Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Response to Arizona Public Service Community Solar Program Proposal - Docket No. E-00000A-22-0103 and Docket No. E-01345A-21-0240 Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and nonprofit advocacy groups — appreciate the time that the Commission Staff, and stakeholders have dedicated to conducting five comprehensive working group meetings to date regarding the implementation of a community solar program in Arizona. With this letter, we provide a summary of necessary changes to the Arizona Public Service (APS) community solar program proposal, filed to the docket on September 26, 2022. While the signatories appreciate that APS has offered a program proposal as required by Commission Decision 78583, the signatories find several components of the APS proposal to be inconsistent with that Decision and generally not representative of how community solar programs operate in established markets across the country. The signatories believe that the APS proposal will not result in any competitive third-party development of community solar projects and, as such, restricts benefits that would be created for subscribers and ratepayers as a result of such development. In fact, APS’s proposal would let a single large-scale, utility-owned project interconnected on the transmission grid satisfy the entire community solar program requirement. The Commission should reject this program structure. The signatories agree with the four core principles guiding APS’s program design:
The program proposal the signatories filed on August 26, 2022 is consistent with Decision 78583, the core principles listed above, and with community solar programs nationally. The signatories maintain that the program proposal we offered represents the best balance of benefits for all stakeholders. Should the Commission attempt to work within the framework proposed by APS, the signatories offer the following recommendations to be incorporated into the APS proposal. These recommendations are necessary for implementation of a successful competitive community solar program. Our recommendations incorporate certain elements of the signatories’ August 26, 2022 program proposal and were further supplemented by the bill credit rate proposal filed on September 9, 2022. The signatories request that Commission Staff adopt these necessary recommendations in its Recommended Opinion and Order (ROO). Key changes and clarifications to the APS program proposal are required in the following thirteen (13) areas. Comprehensive rationale behind each of these changes is provided below.
To further supplement these recommendations, the signatories have provided Attachment A to this filing, which includes a table and graphs summarizing bill credit methodologies, values, and terms from nine programs across the country where the signatories have experience, which are also representative of successful, robust programs. We also provide Attachment B, which summarizes program size and LMI subscriber considerations in programs across the country. Finally, we provide Attachment C, which summarizes the key considerations of subscriber organizations and financiers when financing community solar projects.
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Investing in infrastructure is an opportunity to imagine and build a better future for everyone. The influx of federal dollars from the recently-adopted Inflation Reduction Act and the Bipartisan Infrastructure Law is a once-in-a-generation chance to imagine what a better future for Arizona looks like and then to make it real.
New federal funds have enormous potential to save residents and businesses money on energy and transportation, create new jobs, and expand prosperity – while also improving our health and protecting our climate. However, how local governments choose to implement new policies will have a large effect on their overall impact. We, a coalition of 14 clean energy, energy efficiency, community health, and environmental justice groups, write to ask you to maximize the benefits of this unprecedented opportunity and to steer our region toward a better future. Specifically, we urge you to identify, direct federal funding towards, and maximize public participation in projects and programs that will:
Opportunities to deliver these kinds of benefits to the region and state are plentiful within the Inflation Reduction Act and the Bipartisan Infrastructure Law. For example, states and local governments can:
Successfully implementing the Inflation Reduction Act and the Bipartisan Infrastructure Law will require coordination and cooperation across all levels of government. Our organizations stand ready to assist with the task at hand. We look forward to meeting with you and your staff to help identify opportunities to increase benefits, connect your staff with grant-writing assistance, support your funding applications, or discuss your investment or synergistic policy plans. Additionally, please take a look at the resources and assistance available through the Local Infrastructure Hub, including a grant application bootcamp for small- to medium-sized cities. (localinfrastructure.org) We look forward to working with you to maximize the benefits of this unprecedented investment in the future of our region. To Members of the Salt River Project Board and SRP Management,
Attached please find the People’s Energy Plan to provide clean energy alternatives to the proposed portfolios currently being considered by Salt River Project Agricultural Improvement and Power District (SRP) in your Integrated System Plan (ISP). The proposed portfolios we present are supported by various communities and stakeholders, including those who have signed this letter, who are concerned about a clean energy future for Arizona. Strategen, a consulting firm focused on decarbonizing energy systems, has done the modeling and analysis for the People’s Energy Plan. The People’s Energy Plan presents a comprehensive and detailed resource plan that lays out a roadmap for how SRP can meet its clean energy obligations to SRP ratepayers and stakeholders, as well as the people of Arizona. SRP has the potential today to help Arizona address climate change. The People’s Energy Plan is a culmination of direct feedback from everyday hardworking people, community leaders and stakeholders who have strongly voiced what they would like to see from SRP as the Integrated System Plan moves forward. Unfortunately, SRP has been doubling down on fossil fuels with its efforts to expand the Coolidge Generating Station with 16 additional gas units that would contribute to environmental injustice in the community of Randolph, a proposal to keep the Coronado Generating Station running longer, gas expansions at Agua Fria and Desert Basin, and most recently, proposed gas at Copper Crossing. SRP’s plans to spread out gas turbines to various locations in smaller configurations come at a higher cost for ratepayers and avoids oversight by the Arizona Power Plant and Line Siting Committee and the Arizona Corporation Commission. This is the wrong direction for a utility that indicates it is dedicated to sustainability. The People’s Energy Plan provides a reliable alternative to more gas and continued reliance on coal and finds the following:
Recommendations in the People’s Energy Plan include minimizing investments in new gas, reassessing the retirement dates for coal-fired generating units at Four Corners and Coronado, continuing to support demand side resources, setting more meaningful carbon reduction targets, and exploring the incentives available through the Inflation Reduction Act. We invite SRP leadership and Board members to thoroughly review the People’s Energy Plan and engage with the People’s Energy Plan coalition to ensure that the ISP represents a fair and transparent process that results in the cleanest and most equitable possible path forward for Arizonans. We expect the People’s Energy Plan will be a useful resource that SRP can implement to benefit ratepayers, Arizona communities, and the environment. SRP can and should be a leader among the state’s utilities in developing clean renewable energy, promoting energy efficiency, and integrating further adoption of distributed energy resources. The People’s Energy Plan demonstrates how SRP can achieve these goals and move away from reliance on coal and gas. 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) 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 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.
Arizona Department of Transportation
1655 W. Jackson Street Phoenix, AZ 85007 Director Halikowski and ADOT Staff, On behalf of the Arizona Solar Energy Industries Association (AriSEIA), Solar United Neighbors (SUN), and Vote Solar, we write to thank ADOT for crafting and submitting the National Electric Vehicle Infrastructure (NEVI) Formula Program plan for Arizona. Our organizations would like to express our enthusiastic support for the NEVI program. Electrification of the energy sector, including electric vehicles (EVs), is critical to maximize the benefits of clean energy technologies, reduce pollution, and build a more reliable and affordable grid. Each of our organizations have been thoroughly engaged in developing electrification policy. AriSEIA works to develop and support policies that create opportunities to advance Arizona’s economy through solar energy, storage, and electrification. AriSEIA also advocates for sustainable job creation and encourages utilization of Arizona’s greatest natural resource, the sun. SUN represents solar homeowners, many of whom are also electric vehicle owners or enthusiasts, as they endeavor to install rooftop solar. Vote Solar advocates for state policies and programs needed to repower our electric grid with clean energy. Vote Solar is also working to remove regulatory barriers and implement key policies needed to bring solar to scale. We applaud your department for its vision and for seizing this opportunity to secure $76.5 million in funding for Arizona to build out electric vehicle infrastructure in the state. It is critical to develop Electric Vehicle Supply Equipment (EVSE) along interstate corridors over the next five years for Arizona to reach a clean energy future and to promote quality of life for our residents and businesses. Expanding a strategic network of alternative fuel and charging infrastructure and increasing EV accessibility will accelerate the adoption of electric vehicles, making them more convenient, affordable, and reliable for Arizonans. Building out EV infrastructure will result in a number of significant economic and environmental benefits for Arizona. This includes reducing air pollution from the transportation sector, creating new family-sustaining jobs, boosting the economy, and lowering costs at the fuel pump for Arizonans across the state. In sum, we are grateful to see how the NEVI plan will support the building of a resilient, equitable, accessible, and reliable charging network for Arizonans. Going forward, we provide the following recommendations for ADOT’s consideration to improve the affordability and accessibility of Arizona's transition to clean energy vehicles. The growth of EV charging infrastructure will increase electricity usage, and so it is important to simultaneously invest in distributed energy resources in order to mitigate the need to build additional energy infrastructure. Investments in locally sited solar and storage not only contribute to meeting local energy needs, but improve the resiliency of the grid. It is important that ADOT encourages EVSE owners to set price structures that incentivize the charging of vehicles during off-peak hours. Charging during times when electricity is less expensive will reduce overall costs. We would like to see ADOT require EVSE owners to establish a communication system that allows drivers to opt-in and notify the EVSE owner when a system is down so that issues can be fixed with little to no delay. Lastly, ADOT should prioritize the needs of current EV drivers and traditionally underserved communities when making decisions about where EVSE should be sited. We encourage ADOT to continue engaging stakeholders and the public in regular conversations and outreach available in both English and Spanish throughout the implementation of the plan. Now more than ever, Arizona should take significant steps to capitalize on the momentum behind the growth of electric vehicles. Each of our organizations are eager to see the swift implementation of ADOT’s NEVI Plan. Sincerely, Autumn 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 Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Response to Chairwoman Marquez Peterson’s Letter Dated August 23, 2022 - Community Solar (Docket No. E-00000A-22-0103) & (Docket No. E-01345A-21-0240) Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. The signatories are filing this letter in response to Chairwoman Marquez Peterson’s letter dated August 23, 2022 which posed questions about thirteen models she requested be compared to community solar. As requested in the Chairwoman’s letter, attached as Appendix A is a matrix that provides an analysis of the models referenced. As explained more fully below, most models described in the letter are not community solar and are not models the signatories are recommending for Arizona. Some of the models describe existing tariffs or programs and others describe hypothetical models that, as far as we know, have not been implemented elsewhere, making direct comparison challenging. While the signatories do not recommend adoption of the models referenced in the matrix, the signatories desire to assist Staff and other stakeholders in their review of the models. It is important to note that 22 other states have already implemented community solar programs, and there is substantial precedent for how community solar programs work and experience with the models they follow. The underlying structure of community solar programs across the country is largely the same, and is consistent with the signatories’ program proposal filed on August 26, 2022 (henceforth referred to as “Signatories’ Proposal”). There are, of course, variations among existing programs which were achieved via policy making and/or regulatory decisions. The Signatories’ Proposal relies on common components of community solar programs around the country and has been tailored to Arizona and can be implemented within the existing regulatory framework. Because there is substantial precedent for how community solar programs work across the country, we do not believe it is necessary to complete an exhaustive review of each of the thirteen models referenced in the Chairwoman’s letter beyond what is provided in Appendix A. Below, the signatories have answered, in greater detail, the seventeen questions posed in the Chairwoman’ letter relative to the Signatories’ Proposal. As requested in the Chairwoman’s letter, the signatories seek to narrow the focus of the Commission’s research of how a community solar program fits within the existing regulatory and ratemaking framework in Arizona by reiterating the signatories’ preferred community solar model, filed on August 26, 2022 (henceforth referred to as “Signatories’ Proposal” and noted as item 4 below). The signatories have made four filings to provide the Commission with detailed information on community solar program implementation in Arizona and how the preferred model would work. These filings include:
The signatories will be filing additional information to further supplement the Signatories’ Proposal to address topics discussed at the working group meetings held on August 30 & 31, including a bill credit rate proposal. The Signatories’ Proposal will provide substantial benefits and consumer protections for customers. Please see below for answers to the questions posed by the Chairwoman relative to the Signatories’ Proposal... Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Standardized Contract, Agreement, and/or Tariff for Community Solar (Docket No. E-00000A-22-0103) & (Docket No. E-01345A-21-0240) Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to docketing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. At the working group meetings held on August 30 & 31, 2022, there was discussion of whether a contract, agreement, and/or tariff would exist between a community solar developer and the utility to which a community solar project is interconnected beyond a standard interconnection agreement. Further, there was discussion of whether such contract, agreement, and/or tariff would be subject to negotiation for each project or standardized. At the working group meetings, representatives of the signatories to this letter stated that there would be a contract, agreement, and/or tariff to govern the interactions between the community solar developer and the utility to which a community solar project is interconnected. The representatives of the signatories also stated that the contract, agreement, and/or tariff would be standardized such that it would not be subject to negotiation for each project, thus eliminating any concerns about taking up time and resources to execute. The signatories committed to filing standardized examples from programs in other states that could be used as a template for the community solar program in Arizona. Attached to this letter as Appendix A is the Solar Rewards Community Producer Agreement that is used by Xcel Energy in Colorado. Attached to this letter as Appendix B is the Standard Contract for Solar Rewards Community that is used by Xcel Energy in Minnesota. The signatories have previously referenced certain components of the community solar programs in Colorado and Minnesota because each state has a mature community solar program. The Colorado example in Appendix A is a standardized contract which exists outside of the utilities tariff as a program document. The Minnesota example in Appendix B is also a standardized contract, however it exists within the utilities electric tariff. The standardized examples attached to this letter will need to be edited to reflect Arizona-specific program requirements We appreciate the opportunity to address these important issues. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Resource Comparison Proxy Proposal for Community Solar (RCP-CS) (Docket No. E-00000A-22-0103) & (Docket No. E-01345A-21-0240) Madam Chair, Commissioners, Commission Staff, and Interested Stakeholders, The signatories to this letter — a coalition of solar and storage industry partners, including developers, subscriber acquisition and management firms, and advocacy groups — appreciate the Commission and Staff conducting the working group meetings regarding the implementation of a community solar program in Arizona. We believe that a properly constructed community solar program will provide bill savings to electric utility customers, promote electric grid resiliency, and assist Arizona in its transition to clean energy. We are committed to providing information that will assist in the Commission’s consideration of a proposal for implementation and we look forward to continued participation and discussion in the working group sessions. At the working group meetings held on August 30 & 31, 2022, the signatories made a verbal proposal on the bill credit rate for the community solar program in Arizona. As requested by one of the Commissioner’s offices, the signatories are submitting this letter with the written details of that proposal. As background, the Commission previously approved the Resource Comparison Proxy (RCP) as the compensation mechanism for rooftop solar projects in Arizona. The signatories suggest that the Commission use the current RCP rate for Arizona Public Service (APS) as the initial bill credit rate for the community solar program with two required modifications, discussed herein and summarized in Appendix A. These modifications to the administration of the RCP are required because of the unique characteristics that community solar projects bring to customers and the grid in Arizona. Hereinafter, we refer to this proposal as RCP-CS. The RCP-CS proposal below is consistent with the Commission Order that initiated this proceeding. Specifically, the Order stated that the program should be “...designed to attract long-term private sector investment” and that “[d]irect bill offsets may be considered for subscribers to produce savings in a structure substantially similar to that offered to rooftop solar customers, eliminating the need for incentives. The value proposition for subscribers should be similar to those participating in onsite generation.” The Commission did not order that the bill credit rate mechanism for community solar should be exactly the same as the existing RCP, rather the value proposition should be “substantially similar.” As such, the RCP-CS proposal recognizes the fundamental dynamics of implementing a successful community solar program in Arizona while using the existing RCP as a starting point to simplify the initial bill credit setting process. The signatories offer the RCP-CS proposal below:
The study prepared by The Brattle Group and filed by the signatories on August 26, 2022 supports this RCP-CS proposal. The Brattle analysis suggests that the value of community solar is at least, if not higher than, the current value of APS’ RCP. The Brattle analysis found the value stack of community solar to be approximately $0.09683 per kWh (compared to APS’ current RCP of $0.08465 per kWh). Therefore, the Brattle study findings support the reasonableness of locking-in the bill credit rate at the current level of the RCP during the Stability Period. Further, the Brattle study supports the removal of the component of the existing RCP that allows rates to decline by a maximum of ten percent (10%) year over year because the study shows the value of community solar increasing in the future. The signatories propose that the RCP-CS rate include a Stability Period to allow critical time for the community solar program to be implemented successfully. The Stability Period is a necessary component of the proposal as it will take time for community solar projects to be constructed and for the Commission to gain experience with the community solar program. Several steps must take place before a community solar project is placed into service, including the following:
While some of the activities mentioned above can occur in parallel, some of them are sequential. The five-year Stability Period will allow critical time for projects to come online with reasonable commercial certainty and for the Commission to gain experience with the community solar program. The Stability Period will also allow for additional time to study the value stack of community solar projects to inform future bill credit rates. It is common in other community solar programs around the country to allow for program parameters that promote predictable program ramp-up through this type of approach. Attached as Appendix A is a table that compares the existing RCP with the proposed RCP-CS, including why the changes above are necessary for a community solar program. We appreciate the opportunity to address these important questions. We look forward to continuing to engage in the working group process to develop a successful community solar program in Arizona. Arizona Corporation Commission
1200 W. Washington Street Phoenix, AZ 85007 RE: Support for SunZia Southwest Transmission Line (Docket No. L-00000YY-15-0318-00171) Chairman and Members of the Line Siting Committee, 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, storage, and electrification. As proponents for fostering a booming solar market, we strongly believe in building clean energy infrastructure, which is a necessary step to further the energy transition. Our state has immense solar potential 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.[1] Building out crucial renewable infrastructure will also serve as an important incentive for developers looking to expand their renewable projects into our state. This line is expected to bring in millions of dollars in direct tax revenue across the entirety of the line. The “direct impacts of the Project’s development in Arizona are estimated to be approximately $585 million.”[2] The project is also expected to add hundreds of new jobs, dozens of which will be permanent. The renewables industry has potential to generate a major boon to our economy. In 2021, the solar industry generated over $33 billion of private investment in the American economy.[3] Offering pathways to boosting the renewables industry is particularly crucial in this moment when supply chain constraints have led to fluctuations in the 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 [1] Lazard, Levelized Cost of Energy, available here https://www.lazard.com/perspective/levelized-cost-of-energy-levelized-cost-of-storage-and-levelized-cost-of-hydrogen/. [2] Moss Adams, SunZia Transmission Project Economic and Fiscal Impacts Analysis, June 23, 2021, page 3. [3] Solar Energy Industries Association (SEIA), Solar Industry Research Data, available here https://www.seia.org/solar-industry-research-data#:~:text=In%202021%2C%20the%20solar%20industry%20generated%20more%20than%20%2433%20billion%20of%20private%20investment%20in%20the%20American%C2%A0economy. |
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