Arizona Corporation Commission
1300 W. Washington Street Phoenix, AZ 85007 RE: Comments on the APS and TEP 2023 IRPs, Docket No. E-99999A-22-0046 Chairman, Commissioners, and Staff, AriSEIA is an active member of the Resource Plan Advisory Council (RPAC) for both Arizona Public Service (APS) and Tucson Electric Power (TEP). AriSEIA also jointly hired Rocky Mountain Institute (RMI) to engage in the RPAC process. Their findings are filed separately from these jointly with Vote Solar and Advanced Energy United. AriSEIA submits the following comments on APS[1] and TEP’s[2] Integrated Resource Plans (IRPs) filed on November 1, 2023. Our comments include four sections. First, we include documentation on the affordability and reliability of solar resources. Second, we make recommendations as to the forthcoming Order. Third, we include an analysis of APS’ plan. Fourth, we include a review of TEP’s plan. /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] APS, 2023 IRP, Filed Nov. 1, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000031965.pdf?i=1704923236078 [hereinafter APS IRP]. [2] TEP, 2023 IRP, Filed Nov. 1, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000031960.pdf?i=1704923236078 [hereinafter TEP IRP].
0 Comments
Sierra Club, the Arizona Solar Energy Industries Association, Western Grid Group, Arizona Public Interest Research Group Education Fund, Southwest Energy Efficiency Project, and Western Resource Advocates (collectively, the “Joint Signatories”) provide the following comments regarding Staff’s memorandum, five-year report, and proposed order in Docket No. AUD-00000A-23-0142.
I. BACKGROUND On May 26, 2023, the Utilities Division issued a memorandum opening this docket to review the following Commission rules as part of the Commission’s 5-year review procedure:
On November 30, 2023, Staff issued a memorandum, five-year report, and proposed order recommending that the Commission open a new rulemaking docket to consider amendments to the above-listed rules, with the exception of Article 7 (resource planning and procurement), which already has an existing rulemaking docket (Docket No. RE-00000A-22-0029). Staff’s attached five-year report reviews the objectives, effectiveness, clarity, and probable costs and benefits of each section of Articles 7, 9, 18, 24, and 25, and recommends that portions of each article be amended. II. CONSIDERATION OF POTENTIAL CHANGES TO RESOURCE PLANNING RULES If the Commission decides to consider potential changes to the integrated resource planning (“IRP”) rules in Article 7, the Joint Signatories agree with Staff that such consideration should occur in the existing IRP rulemaking docket (Docket No. RE-00000A-22-0029). A. The Commission Should Consider the Existing Record in the IRP Rulemaking Docket. In considering any proposed changes to the IRP rules, the Commission should refer to the existing record in Docket No. RE-00000A-22-0029. In that docket, proposed rules were developed by Staff via a collaborative process with extensive stakeholder input, which included multiple rounds of comment and several day-long in-person meetings over more than a year. On March 10, 2022, Commission Staff filed a memorandum and proposed order containing the text of proposed rules governing All-Source Requests for Proposals (“ASRFPs”) and the IRP process, which would have been contained in a new Article 28 of the Commission rules.[1] While it appears the current 5-year review rulemaking docket is intended to be narrower in scope, parts of Staff’s 2022 proposal remain relevant and could be adopted via amendments to Article 7. On March 11, 2022, Sierra Club, Western Grid Group, Tierra Strategy, and Western Resource Advocates filed joint comments on Staff’s proposed IRP rules.[2] Those comments are incorporated herein by reference. The 2022 joint comments expressed support for most aspects of Staff’s March 2022 proposal, concluding that the proposed rules would modernize and strengthen Arizona’s IRP process, promoting transparent and accountable resource planning. The 2022 joint comments supported Staff’s proposal to require that a competitive ASRFP procurement process be fuel-neutral and technology-neutral. The comments also supported a robust stakeholder input process via Resource Planning Advisory Councils, and supported requiring utilities to provide stakeholders and Staff with access to modelling software as a permanent feature of the IRP process. However, the 2022 joint comments expressed concerns about a few aspects of Staff’s March 2022 proposal, opposing the inclusion of biomass in the definition of renewable energy resources, and called for IRPs to prioritize development of renewable and clean energy resources in impacted communities affected by fossil fuel power plant closures. Sierra Club filed further comments regarding the Commissioners’ proposed amendments in the IRP rulemaking docket on April 13, 2022, which are incorporated herein by reference.[3] B. The Commission Should Consider Updating Definitions in the IRP Rules. With regard to Staff’s proposed order and 5-year review report in Docket No. AUD-00000A-23-0142, the Joint Signatories agree with Staff that Section R14-2-701 should be amended to clarify the definition of “renewable energy resource” and to define the terms “Resource Planning Advisory Council” and “All-Source Request for Proposals.”[4] The Joint Signatories intend to provide further substantive comments on potential changes to this and other sections of Article 7 if the Commission proceeds with the IRP rulemaking process. C. The Commission Should Include Robust Stakeholder Input In the IRP Rulemaking. The Article 7 IRP rules proposed for review encompass a number of important statewide policy issues related to utility resource planning. Potential amendment of these rules could have far-reaching consequences. These important issues require thorough consideration and robust input from interested parties. The rulemaking process must be transparent and provide ample time for all interested stakeholders to fully participate. In considering any proposed changes to the IRP rules, the Commission should provide extensive opportunities for meaningful stakeholder input. This should include (1) stakeholder workshops, (2) development and issuance of an initial proposal by Staff, including the text of proposed changes to the rules, (3) adequate time for stakeholders to review that proposal and provide feedback, including recommended changes to the text of the rules, (4) issuance of a final proposal by Staff, and (5) adequate time for stakeholders to provide written comments on the final Staff proposal and any proposed amendments prior to the Commission vote. III. CONCLUSION In considering any proposed changes to the IRP rules, the Commission should refer to the existing record in Docket No. RE-00000A-22-0029, and should provide ample opportunities for further stakeholder input. If the Commission decides to consider potential changes to the IRP rules via a rulemaking process as proposed by Staff, the Joint Signatories intend to participate fully in that process, and will provide more detailed comments at the appropriate time.[5] [1] Utilities Division Memorandum and Proposed Order, No. RE-00000A-22-0029 (Mar. 10, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/295540. [2] Sierra Club, Western Grid Group, Tierra Strategy, and Western Resource Advocates, Stakeholder Comments on Possible Rulemaking for the Adoption of All-Source Requests for Proposals and Integrated Resource Planning Rules, No. RE-00000A-22-0029 (Mar. 11, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/295575. [3] Sierra Club, Comments on Amendments to Rulemaking for the Adoption of All-Source Requests for Proposals and Integrated Resource Planning Rules, Docket No. RE-00000A-22-0029 (Apr. 13, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/296682. [4] See Utilities Division Memorandum and Proposed Order, No. RE-00000A-22-0029 (Mar. 10, 2022), Exhibit A at 1. [5] The Joint Signatories’ silence as to any aspect of Staff’s memorandum, five-year report, and proposed order not addressed in these comments should not be interpreted as agreement with or endorsement of those aspects. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: TEP Rate Case, Customer Storage Program Stakeholder Meeting, Docket No. E-01933A-22-0107 Chairman and Commissioners, AriSEIA submits these comments in response to the compliance filing that TEP filed on December 7, 2023, in response to the stakeholder process they were ordered to commence regarding a Bring Your Own Device (BYOD) program (also known as Virtual Power Plant (VPP)) and revisions to the R-TECH and LGST-SP tariffs.[1] These stakeholder processes are the result of Order 79065.[2] Because some of the utilities have recently been using their compliance filings as evidence in other proceedings and have also asserted that stakeholder silence is agreement, AriSEIA makes this filing to detail our numerous concerns about how TEP has so far engaged on BYOD, R-TECH, and LGST-SP. AriSEIA put forth a robust proposal to implement a BYOD program, as well as specific modifications to the R-TECH and LGST-SP in the course of the last rate case. Those proposals are the reason this stakeholder process was ordered. Further, TEP stated multiple times in the course of the last rate case proceeding that they had not had time to review the proposals. January will be one year since AriSEIA filed those proposals and TEP still seems unfamiliar with them. BYOD is a win/win for AZ ratepayers and the utilities. AriSEIA’s BYOD proposal leverages private investment in distributed battery storage to provide much needed capacity to the grid at a price that is less than the cost of utility-owned, utility scale battery storage.[3] Further, any costs associated with the program are pay for performance only. There is no upfront payment, no subsidy, no cost shift. At the stakeholder meeting held by TEP on November 17, 2023, TEP had no substantive content prepared, had no response to the AriSEIA proposals, had no proposals of its own, did not have the correct people at the meeting to discuss policy, nor did they articulate any plan for how to manage this process going forward. Further, despite the fact that the Order is clear as to what these stakeholder processes are meant to do, TEP was not clear in its direction to participants as to what we were even there to discuss. TEP permitted the meeting to devolve into a tangent conversation about wholly unrelated technologies or whether or not storage should even be considered, despite the fact that storage is the very reason the stakeholder process was ordered. AriSEIA makes the following recommendations to the Commission and TEP: 1. TEP should have the correct personnel at the stakeholder meetings to discuss policy and regulatory issues; 2. The AriSEIA proposals on BYOD, R-TECH, and LGST-SP should be the basis on which the process unfolds. TEP should come to the meetings prepared to suggest components of these programs they can or cannot support; 3. R-TECH and LGST-SP are separate issues and while they are to be discussed concurrently with BYOD, need not be discussed simultaneously; 4. TEP needs to provide a capable facilitator of the meetings and process, either internal or external; 5. If TEP wishes to host additional stakeholder meetings on unrelated topics or technologies, it can do so, but these processes should remain consistent with and adherent to the Order and the issues discussed in the last rate case; and 6. TEP needs to articulate a process and timeline for this work. We suggest monthly meetings of one hour, which should be scheduled in advance with a stakeholder list, like TEP does for its other “collaborative” meetings. AriSEIA’s proposal on all three matters can be found in Kevin Lucas’ direct testimony, filed on January 27, 2023, starting at page 314.[4] An excerpt of that testimony is attached herein. /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] TEP, Notice of Filing-Tucson Electric Power Company’s Customer Storage Program Stakeholder Meeting Summary, Dec. 7, 2023, Docket. No. E-01933A-22-0107, available here https://docket.images.azcc.gov/E000032546.pdf. [2] ACC, Opinion and Order No. 79065, Pg. 149, Lines 11-27, Aug. 25, 2023, Docket No. E-01933A-22-0107, available here https://docket.images.azcc.gov/0000209684.pdf?i=1701984045033. [3] Kevin Lucas in APS rate case, hearing test., Sept. 1, 2023, Docket No. E-01345A-22-0144, 00:04:31 (this is also applicable in the TEP rate case). [4] AriSEIA, Direct Testimony of Kevin Lucas, Jan. 27, 2023, Docket No. E-01933A-22-0107, available here https://docket.images.azcc.gov/E000023835.pdf?i=1701984045030. AriSEIA filed its final brief in the APS rate case today. The brief addresses false and misleading statements in APS' opening brief related to VPP, microgrids, community solar, E-32L SP, and its solar cost of service study. You can read the brief at the link above. A decision is expected in Q1.
AriSEIA filed its opening brief today in the ongoing APS rate case. AriSEIA and SEIA's primary objectives in this rate case are to establish a Bring Your Own Device ("BYOD") program to leverage private investment in behind the meter batteries to lower costs for all ratepayers, stop APS' expansion into customer-sited microgrids, revise the battery-supporting E-32 and R-TECH tariffs, establish new and recalculate existing EV tariffs and demand charges, reject APS' solar cost of service study, and reconsider the Commission's community solar policy statement.
There is a common misconception that solar projects do not contribute to the economy nor generate tax revenues for local governments. The report showed that in the first year during construction an estimated $1.1 million in tax revenues and 302 jobs would be created in the local economy from one sample project. In addition, over the life of the project, more than $28.1 million in tax revenue would be generated by personal property tax on equipment. These taxes would directly benefit the county, fire districts, school districts, and other special districts such as flood control, library, and education districts. All totaled, the example solar project would create over $442.5 million in economic activity within Mohave County during construction and 40 years of operations. Again, this is all from just one single project. Additional projects would result in proportional, additional revenue.
If you currently have solar on your home or you hope to someday have solar on your home, ACC Commissioners need to hear from you and soon. This is docket number 14-0023 and you can attend the meeting in person at 10 a.m. on Oct. 11 at 1200 W. Washington St. in Phoenix and/or you can call or email Commissioners to tell them not to re-open the decision they already made on solar and renege on their commitment to 270,000 people in the State of Arizona. The contact information for every Commissioner can be found at azcc.gov/contact. In Arizona, Commissioners are also elected statewide and choices they make that impact your pocketbook ought to be remembered on election day.
FOR IMMEDIATE RELEASE
Arizona Corporation Commission Decision Creates Economic Uncertainty for Rooftop Solar Solar advocates criticize ACC's decision. WATCH Our Press Conference Here Phoenix, Arizona — Yesterday, the Arizona Corporation Commission (ACC) held a meeting to discuss the value of solar. The agenda included a vote on reopening the Value of Solar proceeding, whether to change the 10-year buyback rate lock-in period for solar customers and the rule limiting the reduction in buyback rates to no more than 10% per year, and reversing course on the grandfathering of legacy net metering customers. Thousands of people wrote to the Commission, and dozens provided oral testimony during the meeting, overwhelmingly opposed to the ACC reopening the value of solar proceeding or increasing the step-down rate. Those in opposition included solar homeowners, solar workers, clean energy advocates, ratepayer advocates, and every regulated utility in the state. The Commission decided not to re-open the Value of Solar case, which dictates how solar owners who installed in 2017 or later are credited for the surplus energy they contribute to the grid. However, the Commission did vote to open a new docket to re-evaluate the 10% step-down limitation and lock-in period for future solar customers. The original 2017 Value of Solar decision, reached after a lengthy evidentiary hearing and extensive deliberation and compromise, was designed to ensure predictable compensation for solar owners while providing stability to Arizona's rooftop solar market. Current solar customers will maintain their rates. Autumn Johnson, Arizona Solar Energy Industries Association (AriSEIA), said, "We are very disappointed in the decision to open a new proceeding on the value of solar. Even opening the docket plunges the market into uncertainty. The new hearing to design a rate case for future customers could have a lasting and detrimental impact on both the solar industry and consumers. Solar is not just a source of clean energy; it's a driver of economic growth, job creation, and energy independence. It's essential to remember that the solar industry has been a significant contributor to Arizona's economy, providing thousands of jobs and attracting investments that benefit local communities." While the ACC did not re-open the export rate proceeding today, the potential changes could still substantially reduce compensation for solar energy and erode critical protections for homeowners investing in solar power. The step-down limit and lock-in period give homeowners predictability about the compensation they will receive for energy exported to the grid, which is critical when deciding to invest in solar. Changing these rules would directly impact the Arizona solar industry during a period of heavy federal investment in clean energy. “We're deeply concerned that any changes to how solar owners are credited for their extra power will jeopardize the future of rooftop solar in Arizona. Without the assurance of stable and predictable savings, many Arizonans will lack the confidence to go solar. Low-income and historically disadvantaged communities, especially, will be unable to access solar savings. The decline in rooftop solar growth would harm all ratepayers since rooftop solar creates a more affordable, efficient, and reliable power grid for everyone. It's crucial that we continue to work together to ensure a fair and equitable energy future with rooftop solar at the cornerstone,” said Adrian Keller of Solar United Neighbors. Prior to the meeting, stakeholders hosted a webinar and press conference to shed light on the need to maintain the established rates solar customers are paid by their utility for the extra power they provide to the grid. Experts from Vote Solar, AriSEIA, and Solar United Neighbors provided comments during the ACC meeting. "It's disheartening to witness some Commissioners actively seeking to undermine the value of distributed generation and disrupt the stability that consumers have come to rely on. We firmly believe in the value of distributed generation, like rooftop solar, as a crucial component of a clean and resilient energy future. We'll remain steadfast in our commitment to advocate for policies that prioritize the interests of consumers, the growth of renewable energy, and the protection of energy independence. We are proud of the thousands of people who sent in comments and the dozens who testified against these harmful decisions. We will work together in the new hearing to ensure equitable access to clean energy solutions.” said Kate Bowman, Vote Solar. Commissioners Nick Myers, Jim O'Connor, and Kevin Thompson all voted in favor of the new proceeding. Commissioners Lea Márquez Peterson and Anna Tovar voted against reassessing the stepdown and lock-in rates. The dates for the new hearing are forthcoming, with the six-month proceeding to take place next year. ### For media inquiries, interviews, or further information, please contact: Autumn Johnson autumn@ariseia.org 520-240-4757 Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) trade organization and the state affiliate of the Solar Energy Industries Association (SEIA). AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. We advocate for sustainable job creation and encourage utilization of Arizona’s greatest natural resource, the sun. Solar United Neighbors is a 501(c)3 nonprofit organization that works in Arizona and nationwide to represent the needs and interests of solar owners and supporters. Solar co-ops are part of the organization’s mission to create a new energy system with rooftop solar at the cornerstone. Solar United Neighbors holds events and education programs to help people become informed solar consumers, maximize the value of their solar investment, and advocate for fair solar policies. Vote Solar is a 501(c)3 non-profit organization. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar works to remove regulatory barriers and implement key policies needed to bring solar to scale. Vote Solar works to realize a 100% clean energy future through a solutions-driven, people-first approach. Mohave County Supervisors
700 W. Beale Street Kingman, AZ 96401 RE: Opposition to the Resolution Implementing the Moratorium on the Designation of the E (Energy Overlay) Zone Dear Chairman and Supervisors, The Arizona Solar Energy Industries Association (AriSEIA) is an Arizona based nonprofit, focusing on policies that advance the adoption of solar, storage, and electrification. We urge you to vote NO on the moratorium on renewable energy projects in Mohave County at the Board of Supervisors meeting on October 16, 2023. Economic Benefits. This moratorium will affect the county’s opportunity to benefit from the tax revenues of these projects which could address some of the county’s potential budget deficit issues. In August 2023, the Board voted for a hiring freeze until plans could be made to address the County’s potential $18.5 million deficit.[1] The County is considering an 18% budget cut that would affect, “one-in-five county employees” according to the County’s Chief Financial Officer.[2] Utility scale solar projects could help the County avoid the economic difficulties from the necessary austerity measures it will need to take to address this budget deficit. For example, constructing a 100 MW utility scale project, depending on equipment costs, labor costs, financing costs, and other federal incentives, could cost between $100 - $200 million. The tax revenue from this project using the standard formula of Property Tax Revenue = Assessed Property Value × Property Tax Rate, could be between $1.25 – 2.5 million a year. If we then assume that the following projects: White Hills (450 MW), Mineral Park Solar (275 MW), and Leo Solar (300 MW), all projects proposed on public lands in Mohave County, being considered by the BLM, were on private property, the county could easily collect between $12.8 to $25.6 million per year in tax revenues. This would essentially solve the County’s budget deficit issues. AriSEIA did commission a study by Elliott D. Pollack & Company to assess the benefit to the County of a sample solar + storage project. The study is attached and found that the total economic impact of a single project was $442.5 million in economic impact countywide. The fiscal or tax impact of a single project to the County would be nearly $31 million. Low Water Usage. The draft of the resolution implementing the moratorium, incorrectly cites the study by Kahled Hasan, et al, Effects of Different Environmental and Operational Factors on the Solar Performance: A Comprehensive Review,[3] to justify the statement, “WHEREAS a significant amount of water and other resources are necessary to maintain solar panels in desert and arid environments.” In the Kahled et al. study, the researchers attempt to understand the environmental conditions that may affect the performance of solar systems during their operational lifecycle by conducting a review of the academic literature on the topic. While their study shows that dust and humidity do affect the performance of solar systems, they show that the use of hydrophobic (water repelling) and hydrophilic (water dispersing) coating materials for the panels help clean them by sweeping away all the dirt during a rain. While the study suggests that sprinkling water on the solar modules helps reduce their temperature thereby improving performance, it does not discuss how much water is needed to perform this. In fact, the study suggests that properly tilted solar modules with the necessary cooling and self-cleaning material would require as little water as possible during their lifecycle. In fact, operators of solar farms do not wash the panels, as it costs more to do than the benefit obtained. A study from researchers at the Brookhaven National Laboratory, shows that when compared to conventional power generation technologies such as coal and natural gas, solar actually uses far less water during its lifecycle. That study looked at the lifecycle uses of water of different generation technologies across the United States and concluded that solar and wind are the best options for conserving water supply, when compared to coal, nuclear, oil/gas, and biomass technologies.[4] Another study by researchers at the National Renewable Energy laboratory (NREL), estimated both the water withdrawal and consumption of electricity generating technologies. Again, they found that solar and wind technologies use less water than their counterpart energy technologies. This study looked at the use of water through the entire lifecycle of the technology from component manufacturing to fuel acquisition to power plant operation and decommissioning, and concluded that the water used by thermoelectric plants, such as coal, oil/gas, and nuclear for water cooling still dominate the entire water value chain in electricity production.[5] Panel Safety. The draft resolution states that the “impact of these renewable energy projects on the local population and environment over a long period of time is unknown.” This is not the case. The long-term impacts of some renewable energy technologies such as solar and wind, on host and surrounding communities have been extensively studied in the United States and other parts of the world. One such study on the environmental impacts during the installation and operation of large-scale solar power plants studied these effects with respect to land use, climate, geohydrological resources, and human health in comparison to traditional power systems.[6] They found that solar causes less exposure to hazards like mercury, cadmium, and particulate matter. Further, risks of site contamination are much less than for most other industrial uses because solar technologies employ few toxic chemicals and those used are present in very small quantities.[7] Testing shows that silicon and cadmium telluride (CdTe) panels are both safe to dispose of in landfills and are also safe in worst case conditions of abandonment or damage in a disaster.[8] Multiple sources report that most modern solar panels (both crystalline silicon and cadmium telluride) pass the Toxic Characteristic Leaching Procedure (TCLP), which is a test method used to determine whether a waste is a toxic hazardous waste.[9] Interconnected Grid. During the public hearing meetings on August 7, 2023, and September 5, 2023, some residents and other stakeholders raised the issue of the location of these large utility scale solar projects in Mohave County. They were specifically concerned about the fact that the power generated from the solar farms may not be used by residents of Mohave County. This is a misunderstanding of how the U.S. electric power grid operates and how electricity is regulated at the Federal and State levels. Utility scale solar projects can only be located in areas where land is plentiful and the solar resource – the sun – is abundant. This makes Arizona a good location for these projects. In addition, once a generation asset is connected to the transmission system, there is no way of determining which electrons go to a specific consumer. This is because electricity takes the path of least resistance. Hence there is no way of knowing if the electricity used by residents in Mohave County was generated in Mohave County. The important issue is that there should always be enough capacity on the grid to meet the demand in real time, which is consistently changing. If this is not the case, the reliability of the grid could be called into question. For example, UNS Energy Inc. (UNSE) owns a total of 291 MW of installed thermal capacity from three natural gas generation plants. Only Black Mountain is in Mohave County, with Valencia and Gila River projects located in Nogales and Maricopa respectively. UNSE also purchases about 36% firm capacity through wholesale market power purchase agreements (PPA) to address summer peaks, and also purchases over 89.4% of its renewable energy resources through PPAs with third parties.[10] This is similar to Mohave Electric Cooperative (MEC), which is a member of the Arizona Electric Power Cooperative (AEPCO). AEPCO is the generation and transmission (G&T) co-op utility for Mohave and six other distribution co-ops in Arizona, New Mexico, and California. While MEC owns two solar farms in southeast Fort Mohave, AEPCO, from which it purchases most of its electricity, owns generation assets throughout Arizona and California. This means that Mohave County residents are consuming electricity generated in other counties in Arizona and even in California. The interconnected nature of the US electric power grid is a strength. If a major generation plant in Mohave County fails, its residents can be rest assured that they have access to power from Nevada, California, New Mexico, and other states in the west. Environmental Impact Statements. The draft of the resolution stated that “additional information and research are needed to determine the allowable groundwater usage and suitable areas for large projects such as solar, wind, and geothermal. The location of a facility that uses water, while on the surface may fit the area and general plan, may overuse water and other resources in the groundwater basin.” The draft went on to refer to the environmental impact statement on the Desert Sunlight Solar Farm, one of the largest solar farms in the country located on the California Desert Conservation Area, to justify that claim. This is incorrect. The California Desert Conservation Area is a vast ecosystem located in Southern California managed by the BLM. Based on the environmental impact statement, the BLM amended the “California Desert Conservation Area Plan (CDCA Plan) to allow for solar energy and of a right-of-way (ROW) grant to lease” the land to the developers of the project, which was commissioned in 2015. In fact, according the BLM, many of the adverse impacts of the projects “to biological resources, cultural resources, land use, visual resources, hydrology, water quality, and water use,” were adequately “avoided or substantially reduced based on compliance with applicable laws, ordinances, regulations and standards, and compliance with measures provided” in the impact statement.[11] Hence by conducting the environmental impact study, the effects of the project on wildlife, groundwater, and other resources were adequately known and appropriately mitigated. In fact, a 230 MW Battery Energy Storage System (BESS) was added to the Desert Sunlight Solar farm in August 2022.[12] Conducting an environmental impact study is standard procedure for utility scale solar projects. For the reasons articulated above, please vote no on the draft resolution and reject a renewables moratorium in Mohave County. Respectfully, Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] River City Newspapers, County to Consider Exceptions to Hiring Freeze, Aug 30, 2023, available here https://www.havasunews.com/news/county-to-consider-exceptions-to-hiring-freeze/article_8cbda648-45fa-11ee-bf3b-1b533a671250.html. [2] Today’s News Herald, As County Faces $18.5 Million Deficit, Departments Present Bleak View of Possible Cuts, September 20, 2023, available here https://www.havasunews.com/news/as-county-faces-18-5-million-decit-departments-present-bleak-view-ofpossible-cuts/article_fdd35ab2-581f-11ee-8a65-e36102c35e70.html. [3] Kahled Hasan, et al, Effects of Different Environmental and Operational Factors on the Solar Performance: A Comprehensive Review, 10 ENERGY SCI. ENG. 656, 664-65. [4] Vasilis Fthenakis, Hyung Chul Kim, Life-cycle uses of water in U.S. electricity generation, Renewable and Sustainable Energy Reviews, Volume 14, Issue 7, 2010, Pages 2039-2048, ISSN 1364-0321, available here https://doi.org/10.1016/j.rser.2010.03.008. [5] J Meldrum et al 2013 Environ. Res. Lett. 8 015031, available here https://iopscience.iop.org/article/10.1088/1748-9326/8/1/015031/pdf. [6] Damon Turney, Vasilis Fthenakis, Environmental impacts from the installation and operation of large-scale solar power plants, Renewable and Sustainable Energy Reviews, Volume 15, Issue 6, 2011, Pages 3261-3270, ISSN 1364-0321, available here https://doi.org/10.1016/j.rser.2011.04.023. [7] Parikhit Sinha, Potential Environmental Hazards of Photovoltaic Panel Disposal: Discussion of Tammaro et al. (2015), available here https://doi.org/10.1016/j.jhazmat.2016.04.021. [8] Human Health Risk Assessment Methods for PV Part 3: Module Disposal Risks, 2020, Report IEA-PVPS T12-16: 2020, ISBN 978-3-906042-96-1. [9] Health and Safety Impacts of Solar Photovoltaics, NC Clean Energy Technology Center, North Carolina State University, May 2017. [10] UNS Electric Inc, 2020 Integrated Resources Plan (IRP), available here https://docs.uesaz.com/wp-content/uploads/UNSE-2020-Integrated-Resource-Plan.pdf. [11] US DOE, Office of NEPA Policy and Compliance, EIS-0048, June 24, 2011. [12] Energy Storage News, 230MW BESS Comes Online at Bureau of Land Management Site in California, August 17, 2022, available here https://www.energy-storage.news/230mw-bess-comes-online-at-bureau-of-land-management-site-in-california/. United States Environmental Protection Agency,
Office of the Greenhouse Gas Reduction Fund, Solar for All, Funding Opportunity Number EPA-R-HQ-SFA-23-01 RE: Letter of Support for Arizona’s Solar for All Application To Whom it May Concern: The Arizona Solar Energy Industries Association (AriSEIA) submits this letter in support of the Arizona Governor’s Office of Resiliency’s Solar for All Arizonans application for the maximum amount of $250 million. We were heavily involved in crafting this proposal. It reflects significant stakeholder engagement and the balancing of a myriad of needs within the State. Arizona currently faces numerous political and policy barriers to the implementation of clean energy, including solar, and federal support, such as through this grant, is critically needed. Solar is unique in that it is a zero carbon technology, but is also a tool that anyone can use to help reduce and control their electric bills in a time of what seems like endless rate increases. The programs in this proposal will help advance the clean energy transition in Arizona, while also reducing the energy burden for low income residents. AriSEIA is a 501(c)(6) organization. We operate statewide to advance policies that support solar, storage, and electrification in Arizona. Our work spans all scales of solar and every level of government. We also regularly engage with our state’s major utilities and strive to promote professionalism in our industry with a commitment to consumer protection. Importantly for AriSEIA, this proposal will also help stabilize the health of our solar industry, a vital industry to Arizona’s economy. Arizona has more than 350 solar companies that employ more than 8,000 people statewide. Given policy setbacks at the legislature and utility commission, paired with sky high interest rates, our residential solar installations are down nearly 30% and many companies are worried about laying off their employees and closing their doors. This grant will be a much needed lifeline to a sector that is essential for decarbonization. Through this Solar for All proposal, the Arizona Governor’s Office of Resiliency seeks to bring a wide variety of stakeholders to the table to deliver on the promises of solar. The proposal is guided by the goal and vision of increased access to solar energy and increased energy affordability for Arizona families. We are committed to supporting and collaborating on this proposal to deliver the benefits of solar to all Arizonans. Sincerely, /s/ Autumn T. Johnson Executive Director, AriSEIA (520) 240-4757 autumn@ariseia.org |
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