AriSEIA Files Letter Questioning SSVEC Avoided Cost Calculations

READ THE FILING

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
RE: Sulphur Springs Docket No. E-01575A-24-0160 and E-01575A-23-0299
 
Chairman and Commissioners,
 
We request that you pull agenda item No. 7 from the consent agenda on the September 5th open meeting and place it on the regular agenda to allow public comment and also so that Commissioners and Staff can ask the utility questions.
 
AriSEIA sent Sulphur Springs (SSVEC) questions about this filing earlier this week and scheduled a call with them to discuss those same questions on August 30th. However, SSVEC was not able to answer any of the questions and abruptly ended the call after only approximately 17 minutes.
 
SSVEC filed a different avoided cost calculation on November 6th, 2023.[1] That avoided cost calculation was $.0629, which is greater than their export rate of $.041310. For some unknown reason, this filing never moved forward and was withdrawn one day later. AriSEIA filed a letter in that docket explaining that an export rate below the avoided cost rate was a violation of the Public Utility Regulatory Policies Act (PURPA).[2] Vote Solar and Solar United Neighbors have sued Salt River Project (SRP) in federal court over the same issue.[3]
 
Six days later, SSVEC filed a new avoided cost calculation in a new docket.[4] That avoided cost calculation is $.0307, less than half that of the avoided cost calculation from the prior filing. They filed an amended tariff on August 1st and a Staff proposed order was docketed within a few weeks and it was scheduled for the September 5th open meeting (approximately 6 weeks after being initially filed).
 
Additionally, both tariffs include a meter fee unique to solar customers of $2.70, despite the fact that all residential customers, solar or not, have identical meters. This is the identical issue to the DG meter fee in the last TEP rate case. AriSEIA presented extensive evidence on why that fee was unjustified and it was ended as a result.[5]
 
AriSEIA would like the following questions answered by SSVEC before this item receives a vote:
 

1. Why is the avoided cost calculation so dramatically different between November 2023 and July 2024? Is the methodology the same? Can stakeholders be provided with the workpapers? Has Staff received the workpapers?
2. Why was the November filing withdrawn? How are those customers going to be made whole? It is very concerning that when the utility finds the avoided cost is too low the item does not move, but when the utility finds the avoided cost is too high, the item moves immediately. The process should be applied consistently.
3. Why are solar customers paying more for an identical meter than non-solar customers?

 
Respectfully,
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] SSVEC Tariff Filing, November 6, 2023, available here https://docket.images.azcc.gov/E000032051.pdf?i=1724737112344.

[2] AriSEIA Letter, July 9, 2024, available here https://docket.images.azcc.gov/E000036580.pdf?i=1725068843076.

[3] Complaint for Declaratory and Injunctive Relief, U.S. District Court for the District of Arizona, Case 2:24-cv-02021-DJH, August 12, 2024.

[4] SSVEC Amendment to Application, August 1, 2024, available here https://docket.images.azcc.gov/E000037043.pdf?i=1724736609230.

[5] TEP rate case, AriSEIA direct testimony, P. 365, January 27, 2023, available here https://docket.images.azcc.gov/E000023835.pdf.