Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
RE: Resource Comparison Proxy Proposal for Community Solar (RCP-CS) (Docket No. E-00000A-22-0103) & (Docket No. E-01345A-21-0240)
Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders,
The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to providing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions.
At the working group meetings held on August 30 & 31, 2022, the signatories made a verbal proposal on the bill credit rate for the community solar program in Arizona. As requested by one of the Commissioner’s offices, the signatories are submitting this letter with the written details of that proposal.
As background, the Commission previously approved the Resource Comparison Proxy (RCP) as the compensation mechanism for rooftop solar projects in Arizona. The signatories suggest that the Commission use the current RCP rate for Arizona Public Service (APS) as the initial bill credit rate for the community solar program with two required modifications, discussed herein and summarized in Appendix A. These modifications to the administration of the RCP are required because of the unique characteristics that community solar projects bring to customers and the grid in Arizona. Hereinafter, we refer to this proposal as RCP-CS.
The RCP-CS proposal below is consistent with the Commission Order that initiated this proceeding. Specifically, the Order stated that the program should be “...designed to attract long-term private sector investment” and that “[d]irect bill offsets may be considered for subscribers to produce savings in a structure substantially similar to that offered to rooftop solar customers, eliminating the need for incentives. The value proposition for subscribers should be similar to those participating in onsite generation.” The Commission did not order that the bill credit rate mechanism for community solar should be exactly the same as the existing RCP, rather the value proposition should be “substantially similar.” As such, the RCP-CS proposal recognizes the fundamental dynamics of implementing a successful community solar program in Arizona while using the existing RCP as a starting point to simplify the initial bill credit setting process.
The signatories offer the RCP-CS proposal below:
The study prepared by The Brattle Group and filed by the signatories on August 26, 2022 supports this RCP-CS proposal. The Brattle analysis suggests that the value of community solar is at least, if not higher than, the current value of APS’ RCP. The Brattle analysis found the value stack of community solar to be approximately $0.09683 per kWh (compared to APS’ current RCP of $0.08465 per kWh). Therefore, the Brattle study findings support the reasonableness of locking-in the bill credit rate at the current level of the RCP during the Stability Period. Further, the Brattle study supports the removal of the component of the existing RCP that allows rates to decline by a maximum of ten percent (10%) year over year because the study shows the value of community solar increasing in the future.
The signatories propose that the RCP-CS rate include a Stability Period to allow critical time for the community solar program to be implemented successfully. The Stability Period is a necessary component of the proposal as it will take time for community solar projects to be constructed and for the Commission to gain experience with the community solar program. Several steps must take place before a community solar project is placed into service, including the following:
While some of the activities mentioned above can occur in parallel, some of them are sequential. The five-year Stability Period will allow critical time for projects to come online with reasonable commercial certainty and for the Commission to gain experience with the community solar program. The Stability Period will also allow for additional time to study the value stack of community solar projects to inform future bill credit rates. It is common in other community solar programs around the country to allow for program parameters that promote predictable program ramp-up through this type of approach.
Attached as Appendix A is a table that compares the existing RCP with the proposed RCP-CS, including why the changes above are necessary for a community solar program.
We appreciate the opportunity to address these important questions. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona.
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
Re: Application of APS for Approval of Revised Resource Comparison Proxy, Docket No. E-01345A-22-0105
Madam Chair and Commissioners,
Vote Solar, Solar United Neighbors, and the Arizona Solar Energy Industries Association (AriSEIA) urge you to support Arizona families and businesses who continue to face challenging economic circumstances by delaying the proposed 10% step down of Arizona Public Service’s (APS) Resource Comparison Proxy (RCP) rate for at least one year. The RCP Plan of Administration requires APS to submit an RCP export rate annually for Commission approval and specifies that the RCP “may not be reduced by more than 10% each year.” The Commission has the opportunity to provide consumers looking to save money on their energy bill with relief by postponing the up to 10% step down of the RCP.
After several tumultuous years, Arizona families and businesses continue to face unusual economic challenges. Over the last year, consumers have experienced the largest increase in inflation rates in 40 years and a 36% increase in energy costs. At the same time, manufacturing and supply chain issues are delaying delivery of solar panels and equipment and driving up prices, resulting in the highest prices for polysilicon since 2011. As noted by APS in its Application, forecasted costs for grid-scale solar increased in 2022. Rooftop solar is an important tool that ratepayers can utilize to help reduce their utility bills and increase energy resiliency at their home. As a result of these unprecedented hardships, many Arizona families and businesses hoping to go solar may find that, due to their own economic circumstances or market conditions beyond their control, it will be necessary to delay installing solar. If the RCP is adjusted downward by 10%, families and businesses who must wait until next year to install solar will see a significantly reduced return on their investment for 10 years.
At its current value of $0.09405 cents per kWh, the cost associated with APS’s RCP rate is already lower than other ratepayer expenditures on solar resources. For example, APS recently received approval for its 2022 REST plan which includes $20 to 30 million in annual spending on its utility-owned rooftop solar program, Solar Communities, the closest proxy for a distributed solar installation. The cost of this program includes the capital cost of a rooftop solar installation, which may include recovery of the utilities’ approved rate of return, and a bill credit for participating customers. The cost of the Solar Communities program amounts to approximately $0.147 per kWh over the 20-year lifetime of a solar installation, well above the current RCP rate paid to solar customers.
We respectfully request that the Commission reject the step down as proposed by APS and included within the Staff’s proposed order in an effort to support families and businesses facing challenging and unprecedented economic circumstances and provide them with an extended opportunity to capitalize on the power of the sun to reduce their energy bills. An amendment to the RCP step down is attached as Attachment A below.
Thank you for your consideration of this important matter.
Autumn T. Johnson
Arizona Solar Energy Industries Association (AriSEIA)
Western Region Director
Solar United Neighbors (SUN)
Interior West Regulatory Director
JOINT STAKEHOLDER PROPOSED AMENDMENT NO. 1
Purpose: This Amendment denies the step down authorized in the Decision to give property owners an additional year to install rooftop solar systems at the current export rate. The Commission recognizes that challenging and unforeseen economic circumstances experienced in the last few months may have forced many property owners who otherwise would have installed rooftop solar systems in 2022 to put plans on hold. The Commission also recognizes that the majority, if not the entirety, of the year 2022 will likely be characterized by supply chain disruptions, exorbitant inflation, and high energy costs, presenting reasonable grounds for the Commission to consider the year 2022 an exception to the standard RCP formula. Under this proposal, the Company will still be required to file an application for the step down in 2023.
Page 5, Line 10
Page 5, Line 11
INSERT after “herein”
The Commission recognizes that much of 2022 has subjected ratepayers to unforeseen economic hardships due to supply chain disruptions from COVID-19, high energy rates due to global events, and unprecedented inflation. Therefore, it is not appropriate to decrease the RCP at this time.
Page 5, Line 14
**Make all conforming changes
 See Appendix C, APS Application, (April 29, 2022) https://docket.images.azcc.gov/E000019056.pdf?i=1657141638108.
 See Appendix H, Arizona Corporation Commission, Decision No. 76295, (Aug. 18, 2017), https://docket.images.azcc.gov/0000182160.pdf?i=1657139837798.
 U.S. Bureau of Labor Statistics, Consumer Prices Up 8.6 percent over year ended May 2022, TED: The Economics Daily, (June 14, 2022), https://www.bls.gov/opub/ted/2022/consumer-prices-up-8-6-percent-over-year-ended-may-2022.htm.
 Bloomberg News, Solar Material Price Jumps Most in 8 Months on Supply Woes, Bloomberg, (June 29, 2022), https://www.bloomberg.com/news/articles/2022-06-29/solar-panel-material-price-jumps-most-in-8-months-on-supply-woes.
 APS Application, (April 29, 2022), page 4, lines 6 - 8, https://docket.images.azcc.gov/E000019056.pdf?i=1657141638108.
 Arizona Corporation Commission, Decision No. 78583, (May 27, 2022), https://docket.images.azcc.gov/0000206888.pdf?i=1657141036380.
 This estimate is based on a 6 kW system and a cost of $2.60 per watt, an 8.7% rate of return, annual production of 1,706 kWh/kW in the first year, and 0.5% annual panel degradation.
Keep up with the latest solar energy news!