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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Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: Value of Solar, Docket No. E-00000J-14-0023 Chairman and Commissioners, The Arizona Solar Energy Industries Association (AriSEIA) is a party to the Value of Solar proceeding. That matter took three years to conclude, had approximately 35 parties, and resulted in a compromise. That compromise was adopted by an entirely republican Commission by a 4-1 vote. It is not a decision the solar industry is excited about. But it put in place a predictable framework by which homeowners, solar companies, and the utilities understood the regulatory landscape. As such, AriSEIA strongly opposes reopening the Value of Solar decision. This Commission has stated multiple times that it supports “regulatory certainty.” Regulatory certainty should apply to all matters before the Commission, not only select matters. It is impossible to do business when the rules under which you operate can change on a whim. While reasonable minds can differ on policy, the institution has a responsibility to ratepayers, utilities, and the other stakeholders that appear before it, including the solar industry, to uphold its own rules, regulations, and orders. Decision 75859 states, There were also concerns raised in regard to the possibility of dramatic changes in the export rate and resulting uncertainty. However, to allow the export rate developed using this methodology to change gradually, it will be updated annually after it is initially set in a rate case proceeding or separate rate design phase. At the time that the initial DG export rate is set, a Plan of Administration that provides the mechanism for annual modifications to that initial rate also will be adopted. The annual updates accomplished between rate cases should be formulaic exercises where the Resource Comparison Proxy Methodology and the Avoided Cost Methodology established in the rate case is updated; however the reduction to the compensation rate under the RCP methodology shall not exceed ten percent per year.[1] Gradualism is referred to eighteen (18) times in the order. Multiple parties asserted the importance of making any changes gradually. “RUCO assert[ed] that the process of applying step-down schedules to the initially-established rate, and predictably and gradually lowering the rate, as market uptake increases and the cost of solar declines, will allow solar to ‘become a net benefit to all ratepayers - DG and non-DG customers alike.’”[2] “Staff assert[ed] that it is critical that the Commission's move away from the current framework be accomplished in a gradual manner.”[3] Further, the Commission’s order determined that the proposed methodologies “provide[d] a path for a gradual transition away from the current net metering model.”[4] The Commission stated, “[w]e believe that this will reduce the risk of dramatic changes to customers and the solar industry and is consistent with our interest in rate gradualism.”[5] Again, this adherence to gradual changes in rates or regulations is an essential component to regulatory certainty. Increasing the stepdown percentage would run counter to the positions of RUCO, Staff, and the Commission, as well as the stated goals in every rate case in recent memory. Decision 75859 also locked in the export rate for a period of ten (10) years.[6] This period provides regulatory certainty for the homeowner. Homeowners make significant investments with private capital, into a generating resource that provides predictable power to the grid. Those investments can be tens of thousands of dollars. Those investment decisions take into account the export rate. It would be impossible to evaluate such a significant investment decision without certainty as to the Commission’s regulations for a period of time directly after the investment. Given the cost of the investment and the longevity of the system, ten (10) years is a very reasonable lock-in period. There are more than 350 solar companies operating in Arizona. These companies employ approximately 8,337 people in Arizona alone and have contributed $16.8 billion dollars to the state’s economy, with $1.5 billion invested just last year.[7] Residential rooftop solar installations are down almost 30% year over year since 2022. This decline is due in part to the declining export rate, in combination with very high interest rates for anyone taking out a loan to install solar. Any homeowner looking to finance rooftop solar will find interest rates as high as 11.99%. Further declines in installations are likely to result in workforce reductions. Individual installers are considering job cuts of dozens of jobs with an average, annual pay of $62,500 a year. A decline in solar will also result in declines in the roofing industry and other energy efficiency contractors, such as HVAC, windows, and insulation. Reopening this docket will plunge an already struggling industry into uncertainty. It is hard to imagine why anyone would install solar when they have no way to predict what the Commission will do or if it will continue to honor any decision it does reach longer than an election cycle. High interest rates paired with a declining export rate and significant regulatory uncertainty will result in a substantial negative impact to the state’s economy. Companies looking to do business in Arizona investigate the regulatory environment prior to investing in the state. The rate riders for the Resource Comparison Proxy (RCP) are notably forward looking. For example, APS’ rate rider explicitly states, “[t]he RCP rate may not be reduced by more than 10% each year” and “[e]ach Customer’s initial RCP rate will be applicable for 10 years from the time of their interconnection.”[8] Similarly, TEP’s website on RCP specifically states, “the RCP will not be allowed to fall more than 10 percent annually.”[9] Companies do not make business decisions in two-year election cycles. Changing the rules that impact major investments for homeowners or businesses is not good for the economy or the State. Lastly, the Commission spends considerable time discussing staffing shortages, high workloads, and trouble juggling competing deadlines. A redo of a matter that took three years is simply not a good use of Commission or Staff time and resources. AriSEIA urges you to vote no on reopening the Value of Solar docket for the reasons stated above. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] Arizona Corporation Commission, Order 75859, Page 151, Line 24 through Page 152, Line 4 (emphasis added), Filed January 3, 2017, available here https://docket.images.azcc.gov/0000176114.pdf?i=1692725715837. [2] Id. at 96, Line 20-23. [3] Id. at 137, Line 11-12. [4] Id. at 148, Line 7-8. [5] Id. at 154, Line 2-4. [6] Id. at 156, Line 22-24. [7] Solar Energy Industries Association (SEIA), Arizona Solar Census, Q2 2023, available here https://www.seia.org/sites/default/files/2023-09/Arizona.pdf. [8] APS Rate Rider RCP, Page 1 (a) and (c). [9] TEP, Resource Comparison Proxy Export Rate, available here https://www.tep.com/rcp/. FOR IMMEDIATE RELEASE
Arizona Residents Stand United to Protect Rooftop Solar Stakeholders Meet Ahead of ACC meeting on the fate of rooftop solar in Arizona. Phoenix, Arizona — Yesterday, six years after the original solar export rate decision, energy justice and solar advocates held a virtual stakeholder briefing ahead of the Arizona Corporation Commission (ACC) meeting that could alter the future of rooftop solar in Arizona. The briefing, hosted by Solar United Neighbors in collaboration with Vote Solar and the Arizona Solar Energy Industries Association (AriSEIA), 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. WATCH: Stop the Attack on Solar in Arizona Stakeholder Briefing “Arizonans were promised a certain amount for their excess solar production. They made economic investments based on the ACC’s previous decision. Any changes to the value of solar the Commission makes now r could undermine the private investments made by more than 200,000 Arizonans in an effort to lower their monthly energy bills. Ratepayers rely on their utility’s regulator to make decisions on their behalf that maintain stability and certainty. Reopening the value of solar docket does neither,” said Adrian Keller of Solar United Neighbors. At the upcoming ACC meeting on October 11th, Commissioners will decide whether to re-examine the solar export rate, which dictates how solar owners are credited for surplus energy they contribute to the grid. The original 2017 decision, reached after a lengthy evidentiary hearing as well as extensive deliberation and compromise, was designed to ensure predictable compensation for solar owners while providing stability to Arizona's rooftop solar market. Re-opening this case would initiate a new proceeding and could lead to significant changes, which could undermine the value of investments Arizona families have already made in solar. If the ACC were to re-open this case, it also sends families and businesses in the state a signal that the ACC could reverse course on other important policy decisions at any time, undermining the value of long-term investments. Autumn Johnson, Arizona Solar Energy Industries Association (AriSEIA), said, “Any changes to the solar export rate would not only affect homeowners but could also jeopardize our state's economic development. Solar employs more than 8,000 people in Arizona and contributed $1.5 billion to the state’s economy last year, with a total market of $16.8 billion. Paired with high interest rates, total market uncertainty could devastate this important industry in one of the sunniest states in the country.” The potential changes to export rates could include a substantial reduction in compensation for solar energy and the erosion of critical protections for homeowners investing in solar power. A reduction in the export rate would impact the Arizona solar industry during a period of heavy federal investment in clean energy. “Rooftop solar is an essential tool to help meet Arizona’s rapidly growing energy needs affordably while also improving the resilience of our communities. When families invest their own money in locally-produced solar power, it helps to reduce the need to build expensive new power plants and transmission lines, keeping electricity costs low for everybody. Thanks to new federal programs, tax credits, and financing options, rooftop solar is about to become more affordable and attainable than ever. But changes to the value of solar will slam the door shut on low-income communities, first-time homebuyers, and others who are only now getting access to clean energy solutions for the first time” said Kate Bowman, Vote Solar. Stakeholders will hold a press conference at the ACC on the morning of their October 11th meeting at 9:30 a.m. After the press conference, advocates and the public will provide public comment. To review a recording of this briefing, please click here. ### 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. Salt River Project
1500 N. Mill Avenue Tempe, AZ 85288 RE: Integrated System Plan and Stakeholder Engagement Salt River Project and Board, The Arizona Solar Energy Industries Association (AriSEIA) requested to be a part of the Integrated System Plan (ISP) stakeholder group in 2022. That request was denied. AriSEIA also requested to be included in the Sustainability Advisory Council and, to date, that has also not been granted. It is unclear why AriSEIA continues to be excluded from all formal SRP stakeholder processes. Therefore, AriSEIA submits the following comments on Item 4 of the October 2nd Board Meeting: SRP should be required to issue All Source Requests for Proposals (ASRFPs) for all major procurements of generating resources. Those ASRFPs should be vetted through the ISP stakeholder process, as Arizona Public Service (APS) has started to do. The ISP stakeholder process should not exclude stakeholders that request inclusion, especially if they are well established organizations that participate in the resource planning processes of every other major utility in the state. Additionally, no stakeholder process should purposely exclude an entire stakeholder segment, such as renewable energy organizations. Such a stance needlessly excludes valuable expertise from what should be a technically robust process. Meetings should also be virtual or hybrid. In person meetings, such as has been the case for the last two, exclude many stakeholders. Stakeholders that are out of the Phoenix metro area, have small children, or cannot devote multiple hours to commuting to and from SRP are excluded. The other major utilities all have remote options for stakeholder participation. Further, the ISP stakeholder process should be meaningful. There should be an exchange of information in both directions and the utility should be willing to make modifications based on stakeholder feedback, run requested portfolios, and provide the modeling inputs and results to stakeholders. Board members should familiarize themselves with the Arizona Corporation Commission (ACC) Integrated Resource Plan (IRP) process and should hold SRP to a similar standard, as you all serve as the regulator of SRP. SRP has been holding meetings on the ISP for more than two years. The board should be voting on a resource plan, not three vague slides called “strategies.” That is not adequate oversight of an unregulated monopoly. The “strategies” provide no meaningful information as to what the utility plans to do regarding RFPs, procurement, or implementation of their sustainability goals. The 2017-2019 resource plan was much more detailed and it completely neglected major procurements, such as the Coolidge expansion. SRP is the only major utility in the state that does not have an exit date for all coal; does not have a mass based carbon emissions goal; and has pursued major gas plant expansions that were never in a resource plan or RFP. The board should demand that the company do better. You are the only oversight on the second largest utility in the state. Sincerely, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org Line Siting Committee
Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007-2996 RE: Obed Meadows CEC, Docket No. L-21254A-23-0184-00222 Chairman and Committee Members, The Arizona Solar Energy Industries Association (AriSEIA) submits this letter in opposition to requiring a System Impact Study (SIS) in advance of obtaining a Certificate of Environmental Compatibility (CEC). The legal briefs of the applicant, Arizona Public Service (APS), and Tucson Electric Power (TEP) all agree that such a requirement is outside the authority of the Line Siting Committee. Further, such a requirement would needlessly delay gen-tie applications. The legislature via HB 2496 and the Commission via dockets RLS-00000A-23-0251 and ALS-00000A-22-0320 and the Governor’s Office via signature of HB 2496, have all indicated that the goal of the State of Arizona is to expedite these renewable energy projects, not add additional bureaucratic hurdles and delay. The Line Siting Committee has been issuing CECs without SISs and it is not clear why that would need to change now. Testimony in this case, as well as the legal brief of APS, make clear that the absence of a SIS is not the fault of the applicant. There is a backlog of these studies, which is outside the control of renewable energy developers. Transmission Providers throughout the state of Arizona, including the state’s two largest utilities: APS and Salt River Project (SRP), are currently working through significant queue reforms to address interconnection backlogs. Proposed queue reforms will materially impact the timeline of interconnection studies, the requirements for projects to enter and stay in the interconnection queue, and the commercial expectations of projects when bidding into Request for Proposals (RFPs). Such queue reform is expected to introduce withdrawal penalties that will fundamentally change the way a project is developed, creating a new model whereby a project is incentivized to first acquire all its permits (including a CEC), obtain off-take, and then enter the interconnection queue. Having a SIS prior to filing for a CEC would be counter to the intent of queue reform, and a third-party power flow study would be expensive and redundant to already required utility interconnection studies. While the timeline around queue reform implementation is uncertain, FERC Order 2023 indicates an effective date is likely by the end of 2023 or in early 2024. AriSEIA strongly advocates that the Line Siting Committee adhere to the purpose and intent of the Line Siting statute (A.R.S. 40-360.06); its prior decisions on applications that did not have a SIS; the clear intent of the legislature, Governor’s Office, and Commission to reduce Line Siting delay; and the Federal Energy Regulatory Commission’s (FERC) queue reform process and not require a SIS prior to obtaining a CEC. A requirement to have a SIS may have unintended consequences that limit the ability for projects to reach operations in a timely manner. Sincerely, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: Application of APS (Docket No. E-01345A-23-0110), TEP (Docket No. E-01933A-23-0108), and UNSE (Docket No. E-04204A-23-0109) for Approval of Revisions to Resource Comparison Proxy Chairman and Commissioners, The Arizona Solar Energy Industries Association (AriSEIA) previously filed comments in the Arizona Public Service (APS) and Tucson Electric Power (TEP) dockets in this matter on August 4th.[1] That filing covered the history of the Resource Comparison Proxy (RCP), the dramatic increase to consumers for electricity, and the economic impact of high interest rates paired with a declining RCP rate on Arizona’s solar industry. We urge you not to decrease the RCP rate as proposed by Commissioner Myers’ Proposed Amendments No. 1 in each of the above referenced dockets.[2] This Commission has stated multiple times that it supports “regulatory certainty.” On January 3, 2017 the Commission issued Order 75859 in Docket No. E-00000J-14-0023, the Commission’s Investigation of the Value and Cost of Distributed Generation. That matter stemmed from a 2013 APS filing on net metering.[3] It then created a generic docket, known as the value of solar docket, that commenced on January 27, 2014 and ran for nearly two years before an evidentiary hearing was scheduled. The evidentiary hearing ran for two months in the spring of 2016 with more than eighteen parties participating. A 4-1 decision of an entirely republican Commission was issued in January 2017, three years after the docket was opened. Commissioner Burns was the lone dissenter. Implementation of the specific RCP methodologies was then resolved in subsequent rate cases for each utility. Decision 75859 states, There were also concerns raised in regard to the possibility of dramatic changes in the export rate and resulting uncertainty. However, to allow the export rate developed using this methodology to change gradually, it will be updated annually after it is initially set in a rate case proceeding or separate rate design phase. At the time that the initial DG export rate is set, a Plan of Administration that provides the mechanism for annual modifications to that initial rate also will be adopted. The annual updates accomplished between rate cases should be formulaic exercises where the Resource Comparison Proxy Methodology and the Avoided Cost Methodology established in the rate case is updated; however the reduction to the compensation rate under the RCP methodology shall not exceed ten percent per year.[4] Further, while the Commission outlined directions for calculating the RCP in Decision 75859, the Plan of Administration for each utility’s RCP rate requires the utility to submit an updated RCP calculation annually for Commission approval and specifies that the RCP “may not be reduced by more than 10% each year.”[5] The table below highlights the proposed RCP stepdown as recommended by Commission Staff versus the Myers amendments. These reductions run contrary to Decision 75859 and the Plans of Administration for each utility. As such, they do not adhere to the Commission’s own stated goal of “regulatory certainty” and also have not been noticed in accordance with A.R.S. 40-252.[6] Regulatory certainty should apply to all matters before the Commission, not only select matters. Further, it is likely a due process violation to take an RCP methodology from a multi-year process and modify it in an Open Meeting with no testimony, witnesses, or evidence and only two days’ notice, which has the potential to result in litigation. Any deviation greater than 10% from the established RCP methodology should be determined in an evidentiary hearing. AriSEIA’s previous filing highlighted the economic development importance of the solar industry to Arizona. There are more than 300 solar companies operating in Arizona. These companies employ more than 8,000 people in Arizona alone and have contributed $16.5 billion dollars to the state, with $1.5 billion invested just last year.[7] Declines in the solar industry will have ripple effects throughout the economy impacting many other high quality, blue collar jobs, such as in energy efficiency, HVAC, roofing, windows, and insulation. There is no evidence to support Commissioner Myers’ assertion that decreasing the RCP rate by 37-56% will not have a catastrophic impact on an important industry in one of the sunniest states in the country. A table reflecting an increase in DG adoption despite a 10% stepdown in prior years does not mean that increases will continue in the future with a 10% stepdown and certainly not with a stepdown 3-4 times prior decreases. Further, there is no evidence in this docket that the RCP has not dampened growth of this important industry. Because installation rates continue to creep up in TEP and UNSE’s territories does not mean they are not impacted, it simply means the industry has not completely stagnated due to burdensome regulation. APS’ DG penetration is better than TEP and UNSE’s but is still only looking at 1% growth annually since the RCP framework was adopted. Finally, AriSEIA does not agree that the RCP is a “subsidization.” The utilities pay for the power produced that benefits the grid. That power has a number of benefits that are different than utility scale solar. DG does not require new transmission; lengthy Line Siting and zoning proceedings; major land use implications that impact other industries, such as agriculture; or other major infrastructure improvements. The systems are entirely paid for by individual consumers. They are only compensated for the power they provide to the utility that benefits the entire grid, improves resiliency, and can be utilized with storage in demand response programs. If the Commission wishes to reevaluate the value of DG, an evidentiary hearing, not an open meeting, is the appropriate place to do so. Also, both the TEP and APS rate cases have also reflected numerous incidences of the utilities purchasing wholesale power above the RCP rate. Therefore, it is incorrect to assume that DG is somehow above the market rate for power. AriSEIA opposes the Myers Amendments 1 and continues to advocate for an RCP stepdown less than 10%, which is permissible under Order 75859 and the Plans of Administration. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] AriSEIA, Solar United Neighbors, and Vote Solar Joint Letter, Dockets E-01345A-23-0110 and E-01933A-23-0108, filed August 4, 2023, available here https://docket.images.azcc.gov/E000029205.pdf?i=1692739207146. [2] Commissioner Myers Proposed Amendments 1, filed August 22, 2023, in Docket No. E-01933A-23-0108, available here https://docket.images.azcc.gov/E000029934.pdf; Docket No. E-01345A-23-0110, available here https://docket.images.azcc.gov/E000029933.pdf; and Docket No. E-04204A-23-0109, available here https://docket.images.azcc.gov/E000029935.pdf. [3] Arizona Public Service, In the Matter of the Application of the APS for Approval of Net Metering Cost Shift Solution, Docket No. E-01345A-13-0248, available here https://edocket.azcc.gov/search/docket-search/item-detail/18039. [4] Arizona Corporation Commission, Order 75859, Page 151, Line 24 through Page 152, Line 4 (emphasis added), Filed January 3, 2017, available here https://docket.images.azcc.gov/0000176114.pdf?i=1692725715837. [5] See Appendix H, Arizona Corporation Commission, Decision No. 76295, (Aug. 18, 2017), https://docket.images.azcc.gov/0000182160.pdf?i=1657139837798 (emphasis added). [6] Arizona Revised Statutes, 40-252, available here https://www.azleg.gov/ars/40/00252.htm. [7] Solar Energy Industries Association (SEIA), Arizona Solar Census, Q1 2023, available here https://www.seia.org/sites/default/files/2023-07/Arizona.pdf. Eloy City Council
595 N. C Street Eloy, AZ 85131 RE: Opposition to Sections B and F(2) of the Revision of the City’s Zoning of Solar Generating and Storage Facilities Dear Mayor and Council Members, 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 are active at all levels of government in the state and represent organizations throughout the clean energy economy. I am writing to urge you to modify or eliminate Sections B and F(2) from updates to 21-3-1.39. We previously submitted a letter to this body in February 2023 and have attended three meetings of the Council or Planning and Zoning Committee. We are encouraged by the City’s willingness to make modifications throughout this process. However, there are still two major areas of concern. First, the City should not arbitrarily limit expansion of solar to 16% of City acreage. This number is not based on the public interest or any quantitative or qualitative assessment of appropriate solar development in Eloy. It is a duplication of a Coolidge requirement. This kind of restriction limits private property rights of landowners in Eloy, unnecessarily restricts economic development in the area, and risks grid reliability. With the peak records we are seeing broken this summer,[1] massive load growth in the state,[2] and increasingly hot weather,[3] Arizona’s utilities will need to build significant new infrastructure to keep the lights on in Eloy and around the state. Limiting that development on the front end is unnecessary. The City already has a process by which to approve projects and, if so desired, could keep the second half of Section B, without the 16% cap. Second, while we recommend no cap on the amount of storage per project, any cap should be based on capacity not lot size. Further, that cap should be closer to 10-20% of capacity, not 5% of lot size. This is also arbitrary, needlessly limits reliability, and impedes a growing technology prematurely. We recommend modifying Table 3-1-1 to remove the “Lot Coverage, Maximum” or modifying it to “Capacity Maximum” and 10-20%. Finally, we would like to address some of the statements made over the course of this process that may be based on misunderstanding. Throughout the western interconnect, the grid is interconnected all over the western US. Power is produced and utilized all over the west. Power in Eloy comes from New Mexico and California, for example. Limiting renewables development in Eloy because the power is not used on site is counter to how the grid operates. We are seeing increasing local opposition to renewables development. Coolidge[4] set a limit previously and Mohave County[5] is considering a one-year moratorium. Columbia Law School has found more than 200 local restrictions specifically against renewables.[6] These projects can only be located in some geographic locations. Increased limitation impedes our ability to transition the grid, save water, reduce air pollution, and keep the lights on. It has also been said that renewables projects do not “benefit residents” because the bulk of the tax revenue benefits the County and schools more than the City. However, the schools and County services do benefit residents. Residents work in the schools and send their kids to those same facilities. Personally, where I send my children for 1/3 of the day matters a lot to me as a resident. More funding correlates with better facilities and outcomes. Each of these projects contribute tens of millions of dollars to the local economy, several million of which does go directly to the City. Eloy and Pinal County have very serious air quality and water quantity challenges. It is important to look at economic development opportunities wholistically. These challenges will limit the types of businesses and industries that choose to locate in Eloy. There are only so many industries that do not need water, for example. Renewables, including solar, are an ideal economic opportunity given the constraints of the local area. I have re-included data regarding the water usage and emissions of renewables for your convenience. Solar has no point source emissions and lower lifecycle emissions than fossil fuels. It also uses less water in operations and in its lifecycle than most other electricity generating technologies. Lastly, new companies are relocating to Arizona every day and many of them are doing so to help meet their clean energy goals. The national Solar Energy Industries Association (SEIA) tracks clean energy procurement on behalf of businesses in their Solar Means Business Report and the numbers are staggering. We encourage Eloy to not indicate to those businesses that they are closed for business. Please reject Sections B and F(2) of the staff proposal. Thank you for your consideration to this important matter. Sincerely, Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] Daily Energy Insider, Arizona Public Service Breaks Own Peak Demand Record Seven Days Running, July 26, 2023, available here https://dailyenergyinsider.com/news/40515-arizona-public-service-breaks-own-peak-demand-record-seven-days-running/. [2] APS stated in its currently pending rate case that they are looking at a 40% increase in peak and a 60% increase in demand by 2031. [3] Arizona Republic, July Earned Phoenix Hottest Month on Record for a US City, August 1, 2023, available here https://www.azcentral.com/story/news/local/phoenix-weather/2023/08/01/july-earned-phoenix-hottest-month-on-record-for-a-us-city/70505349007/. [4] Coolidge Council Restricts New Solar, May 14, 2022, available here https://azbex.com/local-news/coolidge-council-restricts-new-solar/#:~:text=After%20nearly%20a%20year%20of,the%20list%20of%20approved%20uses.. [5] Mohave County Board Materials for August 7, 2023, available here https://lfportal.mohavecounty.us/bos/DocView.aspx?dbid=0&id=2038857&page=1&cr=1. [6] Columbia Law School, Report Finds 228 Local Restrictions Against Siting, Wind, Solar, and Other Renewables, May 31, 2023, available here https://blogs.law.columbia.edu/climatechange/2023/05/31/report-finds-228-local-restrictions-against-siting-wind-solar-and-other-renewables-as-well-as-293-contested-projects/. Mohave County Supervisors
700 W. Beale Street Kingman, AZ 96401 RE: Moratorium on Renewable Energy Projects 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 are active at all levels of government in the state and represent organizations throughout the clean energy economy. I am writing to urge you to not to halt all renewable energy projects for the next year within the county. Much of Arizona has very serious air quality and water quantity challenges. Increased deployment of renewable energy can help alleviate both problems. Solar has no point source emissions and lower lifecycle emissions than fossil fuels. It also uses less water in operations and in its lifecycle than most other electricity generating technologies. Further, solar and storage have the opportunity to greatly benefit Mohave County economically. A 25-year fiscal impact summary for an average project reflects the potential to bring in more than $2 million to the City, $12.5 million to the County, and nearly $17 million to the local school districts. That’s a total positive fiscal impact of nearly $32 million from a single project. Further, new companies are relocating to Arizona every day and many of them are doing so to help meet their clean energy goals. The national Solar Energy Industries Association (SEIA) tracks clean energy procurement on behalf of businesses in their Solar Means Business Report and the numbers are staggering. Please affirm the Mohave County Planning and Zoning Commission decision. Certainly, do not institute a moratorium on all solar development in the county. I have attached some information on the number of jobs attributable to solar in Arizona, the water usage of solar (operations and lifecycle), and the lifecycle emissions of different electricity generating resources. Sincerely, Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org AriSEIA submitted a joint filing today calling on the ACC to extend the deadline for comments in its 5-year review of several rules, including resource planning, energy efficiency, and renewable energy. The ACC is reviewing all rules over a 5-year period, but most of the dockets are little known and, therefore, have no comments. AriSEIA asked the deadline for comments be moved to the end of September.
Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: Application of APS & TEP for Approval of Revisions to Resource Comparison Proxy (Dockets No. E-01345A-23-0110 & E-01933A-23-0108) Chairman and Commissioners, Vote Solar, Solar United Neighbors, and the Arizona Solar Energy Industries Association (AriSEIA) urge you to support Arizona families and businesses who wish to invest in their own energy resources by reducing the proposed step down of Arizona Public Service’s (APS) and Tucson Electric Power’s (TEP) Resource Comparison Proxy (RCP) rate for 2023. The Commission outlined directions for calculating the RCP in Decision 75859, and the Plan of Administration for each utility’s RCP rate requires the utility to submit an updated RCP calculation annually for Commission approval and specifies that the RCP “may not be reduced by more than 10% each year.”[1] The Commission has the opportunity to provide consumers looking to save money on their energy bill with relief by reducing the RCP step down less than 10%. This also provides the Commission with the opportunity to support businesses in Arizona by saving jobs. Arizona families and businesses continue to face unusual economic challenges driving up the cost of basic necessities like electricity. Over the last year, consumers experienced a 6% increase in electricity costs[2] following on the heels of a 12% increase in electricity costs the year prior, the largest 12 month increase in nearly 20 years.[3] Rooftop solar is an important tool that ratepayers can utilize to help reduce their utility bills and increase energy resiliency at their home. As interest rates continue to increase to their highest levels in decades, Arizona families and businesses who must rely on long-term financing to afford the upfront cost of a solar installation may find that going solar is no longer an affordable option. Currently, any homeowner looking to finance rooftop solar will find interest rates as high as 11.99%. This makes solar very unaffordable for any homeowner who cannot buy their system outright. Any further reductions of the RCP will reduce the number of Arizona households who are able to benefit from their private investment in solar. Additionally, further reductions to the RCP will depress solar adoption in Arizona and limit opportunities to leverage distributed energy resources for demand response purposes to benefit grid resiliency. Increasingly, customers who invest in solar choose to pair their installation with distributed battery storage. This creates an opportunity for utilities to leverage customer-sited battery storage as a “virtual power plant” that can help provide reliable power to the grid in the evening hours or during summer heat waves. As investments in solar become less affordable, the growth of other innovative distributed energy resources like battery storage will stagnate. Further, there are more than 300 solar companies operating in Arizona. These companies employ more than 8,000 people in Arizona alone and have contributed $16.5 billion dollars to the state, with $1.5 billion invested just last year.[4] Residential rooftop solar installers are reporting a nearly 20% decline in business year over year since 2022, with nearly 35% declines in revenue. This is likely to result in workforce reductions of 20%. Individual installers are considering job cuts of dozens of jobs with an average, annual pay of $62,500 a year. A decline in solar will also result in declines in the roofing industry and other energy efficiency contractors, such as HVAC, windows, and insulation. High interest rates paired with a declining export rate will exacerbate this problem, resulting in a significant impact to the state’s economy. We respectfully request that the Commission reduce the step downs proposed by APS and TEP, as included within the Staff’s proposed order, in an effort to support families and businesses and provide them with an extended opportunity to capitalize on the power of the sun to reduce their energy bills. Thank you for your consideration of this important matter. Sincerely, Autumn T. Johnson Executive Director AriSEIA autumn@ariSEIA.org Adrian Keller Arizona Program Director Solar United Neighbors (SUN) akeller@solarunitedneighbors.org Kate Bowman Interior West Regulatory Director Vote Solar kbowman@votesolar.org [1] See Appendix H, Arizona Corporation Commission, Decision No. 76295, (Aug. 18, 2017), https://docket.images.azcc.gov/0000182160.pdf?i=1657139837798 (emphasis added). [2] U.S. Bureau of Labor Statistics, Consumer Price Index Summary, (May 2023), https://www.bls.gov/news.release/cpi.nr0.htm. [3] U.S. Bureau of Labor Statistics, Consumer Prices Up 8.6 percent over year ended May 2022, TED: The Economics Daily, (June 14, 2022), https://www.bls.gov/opub/ted/2022/consumer-prices-up-8-6-percent-over-year-ended-may-2022.htm. [4] Solar Energy Industries Association (SEIA), Arizona Solar Census, Q1 2023, available here https://www.seia.org/sites/default/files/2023-07/Arizona.pdf. |
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