Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007-2996
 
RE:      Salt River Project (SRP) Coolidge Expansion Project Certificate of Environmental Compatibility (CEC), Docket No. L-00000B-21-0393-00197
 
Chairman O’Connor and Commissioners,
​
The Arizona Solar Energy Industries Association (AriSEIA) filed joint comments opposing the SRP CEC on March 11, 2022. That filing is attached, as is a filing from the Solar Energy Industries Association (SEIA) on March 14, 2022. None of the underlying reasons for our opposition have been resolved and we remain opposed to SRP’s Application to Amend Decision 78545, filed on June 14, 2023.
 
First, we are concerned with how quickly this application was filed and then docketed for an open meeting. We received notice of this filing at 4:30 pm on June 14th. We received notice of it being on the revised June open meeting agenda at 10:06 am on June 15th, which is only six (6) calendar days before the open meeting and three (3) business days before the open meeting. This is an inadequate amount of time for interested parties to respond and a vote should not be taken at the June 21st open meeting. Further, SRP has clearly known about this arrangement much longer than other interested stakeholders, which is reflected in the fact that their supporters had ample warning to file supportive comments in the docket. This is not the case and a significant disadvantage for those in opposition. Finally on this topic, it is worth noting that almost all of their letters in support are the same organizations that supported granting the CEC before any proposed settlement. Therefore, their support is not contingent on the settlement or anything that has happened since the CEC was filed in 2021.
 
Second, none of the underlying reasons why AriSEIA opposed the CEC in the first place have been addressed. SRP first proposed the Coolidge Expansion Project two years ago in the summer of 2021. One of our largest complaints was that SRP made the decision to invest nearly $1 billion dollars in almost 1 GW of new gas at the Coolidge Generating Station with no competitive bidding process in violation of their own Integrated Resource Plan (IRP). It has been two years and SRP has issued multiple all-source requests for proposals (ASRFPs) since and they have still not solicited or made public any bids to substantiate this project or its massive cost. There is simply no legitimate reason why SRP could not have done so in the last two years. It is highly unlikely that this Commission would allow Arizona Public Service (APS) or Tucson Electric Power (TEP) to do similarly with no competitive bidding process.
 
Third, the statutes that permit the CEC review clearly state that the Commission shall consider the cost of the facilities when determining to grant the CEC. SRP has never provided a rate impact analysis regarding this project. We simply do not know how much it will cost ratepayers. Further, SRP has not docketed any data that reflects the total cost of the project nearly two years later. If the project was $1 billion in 2021, how much does it cost now with 1) significantly increased interest rates, 2) millions of dollars in negotiated concessions, and 3) the dramatic increase in fuel prices we have seen in both TEP and APS fuel adjustor dockets, as well as the increase SRP’s board also voted to pass recently for their own fuel adjustor? It is not prudent to only include capital costs. Any resource acquisition should also include the operations and maintenance (O&M) costs for that plant/resource, as ratepayers pay the total cost.
 
It is simply imprudent to grant this CEC now. SRP should complete its currently pending IRP (called Integrated System Plan or ISP by SRP) process to determine what resources are needed and when and then should issue an ASRFP like every other utility in the state to determine the best project at the lowest cost. If the winning proposal is for a thermal resource, SRP should apply for a CEC, as required. There is no reason for the Commission to deviate from a process it would require of TEP and APS for SRP, certainly not for a CEC that has already been denied twice by this Commission and lost in court, as well.
 
Attached are two letters filed in opposition in March of 2022. As the Commission makeup has changed since, please review them. Please do not vote on the SRP’s CEC application to amend at the June open meeting and when you do vote, please vote no.
 
Respectfully,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org

March 27, 2022
 
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: Salt River Project (SRP) Certificate of Environmental Compatibility (CEC), Docket No. L-00000B-21-0393-00197
 
Madam Chair and Commissioners,
 
Our organizations submit these joint comments to urge you to deny SRP’s CEC rehearing request. We support the Commission’s decision on April 12th to deny SRP’s CEC. The reasons for that denial remain. To summarize our opposition to the CEC:
 

• No all-source Requests for Proposal (RFP) was issued prior to the decision to expand Coolidge Generating Station by 820 MW. SRP’s 2017-2018 Integrated Resource Plan (IRP) Report states that, “Prior to making any financial commitments to major equipment or construction contracts for new-build generation, [SRP will] issue all-source RFPs for the planned capacity. That capacity will explicitly include the opportunity for cost competitive and viable energy storage and demand response options.”[1]
• There was considerable testimony at the hearing that SRP did not adequately consider alternatives to this 820 MW expansion of Coolidge. Witness Mr. Robert Gramlich testified that “A battery would have been more economic than [Coolidge Expansion Project] CEP”[2] and that SRP did not meaningfully consider the analysis of its own consultant, E3, in assessing the alternatives to the Coolidge expansion. “E3 found that adding only 731 MW of battery capacity in 2026 provides the same capacity value as the 820 MW CEP.”[3]
• The Commission must consider the cost of the project and the economics of supplying that electric power. Arizona Revised Statute (ARS) 40-360.06(A)(8) states that the Committee shall consider “The estimated cost of the facilities and site as proposed by the applicant and the estimated cost of the facilities and site as recommended by the committee, recognizing that any significant increase in costs represents a potential increase in the cost of electric energy to the customers or the applicant.”[4] Because SRP did not conduct an all-source RFP, the Commission does not have adequate information about the alternatives to this project and the potential for a less costly option, such as solar and storage, that would save customers money and better protect the environment and ecology of the state.

 
Like SRP, nearly every large utility in Arizona is both experiencing and projecting load growth. Unlike SRP, other utilities are not proposing major gas expansions to meet demand. Utilities around the country are investing in storage[5] and they are doing it within the same timeframe as the CEP.[6] Unfortunately, some AriSEIA members have incurred substantial delays and large costs because of SRP’s unfamiliarity with storage. This is a missed opportunity we hope SRP chooses to correct, instead of pursuing major gas investments.
 
Stakeholders stand ready to engage with SRP when it is ready to comply with its own IRP and conduct a competitive bidding process for new resources. We also encourage all utilities to allow stakeholder review of all-source RFPs before their release, as Arizona Public Service (APS) has done with its most recent RFP. We ask the Commission to deny this CEC rehearing request.
 
Respectfully,
 
Autumn T. Johnson
Executive Director
Arizona Solar Energy Industries Association (AriSEIA)
autumn@ariseia.org
520-240-4757
 
Bret Fanshaw
Western Region Director
Solar United Neighbors (SUN)
bfanshaw@solarunitedneighbors.org
602-962-0240
 
Yaraneth Marin
Interior West Regional Director
Vote Solar
yaraneth@votesolar.org
602-492-6077

[1] Salt River Project, Integrated Resource Plan Report, P.49, available here https://srpnet.com/about/stations/pdfx/2018irp.pdf.

[2] February 15, 2022 Hearing Transcript, starting at P.1118, L.9-10, available here https://srpnet.com/electric/transmission/projects/Coolidge/pdfx/cec/07_02-15-2022_SRP_Coolidge_Expansion_Evidentiary_Hearing.pdf.

[3] Id. at 1121, L.1-3.

[4] ARS 40-360.06(A)(8) available here https://www.azleg.gov/ars/40/00360-06.htm.

[5]See PV and Energy Storage Expected to Comprise 62% of US Capacity Additions 2022-23, PV Magazine, available here https://www.pv-magazine.com/2021/12/28/pv-and-energy-storage-expected-to-comprise-62-of-us-capacity-additions-2022-23/; US Energy Storage Developers Plan 9 GW in 2022, Building on 2021 Breakthrough, S&P Global, available here https://www.spglobal.com/marketintelligence/en/news-insights/latest-news-headlines/us-energy-storage-developers-plan-9-gw-in-2022-building-on-2021-breakthrough-68012433; Solar and Battery Storage Make Up 60% of Planned New US Electric Generation Capacity, Electrek, available here https://electrek.co/2022/03/07/solar-and-battery-storage-make-up-60-of-planned-new-us-electric-generation-capacity/#:~:text=Power%20plant%20developers%20and%20operators,Energy%20Information%20Administration%20(EIA); Trends to Watch in Energy Storage in 2022, Utility Dive, available here https://www.utilitydive.com/spons/trends-to-watch-in-energy-storage-in-2022/610870/.

[6] California Regulator CPUC Approves Utility SCE’s Fast-Tracked 500MW BESS Projects, Energy Storage, available here https://www.energy-storage.news/california-regulator-cpuc-approves-utility-sces-fast-tracked-500mw-bess-projects/.

March 11, 2022
 
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: Salt River Project (SRP) Certificate of Environmental Compatibility (CEC), Docket No.  L-00000B-21-0393-00197
 
Madam Chair and Commissioners,
 
Our organizations submit these joint comments to urge you to vote no on SRP’s CEC application. Not only did SRP not engage in a competitive bidding process and not comply with its own 2018 Integrated Resource Plan (IRP), but it did not adequately consider alternatives to the Coolidge Expansion Project (CEP). This leaves serious concerns about the estimated cost of the facilities and the potential increase in the cost of electric energy to customers.
 
SRP’s 2017-2018 IRP Report states that, “Prior to making any financial commitments to major equipment or construction contracts for new-build generation, [SRP will] issue all-source RFPs [Request for Proposal] for the planned capacity. That capacity will explicitly include the opportunity for cost competitive and viable energy storage and demand response options.”[1] No all-source RFP was issued prior to the decision to expand Coolidge Generating Station by 820 MW.
 
Shortly after the SRP Board voted to narrowly approve this project, SRP issued an all-source RFP for an additional 1000 MW to come online between 2024 and 2026.[2] It is unclear why SRP can issue an all-source RFP for these megawatts, but not the Coolidge megawatts given that both projects were announced within months of each other and are intended to come online within the same time frame.
 
There was considerable testimony at the hearing that SRP did not adequately consider alternatives to this 820 MW expansion of Coolidge. Witness Mr. Robert Gramlich testified that not only did SRP not adequately consider alternatives, but that solar and storage would have been more economical.[3] Specifically, he testified that “SRP’s economic analysis overstated the need for clean resources by a factor of 3 or 4.”[4] “So the economic analysis was distorted by overstating the capacity needed for the renewables and storage.”[5] “A battery would have been more economic than CEP.”[6] Mr. Gramlich went on to testify that SRP did not adequately consider the analysis of its own consultant, E3, in assessing the alternatives to the Coolidge expansion. “E3 found that adding only 731 MW of battery capacity in 2026 provides the same capacity value as the 820 MW CEP.”[7]
 
Arizona Revised Statute (ARS) 40-360.06(A)(8) states that the Committee shall consider “The estimated cost of the facilities and site as proposed by the applicant and the estimated cost of the facilities and site as recommended by the committee, recognizing that any significant increase in costs represents a potential increase in the cost of electric energy to the customers or the applicant.”[8] Further, ARS 30-360.07(B) states that the Commission shall “comply with the provisions of section 40-360.06 and shall balance, in the broad public interest, the need for an adequate, economical and reliable supply of electric power with the desire to minimize the effect thereof on the environment and ecology of this state.”[9]
 
Therefore, the Commission must consider the cost of the project and the economics of supplying that electric power. Because SRP did not conduct an all-source RFP, the Commission does not have adequate information about the alternatives to this project and the potential for a less costly option, such as solar and storage, that would save customers money and better protect the environment and ecology of the state. Approval of the CEC application risks locking customers into significant new costs without evidence that the CEP is the right choice to meet the identified capacity need.
 
We ask the Commission to vote no on this CEC application and direct SRP to proceed with an all-source RFP to consider the best available option for adding 820 MW between now and 2025.
 
Respectfully,
 
Autumn T. Johnson
Executive Director
Arizona Solar Energy Industries Association (AriSEIA)
autumn@ariseia.org
520-240-4757
 
Bret Fanshaw
Western Region Director
Solar United Neighbors (SUN)
bfanshaw@solarunitedneighbors.org
602-962-0240
 
Yaraneth Marin
Interior West Regional Director
Vote Solar
yaraneth@votesolar.org
602-492-6077

[1] Salt River Project, Integrated Resource Plan Report, P.49, available here https://srpnet.com/about/stations/pdfx/2018irp.pdf.
[2] Salt River Project, 2021 All-Source Request for Proposals, available here https://srpnet.com/energy/secure/all-resource-rfp.aspx.
[3] February 15, 2022 Hearing Transcript, starting at P.1116, available here https://srpnet.com/electric/transmission/projects/Coolidge/pdfx/cec/07_02-15-2022_SRP_Coolidge_Expansion_Evidentiary_Hearing.pdf.
[4] Id. at 1118, L.3-4.
[5] Id. L. 6-8.
[6] Id. L.9-10.
[7] Id. at 1121, L.1-3.
[8] ARS 40-360.06(A)(8) available here https://www.azleg.gov/ars/40/00360-06.htm.
[9] ARS 40-360.07(B) available here https://www.azleg.gov/ars/40/00360-07.htm.