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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
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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  For Immediate Release: 26 January 2022
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Arizona Regulators Reject Pathway to 100% Clean Energy Corporation Commission votes 2-3, rejecting new clean energy requirements Phoenix, AZ - Today, the Arizona Corporation Commission failed to approve new rules that would have required 50% carbon emission reduction by 2032 and 100% by 2070. The rules, known as the Energy Rules, have undergone many iterations over multiple years with diverse stakeholder input and broad public support. The passage of the Energy Rules would have meant cleaner air, healthier communities, progress on a just and equitable transition, and more local jobs. Studies show that Arizonans could have realized billions in energy benefits if the rules passed. But when faced with the opportunity to drive Arizona towards progress, Commissioners O’Connor, Marquez Peterson, and Olson missed a huge opportunity to lead. “The vast majority of Arizonans want updated clean energy requirements that will keep us competitive with our neighbors and the rest of the country, but our elected representatives on the Corporation Commission aren’t actually representing Arizonans,” said Yara Marin, Regional Director, Interior West at Vote Solar. “This is not the first time the Commission has delayed or dismissed this critical step toward an equitable clean energy future. It is unfortunate that our commissioners will allow our sunny state of Arizona to fall behind when we could easily be a leader in renewable energy.” A 2020 poll conducted by Public Policy Polling on behalf of Vote Solar found that 65% of Arizonans favor 100% clean energy by 2050. A December 2021 poll by the American Lung Association found similar results, including that 80% of Arizona voters want more solar. A broad set of organizations and companies in Arizona also supported the rules including Arizona Public Service, Tucson Electric Power, the Sierra Club, Arizona Technology Council, The Western Way, Ceres, Advanced Energy Economy, Interwest Energy Alliance, Southwest Energy Efficiency Project, and the Arizona Public Interest Research Group, among many others. “Today the sun set on what should have been a shining opportunity to advance clean energy in Arizona,” said Bret Fanshaw, Arizona Program Director at Solar United Neighbors. “Commissioners should be ashamed at wasting this chance to ensure Arizona families have greater access to clean and low-cost energy technologies.” In addition to emission reduction requirements, the comprehensive Energy Rules package also included an increase to the state’s energy efficiency standard, reforms to the commission’s integrated resource planning process, and an innovative new battery storage standard. The first-of-its-kind battery storage standard included a carveout for residential customer participation, as well as requirements for utilities to offer upfront incentives and tariff programs to battery storage users. “The Corporation Commission closed the door on a huge opportunity for economic development in our state. Solar already employs more than 7,000 people in Arizona and a strong commitment to move to 100% decarbonization would have positively contributed to our local economy,” said Autumn Johnson, Executive Director at Arizona Solar Energy Industries Association. “Instead, the Commission has wasted more than three years of government and stakeholder time and resources and has failed to take action to move toward our clean energy future. Anyone who cares about the environment, clean energy, or our economy should be disappointed.” —----------- 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. A 501(c)3 non-profit organization, Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar works to remove regulatory barriers and implement key policies needed to bring solar to scale. Solar United Neighbors is a national 501(c)3 nonprofit. SUN is a community of people building a new energy system with rooftop solar at the cornerstone. We help people go solar, join together, and fight for their energy rights. We envision a clean, equitable energy system that directs control and benefits back to local communities, with solar on every roof and money in every pocket. Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) trade organization and the state chapter of the Solar Energy Industries Association (SEIA). AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy and storage. We advocate for sustainable job creation and encourage utilization of Arizona’s greatest natural resource, the sun. On November 2, the Arizona Corporation Commission voted its final approval to eliminate Arizona Public Service (APS) company’s “grid access charge,” ending a decade-old unfair practice of charging residential solar customers a discriminatory fee. The grid access fee, averaged about $100 per year per solar customer. The Arizona Solar Energy Industries Association (AriSEIA) and the Solar Energy Industries Association (SEIA) argued that the fee unfairly targeted solar customers under the pretense that it cost more to provide them with electricity costs.
AriSEIA and SEIA testified against the charges demonstrating that solar customers paid their fair share of grid costs compared to non-solar customers. “This is an issue of a charge that tens of thousands of customers are paying,” said lawyer Court Rich, representing AriSEIA and SEIA. “It’s a charge that the commission has absolutely no way of knowing if it should be charged or at what level it should be charged at. It is about as egregious of a rate-making device as you could have.” “I appreciate the partnership between AriSEIA and SEIA to participate in this rate case” said Sara Birmingham, Senior Director at SEIA and AriSEIA Board member. “Arizona got rid of an unjustified and outdated charge that has been a drag on the Arizona solar economy. This change will more fairly recognize the benefits of local solar adoption and we hope we can expand solar accessibility to even more Arizonans.” In addition to the grid access charge, positive outcomes were achieved in revising the rules for adopting energy storage systems. The Commission made revisions to both the large customer storage rate (E-32 L), and residential (R-Tech) program to make them more user friendly for Arizona businesses and residents to install energy storage systems, as well as system sizing rules. A large congratulations is in order to the Arizona Corporation Commission for its bipartisan resolution of APS’ rate case. And a huge thank you to our Vice President of the Board – Court Rich for all his efforts in representing AriSEIA and SEIA before the commission and successful achievement of a long list of victories for rooftop solar and distributed battery storage in this case. The Arizona State Legislature adjourned at 4:54 pm on 06/30/2021. For a total of 171 days of session, tied for the third longest session with 1993. This year, 1,774 bills were introduced, the legislature passed 473 of those bills (27%), as of 7/1/2021 the governor has signed 412 of the bills and vetoed 27 bills. This means that 34 bills remain on his desk where he has 10 days (excluding Sundays) to sign, veto or allow the bill to become law without his signature. All legislation has an effective date of September 29, 2021 unless otherwise specified within the legislation.
This year, AriSEIA actively engaged in a handful of legislative efforts that would have directly impacted the Solar Energy Industry. HB 2248 Corporation Commission; Electric Generation Resources – Opposed with Lobbying Sponsored by Representative Gail Griffin – R The bill would remove the ability of the Arizona Corporation Commission to establish energy policy and restrict the Commission to rate-making authority. The legislation was aimed solely at limiting the Commission's ability to act on the Clean Energy Rules package as a retroactive date of June 30, 2020 was included in the legislation. Though this bill made its way through the House of Representatives and did receive a hearing in the Senate Appropriations Committee, AriSEIA lobbied in opposition to the legislation and it was ultimately held, receiving no further legislative action in the Senate Rules Committee, thus died. SB 1175 Corporation Commission; Electric Generation Resources – Opposed with Lobbying Sponsored by Senator Sine Kerr – R This bill is the mirrored version of HB 2248. The bill would remove the ability of the Arizona Corporation Commission to establish energy policy and restrict the Commission to rate-making authority. The legislation was aimed solely at limiting the Commission's ability to act on the Clean Energy Rules package as a retroactive date of June 30, 2020 was included in the legislation. In the Senate, AriSEIA lobbied against this legislation and though this bill did pass through the Senate Natural Resources, Water and Energy Committee, it ultimately failed to progress through the legislative process and died. HB 2737 Corporation Commission Actions: Investigation – Opposed with Lobbying Sponsored by Representative Jacqueline Parker – R This bill would have allowed any legislator to challenge any non-ratemaking decision of the Arizona Corporation Commission by filing a complaint with the Arizona Attorney General’s office. If found to exceed the Commission’s authority, the commission would lose 10% of its budget for the year. This bill passed through the House Committee of the Whole process on, however, did receive opposition from both Democratic and Republican members, and ultimately failed in the process. As a member of AriSEIA, we fight for the continued protection of the Solar Energy Industry and your livelihood. We understand that day in and day out your focus is on your business. That is where AriSEIA steps in. As a member organization, we focus on your behalf and champion the passage of pro-solar energy policies and regulations and defeat measures that present harm and detriment to the industry. But we couldn’t do it without you. Your responsiveness to Calls for Action when asked to ask and your continued commitment to AriSEIA allows for us all to thrive. If you know of an industry partner or solar company that you believe could benefit from membership in AriSEIA, please pass along their information to me at Nicole@AriSEIA.org so that I can follow up with them and continue to build on our associations efforts to bring Arizona to the forefront of the Solar Energy Industry  Twenty organizations applauded a vote today by Arizona Corporation Commissioners requiring utilities to be 100% carbon-free by 2050 and meet benchmarks along the way. The bipartisan decision also established a new energy efficiency policy to help customers save money on their electricity bills.
Click here to read the press release about this historic advancement for Arizona! For many of us, November 3 was a date we were excited to have come and go. As a political wonk, often times Election Day has been referred to as my Olympics. And as of this morning, two-days post-election, we are still awaiting the Presidential outcome, Arizona has a new Arizona State Senator, and a flip of the Arizona State House of Representatives to blue appears to not have happened.
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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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