​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/.

March 11, 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 vote no on SRP’s CEC application. Not only did SRP not engage in a competitive bidding process and not comply with its own 2018 Integrated Resource Plan (IRP), but it did not adequately consider alternatives to the Coolidge Expansion Project (CEP). This leaves serious concerns about the estimated cost of the facilities and the potential increase in the cost of electric energy to customers.
 
SRP’s 2017-2018 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 [Request for Proposal] for the planned capacity. That capacity will explicitly include the opportunity for cost competitive and viable energy storage and demand response options.”[1] No all-source RFP was issued prior to the decision to expand Coolidge Generating Station by 820 MW.
 
Shortly after the SRP Board voted to narrowly approve this project, SRP issued an all-source RFP for an additional 1000 MW to come online between 2024 and 2026.[2] It is unclear why SRP can issue an all-source RFP for these megawatts, but not the Coolidge megawatts given that both projects were announced within months of each other and are intended to come online within the same time frame.
 
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 not only did SRP not adequately consider alternatives, but that solar and storage would have been more economical.[3] Specifically, he testified that “SRP’s economic analysis overstated the need for clean resources by a factor of 3 or 4.”[4] “So the economic analysis was distorted by overstating the capacity needed for the renewables and storage.”[5] “A battery would have been more economic than CEP.”[6] Mr. Gramlich went on to testify that SRP did not adequately 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.”[7]
 
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.”[8] Further, ARS 30-360.07(B) states that the Commission shall “comply with the provisions of section 40-360.06 and shall balance, in the broad public interest, the need for an adequate, economical and reliable supply of electric power with the desire to minimize the effect thereof on the environment and ecology of this state.”[9]
 
Therefore, the Commission must consider the cost of the project and the economics of supplying that electric power. 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. Approval of the CEC application risks locking customers into significant new costs without evidence that the CEP is the right choice to meet the identified capacity need.
 
We ask the Commission to vote no on this CEC application and direct SRP to proceed with an all-source RFP to consider the best available option for adding 820 MW between now and 2025.
 
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] Salt River Project, 2021 All-Source Request for Proposals, available here https://srpnet.com/energy/secure/all-resource-rfp.aspx.
[3] February 15, 2022 Hearing Transcript, starting at P.1116, available here https://srpnet.com/electric/transmission/projects/Coolidge/pdfx/cec/07_02-15-2022_SRP_Coolidge_Expansion_Evidentiary_Hearing.pdf.
[4] Id. at 1118, L.3-4.
[5] Id. L. 6-8.
[6] Id. L.9-10.
[7] Id. at 1121, L.1-3.
[8] ARS 40-360.06(A)(8) available here https://www.azleg.gov/ars/40/00360-06.htm.
[9] ARS 40-360.07(B) available here https://www.azleg.gov/ars/40/00360-07.htm.