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:  

1. Prioritizing low and moderate income customers, 
2. Ensuring adequate consumer protections, 
3. Eliminating or mitigating any cost-shifts through an appropriately designed bill credit rate, and 
4. Ongoing evaluation of the community solar program to guide longer-term program expansion.  

​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. 

1. The bill credit rate must be increased to appropriately reflect the characteristics of community solar resources, be consistent with Commission Decision 78583, and  ensure robust subscriber participation.
2. Initial program size must be larger than one hundred and forty (140) megawatts (MW) in order to provide meaningful benefits to Arizonans.
3. The bill credit term must be increased to twenty-five (25) years to account for the realities of financing larger distributed generation projects.
4. The low and moderate income (LMI) subscriber carve-out is an important component of the program that must be workable in design and requires more consideration to maximize participation. 
5. The Request for Proposal (RFP) format for selecting projects must be eliminated or at a minimum substantially modified.
6. Utility-scale, transmission-connected projects must be eliminated.
7. Economic curtailment must be eliminated for projects to be financeable and to maximize benefits to subscribers.
8. Program capacity should not be determined in APS’s Integrated Resource Plan (IRP) proceedings. 
9. More types of customers must be eligible for participation to maximize the benefits to Arizonans.
10. The participation of third-party-owned projects vs. utility-owned projects must be considered in more detail. 
11. How the utility disconnection moratorium interfaces with the community solar program must be considered in more detail.
12. Utility approval authority over subscription rates and marketing materials must be eliminated.
13. The two (2) percent fee for consolidated billing and the annual subscriber organization fee must be reduced or clarified.

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.

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: 

1. Save people money by reducing consumption of electricity, gas, and liquid fuel; while increasing penetration of renewable electricity and expanding access to regional electricity markets.
   
2. Create green jobs and grow the workforce, with a particular focus on training new workers for forward-looking careers, and helping workers in legacy fields – such as natural gas and petroleum supply and distribution and combustion vehicle maintenance – to transition to new economically sustainable work opportunities. 
   
3. Reduce climate-changing pollution in line with the United States’ goal to cut net greenhouse gas emissions 50% below 2005 levels by 2030.
   
4. Improve public health by investing in opportunities to cut smog and soot pollution, and by promoting active transportation options including biking and walking.
   
5. Advance equity by targeting programs and investments toward communities that have historically been left behind, or that have been disproportionately burdened with the negative impacts of legacy pollution from industry or highways; and 
   
6. Do no harm. Finally, the state and local governments should avoid spending money on projects that actively increase pollution, increase or extend reliance on fossil fuels including methane gas, waste money, deepen inequities, or impede a just transition for workers – such as widening a highway through a low-income community.
   

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:

• Improve building energy efficiency to increase occupant comfort, save money, and conserve resources. New federal laws include a range of incentives for residential and commercial building owners to invest in building performance upgrades, with a significant portion of the funding going to lower-income households and disadvantaged communities. For example, the Arizona Department of Administration will be responsible for setting up our share of the $4.3 billion HOMES Rebate program, and for allocating new funding for worker training. Local governments can increase the value of this effort by encouraging property owners to plan and carry out building efficiency upgrades and by using new federal funds to support the adoption of modern, high-efficiency building codes.
  

• Accelerate the deployment of efficient electric appliances to help residents and businesses lower their energy bills while also reducing pollution. New federal laws include a variety of incentives and programs for consumers to buy energy-efficient, electric appliances, such as heat pumps for heating and cooling buildings and to supply hot water, and induction stoves for cooking. For example, the Arizona Department of Administration will be responsible for setting up our share of the $4.5 billion High-Efficiency Electric Home Rebate Program, and for allocating new funding to train installers. Local governments can increase the value of this effort by encouraging residents and businesses to choose efficient electric appliances  – and discourage inefficient combustion appliances – through marketing, policy, and/or complementary incentive programs.
  

• Electrify vehicles to save money while also protecting the climate and improving public health. New federal laws contain provisions that will help accelerate the electrification of all vehicles, including light-duty passenger cars; medium- and heavy-duty trucks; and off-road equipment. State and local governments should take advantage of new incentives and funding sources to electrify their fleets, while expanding convenient networks of public and private charging stations, in partnership with electric utilities. Local governments should also pursue funding to electrify transit and school buses, garbage trucks, and other service vehicles; while also encouraging and assisting local fleets in acquiring and deploying electric vehicles (EVs) using the new 30 percent tax credit for commercial EVs and charging equipment. A variety of programs can help fund this work, including existing highway funds such as the Congestion Mitigation and Air Quality and the Surface Transportation Block Grant programs, as well as new dedicated funding sources like the National Electric Vehicle Infrastructure program.
  

• Reduce the need to drive by investing in public transit, biking, and walking. Whether the transportation infrastructure funds in the Bipartisan Infrastructure Law will reduce or increase pollution depends on what states and local governments choose to do with the money. Leaders should prioritize projects that reduce the need to drive, increase safety, and maintain a state of good repair. For example, the Georgetown Climate Center estimates that limiting investment in roadway capacity expansion – which increases driving – could cut transportation pollution by 1.6 percent over the next five years. Because vehicle electrification alone will likely not be sufficient to reach our national, state, and local climate goals, regional planning organizations and city transportation planners should incorporate pollution and vehicle miles traveled reduction targets into their infrastructure investment plans. Additionally, local leaders should invest in opportunities to improve access to clean transportation infrastructure and service for low-income and disproportionately impacted communities.
  

• Build compact, location-efficient cities and towns designed around mixed-use, transit-oriented development, with attention to equity and affordability. Residents of location-efficient neighborhoods can accomplish their daily tasks with less time, money, and pollution. Local governments can enhance the value of new investments in sustainable transportation infrastructure by promoting compact, infill development that enables more people to live close to jobs and services, with convenient access to a variety of transportation choices. Local governments with transportation-efficient land-use plans will have an edge when applying for funding from the new Rebuilding American Infrastructure with Sustainability and Equity and Safe Streets for All programs. States and local governments can also access assistance with planning for transit-oriented development through a pilot program at the Federal Transit Administration.
  

• Increase the supply of clean electricity and energy storage to power our lives without pollution and improve the resiliency of the electric grid to increasing threats from climate change. States and local governments should ensure that utilities are incorporating the upgraded tax credits in the Inflation Reduction Act into their least-cost resource planning – because clean energy is now even cheaper. Further, state and local leaders should promote distributed energy resources such as rooftop and community solar and stationary battery storage – both residential and commercial – taking advantage of newly enhanced federal support. Opportunities are available everywhere across the region. In particular, new federal policy targets funding specifically for rural cooperative electric utilities, agricultural producers and rural small businesses for investments in clean energy and energy efficiency. State and local leaders should encourage and assist their constituents in taking advantage of these opportunities.
  

• Improve the flexibility and efficiency of the power grid to save consumers money and integrate higher levels of clean, renewable power on the grid. New federal laws contain a variety of funds that can help states, cities, electric utilities, and others expand demand response programs and actively manage new, flexible sources of power demand. States and local governments should work with utilities to expand demand response programs and minimize electric system costs. Further, government leaders should work with utilities and business partners to pilot new technologies, such as bi-directional EV charging, to unlock new revenue streams and magnify the benefits of new clean energy investments. 
  

• Identify and invest in grid expansion to support a regional market and to transmit and distribute cheaper electricity throughout the West. New federal policy contains billions of dollars for upgrading our electricity system to carry more clean energy across a larger geography. States and local governments should work with utilities to invest in an electricity grid built for a clean energy future, beyond simply investing in basic maintenance of our current system. New funds can help convene stakeholders for conversations about setting up a regional electricity market, which Advanced Energy Economy estimates would create up to 650,000 jobs and save 11 Western states as much as $2 billion a year on electricity. And new federal policy makes billions available for transmission upgrades to help unlock that potential.
  

• Improve industrial operations to use more clean electricity and less polluting fuels while getting more work done with less energy. New federal laws offer multiple pools of money for factories to upgrade their facilities and equipment, including funding for new technology demonstration projects, technical assistance, clean hydrogen production, low-carbon aviation fuel production, low-carbon cement and building material manufacturing, battery manufacturing and recycling, and carbon capture and storage. State and local leaders should work with industrial businesses to help them take advantage of new funding and expanded markets.
  

• Facilitate a Just Transition to help workers and communities successfully navigate and benefit from progress toward a clean energy future. New federal laws offer billions in funding targeted specifically toward communities experiencing the energy transition first-hand, such as communities that host a coal-fired power plant scheduled to close. For example, the Inflation Reduction Act offers new loan guarantees to help utilities refinance coal assets and re-invest in clean energy technologies. State and local governments should actively work to support workers facing change by facilitating the development of new, accessible economic and job training opportunities. 
  

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:

• A more ambitious 85% carbon emissions reduction target, reducing CO2 by 85% from 2005 levels by 2035, is feasible and can result in additional emissions savings.
• The Coolidge gas plant expansion is not part of a least cost portfolio.
• Retiring and replacing SRP’s coal-fired generating units with clean energy could save SRP customers $620 million and avoid 43 million tons of cumulative CO2 emissions. Even higher savings and reduced emissions are possible with the new federal support that is part of the Inflation Reduction Act.
• SRP's current 2035 sustainability goals don't drive any new incremental emissions reductions and are readily achieved by previously announced coal retirements.

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.

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: 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.