AriSEIA and other Solar Stakeholders filed a response to ACC Staff's memorandum calling for comment on five areas of community solar to be resolved in a March policy statement by Commissioners. This is in addition to the various litigated proceedings. You can see the full filing at the link above.
AriSEIA filed the direct testimony of our two experts today in the Tucson Electric Power rate case. We are focusing on community solar and battery storage programs for residential and commercial customers. The testimony and exhibits exceed 400 pages. You can view the entire filing at the button above. TEP is due to file their response on February 15th.
AriSEIA filed expert witness testimony in the currently pending TEP rate case focusing on why the Commission should deny TEP's request to increase their return on equity (ROE). Additionally, several other parties filed testimony about items other than rate design on January 11th. You can view the docket here.
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Re: Arizona Public Service (APS) E-32 L SP Tariff, Docket E-01345A-22-0281
Madam Chair and Commissioners,
Pursuant to Decision No. 78317,1 APS was ordered to engage with stakeholders, namely the Arizona Solar Energy Industries Association (AriSEIA) and the Solar Energy Industries Association (SEIA), to redesign the E-32 L SP (Storage Pilot) rate tariff to increase customer adoption of the 35 MW commercial pilot program. AriSEIA appreciated the opportunity to provide constructive feedback and generally guide the tariff design process towards a solution that creates value for APS and the adopting customers.
Throughout the duration of 2022, AriSEIA met monthly with APS and reiterated that rate optionality and investment certainty are key components of behind-the-meter energy storage adoption as not all customer loads are created equal, and few customers are able to benefit from existing tariffs using 15-minute interval demand charges. To that end, we collaborated with APS on the proposed volumetric, time-of-use (TOU) rate including a substantial differential between on-peak and off-peak rates which de-risks the customer’s energy storage investment in terms of achieving monthly savings while creating grid support during the utility’s coincident peak periods. Our assessment of the new rate tariff is that it will encourage participation in the pilot energy storage program through market-competitive payback opportunities. This rate tariff may also provide a foundation to develop more value-stacking opportunities for utilities such as distributed virtual power plants or similar grid-response programs.
While the proposed E-32 L SP pilot revisions are a significant step in the right direction, we believe that further alignment with APS’ true coincident on-peak demand periods is important to creating an equitable program. To this end, we issued our recommendation to APS to limit the on-peak hours to Monday through Friday in lieu of across all seven (7) days of the week as the weekend load and marginal prices are typically much lower and do not merit the same TOU price differential. We look forward to continuing to work with APS as this program evolves.
Thank you for considering these comments and we encourage you to adopt this rate in the first quarter of 2023 and to continue promoting more grid-interactive programs for customer-sited distributed energy resources.
President, Board of Directors
1 Arizona Corporation Commission, Decision 78317, November 9, 2021, available here https://docket.images.azcc.gov/0000205236.pdf?i=1670984264693.
Goodyear and Oro Valley have been selected by the NREL, the National Laboratory funded by the Department of Energy, as one of 12 communities nationwide to adopt the innovative solar permitting platform SolarAPP+. Through the program, the two cities are eligible to receive $15,000 if SolarAPP+ is adopted successfully.
“We’re excited to see NREL’s announcement and the fact that residential solar is receiving its time in the spotlight here in these two cities,” said Autumn Johnson, Executive Director of the Arizona Solar Energy Industries Association (AriSEIA). “Syncing this program with the community’s burgeoning solar market validates all the hard work that AriSEIA and other advocates continue to do. Both in our market and across the country, ensuring that consumer interest is met with efficient permitting processes can really help ensure the solar industry continues to shine.”
SolarAPP+ is an online platform that instantly issues permits for code-compliant residential rooftop photovoltaic (PV) and battery systems. As many consumers and local jurisdictions know, permitting can often slow the process for residential solar and battery installations. Current permitting delays are estimated to increase solar cost by $7,000 per project. With the convergence of increased consumer interest in solar installation and federal legislative momentum, clearing this potential bottleneck of long review timelines and complicated permitting applications is imperative. SolarAPP+ provides local governments, installers and homeowners with a streamlined process to more quickly achieve clean power generation from the sun.
SolarAPP+ has already approved more than 10,000 permits across jurisdictions, including successful programs in Arizona, California, Illinois and Texas. Since SolarAPP+ provides an immediate permit for those communities vetted and determined to be eligible, projects have been installed about two weeks faster under the program.
Regional Clean Hydrogen Hub Develops in the Desert Southwest
Energy leaders focused on developing low carbon economies in Arizona, the Navajo Nation, and Nevada have joined forces to develop a regional clean hydrogen hub in the Southwest. The Center for an Arizona Carbon Neutral Economy, first introduced in May 2022, is collaborating with partners in Arizona, the Navajo Nation, and Nevada to launch the Southwest Clean Hydrogen Innovation Network, or “SHINe”.
On November 7, as its first step in developing the hub, SHINe submitted a concept paper to seek federal funding from the U.S. Department of Energy (“DOE”) for key clean hydrogen-focused initiatives including production, processing, storage, and delivery systems, community benefits, and other enabling infrastructure. Once fully operational, SHINe will help support DOE’s vision of a regional clean hydrogen hub that provides clean energy for the hard to abate carbon emissions in the transportation, industrial, and electricity sectors while maintaining a reliable and resilient electric grid. SHINe will also work to create economic development opportunities in the region.
“A regional clean hydrogen hub focuses on developing a network of hydrogen producers, consumers and local connective infrastructure,” said Ellen Stechel, AzCaNE’s Executive Director. “The SHINe network includes salt cavern storage, heavy duty transportation, and distribution technologies that will help accelerate the use of clean hydrogen as a source of low carbon energy powering the economy.”
In September, the DOE announced that up to $7 billion is available to fund the development of six to ten U.S.-based regional clean hydrogen hubs. Regional clean hydrogen hubs funding was outlined as part of President Biden’s Infrastructure Investment and Jobs Act, otherwise known as the Bipartisan Infrastructure Bill, which authorized up to $8 billion for at least four regional clean hydrogen hubs. These hubs are meant to help communities across the country benefit from clean hydrogen investments, quality jobs, and improved energy security. When coupled with other public and private investments in new clean hydrogen production, the hubs are expected to accelerate a nationwide clean hydrogen network and economy.
Arizona, the Navajo Nation, and Nevada are in the nation's sunniest region, with significant available undeveloped land and abundant clean energy resources. Arizona also has the nation’s largest nuclear power plant producing 100 percent carbon-free electricity, and energy providers committed to reducing carbon dioxide emissions. Arizona also has world-class universities, established clean energy and clean hydrogen companies, and a healthy environment for innovation and start-ups. The Navajo Nation is one of the largest tribes in the U.S., has a land base larger than West Virginia, and is transitioning to a clean energy economy. Nevada is an early investor in clean hydrogen infrastructure, which will be necessary to integrate more hydrogen-fueled vehicles. These resources, along with the region’s proximity to California, will contribute to decarbonizing the region and ultimately the entire U.S.
SHINe includes more than forty member organizations with expertise and operations throughout the region, including cities, clean energy companies, gas producing companies, non-profits, transit companies, universities, utilities, and others including the following:
THE SOLAR COALITION’S EXCEPTIONS AND PROPOSED AMENDMENT TO STAFF’S MEMORANDUM AND PROPOSED ORDER
DOCKET NO. E-00000A-22-0103
The signatories listed below appreciate the opportunity to continue their close involvement in the development of Arizona's community solar program and offer these Exceptions and Proposed Amendment to support the Commission as it decides how to move forward in the Arizona Public Service (APS) territory. This docket presents the Commission with an opportunity to provide savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. The signatories have been committed to participating in the working group discussions and docketing information to assist in the Commission’s consideration of a proposal for implementation of a community solar program, as envisioned in Commission Decision 78583 (May 27, 2022). The signatories have come together and presented a comprehensive community solar proposal to the Commission on August 26th based on vast experience in community solar programs around the country. The signatories represent a diverse range of interests and the program proposal submitted encompasses a consensus agreement among all fourteen (14) parties represented at the time of filing, was responsive to the directives in Commission Decision 78583 and to the questions raised during working group meetings, was based on sound compromise, and was tailored to Arizona’s regulatory environment.
Unfortunately, Staff’s Memorandum and Proposed Order does not meet the requirements contained in Commission Decision 78583. After six (6) months of robust discussions and dozens of filings in this proceeding, Staff has not provided any substantive policy recommendations on the programmatic elements specified in Commission Decision 78583. Instead, Staff suggests that a substantial portion of the program details be moved to an evidentiary hearing process, which could lead to some elements being significantly delayed. This is not what the Commission directed. Six (6) months ago, the Commission discussed the process of developing a community solar program in detail and decided that this docket and the working group format was the appropriate pathway to create a program proposal on which to vote. The Commission directed Staff to put forth a proposal for implementation in advance of the November 2022 Open Meeting and further specified that the proposal should become effective within six (6) months of Commission approval. An evidentiary hearing would only serve to delay the implementation of a community solar program and needlessly increase the investment of time and resources from participants, Staff, and the Commission. Moreover, because a hearing process would trigger the Commission’s ex parte rules, such a proceeding would limit the Commission’s ability to discuss key program elements with the diverse range of stakeholders, which has been a key benefit throughout the working group process. An evidentiary hearing is simply not required to construct a workable community solar program.
Additionally, Staff’s Memorandum and Proposed Order references only Arizona Public Service’s (APS) program proposal. As discussed in the signatories’ response to the APS proposal filed on October 7, 2022, the APS proposal will not result in competitive third-party development of community solar projects and, as such, restricts benefits that would be created for APS customers and should be disregarded. As detailed in The Potential Economic and Fiscal Impacts of Community Solar in Arizona report prepared by the Seidman Research Institute at Arizona State University, the benefits of community solar investment extend beyond subscribers to the program, to the entirety of the state. The rollout of three hundred (300) MW of community solar each year for ten (10) years (study Scenario #6) would contribute over five (5) billion dollars to state Gross Domestic Product (GDP), result in the creation of more than fifty-eight (58) thousand job years of total employment, and nearly four (4) billion dollars in labor income over a study period of thirty-five (35) years. Commission approval of the APS program proposal, as written, would deny these benefits to Arizonans across the state.
Simply put, APS’s proposal is not community solar. The signatories have dedicated significant time and resources to help develop a program proposal pursuant to Commission Decision 78583 that includes program design elements based on successful community solar programs across the country and is responsive to feedback raised by parties participating in the working group. However, Staff’s Memorandum and Proposed Order does not reference the signatories proposal, despite the comprehensive and robust information that the signatories have continued to submit in this proceeding. The lack of discussion or consideration of any components of the signatories’ proposal is notable given that only two program proposals have been made in this proceeding – one by APS and one by over a dozen diverse signatories.
Herein, the signatories offer Exceptions and a Proposed Amendment to the Staff’s Memorandum and Proposed Order. See Attachment A for the Proposed Amendment. The signatories offer the Proposed Amendment in an effort to assist the Commission in devising a community solar program that is consistent with the intent of Decision 78583 and the months-long discussions in the community solar stakeholder workshops. The participants to those proceedings spent considerable time and resources in those workshops, including the utilities and Commission Staff, and should not be made to duplicate the effort in an entirely new proceeding. The signatories thus urge the Commission to reject Staff’s proposal and adopt the Proposed Amendment, which balances the key program requirements that must be included for successful implementation and operation of the program.
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Re: Support for Approval of a Distributed Demand-Side Resource (DDSR) Aggregation Tariff and Service Schedule, Docket No. E-01345A-22-0143
Madam Chair and Commissioners,
Vote Solar, Solar United Neighbors, and the Arizona Solar Energy Industries Association (AriSEIA) urge you to approve the Arizona Public Service (APS) Company DDSR Aggregation Tariff, as amended by the Sunrun Proposed Amendment Number 1 (Amendment No. 1 and collectively, the DDSR Aggregation Tariff or Tariff).
Arizona is poised to continue to lead the adoption of demand side resources, including distributed battery storage, which benefits all customers. This DDSR Aggregation Tariff will reduce costs for all APS ratepayers, reduce peak capacity needs, and increase reliability and resilience by compensating aggregators for leveraging emerging technologies such as battery storage. The growth and declining cost of distributed storage technology creates a critical opportunity to leverage these customer-sited resources to provide grid benefits. APS’ innovative DDSR Aggregation Tariff is an important step towards realizing a more modern and resilient grid, and now is the time to begin leveraging the grid benefits it will provide. The Lawrence Berkeley National Laboratory (LBNL or the LBNL Report), a third-party evaluator engaged by the Arizona Corporation Commission (Commission), found that participation in this program is likely to be higher than ever because of the investment tax credit (ITC) available for stand-alone storage and other solar incentives available under the Inflation Reduction Act (IRA).
If approved, this Tariff will result in actual projects that will generate real-world data about the value provided by participating aggregators. This data is valuable because it will provide detailed insight into the specific value of participating resources and can be used to refine future iterations of the Tariff to improve its cost-effectiveness. The LBNL Report and Amendment 1 rightfully question why APS chose to consider only five (5) years of benefits when the measures employed will bring ten (10) years benefit to the grid, commensurate with the typical lifetime of battery storage. We agree with Amendment 1 and echo its conclusion that this DDSR Aggregation Tariff will provide ninety-five percent (95%) more grid benefits than are presently quantified by APS, including the benefits associated with daily shifting, avoided outages and associated costs, added grid resilience, and avoided carbon emissions. Current benefits under the LBNL Report include:
Significant Peak Load Reduction for APS Customers - The LBNL Report found that participants in the program will reduce peak period loads substantially during weekdays by installing battery storage to existing rooftop solar. This reduces costs for all utility customers
Increased Reliability and Resilience for Participants - The LBNL Report found that participants who add battery storage to existing rooftop solar will benefit from an annual cost savings of $14/yr. for Flagstaff, $25/yr. for Phoenix, and $29/yr. for Yuma. The LBNL Report also found participants will experience significant resilience benefits, valued at between $2,000 and $6,000 per customer. This is a step towards additional energy efficiency in Arizona.
Overall Cost Reduction for Ratepayers - The LBNL Report found that, from a ratepayer perspective, battery storage is cost neutral and does not result in cost shifting (the study did not consider cost for reconfiguration of an existing rooftop array to incorporate a battery). Further, LBNL found that if evaluated over 10 years, as they recommend, the benefits of the resources chosen through the DDSR Aggregation Tariff equal or exceed its costs. This means that both participants and non-participants will benefit from ratepayers with battery storage.
We support Sunrun’s proposed changes to the Tariff. These changes include requiring APS to periodically issue a minimum number of requests for proposals to drive competition, lowering bidder fees to encourage aggregator participation, accepting bids from aggregators that partially provide the services sought, and creating an open Tariff that all qualified aggregators may leverage, informed by cost data generated through the periodic RFPs. These changes improve the Tariff by allowing the program to develop to its full potential. Making the Tariff available to all aggregators will help reach the realized goal of bringing the Tariff to ratepayers.
While the initial cost savings may seem minor (and also considering the overall benefits are undercounted by 95% in the study), the benefits provided by this DDSR Aggregation Tariff are very significant. Overall, LBNL's expert analysis leads to the conclusion that this innovative Tariff is cost-effective.
We strongly urge the Commission to move forward with approving this Tariff in this docket at the November Open Meeting. Failure to approve the DDSR Aggregation Tariff will put Arizona behind the curve of this fast-changing technology and forgo an opportunity to support a
program that strives for a positive community outcome and can deliver significant cost and grid resilience benefits.
We are eager to participate in the ongoing efforts of the DDSR Aggregation Tariff, which will provide benefits to all ratepayers for many years to come, and feel confident that collaboration with other organizations, consumer advocates, Staff, and the utility will contribute to a bright future for residential solar in Arizona.
Thank you for your consideration of this important matter.
Autumn T. Johnson
Arizona Solar Energy Industries Association (AriSEIA)
Western Region Director
Solar United Neighbors (SUN)
Interior West Regulatory Director
 Arizona Corporation Commission’s Decision No. 78165 (E-10345A-19-148), Filed July 28, 2021, available here https://docket.images.azcc.gov/0000204280.pdf?i=1667008921051
 Sunrun’s Exceptions to Staff’s Memorandum and Proposed Order, Filed October 26, 2022, available here https://docket.images.azcc.gov/E000021983.pdf.
 Arizona Corporation Commission’s Memorandum Re: Lawrence Berkeley Laboratory Reports, Filed September 30, 2021, available here https://docket.images.azcc.gov/E000021442.pdf?i=1667005959409
 Arizona Corporation Commission’s Memorandum Re: Revised Lawrence Berkeley Laboratory Report, Filed October 21, 2022, available here https://docket.images.azcc.gov/E000021864.pdf?i=1667005959409
 See LBNL Report at page 12.
 See LBNL Report at page 15.
Rep. Tom O’Halleran, Business Leaders, Clean Energy Advocates Discuss Benefits of Inflation Reduction Act for Arizonans
Arizona – Clean Air Task Force Action, a U.S. advocacy organization that advances climate and clean energy policies designed to achieve decarbonization, today hosted a virtual roundtable with Rep. Tom O’Halleran (AZ-01), business leaders across Arizona’s energy sector, and clean energy advocates to discuss the Inflation Reduction Act (IRA) and how its continued implementation will benefit Arizonans and the state’s economy.
“For far too long, we’ve failed to take meaningful action to mitigate the effects of climate change on the desert southwest—drought, fires, and flooding are directly impacting Arizonans every day, be it coming water restrictions for southern Arizona families and farmers, homes and businesses lost to deadly wildfires in overgrown northern forests, or flood after flood destroying the homes and businesses of folks in Flagstaff,” said Rep. Tom O’Halleran (AZ-01). “The Inflation Reduction Act makes historic, targeted investments that address climate change head-on, creating new incentives that will produce cleaner, more affordable energy and create good-paying jobs in the process.”
You can watch a full recording of the roundtable discussion here.
Signed into law in August 2022, the IRA will allocate nearly $370 billion to incentivize the private sector to build out America’s 21st-century clean energy infrastructure. The law will help spur the economic transformation needed to address climate change, make clean energy more accessible and affordable, and direct important investments to underserved communities.
"The Inflation Reduction Act provides much needed certainty to an industry that already employs nearly 10,000 people in Arizona," said John Mitman, Board President, Arizona Solar Energy Industries Association (AriSEIA). "That certainty will enable even greater investment in a state with immense solar potential and a flourishing electrification hub. This legislation puts Arizona in an ideal position to be a leader in the clean energy sector."
In Arizona alone, the IRA is expected to create more than 65,000 new, good paying, high-quality jobs in 2035. Additionally, the legislation will reduce energy expenditures each year across the desert southwest region, mitigate extreme heat, prevent wildfires, and provide emergency drought relief to tribes, improve canals, and supply water. In 2030, cost savings from reduced energy expenditures will translate to lower energy costs for Arizonans annually by an average of $360 per household relative to current policy.
“The passage of the IRA is an exciting time for the solar industry and our team at OMCO Solar,” said Eric Goodwin, Director of Business Development, OMCO Solar. “The bill will enable OMCO to leverage our Arizona Manufacturing footprint to bring value to our solar customers in our home state with our factory-direct single axis trackers and fixed tilt ground mount solutions.”
"Korsail Energy is honored to be engaging with Representative O’Halleran and CATF-Action. Today's discussion reaffirmed that the Inflation Reduction Act will be a powerful, pragmatic solution for Arizona as it transitions towards a clean energy future,” said Scott Meyers, Development Analyst, Korsail Energy. “As a utility-scale solar and storage developer, Korsail Energy remains committed to working with diverse groups of stakeholders to proliferate the adoption of zero-carbon energy."
The IRA will also substantially increase Arizona’s clean energy capacity by expanding solar and wind energy, investing in existing nuclear energy, increasing rural and tribal energy, and clean vehicle manufacturing. The IRA is projected to result in 47 gigawatts of new solar capacity and four gigawatts of new wind capacity, adding up to more than 50 gigawatts of new renewable energy. That is enough energy to power the equivalent of roughly 7.5 million homes.
“The Inflation Reduction Act is a once in a generation opportunity for the state to significantly improve our transportation and electric systems; making them cleaner, more equitable, reliable and affordable,” said Amanda Ormond, Director, Western Grid Group. “Arizona needs strong collaboration and coordination across energy sectors and jurisdictions to capitalize on these opportunities.”
“The passage of the Inflation Reduction Act is a crucial step toward securing energy equity and a clean future,” said Trevor Warren, Founder and President, Higherwire. “At Higherwire, our mission is to reduce burdens to renewable energy storage and production, and this legislation will help us achieve that goal. It will also spur investment and innovation to produce clean, cost-effective energy that will create local jobs and reduce energy costs for all Arizona families.”
“Ørsted is excited to be developing its first project in Arizona – Eleven Mile Solar in Pinal County,” said Brianna Berkson, Western Regional Development, Ørsted. “With the passage of the IRA, we look forward to working on more projects in Arizona, bringing jobs and tax dollars to rural areas, and offering low-cost energy to the grid.”
“The Inflation Reduction Act is a win for Arizona businesses and consumers, and the benefits will be far-reaching,” said Lindsey Baxter Griffith, Executive Director, Clean Air Task Force Action. “The law will create high-quality jobs in Arizona and across the country, support the transition to a clean energy economy, and keep American energy globally competitive and affordable for decades to come, all while helping the U.S. achieve our climate goals.”
Other panelists included Jim Mapstead from Accurate Signs; Stephen Lassiter from Sunrun; Adam Stafford from Western Resource Advocates; and Tyler Orcutt from the Coalition for Community Solar Access.
Clean Air Task Force Action is a 501(c)4 nonprofit organization and the counterpart of Clean Air Task Force. CATF Action works to advance U.S. political and advocacy objectives. Learn more at catfaction.org.
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Re: Exceptions to APS Interconnection Manual, Docket E-01345A-20-0152
Madam Chair and Commissioners,
The Arizona Solar Energy Industries Association (AriSEIA) hereby files its Exceptions to Staff’s Memorandum and Proposed Order filed on September 29th, 2022. AriSEIA appreciates Staff’s efforts in reviewing Arizona Public Service’s (APS) Draft Interconnection Manual (the “Manual”). AriSEIA believes that the Order should be amended to incorporate several outstanding changes that are important to simplifying the interconnection process and are justified based on established technology performance across the globe and in other leading U.S. markets. The following Exceptions detail what changes must be made so that APS customers can further benefit from distributed generation, which will play a critical role in modernization of the grid.
As further background, AriSEIA participated in extensive review and discussion of the Manual with Staff and APS personnel throughout 2022, and we have filed comments in this docket and submitted written feedback to both APS and Staff on outstanding issues. During the deliberation on the Commission’s Interconnection Rulemaking, we expressed our concern that there are many utility requirements that unnecessarily inflate costs while adding unnecessary time and complexity to the process for interconnecting distributed generation systems in APS territory. The Exceptions detailed herein remain in the spirit of this prior notion.
I. Production Meters for Energy Storage Systems (Section 9.2(C) and (D) of the Manual)
Section 9.2.(C) of the Manual states that a customer must provide Production Metering for any Static Inverter based Energy Storage System (ESS) (i.e., battery backup system). In addition to requiring Production Metering, Section 9.2.(D) further requires that “[c]ustomer must provide a suitable visible open disconnecting means […] to electrically isolate any CT rated meter from all potential sources of power.”
AriSEIA strongly believes that Production Metering requirements and, by extension, additional disconnecting means, are unreasonable and unwarranted for any residential or commercial customer-owned ESS designed to provide value strictly “behind the meter.” A solar system Production Meter captures all of its production. When discharging, backup batteries do not create new energy production. Furthermore, Tucson Electric Power (TEP) already acknowledged these arguments and agreed to remove their requirement for ESS Production Metering in the latest version of their Interconnection Manual filed and approved earlier this year.
A proposed amendment making this modification is attached below as Attachment A, AriSEIA Proposed Amendment No. 1.
II. Production Meters for All Generating Facilities (Section 9 of the Manual)
In general, and as an extension of our comments above, AriSEIA contends that Production Meters for any customer-owned Generating Facility are unwarranted in the post-incentive era, which included Performance-Based Incentives (PBI) and Upfront Incentives in exchange for ownership of a customer’s Renewable Energy Credits (REC). The applicable requirements of Section 9 are costly and burdensome when considering that distributed generation industries are disproportionately impacted by supply chain and inflation conditions to the extent that project viability is seriously impacted. Meanwhile, it is entirely feasible for regulators and utility companies alike to estimate solar production based on the system details included in Interconnection Applications, and we contend that such estimates are sufficient in lieu of Production Metering.
A proposed amendment making this modification is attached below as Attachment B, AriSEIA Proposed Amendment No. 2.
III. Ground Fault Detection Requirements for Class III Systems (Section 10.2(B)(2)e. and (3)e. of the Manual)
Section 10.2(B)(2)e and (3)e. states that systems in the applicable size range may require the addition of ground fault detectors in cases where the Generating Facility parallels the utility through a transformer with ungrounded configurations (float wye or delta). Utility systems must already include ground fault detection and protection with or without the presence of customer-owned Generating Facilities. In addition, Screen B of Appendix B: Interconnection Application Screens validates whether a Generating Facility’s ground fault current contributions are low enough to be safe, and any system passing this Screen should, therefore, be accommodated through existing utility equipment. At a minimum, AriSEIA contends that a clear exemption from additional ground fault detection equipment must exist for any systems which pass Screen B, as well as Non-Exporting Systems and Inadvertent Export Systems of 20 kW or less.
A proposed amendment making this modification is attached below as Attachment C, AriSEIA Proposed Amendment No. 3.
IV. Study Feed (Appendix C of the Manual)
The Commission’s Rules for Interconnection established that fees are allowed for utility studies “if a tariff containing such a fee for the Utility has been approved by the Commission.” Both APS and TEP include written handbook provisions which require specific fee deposit payments and provide for refunds through subsequent adjustment to the actual study costs (though costs are not defined). AriSEIA members consistently experience disproportionately high utility study deposits relative to the actual charges that are attributable to the work involved. Refunds are issued after extended periods of time (often in excess of 12 months) and represent a consistent majority of the original deposits that were made. Considering the excessive study deposits that the industry continues to grapple with, AriSEIA contends that the deposit amounts, and philosophy on study deposits, be revised in accordance with the following comments, and should be submitted to the Commission for approval:
A proposed amendment making this modification is attached below as Attachment D, AriSEIA Proposed Amendment No. 4.
V. Rate Schedules Applicable to Distributed Generation, System Size Limiting Factors (Appendix D of the Manual)
Under System Size Limiting Factors in Appendix D of the Manual, item 1.b., the methodology for calculating the maximum system size for non-residential DG systems is presented as “125% of connected load for its meter, where connected load is defined as the maximum demand divided by 0.6.” Item 2.a. further defines that the “connected load is measured in AC.” Based on AriSEIA discussions with Staff and APS, and written redlines from APS, AriSEIA notes that the intent of the definition in 2.a. was to establish that the system size is measured in AC, rather than “connected load,” which would translate to the output of the methodology in 1.b. being a non-residential DG maximum system size measured in kW AC.
A proposed amendment making this modification is attached below as Attachment E, AriSEIA Proposed Amendment No. 5.
Because these manuals are iterative, the utilities should establish a stakeholder process to discuss developing issues with the manuals and technological change.
We respectfully request the Commission direct APS to file a revised Manual with the amendments attached below by November 15, 2022, to be effective immediately upon filing. Thank you for considering these comments meant to improve the compliance of the APS Manual with the spirit and letter of the Commission’s Interconnection Rules.
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