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Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: APS Interconnection Manual, Docket E-01345A-20-0152 Madam Chair and Commissioners, This item is scheduled for the Staff Meeting on August 16, 2022, as number 11. The Arizona Solar Energy Industries Association (AriSEIA) has reviewed the Arizona Public Service (APS) Interconnection Requirements for Distributed Generation Rev. 9.0 dated May 6, 2022, and as amended in redlined versions from APS on July 20, 2022 and August 10, 2022 (the “Manual”). We have filed comments in this docket, met with APS and Commission Staff several times, and have submitted written feedback to both APS and Staff on outstanding issues. During the deliberation on the Commission’s Interconnection Rulemaking, we expressed our concern that there are many utility requirements that unnecessarily inflate cost while adding time and complexity to the process for interconnecting distributed generation systems in APS territory. Unfortunately, the July 24, 2020, Rev. 8.5 Manual shown on the APS website is the Manual currently being utilized by APS, despite numerous elements that make interconnecting distributed generation needlessly costly for consumers. In fact, in some respects, APS ignores the Commission’s Interconnection Rules. The usage of this older version of the manual is very detrimental to our member companies. This stands in stark contrast to Tucson Electric Power (TEP) who adjusted their interconnection requirements with each revision of their handbook as issues were identified and eliminated during the stakeholder process. The APS Manual revisions to date make multiple changes as a result of stakeholder engagement that address issues that continue to impact the cost, size, and schedules of projects over two and a half years after the Commission’s Interconnection Rules became effective. We respectfully request the Commission direct APS to file a revised Manual no later than August 31, 2022 and to utilize that version until a final vote by the Commission. Given the significant delay in the finalization of the Manual, we request this matter be noticed for a final vote on the October Open Meeting agenda. Thank you for considering these comments meant to improve the compliance of the APS document with the spirit and letter of the Commission’s Interconnection Rules. Respectfully, Autumn Johnson Executive Director AriSEIA 520-240-4757 autumn@ariseia.org Mark Holohan Board of Directors AriSEIA 602-339-8274 markdholohan@gmail.com
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 For Immediate Release: August 12, 2022
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Arizona’s solar community applauds passage of Inflation Reduction Act Phoenix, AZ – Arizona’s solar community, including the Arizona Solar Energy Industries Association (AriSEIA), Solar United Neighbors Action, and Vote Solar, celebrated the passage of the Inflation Reduction Act on Friday. Among many provisions, the landmark legislation will extend and expand tax credits over the next decade for homeowners and businesses installing solar panels, as well as large-scale clean energy development. The bill earned support from a majority of Arizona’s Congressional Delegation, including Senators Kyrsten Sinema and Mark Kelly, and Representatives Gallego, Grijalva, Kirkpatrick, O’Halleran, and Stanton. It now goes to President Biden for his signature. “The Inflation Reduction Act is a huge win for anyone that wants to use solar power in Arizona,” said Bret Fanshaw, Arizona Program Director with Solar United Neighbors Action. “By making solar more affordable for Arizona families, households will directly reap the benefits with lower electric bills for decades to come. We applaud Arizona’s leaders who supported the bill, especially Senators Sinema and Kelly.” The legislation increases the Federal Solar Investment Tax Credit for residential solar installations from 26% to 30%, beginning this year and extending through 2032. This will lower the cost of an average home solar installation in Arizona by around $6,000. It also makes battery storage technology eligible for tax credits as a standalone resource. “More solar and storage investment in Arizona will mean tens of thousands more jobs in the renewable energy sector,” said Autumn Johnson, Executive Director with AriSEIA. “With the passage of this bill, Arizona is poised to use our ideal climate and existing solar industry to continue to lead the country on the deployment of solar power.” In addition to expanding and extending residential tax credits, the bill also provides direct cash payments to tax-exempt organizations installing solar. Traditionally, tax-exempt entities like nonprofits, schools and local governments have not had direct access to federal solar incentives. Rural small businesses and agricultural producers installing solar will also benefit from an expansion of the Rural Energy for America Program (REAP). REAP provides grants that can cover up to half the cost of an eligible rural solar project. The Inflation Reduction Act also includes a $7 billion EPA grant program to enable deployment of zero-emission technologies in lower-income and environmental justice communities. “We are energized by the solar components within the Inflation Reduction Act. The direct pay and REAP provisions help to reduce barriers to solar for communities and marginalized groups,” said Yara Marin, Regional Director for the Interior West at Vote Solar. “However, we recognize that this bill does not remove every barrier to solar access. Vote Solar will continue to work at the state level to ensure solar for all.” At the same time the bill is poised to make transformational investments in solar and other clean energy resources, it also has significant shortcomings, such as potential for new fossil fuel development which has an outsized negative impact on historically marginalized communities. Advocates recognized the need for federal, state, and local government agencies to ensure the bill delivers meaningful results to all Arizonans. As the sunniest state in the country and a burgeoning hub for clean energy technologies from solar panels to battery storage and electric vehicles, Arizona is poised to reap the benefits of this historic $370 billion investment in clean energy and a healthy climate. +++ Arizona Solar Energy Industries Association (AriSEIA) is a 501(c)(6) trade organization and the state chapter 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 and storage. We advocate for sustainable job creation and encourage utilization of Arizona’s greatest natural resource, the sun. Solar United Neighbors Action is a national 501(c)4 nonprofit. SUN Action represents solar homeowners and everyone who wants to benefit from solar energy. We are fighting for a clean, resilient, and equitable energy system. We do this by putting rooftop solar at the cornerstone. Our grassroots network of solar supporters communicates with lawmakers to implement the policies that will make this vision a reality. 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. Senator Kyrsten Sinema
333 E. Camelback Road, Suite 200 Phoenix, AZ 85018 RE: Support for the Inflation Reduction Act of 2022 Dear Senator Sinema, The Arizona Solar Energy Industries Association’s (AriSEIA) mission is to develop and support policies that create opportunities to advance Arizona’s economy through solar energy and storage. AriSEIA advocates for sustainable job creation in deployment of solar and complementary technologies and collaborates with stakeholders to encourage utilization of Arizona’s greatest natural resource: the sun. We write to encourage you to vote “yes” on the Inflation Reduction Act (IRA). This legislation will provide much needed funding and incentives to advance our transition to a clean energy economy. Renewables are a critical component in that energy transition. In addition to supporting a robust solar supply chain, the IRA will bring new jobs to Arizona, as well as the potential for significant dollars of additional economic development and investment in our state. Princeton’s REPEAT Project estimates that the IRA will create 65,000 new jobs in Arizona in the renewables sector by 2035. It will also save Arizona consumers approximately $360 per household on energy expenses by 2030. AriSEIA represents approximately sixty companies already doing business in Arizona that are ready and willing to ramp up their operations and increase their investment. Solar already provides more than 8,000 jobs in Arizona and we look forward to that continuing to grow. Our members engage in every aspect of the solar supply chain, and they are eager to get to work doing even more to promote our economy, our environment, and our residents with the passage of this historic legislation. Additional renewables deployment also means Arizona’s electric system will use less water, which is critical as we face unprecedented water shortages, because solar uses considerably less water than thermal electricity generation. Voting “yes” on the IRA is a vote for the clean energy transition and the companies and workers in Arizona that make it happen. Please support the Inflation Reduction Act. Sincerely, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org Salt River Project
1500 N. Mill Avenue Tempe, AZ 85288 RE: Integrated System Plan and Stakeholder Engagement Salt River Project and Board, The Arizona Solar Energy Industries Association (AriSEIA) requests inclusion in Salt River Project’s (SRP) Integrated System Plan (ISP) Advisory Group. AriSEIA has previously requested inclusion in the ISP Advisory Group on more than one occasion beginning in January of 2022. We have been told that we cannot participate in the Advisory Group because SRP seeks to “have focused engagement from a diverse, but small group of SRP customers and community stakeholders.” However, as you can see from the list of stakeholders [above], there are zero participants that represent the renewables sector; no companies or nonprofit organizations.[1] Further, the Advisory Group size is not unwieldy or even on the larger size of stakeholder groups run by other utilities. AriSEIA has been included in the Arizona Public Service (APS) and Tucson Electric Power (TEP) resource planning processes. And other utilities, such as Idaho Power, keep their meetings open to anyone interested and have not found it to be burdensome. Many of the entities on the current Advisory Group are not actively engaged, thereby further reducing the burden the inclusion of AriSEIA may hypothetically pose. AriSEIA has also not been included in the Sustainability 2035 Advisory Council. Renewables play a key role in the clean energy transition and the lack of inclusion of any renewables stakeholders is inadequate. We request inclusion in the ISP Advisory Group, as well as the Sustainability Advisory Council. Participation in the very infrequent, public meetings is insufficient, as it does not provide ample opportunity to participate in any of the modeling discussions, where key decisions are made. Sincerely, /s/ Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org [1] SRP Meeting 3 Presentation, 1.19.2022, available here https://www.srpnet.com/assets/srpnet/pdf/grid-water-management/grid-management/isp/ISP-Advisory-Group-Meeting-3-Presentation.pdf. AriSEIA worked with more than 10 other organizations to respond to the Arizona Corporation Commission's Staff's community solar questions. The filing addresses each question, provides examples of community solar programs in other states, and sample consumer disclosure forms. Read the letter and learn more about how community solar would work in Arizona here.
Bureau of Land Management
301 Dinosaur Trail Santa Fe, NM 87508 RE: SunZia Southwest Transmission Line To Whom it May Concern: On behalf of the Arizona Solar Energy Industries Association (AriSEIA), we are writing in support of the proposed SunZia Southwest Transmission Line. Our mission is to develop and support opportunities to advance Arizona’s economy through solar energy and storage. As proponents for fostering a booming solar market, we strongly believe building the infrastructure is a necessary step needed as quickly as possible. Our state has the most solar potential of any in our country and the possibility to become a solar hub. In the last ten years we have seen a 90% drop in the cost of utility-scale solar, a trend we expect to continue as the technology keeps improving and becoming more efficient. Building out crucial renewable infrastructure will also serve as an important incentive for developers looking to expand their renewable projects into our state. The direct tax revenue brought in would amount to approximately $230 million across the entirety of the line. The solar industry also has potential to generate a greater boost to our economy. In 2021, the solar industry generated over $33 billion of private investment in the American economy. Offering pathways to boosting the solar industry is particularly crucial in this moment when supply chain constraints have led to fluctuations in the solar market for the first time since consistent projections have steadily decreased in price over the past decade. Arizona is at a pivotal point in diversifying our energy generation and taking advantage of a prosperous and high-demand industry. Laying the foundation will be a necessary step to tapping into these channels. We ask that the SunZia Southwest Transmission Line be approved. Sincerely, Autumn T. Johnson Executive Director AriSEIA (520) 240-4757 autumn@ariseia.org Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 Re: Application of APS for Approval of Revised Resource Comparison Proxy, Docket No. E-01345A-22-0105 Madam Chair and Commissioners, Vote Solar, Solar United Neighbors, and the Arizona Solar Energy Industries Association (AriSEIA) urge you to support Arizona families and businesses who continue to face challenging economic circumstances by delaying the proposed 10% step down of Arizona Public Service’s (APS) Resource Comparison Proxy (RCP) rate for at least one year. The RCP Plan of Administration[1] requires APS to submit an RCP export rate annually for Commission approval and specifies that the RCP “may not be reduced by more than 10% each year.”[2] The Commission has the opportunity to provide consumers looking to save money on their energy bill with relief by postponing the up to 10% step down of the RCP. After several tumultuous years, Arizona families and businesses continue to face unusual economic challenges. Over the last year, consumers have experienced the largest increase in inflation rates in 40 years and a 36% increase in energy costs.[3] At the same time, manufacturing and supply chain issues are delaying delivery of solar panels and equipment and driving up prices, resulting in the highest prices for polysilicon since 2011.[4] As noted by APS in its Application, forecasted costs for grid-scale solar increased in 2022.[5] Rooftop solar is an important tool that ratepayers can utilize to help reduce their utility bills and increase energy resiliency at their home. As a result of these unprecedented hardships, many Arizona families and businesses hoping to go solar may find that, due to their own economic circumstances or market conditions beyond their control, it will be necessary to delay installing solar. If the RCP is adjusted downward by 10%, families and businesses who must wait until next year to install solar will see a significantly reduced return on their investment for 10 years. At its current value of $0.09405 cents per kWh, the cost associated with APS’s RCP rate is already lower than other ratepayer expenditures on solar resources. For example, APS recently received approval for its 2022 REST plan which includes $20 to 30 million in annual spending on its utility-owned rooftop solar program, Solar Communities, the closest proxy for a distributed solar installation.[6] The cost of this program includes the capital cost of a rooftop solar installation, which may include recovery of the utilities’ approved rate of return, and a bill credit for participating customers. The cost of the Solar Communities program amounts to approximately $0.147 per kWh over the 20-year lifetime of a solar installation, well above the current RCP rate paid to solar customers.[7] We respectfully request that the Commission reject the step down as proposed by APS and included within the Staff’s proposed order in an effort to support families and businesses facing challenging and unprecedented economic circumstances and provide them with an extended opportunity to capitalize on the power of the sun to reduce their energy bills. An amendment to the RCP step down is attached as Attachment A below. Thank you for your consideration of this important matter. Sincerely, Autumn T. Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) autumn@ariSEIA.org 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) bfanshaw@solarunitedneighbors.org 602-962-0240 Kate Bowman Interior West Regulatory Director Vote Solar kbowman@votesolar.org 703-674-8637 ATTACHMENT A JOINT STAKEHOLDER PROPOSED AMENDMENT NO. 1 Purpose: This Amendment denies the step down authorized in the Decision to give property owners an additional year to install rooftop solar systems at the current export rate. The Commission recognizes that challenging and unforeseen economic circumstances experienced in the last few months may have forced many property owners who otherwise would have installed rooftop solar systems in 2022 to put plans on hold. The Commission also recognizes that the majority, if not the entirety, of the year 2022 will likely be characterized by supply chain disruptions, exorbitant inflation, and high energy costs, presenting reasonable grounds for the Commission to consider the year 2022 an exception to the standard RCP formula. Under this proposal, the Company will still be required to file an application for the step down in 2023. Page 5, Line 10 DELETE Approve INSERT Deny Page 5, Line 11 INSERT after “herein” The Commission recognizes that much of 2022 has subjected ratepayers to unforeseen economic hardships due to supply chain disruptions from COVID-19, high energy rates due to global events, and unprecedented inflation. Therefore, it is not appropriate to decrease the RCP at this time. Page 5, Line 14 DELETE $0.08465 INSERT $0.09405 **Make all conforming changes [1] See Appendix C, APS Application, (April 29, 2022) https://docket.images.azcc.gov/E000019056.pdf?i=1657141638108. [2] See Appendix H, Arizona Corporation Commission, Decision No. 76295, (Aug. 18, 2017), https://docket.images.azcc.gov/0000182160.pdf?i=1657139837798. [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] Bloomberg News, Solar Material Price Jumps Most in 8 Months on Supply Woes, Bloomberg, (June 29, 2022), https://www.bloomberg.com/news/articles/2022-06-29/solar-panel-material-price-jumps-most-in-8-months-on-supply-woes. [5] APS Application, (April 29, 2022), page 4, lines 6 - 8, https://docket.images.azcc.gov/E000019056.pdf?i=1657141638108. [6] Arizona Corporation Commission, Decision No. 78583, (May 27, 2022), https://docket.images.azcc.gov/0000206888.pdf?i=1657141036380. [7] This estimate is based on a 6 kW system and a cost of $2.60 per watt, an 8.7% rate of return, annual production of 1,706 kWh/kW in the first year, and 0.5% annual panel degradation. 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. June 7, 2022
The Honorable Mark Kelly U.S. Senate 516 Hart Senate Office Building Washington, DC 20510 Dear Senator Kelly, Last year, we wrote seeking your support for a robust energy tax package that would help the solar industry meet our nation’s climate goals. Now, as the Senate gets closer to considering reconciliation legislation, we are asking for your active support in getting this measure over the finish line. To create jobs and economic prosperity for millions of Americans, we ask for your strong support for passage of the reconciliation energy tax package that will spur solar and clean energy in Arizona, including a 10-year extension of the investment tax credit (ITC). Extending the ITC and adding the option to utilize the credit directly is critical to Arizona’s solar development. Arizona is an incredible solar state, ranking fifth nationwide in overall solar installed, and second in solar energy potential. This has resulted in tremendous economic growth and future potential for Arizona businesses. Hard work, small business ingenuity, and an abundance of sun has made Arizona home to more than 300 companies and more than 7,300 jobs working to advance solar innovation and energy freedom. There are multitudes of young people who are looking to enter careers in solar, thanks in large part to the excellent programs at Arizona State University and the University of Arizona. These jobs range across multiple fields, including design, development, construction, and operations & maintenance. The jobs created by this growing industry span the range of professional opportunities, from immediately available jobs that require no advanced education to those that utilize a PhD. A wide range of non-solar businesses in Arizona are also benefitting from the clean energy economy. In towns, communities, and urban areas, solar is driving down company costs and saving businesses money. In rural areas, ranchers are utilizing solar to save on electricity costs, diversifying farm income and assisting with irrigation. And for families across the state, solar helps save money on home energy bills. Solar contributes not just to national energy independence – it helps small businesses and families with financial independence and stability. Despite tremendous progress in states like Arizona, the United States is falling behind on efforts to meet critical climate goals. Arizonans can benefit from continued investments in the state’s solar energy economy, contributing towards meeting our nation’s climate goals while providing local jobs and reliable economic growth for our state. We strongly urge you to work towards the passage of a robust climate reconciliation package that includes a long-term extension of the solar ITC along with direct pay, to allow businesses to plan for a much larger clean energy buildout than is possible under current policy. We also ask for your continued support of a standalone energy storage credit to help the U.S. meet our energy needs and enhance the resilience of our electricity supply. Additionally, the manufacturing provisions in the legislation ensure that there will be a boom in domestic solar manufacturing. We understand that as the Senate considers a reconciliation package, officials will weigh budgetary issues. The investment tax credit is fiscally prudent and contributes to rapid and needed economic growth. Not only does the ITC save money for families, businesses, and schools, it is an anchor that leverages further critical private sector investment. We appreciate your support and look forward to hearing from you. Sincerely, Autumn Johnson Executive Director Arizona Solar Energy Industries Association (AriSEIA) *More than 80 cosigners **Identical letter sent to Senator Sinema 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) autumn@ariseia.org 520-240-4757 Bret Fanshaw Western Region Director Solar United Neighbors (SUN) bfanshaw@solarunitedneighbors.org 602-962-0240 Yaraneth Marin Interior West Regional Director Vote Solar yaraneth@votesolar.org 602-492-6077 [1] Salt River Project, Integrated Resource Plan Report, P.49, available here https://srpnet.com/about/stations/pdfx/2018irp.pdf. [2] February 15, 2022 Hearing Transcript, starting at P.1118, L.9-10, available here https://srpnet.com/electric/transmission/projects/Coolidge/pdfx/cec/07_02-15-2022_SRP_Coolidge_Expansion_Evidentiary_Hearing.pdf. [3] Id. at 1121, L.1-3. [4] ARS 40-360.06(A)(8) available here https://www.azleg.gov/ars/40/00360-06.htm. [5]See PV and Energy Storage Expected to Comprise 62% of US Capacity Additions 2022-23, PV Magazine, available here https://www.pv-magazine.com/2021/12/28/pv-and-energy-storage-expected-to-comprise-62-of-us-capacity-additions-2022-23/; US Energy Storage Developers Plan 9 GW in 2022, Building on 2021 Breakthrough, S&P Global, available here https://www.spglobal.com/marketintelligence/en/news-insights/latest-news-headlines/us-energy-storage-developers-plan-9-gw-in-2022-building-on-2021-breakthrough-68012433; Solar and Battery Storage Make Up 60% of Planned New US Electric Generation Capacity, Electrek, available here https://electrek.co/2022/03/07/solar-and-battery-storage-make-up-60-of-planned-new-us-electric-generation-capacity/#:~:text=Power%20plant%20developers%20and%20operators,Energy%20Information%20Administration%20(EIA); Trends to Watch in Energy Storage in 2022, Utility Dive, available here https://www.utilitydive.com/spons/trends-to-watch-in-energy-storage-in-2022/610870/. [6] California Regulator CPUC Approves Utility SCE’s Fast-Tracked 500MW BESS Projects, Energy Storage, available here https://www.energy-storage.news/california-regulator-cpuc-approves-utility-sces-fast-tracked-500mw-bess-projects/. |
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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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