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Arizona Public Service (APS) filed for a 90-day extension of their integrated resource plan (IRP). If that is granted, the stakeholder comments would be due in January instead of October. AriSEIA filed to ask for stakeholder comments for all utility IRPs be due in January if the APS request is granted, regardless of whether or not other utilities file their IRPs in August.
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APS recently filed a motion asking the Arizona Corporation Commission to restrict witness examination in its pending rate case.
APS is seeking approval of significant rate increases and numerous policy proposals that could affect Arizona customers for years to come. As the applicant, APS bears the burden of proving that its requests are just, reasonable, and supported by the evidence. Cross-examination is one of the primary tools available to test that evidence and ensure the Commission develops a complete record before making decisions that will impact ratepayers. Arizona courts have recognized that, while ratemaking is legislative in nature, the proceedings leading to those decisions are quasi-judicial and subject to due process requirements. Limiting parties' ability to question witnesses and test evidence raises serious concerns about whether the record will be fully developed before rates are approved. AriSEIA believes APS's request is both premature and unnecessary. The hearing remains underway, and APS has not demonstrated that additional hearing days will be needed. If scheduling concerns ultimately arise, the Commission can address them through additional hearing days rather than restrictions on the examination of witnesses. When a utility seeks to increase customer rates, the answer should not be less scrutiny. Arizona ratepayers deserve a full and fair review of the evidence before any decision is made. AriSEIA has filed surrebuttal testimony in the APS rate case, directly challenging how the utility values rooftop solar and allocates costs.
The testimony argues APS’s “Site Load” cost of service study is fundamentally flawed and should be replaced with a standard Delivered Load approach. The current model understates the benefits of distributed solar and is being used to justify solar-specific charges that lack a valid foundation. A key issue is APS’s reliance on transmission-level peak hours rather than retail customer load, which distorts results and minimizes solar’s contribution during high-demand periods. When evaluated using the correct framework, the testimony finds that rooftop solar significantly reduces peak demand and provides broader system benefits, including serving neighboring customers through exported energy. AriSEIA also criticizes APS’ distributed generation study as methodologically unsound and disconnected from real-world grid operations. The filing urges the Commission to reject APS’ approach, eliminate unsupported solar charges, and adopt a more accurate, data-driven framework for valuing distributed energy resources. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Support for APS’ Revised Interconnection Manual, Docket No. E-01345A-20-0152 Dear Chairman and Commissioners, On behalf of the Arizona Solar Energy Industries Association (AriSEIA), this letter provides comments on Arizona Public Service Company’s (“APS”) revised Distributed Generation Interconnection Requirements Manual. AriSEIA appreciates the collaborative process between stakeholders and APS in developing the revised Manual. We met multiple times over the course of 2025. The current version reflects meaningful improvements, including reduced costs and simplified equipment requirements for customer-sited solar installations. These changes address prior stakeholder concerns and improve clarity, consistency, and administrability of the interconnection requirements. AriSEIA supports the Utilities Division Staff’s Recommended Opinion and Order docketed on March 25th, which finds that the revised Manual complies with the Commission’s Interconnection Rules and Decision No. 78783 and recommends approval. AriSEIA notes that certain issues remain under discussion, including the treatment of Non-Exporting and Inadvertent Export systems. Specifically, the use of nameplate ratings rather than Maximum Capacity for certain requirements raises concerns for systems that are designed not to export to the grid. AriSEIA and APS have engaged on this issue and will continue working toward a resolution in future revisions to the Manual. While these issues remain, AriSEIA supports approval of the revised Manual at this time and appreciates APS’ continued commitment to stakeholder engagement and iterative improvement. AriSEIA remains committed to working collaboratively with APS, Staff, and the Commission to further refine interconnection standards in future updates. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] AriSEIA filed direct testimony in the Arizona Public Service rate case. We make the following recommendations:
Site Load COSS
Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Comments on APS 2026 RES Implementation Plan, Docket No. E-01345A-25-0140 Chairman and Commissioners, The Arizona Solar Energy Industries Association (AriSEIA) submits these comments in response to the Utilities Division Staff Memorandum and Proposed Order concerning Arizona Public Service Company’s (APS) 2026 Renewable Energy Standard Implementation Plan. These comments address two discrete issues: (1) Staff’s recommendation to deny continued funding for the Arizona Goes Solar website, and (2) the proposed waiver allowing Renewable Energy Standard compliance without the use and retirement of Renewable Energy Credits (RECs). I. Objection to Elimination of Arizona Goes Solar Website Funding Staff recommends denial of $360 in annual funding for the Arizona Goes Solar website without articulating any factual or policy basis for doing so. This recommendation is not supported by the record and fails to account for the website’s unique and critical role in Arizona’s energy regulatory ecosystem. The Arizona Goes Solar website is not a discretionary marketing tool. It is a statewide consumer protection, transparency, and grid-awareness resource. It is the only centralized, publicly accessible platform in Arizona that provides neutral information on solar adoption, interconnection, incentives, utility-specific program requirements, and Renewable Energy Standard compliance across every major electric utility operating in the state. No other Commission-sponsored or utility-sponsored resource performs this function. The website serves multiple core public-interest purposes. It provides consumers with clear, comparable information needed to make informed decisions, reduces confusion that can lead to fraud or misinformation, supports proper interconnection by directing customers to accurate utility requirements, and improves grid reliability by promoting informed deployment of distributed energy resources. In practice, the website reduces downstream disputes, complaints, and administrative burdens by improving clarity at the front end. The annual cost of maintaining this resource is $360. This amount is de minimis relative to the overall Renewable Energy Standard budget and has no meaningful rate impact. Eliminating funding would not advance affordability or efficiency. It would instead eliminate the only neutral, statewide informational resource of its kind in Arizona, directly weakening consumer protection and transparency for no discernible benefit. Importantly, elimination of this funding is inconsistent with the Commission’s stated priorities. Chairman Myers has publicly stated that his number one commitment as Chairman is transparency, noting that “transparency is not just about access; it’s about clarity.” The Arizona Goes Solar website embodies that principle. It provides clarity, not merely access, by consolidating complex, utility-specific information into a single, understandable public resource. Defunding the website would move the Commission in the opposite direction. Absent a specific finding that the website is duplicative, inaccurate, unnecessary, or inconsistent with Commission policy, denial of continued funding is arbitrary and unsupported. The Commission has long recognized the value of low-cost educational and transparency tools that support informed participation in Arizona’s energy markets. Continued funding for the Arizona Goes Solar website is squarely aligned with that history and with the Commission’s stated commitment to transparency. For these reasons, the Commission should reject Staff’s recommendation and approve continued funding for the Arizona Goes Solar website. II. Objection to Waiver of REC Use and Retirement AriSEIA also objects to APS’ request for a waiver of Arizona Administrative Code R14-2-1804(A), which would allow Renewable Energy Standard compliance without the use and retirement of RECs. Nationwide, a REC represents the environmental attributes of one megawatt-hour of electricity generated from a qualifying renewable resource.[1] In every established Renewable Portfolio Standard or Renewable Energy Standard program in the United States, the core compliance mechanism is the demonstration that qualifying RECs have been both owned and retired on behalf of customers. Retirement is the act that permanently removes a REC from the market and prevents it from being claimed more than once. This structure is not unique to Arizona. It is the uniform accounting framework used by state regulators, utilities, system operators, and voluntary and compliance markets across the country. The use and retirement of RECs is what ensures environmental integrity, prevents double counting, and preserves the credibility of renewable energy claims. Without retirement, there is no verifiable proof that renewable attributes have been exclusively applied to compliance rather than sold, transferred, or claimed elsewhere. Arizona Administrative Code R14-2-1804(A) reflects this national norm. It is not a procedural preference. It is the substantive mechanism by which Renewable Energy Standard compliance is verified. The waiver requested in this docket would fundamentally depart from this established framework by allowing compliance to be demonstrated without the retirement of RECs. Approval would represent a significant deviation from nationally accepted REC accounting practices and would introduce uncertainty into Arizona’s REC market regarding ownership, exclusivity, and environmental claims. Such a deviation would have consequences extending well beyond this filing. It would affect market confidence, undermine the validity of REC transactions, and create ambiguity for third parties that rely on Arizona RECs for compliance, voluntary procurement, financing, and contractual claims. These impacts would not be limited to APS or the 2026 plan year. Fundamental changes to REC mechanics should not be decided through a single utility’s Renewable Energy Standard Implementation Plan proceeding. The appropriate venue for reconsideration of REC use, retirement, and compliance accounting is a dedicated rulemaking or policy docket with full stakeholder participation and a comprehensive evaluation of market, regulatory, and legal impacts. Determining the basic mechanics of REC compliance in this docket risks unintended and irreversible consequences that extend beyond the scope of the 2026 plan and beyond APS. For these reasons, the Commission should deny the requested waiver and maintain the existing requirement that Renewable Energy Standard compliance be demonstrated through the use and retirement of RECs, unless and until the Commission considers changes through a broader, deliberate, and transparent policy process. III. Conclusion For the reasons stated above, AriSEIA respectfully requests that the Commission reject Staff’s recommendation to eliminate funding for the Arizona Goes Solar website and deny APS’ requested waiver of REC use and retirement requirements in this docket. Two amendments are attached for your convenience. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] [1] US Environmental Protection Agency, Renewable Energy Certificates, available here https://www.epa.gov/green-power-markets/renewable-energy-certificates-recs?utm_source=chatgpt.com. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: AriSEIA Support for the 2024 Arizona Public Service Company Demand Side Management Implementation Plan, Docket No. E-01345A-23-0088 Chairman and Commissioners, The Arizona Solar Energy Industries Association (AriSEIA) respectfully urges the Arizona Corporation Commission (Commission) to approve the Arizona Public Service Company (“APS”) Second Amended 2024 Demand Side Management (DSM) Implementation Plan as filed, along with the Utilities Division Staff Recommended Opinion and Order. AriSEIA supports approval of the APS Second Amended 2024 DSM Implementation Plan[1] because the record demonstrates that the proposed measures comply with the Arizona Administrative Code requirements for cost-effective DSM programs and because the Utilities Division Staff Recommended Opinion and Order concludes that the updated portfolio meets applicable evaluation criteria.[2] AriSEIA’s interest is ensuring a stable, predictable regulatory landscape for distributed energy resources and demand-side programs. Approval of the plan, along with the Staff recommendation, provides needed clarity for market participants, customers, and project developers. AriSEIA also strongly urges the Commission to preserve the Bring Your Own Device (BYOD) Virtual Power Plant Battery Pilot Program even if other changes to the DSM portfolio are considered. The BYOD program has been approved twice by vote of the Commission and resulted from a fully litigated rate case. It is a pay-for-performance-only program designed to compensate customers strictly for verified grid services. The Commission approved BYOD for a five-year term, and the program has not yet operated through even a single summer season. Premature modification or suspension would undermine the purpose of the pilot, create regulatory uncertainty, and diminish the value of distributed demand response resources that the Commission has repeatedly endorsed. The BYOD pilot is also an essential contributor to APS’s projected portfolio-wide capacity savings. APS estimates that BYOD could enroll up to five thousand customers and contribute approximately 17 MW of dispatchable capacity during the pilot period.[3] These distributed, flexible resources play a significant role in meeting peak demand, reducing system costs, and increasing grid resilience for all APS customers. For these reasons, AriSEIA supports approval of the Second Amended 2024 DSM Implementation Plan and the Utilities Division Staff Recommended Opinion and Order. If the Commission elects to modify the plan, AriSEIA respectfully asks that the Commission preserve the BYOD pilot in its entirety, including all funding allocated to the program in this plan, consistent with the Commission’s prior decisions and the purpose of the pilot itself. Thank you for your consideration. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] [1] Application of Arizona Public Service Company for Approval of Its Second Amended 2024 Demand Side Management Implementation Plan, Docket No. E-01345A-23-0088 (filed June 20, 2025). [2] Utilities Division Staff, Recommended Opinion and Order, Docket No. E-01345A-23-0088 (Nov. 19, 2025). [3] Application of Arizona Public Service Company for Approval of Its Second Amended 2024 Demand Side Management Implementation Plan, Docket No. E-01345A-23-0088 (filed June 20, 2025) at page 3. Arizona Public Service 400 N 5th Street Phoenix, AZ 85004 RE: AriSEIA Comments on the APS Interconnection Manual Draft Rev. 9.1 Dear APS Interconnection Team, The Arizona Solar Energy Industries Association (AriSEIA) appreciates the opportunity to provide comments on Arizona Public Service Company’s Interconnection Requirements Manual, Revision 9.1. These comments are intended to support clarity, consistency, and compliance with the Arizona Corporation Commission’s interconnection rules, particularly as they relate to Maximum Capacity, screening criteria, and the treatment of Active Power Limiting systems. AriSEIA’s overarching concerns fall into several categories. First, multiple sections of the Manual reference Nameplate Capacity where Maximum Capacity is required under Arizona Administrative Code R14-2-2615. Consistent and accurate use of the defined regulatory terms is essential to ensure uniform application of the screening process and to prevent inadvertent misclassification of generating facilities. Second, several provisions governing Active Power Limiting systems do not fully align with Arizona Corporation Commission requirements or with best practices used in other jurisdictions. These include scope limitations, terminology inconsistencies, and restrictions that would unnecessarily limit non-parallel operating modes that are widely expected to become more common as solar and storage penetration increases. Third, certain protection and monitoring requirements would benefit from additional specificity to improve predictability for both developers and reviewers. In particular, clarification of Minimum Power Protection settings and the definition of the Relative Generating Facility Rating will help ensure consistent implementation across projects. A detailed list of recommended revisions is attached. These recommendations include requested edits to sections 8.1, 8.3, 10.4, 12.2, and related protection and control provisions. Each recommended change is tied either to Arizona Corporation Commission rule requirements or to accepted technical standards used in other jurisdictions. AriSEIA appreciates APS’s attention to these issues and remains committed to constructive engagement to support an interconnection process that is efficient, transparent, and compliant with state requirements. Please do not hesitate to contact us with any questions. Sincerely, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] 
AriSEIA filed a reply brief with the Arizona Court of Appeals today in the ongoing appeal from Arizona Public Service's last rate case, in which they imposed a discriminatory fee on rooftop solar customers. This is expected to be the last round of briefing and oral argument should be held in early 2026.
Joint Statement from Solar United Neighbors, Vote Solar, and the Arizona Solar Energy Industries Association
Arizona Corporation Commission Disappoints Solar Advocates, Siding with Utility Profits Tucson, Arizona - The Arizona Corporation Commission (ACC) today approved Tucson Electric Power’s (TEP) and UniSource Electric’s (UNSE) proposal to decrease Resource Comparison Proxy (RCP) rates for 2025, further undermining the opportunity to use solar energy to save money on utility bills for customers across Arizona. The Resource Comparison Proxy (RCP) is Arizona’s solar export rate, which determines how much solar customers are paid for the electricity they send back to the energy grid. Commissioners have the option to limit reductions to the RCP in order to avoid negatively impacting solar adoption, and have previously exercised this option during times of economic turmoil such as the COVID-19 pandemic. With the reduction approved today, utilities will pay less for the energy rooftop solar provides, which will ultimately discourage new installations and force the construction of costly new power plants that all customers will pay for through higher energy bills. Solar installations among TEP’s customers fell nearly 40% in 2024, and the ACC-approved reduction to solar rates will only accelerate this trend.[1] “Today’s vote is yet another gift to profit-driven utilities at the expense of communities,” said Kate Bowman, Senior Regulatory Director at Vote Solar. “By cutting the value of solar, the ACC is making it harder for Arizonans to invest in solar—just as these same households are facing rising costs of living and utility bills and a phase out of the federal solar tax credit.” “This decision demonstrates a troubling pattern of behavior by this Commission," said Adrian Keller, Arizona Program Director at Solar United Neighbors. "The ACC consistently approves utility requests while neglecting the ratepayers they are supposed to protect. Following their approval of APS's identical proposal last month, today’s decision continues to penalize families who invest in solar.” “The Commission likes to say it is for an ‘all of the above’ energy strategy, yet its decisions paired with federal policy changes continue to single out renewables punitively,” said Autumn Johnson, Executive Director of the Arizona Solar Energy Industries Association (AriSEIA). “This Commission has imposed solar only fees, continues to reduce the solar export rate, and is trying to eliminate our renewable standards (REST rule), all while the federal government has cut tax credits, imposed extreme tariffs, and enacted a de facto moratorium on all renewables development.” Utilities earn a rate of return on every dollar they spend building power plants and transmission lines. When homeowners invest their own savings to install rooftop solar, they help avoid these expensive projects, saving money for all customers—which is exactly why utilities oppose technologies that threaten their bottom line. Shortly before requesting a 10% reduction to the rate paid to solar customers for exporting electricity, TEP filed a rate case asking Commissioners to increase the rates families pay to purchase electricity from the utility by 14%. Reducing solar export rates will ultimately eliminate jobs, weaken our grid, and force utilities to build new energy generation—a cost that will be passed down directly to customers. On the other hand, increasing access to solar has proven to help families mitigate rising power bills and deliver critical power during record-breaking heat and peak demand. At a time when energy bills are soaring, the Commission should be making solar more affordable, not less. Arizonans deserve the freedom to choose solar power to reduce their bills and protect against rate hikes. Instead, the ACC continues giving utilities tools to discourage renewable energy adoption and maintain their monopoly control. About Solar United Neighbors Solar United Neighbors is a national nonprofit organization that helps people go solar, join together, and fight for their energy rights. SUN's Arizona program advocates for policies that expand solar access and protect solar rights for all Arizonans. About AriSEIA AriSEIA is an Arizona nonprofit trade association working on renewables policies across the state. AriSEIA’s mission is to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. About Vote Solar Vote Solar is a nonprofit advocacy organization working to advance state-level policies that make solar and clean energy solutions accessible to all. Since 2002, Vote Solar has worked to build a just and equitable energy future by leveraging deep policy expertise, strategic partnerships, and public engagement. In the face of powerful opposition, Vote Solar champions bold solutions that expand clean energy access, drive investment in frontline communities, and accelerate the transition to 100% clean energy. [1] According to TEP’s most recent published solar installation data, comparing the first three quarters of 2023 with the first three quarters of 2024. Available at: https://arizonagoessolar.org/tucson-electric-power-tep/ |
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The Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) non-profit trade association representing the solar, storage, and electrification industry, solar-friendly businesses, and others interested in advancing complementary technologies in Arizona. The group's focus is on education, professionalism, and promotion of public policies that support deployment of solar, storage, and electrification technologies and renewable energy job growth and creation. |
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