AriSEIA Submits Letter to Gov. Hobbs' Strategic Energy Working Group

The Honorable Katie Hobbs
Governor of Arizona
1700 West Washington Street
Phoenix, AZ 85007

RE: Recommendations from AriSEIA of the Governor’s Strategic Energy Working Group

Dear Governor Hobbs,

As part of the Strategic Energy Working Group, AriSEIA appreciates the Administration’s ongoing attention to clean energy, economic development, and long term resilience for Arizona. The following recommendations reflect shared priorities from our members that can inform the Working Group process.

Power Purchase Agreement Reform
A more flexible pathway for Power Purchase Agreements (PPA) would unlock many projects that are ready to move but cannot participate under current structures. A parallel track outside of the traditional Request for Proposals (RFP) process would allow self-initiated projects between one and five megawatts to come forward with clear pricing expectations and predictable timelines. This pathway would support parking lot solar, canal solar, agrivoltaics, and other dual use installations that provide community benefits, heat mitigation, and rapid deployment opportunities. Expanding PPA eligibility beyond nonprofit customers would also create new options for schools, small businesses, and commercial customers that wish to adopt clean energy but struggle with upfront capital.

State Incentives for Urban and Suburban Dual Use Solar
Urban and suburban sites introduce unique challenges, but also significant opportunities. These areas include large rooftops, parking structures, canals, and other developed spaces that can host solar without creating land use conflict. A targeted incentive or grant structure would help bring these projects forward more quickly, support local economic development, and expand clean energy access in areas where energy burdens remain high.

Community Energy Demonstration Projects
Many communities are eager to participate in the clean energy transition but lack funding or technical support to begin. A state funded demonstration program would allow local governments, tribes, schools, and nonprofits to pilot community solar, solar plus storage hubs, and neighborhood shade projects. These small and mid-scale initiatives often deliver immediate community benefits and provide valuable lessons for future statewide efforts.

State Energy Financing Modeled on WIFA
Arizona has a successful model in the Water Infrastructure Finance Authority (WIFA). A similar clean energy financing tool would help leverage federal funds, bring down the cost of capital, and ensure that rural, tribal, and underserved communities are not left behind. This approach would create a long term, stable structure for financing solar, storage, microgrids, and other resilience projects.

Solar Development on Federal Lands
Recent federal policy changes, including the July 2025 Department of the Interior memorandum, have created real obstacles for solar development on federal lands. Many projects in Arizona depend on these lands, and delays ripple across economic development, workforce planning, and grid reliability. Engagement from the Governor with the congressional delegation would help elevate these concerns and encourage revisions that better support the state’s clean energy goals.

Arizona State Land Department Coordination
The current development process for state land presents several challenges, including long review timelines, limited visibility into application status, and a circular site control requirement that conflicts with utility interconnection policies. Additional staffing, clearer timelines, and the creation of a conditional site control category would significantly improve predictability. Introducing milestone requirements for long inactive projects would also ensure that valuable land is available for projects that are ready to advance. Even small adjustments to communication and cost transparency would relieve pressure on both the State Land Department and project developers.

Registrar of Contractors Licensing Pathways
A more streamlined solar specific license classification within the Registrar of Contractors would help build the workforce needed for a clean energy economy. Clearer requirements, more targeted training pathways, and simplified classification rules would support safety and quality while making it easier for qualified contractors to enter the market.

Statewide Green Bank
A statewide green bank with broader authority than the current Energy Efficiency Revolving Loan Fund would provide flexible, accessible financing for solar, storage, electrification, and community resilience projects. This tool would help reduce upfront costs and expand clean energy opportunities for households and businesses that do not have access to traditional financing.

Community Solar Development
Many AriSEIA members have expressed strong interest in a community solar framework for Arizona. A well designed program would expand access for renters, low income households, and residents who cannot install rooftop solar. Thoughtful design elements, such as subscriber protections and low income carveouts, would ensure that benefits flow to communities that stand to gain the most.

Solar for All Implementation
The federal Solar for All program is currently subject to a freeze and ongoing litigation, creating uncertainty regarding timelines and implementation pathways. AriSEIA encourages continued pursuit of all available legal and administrative solutions to protect Arizona’s award and to ensure that the program can resume once federal restrictions are lifted. Preparation for a future rollout, including community engagement, program design refinement, and coordination with potential partners, will position Arizona to move quickly when authorization is restored.

Renewable Energy Standard
A statewide Clean Energy Standard would provide a clear signal to investors and utilities and help align long term planning with climate and resilience goals. A target of zero carbon by 2050, combined with interim benchmarks, would support regulatory certainty and economic development.
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Support for the Residential Utility Consumer Office
Strengthening the Residential Utility Consumer Office (RUCO) would help ensure that all customers are represented in regulatory matters, including customers who rely on distributed generation and customers who benefit from clean energy programs. Additional resources or expanded authority (such as in cooperative rate cases) would improve RUCO’s ability to engage across a wider range of energy issues.

Legislative Opportunities
The past several sessions have included both promising clean energy proposals and bills that would have introduced significant barriers. Continued vetoes of harmful legislation, along with support for bills such as SolarApp, Commercial Property Assessed Clean Energy (CPACE), community solar authorization, and PPA reform, would help reduce red tape and accelerate clean energy growth.

State Level Preemption for Siting and Permitting
Many AriSEIA members have expressed concern about inconsistent local rules for clean energy siting and permitting. Limited state level preemption that establishes consistent statewide minimum standards, while still preserving local input, would support predictable development timelines and reduce uncertainty for both utilities and private developers. AriSEIA also encourages direct engagement from the Administration regarding ongoing county and city efforts to restrict solar and battery siting, as these local actions create significant uncertainty and may undermine broader statewide clean energy and economic objectives.

Review of State Assets and Operations
AriSEIA recommends a comprehensive review of all state owned machines, buildings, fleets, and operational processes to support development of a statewide electrification plan. Clear purchasing plans for electric equipment and vehicles would demonstrate meaningful leadership and send a strong market signal. AriSEIA also encourage aggressive pursuit of solar and battery projects on state owned properties, particularly given the availability of federal Direct Pay incentives.
 
Cooling Standards for Data Centers
AriSEIA encourages stronger engagement with data center operators to support adoption of closed loop cooling systems, which would significantly reduce water consumption and strengthen long term sustainability in a desert environment.
 
AriSEIA appreciates the Administration’s leadership and collaborative approach. These recommendations reflect a shared vision for an energy system that is resilient, affordable, community focused, and positioned for long term success. We look forward to continued partnership and collective progress.

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