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
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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/. 

AriSEIA coauthored an article today in PinalCentral on a pending anti-solar ordinance currently being considered in Eloy, AZ. Local renewables opposition is a huge impediment to the clean energy transition and means we will continue to rely on fossil fuels for electricity. Read the full article above and contact Eloy's city council in opposition.

Eloy City Council
595 N. C Street
Eloy, AZ 85131
 
RE: Opposition to 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 not revise the City’s Adopted Zoning Map to restrict solar and storage development.

Pinal County 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 Eloy and Pinal County economically. A 25-year fiscal impact summary for a single 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 everyday 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 reject the staff proposal. Certainly, do not exclude ongoing projects that have been engaging with the City in good faith from any potential “solar zone.” Any changes should only apply to prospective projects. Instead of blanket restrictions, please review each project on its own merits. Also, please reject the separation requirement as it will needlessly prevent important clean energy development.

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

Figure 1 Life cycle water use for electricity generation: a review and harmonization of literature estimates. J Meldrum et al 2013 Environ. Res. Lett. 8 015031

Figure 2 Water Impacts of High Solar PV Electricity Penetration, NREL/TP-6A20-63011, September 2015 (operational water usage)

Figure 3 Life Cycle Greenhouse Gas Emissions from Electricity Generation: Update, NREL, 2021