 May 13, 2022 Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 RE: Community Solar Support in Docket No. E-01345A-21-0240 Madam Chair and Commissioners, The Arizona Solar Energy Industries Association (AriSEIA) very much supports the Commission in an effort to move forward with community solar. Community solar provides a unique opportunity for residential and small business customers to participate in the clean energy transition when they otherwise would not be able to. Community solar is a useful opportunity for those that cannot utilize rooftop solar for practical or financial reasons to be able to join together in projects that are at strategically valuable locations, still close to distribution opportunities. It also provides a way to utilize otherwise underutilized brownfield and agricultural sites. AriSEIA has many member companies that are very interested in investing in Arizona. Community solar provides another avenue for the solar industry to encourage job creation and economic growth in our state. As noted by the Coalition for Community Solar Access (CCSA), several university studies have been conducted that reflect the job and revenue opportunities for states that adopt community solar policies.[1] Failure to act allows other states, including some of our neighbors, to seize those opportunities from us, including New Mexico, Colorado, and California. Arizona should be a leader in solar in the nation. We encourage the Commission to signal to the industry that Arizona very much wants those jobs and investment dollars. We are eager to participate in the working group and feel confident that collaboration with other organizations, consumer advocates, Staff, and the utility will contribute to a better outcome. While there may not be consensus today on what the outcome of the group should be, Commissioner Kennedy’s Proposed Amendment No. 1 is an especially important step towards creating a thoughtful and workable program.[2] AriSEIA encourages the Commission to utilize the working group to explore all of these numerous benefits, as well as utilize the lessons learned from other states that have already adopted community solar policies. All of the details need not be fleshed out today, as that is the very purpose of the working group. AriSEIA is aware that there are presently two different avenues put forward as to how to commence with community solar in Arizona. We do not feel these opportunities are incompatible with each other. We fully support moving forward with a working group in the Arizona Public Service (APS) Renewable Energy Standard and Tariff (REST) docket, as well as utilizing the new docket for fact finding and programs in other service territories if a REST docket is unavailable. We urge the Commission to move forward with a working group in this docket at the May Open Meeting and recommend that a final vote on the outcome of the working group be scheduled for the October Open Meeting. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] Coalition for Community Solar Access, May 13, 2022 Letter, available here https://docket.images.azcc.gov/E000019242.pdf. [2] Commissioner Kennedy Proposed Amendment No. 1, available here https://docket.images.azcc.gov/E000018712.pdf?i=1652155834150. 
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BEFORE THE ARIZONA CORPORATION COMMISSION
COMMISSIONERS Lea Márquez Peterson – Chairwoman Sandra Kennedy Justin Olson Anna Tovar Jim O’Connor IN THE MATTER OF THE APPLICATION OF ARIZONA PUBLIC SERVICE COMPANY FOR A HEARING TO DETERMINE THE FAIR VALUE OF THE UTILITY PROPERTY OF THE COMPANY FOR RATEMAKING PURPOSES, TO FIX A JUST AND REASONABLE RATE OF RETURN THEREON, AND TO APPROVE RATE SCHEDULES DESIGNED TO DEVELOP SUCH RETURN. Docket No. E-01345A-19-0236 Arizona Solar Energy Industries Association (AriSEIA) Comments on Arizona Public Service (APS) Efforts to Comply with Order Relating to Rate Schedule E-32 L Storage Pilot in Decision No. 78317 We appreciate the Commission’s decision to include AriSEIA/SEIA in collaborative discussions with APS on the rate design elements and intended success of the E-32 L Storage Pilot (SP) plan.[1] Background The E-32 L SP tariff was established in December 2017 as a result of APS’ previous rate case with the intention to evaluate the opportunity of large-scale, behind-the-meter energy storage solutions as a value-added benefit to the grid while allowing for high demand (as determined by 15-minute interval kilowatt readings) customers to benefit from peak shaving.[2] Due to several issues, including poor rate tariff mechanics and imbalanced Cost of Service (COS) formulas (notably with lower per-kW rates than the non-pilot, base E-32 L rate tariff), the pilot program offering did not facilitate subscription from any customers. Decision No. 78318 and Current Status AriSEIA/SEIA offered testimony that the E-32 L SP rate schedule required re-evaluation. The Commission ordered APS to do the following:
Subsequent to the order, APS filed its revised rate tariff on December 1, 2021, and held its first stakeholder engagement meeting on February 23, 2022. AriSEIA/SEIA maintains that while APS is complying with the letter of the order, the spirit of the decision is being left to stakeholders to enforce. Key Issues on Proposed E-32 L SP Rate Plan and Discussion It is AriSEIA’s understanding that the intent of this pilot program is to facilitate adoption of energy storage for APS’ large commercial customer class up to 35 megawatts (MW) of installed capacity, and to that end, we submit the following feedback for consideration:
Due to the nature of variability between customer load profiles (predictability of peaks depending on facility type), the economics of energy storage vary significantly from project-to-project. Furthermore, the value proposition (i.e., return on investment), depends on whether or not a customer can monetize federal tax incentives directly. Although pending federal legislation includes a change which provides tax credits to ‘storage only’ projects, the current Internal Revenue Code only allows energy storage customers to claim available tax incentives when the storage systems are charged by solar energy (at least 75%) throughout the operational year.[6] Given that many APS E-32 L customers are tax-exempt and the fact that this tariff is unlikely to support solar projects in conjunction (i.e. tax credits will not be available), we believe it is critical that the tariff be designed in a way that provides sufficient economic incentive to pursue pilot projects for all interested customers. Conclusion Energy storage systems represent significant investments and require a precise and reliable method for return on investment. We submit that the spirit of the Order requires that APS demonstrate a thoughtful and comprehensive approach to the design of the E-32 L SP rate tariff, and we recommend an approach that leverages optionality and increased on-peak vs. off-peak differentials. As it stands, it is AriSEIA’s position that the current E-32 L SP rate plan will not facilitate any adoption toward the cap of 35 MW without substantial changes, and we recommend the Commission direct APS to issue revised rate tariff options that will provide further opportunities for customer adoption. We thank the Commission and its staff for the opportunity to submit these comments. Respectfully submitted this 6th day of May, 2022. /s/ Autumn T. Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) autumn@ariseia.org 520-240-4757 /s/ John Mitman Board President Arizona Solar Energy Industries Association (AriSEIA) john@ariseia.org 480-251-2934 [1] See APS 2019 Rate Case, Docket No. E-01345A-19-0236, Decision No. 78317, available here https://docket.images.azcc.gov/0000205236.pdf?i=1650001754509. [2] See APS 2017 Rate Case, Docket No. E-01345A-16-0036, available here https://edocket.azcc.gov/search/docket-search/item-detail/19348. [3] National Renewable Energy Laboratory, Identifying Potential Markets for Behind-the-Meter Battery Energy Storage: A Survey of U.S. Demand Charges, available here https://www.nrel.gov/docs/fy17osti/68963.pdf. [4] Southern California Edison, Schedule TOU-8 Time-of-Use - General Service – Large (Option E), available here https://www.sce.com/regulatory/tariff-books/rates-pricing-choices and included as Attachment A. [5] National Renewable Energy Laboratory, Storage Futures Study, available here https://www.nrel.gov/analysis/storage-futures.html. [6] National Renewable Energy Laboratory, Federal Tax Incentives for Energy Storage Systems, available here https://www.nrel.gov/docs/fy18osti/70384.pdf.  April 21, 2022
The Honorable Joseph R. Biden, Jr. President The White House 1600 Pennsylvania Avenue, NW Washington, DC 20500 RE: Auxin Solar Tariff Petition Dear President Biden: We write to express our serious concern regarding the U.S. Department of Commerce’s (Commerce) initiation of an anti-circumvention investigation in response to a petition filed by Auxin Solar. Commerce’s decision to launch this investigation is needlessly causing immediate and serious harm to the U.S. solar industry. We respectfully request that your Administration issue an appropriate, expedited preliminary determination, consistent with Commerce’s inherent legal authority. This petition has already had implications in Arizona. Salt River Project (SRP) filed a force majeure letter regarding a solar project last week in a docket at the Arizona Corporation Commission seeking to add nearly a GW of new gas. Arizona Public Service (APS) raised the concern over cost uncertainty of solar in its most recent resource plan advisory council meeting in the context of its forthcoming all-source request for proposals (ASRFP). Now is not the time to make the clean energy transition more costly. We need to be doing all we can to transition away from fossil fuels as quickly as possible. We share your goal of increasing domestic solar manufacturing. Unfortunately, domestic solar panel production capacity is currently less than 20% of annual demand. It will take time and smart policy to expand domestic solar manufacturing, and we stand ready to work with you to address this issue. The subject countries Cambodia, Malaysia, Vietnam, and Thailand are the source of more than 80% of solar panel imports into the United States and 54% of total U.S. panel supply. The ongoing investigation could subject these imports to tariffs ranging from 50% to 250%. Further, duty liability is typically applied retroactive to the date Commerce initiates an anti-circumvention investigation, which was April 1, 2022. As a practical matter, importers are not going to risk this level of duty exposure, and solar customers are unable to absorb these massive and unanticipated costs. As a result, solar panel shipments to the U.S. are increasingly being placed on hold and orders are being cancelled. The results have been predictable. Solar companies are struggling to access the panels they need to finish ongoing projects and begin new ones. If this situation persists, we are going to lose more than 70,000 jobs in the U.S. solar industry, including 11,000 manufacturing jobs. The imposition of tariffs will also lead to an annual loss of 16 GW of solar deployment, devastating the U.S. solar industry and our nation’s ability to address climate change. The anti-circumvention petition is based on the false notion that the production of solar cells is a minor or insignificant process. In fact, solar cell production is a sophisticated manufacturing operation and the most important step in the production of solar panels, as Commerce itself has determined on many occasions. An affirmative finding would thus improperly overturn more than a decade of established Commerce precedent. Based on the foregoing, we respectfully request that your Administration account for the economic damage, negative policy impacts, and legal flaws in the Auxin petition and render an expedited preliminary determination. Tens of thousands of American jobs are depending on a just and expeditious result. Sincerely, Autumn T. Johnson, JD, MBA Executive Director Arizona Solar Energy Industries Association (AriSEIA) autumn@ariseia.org 520.240.4757 Cc: Secretary of Commerce Gina Raimondo  AriSEIA joined a letter with several solar companies asking the Arizona Corporation Commission to direct its Staff to issue a Proposed Order on APS' outstanding interconnection manual, so that the manual can be voted on as soon as the May Open Meeting. The APS manual was filed and has been awaiting review by the Commission for years. This follows a letter by AriSEIA asking for a vote on this matter last year. A status update on this matter is on the agenda for the April Open Meeting, which is this week.
 AriSEIA filed joint comments today with Solar United Neighbors and Vote Solar in the various Demand Side Management (DSM) dockets and the docket containing APS' DDSR Aggregation Tariff. The comments highlighted that customer-sited energy storage systems can be a useful tool in reducing customers' electricity consumption. The comments were in response to a letter issued by Commission Kennedy in the DSM dockets.
March 11, 2022
U.S. Economic Development Administration U.S. Department of Commerce 1401 Constitution Avenue, NW, Suite 71014 Washington, DC 20230 RE: Coal Communities – Build Back Better Regional Challenge Dear Economic Development Administration Representative, We submit this letter jointly on behalf of Arizona Solar Energy Industries Association (AriSEIA), Solar United Neighbors (SUN), and Vote Solar in support of the Hopi Tribe’s Economic Development Administration (EDA) grant application. The solar industry is an essential part of the U.S. and Arizona’s economy. As of Q3 2021, over 113.5 GW of solar has been installed nationwide, representing over 230,000 Americans working in the solar industry. To date, Arizona has 5.2 GW of installed solar capacity representing nearly $14 billion in total solar investment in the state. In addition, the solar industry provides 7,346 jobs within the state, ranking 5th in solar jobs throughout the country. Our organizations believe in Hopi’s vision to rebuild their economy. We have witnessed the impact of coal plant closures in Arizona and have had the opportunity to meet with tribal members and organizations. We also understand Hopi’s EDA grant application and believe in their vision to rewrite their energy story. It is our understanding that the Hopi Tribe is working to develop and construct a large-scale solar facility to transition the Hopi Tribe beyond the closure of the Navajo Generating Station (NGS) and Kayenta Mine. In addition, we understand that the Tribe will pursue local clean energy infrastructure projects to improve reliability on the reservation, as well as a workforce development program that leverages the construction projects to train Tribal Members for clean energy jobs. Our organizations are committed to supporting Hopi through our networks and members. Our networks include solar contractors, installers, manufacturers, distributors, consultants, engineers and designers, residential and commercial system owners, developers, universities, solar supporting businesses, nonprofits, and members of the public. We strongly encourage the EDA to award phase 2 funding to Hopi Utilities Corporation to support the Tribe to deliver these exciting infrastructure and economic development projects through the Build Back Better program. AriSEIA’s mission is to develop and support policies that create opportunities to advance Arizona’s economy through solar energy and storage. AriSEIA is Arizona’s largest trade association for the solar industry and is part of the national Solar Energy Industry Association (SEIA). We advocate for sustainable job creation in deployment of solar and complementary technologies and collaborate with stakeholders to encourage utilization of Arizona’s greatest natural resource, the sun. SUN is a national nonprofit composed of a community of people building a new energy system with rooftop solar at the cornerstone. It helps people go solar, join together, and fight for their energy rights. SUN envisions a clean, equitable energy system that directs control and benefits back to local communities, with solar on every roof and money in every pocket. Vote Solar’s mission is to make solar a mainstream energy resource across the U.S. Since 2002, Vote Solar has been working to lower solar costs and expand solar access. Vote Solar advocates for state policies and programs needed to repower the electric grid with clean energy. It works to remove regulatory barriers and implement key policies needed to bring solar to scale. Sincerely, Autumn T. 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 Yaraneth Marin Interior West Regional Director Vote Solar yaraneth@votesolar.org 602-492-6077 March 11, 2022
Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Re: Salt River Project (SRP) Certificate of Environmental Compatibility (CEC), Docket No. L-00000B-21-0393-00197 Madam Chair and Commissioners, Our organizations submit these joint comments to urge you to vote no on SRP’s CEC application. Not only did SRP not engage in a competitive bidding process and not comply with its own 2018 Integrated Resource Plan (IRP), but it did not adequately consider alternatives to the Coolidge Expansion Project (CEP). This leaves serious concerns about the estimated cost of the facilities and the potential increase in the cost of electric energy to customers. SRP’s 2017-2018 IRP Report states that, “Prior to making any financial commitments to major equipment or construction contracts for new-build generation, [SRP will] issue all-source RFPs [Request for Proposal] for the planned capacity. That capacity will explicitly include the opportunity for cost competitive and viable energy storage and demand response options.”[1] No all-source RFP was issued prior to the decision to expand Coolidge Generating Station by 820 MW. Shortly after the SRP Board voted to narrowly approve this project, SRP issued an all-source RFP for an additional 1000 MW to come online between 2024 and 2026.[2] It is unclear why SRP can issue an all-source RFP for these megawatts, but not the Coolidge megawatts given that both projects were announced within months of each other and are intended to come online within the same time frame. There was considerable testimony at the hearing that SRP did not adequately consider alternatives to this 820 MW expansion of Coolidge. Witness Mr. Robert Gramlich testified that not only did SRP not adequately consider alternatives, but that solar and storage would have been more economical.[3] Specifically, he testified that “SRP’s economic analysis overstated the need for clean resources by a factor of 3 or 4.”[4] “So the economic analysis was distorted by overstating the capacity needed for the renewables and storage.”[5] “A battery would have been more economic than CEP.”[6] Mr. Gramlich went on to testify that SRP did not adequately consider the analysis of its own consultant, E3, in assessing the alternatives to the Coolidge expansion. “E3 found that adding only 731 MW of battery capacity in 2026 provides the same capacity value as the 820 MW CEP.”[7] Arizona Revised Statute (ARS) 40-360.06(A)(8) states that the Committee shall consider “The estimated cost of the facilities and site as proposed by the applicant and the estimated cost of the facilities and site as recommended by the committee, recognizing that any significant increase in costs represents a potential increase in the cost of electric energy to the customers or the applicant.”[8] Further, ARS 30-360.07(B) states that the Commission shall “comply with the provisions of section 40-360.06 and shall balance, in the broad public interest, the need for an adequate, economical and reliable supply of electric power with the desire to minimize the effect thereof on the environment and ecology of this state.”[9] Therefore, the Commission must consider the cost of the project and the economics of supplying that electric power. Because SRP did not conduct an all-source RFP, the Commission does not have adequate information about the alternatives to this project and the potential for a less costly option, such as solar and storage, that would save customers money and better protect the environment and ecology of the state. Approval of the CEC application risks locking customers into significant new costs without evidence that the CEP is the right choice to meet the identified capacity need. We ask the Commission to vote no on this CEC application and direct SRP to proceed with an all-source RFP to consider the best available option for adding 820 MW between now and 2025. Respectfully, Autumn T. 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 Yaraneth Marin Interior West Regional Director Vote Solar yaraneth@votesolar.org 602-492-6077 [1] Salt River Project, Integrated Resource Plan Report, P.49, available here https://srpnet.com/about/stations/pdfx/2018irp.pdf. [2] Salt River Project, 2021 All-Source Request for Proposals, available here https://srpnet.com/energy/secure/all-resource-rfp.aspx. [3] February 15, 2022 Hearing Transcript, starting at P.1116, available here https://srpnet.com/electric/transmission/projects/Coolidge/pdfx/cec/07_02-15-2022_SRP_Coolidge_Expansion_Evidentiary_Hearing.pdf. [4] Id. at 1118, L.3-4. [5] Id. L. 6-8. [6] Id. L.9-10. [7] Id. at 1121, L.1-3. [8] ARS 40-360.06(A)(8) available here https://www.azleg.gov/ars/40/00360-06.htm. [9] ARS 40-360.07(B) available here https://www.azleg.gov/ars/40/00360-07.htm.  Speakers highlight the importance of solar investments to Southern Arizona’s growing clean energy industry
(Tucson, AZ) – Today, Arizona State Representatives Daniel Hernandez (D-2) and Morgan Abraham (D-10) joined solar power advocates gathered for a press conference to call on the U.S. Senate to pass significant investments in climate and clean energy to support the state’s growing clean energy industry. This event was sponsored by Solar United Neighbors Action. In late 2021, the U.S. House of Representatives delivered for the American people with its historic vote to approve $550 billion in climate investments. This included landmark investments in climate change, clean energy, justice, equity, families, and communities. The speakers thanked Senator Mark Kelly for leading on clean energy growth and solar power, and urged him to continue to fight for Arizonans by supporting critically needed investments to address the climate crisis, increase the adoption of solar power in Tucson, and drive growth in Arizona’s renewable energy sector. “When it comes to confronting the climate crisis, our leaders are responsible to do everything in our power to protect both the lives and livelihoods of our constituents,” said State Rep. Daniel Hernandez (D-2) “The results we’ve already achieved at the state level and in cities like Tucson illustrate that an economy that is more resilient to climate change can also be one that creates better-paying jobs and sets up Arizona’s cities for decades of high-tech economic growth. We know that climate change and economic growth are top of mind for Mark Kelly, and we need his help to secure the votes needed to pass this transformational climate funding through the Senate.” “Arizonans are already battling climate change in the form of worsening air quality, more extreme heat, and increasingly frequent potential droughts,” said State Rep. Morgan Abraham (D-10). “There’s broad awareness in this state that taking creative and committed action to move toward more clean energy is of critical importance, and the data is also clear that this transition has the potential to promote entrepreneurship and to create tens of thousands of high-quality long term jobs across Arizona in the process. Mark Kelly has proven time and again that he is a leader who puts science, pragmatic problem solving, and the safety of his constituents first, and we’re counting on him to fight for us to pass this critical climate funding.” Speakers stressed that time is running out to address the climate crisis. Climate change is making extreme weather events more frequent and severe with communities across the state paying the price. From 2010 to 2020, Arizona experienced 13 extreme weather events, costing the state up to $10 billion in damages. More than 40% of Americans experienced a climate change-fueled extreme weather event in 2021 alone. "Going solar helps families save money by taking control of where their electricity comes from," said Adrian Keller, Program Associate with Solar United Neighbors Action. "Congress has an opportunity to help more Arizonans benefit from solar energy. It should take it. In November, the House passed a bill with important investments that will ensure solar's benefits are shared by rural and underserved communities across the state. These investments will create good local jobs. Now, it is up to the Senate to come together to pass these needed measures." These investments in clean energy will not only help fight climate change but also will bring massive economic growth to Arizona. Prior to the COVID-19 pandemic, clean energy jobs were growing faster than the economy as a whole. As of 2021, there were more than 56,000 Arizona residents working in clean energy. Passing the $550 billion in climate investments will add nearly 83,000 jobs in Arizona over the next five years. “Arizona’s solar industries have already proven we can grow fast to meet ambitious capacity goals and create thousands of high-quality, long term jobs in this state,” said John Mitman, President of Arizona Solar Energy Industries Association. “Now, the country has a pivotal opportunity to expand on that progress on an unprecedented scale. This is not only critical funding for the climate fight, but also $550 billion of incentives and investments that will fuel cutting edge industries, foster entrepreneurship across this state, and create tens of thousands of family-sustaining jobs over the next five years. The House did their job – now we need the Senate to step up and pass this bill.” “The people of Arizona have been on the front lines of the climate crisis, and there is a clear popular will behind the measures that passed the House earlier this winter,” said Duane Etiger, of Sustainable Tucson. “This is long overdue funding that will fuel a revitalization and realignment of Arizona’s economy as we create thousands of jobs electrifying dangerously carbon-dependent transportation and broader energy use. These are investments in sustainability, but they are also investments in economic justice, in inidigineous communities and communities of color, and a more prosperous future for our state as a whole. We’re grateful for Mark Kelly’s past leadership on climate, and we’re counting on him to follow the science and champion this bill on behalf of Arizona.” A video of the in-person press conference can be found here. The event was held at The Historic Y in Tucson, Arizona. The Historic Y is the premier center for the arts, education, human rights, and social and environmental justice in Southern Arizona. In 2017, The Historic Y installed a 65.21 kW SunPower PV Solar System on the building’s rooftops that in 2018 accounted for approximately 45% of The Historic Y’s electric consumption. AriSEIA filed extensive comments and amendments on Friday, February 4, 2022 with the Arizona Corporation Commission (ACC) calling for changes with Tucson Electric Power (TEP)'s interconnection manual. Specifically, AriSEIA proposed changes to the treatment of Meter Socket Adapters; Construction Timelines; Fast Track, Non-Exporting, and Inadvertent Export Systems; and Fees and Costs charged to customers. This matter is on the agenda for the ACC's February Open Meeting on February 8, 2022. You can find the agenda and watch the meeting here.
February 7, 2022
Arizona House of Representatives Arizona State Capitol Complex 1700 W Washington St Phoenix, AZ 85007 RE: HB 2101 - Opposed Dear Representatives, The Arizona Solar Energy Industries Association (AriSEIA) is a nonprofit trade association representing the solar and storage industry in Arizona. We focus on educating the public and key decision makers about solar, storage, and energy efficiency. We also advocate on behalf of policies that create opportunities to advance our economy through these technologies. AriSEIA respectfully asks you to vote no on HB 2101. The 9th Circuit Court of Appeals recently issued a landmark decision regarding rooftop solar. Ellis v. Salt River Project (SRP) was decided on Monday, January 31, 2022 and a copy of the decision can be found here. The case is a class action lawsuit against SRP for its treatment of rooftop solar customers. In 2014, SRP announced its E-27 rate plan, which increased costs for rooftop solar customers by 65% and resulted in a decrease of rooftop solar applications by 50-96% (pg. 7). The Court found that SRP was subject to federal antitrust laws for its treatment of rooftop solar customers. SRP asserted two defenses, one of which is applicable here. SRP said that the “state action immunity doctrine” protected it from liability (pg. 25). However, relying on ARS 40-202(D), 30-803(A), 30-805(E), 30-803(F), 30-802(B)(1)(a), 30-805(D), and 30-813, the Court found that "the State of Arizona has not articulated a 'policy to displace competition.'" In fact, the State of Arizona has demonstrated a policy in favor of competition (pg. 26). Even though the Arizona Corporation Commission has not acted on those statutes, the Court reasoned that the statutes demonstrate the favored policy of the state. "Even if '[t]he sort of competition [Arizona law] envisions has yet to emerge on the scale the legislature hoped,’ Arizona has clearly 'expresse[d] a policy preference for competition in electricity generation and supply,'" (pg. 27). Should HB 2101 become law, the statutes that the 9th Circuit relied on to rule in favor of rooftop solar customers would be eradicated and the outcome of the case would very likely be different. Rooftop solar is not a partisan issue. Rooftop solar customers come from all walks of life. Some customers adopt rooftop solar because they want to utilize clean energy. Others do it because they value resiliency and self-reliance and want their homes and families to be independent from the grid. Still others do it to save money on their monthly electric bills. No matter why you might favor rooftop solar, it is a choice that each family should get to make for themselves, and the utilities should not be able to put their thumbs on the scale to make it so burdensome to adopt that families are prevented from making the decision. Arizona also has abundant sun and many of the businesses in this industry are local, small businesses. Please vote no on HB 2101 if you support rooftop solar or support individual families being able to decide for themselves if it is something they value and want to adopt or support the small businesses giving them that choice. Sincerely, Autumn T. Johnson, JD, MBA Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org |
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The Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) non-profit trade association representing the solar and storage industry, solar-friendly businesses, and others interested in advancing solar and storage technologies in Arizona. The group's focus is on education, professionalism and promotion of public policies that support deployment of solar technologies and renewable energy job growth and creation. |
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