AriSEIA hired Rocky Mountain Institute (RMI) jointly with Vote Solar and Advanced Energy United as a consultant during the 2023 IRP process. RMI advised stakeholders and the utilities on integrated resource plan (IRP) best practices, made recommendations about analysis of distributed energy resources and the Inflation Reduction Act (IRA), and also to review the filed plans by Arizona Public Service (APS) and Tucson Electric Power (TEP). Read the comments above.
0 Comments
Arizona Corporation Commission
1300 W. Washington Street Phoenix, AZ 85007 RE: Comments on the APS and TEP 2023 IRPs, Docket No. E-99999A-22-0046 Chairman, Commissioners, and Staff, AriSEIA is an active member of the Resource Plan Advisory Council (RPAC) for both Arizona Public Service (APS) and Tucson Electric Power (TEP). AriSEIA also jointly hired Rocky Mountain Institute (RMI) to engage in the RPAC process. Their findings are filed separately from these jointly with Vote Solar and Advanced Energy United. AriSEIA submits the following comments on APS[1] and TEP’s[2] Integrated Resource Plans (IRPs) filed on November 1, 2023. Our comments include four sections. First, we include documentation on the affordability and reliability of solar resources. Second, we make recommendations as to the forthcoming Order. Third, we include an analysis of APS’ plan. Fourth, we include a review of TEP’s plan. /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] APS, 2023 IRP, Filed Nov. 1, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000031965.pdf?i=1704923236078 [hereinafter APS IRP]. [2] TEP, 2023 IRP, Filed Nov. 1, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000031960.pdf?i=1704923236078 [hereinafter TEP IRP]. Sierra Club, the Arizona Solar Energy Industries Association, Western Grid Group, Arizona Public Interest Research Group Education Fund, Southwest Energy Efficiency Project, and Western Resource Advocates (collectively, the “Joint Signatories”) provide the following comments regarding Staff’s memorandum, five-year report, and proposed order in Docket No. AUD-00000A-23-0142.
I. BACKGROUND On May 26, 2023, the Utilities Division issued a memorandum opening this docket to review the following Commission rules as part of the Commission’s 5-year review procedure:
On November 30, 2023, Staff issued a memorandum, five-year report, and proposed order recommending that the Commission open a new rulemaking docket to consider amendments to the above-listed rules, with the exception of Article 7 (resource planning and procurement), which already has an existing rulemaking docket (Docket No. RE-00000A-22-0029). Staff’s attached five-year report reviews the objectives, effectiveness, clarity, and probable costs and benefits of each section of Articles 7, 9, 18, 24, and 25, and recommends that portions of each article be amended. II. CONSIDERATION OF POTENTIAL CHANGES TO RESOURCE PLANNING RULES If the Commission decides to consider potential changes to the integrated resource planning (“IRP”) rules in Article 7, the Joint Signatories agree with Staff that such consideration should occur in the existing IRP rulemaking docket (Docket No. RE-00000A-22-0029). A. The Commission Should Consider the Existing Record in the IRP Rulemaking Docket. In considering any proposed changes to the IRP rules, the Commission should refer to the existing record in Docket No. RE-00000A-22-0029. In that docket, proposed rules were developed by Staff via a collaborative process with extensive stakeholder input, which included multiple rounds of comment and several day-long in-person meetings over more than a year. On March 10, 2022, Commission Staff filed a memorandum and proposed order containing the text of proposed rules governing All-Source Requests for Proposals (“ASRFPs”) and the IRP process, which would have been contained in a new Article 28 of the Commission rules.[1] While it appears the current 5-year review rulemaking docket is intended to be narrower in scope, parts of Staff’s 2022 proposal remain relevant and could be adopted via amendments to Article 7. On March 11, 2022, Sierra Club, Western Grid Group, Tierra Strategy, and Western Resource Advocates filed joint comments on Staff’s proposed IRP rules.[2] Those comments are incorporated herein by reference. The 2022 joint comments expressed support for most aspects of Staff’s March 2022 proposal, concluding that the proposed rules would modernize and strengthen Arizona’s IRP process, promoting transparent and accountable resource planning. The 2022 joint comments supported Staff’s proposal to require that a competitive ASRFP procurement process be fuel-neutral and technology-neutral. The comments also supported a robust stakeholder input process via Resource Planning Advisory Councils, and supported requiring utilities to provide stakeholders and Staff with access to modelling software as a permanent feature of the IRP process. However, the 2022 joint comments expressed concerns about a few aspects of Staff’s March 2022 proposal, opposing the inclusion of biomass in the definition of renewable energy resources, and called for IRPs to prioritize development of renewable and clean energy resources in impacted communities affected by fossil fuel power plant closures. Sierra Club filed further comments regarding the Commissioners’ proposed amendments in the IRP rulemaking docket on April 13, 2022, which are incorporated herein by reference.[3] B. The Commission Should Consider Updating Definitions in the IRP Rules. With regard to Staff’s proposed order and 5-year review report in Docket No. AUD-00000A-23-0142, the Joint Signatories agree with Staff that Section R14-2-701 should be amended to clarify the definition of “renewable energy resource” and to define the terms “Resource Planning Advisory Council” and “All-Source Request for Proposals.”[4] The Joint Signatories intend to provide further substantive comments on potential changes to this and other sections of Article 7 if the Commission proceeds with the IRP rulemaking process. C. The Commission Should Include Robust Stakeholder Input In the IRP Rulemaking. The Article 7 IRP rules proposed for review encompass a number of important statewide policy issues related to utility resource planning. Potential amendment of these rules could have far-reaching consequences. These important issues require thorough consideration and robust input from interested parties. The rulemaking process must be transparent and provide ample time for all interested stakeholders to fully participate. In considering any proposed changes to the IRP rules, the Commission should provide extensive opportunities for meaningful stakeholder input. This should include (1) stakeholder workshops, (2) development and issuance of an initial proposal by Staff, including the text of proposed changes to the rules, (3) adequate time for stakeholders to review that proposal and provide feedback, including recommended changes to the text of the rules, (4) issuance of a final proposal by Staff, and (5) adequate time for stakeholders to provide written comments on the final Staff proposal and any proposed amendments prior to the Commission vote. III. CONCLUSION In considering any proposed changes to the IRP rules, the Commission should refer to the existing record in Docket No. RE-00000A-22-0029, and should provide ample opportunities for further stakeholder input. If the Commission decides to consider potential changes to the IRP rules via a rulemaking process as proposed by Staff, the Joint Signatories intend to participate fully in that process, and will provide more detailed comments at the appropriate time.[5] [1] Utilities Division Memorandum and Proposed Order, No. RE-00000A-22-0029 (Mar. 10, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/295540. [2] Sierra Club, Western Grid Group, Tierra Strategy, and Western Resource Advocates, Stakeholder Comments on Possible Rulemaking for the Adoption of All-Source Requests for Proposals and Integrated Resource Planning Rules, No. RE-00000A-22-0029 (Mar. 11, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/295575. [3] Sierra Club, Comments on Amendments to Rulemaking for the Adoption of All-Source Requests for Proposals and Integrated Resource Planning Rules, Docket No. RE-00000A-22-0029 (Apr. 13, 2022), available at https://edocket.azcc.gov/search/document-search/item-detail/296682. [4] See Utilities Division Memorandum and Proposed Order, No. RE-00000A-22-0029 (Mar. 10, 2022), Exhibit A at 1. [5] The Joint Signatories’ silence as to any aspect of Staff’s memorandum, five-year report, and proposed order not addressed in these comments should not be interpreted as agreement with or endorsement of those aspects. Salt River Project
1500 N. Mill Avenue Tempe, AZ 85288 RE: Integrated System Plan and Stakeholder Engagement Salt River Project and Board, The Arizona Solar Energy Industries Association (AriSEIA) requested to be a part of the Integrated System Plan (ISP) stakeholder group in 2022. That request was denied. AriSEIA also requested to be included in the Sustainability Advisory Council and, to date, that has also not been granted. It is unclear why AriSEIA continues to be excluded from all formal SRP stakeholder processes. Therefore, AriSEIA submits the following comments on Item 4 of the October 2nd Board Meeting: SRP should be required to issue All Source Requests for Proposals (ASRFPs) for all major procurements of generating resources. Those ASRFPs should be vetted through the ISP stakeholder process, as Arizona Public Service (APS) has started to do. The ISP stakeholder process should not exclude stakeholders that request inclusion, especially if they are well established organizations that participate in the resource planning processes of every other major utility in the state. Additionally, no stakeholder process should purposely exclude an entire stakeholder segment, such as renewable energy organizations. Such a stance needlessly excludes valuable expertise from what should be a technically robust process. Meetings should also be virtual or hybrid. In person meetings, such as has been the case for the last two, exclude many stakeholders. Stakeholders that are out of the Phoenix metro area, have small children, or cannot devote multiple hours to commuting to and from SRP are excluded. The other major utilities all have remote options for stakeholder participation. Further, the ISP stakeholder process should be meaningful. There should be an exchange of information in both directions and the utility should be willing to make modifications based on stakeholder feedback, run requested portfolios, and provide the modeling inputs and results to stakeholders. Board members should familiarize themselves with the Arizona Corporation Commission (ACC) Integrated Resource Plan (IRP) process and should hold SRP to a similar standard, as you all serve as the regulator of SRP. SRP has been holding meetings on the ISP for more than two years. The board should be voting on a resource plan, not three vague slides called “strategies.” That is not adequate oversight of an unregulated monopoly. The “strategies” provide no meaningful information as to what the utility plans to do regarding RFPs, procurement, or implementation of their sustainability goals. The 2017-2019 resource plan was much more detailed and it completely neglected major procurements, such as the Coolidge expansion. SRP is the only major utility in the state that does not have an exit date for all coal; does not have a mass based carbon emissions goal; and has pursued major gas plant expansions that were never in a resource plan or RFP. The board should demand that the company do better. You are the only oversight on the second largest utility in the state. Sincerely, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org |
AriSEIA NewsKeep up with the latest solar energy news! Archives
April 2024
Categories
All
|