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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.
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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/ AriSEIA filed joint comments with Vote Solar and Solar United Neighbors today calling on the ACC to not undertake the annual 10% RCP decrease as requested by TEP, APS, and UNSE. There are too many other policy changes at the state and federal level that have negatively impacted the solar industry to further erode it now.
APS Abandons Clean Energy Commitments, Undermining Public Trust and Arizona’s Energy Future8/6/2025 FOR IMMEDIATE RELEASE
August 6, 2025 Phoenix, AZ — In a stunning reversal, Arizona Public Service (APS) has announced it is rescinding all previously stated clean energy goals—eliminating its 2030 targets of 65% clean and 45% renewable energy, walking back its 2031 coal exit timeline, and discarding its 2050 carbon-free objective. This decision leaves Arizona’s largest utility with no coal retirement plan, no renewable energy goal, and only 19% of its energy currently coming from renewable sources—despite years of public commitments and regulatory filings suggesting a transition was underway. “APS is walking away from every clean energy promise it made to the public, to regulators, to shareholders, and to the communities it serves,” said Autumn Johnson, Executive Director of the Arizona Solar Energy Industries Association (AriSEIA). “We are left with vague intentions and zero accountability. This is not a transition plan—it is a retreat.” The reversal stands in direct contradiction to APS’s last two Integrated Resource Plans (IRP), one of which the utility defended before the Arizona Corporation Commission just last fall. Those IRPs included these now-abandoned commitments and were also used to justify APS’s lobbying for a securitization bill—legislation designed to help finance the cost of transitioning off coal. That rationale is now in serious doubt, as the utility appears to have no intent to exit coal or accelerate clean energy development. “APS fought tooth and nail for a securitization tool they clearly do not intend to use,” said Johnson. “They are signaling not just delay, but abandonment of the entire transition.” In recent statements, APS has attempted to justify its reversal by citing reliability concerns. But its own IRPs clearly show that clean energy, storage, and demand-side management are reliable, scalable resources capable of meeting Arizona’s energy needs. The decision to abandon those resources appears not only unjustified—but politically motivated. “This is not about reliability—it is about politics,” said Johnson. “And customers are the ones who will pay the price, both in dollars and in missed economic opportunities.” The announcement also echoes prior failures in utility planning—particularly in how the closure of the Navajo Generating Station left the Navajo Nation without clear timelines or transition opportunities. APS’s ongoing ambiguity around the Four Corners Power Plant continues that legacy of uncertainty, depriving impacted communities of the ability to plan for their future. Meanwhile, APS is investing in new natural gas pipeline infrastructure, despite previous claims that gas would serve only as a short-term bridge. The company’s actions suggest a long-term recommitment to fossil fuel infrastructure at a time when there is no statewide energy plan and no enforceable clean energy standard in place. The pending repeal of Arizona’s Renewable Energy Standard and Tariff (REST) will leave the state with no formal policy structure to ensure clean energy progress. In that context, APS’s abandonment of its own voluntary goals leaves Arizona residents, businesses, and rural communities with no guarantees, no accountability, and no timeline for a cleaner or more affordable energy future. “This is a betrayal of public trust,” Johnson added. “I personally worked with APS during the formation of their clean energy commitment. I believed it represented a step forward—however modest—for a utility that had long resisted change. But now it is clear: APS lacks leadership, lacks innovation, and lacks the integrity to keep its word.” _____________________________________________________________________________ The Arizona Solar Energy Industries Association (AriSEIA) is a nonprofit trade organization dedicated to advancing solar, storage, and electrification across Arizona. AriSEIA advocates for fair and equitable energy policy, promotes economic development through clean energy investment, and works to ensure that Arizona remains a competitive, reliable, and innovative energy leader. Media Contact: Autumn Johnson Executive Director, AriSEIA [email protected] (520) 240-4757 Arizona Public Service (APS) and Tucson Electric Power (TEP) filed new rate case applications in June (one day apart from each other). The Arizona Corporation Commission (ACC) scheduled the cases overlapping with each other as far as testimony, hearings, and briefing. AriSEIA believes this is prejudicial to all parties other than the utilities and asked for the schedule to be modified.
AriSEIA appealed the Arizona Corporation Commission (ACC) decision that allowed Arizona Public Service (APS) to impose a discriminatory fee on all of its rooftop solar customers, called the Grid Access Charge. Briefs were due to the Court of Appeals on July 18, 2025. Another round of briefs are due in September. You can read our brief here:
May 9, 2025 Arizona Public Service 400 N 5th Street Phoenix, AZ 85004 RE: AriSEIA Comments on the APS Interconnection Manual Draft Rev. 10 Dear APS Interconnection Team, As agreed, we are submitting this summary of the five specific handbook topics of present concern to AriSEIA in advance of APS filing the revised manual with the Commission. We would like to reach resolution prior to filing, if possible. Section 8.2, Utility Disconnect Supply side connections of non-residential systems and the use of the National Electrical Code (NEC)-required external Fused Service Disconnect as the approved Utility Disconnect – Rev. 9.0 to the manual allows the Fused Service Disconnects for customer GF supply side connections in section 8.2(A) to be used as the Utility Disconnect. This language was explicitly negotiated and agreed to by APS during the 2021-2022 manual revisions and was approved by the Commission in November 2022. The use of a Fused Service Disconnect also as a Utility Disconnect is ubiquitous across the country, with those requiring redundant disconnects being the exception rather than the rule. Notably, Tucson Electric Power (TEP) allows the Fused Service Disconnect to serve as the DG Disconnect (see TEP’s Interconnection Manual for Distributed Generation, Section 9.2.1.b) as does Salt River Project (see SRP’s DER Technical Requirements, Section 2.8.1.b). All California utilities also allow for Fused Service Disconnects to serve as the Utility Disconnect – see PG&E’s Supply Side Interconnection Requirements for reference. An additional Utility Disconnect for line-side/supply-side taps beyond a Fused Service Disconnect per NEC is redundant, arbitrary, and a costly requirement, and ARISEIA objects to the Rev. 10 proposed language that limits the dual-purpose potential of Fused Service Disconnects to residential single-phase systems. Moreover, the unilateral and retroactive enforcement of changes to the approved APS Interconnection Manual language, which were negotiated in good faith and approved by the Commission, is a significant oversight by APS management and has led to countless thousands of dollars of additional cost burdens on its customers since approval in 2022. APS staff should immediately adhere to the original intent of the language as previously approved, and attached to these comments are an exhibit demonstrating the written and clear intent to modify the language to remove unnecessary equipment from customer-owned GF installations (See Comment 3 and Response). Furthermore, the verbal comments offered by APS that non-residential GF installations have greater public access than residential systems is specious, as requiring separate fused disconnects and utility disconnects results in double the number of devices the public can access and operate. Locking provisions are readily accessible for both residential and nonresidential versions of Fused Service Disconnects and are a simple solution to the otherwise costly approach administered by APS requiring an additional Utility Disconnect. The NEC is the governing standard for the safe installation of electrical wiring and equipment in the United States. It is fundamentally a safety standard. Its primary purpose is to protect people and property from electrical hazards by preventing electrical fires, reducing risk of shock, setting clear installation standards, ensuring safe use of new technologies, promoting uniformity, and setting guidelines for inspections and permits. The NEC does not require a second utility disconnect for commercial-scale solar projects that are interconnected on the utility side of a customer’s meter; the only equipment required for safety purposes is a single fused service disconnect in accordance with NEC 2017 230.82(6), 705.12(A), and 705.31. Therefore, an additional Utility Disconnect is not necessary for the safe operation of a solar photovoltaic system, and APS should align with its state and national utility counterparts by removing this requirement. Section 9.2, Production Metering Requirements APS requires production metering for Static Inverter based Energy Storage Systems unless they are co-located with a PV system and properly configured, or unless the customer agrees to provide equivalent data hourly. AriSEIA has consistently objected to metering battery discharge, including Rev. 9 of the manual which limited the requirement to standalone battery systems. Note that an Energy Storage System does not produce power at all, so the need for a “production meter” is nonsensical. This requirement will prove even more excessive as APS continues to progress toward adopting electric vehicles as an additional means of balancing the load on the electric grid. Meter disconnects further exacerbate the cost of this requirement. Short of an optional utility program to monitor or dispatch customer battery discharge and compensate customers, the customer’s site meter is sufficient to support the financial transaction for exported energy from battery systems. Utilities do not need real time measurement of battery usage any more than for sub-metered loads turned on or off. AriSEIA recommends that section (C) be removed in its entirety. Section 10.4, Inadvertent Export or Active Power-Limiting Protection Requirements The second sentence says “For GF’s with kVA rating greater than POI kVA rating protection requirements…” This sentence is missing a limiting kVA rating value separate from the POI rating. The value should be above the Commission limits that apply to Inadvertent Export Systems considered Fast Track. Section 4.1, Separate System The revision to include all Non-exporting systems as separate systems needs adjustments. Unlike backup systems, they do serve customer loads in parallel to the utility system on a continuous basis. The language confuses the issue of needing a Transfer Switch, which only applies to those Non-exporting systems incorporating a Backup System operating mode. The non-exporting feature can be provided by control systems and/or relays instead of a transfer scheme. Other sections deal with Non-exporting systems and appropriate exemptions from requirements for exporting systems. AriSEIA suggests limiting the Separate System definition to Non-exporting systems that can function as a Backup system. The new provisions of section 4.1(D) are appropriate for Non-Exporting systems regardless of the Backup capability, which should be clarified as part of the discussion. Section 2, Definitions The new definition for Point of Service describes the identical location as the current definition for Point of Interconnection, except without a GF operating in parallel. Is it needed in the Interconnection Manual? Also, the current definition claims the POI is also known as the Point of Common Coupling. In the industry, the POCC refers to the connection that could be at a different location than customer service equipment, such as a utility transformer. Even in the absence of a deregulated generation market, a change to this language could be useful for developers of APS distributed solar systems and future Community Solar systems. Thank you for considering these comments. We would appreciate a response before filing the manual revision. Sincerely, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected]
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