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Joint Statement from Solar United Neighbors, Vote Solar, and the Arizona Solar Energy Industries Association
Arizona Corporation Commission Disappoints Solar Advocates, Siding with Utility Profits Tucson, Arizona - The Arizona Corporation Commission (ACC) today approved Tucson Electric Power’s (TEP) and UniSource Electric’s (UNSE) proposal to decrease Resource Comparison Proxy (RCP) rates for 2025, further undermining the opportunity to use solar energy to save money on utility bills for customers across Arizona. The Resource Comparison Proxy (RCP) is Arizona’s solar export rate, which determines how much solar customers are paid for the electricity they send back to the energy grid. Commissioners have the option to limit reductions to the RCP in order to avoid negatively impacting solar adoption, and have previously exercised this option during times of economic turmoil such as the COVID-19 pandemic. With the reduction approved today, utilities will pay less for the energy rooftop solar provides, which will ultimately discourage new installations and force the construction of costly new power plants that all customers will pay for through higher energy bills. Solar installations among TEP’s customers fell nearly 40% in 2024, and the ACC-approved reduction to solar rates will only accelerate this trend.[1] “Today’s vote is yet another gift to profit-driven utilities at the expense of communities,” said Kate Bowman, Senior Regulatory Director at Vote Solar. “By cutting the value of solar, the ACC is making it harder for Arizonans to invest in solar—just as these same households are facing rising costs of living and utility bills and a phase out of the federal solar tax credit.” “This decision demonstrates a troubling pattern of behavior by this Commission," said Adrian Keller, Arizona Program Director at Solar United Neighbors. "The ACC consistently approves utility requests while neglecting the ratepayers they are supposed to protect. Following their approval of APS's identical proposal last month, today’s decision continues to penalize families who invest in solar.” “The Commission likes to say it is for an ‘all of the above’ energy strategy, yet its decisions paired with federal policy changes continue to single out renewables punitively,” said Autumn Johnson, Executive Director of the Arizona Solar Energy Industries Association (AriSEIA). “This Commission has imposed solar only fees, continues to reduce the solar export rate, and is trying to eliminate our renewable standards (REST rule), all while the federal government has cut tax credits, imposed extreme tariffs, and enacted a de facto moratorium on all renewables development.” Utilities earn a rate of return on every dollar they spend building power plants and transmission lines. When homeowners invest their own savings to install rooftop solar, they help avoid these expensive projects, saving money for all customers—which is exactly why utilities oppose technologies that threaten their bottom line. Shortly before requesting a 10% reduction to the rate paid to solar customers for exporting electricity, TEP filed a rate case asking Commissioners to increase the rates families pay to purchase electricity from the utility by 14%. Reducing solar export rates will ultimately eliminate jobs, weaken our grid, and force utilities to build new energy generation—a cost that will be passed down directly to customers. On the other hand, increasing access to solar has proven to help families mitigate rising power bills and deliver critical power during record-breaking heat and peak demand. At a time when energy bills are soaring, the Commission should be making solar more affordable, not less. Arizonans deserve the freedom to choose solar power to reduce their bills and protect against rate hikes. Instead, the ACC continues giving utilities tools to discourage renewable energy adoption and maintain their monopoly control. About Solar United Neighbors Solar United Neighbors is a national nonprofit organization that helps people go solar, join together, and fight for their energy rights. SUN's Arizona program advocates for policies that expand solar access and protect solar rights for all Arizonans. About AriSEIA AriSEIA is an Arizona nonprofit trade association working on renewables policies across the state. AriSEIA’s mission is to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. About Vote Solar Vote Solar is a nonprofit advocacy organization working to advance state-level policies that make solar and clean energy solutions accessible to all. Since 2002, Vote Solar has worked to build a just and equitable energy future by leveraging deep policy expertise, strategic partnerships, and public engagement. In the face of powerful opposition, Vote Solar champions bold solutions that expand clean energy access, drive investment in frontline communities, and accelerate the transition to 100% clean energy. [1] According to TEP’s most recent published solar installation data, comparing the first three quarters of 2023 with the first three quarters of 2024. Available at: https://arizonagoessolar.org/tucson-electric-power-tep/
0 Comments
AriSEIA filed joint comments with Vote Solar and Solar United Neighbors today calling on the ACC to not undertake the annual 10% RCP decrease as requested by TEP, APS, and UNSE. There are too many other policy changes at the state and federal level that have negatively impacted the solar industry to further erode it now.
Arizona Public Service (APS) and Tucson Electric Power (TEP) filed new rate case applications in June (one day apart from each other). The Arizona Corporation Commission (ACC) scheduled the cases overlapping with each other as far as testimony, hearings, and briefing. AriSEIA believes this is prejudicial to all parties other than the utilities and asked for the schedule to be modified.
Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Response to Staff Proposed Framework for IRP License Reimbursement; IRP Docket No. E-99999A-25-0058 Chairman and Commissioners, AriSEIA is a member of both the TEP/UNSE and APS Resource Planning Advisory Councils (RPAC). We have been engaged with the last two TEP and APS Integrated Resource Plans (IRPs). In addition to being on the RPACs, regularly attending the meetings, submitting detailed comments on the plans, presenting at the IRP workshop and IRP open meeting; we also participated in the modeling process last time. AriSEIA filed comments on the original Staff recommendation on October 4, 2024.[1] AriSEIA continues to maintain that it is a mistake to require stakeholders to pay for their own modeling licenses. AriSEIA also filed comments refuting utility statements at the IRP workshop that stakeholders had not properly utilized their licenses on August 27, 2024.[2] AriSEIA filed comments on the 2023 IRPs on January 31, 2024 as required. That filing was 142 pages long.[3] AriSEIA also filed 263 pages of joint comments with Vote Solar and Advanced Energy United as to the 2023 IRPs on January 31, 2024.[4] That filing included 124 slides as to RMI’s analysis of TEP and APS’ IRPs, based on their use of the modeling licenses. RMI was our consultant in that matter. AriSEIA filed joint comments in the same docket supporting the need to move the IRP deadline due to modeling delays on May 2, 2023.[5] AriSEIA filed a letter to the docket expressing concerns that APS and TEP were violating the 2020 IRP Order in delaying the release of the modeling tools on April 28, 2023.[6] We note these filings now to draw attention to our robust participation in IRP dockets, but also to highlight that issues with the modeling licenses plagued all of 2023. AriSEIA does not recommend changing the process yet again, as we had just barely worked out the issues with the prior process. Nevertheless, we highlight the following concerns with the Utilities Division Staff Proposed Framework for IRP License Reimbursement filed on May 9, 2025.[7] First, it is important this issue is addressed as soon as possible. It was very clear last time that waiting until the calendar year in which the IRP is due is too late to obtain the modeling licenses and corresponding NDAs, etc. This resulted in significant delays last time, which resulted in the IRP deadline having to be postponed. Second, it is important that the utilities are negotiating down the price of the licenses and provide that price imminently. It is not clear how many licenses we need, how much they cost, or how long we would need to forgo recouping that deposit. It is still unclear what problem this policy is trying to solve. It has been stated that “some” stakeholders, apparently including AriSEIA, did not do enough work to “deserve” a modeling license, despite all of the work described above. However, there were no articulated requirements we failed to meet. The Commission could simply set requirements and not require stakeholders to upfront the cost. There is no articulated reason that small nonprofits need to expend tens of thousands of dollars in advance to provide an essential service to this Commission (i.e., critical review of portfolios that cost ratepayers billions of dollars). That being said, if the Commission proceeds on its current course the requirements should be a floor. It is very strenuous to require stakeholders to run three separate portfolios just to be reimbursed for the licenses. RECOMMENDATION 1: Require One Model AriSEIA recommends the policy require a stakeholder to run the base case scenario or one (not two) distinct portfolio. Staff’s concerns about ability to hire consultants, Staff capacity as to time, and their lack of any modeling in the 2023 IRP process highlight how onerous this work is. There is no substantiation as to why stakeholder need to run three models. One should be the floor. If a stakeholder has the time or resources to run more, then there is nothing stopping them from doing that. RECOMMENDATION 2: Create a Data Request Process Further, there were data limitations from the utilities last time that would not have even allowed stakeholders to run the base case as required by the policy. Stakeholders should not have to forgo their deposit due to a failure on the part of the utility. Not only should the policy be clear what the utilities must provide and by when, it should allow for a discovery like process. If you have issued a Letter of Intent, you should also be able to issue data requests that the utilities have to comply with in 10 days, just like in a rate case. RECOMMENDATION 3: Honor Reciprocity as to Any Deadline Delays Any delays by the utilities to meet their deadlines in the IRP process should correspond with an equal delay in the requirements for stakeholders to meet their subsequent deadlines. A delay on the part of a utility should not require a stakeholder to forfeit their deposit. RECOMMENDATION 4: Allow Stakeholders to Jointly Complete the Framework Requirements “Stakeholder” in this policy should not be singular. Stakeholders should be able to work collaboratively with one Letter of Intent and be able to share the data and responsibility for the requirements articulated in this policy, even if only one person is actually allowed to run the model (i.e., maintains the license). Stakeholders should be able to work together to fund one consultant. A consultant that does capacity expansion modeling likely exceeds $100,000. That number will go up if more modeling runs (like three) are required. Even with model license reimbursement, the Commission is making this process so onerous that most stakeholders, like AriSEIA, will not be able to participate absent working collaboratively with other stakeholders. RECOMMENDATION 5: Reimbursement Must Occur within 60 days of October 30, 2026 Reimbursement should happen within 60 days of the stakeholder filing its analysis on October 30, 2026 and should not require a subsequent vote of the Commission and should, certainly, not have to wait until a vote of the Commission on the actual IRPs, which is typically one to two years after the IRPs are filed. A stakeholder being out >$30,000 for two to three years is not reasonable. The utilities will know what the requirements are and reimbursement should happen seamlessly after filing. If there is any kind of dispute, a stakeholder can notify Staff and that can be taken up by a vote of the Commission. But all stakeholders should not need a vote on something that a) you will have voted on already before the process commences and b) is not likely to be controversial. Note, should any of the deadlines be moved, the 60 days should run from the due date for filing the analysis. RECOMMENDATION 6: Create a Scholarship Option The Commission should consider a scholarship process for stakeholders that can demonstrate a financial hardship. The Commission should put parameters in place to make sure only qualified stakeholders qualify for the scholarship. If a stakeholder does qualify, they should be required to complete the requirements set out in this policy, but without paying for the license themselves. Suggested parameters may include: being a member of the RPAC, attending a certain percentage of RPAC meetings, demonstrated participation in the last IRP process, being a not for profit entity, and financial hardship either by 990 or other means. Penalty for obtaining a scholarship and not completing the requirements as set forth in this policy could be disqualification from any such similar program in the next IRP cycle. RECOMMENDATION 7: Spread Out When the Fees are Due Finally, entities should not have to upfront the entire cost of the license at the outset. Perhaps half is paid at the beginning and half is paid in Q1 2026 or some other date. Being out >$30,000 for multiple budget cycles could be very difficult for many nonprofit organizations. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] [1] AriSEIA Comments on the August 30, 2024 Utilities Division Memorandum and Amendments, Docket No. E-99999A-22-0046, filed October 4, 2024, available here https://docket.images.azcc.gov/E000039019.pdf?i=1749756384020. [2] AriSEIA Response, Docket No. E-99999A-22-0046, filed August 27, 2024, available here https://docket.images.azcc.gov/E000037591.pdf?i=1749756384020. [3] AriSEIA Comments on the APS and TEP 2023 IRPs, Docket No. E-99999A-22-0046, filed January 31, 2024, available here https://docket.images.azcc.gov/E000033415.pdf?i=1749756384020. [4] Joint Comments of AriSEIA, Advanced Energy United, and Vote Solar on the 2023 IRPs, Docket No. E-99999A-22-0046, filed January 31, 2024, available at https://docket.images.azcc.gov/E000033451.pdf?i=1749756384020. [5] Support for APS and TEP’s Request for an Extension of IRP Filing Deadline, Docket No. E-99999A-22-0046, filed May 2, 2023, available at https://docket.images.azcc.gov/E000026358.pdf?i=1749756384020. [6] AriSEIA Letter on IRP Modeling Licenses, Docket No. E-99999A-22-0046, available at https://docket.images.azcc.gov/E000026311.pdf?i=1749756384020. [7] Utilities Division Staff Proposed Framework for IRP License Reimbursement Memorandum, Docket No. E-99999A-25-0058, filed May 9, 2025, available here https://docket.images.azcc.gov/E000044023.pdf?i=1748461994048. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Comments on the August 30, 2024 Utilities Division Memorandum and Amendments, Docket No. E-99999A-22-0046 Chairman and Commissioners, On August 30, 2024, Commission Staff filed a Memorandum with their recommendations as to the Integrated Resource Plans (IRP) of Arizona Public Service (APS), Tucson Electric Power (TEP), UNS Electric (UNSE), and Arizona Electric Power Cooperative (AEPCO).[1] AriSEIA participates on the Resource Planning Advisory Council (RPAC) for APS and TEP and has for many years. I. AriSEIA IRP Engagement AriSEIA first filed in this docket on April 28, 2023 expressing concerns about the delay with APS and TEP providing the modeling licenses that were required from the 2020 IRP Order (Decision No. 78499).[2] It had been 15 months and stakeholders still did not have nondisclosure agreements (NDAs) executed, licenses, or utility data. At that time, we asked for an IRP filing extension, as it takes months to review these models. AriSEIA reiterated these concerns verbally at the June 21, 2023 Open Meeting. AriSEIA also hired a consultant and obtained a modeling license for this IRP. AriSEIA filed two different sets of comments in this docket on January 31, 2024. The comments we filed with our consultant, Rocky Mountain Institute (RMI), are 263 pages long.[3] These comments included comprehensive slides as to their review of the modeling done by APS (60 slides) and TEP (63 slides). We presented this work one on one with each utility and to each RPAC (four total presentations). Plus, RMI provided a presentation to each RPAC on IRP best practices (another two presentations, for six total presentations). We also provided an abbreviated version of the slides to Commission Staff, which we presented at the IRP workshop on July 31, 2024. AriSEIA also attended all of the modeling trainings and briefed APS on what we intended to do with the model before we ever obtained a license. AriSEIA also filed individual comments on the IRP on January 31, 2024, which were 142 pages in length.[4] Those comments focused on our recommendations for the next IRP (the 2026 IRP). Those recommendations are worth repeating here, as many of them are not included in Staff’s recommendation. Namely we recommend retaining the following requirements from the 2020 IRP Order:
We also recommended the inclusion of the following new requirements:
The Sierra Club filed 36 pages of single spaced comments on the APS plan[19] and 26 single spaced comments on the TEP plan[20] on January 31, 2024 and hired Synapse Energy Economics, Inc. to review the models. WRA filed 24 pages of single spaced comments on the TEP plan[21] and 49 pages of single spaced comments on the APS plan.[22] WRA hired Energy Strategies as their consultant on the model analysis, as well as to conduct their own modeling. Sierra Club and WRA also presented their work to the RPAC. Other than Staff, AriSEIA is not aware of any other stakeholder obtaining a modeling license. Collectively, the stakeholders that obtained modeling licenses filed 540 pages of analysis and gave at least 11 presentations on our work between the RPAC, the utilities, and the Commission. And that is despite the fact that we received the licenses and data from the utilities very late in the process. Until TEP filed comments on May 31, 2024, it had never before been asserted that the stakeholders had used the licenses insufficiently.[23] APS did not assert there was any deficiency with the stakeholder use of the licenses until August 26, 2024, nearly seven months after the stakeholders filed their comments.[24] II. Staff Recommendation AriSEIA did no less work than Staff did with the modeling license. In Staff’s recommendation, they wrote: "Staff did find value in being able to navigate the software and step through the inputs in the project files…. Staff believes this software is important for Staff’s analysis in the IRP process. Staff recommends that APS, TEP, and UNSE continue to provide Staff` with a license to the Aurora Modeling Software."[25] Staff then acknowledges the numerous issues stakeholders had in obtaining licenses from the utilities, stating: "Stakeholders in the RPAC stated that they experienced difficulties with fully utilizing the licensing that was provided because of timelines and insufficient data sharing. As a result, stakeholders modeling effects were not as impactful as they could have been. APS only provided the project files for its reference case and TEP and UNSE only provided the project files for its base case."[26] Despite Staff stating that even though they did not do their own modeling and acknowledging the many issues stakeholders encountered with the utilities in being able to access the models, Staff removes the requirement to provide modeling licenses to stakeholders. The 2020 IRP order stated: "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."[27] Despite recommending removal of this requirement, Staff then states that “Staff believes that transparency in the IRP process is important to develop comprehensive IRPs.”[28] However, removing the requirement to provide access to the modeling inhibits transparency. Staff’s only stated reason for removing the modeling requirement for stakeholders is cost.[29] However, a reimbursement model would not lower costs. In fact, because it would create additional administrative burdens, it would likely cost more. There is nothing in the Staff Recommendation that articulates the process by which Staff or the utilities will manage a reimbursement program. Some initial questions include: · Who will manage and monitor this program? · By what date must the utilities reimburse the costs of the modeling licenses? · What is the deliverable that stakeholders must provide to the utilities and by when? · What is the remedy process should there be a dispute? Additionally, it is unclear if the utilities will be able to negotiate a reduced rate license if the stakeholders are to procure the licenses on their own to be potentially reimbursed someday if the utilities, in their sole discretion, deem it warranted. For example, WRA objectively met the never before stated requirement to model their own portfolios (something Staff admits they did not do). Therefore, if only WRA is entitled to reimbursement and that license is astronomically more expensive than the negotiated bulk licenses procured by the utility, the reimbursement could be higher than it is with the current system. Further, a reimbursement program would make it impossible for small nonprofits, such as AriSEIA, to participate at all. AriSEIA has never missed an RPAC meeting. AriSEIA has objectively actively engaged in this docket. It has never been asserted that we do not participate or contribute and yet, under the Staff Recommendation, we are the stakeholder that would be excluded from this process going forward. AriSEIA reached out to Staff three times before this filing in an attempt to understand what problem they are trying to solve with their recommendations, but we were not provided the opportunity to discuss this issue. AriSEIA objects to Staff recommendations 7 and 8 (also known as G and H). Those recommendations will not increase transparency. There is also no evidence that those recommendations will save ratepayers’ money. AriSEIA also objects to Staff recommendation 13 (also known as M). The proper way for the Commission to modify a prior order is through A.R.S. § 40-252. Also, the Staff Recommendation is missing several of the items listed on page 2 above from the 2020 IRP Order that are still very valuable, such as:
AriSEIA also recommends the utilities model ten, not seven, portfolios in the 2026 IRP. Staff recommended only seven in its recommendation 14 (also known as N). The Commission removed the requirement for Staff to obtain a consultant to provide an independent review of the IRPs.[30] This is reason enough for continued stakeholder access to the models. Removing the third party requirement and limiting stakeholder participation in the IRP docket is a step in the wrong direction and takes us back to the backbox utility IRPs that we not acknowledged by the Commission in prior years.[31] This is the first time the utilities have ever provided modeling access and no evidence has been provided that those licenses were misused. No evidence has been provided that removing that requirement will save ratepayers money. Therefore, AriSEIA has provided two Proposed Amendments below. III. Battery Storage Baseload resources are resources that run consistently all or most of the time. Nuclear is an example. You are not going to ramp up and down a nuclear plant based on changes in demand. Dispatchable resources are resources that can be increased or decreased on demand as the needs of the grid change. Some resources are both, such as geothermal and hydropower. They can be run consistently or they can be ramped up and down based on needs. Some resources like gas peakers (combustion turbines (CTs)) and batteries are dispatchable, but are not baseload. Batteries can be dispatched as needed.[32] There are many kinds of storage, batteries are one type. There are many different kinds of battery technologies and they have different capabilities. There are lithium ion batteries, redox flow batteries, lead batteries, vanadium redox flow batteries, nickel-cadmium batteries, sodium sulfur batteries, iron-chromium flow batteries, and zinc-bromine flow batteries.[33] The durations of these technologies range from two hours to ten hours.[34] Indeed, Salt River Project (SRP) has a ten hour flow battery expected to be operational by Q1 of 2026.[35] Batteries are dispatchable. Therefore, they should not be excluded from the Commissioner Thompson and Commissioner Myers Joint Proposed Amendment No. 1. Further, singling out specific technologies undermines the utilities’ usage of all source requests for proposals (ASRFPs). The entire point of moving to ASRFPs is so that all resources have a level playing field on which to compete on cost and utility needs. The Commission singling out specific technologies that cannot be used for capacity or resource planning will jeopardize affordability. Further, it undercuts innovation. Why would the Commission want to choose winners and losers in a game with constantly improving technology? Additionally, specifically eliminating certain technologies makes the utilities more vulnerable to supply chain constraints. A war, natural disaster, new political administration, global pandemic, port strike, etc. can all impact which technologies are available and affordable at any given time. Why would the Commission want to constrain those options? As the amendment is drafted, the only resources that appear to count as “dependable and dispatchable capacity, not including battery storage” but also “approved” after December 31, 2024 and before 2031 would be gas peakers (CTs). Specifying how much of what kind of resource a utility must buy and when, in order to make an additional decision about which plants to retire, is very prescriptive and may be more of a managerial decision than a regulatory one. Finally, because APS first announced it was closing Four Corners in 2020. It is not clear why the new capacity resources that APS must procure to replace Four Corners need be procured only after December 31, 2024. All capacity resources APS procures to replace Four Corners should count for resource adequacy purposes. That being said, AriSEIA understands the purpose of the Amendment and has suggested a friendly amendment below to maintain the spirit of the Amendment while being technology agnostic. IV. Commissioner and Staff Amendments AriSEIA has reviewed the documents filed by Staff, Commissioner Myers, and Commissioner Thompson. AriSEIA supports Staff Proposed Amendment No. 1. The utilities have been clear that the coal retirement dates are economic decisions. AriSEIA opposes Staff Proposed Amendment No. 3. This amendment makes the data that the utilities are to provide to stakeholders with the modeling licenses more ambiguous. “Portfolios” are more specific. If Staff wishes to add “information” it should be additive to and not in lieu of the “portfolios.” AriSEIA opposes Staff Proposed Amendment No. 2. This language is removed by AriSEIA Proposed Amendment No. 1. Further, this language is redundant. For the stakeholder to have modeling results, they would have to use the software. AriSEIA supports Commissioner Myers Proposed Amendment No. 3. Ensuring the accuracy of load forecasts is essential for maintaining reliability and ensuring affordability. AriSEIA supports Commissioner Myers Proposed Amendment No. 6. Regional markets participation is a relevant factor that can impact resource selections and costs and should be included in long term planning. AriSEIA has offered a friendly amendment to Commissioner Thompson and Commissioner Myers Joint Proposed Amendment No. 1. AriSEIA supports efforts to ensure resource adequacy, but does not think the Commission should exclude any technologies that provide “dependable and dispatchable capacity.” Please see AriSEIA Proposed Amendment No. 3. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] [1] Arizona Corporate Commission, Staff’s Integrated Resource Plans (IRP) Recommendation, August 30, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000037784.pdf [hereinafter Staff Recommendation]. [2] AriSEIA, Letter to Commission on IRP, April 28, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000026311.pdf?i=1727931647086. [3] AriSEIA, Vote Solar, and Advanced Energy United, Joint Comments to Commission on IRP, January 31, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000033451.pdf?i=1727931647086. [4] AriSEIA, Comments to Commission on IRP, January 31, 2024, Docket No. E-99999A-22-0046, at 4-5, available here https://docket.images.azcc.gov/E000033415.pdf?i=1727931647086. [5] Arizona Corporate Commission, Staff Assessment of 2020 IRP, March 2, 2022, Decision No. 78499, at 11:1-2, available here https://docket.images.azcc.gov/0000206081.pdf?i=1700515655944 [hereinafter 2020 IRP Order]. [6] Id. at 11:8-13. [7] Id. at 13:10-16. [8] Id. at 14:5-8. [9] Id. at 14:9-14. [10] Id. at 14:15-17. [11] Id. at 14:22-25. [12] Id. at 15:1-3. [13] Id. at 15:4-6. [14] Id. at 15:7-9. [15] Id. at 15:14-16. [16] Id. at 17:15-17. [17] AriSEIA, Letter to Commissioners, August 27, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000037591.pdf?i=1727931647086. [18] Utilities Division Staff, IRP Memorandum, July 29, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000036917.pdf?i=1727931647086. [19] Sierra Club, Comments on the APS 2023 IRP, January 31, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000033488.pdf?i=1727931647086. [20] Sierra Club, Comments on the TEP 2023 IRP, January 31, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000033487.pdf?i=1727931647086. [21] WRA, Notice of Filing Comments on the 2023 IRP of TEP, January 31, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000033471.pdf?i=1727931647086. [22] WRA, Amended Notice of Filing Comments on the 2023 IRP of APS, January 31, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000033473.pdf?i=1727931647086. [23] TEP, Response to Stakeholder Comments, May 31, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000035982.pdf?i=1727931647086. [24] APS, Response to Commissioner Questions, August 23, 2024, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000037555.pdf?i=1727931647086 (APS asserts they purchased a total of six licenses for stakeholders. It is unclear if this number includes Staff. It is unclear who the additional licenses were for and contradicts information APS has provided as to the total amount spent on the licenses. It also falsely asserts that “APS is not aware of whether any other stakeholders utilized the remaining licenses,” despite us presenting at least 11 total times.) [25] Staff Recommendation at 86. [26] Id. at 86-87. [27] 2020 IRP Order at 14:9-14. [28] Staff Recommendation at 87. [29] Id. [30] Arizona Corporate Commission, Order, June 20, 2024, Decision No. 79385, Docket No. E-00000V-15-0094, available here https://docket.images.azcc.gov/0000211300.pdf?i=1727936736722. [31] Arizona Corporate Commission, Order, March 29, 2018, Decision No. 76632 at 53:4-6, Docket No. E-00000V-15-0094, available here https://docket.images.azcc.gov/0000186964.pdf?i=1727936284687. [32] American Clean Power, Clean Energy Storage Facts, available here https://cleanpower.org/facts/clean-energy-storage/. [33] American Clean Power, Battery Storage, available here https://cleanpower.org/facts/clean-energy-storage/battery-storage/. [34] Id. [35] Salt River Project and CMBlu Energy Announce Launch of Innovative Long-Duration Energy Storage Project, Aug. 31, 2023, available here https://media.srpnet.com/salt-river-project-and-cmblu-energy-announce-launch-of-innovative-long-duration-energy-storage-project/. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: APS 2024 RCP, Docket No. E-01345A-24-0095; TEP 2024 RCP, Docket No. E-01933A-24-0094 Dear Chairman and Commissioners, Both Arizona Public Service (APS) and Tucson Electric Power (TEP) have filed in the above noted dockets to request the maximum annual reduction in the Resource Comparison Proxy (RCP).While it is AriSEIA’s position that the underlying Value of Solar decision from Docket No. E-00000J-14-0023 should not be modified in the new export rate Docket No. AHD-00000J-23-0273, we would like to highlight concerning developments in the residential solar sector in Arizona. Recently, Arizona has seen several major residential solar companies leave the Arizona market. Very large residential solar installers based in Arizona have closed entirely. And just in the last week, several AriSEIA members have declared bankruptcy, including companies local to Arizona. Overall, residential solar installations in Arizona are down 31% year over year. Installations in the state are at their lowest level since 2020, a year in which the Commission decreased the RCP by less than the maximum. The decline in residential solar installations, bankruptcies, and company closures are not due solely to the RCP. But a decrease in the RCP will continue to exasperate this alarming situation. Solar represents a significant amount of jobs and economic development in Arizona. Such a significant downturn in this sector in the sunniest state in the country should be cause for concern. Further, distributed generation, including rooftop solar and battery storage, is a critical tool in the toolbox for peak demand reduction and grid reliability. With solar alone, it is possible for rooftop solar customers to completely eliminate or dramatically reduce their peak usage. With a battery, it is possible for them to provide that capacity back to the grid. With well designed policies, these resources can benefit all ratepayers. Respectfully, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 [email protected] A recent Arizona Republic article thoroughly discussed Mohave Electric Cooperative’s Mohave Energy Park and its local opposition. It also stated that “with a capacity of 98 megawatts – just shy of the 100 MW limit that requires approval under Arizona law by a committee that would provide a ‘forum for interested and affected individuals.'"
What folks in Mohave County may not know is that Unisource Electric (UNSE) is simultaneously planning a 200 MW expansion of Black Mountain Generating Station located in Golden Valley. Not only is the UNSE gas plant expansion twice as big as the Mohave Electric project, but UNSE is arguing that the Arizona law referenced above should be reinterpreted to exempt their project from review, too. UNSE has asked the Arizona Power Plant and Line Siting Committee to waive its jurisdiction over the Black Mountain Expansion Project because the individual turbines are less than 100 MW. UNSE argues that Arizona law considers the individual turbines “plants” instead of the entire project and since their turbines are 50 MW each for a total of 200 MW of new gas, they do not need review. Not only would this limit the ability of Mohave County residents to weigh in on the siting of this project, but it would pave the way for all utilities in Arizona to argue the same thing for their projects. If UNSE is successful, essentially all new gas plants in Arizona would be exempt from the law that intended to create a public process and protect the local environment from new power plants. Mohave County residents, like everyone in Arizona, would not have a voice at the Arizona Corporation Commission (ACC) before these plants are built. April 24 is the time to offer public comment on UNSE’s interpretation of Arizona law. The public can file comments online through the ACC’s website (use Docket No. L-00000F-24-0056-00230) or in person, via Zoom, or via the telephone at the time of the hearing (April 24 starting at 10 a.m.). The hearing will take place at the ACC at 1200 W. Washington Street in Phoenix. Unisource Electric (UNSE) the sister company of Tucson Electric Power (TEP) and subsidiary of Fortis Inc., an international energy company, has asked the Arizona Power Plant and Line Siting Committee (and the ACC) to waive its jurisdiction over new gas projects. UNSE is planning a 200 MW expansion of Black Mountain Generating Station located in Mohave County. UNSE is arguing that Arizona law should be reinterpreted to exempt their project from review because the individual turbines are less than 100 MW. The hearing is on April 24, 2024.
Unisource Electric, the sister company to Tucson Electric Power (TEP), has filed an application for a 200 MW gas plant in Mohave County and has asked the Power Plant and Line Siting Committee of the Arizona Corporation Commission (ACC) to waive its jurisdiction. This is problematic, because if granted, utilities would essentially stop getting ACC approval to build any new gas plants. Review would essentially be limited to transmission lines.
AriSEIA hired Rocky Mountain Institute (RMI) jointly with Vote Solar and Advanced Energy United as a consultant during the 2023 IRP process. RMI advised stakeholders and the utilities on integrated resource plan (IRP) best practices, made recommendations about analysis of distributed energy resources and the Inflation Reduction Act (IRA), and also to review the filed plans by Arizona Public Service (APS) and Tucson Electric Power (TEP). Read the comments above.
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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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