Support for Arizona Public Service (APS) and Tucson Electric Power (TEP)’s Request for an Extension of Integrated Resource Plan (IRP) Filing Deadline

The Joint Signatories, all members of APS and/or TEP’s IRP Advisory Council, write to support APS and TEP’s request to extend the deadline for filing their IRPs from August 1st, 2023, to November 1st, 2023, contingent on timely access to the modeling software and training.

The APS and TEP Resource Planning Advisory Councils (RPAC) comprise a diverse group of stakeholders and community representatives the RPACs have been providing input to APS and TEP on their next IRP on behalf of residential and business customers, local governments, public schools, the limited-income community, and the solar and environmental community, among others.

We have been meeting monthly since the spring of 2021 for APS, and the fall of 2022 for TEP, to share perspectives and provide input to help both utilities chart a long-term integrated resource plan that maintains reliable, affordable electric service through a balanced, flexible resource mix, which also advances sustainable outcomes. Meetings have addressed topics vital to developing a comprehensive, integrated resource plan, such as load forecasting, existing resource fleet and transmission systems, technology options and costs, and environmental impacts. During these meetings, stakeholders have been invited to listen, offer feedback, and pose questions. Participants have also been encouraged to present their own views. All meeting materials, agendas, and summaries are publicly available on APS and TEP’s RPAC websites. 

Also, pursuant to the Commission’s Decision 78499, APS and TEP are preparing to provide access to modeling licenses for RPAC members so that they will have the ability to conduct their own modeling analysis to better inform and provide feedback to the final IRP scenarios. However, APS and TEP have not yet provided RPAC members with the model licenses or data necessary to start the modeling efforts. Because the three months remaining before the August 1st deadline is not enough time to give this process the due diligence it deserves, a three-month extension to November 1st, 2023, is justified.
This new engagement model provides value to the Commission, APS, TEP, and other stakeholders by:

1. Helping APS and TEP to craft a resource plan that is informed by and reflective of stakeholder and community input, and
   
   
2. Contributing to the publicly available information that others can use to conduct their review and evaluation of APS and TEP’s IRP filings, including dozens of modeled IRP portfolios.

We also hope that a new engagement model will support an IRP process before the Commission that is less contentious than prior IRPs and will ensure that community input and feedback are considered from the outset. To realize these outcomes, however, RPAC members engaging in the additional modeling process must be allowed to complete their analysis fully with enough time to bring results to the RPAC consistent with the Commission’s directive. Without additional time, these efforts may be for naught. 

Because this is the first time this kind of advisory structure with modeling access has been implemented, ensuring that all RPAC participants have a solid understanding of various complex energy issues is essential. As such, many of the RPAC’s initial meetings have focused on education and information sharing. While these educational sessions have been valuable and necessary, the RPAC members have yet to receive the modeling licenses or modeling data and have not begun reviewing and providing input on the dozens of modeled IRP portfolios that APS and TEP produce. Approving APS and TEP’s request to extend the deadline for the filing of their IRPs from August 1st, 2023, to November 1st, 2023, and providing RPAC members access to the modeling license no later than May 2023, would enable the completion of this vital work. This deadline extension should be contingent on the utilities timely providing license access and training. The extension should require APS and TEP to provide access to the model and the requisite training within 30 calendar days of the decision.
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Thank you for considering our comments, and we encourage the Commission to discuss this matter during the May Contingency Open Meeting date on May 11th.

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007-2996
 
RE: Resource Planning and Procurement in 2021, 2022, and 2023 (Docket No. E-99999A-22-0046) and In the Matter of Resource Planning and Procurement in 2019, 2020, and 2021 (Docket No. E-00000V-19-0034)
 
Chairman O’Connor and Commissioners,

At the February 2022 Open Meeting, scheduled for February 8th and 9th, 2022, the Commission voted to acknowledge the 2020 Integrated Resource Plans (IRPs) of Tucson Electric Power (TEP) and Arizona Public Service (APS).[1] In addition to acknowledging the IRPs, the Commission placed numerous other requirements on the utilities, including a requirement to provide stakeholders and Commission Staff with the requisite tools to meaningfully participate in the subsequent modeling process.

IT IS FURTHER ORDERED that Arizona Public Service Company, Tucson Electric Power Company, and UNS Electric, Inc. shall in future Integrated Resource Plans negotiate a project-based licensing fee that permits up to 12 Resource Planning Advisory Council members and Staff the ability to perform their own modeling runs in the same software package as these load serving entities, and to provide all necessary data and support to fully utilize the models. The load serving entities shall absorb the cost of the licensing fees.[2]

To date, nearly 15 months after this vote, neither utility has complied with the Order. Stakeholders have been requesting access since Q4 2022. Stakeholders are still waiting on Nondisclosure Agreements (NDAs) from TEP and were told by APS that training on the software would occur in April 2023. Only the utilities have the ability to execute NDAs, provide the licenses and data, and conduct the requisite training. Without these tools, stakeholders are unable to meaningfully participate in the manner desired by Order 78499.

We ask the Commission to direct both TEP and APS to provide all of the above mentioned tools no later than May 31, 2023. Additionally, because of this lengthy delay, we ask for the IRP filing deadline to be extended past August 1, 2023. That is simply not enough time to conduct modeling and provide meaningful feedback on the results. Finally, we ask that the Commission take this issue up as soon as possible, at either the May 2nd Open Meeting or the May 11th Contingency Meeting, because the June Open Meeting is too close to the IRP deadline to permit resolution of these issues with sufficient time to carry out the analysis envisioned in the Commission’s Order.

Respectfully,

Autumn T. Johnson
Executive Director
Arizona Solar Energy Industries Association (AriSEIA)
520-240-4757
autumn@ariseia.org

[1] Open Meeting Notice, Docketed February 3, 2022, Agenda Item 26, available here: https://docket.images.azcc.gov/0000205866.pdf?i=1682712327380.

[2] Decision No. 78499, Docketed March 2, 2022, Page 14, Lines 9-14, available here: https://docket.images.azcc.gov/0000206081.pdf?i=1682710289643.

​To Members of the Salt River Project Board and SRP Management,

Attached please find the People’s Energy Plan to provide clean energy alternatives to the proposed portfolios currently being considered by Salt River Project Agricultural Improvement and Power District (SRP) in your Integrated System Plan (ISP). The proposed portfolios we present are supported by various communities and stakeholders, including those who have signed this letter, who are concerned about a clean energy future for Arizona. Strategen, a consulting firm focused on decarbonizing energy systems, has done the modeling and analysis for the People’s Energy Plan.

The People’s Energy Plan presents a comprehensive and detailed resource plan that lays out a roadmap for how SRP can meet its clean energy obligations to SRP ratepayers and stakeholders, as well as the people of Arizona. SRP has the potential today to help Arizona address climate change. The People’s Energy Plan is a culmination of direct feedback from everyday hardworking people, community leaders and stakeholders who have strongly voiced what they would like to see from SRP as the Integrated System Plan moves forward.

Unfortunately, SRP has been doubling down on fossil fuels with its efforts to expand the Coolidge Generating Station with 16 additional gas units that would contribute to environmental injustice in the community of Randolph, a proposal to keep the Coronado Generating Station running longer, gas expansions at Agua Fria and Desert Basin, and most recently, proposed gas at Copper Crossing. SRP’s plans to spread out gas turbines to various locations in smaller configurations come at a higher cost for ratepayers and avoids oversight by the Arizona Power Plant and Line Siting Committee and the Arizona Corporation Commission. This is the wrong direction for a utility that indicates it is dedicated to sustainability.

The People’s Energy Plan provides a reliable alternative to more gas and continued reliance on coal and finds the following:

• A more ambitious 85% carbon emissions reduction target, reducing CO2 by 85% from 2005 levels by 2035, is feasible and can result in additional emissions savings.
• The Coolidge gas plant expansion is not part of a least cost portfolio.
• Retiring and replacing SRP’s coal-fired generating units with clean energy could save SRP customers $620 million and avoid 43 million tons of cumulative CO2 emissions. Even higher savings and reduced emissions are possible with the new federal support that is part of the Inflation Reduction Act.
• SRP's current 2035 sustainability goals don't drive any new incremental emissions reductions and are readily achieved by previously announced coal retirements.

Recommendations in the People’s Energy Plan include minimizing investments in new gas, reassessing the retirement dates for coal-fired generating units at Four Corners and Coronado, continuing to support demand side resources, setting more meaningful carbon reduction targets, and exploring the incentives available through the Inflation Reduction Act.

We invite SRP leadership and Board members to thoroughly review the People’s Energy Plan and engage with the People’s Energy Plan coalition to ensure that the ISP represents a fair and transparent process that results in the cleanest and most equitable possible path forward for Arizonans. We expect the People’s Energy Plan will be a useful resource that SRP can implement to benefit ratepayers, Arizona communities, and the environment. SRP can and should be a leader among the state’s utilities in developing clean renewable energy, promoting energy efficiency, and integrating further adoption of distributed energy resources. The People’s Energy Plan demonstrates how SRP can achieve these goals and move away from reliance on coal and gas.

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) requests inclusion in Salt River Project’s (SRP) Integrated System Plan (ISP) Advisory Group. AriSEIA has previously requested inclusion in the ISP Advisory Group on more than one occasion beginning in January of 2022. We have been told that we cannot participate in the Advisory Group because SRP seeks to “have focused engagement from a diverse, but small group of SRP customers and community stakeholders.” However, as you can see from the list of stakeholders [above], there are zero participants that represent the renewables sector; no companies or nonprofit organizations.[1] Further, the Advisory Group size is not unwieldy or even on the larger size of stakeholder groups run by other utilities. AriSEIA has been included in the Arizona Public Service (APS) and Tucson Electric Power (TEP) resource planning processes. And other utilities, such as Idaho Power, keep their meetings open to anyone interested and have not found it to be burdensome. Many of the entities on the current Advisory Group are not actively engaged, thereby further reducing the burden the inclusion of AriSEIA may hypothetically pose.

AriSEIA has also not been included in the Sustainability 2035 Advisory Council. Renewables play a key role in the clean energy transition and the lack of inclusion of any renewables stakeholders is inadequate. We request inclusion in the ISP Advisory Group, as well as the Sustainability Advisory Council. Participation in the very infrequent, public meetings is insufficient, as it does not provide ample opportunity to participate in any of the modeling discussions, where key decisions are made.

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

[1] SRP Meeting 3 Presentation, 1.19.2022, available here https://www.srpnet.com/assets/srpnet/pdf/grid-water-management/grid-management/isp/ISP-Advisory-Group-Meeting-3-Presentation.pdf. 

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/.