AriSEIA filed the direct testimony of our two experts today in the Tucson Electric Power rate case. We are focusing on community solar and battery storage programs for residential and commercial customers. The testimony and exhibits exceed 400 pages. You can view the entire filing at the button above. TEP is due to file their response on February 15th.
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AriSEIA filed expert witness testimony in the currently pending TEP rate case focusing on why the Commission should deny TEP's request to increase their return on equity (ROE). Additionally, several other parties filed testimony about items other than rate design on January 11th. You can view the docket here.
AriSEIA Joins Letter in Support of Transportation Electrification Implementation Plan at ACC9/21/2022 RE: In the Matter of Electric Vehicles, EV Infrastructure and Electrification of the Transportation Sector in Arizona (Docket No. E-00000A-21-0104)
Madam Chair and Commissioners, On behalf of Arizona Solar Energy Industries Association (“AriSEIA”), Solar United Neighbors (“SUN”), and Vote Solar, we would like to commend Tucson Electric Power (“TEP”) for bringing forward a comprehensive Transportation Electrification Implementation Plan (“TEIP”). We want to make our support known and urge the Commission to act swiftly to approve the TEIP. Our organizations have been thoroughly engaged in developing electrification policy as we believe transportation electrification is key to building a cleaner, more flexible, and more affordable grid. The growth of transportation electrification is also an opportunity to make Arizona a leader in the clean energy transition. TEP’s TEIP provides a comprehensive framework for reaching this ambitious goal. Building out electric vehicle (EV) infrastructure has numerous economic and environmental benefits. Implementation of the TEIP will make it more convenient, affordable, and reliable for Arizonans to adopt EVs, while also reducing air pollution. We would like to highlight and applaud some key objectives TEP laid out in the TEIP. First, we appreciate TEP’s willingness to invest in educational campaigns and outreach. Many customers remain unfamiliar with EVs, so it is important to give customers opportunities to learn more and especially to get hands-on experience driving an EV, as TEP has proposed through their “EV Showcase.” We hope that TEP’s proposal to develop multiple marketing campaigns based on segmented customer data will result in educational campaigns that appeal to a wide variety of TEP customers and are equally accessible in English and in Spanish. This will ensure consumers, especially in disadvantaged communities, better understand the benefits of EVs and how to optimize charging, thereby saving money and reducing peak demand. The plan correctly recognizes that although investments in EV charging will positively lead to a reduction in fuel costs, high peak loads on our grid systems need to be proactively minimized through education and awareness of rate structures. Second, we are pleased that the TEIP includes a variety of incentive options to help residential and commercial customers adopt EV charging infrastructure at their homes and businesses. Incentivizing customers to adopt smart charging equipment that contributes to grid flexibility will save all customers money. Above and beyond the upfront cost of purchasing EV charging equipment, many EV adopters will find that they need to upgrade the wiring in their home or business. This additional cost can be a significant deterrent, so we appreciate that the proposed Smart Home and Smart City Programs include an incentive for a panel upgrade for Low- and Moderate-income (LMI) customers, as well as incentives to pre-wire new homes for EV charging. Third, we commend TEP for including incentives to support charging infrastructure for public transit, micro-mobility solutions, and non-profit rideshares. These investments will help to ensure that Arizona residents who rely on public transportation, or cannot afford an EV, benefit from the electrification of the transportation sector. Fourth, we are glad to see that TEP’s plan considers the needs of fleet customers who will rely on the correct planning tools to create cost-effective fleet transitions. Total cost of ownership calculators (TCO) will enable fleet customers to accurately address their needs while transitioning. The proposed assistance to fleet managers also creates an opportunity to educate managers about strategies and technologies to optimize charging and avoid adding to peak load. We hope to see a more developed plan in the near future. Fifth, we appreciate that TEP’s plan includes considerations to proactively manage the grid impacts of transportation electrification as EV adoption grows. The TEIP proposes a managed charging pilot program that would encourage EV drivers to align charging with times of day when the cost of energy is lower or when plentiful clean energy resources, like solar, are available. Managed charging reduces peak demand, which improves grid resiliency and reduces the need to build additional generation. We hope this pilot will provide TEP with experience and information to roll out managed charging programs for all customers with EVs. In the meantime, we support the recommendation to require customers who use the Smart Home or Smart City incentives to purchase a networked charger to ensure that EV infrastructure installed today has the communications equipment necessary to help improve grid flexibility. We are also supportive of TEP’s proposal to conduct a grid impact analysis focused on optimizing the use of distribution assets. Understanding and planning for the growth of distributed energy resources is the best way to keep grid costs low for all customers. Going forward, we provide the following recommendations for TEP’s consideration to improve the success of the TEIP. First, customers should be provided with additional information regarding the enrollment process and planned program initiation. We would also like to see how the company plans to evaluate and gather data from customers. Second, we support the recommendation to align the LMI incentive with that of other nearby states, at least $1,300, and distribute it as one lump sum instead of dividing it into separate upgrade allowances. Third, we agree that customers who receive an EV incentive should be required to purchase a networked Level 2 charger. Those receiving this incentive should also be encouraged to enroll in a managed charging program or time of use (TOU) rate when available, with the option to opt-out if appropriate. Once again, the TEIP is a victory for Arizona’s economy. The sooner the plan is implemented, the sooner its plethora of benefits can be reaped. We request that the Commission vote to approve the TEIP and proposed budget during the October Open Meeting. Sincerely, Autumn 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 Kate Bowman Interior West Regulatory Director Vote Solar [email protected] 703-674-8637 AriSEIA is partnering with the Solar Energy Industries Association (SEIA) to intervene in the Tucson Electric Power (TEP) 2022 General Rate Case. TEP filed the rate case in June 2022, testimony is due in January 2023, and the hearing is expected to start in late March 2023.
AriSEIA Negotiated TEP Revised Distributed Generation Interconnection Manual Approved by ACC6/30/2022 Commissioners approved Tucson Electric Power Company’s (TEP) revised Distributed Generation Interconnection Manual. The creation of these manuals was required following the Commission passing rules dealing with the interconnection of distributed generation facilities. TEP’s manual lays out technical and safety requirements that customers within its service territory must follow when interconnecting a distributed generation system, such as residential and commercial solar projects, to the existing grid. The manual is meant to create a standardization process for customers.
TEP’s manual was initially approved at the Commission’s February 2022 Open Meeting, however, following the passage of AriSEIA proposed amendments at that meeting, a revision to the manual was necessary. After several meetings between AriSEIA, TEP, and ACC Staff, the manual was revised to include information regarding Meter Socket Adapters (MSA), detailing their use for generating facilities. The manual was updated to better preserve the Super-Fast Track and Fast Track designations, allowing for faster review tracks for qualified projects. The revised manual also clarifies study cost fees customers are responsible for prior to beginning any study. TEP’s revised manual does not prematurely require inverters to comply with the IEEE sections that are not yet developed or for which equipment is not yet capable of compliance. Further, the manual modified its requirements around transfer trip infrastructure so as not to be overly burdensome, thereby reducing costs for large installations. Finally, the revised manual includes an additional section that provides a list of scenarios meriting an extension of time. All documents related to this agenda item can be found in the Corporation Commission’s online docket at https://edocket.azcc.gov and entering docket number E-01933A-20-0116. AriSEIA filed extensive comments and amendments on Friday, February 4, 2022 with the Arizona Corporation Commission (ACC) calling for changes with Tucson Electric Power (TEP)'s interconnection manual. Specifically, AriSEIA proposed changes to the treatment of Meter Socket Adapters; Construction Timelines; Fast Track, Non-Exporting, and Inadvertent Export Systems; and Fees and Costs charged to customers. This matter is on the agenda for the ACC's February Open Meeting on February 8, 2022. You can find the agenda and watch the meeting here.
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