​If you currently have solar on your home or you hope to someday have solar on your home, ACC Commissioners need to hear from you and soon. This is docket number 14-0023 and you can attend the meeting in person at 10 a.m. on Oct. 11 at 1200 W. Washington St. in Phoenix and/or you can call or email Commissioners to tell them not to re-open the decision they already made on solar and renege on their commitment to 270,000 people in the State of Arizona. The contact information for every Commissioner can be found at azcc.gov/contact. In Arizona, Commissioners are also elected statewide and choices they make that impact your pocketbook ought to be remembered on election day. 

FOR IMMEDIATE RELEASE

Arizona Corporation Commission Decision Creates Economic Uncertainty for Rooftop Solar 
Solar advocates criticize ACC's decision.

​WATCH Our Press Conference Here

Phoenix, Arizona — Yesterday, the Arizona Corporation Commission (ACC) held a meeting to discuss the value of solar. The agenda included a vote on reopening the Value of Solar proceeding, whether to change the 10-year buyback rate lock-in period for solar customers and the rule limiting the reduction in buyback rates to no more than 10% per year, and reversing course on the grandfathering of legacy net metering customers. Thousands of people wrote to the Commission, and dozens provided oral testimony during the meeting, overwhelmingly opposed to the ACC reopening the value of solar proceeding or increasing the step-down rate. Those in opposition included solar homeowners, solar workers, clean energy advocates, ratepayer advocates, and every regulated utility in the state.

The Commission decided not to re-open the Value of Solar case, which dictates how solar owners who installed in 2017 or later are credited for the surplus energy they contribute to the grid. However, the Commission did vote to open a new docket to re-evaluate the 10% step-down limitation and lock-in period for future solar customers. 

The original 2017 Value of Solar decision, reached after a lengthy evidentiary hearing and extensive deliberation and compromise, was designed to ensure predictable compensation for solar owners while providing stability to Arizona's rooftop solar market. Current solar customers will maintain their rates. 

Autumn Johnson, Arizona Solar Energy Industries Association (AriSEIA), said, "We are very disappointed in the decision to open a new proceeding on the value of solar. Even opening the docket plunges the market into uncertainty. The new hearing to design a rate case for future customers could have a lasting and detrimental impact on both the solar industry and consumers. Solar is not just a source of clean energy; it's a driver of economic growth, job creation, and energy independence. It's essential to remember that the solar industry has been a significant contributor to Arizona's economy, providing thousands of jobs and attracting investments that benefit local communities."

While the ACC did not re-open the export rate proceeding today, the potential changes could still substantially reduce compensation for solar energy and erode critical protections for homeowners investing in solar power. The step-down limit and lock-in period give homeowners predictability about the compensation they will receive for energy exported to the grid, which is critical when deciding to invest in solar. Changing these rules would directly impact the Arizona solar industry during a period of heavy federal investment in clean energy. 

“We're deeply concerned that any changes to how solar owners are credited for their extra power will jeopardize the future of rooftop solar in Arizona. Without the assurance of stable and predictable savings, many Arizonans will lack the confidence to go solar. Low-income and historically disadvantaged communities, especially, will be unable to access solar savings. The decline in rooftop solar growth would harm all ratepayers since rooftop solar creates a more affordable, efficient, and reliable power grid for everyone. It's crucial that we continue to work together to ensure a fair and equitable energy future with rooftop solar at the cornerstone,” said Adrian Keller of Solar United Neighbors.

Prior to the meeting, stakeholders hosted a webinar and press conference to shed light on the need to maintain the established rates solar customers are paid by their utility for the extra power they provide to the grid. Experts from Vote Solar, AriSEIA, and Solar United Neighbors provided comments during the ACC meeting. 

"It's disheartening to witness some Commissioners actively seeking to undermine the value of distributed generation and disrupt the stability that consumers have come to rely on. We firmly believe in the value of distributed generation, like rooftop solar, as a crucial component of a clean and resilient energy future. We'll remain steadfast in our commitment to advocate for policies that prioritize the interests of consumers, the growth of renewable energy, and the protection of energy independence. We are proud of the thousands of people who sent in comments and the dozens who testified against these harmful decisions. We will work together in the new hearing to ensure equitable access to clean energy solutions.” said Kate Bowman, Vote Solar. 

Commissioners Nick Myers, Jim O'Connor, and Kevin Thompson all voted in favor of the new proceeding. Commissioners Lea Márquez Peterson and Anna Tovar voted against reassessing the stepdown and lock-in rates. The dates for the new hearing are forthcoming, with the six-month proceeding to take place next year. 

###

For media inquiries, interviews, or further information, please contact:
Autumn Johnson
autumn@ariseia.org
520-240-4757

Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) trade organization and the state affiliate of the Solar Energy Industries Association (SEIA). AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. We advocate for sustainable job creation and encourage utilization of Arizona’s greatest natural resource, the sun.

Solar United Neighbors is a 501(c)3 nonprofit organization that works in Arizona and nationwide to represent the needs and interests of solar owners and supporters. Solar co-ops are part of the organization’s mission to create a new energy system with rooftop solar at the cornerstone. Solar United Neighbors holds events and education programs to help people become informed solar consumers, maximize the value of their solar investment, and advocate for fair solar policies.

Vote Solar is a 501(c)3 non-profit organization. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar works to remove regulatory barriers and implement key policies needed to bring solar to scale. Vote Solar works to realize a 100% clean energy future through a solutions-driven, people-first approach. ​

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: Value of Solar, Docket No. E-00000J-14-0023
 
Chairman and Commissioners,
 
The Arizona Solar Energy Industries Association (AriSEIA) is a party to the Value of Solar proceeding. That matter took three years to conclude, had approximately 35 parties, and resulted in a compromise. That compromise was adopted by an entirely republican Commission by a 4-1 vote. It is not a decision the solar industry is excited about. But it put in place a predictable framework by which homeowners, solar companies, and the utilities understood the regulatory landscape. As such, AriSEIA strongly opposes reopening the Value of Solar decision.
 
This Commission has stated multiple times that it supports “regulatory certainty.” Regulatory certainty should apply to all matters before the Commission, not only select matters. It is impossible to do business when the rules under which you operate can change on a whim. While reasonable minds can differ on policy, the institution has a responsibility to ratepayers, utilities, and the other stakeholders that appear before it, including the solar industry, to uphold its own rules, regulations, and orders. Decision 75859 states,
 
There were also concerns raised in regard to the possibility of dramatic changes in the export rate and resulting uncertainty. However, to allow the export rate developed using this methodology to change gradually, it will be updated annually after it is initially set in a rate case proceeding or separate rate design phase. At the time that the initial DG export rate is set, a Plan of Administration that provides the mechanism for annual modifications to that initial rate also will be adopted. The annual updates accomplished between rate cases should be formulaic exercises where the Resource Comparison Proxy Methodology and the Avoided Cost Methodology established in the rate case is updated; however the reduction to the compensation rate under the RCP methodology shall not exceed ten percent per year.[1]
 
Gradualism is referred to eighteen (18) times in the order. Multiple parties asserted the importance of making any changes gradually. “RUCO assert[ed] that the process of applying step-down schedules to the initially-established rate, and predictably and gradually lowering the rate, as market uptake increases and the cost of solar declines, will allow solar to ‘become a net benefit to all ratepayers - DG and non-DG customers alike.’”[2] “Staff assert[ed] that it is critical that the Commission's move away from the current framework be accomplished in a gradual manner.”[3] Further, the Commission’s order determined that the proposed methodologies “provide[d] a path for a gradual transition away from the current net metering model.”[4] The Commission stated, “[w]e believe that this will reduce the risk of dramatic changes to customers and the solar industry and is consistent with our interest in rate gradualism.”[5] Again, this adherence to gradual changes in rates or regulations is an essential component to regulatory certainty. Increasing the stepdown percentage would run counter to the positions of RUCO, Staff, and the Commission, as well as the stated goals in every rate case in recent memory.
 
Decision 75859 also locked in the export rate for a period of ten (10) years.[6] This period provides regulatory certainty for the homeowner. Homeowners make significant investments with private capital, into a generating resource that provides predictable power to the grid. Those investments can be tens of thousands of dollars. Those investment decisions take into account the export rate. It would be impossible to evaluate such a significant investment decision without certainty as to the Commission’s regulations for a period of time directly after the investment. Given the cost of the investment and the longevity of the system, ten (10) years is a very reasonable lock-in period.
 
There are more than 350 solar companies operating in Arizona. These companies employ approximately 8,337 people in Arizona alone and have contributed $16.8 billion dollars to the state’s economy, with $1.5 billion invested just last year.[7] Residential rooftop solar installations are down almost 30% year over year since 2022. This decline is due in part to the declining export rate, in combination with very high interest rates for anyone taking out a loan to install solar. Any homeowner looking to finance rooftop solar will find interest rates as high as 11.99%. Further declines in installations are likely to result in workforce reductions. Individual installers are considering job cuts of dozens of jobs with an average, annual pay of $62,500 a year. A decline in solar will also result in declines in the roofing industry and other energy efficiency contractors, such as HVAC, windows, and insulation. Reopening this docket will plunge an already struggling industry into uncertainty. It is hard to imagine why anyone would install solar when they have no way to predict what the Commission will do or if it will continue to honor any decision it does reach longer than an election cycle. High interest rates paired with a declining export rate and significant regulatory uncertainty will result in a substantial negative impact to the state’s economy.

Companies looking to do business in Arizona investigate the regulatory environment prior to investing in the state. The rate riders for the Resource Comparison Proxy (RCP) are notably forward looking. For example, APS’ rate rider explicitly states, “[t]he RCP rate may not be reduced by more than 10% each year” and “[e]ach Customer’s initial RCP rate will be applicable for 10 years from the time of their interconnection.”[8] Similarly, TEP’s website on RCP specifically states, “the RCP will not be allowed to fall more than 10 percent annually.”[9] Companies do not make business decisions in two-year election cycles. Changing the rules that impact major investments for homeowners or businesses is not good for the economy or the State.

Lastly, the Commission spends considerable time discussing staffing shortages, high workloads, and trouble juggling competing deadlines. A redo of a matter that took three years is simply not a good use of Commission or Staff time and resources. AriSEIA urges you to vote no on reopening the Value of Solar docket for the reasons stated above.

Respectfully,

/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org

[1] Arizona Corporation Commission, Order 75859, Page 151, Line 24 through Page 152, Line 4 (emphasis added), Filed January 3, 2017, available here https://docket.images.azcc.gov/0000176114.pdf?i=1692725715837.

[2] Id. at 96, Line 20-23.

[3] Id. at 137, Line 11-12.

[4] Id. at 148, Line 7-8.

[5] Id. at 154, Line 2-4.

[6] Id. at 156, Line 22-24.

[7] Solar Energy Industries Association (SEIA), Arizona Solar Census, Q2 2023, available here https://www.seia.org/sites/default/files/2023-09/Arizona.pdf.

[8] APS Rate Rider RCP, Page 1 (a) and (c).

[9] TEP, Resource Comparison Proxy Export Rate, available here https://www.tep.com/rcp/. 

​FOR IMMEDIATE RELEASE
 
Arizona Residents Stand United to Protect Rooftop Solar
Stakeholders Meet Ahead of ACC meeting on the fate of rooftop solar in Arizona.
 
Phoenix, Arizona — Yesterday, six years after the original solar export rate decision, energy justice and solar advocates held a virtual stakeholder briefing ahead of the Arizona Corporation Commission (ACC) meeting that could alter the future of rooftop solar in Arizona. The briefing, hosted by Solar United Neighbors in collaboration with Vote Solar and the Arizona Solar Energy Industries Association (AriSEIA), shed light on the need to maintain the established rates solar customers are paid by their utility for the extra power they provide to the grid.
 
WATCH: Stop the Attack on Solar in Arizona Stakeholder Briefing
 
“Arizonans were promised a certain amount for their excess solar production. They made economic investments based on the ACC’s previous decision. Any changes to the value of solar the Commission makes now r could undermine the private investments made by more than 200,000 Arizonans in an effort to lower their monthly energy bills. Ratepayers rely on their utility’s regulator to make decisions on their behalf that maintain stability and certainty. Reopening the value of solar docket does neither,” said Adrian Keller of Solar United Neighbors.
 
At the upcoming ACC meeting on October 11th, Commissioners will decide whether to re-examine the solar export rate, which dictates how solar owners are credited for surplus energy they contribute to the grid. The original 2017 decision, reached after a lengthy evidentiary hearing as well as extensive deliberation and compromise, was designed to ensure predictable compensation for solar owners while providing stability to Arizona's rooftop solar market. Re-opening this case would initiate a new proceeding and could lead to significant changes, which could undermine the value of investments Arizona families have already made in solar. If the ACC were to re-open this case, it also sends families and businesses in the state a signal that the ACC could reverse course on other important policy decisions at any time, undermining the value of long-term investments.
 
Autumn Johnson, Arizona Solar Energy Industries Association (AriSEIA), said, “Any changes to the solar export rate would not only affect homeowners but could also jeopardize our state's economic development. Solar employs more than 8,000 people in Arizona and contributed $1.5 billion to the state’s economy last year, with a total market of $16.8 billion. Paired with high interest rates, total market uncertainty could devastate this important industry in one of the sunniest states in the country.”
 
The potential changes to export rates could include a substantial reduction in compensation for solar energy and the erosion of critical protections for homeowners investing in solar power. A reduction in the export rate would impact the Arizona solar industry during a period of heavy federal investment in clean energy.
 
“Rooftop solar is an essential tool to help meet Arizona’s rapidly growing energy needs affordably while also improving the resilience of our communities. When families invest their own money in locally-produced solar power, it helps to reduce the need to build expensive new power plants and transmission lines, keeping electricity costs low for everybody. Thanks to new federal programs, tax credits, and financing options, rooftop solar is about to become more affordable and attainable than ever. But changes to the value of solar will slam the door shut on low-income communities, first-time homebuyers, and others who are only now getting access to clean energy solutions for the first time” said Kate Bowman, Vote Solar.
 
Stakeholders will hold a press conference at the ACC on the morning of their October 11th meeting at 9:30 a.m. After the press conference, advocates and the public will provide public comment.
 
To review a recording of this briefing, please click here.
 
###
 
For media inquiries, interviews, or further information, please contact:
Autumn Johnson
autumn@ariseia.org
520-240-4757
 
Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) trade organization and the state affiliate of the Solar Energy Industries Association (SEIA). AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. We advocate for sustainable job creation and encourage utilization of Arizona’s greatest natural resource, the sun.
 
Solar United Neighbors is a 501(c)3 nonprofit organization that works in Arizona and nationwide to represent the needs and interests of solar owners and supporters. Solar co-ops are part of the organization’s mission to create a new energy system with rooftop solar at the cornerstone. Solar United Neighbors holds events and education programs to help people become informed solar consumers, maximize the value of their solar investment, and advocate for fair solar policies.
 
Vote Solar is a 501(c)3 non-profit organization. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar works to remove regulatory barriers and implement key policies needed to bring solar to scale. Vote Solar works to realize a 100% clean energy future through a solutions-driven, people-first approach. 

​Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: Application of APS (Docket No. E-01345A-23-0110), TEP (Docket No. E-01933A-23-0108), and UNSE (Docket No. E-04204A-23-0109) for Approval of Revisions to Resource Comparison Proxy
 
Chairman and Commissioners,
 
The Arizona Solar Energy Industries Association (AriSEIA) previously filed comments in the Arizona Public Service (APS) and Tucson Electric Power (TEP) dockets in this matter on August 4th.[1] That filing covered the history of the Resource Comparison Proxy (RCP), the dramatic increase to consumers for electricity, and the economic impact of high interest rates paired with a declining RCP rate on Arizona’s solar industry. We urge you not to decrease the RCP rate as proposed by Commissioner Myers’ Proposed Amendments No. 1 in each of the above referenced dockets.[2]
 
This Commission has stated multiple times that it supports “regulatory certainty.” On January 3, 2017 the Commission issued Order 75859 in Docket No. E-00000J-14-0023, the Commission’s Investigation of the Value and Cost of Distributed Generation. That matter stemmed from a 2013 APS filing on net metering.[3] It then created a generic docket, known as the value of solar docket, that commenced on January 27, 2014 and ran for nearly two years before an evidentiary hearing was scheduled. The evidentiary hearing ran for two months in the spring of 2016 with more than eighteen parties participating. A 4-1 decision of an entirely republican Commission was issued in January 2017, three years after the docket was opened. Commissioner Burns was the lone dissenter. Implementation of the specific RCP methodologies was then resolved in subsequent rate cases for each utility. Decision 75859 states,
 
There were also concerns raised in regard to the possibility of dramatic changes in the export rate and resulting uncertainty. However, to allow the export rate developed using this methodology to change gradually, it will be updated annually after it is initially set in a rate case proceeding or separate rate design phase. At the time that the initial DG export rate is set, a Plan of Administration that provides the mechanism for annual modifications to that initial rate also will be adopted. The annual updates accomplished between rate cases should be formulaic exercises where the Resource Comparison Proxy Methodology and the Avoided Cost Methodology established in the rate case is updated; however the reduction to the compensation rate under the RCP methodology shall not exceed ten percent per year.[4]
 
Further, while the Commission outlined directions for calculating the RCP in Decision 75859, the Plan of Administration for each utility’s RCP rate requires the utility to submit an updated RCP calculation annually for Commission approval and specifies that the RCP “may not be reduced by more than 10% each year.”[5] The table below highlights the proposed RCP stepdown as recommended by Commission Staff versus the Myers amendments.

These reductions run contrary to Decision 75859 and the Plans of Administration for each utility. As such, they do not adhere to the Commission’s own stated goal of “regulatory certainty” and also have not been noticed in accordance with A.R.S. 40-252.[6] Regulatory certainty should apply to all matters before the Commission, not only select matters. Further, it is likely a due process violation to take an RCP methodology from a multi-year process and modify it in an Open Meeting with no testimony, witnesses, or evidence and only two days’ notice, which has the potential to result in litigation. Any deviation greater than 10% from the established RCP methodology should be determined in an evidentiary hearing.
 
AriSEIA’s previous filing highlighted the economic development importance of the solar industry to Arizona. There are more than 300 solar companies operating in Arizona. These companies employ more than 8,000 people in Arizona alone and have contributed $16.5 billion dollars to the state, with $1.5 billion invested just last year.[7] Declines in the solar industry will have ripple effects throughout the economy impacting many other high quality, blue collar jobs, such as in energy efficiency, HVAC, roofing, windows, and insulation. There is no evidence to support Commissioner Myers’ assertion that decreasing the RCP rate by 37-56% will not have a catastrophic impact on an important industry in one of the sunniest states in the country. A table reflecting an increase in DG adoption despite a 10% stepdown in prior years does not mean that increases will continue in the future with a 10% stepdown and certainly not with a stepdown 3-4 times prior decreases. Further, there is no evidence in this docket that the RCP has not dampened growth of this important industry. Because installation rates continue to creep up in TEP and UNSE’s territories does not mean they are not impacted, it simply means the industry has not completely stagnated due to burdensome regulation. APS’ DG penetration is better than TEP and UNSE’s but is still only looking at 1% growth annually since the RCP framework was adopted.
 
Finally, AriSEIA does not agree that the RCP is a “subsidization.” The utilities pay for the power produced that benefits the grid. That power has a number of benefits that are different than utility scale solar. DG does not require new transmission; lengthy Line Siting and zoning proceedings; major land use implications that impact other industries, such as agriculture; or other major infrastructure improvements. The systems are entirely paid for by individual consumers. They are only compensated for the power they provide to the utility that benefits the entire grid, improves resiliency, and can be utilized with storage in demand response programs. If the Commission wishes to reevaluate the value of DG, an evidentiary hearing, not an open meeting, is the appropriate place to do so. Also, both the TEP and APS rate cases have also reflected numerous incidences of the utilities purchasing wholesale power above the RCP rate. Therefore, it is incorrect to assume that DG is somehow above the market rate for power.
 
AriSEIA opposes the Myers Amendments 1 and continues to advocate for an RCP stepdown less than 10%, which is permissible under Order 75859 and the Plans of Administration.
 
Respectfully,
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
autumn@ariseia.org

[1] AriSEIA, Solar United Neighbors, and Vote Solar Joint Letter, Dockets E-01345A-23-0110 and E-01933A-23-0108, filed August 4, 2023, available here https://docket.images.azcc.gov/E000029205.pdf?i=1692739207146.

[2] Commissioner Myers Proposed Amendments 1, filed August 22, 2023, in Docket No. E-01933A-23-0108, available here https://docket.images.azcc.gov/E000029934.pdf; Docket No. E-01345A-23-0110, available here https://docket.images.azcc.gov/E000029933.pdf; and Docket No. E-04204A-23-0109, available here https://docket.images.azcc.gov/E000029935.pdf.

[3] Arizona Public Service, In the Matter of the Application of the APS for Approval of Net Metering Cost Shift Solution, Docket No. E-01345A-13-0248, available here https://edocket.azcc.gov/search/docket-search/item-detail/18039.

[4] Arizona Corporation Commission, Order 75859, Page 151, Line 24 through Page 152, Line 4 (emphasis added), Filed January 3, 2017, available here https://docket.images.azcc.gov/0000176114.pdf?i=1692725715837.

[5] See Appendix H, Arizona Corporation Commission, Decision No. 76295, (Aug. 18, 2017), https://docket.images.azcc.gov/0000182160.pdf?i=1657139837798 (emphasis added).

[6] Arizona Revised Statutes, 40-252, available here https://www.azleg.gov/ars/40/00252.htm.

[7] Solar Energy Industries Association (SEIA), Arizona Solar Census, Q1 2023, available here https://www.seia.org/sites/default/files/2023-07/Arizona.pdf. 

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: Application of APS & TEP for Approval of Revisions to Resource Comparison Proxy (Dockets No. E-01345A-23-0110 & E-01933A-23-0108)
 
Chairman and Commissioners,
 
Vote Solar, Solar United Neighbors, and the Arizona Solar Energy Industries Association (AriSEIA) urge you to support Arizona families and businesses who wish to invest in their own energy resources by reducing the proposed step down of Arizona Public Service’s (APS) and Tucson Electric Power’s (TEP) Resource Comparison Proxy (RCP) rate for 2023. The Commission outlined directions for calculating the RCP in Decision 75859, and the Plan of Administration for each utility’s RCP rate requires the utility to submit an updated RCP calculation annually for Commission approval and specifies that the RCP “may not be reduced by more than 10% each year.”[1] The Commission has the opportunity to provide consumers looking to save money on their energy bill with relief by reducing the RCP step down less than 10%. This also provides the Commission with the opportunity to support businesses in Arizona by saving jobs.
 
Arizona families and businesses continue to face unusual economic challenges driving up the cost of basic necessities like electricity. Over the last year, consumers experienced a 6% increase in electricity costs[2] following on the heels of a 12% increase in electricity costs the year prior, the largest 12 month increase in nearly 20 years.[3] Rooftop solar is an important tool that ratepayers can utilize to help reduce their utility bills and increase energy resiliency at their home. As interest rates continue to increase to their highest levels in decades, Arizona families and businesses who must rely on long-term financing to afford the upfront cost of a solar installation may find that going solar is no longer an affordable option. Currently, any homeowner looking to finance rooftop solar will find interest rates as high as 11.99%. This makes solar very unaffordable for any homeowner who cannot buy their system outright. Any further reductions of the RCP will reduce the number of Arizona households who are able to benefit from their private investment in solar.
 
Additionally, further reductions to the RCP will depress solar adoption in Arizona and limit opportunities to leverage distributed energy resources for demand response purposes to benefit grid resiliency. Increasingly, customers who invest in solar choose to pair their installation with distributed battery storage. This creates an opportunity for utilities to leverage customer-sited battery storage as a “virtual power plant” that can help provide reliable power to the grid in the evening hours or during summer heat waves. As investments in solar become less affordable, the growth of other innovative distributed energy resources like battery storage will stagnate.
 
Further, there are more than 300 solar companies operating in Arizona. These companies employ more than 8,000 people in Arizona alone and have contributed $16.5 billion dollars to the state, with $1.5 billion invested just last year.[4] Residential rooftop solar installers are reporting a nearly 20% decline in business year over year since 2022, with nearly 35% declines in revenue. This is likely to result in workforce reductions of 20%. Individual installers are considering job cuts of dozens of jobs with an average, annual pay of $62,500 a year. A decline in solar will also result in declines in the roofing industry and other energy efficiency contractors, such as HVAC, windows, and insulation. High interest rates paired with a declining export rate will exacerbate this problem, resulting in a significant impact to the state’s economy.
 
We respectfully request that the Commission reduce the step downs proposed by APS and TEP, as included within the Staff’s proposed order, in an effort to support families and businesses and provide them with an extended opportunity to capitalize on the power of the sun to reduce their energy bills.
 
Thank you for your consideration of this important matter.
 
Sincerely,
Autumn T. Johnson
Executive Director
AriSEIA
autumn@ariSEIA.org
 
Adrian Keller
Arizona Program Director
Solar United Neighbors (SUN)
akeller@solarunitedneighbors.org
 
Kate Bowman
Interior West Regulatory Director
Vote Solar
kbowman@votesolar.org
 
[1] See Appendix H, Arizona Corporation Commission, Decision No. 76295, (Aug. 18, 2017), https://docket.images.azcc.gov/0000182160.pdf?i=1657139837798 (emphasis added).

[2] U.S. Bureau of Labor Statistics, Consumer Price Index Summary, (May 2023), https://www.bls.gov/news.release/cpi.nr0.htm.

[3] 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.

[4] Solar Energy Industries Association (SEIA), Arizona Solar Census, Q1 2023, available here https://www.seia.org/sites/default/files/2023-07/Arizona.pdf. 

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[1] 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.”[2] 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.[3] 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.[4] As noted by APS in its Application, forecasted costs for grid-scale solar increased in 2022.[5] 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.[6] 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.[7]
 
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.
 
Sincerely,
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

Kate Bowman
Interior West Regulatory Director
Vote Solar
kbowman@votesolar.org
703-674-8637
  
ATTACHMENT A
 
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.
 
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DELETE
 
            Approve
 
INSERT
 
            Deny
 
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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.
 
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            $0.08465
 
INSERT
           
            $0.09405
 
**Make all conforming changes
 
[1] See Appendix C, APS Application, (April 29, 2022) https://docket.images.azcc.gov/E000019056.pdf?i=1657141638108.

[2] See Appendix H, Arizona Corporation Commission, Decision No. 76295, (Aug. 18, 2017), https://docket.images.azcc.gov/0000182160.pdf?i=1657139837798.

[3] 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.

[4] 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.

[5] APS Application, (April 29, 2022), page 4, lines 6 - 8, https://docket.images.azcc.gov/E000019056.pdf?i=1657141638108.

[6] Arizona Corporation Commission, Decision No. 78583, (May 27, 2022), https://docket.images.azcc.gov/0000206888.pdf?i=1657141036380.

[7] 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.