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Salt River Project 1500 N. Mill Avenue Tempe, AZ 85288 RE: 2025 Pricing Proceeding Recommendations Mr. President, Board Members, and Staff, The Arizona Solar Energy Industries Association (AriSEIA) is the solar, storage, and electrification trade association for the State of Arizona. We advocate for pro renewables policies at every level of government. AriSEIA does not speak for or represent a single company. We represent nearly 100 companies in the State and we advocate for policies that we think are beneficial for the industry and the grid and best serve the public interest to the greatest extent possible. As such, we agree with most of the proposals made by the other organizations, namely Southwest Energy Efficiency Project (SWEEP), Vote Solar, Wildfire, Arizona PIRG, Western Resource Advocates, and Sierra Club on February 6th. We also support many of the points made by Mr. Neil. We agree with an evidenced based approach to policy and ratemaking. We do not support or endorse comments or proposals that impede the clean energy transition, either by individual commenters or individual companies. Batteries are an essential and integral component to increased renewables on the grid, both at the distributed and utility scale levels. Misinformation about the safety or efficacy of batteries is unhelpful and shortsighted and we encourage the board and management to disregard such comments and proposals. Correcting Battery Misinformation While China is currently the world's leading manufacturer of battery cells, a diversified supply chain outside of China is rapidly developing, including manufacturing here in the U.S. The risk of China-only sourcing diminishes by the day. Residential batteries do not fail at high rates; they work well when properly installed. Very few residential batteries fail. Like any other mechanical or chemical device, batteries degrade over time. The manufacturer maps, specifies, discloses, and guarantees this degradation. After 10 years, typical home batteries are guaranteed to still produce 70% (on average) of their original rated capacity. Capable installers consider this degradation when modeling system performance and expected savings and discuss these factors with their clients. Every home is different, uses different amounts of energy, and has different load profiles from other houses. Ethical, competent solar installers study the complexities of home batteries and design the best system for the home, the homeowner's usage, and savings goals. Batteries are often used to achieve these goals, and when designed and installed correctly, they will provide many years of reliable operation and savings. There are very few fire risks associated with modern batteries. Manufacturers have incorporated numerous safety features designed to ensure safety, and data shows very few issues. Additionally, the best practice in Arizona is to install the battery inside of a home, in a garage or utility room, and not outdoors. Home batteries are widely available and can be ordered, delivered, and installed today. Out of half a dozen popular battery manufacturers, only one is experiencing supply issues. Virtual Power Plants Distributed batteries allow individual ratepayers to reduce their electric bills and increase their resiliency in the event of a power outage, while also benefiting the utility and other ratepayers, by providing valuable capacity when the grid needs it most. Valuing that capacity sends a price signal to a ratepayer who has used their own capital to install a battery to provide the stored energy to the grid, instead of their own home, when there is strain on the grid. This is a supply virtual power plant (VPP). SRP can call an event on a hot August afternoon and thousands of homeowners can respond by allowing SRP to use their batteries, instead of them using the stored power themselves. According to the U.S. Department of Energy, there is currently 30-60 GW of VPP capacity on the grid today, but that amount needs to triple by 2030.[1] Arizona Public Service (APS) is in the process of adopting a VPP modeled off of AriSEIA’s proposal, which is derived from a very successful VPP program called ConnectedSolutions. Our proposal is a pay for performance only model that allows the utility to call up to 60 events in the summer season for up to three hours. A third party aggregator operates the program just like a smart thermostat program. Participants can lock in their rate for five years. While we understand that actual adoption of a VPP program within this pricing proceeding may not be possible, we recommend the Board direct management to engage with AriSEIA to develop a program to bring to the board for consideration by the end of the year. Time of Use 64% of SRP’s customers are not on a time of use rate and 95% of SRP’s customers can opt out of a time of use rate. Only 5% of SRP’s customers are solar customers and, yet, they are the only customers required to be on a time of use rate. All customers should have the same rate plan options and all customers should be defaulted onto a time of use rate. Contrary to the comments of the board consultant, no one has argued for 100% participation on the time of use rates, but it should be the majority of customers and customers should have to opt out, rather than opt in. No current time of use customers should be defaulted to non-time of use rates in 2029. They should instead be defaulted to E-28. The differential between the on peak and off peak rates should be roughly 3:1 and that differential should be between on and off peak, not on and super off peak. The on peak time of use window should be three hours to maximize participation. We recommend that E-16 and E-28 have the same on peak period. To alleviate management’s concern about the shifting on peak window and the need to cover more than just 3 hours, we recommend customers have the option of one of two staggard on peak windows. We recommend a 4-7pm on peak option and a 6-9pm on peak option. This alleviates strain on the grid, allows families to select which plan works best for their schedule, and does not penalize solar owners. We also recommend that the super off peak window be 10-3pm in the winter. This aligns with both the costs experienced by SRP and with what other utilities, such as APS, are currently offering. This will reduce customer confusion, creates an evidence and cost based program, and does not unnecessarily penalize solar customers. Fixed Fees AriSEIA agrees with the other organizations that made comments on February 6th. Fixed fees should be as low as possible, as volumetric charges better align price signals with behaviors that improve efficiency. However, to the extent SRP has fixed fees, there should be parity between solar and non-solar residential customers. Solar customers should not be singled out for punitive and discriminatory fees. Export Rate SRP’s export rate is significantly below the other large utilities in Arizona. The valuation of the avoided cost is not correct. That methodology has not been highly scrutinized by the Arizona Corporation Commission or stakeholders because the Resource Comparison Proxy (RCP) framework has not yet rendered it necessary; however, SRP’s proposed export rate methodology in this case is inadequate. AriSEIA met with SRP extensively about our concerns with the value of solar study in 2024. The current cost allocation study does not correctly assign value to capacity costs and avoided transmission and distribution costs. We recommend that SRP adopt an export rate closer to that of Tucson Electric Power (TEP) to be evaluated on an annual basis and locked in for existing customers for a period of ten years, not one year. Even though SRP is three times larger than TEP, their current number of solar customers are comparable. Therefore, TEP is a reasonable starting place for an export rate that is fair to solar customers, but is closer to the current SRP proposal. Additionally, any customers on a net metered rate should be allowed to stay on that rate until 2034 and not be inadvertently bumped in 2029, as is currently proposed. If SRP provided more than two months to process this pricing proceeding, AriSEIA could provide a more detailed analysis and recommendation as to solar rate design. Organizations need time to hire an expert, have the expert review the workpapers, run their own analyses, and make a detailed recommendation. Therefore, we recommend the board set a vote on this pricing proceeding this summer, since the rate will not take effect until November of 2025, so that the best possible recommendations can be brought forward. Commercial Rates SRP seems to want to move to more plans with a storage component, but not in a way that will increase the adoption of storage. We recommend SRP adopt a pilot storage rate similar to the E-32L SP rate that APS adopted in 2024. APS developed that tariff in 2023 as a result of the prior rate case in a stakeholder process with AriSEIA. A copy of that tariff is included as Attachment A. Recommendations As such, AriSEIA recommends the Board offer amendments that accomplish the following: 1. Move the final vote on the pricing proposal until summer of 2025, with new rates to still take effect in November of 2025; 2. Open all four proposed rate plans to solar and non-solar customers; 3. Default all new customers to E-28 with an opportunity to opt out; 4. Have the super off peak time be 10-3pm in winter, instead of 8-3pm year round; 5. Have the same on peak time of 4-7pm or 6-9pm on both E-28 and E-16 with the ability of the customer to choose which of those periods works better for their family; 6. Move the export rate closer to that of TEP with a 10 year lock in, evaluated annually by SRP; 7. Adopt a pilot commercial storage rate similar to APS’ E-32L SP; 8. Grandfather all net metered customers on their current rate until 2034, if so desired by the customers; and 9. Management should be directed to work with AriSEIA via a stakeholder process to develop a VPP program to be presented to the board by the end of the year. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] [1] U.S. Department of Energy, Pathways to Commercial Liftoff: Virtual Power Plants, Sept. 2023, available here https://liftoff.energy.gov/wp-content/uploads/2023/10/LIFTOFF_DOE_VVP_10062023_v4.pdf. 
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AriSEIA is making several recommendations to SRP's board of directors at the February 6th pricing proceeding meeting. AriSEIA will subsequently submit written recommendations. A vote is expected by the board on February 27th. The changes have a disproportionately negative impact on SRP's solar customers, which are only 5% of the residential customers. Our slides are below. More information about the pricing proceeding process can be found here.
Salt River Project
1500 N Mill Avenue Tempe, AZ 85281 RE: Salt River Project (SRP) Status Change Enforcement of Master Meter Dear Board of Directors and Staff, It recently came to our attention that SRP proceeded with a rule change that reduced or eliminated a multi-family development’s ability to meter their facility at a centralized location. This change has significant impacts on our industry and our collaboration efforts with property developers using the Low-Income Housing Tax Credit (LIHTC) who proceeded over the last 18 months with development plans incorporating solar projects to an almost ubiquitous degree to claim the 20% Qualifying Low-Income Residential Building or Benefit Project tax credit. These developments have executed contracts, ordered electrical gear, and proceeded on the basis that their ability to elect the metering infrastructure design of their own accord would be unhindered. The essence of the solar bonus from the LIHTC program is to ensure that solar benefits are passed through to Low-Income Residents to reduce costs, and we urge SRP staff to adjust the rule change allowing for both centralized and distributed metering arrangements subject to a developer’s preference. It is also important to point out that in SRP territory, the lack of Virtual Net Metering, a program which allows multi-family developments across the country to apply solar benefits virtually from a single (most cost effective) interconnection point, is not an option and therefore the only sensible route for these properties to access solar is through a pre-meditated strategy to centralize their electrical infrastructure in a manner that allows for a solar project to be implemented. We recognize that our request may relate to other circumstances for Limited/Moderate Income (LMI) residents who wish to access SRP’s existing bill assistance programs, and we understand the importance of SRP’s plight to continue providing value to these residents in every form possible; however, the millions of dollars that have been invested by numerous LMI residential developers (Ulysses Development Group, Weis-Dominium, DEVCO to name a few in the area with active solar interests) under the auspice of their ability to centralize metering for a cost-effective solar project should be considered. We understand the argument that low-income residents will lose access to individual plans for low income residents, but also want to point out that individually metered solar projects have the same restriction, i.e., once solar is put on an apartment complex, the ability to access low income rate plans is eliminated. This change will result in projects costing 10% - 20% more due to the multiple interconnections, and the challenge to manage the property will be increased. The benefits of allowing master metering with solar are that the developer can install a solar system, share the savings with the tenant, and have a much easier time administering the site than with numerous interconnections. SRP is expecting massive new load growth. We would encourage SRP to work with developers and solar companies to create development friendly policies that encourage more generation on the grid. Solar and solar+storage can be a great asset to “beating the peak.” Putting restrictions on the most straightforward way to achieve those goals is a detriment to the projects and the residents. Further, such significant changes should undergo a stakeholder process before being implemented. This is the first we have heard about this change and the impending change or its justifications was never discussed with AriSEIA. We recommend changing the Electric Service Specifications in 9.I.F to: F. A Master Meter Service is available for new commercial and multi-level residential projects where SRP’s billing meters cannot be located on the ground floor or one level below the ground floor, provided this is not the lowest level of the Building. Also, master metering is allowed when a developer is intending to install a solar system and it would be infeasible to install it on every meter of the building. Sincerely, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] Most people know who their electric utility is, but even if they are Salt River Project (SRP) customers, they do not know there is a huge election coming up on April 2nd. They also very rarely know that SRP is not regulated by anyone, including the Arizona Corporation Commission (ACC), which regulates Arizona Public Service (APS). SRP is almost as big as APS with more than 1 million customers and is one of the largest public power utilities in the United States. It is also a monopoly like APS, but it gets to govern itself. The only check on its activities is its board of directors. For years the board of directors has been so friendly to the utilities’ management, there is effectively zero oversight of this unregulated monopoly.
I have been out knocking on doors for the last couple of weeks to increase voter turnout and despite talking to dozens of ratepayers, I have only met 2 people that knew there was an upcoming election. I also have not knocked on a single door that has had rooftop solar, despite living in the sunniest state in the country, and over 260,000 homes in Arizona have rooftop solar. Both facts are due to SRP policies. The board of directors is elected by SRP ratepayers. There are 14 board members and about half of them are up for election every other year in even numbered years. Only about half of SRP customers are eligible to vote and of those, less than 1% do so. The low voter turnout is largely due to very few people know about the election, and SRP makes it hard to vote. They do not just mail ballots out to eligible voters. Eligible voters have to request a ballot in advance. They also do not allow renters to vote. The board is the only oversight for the utility. The board oversees your rates, the types of power SRP uses to provide electricity like coal or renewables, and the board sets policy. For years, SRP has had some of the worst policies in the state. SRP has the weakest clean energy goals of any major utility in Arizona. SRP is the only major utility in the state without a date to exit all coal. SRP has the worst solar policy of any major utility in the state. It takes years longer for your rooftop solar to pay for itself than if you had APS. SRP raised rates last year due to higher fossil fuel costs and announced this month they are collecting $243.1 million more than budgeted. About half of Arizona’s carbon emissions are attributable to utilities. Therefore, whether you care about the environment, air quality, public health, energy independence, or just want to save money on your bills, there is reason to participate in the upcoming SRP board election. You must request your ballot by March 22nd. Even if you think you are on the early voting list, sign up again to confirm. SRP will begin to mail ballots on March 6th. You need to complete both ballots and return them in the correct envelopes. You must mail your ballots back in advance, because ballots must be received on or before election day, April 2nd. You can also vote in person at SRP (1500 N Mill Avenue in Tempe) on April 2nd. Several candidates are committed to advancing clean energy. But no matter who you vote for, make sure to vote. Request your early ballot today. With such a small voter turnout, your vote can dramatically impact the outcome of the election. 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 [email protected] Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007-2996 RE: Salt River Project (SRP) Coolidge Expansion Project Certificate of Environmental Compatibility (CEC), Docket No. L-00000B-21-0393-00197 Chairman O’Connor and Commissioners, The Arizona Solar Energy Industries Association (AriSEIA) filed joint comments opposing the SRP CEC on March 11, 2022. That filing is attached, as is a filing from the Solar Energy Industries Association (SEIA) on March 14, 2022. None of the underlying reasons for our opposition have been resolved and we remain opposed to SRP’s Application to Amend Decision 78545, filed on June 14, 2023. First, we are concerned with how quickly this application was filed and then docketed for an open meeting. We received notice of this filing at 4:30 pm on June 14th. We received notice of it being on the revised June open meeting agenda at 10:06 am on June 15th, which is only six (6) calendar days before the open meeting and three (3) business days before the open meeting. This is an inadequate amount of time for interested parties to respond and a vote should not be taken at the June 21st open meeting. Further, SRP has clearly known about this arrangement much longer than other interested stakeholders, which is reflected in the fact that their supporters had ample warning to file supportive comments in the docket. This is not the case and a significant disadvantage for those in opposition. Finally on this topic, it is worth noting that almost all of their letters in support are the same organizations that supported granting the CEC before any proposed settlement. Therefore, their support is not contingent on the settlement or anything that has happened since the CEC was filed in 2021. Second, none of the underlying reasons why AriSEIA opposed the CEC in the first place have been addressed. SRP first proposed the Coolidge Expansion Project two years ago in the summer of 2021. One of our largest complaints was that SRP made the decision to invest nearly $1 billion dollars in almost 1 GW of new gas at the Coolidge Generating Station with no competitive bidding process in violation of their own Integrated Resource Plan (IRP). It has been two years and SRP has issued multiple all-source requests for proposals (ASRFPs) since and they have still not solicited or made public any bids to substantiate this project or its massive cost. There is simply no legitimate reason why SRP could not have done so in the last two years. It is highly unlikely that this Commission would allow Arizona Public Service (APS) or Tucson Electric Power (TEP) to do similarly with no competitive bidding process. Third, the statutes that permit the CEC review clearly state that the Commission shall consider the cost of the facilities when determining to grant the CEC. SRP has never provided a rate impact analysis regarding this project. We simply do not know how much it will cost ratepayers. Further, SRP has not docketed any data that reflects the total cost of the project nearly two years later. If the project was $1 billion in 2021, how much does it cost now with 1) significantly increased interest rates, 2) millions of dollars in negotiated concessions, and 3) the dramatic increase in fuel prices we have seen in both TEP and APS fuel adjustor dockets, as well as the increase SRP’s board also voted to pass recently for their own fuel adjustor? It is not prudent to only include capital costs. Any resource acquisition should also include the operations and maintenance (O&M) costs for that plant/resource, as ratepayers pay the total cost. It is simply imprudent to grant this CEC now. SRP should complete its currently pending IRP (called Integrated System Plan or ISP by SRP) process to determine what resources are needed and when and then should issue an ASRFP like every other utility in the state to determine the best project at the lowest cost. If the winning proposal is for a thermal resource, SRP should apply for a CEC, as required. There is no reason for the Commission to deviate from a process it would require of TEP and APS for SRP, certainly not for a CEC that has already been denied twice by this Commission and lost in court, as well. Attached are two letters filed in opposition in March of 2022. As the Commission makeup has changed since, please review them. Please do not vote on the SRP’s CEC application to amend at the June open meeting and when you do vote, please vote no. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] 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:
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 [email protected] [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:
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) [email protected] 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) [email protected] 602-962-0240 Yaraneth Marin Interior West Regional Director Vote Solar [email protected] 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) [email protected] 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) [email protected] 602-962-0240 Yaraneth Marin Interior West Regional Director Vote Solar [email protected] 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. |
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The Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) non-profit trade association representing the solar, storage, and electrification industry, solar-friendly businesses, and others interested in advancing complementary technologies in Arizona. The group's focus is on education, professionalism and promotion of public policies that support deployment of solar, storage, and electrification technologies and renewable energy job growth and creation. |
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