additional cost can be a significant deterrent, so we appreciate that the proposed Smart Home and Smart City Programs include an incentive for a panel upgrade for Low- and Moderate-income (LMI) customers, as well as incentives to pre-wire new homes for EV charging. Third, we commend TEP for including incentives to support charging infrastructure for public transit, micro-mobility solutions, and non-profit rideshares. These investments will help to ensure that Arizona residents who rely on public transportation, or cannot afford an EV, benefit from the electrification of the transportation sector. Fourth, we are glad to see that TEP’s plan considers the needs of fleet customers who will rely on the correct planning tools to create cost-effective fleet transitions. Total cost of ownership calculators (TCO) will enable fleet customers to accurately address their needs while transitioning. The proposed assistance to fleet managers also creates an opportunity to educate managers about strategies and technologies to optimize charging and avoid adding to peak load. We hope to see a more developed plan in the near future. Fifth, we appreciate that TEP’s plan includes considerations to proactively manage the grid impacts of transportation electrification as EV adoption grows. The TEIP proposes a managed charging pilot program that would encourage EV drivers to align charging with times of day when the cost of energy is lower or when plentiful clean energy resources, like solar, are available. Managed charging reduces peak demand, which improves grid resiliency and reduces the need to build additional generation. We hope this pilot will provide TEP with experience and information to roll out managed charging programs for all customers with EVs. In the meantime, we support the recommendation to require customers who use the Smart Home or Smart City incentives to purchase a networked charger to ensure that EV infrastructure installed today has the communications equipment necessary to help improve grid flexibility. We are also supportive of TEP’s proposal to conduct a grid impact analysis focused on optimizing the use of distribution assets. Understanding and planning for the growth of distributed energy resources is the best way to keep grid costs low for all customers. Going forward, we provide the following recommendations for TEP’s consideration to improve the success of the TEIP. First, customers should be provided with additional information regarding the enrollment process and planned program initiation. We would also like to see how the company plans to evaluate and gather data from customers. Second, we support the recommendation to align the LMI incentive with that of other nearby states, at least $1,300, and distribute it as one lump sum instead of dividing it into separate upgrade allowances. Third, we agree that customers who receive an EV incentive should be required to purchase a networked Level 2 charger. Those receiving this incentive should also be encouraged to enroll in a managed charging program or time of use (TOU) rate when available, with the option to opt-out if appropriate. Once again, the TEIP is a victory for Arizona’s economy. The sooner the plan is implemented, the sooner its plethora of benefits can be reaped. We request that the Commission vote to approve the TEIP and proposed budget during the October Open Meeting. Sincerely, Autumn Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) autumn@ariseia.org 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) bfanshaw@solarunitedneighbors.org 602-962-0240 Kate Bowman Interior West Regulatory Director Vote Solar kbowman@votesolar.org 703-674-8637
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AriSEIA is partnering with the Solar Energy Industries Association (SEIA) to intervene in the Tucson Electric Power (TEP) 2022 General Rate Case. TEP filed the rate case in June 2022, testimony is due in January 2023, and the hearing is expected to start in late March 2023.
Arizona Department of Transportation
1655 W. Jackson Street Phoenix, AZ 85007 Director Halikowski and ADOT Staff, On behalf of the Arizona Solar Energy Industries Association (AriSEIA), Solar United Neighbors (SUN), and Vote Solar, we write to thank ADOT for crafting and submitting the National Electric Vehicle Infrastructure (NEVI) Formula Program plan for Arizona. Our organizations would like to express our enthusiastic support for the NEVI program. Electrification of the energy sector, including electric vehicles (EVs), is critical to maximize the benefits of clean energy technologies, reduce pollution, and build a more reliable and affordable grid. Each of our organizations have been thoroughly engaged in developing electrification policy. AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. AriSEIA also advocates for sustainable job creation and encourages utilization of Arizona’s greatest natural resource, the sun. SUN represents solar homeowners, many of whom are also electric vehicle owners or enthusiasts, as they endeavor to install rooftop solar. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar is also working to remove regulatory barriers and implement key policies needed to bring solar to scale. We applaud your department for its vision and for seizing this opportunity to secure $76.5 million in funding for Arizona to build out electric vehicle infrastructure in the state. It is critical to develop Electric Vehicle Supply Equipment (EVSE) along interstate corridors over the next five years for Arizona to reach a clean energy future and to promote quality of life for our residents and businesses. Expanding a strategic network of alternative fuel and charging infrastructure and increasing EV accessibility will accelerate the adoption of electric vehicles, making them more convenient, affordable, and reliable for Arizonans. Building out EV infrastructure will result in a number of significant economic and environmental benefits for Arizona. This includes reducing air pollution from the transportation sector, creating new family-sustaining jobs, boosting the economy, and lowering costs at the fuel pump for Arizonans across the state. In sum, we are grateful to see how the NEVI plan will support the building of a resilient, equitable, accessible, and reliable charging network for Arizonans. Going forward, we provide the following recommendations for ADOT’s consideration to improve the affordability and accessibility of Arizona's transition to clean energy vehicles. The growth of EV charging infrastructure will increase electricity usage, and so it is important to simultaneously invest in distributed energy resources in order to mitigate the need to build additional energy infrastructure. Investments in locally sited solar and storage not only contribute to meeting local energy needs, but improve the resiliency of the grid. It is important that ADOT encourages EVSE owners to set price structures that incentivize the charging of vehicles during off-peak hours. Charging during times when electricity is less expensive will reduce overall costs. We would like to see ADOT require EVSE owners to establish a communication system that allows drivers to opt-in and notify the EVSE owner when a system is down so that issues can be fixed with little to no delay. Lastly, ADOT should prioritize the needs of current EV drivers and traditionally underserved communities when making decisions about where EVSE should be sited. We encourage ADOT to continue engaging stakeholders and the public in regular conversations and outreach available in both English and Spanish throughout the implementation of the plan. Now more than ever, Arizona should take significant steps to capitalize on the momentum behind the growth of electric vehicles. Each of our organizations are eager to see the swift implementation of ADOT’s NEVI Plan. Sincerely, Autumn Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) autumn@ariseia.org 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) bfanshaw@solarunitedneighbors.org 602-962-0240 Kate Bowman Interior West Regulatory Director Vote Solar kbowman@votesolar.org 703-674-8637 Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Response to Chairwoman Marquez Peterson’s Letter Dated August 23, 2022 - Community Solar (Docket No. E-00000A-22-0103) & (Docket No. E-01345A-21-0240) Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. The signatories are filing this letter in response to Chairwoman Marquez Peterson’s letter dated August 23, 2022 which posed questions about thirteen models she requested be compared to community solar. As requested in the Chairwoman’s letter, attached as Appendix A is a matrix that provides an analysis of the models referenced. As explained more fully below, most models described in the letter are not community solar and are not models the signatories are recommending for Arizona. Some of the models describe existing tariffs or programs and others describe hypothetical models that, as far as we know, have not been implemented elsewhere, making direct comparison challenging. While the signatories do not recommend adoption of the models referenced in the matrix, the signatories desire to assist Staff and other stakeholders in their review of the models. It is important to note that 22 other states have already implemented community solar programs, and there is substantial precedent for how community solar programs work and experience with the models they follow. The underlying structure of community solar programs across the country is largely the same, and is consistent with the signatories’ program proposal filed on August 26, 2022 (henceforth referred to as “Signatories’ Proposal”). There are, of course, variations among existing programs which were achieved via policy making and/or regulatory decisions. The Signatories’ Proposal relies on common components of community solar programs around the country and has been tailored to Arizona and can be implemented within the existing regulatory framework. Because there is substantial precedent for how community solar programs work across the country, we do not believe it is necessary to complete an exhaustive review of each of the thirteen models referenced in the Chairwoman’s letter beyond what is provided in Appendix A. Below, the signatories have answered, in greater detail, the seventeen questions posed in the Chairwoman’ letter relative to the Signatories’ Proposal. As requested in the Chairwoman’s letter, the signatories seek to narrow the focus of the Commission’s research of how a community solar program fits within the existing regulatory and ratemaking framework in Arizona by reiterating the signatories’ preferred community solar model, filed on August 26, 2022 (henceforth referred to as “Signatories’ Proposal” and noted as item 4 below). The signatories have made four filings to provide the Commission with detailed information on community solar program implementation in Arizona and how the preferred model would work. These filings include:
The signatories will be filing additional information to further supplement the Signatories’ Proposal to address topics discussed at the working group meetings held on August 30 & 31, including a bill credit rate proposal. The Signatories’ Proposal will provide substantial benefits and consumer protections for customers. Please see below for answers to the questions posed by the Chairwoman relative to the Signatories’ Proposal... Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Standardized Contract, Agreement, and/or Tariff for Community Solar (Docket No. E-00000A-22-0103) & (Docket No. E-01345A-21-0240) Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. At the working group meetings held on August 30 & 31, 2022, there was discussion of whether a contract, agreement, and/or tariff would exist between a community solar developer and the utility to which a community solar project is interconnected beyond a standard interconnection agreement. Further, there was discussion of whether such contract, agreement, and/or tariff would be subject to negotiation for each project or standardized. At the working group meetings, representatives of the signatories to this letter stated that there would be a contract, agreement, and/or tariff to govern the interactions between the community solar developer and the utility to which a community solar project is interconnected. The representatives of the signatories also stated that the contract, agreement, and/or tariff would be standardized such that it would not be subject to negotiation for each project, thus eliminating any concerns about taking up time and resources to execute. The signatories committed to filing standardized examples from programs in other states that could be used as a template for the community solar program in Arizona. Attached to this letter as Appendix A is the Solar Rewards Community Producer Agreement that is used by Xcel Energy in Colorado. Attached to this letter as Appendix B is the Standard Contract for Solar Rewards Community that is used by Xcel Energy in Minnesota. The signatories have previously referenced certain components of the community solar programs in Colorado and Minnesota because each state has a mature community solar program. The Colorado example in Appendix A is a standardized contract which exists outside of the utilities tariff as a program document. The Minnesota example in Appendix B is also a standardized contract, however it exists within the utilities electric tariff. The standardized examples attached to this letter will need to be edited to reflect Arizona-specific program requirements We appreciate the opportunity to address these important issues. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Resource Comparison Proxy Proposal for Community Solar (RCP-CS) (Docket No. E-00000A-22-0103) & (Docket No. E-01345A-21-0240) Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to providing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. At the working group meetings held on August 30 & 31, 2022, the signatories made a verbal proposal on the bill credit rate for the community solar program in Arizona. As requested by one of the Commissioner’s offices, the signatories are submitting this letter with the written details of that proposal. As background, the Commission previously approved the Resource Comparison Proxy (RCP) as the compensation mechanism for rooftop solar projects in Arizona. The signatories suggest that the Commission use the current RCP rate for Arizona Public Service (APS) as the initial bill credit rate for the community solar program with two required modifications, discussed herein and summarized in Appendix A. These modifications to the administration of the RCP are required because of the unique characteristics that community solar projects bring to customers and the grid in Arizona. Hereinafter, we refer to this proposal as RCP-CS. The RCP-CS proposal below is consistent with the Commission Order that initiated this proceeding. Specifically, the Order stated that the program should be “...designed to attract long-term private sector investment” and that “[d]irect bill offsets may be considered for subscribers to produce savings in a structure substantially similar to that offered to rooftop solar customers, eliminating the need for incentives. The value proposition for subscribers should be similar to those participating in onsite generation.” The Commission did not order that the bill credit rate mechanism for community solar should be exactly the same as the existing RCP, rather the value proposition should be “substantially similar.” As such, the RCP-CS proposal recognizes the fundamental dynamics of implementing a successful community solar program in Arizona while using the existing RCP as a starting point to simplify the initial bill credit setting process. The signatories offer the RCP-CS proposal below:
The study prepared by The Brattle Group and filed by the signatories on August 26, 2022 supports this RCP-CS proposal. The Brattle analysis suggests that the value of community solar is at least, if not higher than, the current value of APS’ RCP. The Brattle analysis found the value stack of community solar to be approximately $0.09683 per kWh (compared to APS’ current RCP of $0.08465 per kWh). Therefore, the Brattle study findings support the reasonableness of locking-in the bill credit rate at the current level of the RCP during the Stability Period. Further, the Brattle study supports the removal of the component of the existing RCP that allows rates to decline by a maximum of ten percent (10%) year over year because the study shows the value of community solar increasing in the future. The signatories propose that the RCP-CS rate include a Stability Period to allow critical time for the community solar program to be implemented successfully. The Stability Period is a necessary component of the proposal as it will take time for community solar projects to be constructed and for the Commission to gain experience with the community solar program. Several steps must take place before a community solar project is placed into service, including the following:
While some of the activities mentioned above can occur in parallel, some of them are sequential. The five-year Stability Period will allow critical time for projects to come online with reasonable commercial certainty and for the Commission to gain experience with the community solar program. The Stability Period will also allow for additional time to study the value stack of community solar projects to inform future bill credit rates. It is common in other community solar programs around the country to allow for program parameters that promote predictable program ramp-up through this type of approach. Attached as Appendix A is a table that compares the existing RCP with the proposed RCP-CS, including why the changes above are necessary for a community solar program. We appreciate the opportunity to address these important questions. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Support for SunZia Southwest Transmission Line (Docket No. L-00000YY-15-0318-00171) Chairman and Members of the Line Siting Committee, On behalf of the Arizona Solar Energy Industries Association (AriSEIA), we are writing in support of the proposed SunZia Southwest Transmission Line. Our mission is to develop and support opportunities to advance Arizona’s economy through solar energy, storage, and electrification. As proponents for fostering a booming solar market, we strongly believe in building clean energy infrastructure, which is a necessary step to further the energy transition. Our state has immense solar potential and the possibility to become a solar hub. In the last ten years we have seen a 90% drop in the cost of utility-scale solar, a trend we expect to continue as the technology keeps improving and becoming more efficient.[1] Building out crucial renewable infrastructure will also serve as an important incentive for developers looking to expand their renewable projects into our state. This line is expected to bring in millions of dollars in direct tax revenue across the entirety of the line. The “direct impacts of the Project’s development in Arizona are estimated to be approximately $585 million.”[2] The project is also expected to add hundreds of new jobs, dozens of which will be permanent. The renewables industry has potential to generate a major boon to our economy. In 2021, the solar industry generated over $33 billion of private investment in the American economy.[3] Offering pathways to boosting the renewables industry is particularly crucial in this moment when supply chain constraints have led to fluctuations in the market for the first time since consistent projections have steadily decreased in price over the past decade. Arizona is at a pivotal point in diversifying our energy generation and taking advantage of a prosperous and high-demand industry. Laying the foundation will be a necessary step to tapping into these channels. We ask that the SunZia Southwest Transmission Line be approved. Sincerely, Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] Lazard, Levelized Cost of Energy, available here https://www.lazard.com/perspective/levelized-cost-of-energy-levelized-cost-of-storage-and-levelized-cost-of-hydrogen/. [2] Moss Adams, SunZia Transmission Project Economic and Fiscal Impacts Analysis, June 23, 2021, page 3. [3] Solar Energy Industries Association (SEIA), Solar Industry Research Data, available here https://www.seia.org/solar-industry-research-data#:~:text=In%202021%2C%20the%20solar%20industry%20generated%20more%20than%20%2433%20billion%20of%20private%20investment%20in%20the%20American%C2%A0economy. Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 RE: Community Solar, Docket No. E-00000A-22-0103 and APS RES, Docket No. E-01345A-21-0240 Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. We put forward, as Attachment A, this draft program design to aid in the working group discussions and the successful adoption of a community solar program in advance of the November Open Meeting. We additionally put forward, as Attachment B, an assessment regarding the Commission’s authority to implement the community solar program and tariff outside of a rate case. Further, we appreciate the letter filed by the Chairwoman on August 23, 2022 regarding the various models of community solar her office sees as relevant to this proceeding. The undersigned stakeholders plan to file a separate response to that letter as soon as possible with answers to the questions therein that are grounded in the program proposal put forth below. We appreciate the opportunity to address these important concerns. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Study of Community Solar Value Stack in Arizona - Community Solar (Docket No. E-00000A-22-0103), APS RES (Docket No. E-01345A-21-0240) Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. Attached to this letter is a study completed by The Brattle Group that analyzes the value stack of community solar in Arizona. The Brattle Group is a leading consulting firm that specializes in answering complex economic, finance, and regulatory questions for corporations, law firms, and governments around the world. The value stack of a community solar project represents the costs that would otherwise be borne by ratepayers but that are avoided due to the energy and grid services provided by a community solar project. The community solar value stack consists of three value streams: (1) Avoided Generation, (2) Avoided Transmission and Distribution, and (3) Avoided Emissions. The purpose of this value stack study is to provide the Commission and stakeholders with information to guide discussions on an appropriate bill credit rate and compensation mechanism for the community solar program in Arizona. Brattle will be prepared to present this material and answer questions at the working group session on August 30, 2022. We look forward to additional discussions regarding designing a final bill credit rate, tariff, and compensation mechanism for projects.  Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Community Solar, Docket No. E-00000A-22-0103 Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. We were encouraged by the progress made during the Commission’s community solar working group held on August 4, 2022 and appreciate that the next meeting will be a two day working group session held on August 30 and 31. We understand that Staff is still developing the proposed agenda for the August meetings; therefore, we suggest the following topics: bill credit structure and value, eligible subscribers and low- and moderate-income (LMI) subscriber participation, program and project size, project selection, storage, and hosting capacity maps. To the extent that it is helpful to the Staff and other stakeholders, below are potential questions that could be posed for each topic at the next meeting. ● Bill credit structure and value ○ How should the bill credit be structured? ○ Would the resource comparison proxy (RCP) accurately represent the full value of community solar projects? ○ Given the bill credit structure, what is the projected value of the bill credit? ○ What should the term of the bill credit be? ● Eligible subscribers and LMI participation ○ Which customer classes should be eligible for participation in the program? ○ Should there be percentage per-project subscription targets or requirements for certain customer classes? ○ Should there be a required percentage for LMI customer subscription? ○ Should there be a maximum project capacity that “anchor tenants” can subscribe to? ● Program size and project size ○ Should there be a cap on program size? ○ If yes, how should it be constructed? (e.g., percentage of total retail sales vs. number of MW) ○ Should there be a maximum project size or only a requirement that projects connect to the distribution grid? ● Project selection ○ How should projects be selected for participation in the program? (e.g., first-come first-served vs. RFP) ○ What type of project maturity milestones should be required for eligibility in the program, and should those milestones depend on the program size (capped versus uncapped)? ● Storage ○ Should community renewables projects be limited to solar photovoltaic systems, potentially paired with storage? ● Hosting capacity maps ○ Has Arizona Public Service (APS) completed a hosting capacity study and if so, how do the results compare to what would be needed for program implementation? ○ Does APS have hosting capacity maps and if so, how are they to be used by developers? ○ Are there recommended examples of hosting capacity maps in other states? ○ What types of data should be included in hosting capacity maps and how often should they be updated? Further, as was requested at the August 4th working group meeting, we have provided as Attachment A an illustrative example of cash flows for a community solar program, sample or redacted bills as Attachment B from Minnesota and New York, and sample contracts from Nautilus and Arcadia as Attachment C. We appreciate the opportunity to address these important concerns. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona. Respectfully, Autumn Johnson Executive Director Arizona Solar Energy Industries Association (520) 240-4757 autumn@ariseia.org Salar Naini Executive Vice President, Business Development Turning Point (480) 330-1245 snaini@tpoint-e.com Justin Biltz Director, Policy & Strategy, Community-Scale Markets Cypress Creek Renewables (330) 515-1564 justin.biltz@ccrenew.com Bret Fanshaw Arizona Program Director | West Region Director Solar United Neighbors (602) 962-0240 bfanshaw@solarunitedneighbors.org Angela Navarro Head of State Regulatory Affairs Arcadia (352) 262-8201 angela.navarro@arcadia.com Kevin Cray Mountain West Regional Director Coalition for Community Solar Access (CCSA) (303) 819-3457 kevin@communitysolaraccess.org Maria McCoy Research Associate, Energy Democracy Institute for Local Self-Reliance (612) 808-0688 maria@ilsr.org Sara Birmingham Senior Director of State Affairs Solar Energy Industries Association (415) 385-7240 sbirmingham@seia.org Joy Crossman Director of Development Soltage, LLC (201) 559-6243 jcrossman@soltage.com Kate Bowman Interior West Regulatory Director Vote Solar (703) 674-8637 kbowman@votesolar.org Landon Stevens Director of Policy Conservative Energy Network (480) 338-9767 Lstevens@conservativeenergynetwork.org Scott Risley Executive Director of Public Policy Nautilus Solar (928) 925-5972 srisley@nautilussolar.com Christopher Mejia Founder Consolidated Solar (717) 884-2204 chris@consolidatedsolar.net |
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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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