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, 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.

Arizona Corporation Commission
1300 W. Washington Street
Phoenix, AZ 85007
 
RE: Comments on the APS and TEP 2023 IRPs, Docket No. E-99999A-22-0046
 
Chairman, Commissioners, and Staff,
 
AriSEIA is an active member of the Resource Plan Advisory Council (RPAC) for both Arizona Public Service (APS) and Tucson Electric Power (TEP). AriSEIA also jointly hired Rocky Mountain Institute (RMI) to engage in the RPAC process. Their findings are filed separately from these jointly with Vote Solar and Advanced Energy United.
 
AriSEIA submits the following comments on APS[1] and TEP’s[2] Integrated Resource Plans (IRPs) filed on November 1, 2023. Our comments include four sections. First, we include documentation on the affordability and reliability of solar resources. Second, we make recommendations as to the forthcoming Order. Third, we include an analysis of APS’ plan. Fourth, we include a review of TEP’s plan.
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] APS, 2023 IRP, Filed Nov. 1, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000031965.pdf?i=1704923236078 [hereinafter APS IRP].

[2] TEP, 2023 IRP, Filed Nov. 1, 2023, Docket No. E-99999A-22-0046, available here https://docket.images.azcc.gov/E000031960.pdf?i=1704923236078 [hereinafter TEP IRP]. 

Arizona Corporation Commission
1200 W. Washington Street
Phoenix, AZ 85007
 
Re: TEP Rate Case, Customer Storage Program Stakeholder Meeting, Docket No. E-01933A-22-0107
 
Chairman and Commissioners,
 
AriSEIA submits these comments in response to the compliance filing that TEP filed on December 7, 2023, in response to the stakeholder process they were ordered to commence regarding a Bring Your Own Device (BYOD) program (also known as Virtual Power Plant (VPP)) and revisions to the R-TECH and LGST-SP tariffs.[1] These stakeholder processes are the result of Order 79065.[2]
 
Because some of the utilities have recently been using their compliance filings as evidence in other proceedings and have also asserted that stakeholder silence is agreement, AriSEIA makes this filing to detail our numerous concerns about how TEP has so far engaged on BYOD, R-TECH, and LGST-SP. AriSEIA put forth a robust proposal to implement a BYOD program, as well as specific modifications to the R-TECH and LGST-SP in the course of the last rate case. Those proposals are the reason this stakeholder process was ordered. Further, TEP stated multiple times in the course of the last rate case proceeding that they had not had time to review the proposals. January will be one year since AriSEIA filed those proposals and TEP still seems unfamiliar with them.
 
BYOD is a win/win for AZ ratepayers and the utilities. AriSEIA’s BYOD proposal leverages private investment in distributed battery storage to provide much needed capacity to the grid at a price that is less than the cost of utility-owned, utility scale battery storage.[3] Further, any costs associated with the program are pay for performance only. There is no upfront payment, no subsidy, no cost shift.
 
At the stakeholder meeting held by TEP on November 17, 2023, TEP had no substantive content prepared, had no response to the AriSEIA proposals, had no proposals of its own, did not have the correct people at the meeting to discuss policy, nor did they articulate any plan for how to manage this process going forward. Further, despite the fact that the Order is clear as to what these stakeholder processes are meant to do, TEP was not clear in its direction to participants as to what we were even there to discuss. TEP permitted the meeting to devolve into a tangent conversation about wholly unrelated technologies or whether or not storage should even be considered, despite the fact that storage is the very reason the stakeholder process was ordered.
 
AriSEIA makes the following recommendations to the Commission and TEP:
 
1.      TEP should have the correct personnel at the stakeholder meetings to discuss policy and regulatory issues;
2.    The AriSEIA proposals on BYOD, R-TECH, and LGST-SP should be the basis on which the process unfolds. TEP should come to the meetings prepared to suggest components of these programs they can or cannot support;
3.     R-TECH and LGST-SP are separate issues and while they are to be discussed concurrently with BYOD, need not be discussed simultaneously;
4.     TEP needs to provide a capable facilitator of the meetings and process, either internal or external;
5.    If TEP wishes to host additional stakeholder meetings on unrelated topics or technologies, it can do so, but these processes should remain consistent with and adherent to the Order and the issues discussed in the last rate case; and
6.   TEP needs to articulate a process and timeline for this work. We suggest monthly meetings of one hour, which should be scheduled in advance with a stakeholder list, like TEP does for its other “collaborative” meetings.
 
AriSEIA’s proposal on all three matters can be found in Kevin Lucas’ direct testimony, filed on January 27, 2023, starting at page 314.[4] An excerpt of that testimony is attached herein.
 
/s/ Autumn T. Johnson
Executive Director
AriSEIA 
(520) 240-4757
[email protected]

[1] TEP, Notice of Filing-Tucson Electric Power Company’s Customer Storage Program Stakeholder Meeting Summary, Dec. 7, 2023, Docket. No. E-01933A-22-0107, available here https://docket.images.azcc.gov/E000032546.pdf.

[2] ACC, Opinion and Order No. 79065, Pg. 149, Lines 11-27, Aug. 25, 2023, Docket No. E-01933A-22-0107, available here https://docket.images.azcc.gov/0000209684.pdf?i=1701984045033.

[3] Kevin Lucas in APS rate case, hearing test., Sept. 1, 2023, Docket No. E-01345A-22-0144, 00:04:31 (this is also applicable in the TEP rate case).

[4] AriSEIA, Direct Testimony of Kevin Lucas, Jan. 27, 2023, Docket No. E-01933A-22-0107, available here https://docket.images.azcc.gov/E000023835.pdf?i=1701984045030. 

FOR IMMEDIATE RELEASE

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

​WATCH Our Press Conference Here

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

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

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

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

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

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

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

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

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

###

For media inquiries, interviews, or further information, please contact:
Autumn Johnson
[email protected]
520-240-4757

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

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

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

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

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

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

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

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

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

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

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

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

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

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

[3] U.S. Bureau of Labor Statistics, Consumer Prices Up 8.6 percent over year ended May 2022, TED: The Economics Daily, (June 14, 2022), https://www.bls.gov/opub/ted/2022/consumer-prices-up-8-6-percent-over-year-ended-may-2022.htm.

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